206
Toxic Chemicals
The processing facility uses a lost wax process to cast a wide variety of complex
turbine blades and other critical parts. Using best management practices, the processing facility tracks wasted parts and minimizes waste as much as possible, with the wax
and sludge generated during processing sent to a recycling facility in Pennsylvania.
Management of Howmet discussed the New Jersey DEP P2 program with us and
how the P2 Program could be improved.
The advantages are as follows:
• Preparing a P2 plan helps to detect toxic use reduction opportunities.
• Hazardous waste that is recycled is credited back to the facility when hazardous waste disposal is reported on Form R.
The disadvantages are as follows:
• Because the New Jersey P2 Program is specifically outlined in the New
Jersey law, it is hard to modify and is therefore not flexible for all industries.
• The preparation of a P2 plan requires many hours of labor to complete,
and there are also efforts to fill out duplicate mass balance reports for New
Jersey in addition to multiple Form Rs that contain similar information
under the TRI program.
• The New Jersey P2 program recommends that facilities target for reduction the TRI chemicals that constitute 90 percent of use; however, since
chromium, cobalt, and nickel are in the alloy that makes up the product
of the company, the plan would target these rather than materials used in
production that are much more of a toxic product and should be targeted for
reduction. The superalloy is inert and not an environmental or health threat.
Lower-volume materials like etching solutions should be targeted.
• Therefore, the law has the unintended consequence of targeting the product
of the facility not the toxic chemicals used in its production.
Air Products Polymers, L.P., of Dayton, New Jersey, produces raw materials,
primarily vinyl acetate-ethylene emulsion polymers for high-quality binders used for
packaging, wood bonding/furniture, pressure-sensitive adhesives, wall and ceiling
coverings, flooring, consumer glues, and film laminates.
P2 is part of the corporate culture of Air Products and is implemented voluntarily.
The company makes an effort to reduce the use of toxic materials at the source
by substituting alternative materials to produce products. Air Products also has a
hierarchy for waste minimization, with land disposal at the bottom.
Management of Air Products discussed the New Jersey DEP P2 program with us
and how the P2 program could be improved.
• The managers at Air Products suggested that the New Jersey P2 program
should be more compliance advantageous to industries by providing incentives for those firms that comply with P2 regulations.
• The managers at Air Products noted that larger companies have P2 programs as part of their corporate culture. Smaller-to-midsize facilities
Toxic Chemicals
The processing facility uses a lost wax process to cast a wide variety of complex
turbine blades and other critical parts. Using best management practices, the processing facility tracks wasted parts and minimizes waste as much as possible, with the wax
and sludge generated during processing sent to a recycling facility in Pennsylvania.
Management of Howmet discussed the New Jersey DEP P2 program with us and
how the P2 Program could be improved.
The advantages are as follows:
• Preparing a P2 plan helps to detect toxic use reduction opportunities.
• Hazardous waste that is recycled is credited back to the facility when hazardous waste disposal is reported on Form R.
The disadvantages are as follows:
• Because the New Jersey P2 Program is specifically outlined in the New
Jersey law, it is hard to modify and is therefore not flexible for all industries.
• The preparation of a P2 plan requires many hours of labor to complete,
and there are also efforts to fill out duplicate mass balance reports for New
Jersey in addition to multiple Form Rs that contain similar information
under the TRI program.
• The New Jersey P2 program recommends that facilities target for reduction the TRI chemicals that constitute 90 percent of use; however, since
chromium, cobalt, and nickel are in the alloy that makes up the product
of the company, the plan would target these rather than materials used in
production that are much more of a toxic product and should be targeted for
reduction. The superalloy is inert and not an environmental or health threat.
Lower-volume materials like etching solutions should be targeted.
• Therefore, the law has the unintended consequence of targeting the product
of the facility not the toxic chemicals used in its production.
Air Products Polymers, L.P., of Dayton, New Jersey, produces raw materials,
primarily vinyl acetate-ethylene emulsion polymers for high-quality binders used for
packaging, wood bonding/furniture, pressure-sensitive adhesives, wall and ceiling
coverings, flooring, consumer glues, and film laminates.
P2 is part of the corporate culture of Air Products and is implemented voluntarily.
The company makes an effort to reduce the use of toxic materials at the source
by substituting alternative materials to produce products. Air Products also has a
hierarchy for waste minimization, with land disposal at the bottom.
Management of Air Products discussed the New Jersey DEP P2 program with us
and how the P2 program could be improved.
• The managers at Air Products suggested that the New Jersey P2 program
should be more compliance advantageous to industries by providing incentives for those firms that comply with P2 regulations.
• The managers at Air Products noted that larger companies have P2 programs as part of their corporate culture. Smaller-to-midsize facilities