Performance Track Logo
OMB No. 2010-0032
Expiration Date 08/30/06
2004 Performance Track Annual Performance Report

















Firestone Agricultural Tire Company
A070012
Year 1 Annual Performance Report
Member Since 2001 (2nd Member Term)

























SECTION A: GENERAL FACILITY INFORMATION


Firestone Agricultural Tire Company

Bridgestone Americas Holding, Inc

  Mr. Dain Brandrup
  Utilities/Environmental Engineer
  (515) 243-1211 x 5258
  (515) 237-5695
  brandrupdain@firestoneag.com


  Second Avenue & Hoffman Lane
  
  DesMoines
  IA
  50313

  
  
  
  
  



http://www.firestoneag.com

More than 1,000

326211    

No



No





Section B: ENVIRONMENTAL MANAGEMENT SYSTEM


2004



ISO 14001 Surveillance

Mandatory items, document control, emergency preparedness and response, Cell 2 (tire building, stockcutting, bead building, final), bladder production, waste management, medical department - all ISO 14001 standard elements

  April  2004  

ISO 14001 Surveillance

Mandatory items, Cell 3 (tire building, stockcutting, bead building, curing, final), Powerhouse, waste water and stormwater management - all ISO 14001 standard elements

  October  2004  

2004

Area 1 (Mixing, Tubing, Calenders, Receiving), Area 2 (Stockcutting, Bead Building, Tire Building), Area 3 (Curing, Bladders, Final), Area 4 (Maintenance, ER Shop, Jeep Shop, Machine Shop), Area 5 (Powerhouse), Warehouse & Physical Distribution, IT, Safety & Security, HR, QA, Purchasing, Engineering (General, Process), Environmental Engineering

  December  2004  

2004



Air quality management, water discharges, waste management, chemical review processes, energy managment, facility and grounds issues, emergency preparedness

  December  2004Dan Smidt - FSAG Environmental Engineer

Comprehensive

   July  2004Jesse Hunter - Senior Enviornmental Engineer, Bridgestone Americas Holding Jimmy Kirkland - King & Spalding, LLP


1. NPDES - Iowa Depatment of Natural Resources (IDNR) - 08-02-04 Conducted by Ms. Amy Scott. Scope included 1999-2004 file and DMR review, site assessment and walk through of permitted outfalls and split sampling. The follow-up report gave FSAG a general NOV (no fine) for the following self-monitoring exceedances (from 1999-2004): 6 high pH, 6 TSS (2 from reported spill events) and 5 O&G (3 from reported spill events). The report categorized FSAG's self monitoring as "marginal" and included 3 recommendations for improvement, of which FSAG has completed 2.

2. Air Quality - Polk County Air Quality - 12-16-04 -
Conducted by Mr. Jim McCasland. Scope included a review of excess emissions and countermeasures, draft Title V progress, file review, stack test results and inspection of the carbon black tower area. No items of concern noted.

3. POTW - Des Moines Waste Water Reclamation Authority (WRA) - 12-01-04 - Conducted by Mr. Larry Hare. Scope included a discussion of general waste water issues, process changes, SPCC, new equipment installations (Sonoxide, curing presses), facility cleaning and communications improvements that specifically impacted the facility's zinc discharge, WRA's discharge permit, potential discharge limit changes, FSAG's decreased sanitary flow (due to improved steam and water leak repair) and a plant inspection. No items of concern were noted.

4. US EPA Region VII - NEPT site visit conducted in October 6-8, 2005. Personnel attending from EPA Region VII were Ruben McCullers, Cindy Warner, Dedriel Newsome and Scott Postma and from the IDNR was Charles Geguzis. No major items of concern noted; however many potential small improvements to the EMS were discussed.


1. Document and procedural changes
2. Improved universal waste management
3. Improved operational flexibility via more functional draft Title V permit
4. Improved housekeeping (specifically roof areas w/ augers and compounding and mixing department)
5. Expanded satellite accumulation areas
6. Improved management of condensate associated w/ fuel oil
7. Updated emergency plans
8. Updated waste disposal reference matrix
9. Monitoring well closure


No

Several potential non-compliance and EMS non-conformance items identified during the facility's audits have not yet been corrected. Corrective actions for these items have been outlined and a schedule for completion and implimentation created. However, due to the nature of the corrective actions additional time, capital expenditures or both are required for proper completion of corrective actions.

December  04
Mr.  Joe Ivy
  Director of Manufacturing


Yes

No

October 04




SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS



C.1 COMMITMENT 1



Firestone Agricultural Tire Company's first commitment is to reduce the facility's hazardous materials use, specifically slab lube soap containing glycol ethers (a Form R reportable toxic chemical).

Successfully trialed a replacement for slab lube soap w/o glycol ethers. Cost of replacement is higher than current product. Continuing to evaluate materials for trial, giving preference to no and lower cost alternatives. Final change to be implemented in second quarter 2005.
 
 
2003
2004
2005
2006
Actual Quantity (per year) 198,880 198,880 0 Pounds

Normalizing Factor 1.0 1.0
Normalized Quantity 198,880 198,880.00 n/a Pounds

Adjusted weight and shipout rubber (lbs)






C.2 COMMITMENT 2



Firestone Agricultural Tire Company's second commitment is to reduce the facility's toxic air emissions, specifically hexane, ethylbenzene, and xylene.

Successfully trialed 8 HAP-free replacement striping and marking inks (please note one HAP containing striping ink [brown] will no longer be used). The facility is currently purchasing the HAP-free replacements and using up the remaining inventory of HAP-containing striping and marking inks. Any HAP-containing striping and marking inks will no longer be used after June 30, 2005.

Per US EPA comments this commitment has been changed to a facility wide commitment of reducing the HAP emissions from hexane, ethylbenzene and xylene by 20%. This would mean reducing these emissions by 1.51 tons per year from 7.75 to 6.06 tons per year on a facility wide basis. Please note the baseline year of 2003 actual quantity should now be 7.75 tons.
 
 
2003
2004
2005
2006
Actual Quantity (per year) 7.75 8.55 0.00 Tons

Normalizing Factor 1.0 1.11
Normalized Quantity 7.75 7.70 n/a Tons

Adjusted weight only (lbs)






C.3 COMMITMENT 3



Firestone Agricultural Tire Company's third commitment is to reduce the facility's non-hazardous waste generation, specifically carbon black.

In 2004 the following actions were taken in order to reduce the facility's non-hazardous waste generation of carbon black:

1. Recycled carbon black collected in the facility's dust collectors into numerous rubber mixture formulas as a small percentage work away (Process Engineering department).
2. Made recycling carbon black easier by tying the dust collection work away system directly into the carbon black usage bins (622 dust collector to #10 bin).
3. Eliminated the use of supersacks to collect carbon black in four locations (621 and 622 charge belt and pelletizer dust collectors).
4. Recycled carbon black in supersack bags via the railcar unloading transporters (starting in the fourth quarter).
2003
2004
2005
2006
Landfill 394,800 293,420 Pounds

Total Non Hazardous Waste 197.40 146.71 39.48 Tons


Normalizing Factor 1.0 1.0
Total Non Hazardous Waste 197.40 146.71 n/a Tons

Adjusted weight and shipout rubber (lbs)




C.4 COMMITMENT 4



Firestone Agricultural Tire Company's fourth commitment is to reduce the facility's total (non-transportation) energy use.

This commitment has been met. FSAG completed numerous energy saving projects in 2004 (and prior years) in order to meet this commitment:

1. Insulation projects
2. Compressed air leak repair
3. Steam and water leak repair
4. Equipment removal (non-necessary cooling fans in Dept 426)
5. Consolidate and turn off services for equipment (V-line curing presses)
6. Complete dissolved oxygen study and properly set vent settings for steam fired pressure vessels

1,251,983 1,283,389 MMBtus
1,251,983.00 1,283,389.00
1,379,835 1,129,225 MMBtus
271,040 MMBtus
1,379,835.00 1,400,265.00
45,071.39 46,202.00
2,586,746.61 2,637,452.00
2,631,818.00 2,683,654.00
401,255.45 416,612.84
401,255.45 416,612.84

2,631,818.00 2,683,654.00 n/a
401,255.45 416,612.84 n/a


1.0 1.07
2,631,818.00 2,508,087.85 2,592,340.00 MMBtus
401,255.45 389,357.79 395,236.53 MTCO2E

Production data (i.e. monthly adjusted weight of tires into the warehouse + rubber shipped to other facilities) and Heating/Cooling Degree Days (HDD/CDD)




In the table below, please provide a narrative summary of progress made toward EMS objectives and targets other than those reported as Environmental Performance Commitments. You may limit the summary to environmental aspects that are significant and towards which progress has been made during the reporting year. Do you have additional environmental aspects to report?Yes

(e.g., quantitative or qualitative improvements, activities conducted)

Landfill Disposal Indexed to Production

Exceeded the target of landfilling less than 23.8 pounds of waste per 1,000 pounds of production (actual 19.4 vs. 22.3 in 2003). This was accomplished by the renewed recycling efforts described in C3 and by reducing waste and scrap as generated in individual departments throughout the facility.




Attachments (if applicable) :



SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING


FSAG communicates information regarding our facility, including environmental issues, via many different methods. The following are a few examples of the public outreach completed by FSAG in 2004: 1. Charitable outreach - FSAG salaried and hourly teammates contribute annually to the United Way, Red Cross and Variety Club of Iowa. FSAG also provided volunteers to man the phones during the Variety Club's annual telethon. 2. Civic outreach - FSAG provides facility tours (including information regarding environmental aspects, recycling, etc.) to suppliers, customers, civic groups and schools. Additionally, FSAG staffed an information booth and were sponsors for one day of the 2004 Iowa State Fair. 3. Environmental awards - FSAG was recognized by Bridgestone Americas Holding in 2004 for the following accomplishments: Ted Gaul (Manager, Process Engineering) was awarded the Alva King Environmental Award for Outstanding Environmental Leadership award for career contributions at FSAG including participation and accomplishment of FSAG's commitment to the US EPA's 33/50 program, materials recycling and landfill avoidance projects, beneficial reuse and recycling projects and hazardous air pollutant reductions. The entire FSAG team was also recognized for recycling efforts and energy reduction projects which saved the company over one million dollars and reduced indexed energy usage by 7.2%. Lastly, FSAG personnel Dan Smidt and Dain Brandrup were awarded President's awards during the Bridgestone Firestone North American Tire annual meeting in February 2005 for environmental accomplishments in 2004. These awards were publicized via FSAG's internal newsletter "Tire Tracks" and external press releases. 4. Neighbor relations - FSAG personnel responded to a commerical neighbor's complaints regarding particulate matter on their property in 2004. FSAG was able to open a dialog in order to more readily respond to and prevent future complaints and educate our neighbor regarding FSAG's environmental commitment (NEPT, ISO 14001, P2, etc.). 5. The FSAG Environmental Department conducts outreach and education regarding our involvement in NEPT and commitment to the environment by utilizing the NEPT logo at the top of our letterhead which is used in all communications with community officials, federal, state and local regulatory agencies, neighbors, suppliers, customers and the community at large. By utilizing the NEPT logo FSAG hopes to make others aware of NEPT and that some may investigate the benifits of NEPT membership. 6. FSAG Purchasing and Process Engineering department personnel participated in rebuilding the playground at the Daycare for Exceptional Children in Des Moines. The project included the installation of recycled rubber playground material and new playground equipment.



Web Site
URL: http://www.firestoneag.com/








OMB No. 2010-0032

SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION


The U.S. Environmental Protection Agency is not yet in a position to accept electronic signatures and therefore requests a faxed, signed copy of the Section E page. Please complete Section E online, then print Section E using the link on the Overview page.Section E should be signed by the senior manager of your facility and faxed it to the Performance Track Information Center at (617) 354-0463.

On behalf of Firestone Agricultural Tire Company, I certify that:

  • I have read and agree to the terms and conditions as specified in the National Enviromental Performance Track Program Guide. This facility, to the best of my knowledge, continues to meet all program criteria;

  • I have personally examined and am familiar with the information contained in this Annual Performance Report. The information contained in this report is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete;

  • My facility has an environmental management system (EMS), as defined in the Performance Track EMS criteria, including systems to maintain compliance with all applicable federal, state, tribal, and local environmental requirements, in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program;

  • My facility has conducted an objective assessment of its compliance with all applicable federal, state, tribal, and local environmental requirements; and the facility has corrected all identified instances of potential or actual noncompliance; and

  • Based on the foregoing compliance assessments and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable federal, state, tribal, and local environmental requirements.

I agree that EPA's decision whether to accept participants into or remove them from the National Environment Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision.

I am the senior manager with responsibility for the facility and am fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is part of the National Environmental Performance Track program.

______________________________________________________
Mr. Joe Ivy
Director of Manufacturing
(515) 243-1211 x5620
ivyjoe@firestoneag.com
Firestone Agricultural Tire Company
Second Avenue & Hoffman Lane
DesMoines, IA 50313

,
A070012