Performance Track Logo
OMB No. 2010-0032
Expiration Date 01/31/2010
2006 Performance Track Annual Performance Report

















DuPont Mt Clemens Plant
A050077
Year 3 Annual Performance Report
Member Since 2004 (1st Member Term)

























SECTION A: GENERAL FACILITY INFORMATION


DuPont Mt Clemens Plant

 
E.I. Du Pont de Nemours and Company, Inc.

  Ms. Denise Trabbic-Pointer, CHMM
  Health and Environmental Coordinator
  (586) 468-9087
  (586) 468-9085
  denise.trabbic-pointer@usa.dupont.com


  400 Groesbeck Hwy
  
  Mt Clemens
  MI
  48043

  
  
  
  
  



http://www.dupont.com

500-1,000

325510 325211   

Yes

In July 2006 the Facility R&D organization was expanded to include R&D of all OEM Paint products. Previously the Facility only performed R&D work for electrocoat products. This increased our work force by about 150 people. We also increased the number and activity of site paint testing spraybooths. All spraybooths were converted from "wet" to "dry" filtration in this process.

Yes

The site became subject to SPCC rules as a relsult of the change in the definition of "oil".

The site applied for and received a synthetic minor air permit for hazardous air pollutants and rolled all provisions into the facility Title V permit.



Section B: ENVIRONMENTAL MANAGEMENT SYSTEM



2006



ISO14001 Surveillance audit

The entire DuPont Automotive Systems (DAS) Business EMS plus: Manufacturing filling floors, resin, R&D Spraybooths & ovens, Maintenance & Power House, Waste Mgt. & Solvent Recovery

The entire EMS consists of the following:

Env. Records
Compliance Evaluation
Management of Change
Emergency Planning
Calibration
Document/Data Control
Spill Control & Drainage
Contractor Management
Manual & Documentation
Training

  May  2006  

2006

Environmental Policy
Environmental Aspects
Legal and Other Requirements
Objectives. Targets and programmes
Resources, roles, responsibility and authority
Competence, training and awareness
Communication
Documentation
Control of documents
Operational Control
Emergency preparedness and response
Monitoring and measurement
Evaluation of compliance
Nonconformity, corrective action and preventive action
Control of records
Internal Audit
Management Review
Training

Paint Manufacturing and R&D Laboratories; Waste Manifests and Waste Handling

  August  2006  


2004

October 2007



Improved communication with employees on how to electronically access written procedures, give periodic updates to employees on the status of annual Obecjtives & Targets, and better communicated the Environmental Policy to contract employees. Reinstituted effectiveness audits (job cycle checks) in areas where they had not been consistently performed. Assured that all magenehelic gauges associated with site spray booths were included in a preventive maintenance program for regular calibration. Identified and controlled all external documents as required by the ISO14001:2004 standard. Improved the root cause analysis and effectiveness of corrective actions in response to environmental incidents. Created a formal process for following up and closing items resulting from emergency services response critiques.

Yes



September  06
Mr.  Stephen Cox
  DAS Business Director
Yes

No

January 07




SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS



C.1 COMMITMENT 1



DuPont Mt Clemens Plant's first commitment is to reduce the facility's generation of hazardous waste.

The site has acheived a 16 % normalized reduction of hazardous waste between baseline year 2003 and end-ofyear 2006. There was, however an increase of normalized waste in 2006 versus 2005. The DuPont Automotive Systems Business made a decision in May of 2006 to close the Troy Laboratory facility and to move those operations to the Mt Clemens site. This move required that the Mt Clemens site make room for Troy R&D operations and associated small package stock. This entailed the expedited disposal of raw material, intermediate and finished product stock. Much of these waste materials were unusable and/or unpumpable and therefore reuse or sale was not an option. This was cause for increased generation of hazardous waste in 2006. This was a one time setback and renewed efforts are ongoing to hold the gains from previous years.

Issues continued with our on-site solvent recovery system in 2005. However, reduction of hazardous waste was still achieved. Reductions were achieved primarily by changes in manufacturing to more "semi-continuous" processes thereby reducing vessel cleaning and tank clingage. Other efforts included putting materials back into processes and improved campaigning of colors per equipment. All solvent recovery system maintenance items have been resolved as of January 2006 and more aggresive reduction goals have been set for 2006.


For the first time in 5 years, the Plant did not achieve the targetd goal for reduction of hazardous waste generation. The primary reason for not realizing the goal has been issues with the operation of our on-site solvent recovery system that required us to send the spent solvent for off-site recovery. We generally sell our still bottoms from solvent recovery for beneficial reuse and the reclaim facility does not. Therefore, those waste numbers added to our 2004 hazardous waste generation numbers.
2003
2004
2005
2006
Incineration 1,536,714 1,088,512 1,071,486 1,564,221 Pounds
Other management

 Fuel Blending
1,998,000 2,474,230 667,420 1,181,965 Pounds
Other management

 Reused/recycled off-site
1,048,000 921,046 1,001,298 829,708 Pounds

Total Hazardous Waste 2,291.36 2,241.89 1,370.10 1,787.95 n/a Tons


Normalizing Factor 1.0 .97 1.02 .93
Total Hazardous Waste 2,291.36 2,311.23 1,343.24 1,922.52 1,485.00 Tons

total gallons of paint and resin produced


Michigan Business Pollution Prevention Partnership (MBP3)



C.2 COMMITMENT 2



DuPont Mt Clemens Plant's second commitment is to reduce the facility's total (non-transportation) energy use.

The site has acheived a 11 % normalized reduction in overall energy usage and an approximate 6 % reduction in CO2 emissions from the baseline year of 2003 to end-of-year 2006. Reductions in 2006 were acheived by replacement of one of the older, less efficient hot oil heaters and continuing efforts to reduce temperature settings inside manufacturing buildings. Other efforts included installation of more efficient lighting in shipping/receiving warehouses and laboratories turning off panel ovens when not in use. Automatic lighting and replacement of the other two hot oil heaters is being investigated/ planned in 2007.

Efforts continue replacing old and less energy-efficient equipment. Next phase is to replace on-site hot oil system heaters in 2006 (nat gas reduction). All site HV unit temperature/heat settings have been lowered this winter to reduce natural gas usage and all heat trace on piping was shut off during summer months (electric). Other efforts include installation of improved, more efficient lighting in manufacturing areas and programs to reduce steam usage (nat gas reduction).

Natural gas usage is given for total site and all process and non-process related use. Overall reduction for gas consumption is illustrated by the 2004 numbers. Reduction in usage is primarily due to improved maintenance of existing equipment and installation of newer, more efficient equipment. Examples of electrical usage reduction efforts include installation of new air compressor units in the site powerhouse and repair of hot-spots in electrical control units. Site is also retro-fitting all facility HV and HVAC units with more efficient heat exchangers, doing this several units each year.

Baseline and commitment data have changed. They currently reflect total energy use.


134,097 129,320 127,955 123,835 MMBtus
0 MMBtus
134,097.00 129,320.00 127,955.00 123,835.00 MMBtus

ECAR Michigan


EPA will be determining the greenhouse gases associated with the generation of the steam that you purchase. We will be contacting you for additional information regarding the source of the steam generated.
0 0 Btus
134,097.00 129,320.00 127,955.00 123,835.00

363,083 329,588 323,755 286,318 MMBtus
363,083.00 329,588.00 323,755.00 286,318.00

2,869.68 2,767.45 2,738.24 2,650.07 n/a
494,310.32 456,140.55 448,971.76 407,502.93 n/a
497,180.00 458,908.00 451,710.00 410,153.00 n/a
48,291.64 45,483.59 44,878.95 42,004.84 n/a
0 0
48,291.64 45,483.59 44,878.95 42,004.84 n/a


1.0 0.97 1.02 0.93
497,180.00 473,101.03 442,852.94 441,024.73 421,099.00 MMBtus
48,291.64 46,890.30 43,998.97 45,166.49 42,507.51 MTCO2E

total gallons of paint and resin produced




C.3 COMMITMENT 3



DuPont Mt Clemens Plant's third commitment is to reduce the facility's NOx emissions.

The site has acheived a normalized 27 % reduction in NOX emissions between 2003 and year-end 2006 and a 9 % reduction 2005 to 2006. This has primarily been acheived by continual improvement of preventive maintenance and improved efficiency of new gas-burning equipment. Further evidence of improved combustion in this type equipment has been reduced incidents of products of combustion inside buildings where direct- fired HV units are installed and by evidence of reduced soot on the outside of HV unit stacks. Other significant projects that positively impacted this effort include replacement of one hot oil heater and a new steam generator.

The DuPont corporate and Mt Clemens site commitment continues to be to keep energy uses flat and to reduce NOx emission. The primary method for NOx reduction continues to be attention to reduced natural gas usage, purchase of more efficient equipment and improved maintenance of existing equipment.

Reduction of Natural Gas usage and associated NOx reduction was achieved primarily through improved preventive maintenance of gas-consuming heating and process equipment and through installation of newer/more efficient equipment. A 50 degree F reduction in the temperature of the manufacturing area thermal oxidizer also contributed to the reduced gas usage. The thermal oxidizer temperature change remains within permit-required limits.

 
 
2003
2004
2005
2006
Actual Quantity (per year) 2.2 1.8 1.8 1.5 n/a Tons

Normalizing Factor 1.0 0.97 1.02 .93
Normalized Quantity 2.2 1.86 1.76 1.61 1.8 Tons

total gallons of paint and resin produced






C.4 COMMITMENT 4



DuPont Mt Clemens Plant's fourth commitment is to reduce the facility's VOC emissions, specifically xylene, methyl ethyl ketone, methyl isobutyl ketone, toluene, methanol, and ethylbenzene.

The facility has achieved a normalized 29 % reduction of the listed HAPs in 2006 versus baseline year 2003 and a 21 % reduction 2006 over 2005. This assessed reduction has been adjusted to remove methyl ethyl ketone in year 2003 as it has since been removed from the HAP list. The DuPont Mt Clemens site is now a synthetic minor for HAP and expects that HAP emissions will ultimately normalize at < 16 tons per year. This reduction as been acheived by replacement of hazardous air pollutants with less toxic materials and by installation of a condensation control devise on the facility cathodic resin manufacturing systems.

Efforts continue to reduce HAP emissions through reformulations. A project to install abatemement equipment on resin operations and completion of all finished product reformulations will be completed by July 2006. New site synthetic minor permit 158-05 takes affect 11/1/06 and total HAP emissions will remain below 22 tons/year per this commitment.

Note: The baseline quantity was changed from 36 tons to 30.3 tons in order to be consistent with what was reported (three months later) to the Toxic Release Inventory. At the time of the application to Performance Track (due April 1), measurements for TRI (due July 1) had not yet been completed. The quantity for the Performance Track report was calculated in April, but then more precisely refined between April and June. Specifically, speciation of total VOC to individual emission components, including the listed hazardous air pollutants was better defined for the July TRI report.

VOC reduction efforts inlude re-formulation to non-HAP solvents and increased usage of continuous-process primer manufacturing versus batch process. The increased use of the continuous process equipment has allowed the Plant to place more intermediate product into process flow-through tanks instead of into drums thereby further reducing emissions to the air. This also has improved/reduced employee exposure.

 
 
2003
2004
2005
2006
Actual Quantity (per year) 30.3 30.2 27.6 19.9 n/a Tons

Normalizing Factor 1.0 0.97 1.02 0.93
Normalized Quantity 30.3 31.13 27.06 21.40 22 Tons

total gallons of paint and resin produced







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)
Reduce sitewide VOC by 15% over year 2005. Normalized/actual reduction was about 10% in sitewide VOC emissions. This was achieved even though all Troy Lab R&D activities were moved to the Mt Clemens facility in July 2006. Adding R&D activities to the facility included an increase of about 150 people and installation of several new paint-testing spraybooths.
Meet equivalency to emergency venting requirements per timetable as agreed to by MDEQ Storage Tank Division The DuPont Mt Clemens facility was built to 1966 standards and the exisitng resin storage tanks did not have emergency vents as required by NFPA and MDEQ. The way the facility and the tanks were built made it impossible to retrofit the storage tanks with required emergency venting. The facility worked with the MDEQ and resolved to install a firefighting foam system and other upgrades to the facility that were equivalent in making the storage tank system safe. All agreed-upon upgrades were completed and the system tested in 2006.
No significant SHE incidents or spills to the environment during integration of Troy site activities; all written programs related to EMS maintained up-to-date; all regulatory projects completed in timely manner; No major non-conformance from ISO audits All wet spraybooths were converted to dry-filter, all existing laboratories were upgraded and new labs installed. A new downdraft booth was built and > 150 people brought from Troy Lab to the Mt Clemens facility. All of this was completed without incident or adverse impact to the environment and/or the site EMS.
Improve timely PM on all environmental critical equipment by 75%. An approximate 50 % improvement in completion of preventive maintenance to environmental critical equipment was acheived in 2006 over 2005. Environmental critical equipment is defined as equipment that is either regulated (e.g. by RCRA, air permit or water discharge permit) or that, if it fails, an environmental incident might occur.



Attachments (if applicable) :



SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING



The most common and consistent way that the DuPont Mt Clemens site interacts with the community is by working closely with local fire departments. The site continues to conduct annual drills and joint training with several local fire departments each year. These joint training sessions are generally conducted at the DuPont facility and mutually benefit DuPont and local response personnel.

The DuPont Mt Clemens Plant also cooperated with several graduate students from at the University of Maryland in an effort to improve the environmental management system at our facility. A professor/doctor at the University had found our site in the Performance Track system and asked us if we would be willing to work with the students in a program that would mutually benefit us and them. Specifically, their request was to "assess the environmental management system (EMS) at [our] opertating facility and make recommendations for improvement". We worked with the distance-learning students from across the country, derived an assignment for them, provided them with necessary information and they assisted us by completing the assignment. The specific assignment that the students completed was to provide us with a system and checklists that anyone could use to audit our EMS against applicable regulatory requirements. The checklist that they put together is now a tool that we will use to internally audit the efficacy of our EMS in respect to compliance with Legal and Other Requirements. The audit checklist is comprehensive and will also be useful during 2nd and 3rd party audits.



Meetings








OMB No. 2010-0032

SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION FOR ANNUAL PERFORMANCE REPORT


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 DuPont Mt Clemens Plant, 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. Gregory Martz
Plant Manager
(586) 468-9001
gregory.a.martz@usa.dupont.com
DuPont Mt Clemens Plant
400 Groesbeck Hwy
Mt Clemens, MI 48043

,
A050077