CAPACCIO reviewed this client’s, the country’s largest branded dairy operator, threshold determination calculations for RY 2005 to determine which EPCRA 313 / TURA chemicals triggered thresholds. CAPACCIO recommended that the client put together a spreadsheet for all chemicals used in 2005 for these calculations. CAPACCIO discussed “manufactured byproducts” with a employee knowledgeable with the process.

CAPACCIO reviewed four Form R reports for the reporting year completed by the client. The Form R report included general facility information as well as chemical specific information. CAPACCIO assisted with the calculation of emissions to all environmental media (i.e., land, water, air, off-site transfer) and other required information such as pollution prevention information, maximum quantity stored on-site, and the various uses of the chemicals.

CAPACCIO reviewed four Form S Reports for the reporting year completed by the client. CAPACCIO assisted the client in the review of production units, units of product, review of a process flow diagram developed by the client, calculation of By-product Reduction Indices (BRIs) and Emission Reduction Indices (ERIs) for each production unit, and detailing of source reduction codes for those production units for which the client had achieved source reduction. CAPACCIO also conducted a site visit to better understand the processes at one of the client’s plants.

CAPACCIO reviewed and consolidated existing information relative to pollution prevention, and toxics use reduction activities including materials inventory, SARA / TURA emissions calculations, monitoring data, BRI / ERI calculations, and process flow diagrams. CAPACCIO helped develop a plan by identifying the client’s TUR team members, and preparing a written description of responsibilities, goals, and regulatory requirements for TUR team and conducting a brief TUR overview for the team. Designated TUR Team members were chosen to develop a written TUR mission statement, scope, and objectives.

The client’s TUR Team calculated Production Unit information for each reportable toxic chemical including: by product/unit of product; emissions / unit of product; costs of toxic chemical / unit of product; and detailed process flow diagrams for each production unit. The client developed the process characterization section of the TUR Plan including a description of the production unit and a description of the purpose of each chemical used for the production unit. The client created the flow diagrams and CAPACCIO reviewed the information.

CAPACCIO assisted the client's TUR team to research, identify and screen TUR options applicable to operations and evaluated the technical, economic, social, and regulatory feasibility of options. CAPACCIO developed a TUR option matrix with weighting criteria to screen and select TUR options for implementation. A meeting was held to brainstorm and a second meeting was held to weigh options to determine which options need further evaluation.

CAPACCIO assisted the client's TUR Team in preparing a draft written TUR plan to meet the requirements of 310 CMR 50.40 for sodium hydroxide, acetic acid, nitric acid, nitrate compounds, and sulfuric acid. The plan addressed facility-wide and production unit information, cost of toxics (optional), and a technical and economic evaluation of toxics use reduction techniques. CAPACCIO assisted the client's TUR Team in preparing an implementation schedule for selected TUR options, and identifying specific TUR team responsibilities to ensure effective implementation.

Based on TUR Team input, SARA / TURA data, and updates to TUR information database, CAPACCIO assisted the client in finalizing the written TUR plan to meet the requirements of 310 CMR 50.42. CAPACCIO certified the plan and assisted the client's TUR Team in preparing a written plan summary and backup information package for submittal to the MassDEP in accordance with the requirements of 310 CMR 50.47.


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