TRI Pollution Prevention Report for AAR MOBILITY SYSTEMS and Lead

Facility ID: 49601RBRKS201HA

Facility Name and Address:
AAR MOBILITY SYSTEMS
201 HAYNES ST
CADILLAC, MI 49601

Parent Company: AAR CORP

Industry: Prefabricated Metal Building and Component Manufacturing (332311)
Chemical: Lead

Production Related Waste Management for Selected Chemical


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    Waste Management Comparison - 2020



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 Source Reduction:: S11: Reformulated or developed new product line[-50-99%]
Methods to Identify SR Opportunities: T11: Other
S11: Pallet Production is decreasing and demand for pallet refurbishing is decreasing.

Source Reduction - New pallet design is replacing the former balsa pallet.
2021 Source Reduction:: S35: Other improvements to inventory and material management[-5-14%]
Methods to Identify SR Opportunities: T11: Other
S35: Increased pallet production from 2020 to 2021 increased. Refurbishing pallets also increased. The increased pallet production and increased refurbishing of used pallets increased aluminum usage and recycling of aluminum recycled and sent off site.

Source Reduction - 2022 pallet production is expected to decrease over the next 1-3 years which should decrease aluminum usage and amount of aluminum recycled and sent off site.
2020 Source Reduction:: W89: Other product modifications[-100%]

Methods to Identify SR Opportunities: T11: Other
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Barriers: B7-Barriers to P2 B7 - No known substitutes or alternative technologies.
W89: AAR may see production throughputs for aluminum go down which would impact the amount of aluminum that would be recycled and reclaimed which would impact the amount of lead in aluminum recycled.

Source Reduction - AAR may see production throughputs for aluminum go down which would impact the amount of aluminum that would be recycled and reclaimed which would impact the amount of lead in aluminum recycled.
Source Reduction - Industrial Pre-Treatment permit sampling in 2020 all monthly analysis discharge reports lead was non-detect. Keeping lead from being discharged in the Tanks process will keep the lead out of the discharge to the POTW
Other Environmental Practices - Keeping lead from being discharged in the Tanks process will keep the lead out of the discharge to the POTW



Other Environmental Practices: General Environmental Management - Provide environmental management in the Tanks process by cleaning sludges out of the processing tanks to keep lead out of the Tanks discharge.

Barriers to P2: B7 - No known substitutes or alternative technologies. - Tanks process etches aluminum, which is a source of lead in the IPP discharge analysis. AAR can not substitute aluminum for the articles currently being manufactured.

2019 Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible
Barriers: B7-Barriers to P2 B7 - No known substitutes or alternative technologies.

Barriers to P2: B7 - No known substitutes or alternative technologies. - Lead is discharged to the Clam River via wastewater discharge under an IPP permit to the City of Cadillac POTW. The lead comes from PII Etch process in the Tanks Department.

Barriers to P2: B8 - A reduction does not appear to be technically feasible - Lead is discharged to the Clam River via wastewater discharge under an IPP permit to the City of Cadillac POTW. The lead comes from PII Etch process in the Tanks Department at this time it is not technically feasible to eliminate lead from the Tanks discharge.

2018 Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible
Other Environmental Practices - Machine shop introduces aluminum shavings into the Etch and rinse tank processes. Additional cleaning of machined parts could reduce meatal shavings into the Etch process which may reduce soluble metals leaching into the effluent.



Other Environmental Practices: General Environmental Management - Facility utilizes sand filtration to polish and clean rinse tank effluent. Current filter changes are not a routine change out schedule. Implement an annual filter media change out could reduce metal discharges.

Barriers to P2: B8 - A reduction does not appear to be technically feasible - Installing additional chemical or mechanical treatment for metals prior to discharge from the process to the POTW could be explored, but may not be feasible.

2016
Source Reduction: Source Reduction - Production demands from customers are reduced and the trend is expected to continue

2015 Source Reduction:: W19: Other changes in operating practices[-0-4%]
Methods to Identify SR Opportunities: T11: Other
Source Reduction - Production reduced due to customer demand
2014 Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers
Methods to Identify SR Opportunities: T04: Participative team management
Source Reduction - LEAN Manufactruing has been implemented and Teams are internally tracking material usages.
2010 Source Reduction:: W41: Increased purity or raw materials
Methods to Identify SR Opportunities: T10: Vendor assistance
*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:
Facilities may also provide optional Pollution Prevention Information describing their source reduction, recycling, or pollution control activities.