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.
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.
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
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
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.
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.
total gallons of paint and resin produced
Michigan Business Pollution Prevention Partnership (MBP3)
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.
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.
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.