TRI Pollution Prevention Report for ASH STEVENS and Toluene

Facility ID: 48192SHSTV18655

Facility Name and Address:
ASH STEVENS
18655 KRAUSE ST
RIVERVIEW, MI 48193

Parent Company: PEL PHARMA INC

Industry: Pharmaceutical Preparation Manufacturing (325412)
Chemical: Toluene

Production Related Waste Management for Selected Chemical

lchemid=0000108883

Waste Management Comparison - 2021

Pollution Prevention Activities for Selected Chemical

Reporting Year	Section 8.10: Newly Implemented Source Reduction Activity	Section 8.10: Methods to Identify Activity	Section 8.11: Optional Pollution Prevention Information*
2022			Other Environmental Practices: Recycling - Facility does not have enough space for recycling. Source Reduction: Source Reduction - Process is designed to use the least possible amount of material.
2021		Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible	Barriers to P2: B8 - A reduction does not appear to be technically feasible - The process is designed to use the minimum amount of material possible.
2020		Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible	Source Reduction: Ways P2 Was Incorporated in Original Process Design - The process is designed to use the minimal amount of material Barriers to P2: B8 - A reduction does not appear to be technically feasible - The process is designed to use the minimum amount of material possible
2019		Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible	Source Reduction: Ways P2 Was Incorporated in Original Process Design - Process is designed to use the minimum amount of material possible. Barriers to P2: B8 - A reduction does not appear to be technically feasible - Process is designed to minimize material use.
2018		Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible	Source Reduction: Ways P2 Was Incorporated in Original Process Design - Process is designed to use the minimum amount of material possible. Barriers to P2: B8 - A reduction does not appear to be technically feasible - Process is designed to minimize material use.
2013	Source Reduction:: W50: Optimized reaction conditions or otherwise increased efficiency of synthesis	Methods to Identify SR Opportunities: T04: Participative team management

*Classifications of Optional Pollution Prevention Information shown in brackets are provided by EPA.

TRI Pollution Prevention Glossary

The Waste Management Hierarchy

The waste management hierarchy established by the Pollution Prevention Act (PPA) guides waste generators toward the best options for managing wastes. The preferred option is to prevent pollution at its source, but for waste that is generated, the preferred management methods are recycling, followed by burning for energy recovery, treatment and, as a last resort, disposing of the waste.

Source Reduction includes activities that eliminate or reduce the generation of chemical waste.
Recycling includes the recovery of a toxic chemical in waste for reuse.
Energy Recovery includes the combustion of toxic chemicals in waste to generate heat or electricity.
Treatment includes the destruction of a toxic chemical in waste.
Disposal or Other Releases includes toxic chemical quantities entering the environment.

The PPA requires facilities to provide the following details about each chemical they report to TRI:

A breakdown of production-related waste managed. This includes all amounts of the chemical released directly to the environment or otherwise managed as waste, other than waste generated by one-time events not associated with normal production processes (e.g., fires or remedial actions).
A production ratio or activity index to provide context for reported toxic chemical quantities. For example, if a chemical is used in the manufacture of refrigerators, the production index would track the number of refrigerators produced and could be used to help gauge how much of the chemical is being released per unit of production.
Any newly implemented source reduction activities, reported using "W-codes" (e.g., "W41: Increased purity of raw materials")

Facilities may also provide optional Pollution Prevention Information describing their source reduction, recycling, or pollution control activities.