TRI Pollution Prevention Report for CS WIND AMERICA and Xylene (mixed isomers)

Facility ID: 8100WVSTST1TWER

Facility Name and Address:
CS WIND AMERICA
100 TOWER ROAD
PUEBLO, CO 81004

Parent Company: CS WIND AMERICA

Industry: Fabricated Structural Metal Manufacturing (332312)
Chemical: Xylene (mixed isomers)

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:: S14: Other product modifications made[-5-14%]


Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Methods to Identify SR Opportunities: T04: Participative team management
Methods to Identify SR Opportunities: T10: Vendor assistance
S14: In 2023, CS WIND is evaluating ways to improve its waste reclamation process and capture more paint from the process. This will eliminate waste paint which includes raw paint material as well as solvents used in the cleaning process thereby reducing the amount of toxic chemicals being generated and disposed of

Source Reduction - Looking for opportunities to recycle/reclaim material rather than have it disposed of
Source Reduction - Integrating other departments for feedback with respects to substituting toxic chemicals and moving towards non-hazardous constituents without impacting the quality of our product
Source Reduction - Using applicable stakeholder from: engineering, production and HSE we are evaluating improved process opportunities to use more paint prior to it settling and becoming a waste

Source Reduction: Source Reduction - Evaluating various methods and improvements for tracking and reporting which will help us to gauge our waste as a percent of raw materials

2020 Source Reduction:: W36: Implemented inspection or monitoring program of potential spill or leak sources
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
W36: Dedicated day shift and night shift paint pump technicians to ensure pumps are operating effectively and not leaking. Also on site to ensure if there is a leak, it is stopped immediately.

2019
Other Environmental Practices: General Environmental Management - HSE is continually searching for ways to reduce waste and consumption (where applicable)

2018 Source Reduction:: W19: Other changes in operating practices[-0-4%]

Methods to Identify SR Opportunities: T04: Participative team management
Methods to Identify SR Opportunities: T11: Other
W19: Modifications to the paint spray system to improve transfer efficiency and reduce the amount of consumption and waste. Major reductions in the amount of bypass time used which lessened the amount of emissions through point source discharges.

Source Reduction - Logging of paint consumption and review of trends concerning paint data.
Source Reduction - Surface Treatment Manager requested participation from all applicable stakeholders to devise new ways of improving transfer efficiency and reducing waste

Other Environmental Practices: General Environmental Management - HSE is continually searching for ways to reduce waste and consumption (where applicable).

2017 Source Reduction:: W19: Other changes in operating practices[-0-4%]

Methods to Identify SR Opportunities: T04: Participative team management
Methods to Identify SR Opportunities: T11: Other
W19: Modifications to the paint spray system to improve transfer efficiency and reduce the amount of consumption and waste. Major reductions in the amount of bypass time used which lessened the amount of emissions through point source discharges.

Source Reduction - Surface Treatment Manager requested participation from all applicable stakeholders to devise new ways of improving transfer efficiency and reducing waste
Source Reduction - logging of paint consumption and review of trends concerning paint data

Other Environmental Practices: General Environmental Management - HSE is continually searching for ways to reduce waste and consumption (where applicable). We are going to have a a Kaizen event that will help operators search for ways to find and address waste, as well as, how leaders can invest in their people to drive changes

2016 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures[-0-4%]

Methods to Identify SR Opportunities: T04: Participative team management
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
W13: Better oversight from management to ensure operators are not wasting paint product. Line walks and waste metrics will help us to gauge how much paint is wasted and being expended over the necessary amounts.

Source Reduction - Vigilant oversight from QSE
Source Reduction - Managers should train floormen in procedures that will help them to monitor waste generation.
2015 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2014 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures

Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
Methods to Identify SR Opportunities: T10: Vendor assistance
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2013 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures

Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
Methods to Identify SR Opportunities: T10: Vendor assistance
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2012 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures
Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2011 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures
Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
W13: improved work proceedures to minimize useage
W14: improved production to minimize cleaning / usage

*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.