E MAMUFAOTJW© INDUSTRY m ------- Definitions The definition of pollution prevention used in this manual includes source reduction, but not recycling, treatment or disposal. This is consistent with the definitions provided in EPA's Pollution Prevention Strategy of January 1991 and Pollution Prevention Act of 1990. The definition from the Pollution Prevention Strategy is as follows: Pollution generated during manufacturing, or when certain products are used commercially or by consumers may be prevented in three ways: • Changing Inputs/Reducing Reliance on Toxic or Hazardous Raw Materials: A Manufacturer may substitute non-toxic for toxic feedstocks in making a product; • Process Changes/Increasing Efficiency/Improved Maintenance Practices: The production process may be altered to reduce the volume of materials released to the environment as toxic or hazardous waste; in addition to avoiding waste management costs, these changes often improve efficiency by reducing raw material losses and conserving water. Process changes may include equipment modifications or less expensive housekeeping measures, as well as in-process, closed loop recycling that returns waste materials directly to production as raw materials; • Changing Outputs/Reducing Reliance on Toxic or Hazardous Products: The manufacturers or users of commercial products may switch to non-toxic or less toxic substitutes. This manual also uses the term waste reduction, which includes both source reduction and recycling, but not treatment or disposal. ------- For More Information Regarding this Manual, Contact: C. Tucker Helmes Executive Director U.S. Operating Committee of ETAD 1330 Connecticut Ave. NW Suite 300 Washington, DC 20036 Tel: 202-659-0060 FAX: 202-659-1699 Jocelyn Woodman U.S. EPA Office of Pollution Prevention 401 M Street SW (PM-222B) Washington, DC 20460 Tel: 202-260-4418 Fax: 202-260-0178 ------- TABLE OF CONTENTS 1.0 Introduction 1 1.1 History of the Program 2 1.2 The Guidance Manual 3 1.3 Measurement and Reporting 3 PART 1 • PROGRAM ADMINISTRATION 5 2.0 Getting Started - Management Commitment and the Program Task Force 5 2.1 Gaining Management Commitment ' 5 2.2 The Role of the Program Task Force 6 3.0 The Role of the Regulatory Affairs Staff < . 13 3.1 Compliance and Documentation 13 3.2 Technology and Information Transfer 13 3.3 Risk and Hazard Assessment 14 PART 2 - PROGRAM IMPLEMENTATION 15 4.0 Production 16 4.1 Raw Material Receiving and Charging/Material Transfer 18 4.2 Synthesis 20 4.3 Isolation/Filtration 21 4.4 Drying 24 4.5 Grinding 26 4.6 Blending 28 4.7 Sample Taking, Weighing 30 4.8 Equipment Cleanout 30 4.9 Packaging 31 5.0 Research and Development 35 5.1 Product Development 35 5.2 Laboratory Practices 38 6.0 Purchasing 42 ------- TABLE OF CONTENTS 7.0 Inventory Control : 45 8.0 Sales/Marketing 48 9.0 Distribution 52 10.0 Finance 54 11.0 Engineering 57 12.0 Utilities 60 Bibliography 63 Appendix A - Waste Reduction Survey Appendix B - Corporate Statement of Policy Appendix C - Waste Assessment Worksheets Appendix D - Weighted Sum Method Appendix E - Evolutionary Operation (EVOP) ------- SCHEMATIC DIAGRAM OF THE POLLUTION PREVENTION GUIDANCE MANUAL FOR THE DYE MANUFACTURING INDUSTRY INTRODUCTION PROGRAM ADMINISTRATION PART 2 PROGRAM IMPLEMENTATION A P P E N D I C E S B WASTE REDUCTION SURVEY OPPORTUNITY ASSESSMENT CASE STUDIES WASTE GEN. DATA CORPORATE STATEMENT OF POLICY WASTE ASSESSMENT WORKSHEETS WEIGHTED SUM METHOD EVOLUTIONARY OPERATION (EVOP) DYE PRODUCTION INFO. SOLID, LIQ., AIR, UTILITY TRI RELEASES ------- POLLUTION PREVENTION GUIDANCE MANUAL FOR THE DYE MANUFACTURING INDUSTRY 1.0 INTRODUCTION Pollution prevention reduces the amount of Pollution Prevention Affects All Aspects of Our Lives waste released to the land, air, and water by minimizing pollution at its source. If the environmental challenges of the 1990's are to be confronted in a cost-effective manner, pollution prevention should be incorporated into all aspects of our lives, including transportation, agricultural practices, manufacturing procedures, and office routines. The gains can be enormous, including reductions in the costs of raw materials, energy, and waste management, as well as regulatory compliance and liabilities. Among the many other benefits are improved production efficiency and enhanced public relations. These advantages will help keep the United States competitive in the increasingly challenging world market. The U.S. Environmental Protection Agency (EPA) has initiated multimedia pollution prevention projects that are growing in number and emphasis throughout the United States not only because of their success in meeting our Nation's environmental goals, but also because of the financial benefits and reduced liabilities associated with these efforts. In conjunction with EPA, the members of the Ecological and Toxicological Association of the Dyestuffs Manufacturing Industry (ETAD) have developed a pollution prevention program to record their past pollution prevention achievements, further reduce waste generation, and continue to realize the benefits of pollution prevention in the dye industry. ------- 1.1 History of the Program Several ongoing activities at EPA address the ETAD/EPA Pollution Prevention Task Force Created dye industry - both in the form of research and in the regulatory arena. These activities and the recognition that pollution prevention is a superior waste management option have motivated EPA and the dye industry to join forces. In early 1990, they formed the ETAD/EPA Pollution Prevention Task Force, which consists of representatives from EPA's Offices of Solid Waste and Pollution Prevention and 11 member companies of the U.S. Operating Committee of ETAD. Program Elements In March 1990, the task force formally initiated the pollution prevention program in the dye industry with a workshop followed by a program development meeting. The goal is to develop and implement a comprehensive, industry-wide pollution prevention program that arrives at quantified and documented results. The program does not limit itself to pollutants regulated by any particular statute but instead covers .all pollutants, including those that are unregulated. Elements of the program include: Development of this manual, which identifies pollution prevention opportunities and assists companies in establishing a program Distribution of a survey document to determine a baseline of waste volumes and pollution prevention activity in the industry and to survey progress for 3 consecutive years Development of a measurement system for quantifying reductions and monitoring release reductions on an annual basis. ETAD and EPA are also engaged in a dye dust exposure reduction program that closely relates to pollution prevention objectives. In this program, which involves the National Institute of Occupational Safety and Health (NIOSH) and the American Textile Manufacturers Institute (ATMI), efforts are being directed toward reducing exposure to dye dust during textile dye weighing operations. By focusing on work practices, packaging and dispensing methodology, and workplace design and dye dustiness characteristics, opportunities are being identified to integrate pollution prevention techniques with a goal of reducing exposure to dye dust. ------- Guidance for Assessing Opportunities 1.2 The Guidance Manual The Pollution Prevention Guidance Manual for the Dye Manufacturing Industry was developed by members of industry for use by personnel in all areas of operation, ranging from research and development to sale of the finished product. The document provides a comprehensive guide for assessing waste reduction opportunities associated with all departments in a dye manufacturing facility. The intent of the manual is to provide ideas for pollution prevention projects, while allowing for flexibility in adapting the projects to individual sites, operations, and manufacturing processes. ETAD and EPA have contributed their expertise to the development of this guidance manual and will continue working to gather the results of dye pollution prevention projects. Pollution prevention opportunities exist at all levels of business and range from establishing recycling programs for paper, plastic, and aluminum in the office to evaluating alternate materials for use in production. Every effort to reduce the burden on the environment is viewed as a contribution to pollution prevention. Therefore, an effective pollution prevention effort must involve all departments within the organization. This manual provides guidance on the steps needed in developing and implementing a pollution prevention program. The initial steps include obtaining management commitment and representation for the project, setting up a project task force, and conducting a thorough inventory, or assessment, of all wastes. 1.3 Measuring and Reporting Industry's environmental achievements can be recognized only if the results of pollution prevention/waste reduction efforts are both measured and reported. In addition to responding to the interests'of the public and environmental agencies, measuring and providing feedback of progress are also needed for internal company accounting. The pollution prevention program in the dye industry begins with a Waste Reduction Survey to establish a baseline for pollution prevention activities and waste generation volumes. This initial assessment will be followed by annual progress reviews and reporting using the same Waste Reduction Survey form. The Waste Reduction Survey, provided in Appendix A of this manual, comprises the following three parts: ------- Parti Opportunity Assessment This section consists of an evaluation form that asks you to assign an activity status ranking to. various pollution prevention opportunities based on the level of activity at your site. This will provide a "snapshot" of where the site stands in pollution prevention efforts today and will be useful in identifying future projects. Feel free to add opportunities to the list if your ideas are not presented. The first year for which information should be provided is 1990. Part II Case Studies ETAD member companies were concerned that past waste reduction efforts would not be represented in the "snapshot" of the industry's performance. Therefore, the survey also allows for reporting of completed or ongoing waste reduction projects. You are encouraged to use this section to provide case studies describing your projects. Include the wastes that were reduced, the quantities of reduction, and the cost effects. Part III Waste Generation Data This section establishes an inventory of wastes and waste volumes generated across all media during dye manufacture, standardization, and distribution. You are asked to provide quantitative information for general w$ste categories. The first reporting year corresponds to the first year of the Toxic Release Inventory (TRI), which was 1987. Significant resources will be required to complete the Waste Reduction Survey, which addresses many waste categories. The direction and progress of our industry's waste reduction efforts over the next few years will depend on the care taken by each respondent in answering questions and on the quality of information provided. ------- PART1 PROGRAM ADMINISTRATION 2.0 GETTING STARTED Pollution prevention programs require commitment and organization for successful implementation and high levels of participation. This section provides guidance on gaining commitment from senior management and describes the formation and responsibilities of the program task force. 2.1 Gaining Management Commitment Support from senior management is essential to the Management Commitment success of a pollution prevention program. The program can be initiated from either staff or management; however, the objectives of the program are best conveyed to employees through a formal policy statement or directive from senior management. The person in charge of the company's environmental affairs should be responsible for advising management of the continued importance of pollution prevention and the need for a formal commitment. To obtain continued management support for the pollution prevention program, it must be demonstrated that the benefits of such an effort will outweigh the costs. As indicated in the Introduction to this manual, the potential benefits (immediate and long- term) include improved production efficiency, reduced raw materials consumption, lower operational costs, decreased costs for compliance with regulations, reduced liabilities associated with waste generation, improved public image, and reduced environmental impact. See the reference on "Pollution Prevention Benefits" in the bibliography for a detailed analysis of economic benefits. Benefits Outweigh Costs Proper cost accounting methods are an important element in the success of the program and an important selling point in demonstrating the benefits of pollution prevention. Until the actual costs associated with specific wastes are known, the cost savings associated with pollution prevention will not be appreciated. Development of a company-wide waste and financial tracking system is essential in providing much of the information needed for the program. Section 10, Finance, discusses the implementation of cost accounting methods. ------- 2.2 The Role of the Program Task Force The pollution prevention program will affect a number of Program Task Force groups within a company. For this reason, a program task force should be assembled from various departments within the company, including environmental affairs, operations, engineering, management, research and development, and marketing. Plant personnel with responsibility for production, facilities, maintenance, quality, control, and waste management should be included on the program task force. If the facility is small, one person may be responsible for many of these areas. However, several people should be included on the task force to obtain a variety of perspectives. This section addresses the following goals of the task force: Obtain Cornmitment and Statement of Policy from Management Establish Program Goals Promote Employee Involvement Provide Training, Incentives, and Recognition for Employee Participation Implement Good Operating Practices Institute a Waste Tracking System Establish Waste Assessment Teams Conduct Waste Assessments Select and Justify Options Obtain Funding and Establish Schedules for Project Implementation Monitor Progress. Obtain Commitment and Statement of Policy from Management The person in charge of the company's environmental affairs should be responsible for advising management of the importance of pollution prevention and the need for a formal commitment to a company-wide pollution prevention program. Once this commitment is obtained, management should develop a statement of policy and publicize it throughout the plant. Appendix B contains an example of a corporate statement of policy. ------- Program Goals Establish Program Goals The program task force is responsible for establishing goals consistent with the policy adopted by management. Because qualitative goals can be interpreted ambiguously, it is preferable to establish measurable, quantifiable goals, such as a percent reduction of a particular waste in a particular period. You may prefer to set corporate-wide goals, giving each division within the company the responsibility and freedom to develop its own program to meet this overall goal. Pollution prevention goals should be reviewed periodically to ensure that they are both realistic and challenging. Measurement of reductions can be done in a variety of ways. Particularly meaningful results are obtained by tying reductions to production volumes. The EPA/ETAD Task Force has developed measurement methodology, found in the Waste Reduction Survey in Appendix A, that may be used to measure and monitor waste generation quantities at your plant. This method may need to be modified, however, to suit your specific operations. An additional reference on measurement is provided in the bibliography to this manual. Promote Employee Involvement Although management commitment and direction are fundamental to the success of a pollution prevention program, commitment must also be obtained throughout the organization to solve problems, remove barriers, and ensure the coordination needed for a successful effort. Because of their direct influence on the volume of waste generated at a plant, employees are the key to the overall effectiveness of a pollution prevention program. The task force should publicize and promote the program throughout the plant using signs, posters, refillable pens, otner giveaways. Management should encourage employees to identify pollution prevention opportunities and Employee involvement may be promoted by should maintain an open-minded and positive attitude toward the responses received. In addition, management should provide a vehicle for employees to voice their ideas. ,1 IW glass recycling program. Every pollution prevention program needs one or more people to "champion" the cause. Champions work to overcome the inertia faced when changes to an existing operation are proposed. They also lead the pollution prevention program, either formally or informally. Environmental engineers, production managers, or plant process engineers are good candidates for this role. Regardless of who takes the lead, the champion must be given the authority to implement the program effectively. It is important to realize, however, that all employees must be empowered to make waste reduction their goal so that if the champion leaves the company, the program ------- will not fall apart. Thus, the champion is responsible for institutionalizing the program, not just supporting it. Provide Training. Incentives, and Recognition for Employee Participation Training should be an important part of a company's pollution prevention awareness and education efforts and should serve as a tool in teaching employees operating procedures that support pollution prevention goals. Through training, employees will learn to recognize pollution prevention opportunities. Training requirements must be specific to the target audience and sensitive to.individual needs and limitations. Training programs are most effective when the trainees provide feedback on potential improvements in the program. Spray gun operators at a furniture finishing plant were trained by videotaping their performance and critiquing it with their supervisor. The company realized a savings of$60,000 annually in reduced consumption of finishing materials. Your company can use bonuses, awards, plaques, and other forms of recognition to encourage employee cooperation and participation. For example, the performance evaluations of both managers and employees could be based in part on progress toward attaining the company's pollution prevention goals. Implement Good Operating Practices Total Quality Requires Good Operating Practices Good procedural, administrative, or institutional operating practices are measures a company can use to minimize waste and address the human aspect of operations. They can often be implemented with little cost and, therefore, have a high return on investment. The program task force can promote and implement good operating practices in all areas of the plant, including production, maintenance operations, and raw material and product storage. Good operating practices are linked to the company's "total quality management" activities. Total quality programs generally reduce waste and have the overall advantage of increasing profits, improving competitiveness, and improving employee morale. Institute a Waste Tracking System To identify pollution prevention opportunities and measure the progress achieved toward the company's pollution prevention goals, you need to establish waste tracking systems that are adapted to plant layout and allow you to assign sources and costs to each waste stream. These systems may include flow Tracking Wastes 8 ------- diagrams, control charts that track waste generation at specific production units, or records of waste generation from the entire operation. Material balance calculations are often applied and are especially useful in tracking process wastes. The first step in conducting a facility-wide waste assessment is establishing waste tracking systems. Appendix C provides a sample process flow diagram, along with waste assessment worksheets. Establish Waste Assessment Teams Waste Assessment Teams Make Recommendations to the Task Force Waste assessment teams should include members from the regulatory affairs and engineering staffs. Team responsibilities include providing a broad perspective of plant operations and making recommendations for pollution prevention projects to the program task force. In addition, waste assessment teams oversee the waste measurement and monitoring conducted in support of the pollution prevention program. Some larger companies have developed a system in which assessment teams periodically visit their various plants and share ideas and experiences among the divisions. Similar results can be achieved through periodic inhouse seminars, workshops, or meetings that involve personnel from different areas within the plant. Teams with specific expertise may be formed to assess individual processes or areas of the plant. Conduct Waste Assessments The waste assessment team conducts waste assessments to acquire a detailed understanding of the facility's operations, wastes, and waste management practices. The team also uses these assessments to confirm the findings of the waste tracking system. Waste Assessments Result in Development of Pollution Prevention Options You may conduct assessments using the worksheets provided in Appendix C or other forms developed by the waste assessment team. Waste assessments and waste assessment worksheets are discussed in more detail in Section 4, Production, since production assessments are generally more complicated than those conducted in other areas of the plant. However, waste assessments should be conducted for all plant operations in order to identify and prioritize pollution prevention opportunities. Completed waste assessment worksheets will provide the information needed in selecting and justifying your pollution prevention options. ------- Select and Justify Options Pollution prevention options should be identified in an Identify Options environment that encourages creativity and independent thinking by the members of the waste assessment team. Brainstorming sessions with team members are an effective way of developing these options. Many pollution prevention options will be identified in a successful program, and it is necessary to identify the options that offer the greatest potential to minimize waste and reduce costs. The waste assessment baseline surveys distributed at the start of the dye industry's pollution prevention project and the results from the site assessments will provide most of the information needed to generate and prioritize options. Since detailed evaluation of technical and economic feasibility is usually costly, proposed options should be screened to identify those that deserve further evaluation. By following this procedure, you can eliminate options that appear marginal or impractical and forgo the need for a detailed and more costly feasibility study. Initial Screening Screening procedures can range from an informal review to the use of quantitative decisionmaking tools. The informal evaluation is an unstructured procedure by which the assessment team selects the options that appear best. This method, which consists of a discussion and examination of each option, is useful in small facilities or in situations in which only a few options are generated. If there are a large number of options, the weighted sum method is a means of quantifying the important factors that affect waste management at a particular facility and evaluating the performance of each option with respect to these factors. Appendix D to this manual provides a discussion and example of the weighted sum method. Regardless of the selection method, you should initially use a screening procedure that addresses the following questions: What is the main benefit in terms of such factors as economic, compliance, liability, and safety considerations to be gained by implementing this option? Does the necessary technology exist to pursue the option? How much will implementation of the option cost? Will the procedures be cost effective? Consider all costs of managing the waste, including liability and paperwork. 10 ------- Can the option be implemented within a reasonable amount of time without disrupting production or other operations? Does the option have a good "track record"? If not, is there convincing evidence that the option will succeed? What other benefits will be realized? Some options, such as a procedural change, may not involve capital costs and may be implemented quickly with little or no further evaluation. The results from the screening procedure should provide information on the ease of implementation and the potential cost savings of each alternative. This information will allow you to decide whether to discard the option, promote it for further study, or directly implement the pollution prevention option. Obtain Funding and Establish Schedules for Project Implementation Pollution Prevention Projects Require Personnel and Funding Resources For Their Implementation Pollution prevention projects that require substantial employee time and funding should be described to management in accordance with company approval and budgeting procedures. Gather information.for,your presentation by holding discussions and briefings with the departments involved in the approval process. In addition to addressing the questions posed in the section above on "Select and Justify Options," the presentation should do the following: Capital Costs Provide an estimate of capital costs that may be required for new or upgraded equipment and facilities. Operating Costs Project any increases in operating costs, including materials and personnel. Long-term savings in operating costs following project implementation should be addressed in the profitability calculation. 11 ------- Implementation Time techniques. Provide, depending on the size of the project, either a I I ^^Vl^rfWf ^WI^WI l^^l* '>3 ^Ft • »» i*^ «*I*B«^ ^*« • • • w F" * ^»«w^»j -w • — - • •—- • •»- brief projection of the implementation schedule or a graphic description using critical path charts or similar Profitability Calculation Calculate the potential cost/benefit of projects that require substantial funds and personnel. Request assistance from your company's financial department in obtaining numerical values to use in the calculations. Monitor Progress Regardless of the size of a pollution prevention project, feedback on its results is essential for documenting and reporting progress and deciding on the future of the effort. In addition, company employees will benefit from updates on the results and achievements of the project. Two Phases of Project 1) Implementation (e.g., equipment installation, process and procedural changes) Monitoring 2) Waste Reduction Measurement Implementation may be monitored using the implementation plan and timetable presented to management to obtain funding. The section entitled "Establish Program Goals" and Appendix A discuss methods for waste reduction measurement. Waste reduction measurement, an integral part of any pollution prevention project, must be designed and instituted at the start of the effort. Measurement reports will provide the data necessary for interim checks and annual project reports. Several departments in the company typically use project monitoring information. For example, the accounting department may require progress reports on funds expended for their cost accounting records. Management may request reports of progress on a monthly or quarterly basis. You may also initiate reports in a company news bulletin at juncture points in the critical path time chart. The engineering department may provide experience and assistance in developing the reporting schedule and identifying the information needed by specific departments. 12 ------- 3.0 THE ROLE OF THE REGULATORY AFFAIRS STAFF Regulatory affairs personnel, consisting of environmental, industrial health, safety, and adjunct legal staff, play an important role in every waste management program. They typically take the lead in promoting pollution prevention among management and employees and reporting on pollution prevention activities to management, customers, the public, and trade associations. The pollution prevention activities of the regulatory affairs staff can generally be placed into three main categories: Compliance and Documentation Technology and Information Transfer Risk and Hazard Assessment 3.1 Compliance and Documentation Land, Air, and Water Regulations Members of the regulatory affairs staff are most knowledgeable of the current Federal, State, and local laws and regulations pertaining to chemical releases to the land, air, and water. Project activities related to compliance, include review and evaluation of the consistency of on-site pollution prevention projects with company goals and regulatory requirements. The regulatory affairs staff is responsible for verifying and maintaining compliance records, including permits, manifests, inspection reports, and minutes of pollution prevention team meetings. Your staff should also maintain records of changes in the volume and toxicity of the waste generated, as well as costs associated with waste management and its related paperwork. 3.2 Technology and Information Transfer The second major focus of the regulatory affairs function is the transfer of technology and information to the operating units. This includes identifying new pollution prevention technologies and promoting their evaluation and implementation by the operating units. Examples of new technologies may include the use of solvent reclaimers to minimize solvent in the waste stream, spray dryers to reduce wastewaters, and reusable versus disposable personal protective equipment. Innovative Pollution Prevention Technologies 13 ------- In addition, the regulatory affairs staff should remain aware of internal and external constraints on pollution prevention activities. Constraints develop from regulatory, legal, contractual, financial, and logistical activities. The regulatory affairs staff should identify and mitigate institutional and regulatory impediments to recycling and waste elimination options. Creating and maintaining a corporate commitment to pollution prevention is important in overcoming internal and external barriers. Regulatory awareness and technology oversight are both needed in identifying and assessing pollution prevention opportunities. Because of their knowledge of regulatory requirements and constraints, as well as pollution prevention technologies and strategies, regulatory affairs personnel should participate in the development of pollution prevention training programs. 3.3 Risk and Hazard Assessment The third major focus of the regulatory affairs staff is Reevaluate Risk After Process Modifications assessing the risks and hazards involved with waste management and minimization activities. Environmental engineers within the staff should review the process improvements intended to minimize waste for regulatory compliance and to reduce potential hazards posed by the. new or different wastes generated. Members of the staff should ensure that process modifications do not increase the hazard or risk posed by the waste. 14 ------- PART 2 PROGRAM IMPLEMENTATION Identify and quantify all facility wastes as a first step to project implementation. The term "waste" means all material that leaves the facility other than saleable product. It includes filtrates, wash waters, cooling water, production off-gases, and air scrubber water, as well as solid materials, such as clarification residues, packaging materials, waste paper, and sample containers. Quantification involves measuring or estimating liquid and air flow, and weighing or counting solid materials, together with an analysis (estimated or measured) of each component of the waste stream. As described in Section 2.2, The Role of the Program Task Force, quantification of wastes is conducted using waste tracking systems and site assessments. The second step in project implementation is establishing and adhering to written operating procedures. Written procedures and training programs are essential to ensure that the practices of the production staff are uniform and consistent. Operations include not only the actual manufacturing operations (i.e., dye synthesis) but all procedures that generate waste, including equipment cleaning, line purging prior to repairs, cleaning drums after material charging, sample disposal following testing, and office and laboratory practices. For example, high-pressure nozzles installed for cleaning Maintain equipment require the use of specified volumes, times, Written temperatures, and pressures. Procedures Procedures must also include control steps to ensure that the methods are precisely followed. These controls should be applied not only to major processing steps but also to such details as the return of samples to the respective kettles at the correct times. Only when operations in a batch processing industry are exactly reproduced can the waste quantities be controlled. 15 ------- 4.0 PRODUCTION Production may be one of the most lucrative areas within a Dye Production company for pollution prevention projects. This section provides project ideas for nine dye production operations. Continued operator training is key to maintaining good industrial practices. The discussion begins by addressing good industrial practices, process assessments, and pollution prevention objectives, which are important to meeting pollution prevention goals in all areas of production operations. The following list of good industrial practices may appear obvious, but as stated above, there is significant value in maintaining written procedures for all activities, including industrial practices. Good practices are reinforced when they are incorporated into the employee training program and operating instructions. Process waste assessments are addressed separately in this section because they may be more complex in the production area than in other areas of the plant. Examples of general production-related questions to include on waste assessment worksheets are presented in this section. Good Industrial Practices Before addressing complicated production operations, attention should be directed to good overall industrial practices, such as the following: Verify the identity, quality, and quantity of all materials before they are used. Empty bags of material completely and rinse drums into the reaction vessels. Verify the container labels before putting any product into a drum to avoid cross-contamination. Practice spill prevention measures. If a spill does occur, segregate the spilled materials and, whenever possible, return them to the system rather than wash them down the sewer. Follow reaction and cleanup procedures in a strict manner and report any deviations immediately. Water should be treated with the same value as other raw materials, particularly during cleanup. 16 ------- Keep equipment and instruments in good working order. Process Assessments The waste assessment team or another assigned group should periodically conduct a formal review of each production process using the worksheets provided in Appendix C or other appropriate forms. Waste assessments should involve material balances around each process. The process flow diagrams discussed in Appendix C will be useful in Process performing material balances. Material balances may be based Assessments on engjneerjng calculations, using the chemical equations for in the eac^ reactj0n, and analysis, wherever possible, to confirm the Production calculations and the course of the chemical reaction. In addition Area to asking the process-specific questions, such as those provide^ in the worksheets, responses to more general questions, including the following, may provide valuable information in . characterizing facility waste streams: Which operations contribute the most to the hydraulic load? Can product washing operations or other contributing operations be improved? Does process water consumption correspond to estimated usage? How can the difference, if significant, be explained? What are the input materials used that generate the waste streams? How much raw material is estimated to be lost through fugitive emissions? Pollution Prevention Objectives The data obtained from the process reviews should be used to indicate the best approaches for meeting specific objectives set by the pollution prevention task force. These reviews may also generate suggestions for other departments involved in the operation. Any changes in operating or processing methods proposed as a result of pollution prevention efforts must be subject to required reviews to ensure safety, 17 ------- health, and quality standards. The following are two examples of using specific objectives to select an approach: 1) 2) Reduce hydraulic load on the wastewater treatment plant by X% - Changing wash-out procedures or initiating the recycle of scrubber water may provide a greater initial reduction than projects aimed at increasing batch concentrations. One plant substituted sodium acetate buffer with sodium formate in some processes to reduce the BOD loading in the effluent. Reduce BOD load on the wastewater treatment plant by Y% - The waste assessment worksheets will indicate which products contribute high BOD loads and, in some cases, which aspect of the process offers the greatest potential for development work to reduce BOD. For example, you may achieve your BOD objectives where solvents or acetate buffers are used by simply changing a solvent or pH buffer instead of opting for a more complicated modification. 4.1 Raw Material Receiving and Charging/Material Transfer Raw Material Transport A major source of waste is the receipt and transfer of material from the shipping container to the production equipment. Be sure that all containers are properly labeled prior to putting any product into a drum. In addition, segregate spilled materials. These practices, in addition to the specific examples presented below, can eliminate cross-contamination and better allow for product rework. Empty Containers Recycle Containers Empty containers are reusable when they are in good condition and are clean or dedicated to a specific material. Container damage during handling is the primary reason that many containers are not reused. Operator training and quality control procedures should address the proper handling of containers so that reuse can be instituted. Try to reuse containers onsite. If a use has not been identified for them onsite, investigate potential uses at other sites (within or outside the company) or request your suppliers to reuse or recycle the empty containers. You can make an impact on the volume of packaging material that enters the waste stream by switching to bulk supply for raw materials. Bulk containers should have a longer life for reuse because there is less handling for a given quantity of 18 ------- Use Bulk Supply material. Other advantages of bulk supply may include reduced labor due to ease in handling, improved material control, more efficient packaging, and fewer transfer operations, which in turn reduce material losses. Residual Raw Materials Utilize All Material From Containers Raw materials left in containers represent lost product and higher production costs. They may also constitute health hazards to operators who handle the containers. When they are added to the waste stream, treatment chemicals may be required that further increase the volume of the waste stream. You can minimize residual raw material losses by selecting containers that are easy to empty. You can also use equipment, such as drum lifters and vibrators, that facilitates container discharge. Once all the accessible material is removed, rinse the containers into the batch, whenever feasible, to remove the final residuals. Transfer Operations Material losses originate from transfer operations using conveying equipment for solids and pipelines and pumps for liquids (i.e., with leaky connections or seals). Losses are costly and result in handling hazards and additional load to the waste treatment plants. Operating procedures should.emphasize routine equipment maintenance, inspections, and operating care to prevent material losses. Frequently, careful studies of material transfer operations, including operator handling and equipment use, can result in reduced labor, decreased material losses, and lowered employee exposure. OSHA, NIOSH, and private industry offer assistance in these studies. Because transfer operations usually involve direct operator handling, success in pollution prevention also depends on operator training. Optimum transfer operations include fully enclosed and automated systems wherever possible. Air Emissions During Material Transport Materials collected to avoid emissions or other releases typically include vapors or dusts captured through scrubbers and bag filters. Because scrubbers are frequently used on multiple pieces of equipment, scrubber liquids are complex mixtures difficult to separate and recover. Try to avoid multiple stream collecting equipment whenever possible. Optimize scrubber operations to allow for collection of dusts from filter bags and cyclones that recycle the dusts into the regular material streams. In addition, clean- 19 Optimize Dust Collection Operations ------- outs from filter equipment can often be used to make saleable dye formulations, or saved for use in a future dye campaign. 4.2 Synthesis Dye synthesis is a critical step in process assessments because it is the primary operation that determines the volume and type of chemicals used in the process and the chemical characteristics of the effluent. This step should receive the most detailed assessment. Conduct process waste assessments through several shifts, particularly when waste generation is operator-dependent (e.g., as in equipment washing), and observe the housekeeping practices surrounding the operation. The following specific questions should be asked during the assessment: Why are excess intermediates used in reactions? Can the excess be reduced by the introduction of better control procedures? What compounds contribute to BOD? Is it possible to reduce their use? Can initial wash waters be collected and recycled for use in the next campaign? Are gases released during processing? Can the amount be reduced or can the gases be recovered for use in other products? Recover/Recycle Wash Waters, Off-Gases, Byproducts, Offgrade Material Are cycle times excessive? Are processing and isolation operations conducted at the most efficient temperatures? (Be sure to include the optimum parameters and procedures in operator training sessions and materials.) What byproducts are formed during processing? Can they be recovered for reuse or sale? Can spilled materials be segregated, in some instances, and returned to the process? Is the amount of offgrade material produced excessive? Are the identity, quality, and quantity of all raw materials verified before they are used? Are material containers emptied completely and rinsed into the reaction vessel? 20 ------- Is the equipment being used the best match for the process? Can indirect heating and cooling be used 'to reduce waste volume? Can tank scrubbers be run more efficiently to save on water? What process deviations may affect operations further downstream and should be flagged for immediate action? 4.3 Isolation/Filtration Filtration can often be the source of excessive wastewater generation, lost product, and spent processing aids. Various pollution prevention opportunities have been identified that will reduce operational costs associated with isolation and filtration and will minimize the volume of waste generated from the process. Precipitating Agents The amount of precipitating agent used is crucial in Eliminate Excess Additives ensuring that the product is completely precipitated and not lost in the filtration. However, excess precipitating agent is frequently added for "insurance" purposes. To minimize the use of excess agents, determine the optimum amount of precipitating agent in the product development stage. This determination is made with tests, such as lab filtration and spot tests. In addition, some precipitating agents are more efficient than others for specific products. The selection of the most efficient agents also needs to be considered during product development. Temperature/Volume Control The maximum or minimum temperature needed to ensure proper crystal formation of the product should be determined and used in the isolation. By using a higher or lower temperature than necessary, energy is wasted. Incorrect temperatures may require excessive volumes of steam or ice for heating or cooling. In addition, in the case of excessive heating, the product frequently becomes more soluble and requires additional precipitating agent. The operating instructions should indicate whether the elevated temperature after crystal formation needs to be maintained for filtration or if the product can be allowed to cool as it is filtered. You can save energy by allowing the product to cool as it is filtered. In addition, you will reduce the possibility of the product becoming resolubilized. Energy savings can also be realized by using instrumentation to control batch temperature. Conserve Energy 21 ------- You can reduce the amount of precipitating agent required and optimize the amount of product precipitated from the mother liquor by controlling the volume of the batch. Volume control is accomplished by batch concentration, the use of indirect heat sources, such as coils or jackets, and the use of temperature control equipment. Indirect heat sources may result in reduced energy efficiency, which needs to be balanced against optimum batch volumes. Reusable Filter Media Rlter cloths that can be cleaned or laundered allow Minimize Volume of Spent Filter Aid and Media the reuse of filter media for different products. You can eliminate the need for paper in addition to. cloth by selecting the appropriate cloth media for your products. In clarifications, testing to determine the optimum filter aid can reduce the amount needed for the filtration. In addition, the volume of waste generated can be reduced by using bags or other filters that can be cleaned, instead of cartridge filters that cannot be cleaned. Leak Elimination Leaks caused by improper alignment of the filter press and/or punctures in filter paper or cloth result in lost product and increased load on wastewater treatment plants. Losses result from both the leak and the cleanup needed to reset the leaking press. Operations supervisors can reduce the number of leaks by implementing .and overseeing a standard procedure for cleaning, resetting, and closing the filter press. The press design should allow all filtrations (even closed delivery) to be checked for filtrate leakage from the individual chambers. By detecting leaking chambers individually, you will be able to close only the leaking chamber and prevent loss throughout the filtration. You will also be able to ascertain the source of the leak so that punctures in the filtration media can be repaired. Reduction of wastewater contaminant load may be accomplished by starting each filtration with recycle of mother liquor until clarity is established. Filter Wash Endpoint Establish testing parameters and values for each product that indicate the endpoint for washing, so that operators can determine whether an amount of filter washing is excessive or insufficient. The parameters may be as simple as conductivity when salts are removed or as complicated as spectrophotometric curves or thin-layer chromatography (TLC) when an impurity is removed. It may even be possible to test individual press spigots and close them to washing when they meet the necessary parameter values. 22 Eliminate Excessive Filter Washing ------- Filter Wash Water Reuse Many filter wash waters contain only small amounts of impurities. Whenever possible, collect this water for use in washing floors or equipment or for other appropriate purposes. Wash. Soak, and Rinse Process Minimize Wastewaters Requiring Treatment Washing the filter equipment with large amounts of water on a continuous basis is extremely inefficient. To reduce the amount of filter wash water used, fill the filtration equipment with wash water, allow it to soak in the filter unit for a period of time, and repeat the procedure. Filter Press Slowdown To minimize drying time and improve energy utilization, blow excess liquid from the filter press with compressed air. This procedure saves energy by reducing the amount of liquid that needs to be evaporated in the drying process. Additionally, the removal of residual wash or filtrate by blowing can improve product strength and quality and may result in less offgrade product. Improved drying efficiency is also obtainable with the newer diaphragm presses. Product Transfer Avoid Filter Cake Losses and Spillage Large amounts of product are often unnecessarily lost due to filter cake spillage during product transfer. Use custom boxes or bins along with pans or chutes to catch filter cake as it is removed from the filtration equipment. This will eliminate product losses and contamination, in addition to increased waste generation caused by spillage onto the floor. High-Pressure Sprav Many types of commercial grade pressure wash equipment are available for filter press and centrifuge cleanup. These units expedite the removal of residual filter cake from the filter equipment while minimizing the amount of wastewater generated. Common "garden hose"-type spray nozzles result in the use of 10-100 times the amount of water used by high pressure sprays to clean the same surface area. A pressure washer also allows the introduction of heat into the cleaning water. 23 ------- 4.4 Drying Drying wet filter cake is an energy intensive process. This Optimize Drying Operations section presents suggestions on optimizing dryer operation. Optimization of drying conditions will reduce energy consumption, save in operational costs, and assist in reaching pollution prevention goals. Techniques to reduce material losses from dust emissions and wash waters generated during drying can be similar to those used in other production areas. These techniques are also addressed in this section. Energy Consumption Increased Efficiency Conserves Energy and Reduces Costs Conduct energy audits periodically. As a starting point for dryers, take measurements to determine BTU consumption versus pounds of water evaporated. Use the results to establish energy and efficiency goals for your dryers. Optimize drying temperature to minimize energy consumption. An increase or decrease in drying temperature versus drying time may favorably affect energy usage. Improve temperature control. Passage of vented heated air from dryers over Control drying time by increasing sampling frequency or replacing required to generate steam' boiler feed water reduces the amount of energy manual sampling with instrumentation that measures humidity and pinpoints when material is dry. Evaluate alternative drying processes to optimize the drying operation. Newer technologies, such as spray drying, and new equipment often offer much better energy efficiency in addition to improved material handling, leading to better drying temperature, time control, and reduced material losses. Recycle dryer heat, whenever possible (e.g., to preheat boiler water). Prevent heat loss with better oven insulation. 24 ------- Use such techniques as zone heating to optimize dryer efficiency. Identify the maximum acceptable moisture content for the product since dye products are often dried beyond what is necessary for the customer. Operating procedures should identify this value, which will save energy and may reduce dustiness. Heat Transfer Use available techniques to distribute the filter cake on the trays. These techniques may include extruders to place cake on the trays in spaghetti form, optimization of tray and rack loadings, and mechanical means to break up presscake lumps. Increase the solids content in dryer feed stream to reduce the energy required to dry the product and improve throughput. "Squeeze" presses may be used to increase the percent solids of the presscakes prior to drying. Keep the heating elements free of deposits. Evaluate alternative dryer designs to optimize the dryer air flow. Establish a preventative maintenance program for dryers. Material Losses Consider customized equipment for dryer loading that allows even distribution of cakes on the trays without spilling. Mechanized loading (e.g., extruders), which may improve heat transfer and evaporation from the filter cake, reduces labor requirements and the amount of spillage. Minimize Material Losses From Spillage and Dust Collect dye dust in cyclones, baghouses, or scrubbers to avoid emission losses and air pollution. As described in Section 4.5, Grinding, and Section 4.6, Blending, dusts should be collected and segregated so they can be recycled into the regular production process. You should also use an appropriate amount of deduster to reduce dust losses. Enclose dumping stations with dust collectors and monitor emissions and employee dust exposure levels. Dryer unloading, which is usually the most dust-generating step, requires careful control. In addition, establish reduction 25 ------- goals for the amount of dust emitted. Again, materials collected in baghouses and other collection equipment should be recycled to regular production. Minimize dust generation by employing continuous drying processes, such as spray dryers. Additional controls can be introduced by automatic, enclosed filling of containers. Avoid open dumping of dry materials from tays into containers or other equipment. Schedule long production campaigns to minimize water consumption and waste generation from cleanouts. You can also reduce washing requirements by scheduling batches from light to dark colors and by keeping products of the same basic chemistry in dedicated dryers. Use a high-pressure "power washer" to wash drying equipment with the minimum amount of water consumption. Reduce the amount of wastewater generated from the plant by using spray dryers to dry entire batches without isolation. Wastewaters can also be reduced by reworking equipment rinses into future campaigns and redrying rinses. 4.5 Grinding Pollution prevention opportunities in the area of grinding have been identified in four major areas: Waste materials (products, raw materials, and byproducts) Wastewater Air emissions Energy Waste Materials Recycle or sell collected fines to reduce the amount requiring disposal. Establish goals to reduce the dustiness of your product and improve dust collection. This will minimize particulate losses to the atmosphere and wastewater treatment system. Eliminate the practice of using excess and unnecessary deduster in order to save on raw materials usage and costs and to reduce the generation of off- spec product. 26 ------- Optimize product formulations and grinding conditions to minimize screen blockage and the waste associated with removing, cleaning, and replacing screens. Eliminate Excess Deduster Reduce material losses by improving process equipment and/or investing in new technology. Evaluate the process for potential improvements and communicate ideas to your pollution prevention task force. • Optimize media selection in your milling operation to reduce the frequency required for media disposal. Select and maintain pumps and mill seals to minimize leakage of material from malfunctioning seals. Wastewater Reduction Minimize Wastewaters Requiring Treatment By Recycling Collect and recycle wash water, whenever possible. Control wash water volumes to meet, but not exceed, process needs. Install automated control and recycling of non-contact cooling waters. Improve seal selection and maintenance practices to reduce leaks and cleanup waters sent to the wastewater treatment system. - Install building or plant wastewater monitoring systems to detect and minimize spills and leaks. Reductions of Air Emissions Reduce Emissions and Improve Working Environment 27 ------- Reduce particulate emissions and the amount of material washed to the wastewater treatment system by reducing product dustiness and improving dust collection. Reduce particulate emissions, improve product yields, and reduce the amount of product washed to the wastewater treatment system by improving material transfer and grinder loading techniques. Reduction of Energy Usage Conserve Energy and Save Resources Establish product size requirements to avoid overgrinding and unnecessary energy usage. Optimize grinding temperature and media to shorten grinding times and reduce energy usage. Optimize product formulations, concentrations, viscosity, and milling media charges to minimize grinding times. In turn, shorter grinding times reduce both energy and cooling water usage. 4.6 Blending Blending operations often generate large volumes of waste Blending Operations consisting of spilled material, dust collector waste, packaging materials, and material left in containers. Below are some ideas for good operating practices in the blending area. Material Handling Reduce spillage by training employees in proper material handling techniques. Emphasize the cost, safety, and environmental benefits of spill prevention in the employee training program. In addition, maintain an adequate supply of funnels, hoses, valves, pumps, transfer containers, and other materials handling equipment. Spill Prevention 28 ------- Dust Collection Dusts generated during blending can frequently be captured by dust collection systems and recycled into the same product or other saleable product, such as a black dye. Some blending operations may also allow for dust recycling into colors other than black, which may be sold as one-time blends. However, careful control of the dusts collected from the various dye classes must be maintained to prevent contamination. Generally, dusts need to be segregated and stored for a period of time to collect a marketable quantity of dye. Blending Method When selecting new blending equipment, consider the amount of dust generated by each type of equipment and blending method (e.g., pneumatic, agitation). For plants equipped with several types of blending equipment, try to match the blending equipment that generates the least dust with the particular dyes that are inherently most dusty. This will minimize the total amount of dust generated by the plant. Blend Size Optimization of blend size can reduce the amount of equipment cleanups required and, consequently, the volume of wash water generated. After reviewing your product sales history, warehouse capacity, and product stability in storage, schedule the largest production volume possible for a single blending operation. Dedusting Materials Increased Blend Sizes Reduce Wastewater Avoid the Syndrome of "One Pound is Good, So Ten Pounds is Better"! Dedusting materials are added to the blend to reduce the dustiness of the dye. Frequently, a certain amount of deduster is required to reduce dusting, while subsequent additions do not further enhance the performance of the deduster. Train your blend formulator and blending equipment operators to avoid excessive use of dedusters and evaluate different methods of deduster addition. Solution Filtration Typical waste streams generated from filtration of solutions during standardization include equipment cleanup wastes from tanks, filters and hoses, and clarification aids, such as diatomaceous earth and filter cloths. To minimize these 29 ------- wastes, you should optimize product formulations, filtration methods, equipment sizing, and cleanup techniques. 4.7 Sample Taking, Weighing Sampling, though not the largest waste-generating activity in the plant, can incorporate pollution prevention objectives. Extending your pollution prevention program to the activities associated with small material volumes may result in broader benefits, such as reduced worker exposure, environmental improvements, and lower operational costs. Sample Taking Statistical sampling of multiple containers requires many Avoid "Over- Sampling" small bottles and produces small product quantities, which are often discarded rather than recycled into the production process. Frequently, presampling is performed by the supplier and results may be available on each batch. This may reduce the need for statistical sampling at your plant. When sampling raw materials, process intermediates, blends, and final products, minimize the amount of sample collected, especially if it will be discarded later. Return the product to the process whenever possible. Weighing , Reduce Opportunity for Spills Weight adjustments in the packaging process are the most frequent source of spills and result in material loss and waste. To reduce the probability of spillage, shorten the distance required for material travel between containers involved in weight adjustments. In addition, operator training should provide guidance in selecting an appropriately designed scoop for weight adjustments. You may be able to install automatic packaging equipment, which minimizes the need for manual adjustments. To avoid weight adjustments when charging equipment, adjust batch sizes for material quantities that correspond to one or more standard container weights. 4.8 Equipment Cleanout While it is necessary to clean equipment, the methods used can result in excessive amounts of wash waters that need to be treated. Current vessel cleanout procedures often include initial hose-down followed by total fill with hot water and draining to the effluent treatment plant. You can reduce the volume of spent wash 30 ------- waste sent to the wastewater treatment plant by reducing the amount of water (or other liquid) used and by recycling the wash water into the next production batch/process or other initial washing procedures. This section presents some specific suggestions. Monitoring Water Usace As a first step in reducing the amount of wastewater generated by equipment cleaning, monitor the need for wash water by simple visual control (e.g., color) or analysis (e.g., salt loading). Always avoid uncontrolled overnight flushing of equipment. High Pressure Cleaning Minimize a —a Wastewaters Several commercially available high-pressure water Requiring cleaning units can be installed in reaction tubs to substantially Treatment reduce the volume of water required for satisfactory cleanout. Wash Water Reuse Cleanout wash- waters can be substantially reduced by sequencing the same wash through the system, from small vessels to large units and then to the filter presses. Reuse can also be successful by employing concentrated wastewaters generated from a first equipment wash for use in the next production batch. Subsequent rinses generate low concentration wastewat.ers that can be recycled as rinse water. Cleanout Frequency Whenever possible, cleanout for some units should be deferred or reduced by running longer campaigns of the same product and by sequencing the manufacture of products from lighter/brighter to darker/duller. In cases where vessel cleanout is essential to maintain product quality (e.g., the vessel is contaminated with a diazotizable intermediate or product), consider the pollution prevention opportunities identified above. 4.9 Packaging Avoid Excess Packaging A large volume of the solid waste disposed of in today's landfills is a direct result of excess packaging. Many companies are identifying ways to use less packaging and to replace materials that cannot be recycled (e.g., plastic laminated substrates) with recyclable materials. Ideas are presented in this section on ways to 31 ------- protect products and raw materials better and prevent the generation of offgrade material, which adds to the waste stream and subtracts from profits. Alternative Packaging Select packaging materials that may be reused or recycled. Switching to washable, reusable plastic drums for transfer of in- plant materials can significantly reduce solid waste. Promote bulk deliveries with storage in large tanks or deliveries in semi-bulk reusable containers (e.g., totes), which can be returned for reuse. As a first step, you may use disposable 2200-pound bulk containers to replace a large number of smaller packages. Institute market forecasting of customer requirements to assist your customers in identifying opportunities for bulk shipments. Limit materials of construction and container sizes to the most common types found in the industry. This will reduce the need for repackaging and promote packaging reuse. Packaging Technology , Design packaging, procedures to minimize the product dusting that occurs j during transfer from the blender to the final package. This dusting creates air : emissions and increased wastewaters that result from cleanup. I 1 Maximize the bulk density of the product to obtain maximum efficiency in package usage. This reduces the amount of packaging required and helps j reduce dust generation, which can cause cross contamination in both your i plant and your customer's facility. i : Design packaging to minimize dust exposure to employees weighing the product at your customer's plant. Storage and Warehousing Design storage and warehousing operations with consideration for minimizing potential container damage. Institute proper handling procedures for the transfer, palletizing, and stacking of the product. Protect Products to Eliminate Off-Grade 32 ------- Minimize the need for repackaging through accurate materials resource planning and improved forecasting. Train your staff in the procedures for product storage that protect the properties of the products and do not result in the generation of offgrade product. Refer to Section 7.0, Inventory Control, for descriptions of systems on inventory rotation and the prevention of product expiration. 33 ------- Additional Opportunities Identified In Your Plant in the Area of Production: Note: This and subsequent similar pages are provided for notes and additional project ideas specific to your site. 34 ------- 5.0 RESEARCH AND DEVELOPMENT Implement Pollution Prevention Options From the Start Research and development can affect all stages of a. product cycle, including raw material selection, production processes, product formulations, customer applications, and ultimate product disposal. Thus, R&D projects provide a unique opportunity to implement pollution prevention options from the very start and to minimize waste generation in your plant, your customers' plants, and in the laboratory. The pollution prevention opportunities identified for the R&D Department are separated into two sections: Product Development Laboratory Practices 5.1 Product Development Pollution prevention objectives should be a primary consideration during the development of new dyes and manufacturing processes and in the application of new dyes. R&D staff need to be aware of all wastes potentially generated from a given process and must identify and consider opportunities for elimination or reduction of these wastes. Product Substitutions Develop Dust-Free and Residue-Free Products R&D staff should consider substitutions for chemical products used in the development of new dye products and in modifications to existing products that contribute to an overall reduction in wastes created in the manufacture or use of the product. They should, for example, give top consideration to chemical products that do not require clarification to remove insoluble residues or that are rendered dustless. Economic considerations for this substitution should reflect the costs of the additional processing and waste disposal as well as the direct product costs. In developing new or modified products intended as substitute products for existing dyes, consider properties that contribute to waste reduction in addition to the traditional properties of color and fastness. The waste reduction properties should 35 ------- affect waste generation during both the manufacture and use of the product. These properties may include improved substantivity, reduction of dustiness, increased concentration of active ingredients, and improved dye application properties. Efficiency of Dves and Application Processes The development of more efficient dyes and application processes will result in more dye being used for its intended purpose of coloring a substrate and less loss of dye to the environment. R&D staff should consider high substantivity to the desired substrate as a primary factor in the development of new dyes. R&D management should also encourage the development of more efficient application procedures and processes, including research on fiber modification and additives to improve dyeability. Concentration of Active Ingredient Products containing higher concentrations of active ingredient reduce the volume of waste generated from product diluents and packaging. Whenever possible, produce and market products at the highest concentration acceptable for the end product. i i Development of New Molecules In the research and development of new dye molecules, consider the use of nonhazardous reactants and ancillary chemicals! whenever possible, for the synthesis of the new molecules. ' j , Environmentally Safe Diluents : Certain chemicals are traditionally used as diluents for each dye class. Thesej diluents are generally inexpensive chemicals that do not interfere with the dyeing process and are frequently already used in the dyeing process or are inert. When developing new formulations or reformulating existing products, consider nonhazardous chemicals that do not present an environmental risk for use as diluents. Synthesis Routes In the development of new dyes, consider alternative synthesis routes that use less toxic reactants and generate less waste. Remember: the objective is to reduce the toxicity or other the volume of waste. 36 ------- Process Changes Minimize Filtration Aids Insoluble residual materials created in certain dye manufacturing processes must be removed prior to isolation of the dye in its final form. Typically, this removal is accomplished through clarification of a solution of the dye using diatomaceous earth and activated carbon, a procedure that results in a material having no commercial value and requiring disposal. R&D staff should encourage research into modifications for those processes that produce residual filter aid wastes. Examples of possible modifications to reduce this waste include alternative synthesis routes, changes to reactant addition conditions, adjustments in reactant specifications, and the use of additives in the reaction. New Production Processes As newer technologies evolve, R&D staff should determine their applicability to older, established processes, in addition to the new processes. Evaluation procedures should be instituted to accomplish this goal. Pilot Plant Trials One R&D Department developed a method to prepare an intermediate from a sulfur-containing reactant without the release of SOj. Previously, SOfe was released during filtration and sent to an alkaline scrubber, which discharged a sulfite/bisulfite mixture to the wastewater treatment unit. Reuse Pilot Plant Products Products generated from pilot plant trials cannot always be marketed as saleable product and are frequently disposed of as waste. Any products produced during successful pilot plant runs that are not sold should be transferred to the manufacturing plant for use in production. Frequently, it is possible to incorporate such pilot plant products, even though' they do not fully meet the product specifications, into production without adversely affecting the properties of the final product. With due consideration given to the requirements of the Toxic Substances Control Act, it is also possible to use quality pilot plant products from discontinued projects by incorporating them into a mixed dye product (e.g., black). Solvents and Reactants R&D staff should review new processes to ascertain that solvents and chemicals required by the processes are the most efficient and, where applicable, lend themselves to recycling. Whenever possible, select nonhazardous solvents and reactants. Solvent Recycling 37 ------- Minimum Filtration Requirements Filtration typically results in the generation of waste from either the filter cake or the filtrate. When the reaction chemistry allows, consider processes that generate products in situ and eliminate the isolation of chemicals formed in intermediate stages of the process. Raw Materials Avoid Excess and Inefficient Raw Materials Raw material specifications often influence the yield of reaction and, consequently, the amount of raw material .discharged in the waste stream. In addition, existing processes may use excess raw materials to ensure complete reaction. You should identify these processes and reevaluate the minimum quantity of reactant or additive necessary for complete reaction. One method used to modify existing production procedures for the maximum utilization of reactants is the Evolutionary Operation (EVOP). See Appendix E for selected references on EVOP. Maximum Reactant Concentrations Waste generation relative to product yield can be reduced by producing products at their maximum possible concentration. R&D staff should determine the maximum concentration at which a reaction can be run for new and existing processes. Reaction Yields Product yield can also be improved by determining the optimum isolation temperature and pH, isolation procedures, cycle times, and other appropriate variables. 5.2 Laboratory Practices Maximize Product Yields Laboratory Wastes Improving laboratory practices is another means for Research and Development staff to prevent pollution. Simple changes in operating procedures often result in significant reductions in the volume of laboratory waste generated. 38 ------- Sample Sizes R&D staff should determine the quantity of a laboratory chemical required for a project prior to obtaining the chemical. This step will minimize excess chemicals that remain in the laboratory and will eventually require disposal. Laboratory Chemical Supply A chemical required for particular laboratory work and is used in a current manufacturing process, should be obtained from the plant inventory. Chemically stable materials used in large amounts in the manufacturing process can be purchased in larger quantities and are less likely to be unused and discarded as waste. When additional quantities of the same chemical are required, an uncontaminated container can be reused. Unused Chemicals and Products When chemicals and products utilized in laboratory processes are also used in current manufacturing processes, any excess chemical remaining from the laboratory project should be sent to the manufacturing plant for use in the production process. Recyclable Solvents Certain solvents routinely used in the laboratory can frequently be recovered through distillation, even though the used solvents contain residual materials. , Distillation can be effective in recovering the majority of the used solvent and in reducing the overall quantity of waste requiring disposal. Small-Scale Laboratory Equipment Small-Scale Equipment Generates Less Waste The quantity of a new chemical substance needed for the initial screening of a new product is often small (e.g., grams). The use of small-scale laboratory equipment can generally produce the quantities necessary for an initial evaluation of a new dye. Spill Cleanup Efficient spill recovery products are commercially available and frequently minimize the quantity of waste requiring disposal. 39 ------- Reusable Laboratory Equipment Many articles of laboratory equipment are now available as disposable equipment. Disposable equipment may be more convenient and desirable for certain applications because of safety reasons, but it may also present a disposal problem when contaminated. For this reason, include pollution prevention as a factor in the evaluation of disposable equipment and discourage its use when possible. Discourage Disposable Equipment 40 ------- Additional Opportunities Identified in Your Plant in the Area of Research and Development: 41 ------- 6.0 PURCHASING Purchasing Can Communicate Your Pollution Prevention Program to Vendors The Purchasing Department sets a visible example for the company's pollution prevention program by instituting the company's policies in its negotiations with suppliers. The Purchasing, Sales, and Marketing Departments should implement the pollution prevention program when negotiating with vendors and customers to play their part in contributing to the goals of the program and publicize the company's attitudes and achievements. This section provides examples of pollution prevention opportunities available to purchasing agents. Purchase Recycled Products Patronize Vendors Who Support Recycling Programs Your facility should establish a policy of patronizing vendors who both specialize in products made from recycled or recyclable materials and support recycling programs. This policy should encourage purchasing from vendors who offer rebuilt or reconditioned materials and equipment as an alternative to new items. Container Selection Where possible, require reusable/returnable containers from vendors. Where reusable/returnable containers are not feasible, use recycled or recyclable containers (e.g., steel drums can be recycled as scrap metal whereas bags are always discarded as trash). If possible, purchase in bulk. Raw Material Quality Assurance Minimize Offgrade Minimize offgrade product generated from poor quality raw material by purchasing higher quality raw materials, which additionally produce less waste byproduct. The purchasing agent should, for example, select raw materials with minimum trace metal content to reduce the metal content in the waste stream. This may appear more costly in the short-term but will generally result in long-term savings. Combine Purchases Try to minimize the purchasing of several products for the same or similar uses. For example, a single solvent may be appropriate for multiple applications where small 42 ------- volumes of different products were previously purchased and stored. Reducing the number of products purchased will also improve your inventory control. Return of Offgrade Materials to Vendors Contracts with vendors should include provisions to return offgrade raw materials to the vendor for rework or sale into a less sensitive end use. Your facility should not be responsible for disposal of offgrade materials. Periodic Review of Current and Alternate Vendors to Improve Flexibility and Assurance of Quality Supply Maintain High Quality Standards The purchasing agent should conduct frequent market surveys of raw materials to ascertain the best available suppliers. Maintaining competitiveness among suppliers allows the purchaser to negotiate for higher quality materials. Outdated Raw Materials Tight inventory control should be used to minimize the amount of outdated raw material in storage. Refer to Section 7.0 for suggestions on inventory control. In the event that raw materials become outdated, they should be reclaimed or sold to a waste exchange. 43 ------- Additional Opportunities Identified in Your Plant in the Area of Purchasing: 44 ------- 7.0 INVENTORY CONTROL Eliminate Losses From Outdated or Contaminated Raw Materials The purpose of carefully controlled inventory systems in a pollution prevention program is to minimize the creation of wastes from useable material. Inefficient inventory control systems and sloppy housekeeping are large contributors to the generation of waste in the warehouse. This section suggests practices that may improve this area of operation. Material Storage Overstocking of materials leads to extended storage with potential for raw material and product deterioration, resulting in increased waste. Aged raw materials may cause process or application inefficiency, or require rework, or disposal. Losses can also result from packaging damage caused by warehouse overcrowding, careless handling, or deterioration and from product damage caused by temperature variations or water. Opportunities exist for pollution prevention in this area through developing better sales and production forecasting and working with suppliers to improve their ability to deliver in a timely manner. First-ln/First-Out Inventory Scheme First-in/first-out is important for pollution prevention for the reasons outlined above. Opportunities exist in the design of an inventory control system to maximize first-in/first-out, develop better control of stock levels where multiple warehouses are involved, and use warehouse space better to minimize movements of stock. Uses for Aged Product To assist in moving aged products, encourage staff members who track the inventor/ system to communicate regularly and to update the status of product inventory to the sales/marketing staff. An improvement in the communication process can often reduce the amount of aged product that requires disposal and thereby improve profitability. Market Aged Inventory Waste Exchange Market Byproducts Maintain a tight inventory on the process byproducts and wastes, and provide marketing and sales staff with a list of byproducts that may be marketable. Byproducts generated by one process or facility can frequently be used in another process or facility. For example, acids generated in one process may be 45 ------- used to neutralize alkaline process waters in another. This procedure eliminates the generation of a potential waste. 46 ------- Additional Opportunities Identified in Your Plant in the Area of Inventory Control: 47 ------- 8.0 SALES/MARKETING Sales/Marketing Can Encourage Customers to Participate The most important function of the sales/marketing team in an active pollution prevention program is to provide the communication link between customer and company. The sales/marketing staff has the unique opportunity of publicizing and promoting your pollution prevention program to customers, encouraging them to support its goals, and increasing your customers' awareness of their own pollution prevention opportunities. The sales/marketing staff may recognize that benefits gained from pollution prevention efforts and company contributions to the environment are valuable marketing tools. Pollution prevention activities that create marketing advantages should be communicated and encouraged throughout the company. Consequently, a. high level of awareness exhibited by the marketing/sales staff should filter through all areas of your and your customer's business. Opportunities exist under each area of responsibility of the sales/marketing staff to contribute to the success of your pollution prevention program. The major responsibilities of the sales/marketing staff (next to meeting sales goals) include: Pollution Prevention is a Marketing Tool Informing the customer of all product benefits Communicating feedback.from the customer on quality, performance, and other requirements to the production and research and development staff Identifying pollution prevention-related sales opportunities Informing the Customer To market all product benefits, the sales/marketing staff should provide the customer with information that allows selection of products not only on performance but also on environmental criteria. In discussions with customers, the sales/marketing staff should consider the following: 48 ------- Packaging Product Characteristics Potential Waste Byproducts Technical Product Description New/Improved Products Using bulk deliveries for large quantities to reduce packaging Discouraging the use of partial containers by determining the quantity of product needed and the appropriate container size prior to placing an order Minimizing the need to transfer material between containers in the customer's drug room by selecting the correct container when filling an order Recycling or reusing empty containers Addressing substantivity and exhaust rates during - product selection Reducing dust emissions and improving the ease of handling by selecting liquid or other non-dusting forms of products over powder Addressing such parameters as salt-loading Selecting more concentrated products to reduce diluents and additives Minimizing such byproducts as heavy metals Distributing literature and training customers to optimize dye application processes and minimize waste Assisting in solving customers' waste management problems by identifying source reduction opportunities Promoting product development that provides pollution prevention opportunities for you and your customers Suggesting product substitutions where appropriate Promoting new application technologies that minimize waste generation. 49 ------- Communicating Feedback to Production and Research and Development Recognize Pollution Prevention Opportunities The sales force should provide Production and R&D with an accurate picture of product performance to support product improvement efforts. Product improvements and pollution prevention opportunities are not easily recognized unless the sales and marketing managers understand product characteristics and performance and have insight into customers' operations. To assist the sales/marketing team in recognizing pollution prevention opportunities, implement the following: Training for field personnel in methods to improve their communication between the customer and Production and/or R&D Scheduled meetings, between Marketing/Sales and Production/R&D to focus on pollution prevention opportunities Identifying Pollution Prevention-Related Sales Opportunities Pollution prevention opportunities may arise from spontaneous market situations that need to be recognized and quickly implemented. These opportunities may include: Sales possibilities for offgrade, slow-moving, or obsolete materials at markdown prices to avoid disposal or rework Identification of special markets for dyes based on isomeric byproducts Identification of markets for products previously classified as wastes, such as one-time black dyes made from dust collector residues Identification of exchange opportunities for wastes such as inorganic acids, which could be used by other industries for their neutralization needs and, thus, would not require treating by onsite neutralization and disposal. Waste Products May Be Sold For Profit 50 ------- Additional Opportunities Identified in Your Plant in the Area of Sales/Marketing: 51 ------- 9.0 DISTRIBUTION The process of distributing product can contribute to an increase in pollution. Several ways for the distribution staff to reduce the generation of waste are presented in this section. Handling and Storage Store raw materials and products at the proper Protect Raw Materials temperature, in dry conditions, and in sufficient space to optimize inventory control. This will prevent the generation of offgrade materials caused by damaged packaging. Avoid Packaging Waste Energy Efficient Shipping Work with marketing to encourage customers to purchase full containers and order early enough to minimize'special deliveries and air freighting. Develop schemes for bulk handling, bulk shipments, or extra large containers. i Reusable Containers One of the largest sources of solid waste in our plants and our customers' plants are empty containers. The distribution staff can help to reduce the amount of solfd waste generated by promoting the use of reusable containers along with a program for managing transport in an economic and energy-efficient manner. i Packing Materials i Packing materials are also a large source of solid waste. Opportunities exist to minimize this waste stream by using recyclable materials or materials that can be disposed of with a minimum effect on the environment. Control Inventory Age to Prevent Out-of-Date Materials See Section 7.0, Inventory Control, for opportunities in this area. 52 ------- Additional Opportunities Identified in Your Plant in the Area of Distribution: 53 ------- 10.0 FINANCE . The Finance Department has the very important role of Waste Costs tracking waste treatment and disposal costs for specific product manufacture. This information establishes a basis of comparison to allow effective implementation of pollution prevention strategies. Cost Accounting for Waste Treatment The Rnance Department should determine the actual cost per pound for waste and pollutant treatment, handling and disposal for each dye product, class of products, or unit operation at each location. It is important to know which operations carry the highest waste handling cost so that pollution prevention activities may initially be focused in that particular area. It is generally ineffective to assess costs for all treatment and disposal operations plant-wide. Instead, track the waste to its specific source to provide a clear understanding of where reduction may be most cost- effective. You can better justify a pollution prevention project if the true waste management cost associated with the product or process is known. Scrutinizing of "Full" Environmental Costs Your evaluation of environmental costs should not only include the direct costs (e.g., capital for treatment plants, labor and operational costs, and disposal costs) but also the indirect costs (e.g., expenses for regulatory staff, consultants, paperwork and potential litigation) and intangible costs (e.g., concerning public image). You should also consider the potential costs of any environmental liability associated with a treatment or disposal option. Cost Analyses to Identify Pollution Prevention Opportunities The Finance Department should provide cost figures to manufacturing and environmental staff to identify areas where pollution prevention could have the greatest impact and aid in the justification of pollution prevention projects. Recordkeeping Maintain complete records on the amount of waste reduction achieved and the savings that resulted from implementing a pollution prevention option. These records will be needed as you complete the Waste Reduction Survey and publicize progress. Consider Direct and Indirect Costs 54 ------- Special Accounts for Waste Minimization A portion of the capital budget should be set aside for pollution prevention projects. Establish rules for accessing this special capital account that are separate from those used for other budgets. Projects that use these funds should be justified by the volume of waste reduced and the efficiency of the pollution prevention option. You may be able to utilize profits from successful pollution prevention projects to fund other environmentally viable projects. Dedicated Funds 55 ------- Additional Opportunities Identified in Your Plant in the Area of Finance: 56 ------- 11.0 ENGINEERING Efficient Designs Waste is often generated unnecessarily because of inefficiencies in the manufacturing process that range from out- dated technologies and equipment to excessive distances for material transport. The engineering staff can contribute to the pollution prevention program by designing efficient facilities and equipment that minimize waste generation. Equipment Optimization The engineering staff should select the equipment that results in the least amount of waste generated by the process. They should recommend, for example, the use of external heating and cooling whenever possible so that waste, brine, or condensate can be recycled and the use of mechanical seals on pumps in place of packing to prevent leaks. In addition, equipment should be sized so that optimum batch sizes can be run. This procedure prevents reaction inefficiencies and excessive material loss in cleanup. Insufficient Agitation May Reduce Diazotization Yields Inefficient equipment may also increase waste volume. For example, incomplete diazotization of aromatic amines may be due to a lack of agitation and particle size reduction. The raw material lost to the waste stream may be hazardous, and there will be a yield loss'in final dyestuff. Unsuitable grinding equipment for reducing the particle size of the finished product may inhibit the ability of the dye to dissolve. Waste may be generated when dyestuff does not dissolve fast enough in the customer's dyebath. Technology Transfer The engineers who design and install new equipment should be intimately involved in both startup operations and situations in which the equipment is used for a significantly different operation or process. This will prevent errors that result in the generation of offgrade product. Careful training of operators will also ensure maximum reaction efficiency when the equipment is turned over to manufacturing operators. Industrial Engineering and Work Practices Prevent Offgrade Generation Using industrial engineering practices, engineers should analyze existing manufacturing operations to ensure that standard work practices are optimized to 57 ------- Reduce Solvent Use reduce waste. . Possible areas to study include the management of press cakes, dried crude dyes, and containers. Design of Easv-to-Clean Equipment One of the potentially largest waste streams is cleanup water or solvents. Engineers can assist in the reduction of this waste stream by designing equipment that is free of hard-to-reach areas or allows for special access to these areas. In large equipment, spray nozzles for washing should be included in the design. Additionally, recommended cleaning procedures should be included as part of the equipment's operating instructions to avoid the overuse of wash waters and/or solvents. Equipment Maintenance Routine maintenance and repair of equipment is a valuable means of preventing releases to the environment. Regular maintenance extends equipment life and prevents (oss of efficiency and breakdowns that might result in lost batches requiring disposal.' Written procedures should be established for regularly checking the calibration and accuracy of instruments, such as thermometers, pH meters, flow- meters, level indicators, and scales. Attention should be given to piping connections, flanges, pump seals, and glass lining integrity. These procedures ensure that equipment is accurately maintained and replaced when needed, and optimum production efficiency is obtained. 58 ------- Additional Opportunities Identified in Your Plant in the Area of Engineering: 59 ------- 12.0 UTILITIES Energy Use Affects Air, Water, Land, and Public Health The environmental impacts of energy consumption are far-reaching, affecting air and water quality, land use, and public health. C02 concentrations in the atmosphere are increasing primarily from the burning of fossil fuels in power plants, factories, and cars. Energy-consuming equipment in plants includes grinding equipment, compressors, HVAC equipment, lights, appliances, fans, pumps, agitators, and controls. Prevention in energy usage means pursuing practices that reduce emissions through the use of conservation methods and clean, renewable sources of energy when feasible. Lighting accounts for approximately 20% of the energy we use nationally. There are many opportunities to conserve energy in every facility. It has been estimated that we could save 44 percent of the energy used to drive electric motors simply by switching to the high efficiency models available on the market today. Using the best available technology, we can reduce energy consumption from lights by up to 92 percent u (according to a study by the Rocky Mountain Institute). We can cut down on the pollutants emitted from burning coal and oil by switching to cleaner fuels, such as natural gas and solar energy. Implicit in these environmental benefits is the economic benefit derived from reduced fuel consumption. Water: An Irreplaceable Resource Much of our water is unavailable for desired uses' because of inadequate quality or inaccessibility. Water usage has many environmental impacts that can be avoided or minimized with proper management. Excessive surface water withdrawal affects the ecology of streams and streamflow. Continued groundwater withdrawal may result in the spreading of contaminant plumes, saltwater intrusion, and reduced streamflow with accompanying ecological effects. Return flows introduce toxins and other contaminants to natural systems. Some water uses have pollution impacts through accompanying energy use, such as hot water heating and water pumping. Effective water management includes use reduction, recycling and wastewater reclamation, and reuse. Benefits include avoidance and/or downsizing of water treatment construction projects, reduced costs for wastewater treatment due to decreased expenditure for chemicals and electricity, and reduced water and energy bills. Current water-saving technologies, along with no-cost procedural changes, can achieve considerable savings in operating costs without requiring significant changes in production methods. 60 ------- Suggestions on ways to make your plant operate at its highest possible efficiency are given below. Consider posting some of these ideas so that your employees will remember to work each day toward achieving the plant's pollution prevention goals. Reduce Costs, Avoid Treatment Projects, Reduce Treatment Chemicals Choose the best utility for the job (e.g., steam for heating). Promote multiple use of utilities (e.g., reuse of cooling water, reclamation, and reuse of waste heat). Consider implementing solar heating when building or remodeling. . Use more efficient equipment and cleaner fuels. Promote energy efficiency. Turn off lights and equipment when not in use. Change equipment cleaning procedures to minimize water consumption. Conduct periodic maintenance of equipment to ensure peak efficiency. Replace aging equipment with more energy-efficient models. ' Replace light bulbs and fixtures with new, high-efficiency products. 61 ------- Additional Opportunities Identified in Your Plant in the Area of Utilities: 62 ------- BIBLIOGRAPHY Evaluation of Measures Used to Assess Pollution Prevention Progress in the Industrial Sector. Final Report. U.S. EPA, Office of Pollution Prevention. January 1991. 56 pp. Available from Jim Craig, U.S. EPA Office of Pollution Prevention, 401 M Street S.W. (PM-222B), Washington, D.C. 20460. Phone (202) 245-4168. • Pollution Prevention Training Opportunities in 1991. U.S. EPA, Office of Policy, Planning, and Evaluation and Office of Research and Development. March .1991. 85 pp. Available from Pollution Prevention Information Clearinghouse (PPIC) Technical Support, SAIC, 7600-A Leesburg Pike, Falls Church, Virginia, 22043. Phone (703) 821-4800, FAX (703) 821- 4775. U.S. EPA Pollution Prevention Strategy. U.S. EPA, Office of Policy, Planning, and Evaluation. January 1991. 45 pp. Available from PPIC Technical Support, SAIC, 7600-A Leesburg Pike, Falls Church, Virginia, 22043. Phone (703) 821-4800, FAX (703) 821-4775, or from the U.S. EPA Office of Pollution Prevention, 401 M Street S.W. (PM-222B), Washington, D.C. 20460. Phone (202) 245-4167. Waste Minimization Opportunity Assessment Manual. U.S. EPA, Hazardous Waste Engineering Research Laboratory (EPA/625/7-88/003). July 1988. 100 pp. Available from PPIC Technical Support, SAIC, 7600-A Leesburg Pike, Falls Church, Virginia, 22043. Phone (703) 821-4800, FAX (703) 821 4775. Pollution Prevention Benefits Manual: Volume 1 (DRAFT). U.S. EPA, Office of Solid Waste and Office of Policy, Planning and Evaluation. October 1989. 92 pp. Available from PPIC Technical Support, SAIC, 7600-A Leesburg Pike, Falls Church, Virginia, 22043. Phone (703) 821-4800, FAX (703) 821-4775. "Pollution Prevention Act of 1990" Available from the U:S. EPA Office of Pollution Prevention, 401 M Street S.W. (PM-222B), Washington, D.C. 20460. Phone (202) 245-4167. For a complete list of documents distributed by the U.S. EPA Pollution Prevention Information Clearinghouse, contact SAIC at above address. ------- APPENDIX A ------- ETAD/EPA POLLUTION PREVENTION/WASTE REDUCTION PROJECT WASTE REDUCTION SURVEY Executive Overview: In its Pollution Prevention Guidance Manual, the ETAD/EPA project task force has provided you with a comprehensive description of waste reduction opportunities in the dye manufacturing industry. The Waste Reduction Survey presented in this package will be the first step in the implementation of a pollution prevention program which should be carried out for the next two years and beyond, resulting in waste reductions that can be quantified and reported on an industry wide basis. The survey has three parts, each complete with a set of instructions: I. 'Opportunity Assessment II. Case Studi-es (optional) III. Waste Generation Data Each member company is expected to complete the survey by February 28, 1992. and send it to Dr. Tucker Helmes, Executive Director, U.S. Operating Committee of ETAD, 1330 Connecticut Avenue, NW, Suite 300, Washington, DC 20036. ' Your response to this survey will be evaluated and aggregated into the first annual waste reduction report of the dye manufacturing industry. Response to parts I and II will provide an overview of industry pollution. prevention practices and projects already established. Values reported in part III will be used to establish the quantity of waste generated by the industry in all media based on total annual dye production and chemical usage for the base year. The project task force recognizes the potentially proprietary nature of some of the information collected as part of this survey. While we encourage member companies to provide as many answers as possible on a nonconfidentia1 basis, we assure strict confidentiality for all information so marked by the responder. We expect confidential information to become a concern only in part III-A, Waste Generation Data/Dye Production information. For part II of the survey, we feel that evaluating and handling confidential case studies is impractical and provides little usable information. Under part III-A, we have tried to design the reporting forms to minimize the need for confidential information. Thus we have eliminated any dye identification, and request only submission of the Summary Production Forms (companies retain the underlying worksheets). We hope that member companies will provide their responses in a timely and complete manner. This waste reduction survey and the subsequent annual reports will help demonstrate the dye industry's efforts to reduce waste. Tne quality of this survey and the direction provided to our industry's waste reduction efforts over the next few years depend upon the care taken by you in answering each question. Thank you for your cooperation. ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT This part of the survey corresponds to the organization of the Guidance Manual. We suggest that you use the manual as a reference when completing this form. Part I of the survey should cover all of your waste reduction programs regardless of the year of implementation. The assessments will be conducted annually to monitor the overall dye manufacturing industry progress in waste reduction. For each department or area of operation addressed in the Guidance Manual, we have listed the corresponding waste reduction opportunities. Please provide an evaluation of the status of programs or projects involving waste reduction a-t your site for each of these opportunities. Please evaluate and enter your waste reduction activity status for each box. Additional activities not covered by the Guidance Manual or this survey should be entered •in the blank boxes provided at the end of each operation component section. For evaluation of waste reduction activity status, please choose the appropriate value (number and alpha) from the list below, and enter in the first column. You may want to further characterize the reduction activity in the remark column. Waste Reduction Activity Status ' • 1. Assessing Reduction Opportunities 2. Developing Reduction Program 3. Implementing Reduction Program 4. Reduction Program in Place 5. Reduction Program in Place and Evaluated Against Objectives 6. Not Applicable - if checked, classify as follows: a. Ho such operation b. °- '--- J r- - c. d. e. f. NO sucn operation Rejected for economical reasons Rejected - not technically feasible Rejected - low impact/development resources not presently ava i lab le Regulatory and/or institutional barrier Other Completing this Form Separate the individual Haste Reduction Opportunity Assessment Forms and have them completed by the appropriate, department at your site. This will ease the workload and allow each individual to complete that section of the form which falls into his/her area of responsibility and expertise. . A completed sample page is provided as part of these instructions. Please copy these instructions and the sample page as necessary to distribute with the individual forms. ------- Impediments to Waste Reduction Opportunity EPA and ETAD are interested in learning about regulatory and institutional barriers encountered during your efforts to develop waste reduction programs. Please describe the nature and effect of any impediments on an additional page and include this with your completed survey. On your opportunity assessment form the activity status for an impediment should be entered as "6.e" (not applicable - regulatory and/or institutional barrier); you may also use the remark box to refer to your separate case description. Impediment Example In an effort to better utilize its raw materials and reduce waste water (volume and loading), High Tech Dye Company (HTDC) tried to replace a-wet scrubber operation with a dry filter bag housing, allowing the fines collected to be recycled into the manufacturing process, the bag house was to be installed on the roof of the mill, but HTDC could not obtain a permit from the local authorities. This situation can be described under OPERATION COMPONENT 4.1, Raw Material Receiving and Charging/Material Transfer. The appopriate entry is shown on the Sample Page of the Waste Reduction Opportunity Assessment Form. ------- Activity Status SAMPLE ONLY PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.1 RAW MATERIAL RECEIVING AND CHARGING/MATERIAL TRANSFER Waste Reduction Opportunity Remarks EMPTY CONTAINERS I. 4. 5. • 5. 5 Container aDe hng * Operator training on handling Reuse Recycle Bulk supply and/or containers RESIDUAL RAW MATERIALS 4. 1. Operator training Container selection EMISSIONS/RELEASES b.e 6.e Scrubber se iect ion/use ot cyciones or f i 1 ter baas Recycle or reuse of collected fines Impediment identif (see extra pace) impediment identif (see extra paqe) led ied Waste Reduction Activity Status 1. Assessing Reduction Opportunities 2. Developing Reduction Program 3. Implementing Reduction Program 4. Reduction Program in Place 5. Reduction Program in Place and Evaluated Against Objectives 6. Not applicable - if checked, classify as follows: a. No such operation b. Rejected for economical reasons c. Rejected -not technically feasible d. Rejected - low impact/development resources not presently a va i lab le — e. Regulatory and/or institutional barrier f. Other ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.0 PRODUCTION Waste Reduction Opportunity Remarks GOOD INDUSTRIAL PRACTICES Raw materials verification Container handling procedures Spill prevention procedures Return of spilled materials to process Operator training on procedures Regular maintenance scnedules for equipment and instruments Standard procedures for updating operatinq instructions PROCESS ASSESSMENTS Periodic review of process Hydraulic load reduction Clean up minimization Control of process water usage OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.1 RAW MATERIAL RECEIVING AND CHARGING/MATERIAL TRANSFER Waste Reduction Opportunity Remarks EMPTY CONTAINERS lonta i ner Operator lace i i ing training on hand i ing Reuse Recycle Bulk supp ly and/or containers j RESIDUAL RAW MATERIALS Operator training Container selection FRANSFER OPERATIONS Equipment maintenance Operator training Equipment selection [MISSIONS/RELEASES Scrubber se ection/use ot cyclones or f i Her baas Recycle or reuse of collected tines JTHER OPPORTUNITIES ------- Activity Status GENERAL PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORH 4.2 SYNTHESIS Waste Reduction Opportunity Remarks btoichiometry BOD load Wash water recycle Gases released Cycle times Temperatures By-products - reuse or sell Spilled materials management Off grade production control Emptying of raw material containers 'Hatching of equiment to process Indirect, heating and cooling Scrubber efficiency OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.3 ISOLATION/FILTRATIONS Waste Reduction Opportunity Remarks PRECIPITATING AGENTS Usage Selection TEMPERATURE/VOLUME CONTROL Temperature optimization Temperature maintenance Proper instrumentation Control of steam and ice usage Use of indirect heat source REUSABLE FILTER MEDIA Cloth selection Filter aid selection Equipment and media se lection LEAK ELIMINATION Operator training on set up Filtration procedures Leak detection procedures Recycle during filtration start up (Cont'd) ------- 4.3 ISOLATION/FILTRATIONS - (Cont'd) Activity Waste Reduction Opportunity Remarks Status FILTER WASH END POINTS tnd points tests FILTER WASH WATER REUSE wash water reuse procedures ^ASH-SOAK AND RINSE PROCESS Use of soak and rinse process •ILTER PRESS SLOWDOWN Slowdown process efficiency More efficient, equipment ?RODUCT TRANSFER Filter dumping equipment Operator training UGH PRESSURE SPRAY Clean-up equipment selection ' )THER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.4 DRYING Waste Reduction Opportunity Remarks ENERGY CONSUMPTION Periodic energy audit Temperature optimization Temperature control Product moisture control , Alternative drying process Recycle of dryer heat Equipment insulation Drying techniques Maximize product moisture contents HEAT TRANSFER Dryer loading Techniques to sol ids techniques increase dryer feed Heating element cleaning Dryer design Preventative maintenance program (Cont'd) ------- 4.4 DRYING - (Cont'd) Activity Status Waste Reduction Opportunity Remarks MATERIAL LOSSES Dryer loading equipment Scrubber/cyclone/filter bag selection for reeve linq of fines Deduster use Dryer dumping techniques Alternative drying processes Production campaign length and schedul inq Equipment washing techniques Drying batches without isolation Reuse of rinses into product OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.5 GRINDING Waste Reduction Opportunity Remarks WASTE MATERIALS Recycle. or reuse collected dust Reduce product dustiness Improve on use of deduster Improve dust collecting Formulate and grind to minimize screen blockaqe Equipment selection Use of new technology Media selection Material transfer WASTE WATER REDUCTION Pump sea Is Co 1 lection and recyc le Washing procedures Cooling water recycle j Seal selection and maintenance Waste water monitoring (Cont'd) ------- Activity Status 4.5 GRINDING - (Cont'd) Waste Reduction Opportunity REDUCTION OF EMISSIONS Remarks Reduce product dustiness Improve dust collection Material transfer Grinder feeding REDUCTION OF ENERGY USAGE Optimize product size requirements Control grinding times Optimize grinding temperatures Optimize media Automate control of cooling Recycle coo 1 ing ^ater Optimize product formulations for concentration and viscosity Optimize media charges i i OTHER OPPORTUNITIES ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM Activity Waste Status MATERIAL HANDLING Emp loyee tra Equipment se 4.6 BLENDING Reduction Opportunity Remarks in i ng lection DUST COLLECTION Equipment se or reuse lection to a Mew recycle 3LENDING METHOD Equipment design Optimization or product to equipment 3LEND SIZE bchedu i ing bize or D lend 3EDUSTING MATERIALS Training to avoid excess use Deduster addition ------- 4.6 BLENDING - (Cont'd) Activity Status Waste Reduction Opportunity Remarks SOLUTION FILTRATION equipment selection Equipment sizing Cleanup procedures Optimize product formulations OTHER OPPORTUNITIES ------- Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.7 SAMPLE TAKING AND WEIGHING Waste Reduction Opportunity Remarks SAMPLE TAKING bamp I ing procedures Sample size Sample return or reuse - - WEIGHING Weigh station design Operator training Automated packaging stations Standardize purchasing for batch sizes OTHER OPPORTUNITIES ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.8 EQUIPMENT CLEANOUT Activity Waste Reduction Opportunity Remarks Status CLEANOUT washout procedures Operator training MONITORING WATER USAGE Monitoring ot //ashing •IIGH PRESSURE CLEANING Equipment selection •MSHWATER REUSE Sequencing use Reuse Recycle rREQUENCY OF CLEANOUT Schedu I ing Amount of cleanup required 3THER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 4.9 PACKAGING Waste Reduction Opportunity Remarks ALTERNATIVE PACKAGING Materials tnat allow reuse or reeve 1 inq Bulk or semi-bulk shipping Customer market forecasting Limit container sizes Limit container types " PACKAGING TECHNOLOGY Packaging station design Maximize product bulk density Packaging design for reduction of worker exposure STORAGE AND WAREHOUSING Warehouse, des ign Warehouse operat ing procedures Repackaging minimization Worker training Inventory rotati on OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORK 5.1 PRODUCT DEVELOPMENT Waste Reduction Opportunity Remarks Product suost i tutions Efficiency of dyes and application processes Concentration of active ingredient Development of new molecules Environmentally safe diluents byntnesis routes Process changes. New production processes Pi lot plant trials Solvents and reactants Minimum filtration requirements Raw materials Maximum reactant concentrations Reaction yields OTHER OPPORTUNITIES ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 5.2 LABORATORY PRACTICES Activity Status Waste Reduction Opportunity Remarks 1 bamp le sizes Laooratory cnermcal supply Unused chemicals and products Recyclable solvents Small-scale laboratory equipment Spill clean up Reusaoie laooratory equipment OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 6.0 PURCHASING Waste Reduction Opportunity Remarks Purchase recycled products Container selection Raw material quality assurance Return of off-grade materials Periodic review of alternate vendors Outdated raw materials OTHER OPPORTUNITIES ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 7.0 INVENTORY CONTROL Activity Status Waste Reduction Opportunity Remarks Minimize storage age First in/first out inventory scheme Uses for aged product Waste exchange OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 8.0 SALES/MARKETING Waste Reduction Opportunity Remarks Informing customers Feedback to production and R&D Pollution prevention sales opportunities • • . ' OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 9.0 DISTRIBUTION Waste Reduction Opportunity Remarks Harm I ing ana storage Energy efficient shipping Reusable container Packaging materials • OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 10.0 FINANCE Waste Reduction Opportunity Remarks Cost accounting tor waste treatment Full environmental cost determinations Cost analyses to identify pollution prevention opportunities ftecordkeeping of waste reductions Special accounts for waste minimization . OTHER OPPORTUNITIES ------- Activity Status PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 11.0 ENGINEERING Waste Reduction Opportunity Remarks Lquipment optimization Technology transfer Industrial engineering practices and work Design easy-to-clean equipment Equipment maintenance i OTHER OPPORTUNITIES ------- PART I - WASTE REDUCTION OPPORTUNITY ASSESSMENT FORM 12.0 UTILITIES Activity Waste Reduction Opportunity Status Remarks Llectncity conservation Water conservation 3THER OPPORTUNITIES ------- PART II - WASTE REDUCTION CASE STUDIES In developing a pollution prevention program for the dye manufacturing industry, ETAD member companies were concerned that past waste reduction efforts would not be represented in the overview of the industry's performance reported in part I of the Waste Reduction Survey. Part II of the survey therefore allows companies to report on existing or completed waste reduction projects in the form of case studies. In general you should generate a case study on programs identified and evaluated in the Waste Reduction Opportunity Assessment Form (part I of this survey) with an activity status of 5". In your case study, provide a one- or two- paragraph description of the program, identifying the type and quantity of waste reduction, and quantifying (if applicable) the following: o investment o cost impact o cost savings (on an annual basis). You should also include any planned measures to 'improve the program. A sample case study is provided as part of these instructions. Confidentiality: Please keep in mind Ithat case' studies marked as confidential cannot be used in any ETAD report on waste reduction activities. You may want to consider presenting the major 'thrust of a specific pollution prevention program on a nonconfidential basis, leaving out confidential details (e.g., linkage of the opportunity to a specific dye or dye class). ------- SAMPLE ONLY PART II - WASTE REDUCTION CASE STUDY Drum Reeve 1 ing Timeframe: Program description: Waste Reduced: Environmental effect: (Area of Operation 9.0, Distrbution, from Waste Reduction Opportunity Assessment Form) Ongoing'program started in 1987 Customers send empty drums for cleaning and reconditioning. Drums are reused as many times as possible. Although cleaning the drums produces additional waste water whicn needs to be treated, the overall environmental effect will be favorable. Empty polyethylene drums sent to landfill Reduction in landfill use Reduction in residual dyes going to landfill Reduction in plastic material consumption Reduction in potential liability for drums left to unauthorized use. Quantification: * Net reduction of drums Number being sent to landf i 1 1 : Wt(lbs. * Total savings in $: Detail: Cost of new container less: 1987 1988 1989 1990 1991 25,000 30,000 35,000 40,000 550,000 660,000 770,000 880,000$_ _ reconditioning, additional shipping \$_ Net savings per drum ------- PART III - WASTE GENERATION DATA This compilation of waste generation data is divided into three sections. Section A requests confidential and nonconfidential • information regarding total and individual dye production and raw material consumption which will be used to calculate and index the annual reduction of chemical wastes generated. Section B requests information on the types and volumes of solid and liquid wastes, air emissions, and utility usage. Section C requests information from your site s Toxic 'Release Inventory reports (TRI-SARA Section 313). The information reauested is for the years 1987-1990. o A survey should be completed for each of your company's U.S. dye manufacturing sites. Report only on your dye manufacturing activities. o For each category, provide actual quantities, in pounds. o Where values are .not available (because they were not measured in the past), enter N/A. 'o Where values are not measured presently enter N/M. o Code numbers, wherever provided to protect anonymity, will be entered by the reviewer. ------- SECTION A: DYE PRODUCTION INFORMATION Section A of the Waste Generation Form is divided into two parts. The first is designed to provide an overview of the reduction of total chemical waste from production operations by comparing the total pounds of dye produced to the pounds of raw materials used for any given year to a base year and the previous year. Index formulas are provided to compensate for changes in production volume. The second part will evaluate waste generation patterns associated with individual products through information on 21 specific dyes. Based .on 1990 production volumes, select for each site the following dyes: * * the seven highest-volume orcducts; the product at the 60% volume percentile and the six next lower in vo lume ; * the product at the 30% volume percentile and the six next lower in vo 1 ume . In subsequent years, report on the same 21 products. A completed set of worksheets is enclosed as an example to assist you in completing this section. When completing the reports for total production or individual dyes, the following guidelines apply: Do not include water or ice; Include solvents as part of the organic chemicals used but report only the net use (loss) of solvent. If possible use 1987 as the base year; if not, indicate which year is used in the report. Also, be sure to provide waste reduction calculations comparing, wherever possible, the current year against the base year and the year prior to the current year to track annual progress in ongoing programs. Complete one report form (copy as needed) for each individual dye. The attached worksheets and examples should help you to complete this section without problems. You do not need to return worksheets with your completed forms. For this first survey, you may not be able to complete section A if you choose 1990 as your base year. In that case supply only the data available for 1990 on total production and do not report on individual dyes for which you do not have previous year data. Hake sure you mark any pages you wish to keep confidential. ------- Confidentiality: The report forms provided with section A are designed to keep confidential reporting and subsequent handling of confidential information to a minimum. * You are not required to identify any dye by name or generic class. Instead, you merely rank your 21 individual dyes as outlined above. * Your individual dye production and raw material use will be kept confidential if requested. * The Annual Waste Reduction values will be used to generate the industry reports, but will not be linked to the name of the reporting company. Rather, companies will be assigned a code number for identification. ------- COMPANY XYZ WORK SHEET WASTE GENERATION DATA SECTION A - TOTAL DYE PRODUCTION SITE Mill Town PRODUCTION VOLUME YEAR Ibs Saleable Ibs Organic Ibs Inorganic Ibs Diluents Total Ibs Dye . Chemicals Chemicals • & Binding of Produced Used Used Agents Used Chemical (Adjuvants) Used I¥ase) 1989 1990 3,550,000 4,000.000 3,900,000 2,100.000 2,310,000 2,240,000 4.450.000 4,700.000 4,350,000 975,000 7,525.000 AI = ANNUAL INDEX = (1990) Current Year Production Previous Year Production PI = (1990) PROJECT INDEX = Current Year Production Base Year Production 1,100,000 1.200,000 3,900,000 4,000,000 3,900,000 3,550,000 8,110,000 7,790,000 = 0.975 1.099 POUNDS OF WASTE REDUCED ARW = Annual Ibs of reduced waste = (Ibs chemicals used in previous year x AI (Ibs) PRW = Project Ibs of reduced waste = (Ibs) (1990) ARW Total Chemicals (Ibs) (8,110,000 x ARW Organic Chemicals (2,310,000 x ARW Inorganic Chemicals (4,700,000 x ARW Adjuvants (1.100,000 x (1989) PRW Total Chemicals (7,525,000 x PRW Organic Chemicals (2,100,000 x PRW Inorganic Chemicals (4,450,000 x PRW Adjuvants ( 975.000 x - Ibs chemicals used in current year Ibs chemicals used in base year x PI) - Ibs chemicals used in current year (AI) '(Ibs) (Ibs) 0.975 ) - 7,790,000 = 117.250 0.975 ) - 2,240,000 = 12,250 Q.975 ) - 4,350,000 = 232,500 0.975 ) - 1.200,000 =-127.500 (PI) 1.099 1.099 .) - 7.790.000 = 479,975 .) - 2,240,000 = 67,900 1.099 ) - 4,350,000 = 540,550 1.099 ) - 1.200.000 =-128.475 ------- (Cont'd) WORK SHEET (CONT'D) SECTION A - TOTAL DYE PRODUCTION WASTE REDUCTION-PERCENTAGE CHANGE ARW X 100 PARW = % ANNUAL CHANGE IN WASTE = Ibs CHEMICALS X AI USED IN PREVIOUS YEAR PRW ' X 100 PPRW = % PROJECT CHANGE IN WASTE = Ibs CHEMICALS X PI USED IN BASE YEAR 117,250 X 100 PARW TOTAL CHEMICALS = = 1.48 % (1990) 8.110,000 X 0.975 12,250 X 100 PARW ORGANIC CHEMICALS = = 0.54 % (1990) 2.310.000 X 0.975 ' 232,500 X 100 ' PARW INORGANIC CHEMICALS = = 5.07 % (1990) • 4,700,000 x 0.975 -127,500 X 100 PARW ADJUVANTS = = -11.89 % (1990) 1,100,000 X 0.975 479,975 X 100 PPRW TOTAL CHEMICALS = = 5.80 % (1990) 7,525,000 X 1.099 67,900 X 1.00 PPRW ORGANIC CHEMICALS = = 2.94 % (1990) 2,100.000 X 1.099 540,550 X 100 PPRW INORGANIC CHEMICALS = = 11.05 % (1990) 4.450.000 X 1.099 -128,475 X 100 PPRW ADJUVANTS = = -12.01 % (1990) 975,000 X 1.090 ------- WORK SHEET WASTE GENERATION DATA SECTION A - INDIVIDUAL DYE PRODUCTION YEAR TBTSl 1989 1990 COMPANY DYE Ibs Saleab Dye Produced 24.000 •) 256,000 128,000 XYZ A le ibs Organic Chemicals Used 6,764 67,640 33,820 SITE Mil 1 Town VOLUME PERCENTILE 25 Ibs Inorganic Chemicals Used 34.640 .357.000 175,000 , Ibs Diluents & Binding Agents Used (Adjuvants) 16.600 138,000 70,000 Total Ibs of Chemical Used 58.004 562,640 278,820 AI = ANNUAL INDEX Current Year Production 128, 000 n qn (1990) Previous Year Production 256,000 Current Year Production 128,000 PI = PROJECT INDEX = : = (1990) Base fear Production 24,000 POUNDS OF WASTE REDUCED 5.333 ARW = Annual Ibs of reduced waste = (Ibs) ibs chemicals used in previous year x AI) - Ibs chemicals used in current year PRW = Project Ibs of reduced waste = (Ibs chemicals used in base year x PI) (Ibs) - Ibs chemicals used in current year (Ibs) ( (1990) ARW Total Chemicals ( ARW Organic Chemicals ( ARW Inorganic Chemicals ( ARW Adjuvants ( (1990) PRW Total Chemicals ( PRW Organic Chemicals ( PRW Inorganic Chemicals ( 34,640 PRW Adjuvants (Ibs) 552,640 x 67,640 x 357,000 x 138.000 x 58,004 x 6,764 x 34,640 x 16,600 x (AI) 0.5 0.5 0.5 0.5 (PI) 5.333 5.333 5.333 5.333 (Ibs) ) - 278,820 ) - 33,820 ) - 175,000 ) - 70.000 ) - 278.820 ) - 33,820 ) - 175,000 ) - 70.000 (Ibs) = 2,500 0 = 3,500 = -1.000 = 30,515 = 2,252 = 9,735 = 18,528 (CONT'D) ------- WORK SHEET (CONT'D) SECTION A - INDIVIDUAL DYE PRODUCTION WASTE REDUCTION PERCENTAGE CHANGE (DYE A) ARW X 100 PARW = % ANNUAL CHANGE IN WASTE - Ibs CHEMICALS X AI USED IN PREVIOUS YEAR PRW X 100 PPRW = % PROJECT CHANGE IN WASTE = Ibs CHEMICALS X PI USED IN BASE YEAR 2,500 X 100 PARW TOTAL CHEMICALS = = 0.89 % (1990) 562,640 X 0.5 0 X 100 PARW ORGANIC CHEMICALS = (1990) 67.640 X 0.5 3,500 X 100 PARW INORGANIC CHEMICALS = = .1.96 % (1990) 357,000 X 0.5 -1,000 X 100 PARW ADJUVANTS = = -1.45 % (1990) 138.000 X 0.5 30,515 X 100 PPRW TOTAL CHEMICALS = = 9.30 % (1990) 58,004 X 5.333 2,252 X 100 PPRW ORGANIC CHEMICALS = = 6.25 % (1990) 5,764 X 5.333 9,735 X 100 PPRW INORGANIC CHEMICALS = = 5.27 % (1990) 34,640 X 5.333 18,528 X 100 PPRW ADJUVANTS = = 20.94 % (1990) 16.600 X 5.333 ------- COMPANY WORK SHEET WASTE GENERATION DATA SECTION A - TOTAL DYE PRODUCTION SITE PRODUCTION VOLUME YEAR T&ase) Ibs Saleable Ibs Organic Dye Chemicals Produced Used Ibs Inorganic Chemicals Used Ibs Diluents & Binding Agents Used (Adjuvants) Total Ibs of Chemical Used AI = ANNUAL INDEX = Current Year Production Previous Year Production PI = PROJECT INDEX = Current Year Production Base Year Production POUNDS OF WASTE REDUCED ARW = Annual Ibs of reduced waste = (Ibs chemicals used in previous year1 x AI) (Ibs) PRW = Project Ibs of reduced waste = (Ibs) (Ibs) ARW Total Chemicals ( ARW Organic Chemicals ( ARW Inorganic Chemicals ( ARW Adjuvants ( PRW Total Chemicals (. PRW Organic Chemicals (. PRW Inorganic Chemicals (. PRW Adjuvants (. x x x x - .Ibs chemicals used in current year Ibs chemicals used in base year x PI) - Ibs chemicals used in current year 'AI (Ibs) (Ibs) (PI) (Cont'd) ------- WORK SHEET (CONT'D) SECTION A - TOTAL DYE PRODUCTION WASTE REDUCTION-PERCENTAGE CHANGE ARW X 100 PARW = % ANNUAL CHANGE IN WASTE = Ibs CHEMICALS X AI USED IN PREVIOUS YEAR PRW X 100 PPRW = % PROJECT CHANGE IN WASTE = Ibs CHEMICALS X.PI USED IN BASE YEAR X 100 PARW TOTAL CHEMICALS = (1990) X X 100 PARW ORGANIC CHEMICALS = (1990) X X 100' PARW INORGANIC CHEMICALS = (1990) X X 100 PARW ADJUVANTS = (1990) X X 100 PPRW TOTAL CHEMICALS = (1990) X X 100 PPRW ORGANIC CHEMICALS = (1990) X X 100 PPRW INORGANIC CHEMICALS = (1990) X X 100 PPRW ADJUVANTS = (1990) X ------- WORK SHEET WASTE GENERATION DATA SECTION A - INDIVIDUAL DYE PRODUCTION YEAR TTOF) COMPANY DYE Ibs Saleable Dye Produced SITE VOLUME PERCENTILE Ibs Organic Chemicals Used Ibs Inorganic Chemicals Used Ibs Diluents & Binding Agents Used (Adjuvants) Total Ibs of Chemical Used AI = ANNUAL INDEX = (1990) Current Year Production Previous Year Production Current Year Production PI = PROJECT INDEX = (1990) 3ase Year Production POUNDS OF WASTE REDUCED ARW = Annual Ibs of reduced waste = (Ibs chemicals used in'previous year x AI) (Ibs) ' - Ibs chemicals used in current year PRW = Project Ibs of reduced waste = (Ibs chemicals used in base year x PI) (Ibs) (Ibs) - Ibs chemicals used in current year (AI) (Ibs) (Ibs) ARW Total Chemicals (. ARW Organic Chemicals (. ARW Inorganic Chemicals (_ ARW Adjuvants (. i PRW Total Chemicals (. PRW Organic Chemicals (. PRW Inorganic Chemicals (. PRW Adjuvants (. x x x x x x x x (PI) ------- WORK SHEET (CONT'D) SECTION A - INDIVIDUAL DYE PRODUCTION WASTE REDUCTION PERCENTAGE CHANGE (DYE A) ARM X 100 PARW = '% ANNUAL CHANGE IN WASTE = Ibs CHEMICALS X AI USED IN PREVIOUS YEAR PRW X 100 PPRW = % PROJECT CHANGE IN WASTE = Ibs CHEMICALS X PI USED IN BASE YEAR X 100 PARW TOTAL CHEMICALS = (1990) X X 100 PARW ORGANIC CHEMICALS = (1990) • X X 100 PARW INORGANIC CHEMICALS = —, (1990) . X __ X 100 PARW ADJUVANTS = (1990) X X 100 PPRW TOTAL CHEMICALS = (1990) X X 100 PPRW ORGANIC CHEMICALS = (1990) X X 100 PPRW INORGANIC CHEMICALS = (1990) X X 100 PPRW ADJUVANTS— (1990) X ------- Code No. ^^_T__ (will be fi I led in 6y reviewer) WASTE GENERATION DATA SECTION A - TOTAL PLANT PRODUCTION REPORT FORM COMPANY YEAR SITE Ibs Saleable Product Produced Ibs Organic Chemicals Used Ibs Inorganic Chemicals Used Ibs Diluents & Binding Agents Used (Adjuvants) Total Ibs of . Chemicals Used AI = PI = Total Chemicals Organic Chemicals Inorganic Chemicals Adjuvants ARW (Ibs) PRW (Ibs) PARW (%) PPRW (%) * Company name and site will be coded to protect anonymity. Report will be generated only by using Code Number. ------- Code No. ^^_^__ (will be filled in by reviewer) WASTE GENERATION DATA SECTION A - INDIVIDUAL DYE PRODUCTION AND RAW MATERIAL USE REPORT FORM* COMPANY SITE VOLUME PERCENTILE YEAR Ibs Saleable Ibs Organic Ibs Inorganic Ibs Diluent Total Ibs Dye Chemical Chemical & Binding Chemicals Produced Used Used Agents Used Used (Adjuvants) TWST) AI = PI = * All data on this form *ill be kept confidential if requested, ------- COMPANY Code No. __^^_ (will be filled in by reviewer) WASTE GENERATION DATA SECTION A - INDIVIDUAL DYE REPORT FORM * SITE VOLUME PERCENTILE ARW (Ibs) - PRW (Ibs) = PARW (%) = PPRW '(%) = Tota-1 Organic Inorganic Chemicals Chemicals Chemicals Adjuvants * Company names and site will be coded to protect anonymity. ------- SECTION B: SOLID/LIQUID/RCRA HAZARDOUS WASTES. AIR EMISSIONS. UTILITY USAGES Please use 1987 as the base year for section B. If data are not available for 1987, please indicate which year you select as the base year. Solid Waste • • Please provide the volume of total solid waste generated and disposed of for 1987, 1988. 1989, and 1990. If report is made for multiple manufacturing sites, list only those wastes associated with dye manufacturing. Please categorize wastes according to disposal method and location (otfsite/onsite). Do not include RCRA hazardous wastes. Volumes and disposal methods for specific solid wastes from dye manufacture, such as those listed on the form, should be provided. If more'than one disposal method is used for a particular waste, list each method separately. If you do not generate a specific waste, enter "0"- for amount. Liquid Waste Data are requested on wastewater prior to treatment. Indicate whether wastewater is treated onsite or sent to a POTW. If treated onsite, a.lso provide data on wastewater discharged from the onsite treatment plant. Please provide volume and disposal method for all other liquid waste streams from dye manufacture at this site. Do not include RCRA hazardous wastes. RCRA Hazardous Wastes Provide volume, disposal location, and disposal method for all RCRA hazardous wastes. Specify whether liquid or solid, and list separately. Air Emissions Please provide volume of atmospheric emissions for 1987, 1988, 1989, and 1990. If you have data on specific air emissions from dye manufacture, whether by chemical or type, please list separately. Energy Please provide water, fuel, and power usages for the site or the dye manufacturing portion of the site, for the years 1987 through 1990. ------- WASTE GENERATION DATA SECTION B AIR EMISSIONS Total Participates Total Fugitive Emissions (Including Solvents) Total Solvent Losses Other (Specify) ENERGY Water Usage (MMGPY) Fuel: Natural Gas (MMSCFTPY) Oil (MMGPY) Other (Specify) Electricity (MKWHPY) Lbs/Yr 1987 1988 1989 1991) ------- WASTE GENERATION DATA SECTION B LIQUID WASTE Untreated Wastewater To On-site WWTP ( ) to POTW ( ) Lbs/Yr 1987 1988 1989 1990 COD BOD . SS Volume Other (Specify) Treated Wastewater Treated wastewater from on-site WWTP: ' COD BOD SS Volume Other (Specify) Lbs/Yr Other Specific Liquid Wastes Disposal Method 1957 1988 1989 1991) (Exclude RCRA Hazardous Waste) Waste Solvent Waste Oils Other (Specify) ------- WASTE GENERATION DATA SECTION B Lbs/Yr RCRA Hazardous Waste Disposal Method T9"8TT9B%19891990 (Include liquid hazardous Wst) a. Off-site Landfill b. On-site Landfi 11 c. Off-site Incineration/ Thermal Oxidation d. On-site Incineration/ Thermal Oxidation e. Other Disposal (Specify) ------- WASTE GENERATION DATA SECTION B SOLID WASTE Solid Waste Generated (Exclude RCRA hazardous waste) a. Off-site Landfill b.. On-site Landfi 11 c. Off-site 'Incineration/ Thermal Oxidation d. On-site Incineration/ Thermal Oxidation e. Other Disposal (Specify) Lbs/Yr Disposal Method 1987 1988 1989 Specific Sol id Waste Dye Dust Collectings Containers Paper Wastewater Treatment Solids Spent Adsorbents/Filter Aids Other (Specify) ota Disoosal method Lbs/Yr 1987 1988 19891990 ------- SECTION C: TRI WASTES The Toxic Release Inventory (SARA Section 313) data requested may be taken in part from your Form R's. In addition, please provide information for all TRI chemicals that are found in your waste, including those that fall below the threshold for mandatory EPA reporting. If you needed to report a chemical in a later year but you did not meet the threshold reporting levels in prior years, be sure to report releases for these prior years. If you do not, your data will erroneously show increased emissions in the later years. Please copy and number as many pages of this form as you need to provide a complete set -of data. ------- WASH CINfRAIIOH OAIA SfCflON C - TRI WASHS Direct Discharges. Chemical Fugitive Air Stack Air to Receiving Release to Discharges Off-site transfer Off-site Transfer Other On-slte or Year Emissions Cuissions Streams (Total) land On-site to POTH to landfill Incineration Transfer Category (5.1) (5.2) (5.3) (5.5) (6.1.1) (6.2) (6.2) (6.2) I. 1987 1988 1989 1990 7. 19B7 1988 1989 1990 3. ''_ 1987 1988 1989 1990 «.___._ _ 19fl/ 198R 1989 1990 ------- APPENDIX B ------- APPENDIX B SAMPLE CORPORATE POLICY ON POLLUTION PREVENTION These are examples of generic corporate policies. When formulating its own policy, a company should carefully consider its specific situation (e.g., CMA member?) and internal needs. Review by legal counsel is recommended. Sample A could be used by companies that have signed on to the CMA Responsible Care® program. Sample B could be used by companies not participating in the CMA program. SAMPLE A It is the policy of XYZ Corporation to manage air emissions, water discharges, and solid wastes so as to minimize the risk and burden to public health and the environment. A significant part of this objective requires the commitment, as a company, to eliminate or minimize waste generation at the source. Other management alternatives include recycling wherever possible and, as a last resort, treatment of wastes that cannot be eliminated. In accordance with the Chemical Manufacturers Association's Responsible Care 'Pollution Prevention Code, all XYZ facilities are required to: Inventory wastes generated and the volume of releases to the land, air, and water, and evaluate their potential impact on employees, the public, and the environment First evaluate reducing wastes and releases at their sources, then evaluate recycling or treatment programs Include waste and release prevention objectives in product research, and in the design of new or modified facilities and processes Establish an ongoing program for promoting and supporting waste and release reduction by all CMA members. In managing wastes that cannot be eliminated at the source, XYZ Corporation will comply with all applicable regulatory requirements. ------- SAMPLE B It is the policy of ABC Corporation to manage air emissions, water discharges, and solid wastes so as to minimize the risk and burden to public health and the environment. A significant part of this objective requires the commitment, as a company, to eliminate or minimize waste generation at the source. Other management alternatives include recycling wherever possible and, as a last resort, treatment of wastes that cannot be eliminated. . . . All ABC facilities are required to identify their wastes and quantify the releases to all media (land, air, and water) ABC facilities will assess the impact of their wastes on human health and the environment ABC facilities will establish waste reduction programs including: 1. Reduction of waste generation at the source before establishing .recycling or treatment programs 2. Research directed at products, manufacturing processes, and product applications that generate less waste. ABC facilities will promote waste reduction throughout their organization as well as in their dealings with suppliers, customers, and the community. ------- APPENDIX C ------- APPENDIX C ASSESSMENT WORKSHEETS A comprehensive pollution prevention assessment includes a planning and organizational phase, an assessment phase that includes gathering background data and information, a feasibility study on specific pollution prevention options, and an implementation phase. The worksheets in this appendix will assist with the assessment phase. The worksheets provided are intended to assist dye manufacturers in systematically evaluating processes relative to waste generation, and identifying opportunities to prevent pollution. Because individual facilities' circumstances and needs vary, users of these worksheets are encouraged to modify them to fit their unique requirements. The worksheets parallel the Guidance Manual, guiding the user through individual plant operations. They are intended for internal use, to assist in selecting and justifying pollution prevention activities. The first set of worksheets list WASTE SOURCES, to help target pollution prevention activities and focus resources on highly significant waste streams. Significance is defined based on individual company priorities. The second set of worksheets list POLLUTION PREVENTION opportunities, and is a questionnaire on procedures that may be implemented. This latter set of worksheets will be helpful in completing the OPPORTUNITY ASSESSMENT portion of the WASTE REDUCTION SURVEY. For a more complete description of pollution prevention assessment procedures and additional worksheets, refer to EPA's Waste Minimization Opportunity Assessment t Manual. c-i ------- PROCESS FLOW DIAGRAMS AND MATERIAL BALANCES • Process flow diagrams provide the means for identifying and organizing information that is useful for your assessment. Flow diagrams should be prepared to identify important process steps and to identify sources of discharges to air, land and water. Flow diagrams also provide the foundation for conducting material balances. Material balances are important for pollution prevention projects because they allow for quantifying losses or emissions that were previously unaccounted for. Also, material balances assist in developing the following information: - baseline for tracking progress - data to estimate the size and cost of additional equipment and other changes • data to evaluate economic performance Material balances can.assist in determining concentrations of waste constituents where analytical test data is limited. They are particularly useful for points in the production process where it is difficult (due to inaccessibility) or uneconomical to collect analytical data. A material balance can help determine if fugitive losses are occurring. Characterizing waste streams by material balance can require considerable effort. However, by doing so, a more complete picture of material losses is developed. Material balances are easier, more meaningful, and more accurate when they are conducted around individual units, operations, or processes. For this reason, the material balance envelope should be drawn around the specific area of concern, rather than a larger group of areas or the entire facility. Multiple material balances will be needed to characterize each of the operations identified in this manual. An overall material balance for your facility can be constructed from the individual unit material balances. This will highlight relationships between units and help identify areas for pollution prevention that require cooperation between different departments. A generic facility-wide flow diagram has been provided as an example. It does not include all the throughput information needed, but serves as a generalized example. C-2 ------- Certain factors must be considered when establishing material balances for batch operations. Individual batch raw material inputs and yields are usually established by weighing. Raw material losses can then be identified based on stoichiometric calculations. Inorganic salt is both used and generated during the manufacturing process, and must be carefully considered. Salts will show up in the final dye product as well as in mother liquors and other waste streams, and will complicate measurements used to pinpoint product losses to various waste media. It is also important to recognize raw material losses to chemicals generated from side reactions. When using material balances to make estimates of chemical releases to each medium, some of the chemical goes to water, to air, and to solid waste, some to product, and some may react in the process to form another compound. Thus it would be erroneous, for example, to assume that raw material losses not accounted for in the waste water or in solid waste must have occurred in the form of emissions. When using raw material purchasing records and on-site inventories for calculating input material quantities, be aware of the time period. The quantities of materials purchased during a specific time'period may not necessarily equal the quantity of materials used in production during the same time period, since purchased materials can accumulate in warehouses or stockyards. With these considerations in mind, material balances should be developed for as many processes as possible, and should be revised periodically. By tracking wastes,- seasonal variations in waste flows or single large waste streams can be distinguished from continual, constant flows. In order to collect meaningful information on pollution prevention progress, data must be collected before and after waste reduction activities are imple'mented. Computerized systems may reduce the time and effort required to perform material balances and track waste generation. C-3 ------- GENERAIJZED PROCESS FLOW DIAGRAM FOR THE MANUFACTURE OF AZO DYES Vent Water U o Diozo Component ^ HCI Solution ^ NuNOg Solution ^^^ p^- Scrubber ! Spent (may be captured in wet scrubber) ; Dust ^^,* Scrubber ! Collector •llnijri ! Fines DiazoU- zotion Reactor i Coupling ^^ Components) NaOH or Sotutlon Coupling Reactor Filtration Ul ' Equip. Wosrulown IU~_l__nJ_r / In i L If 1 1 Press Cake 1 UittHMJll W Drying and . Spent Scrubber Mother Grinding ' Liquid Liquor SP^* : 11 1 Adsorbent) f W W Note: • Treatment -^ — .Sludge Was tew at er Treatment Inert Material Standardization ^. (Sodium and Packaging "*^ Chloride / Sodium Sulfate} * A Was lew at or Discharge / >^ Sold as~ to Publicly Owned / \ Treatment Works { Product } Press Coke V / flushed Color Dotted rectangles Indicate some \ / Dispersion wastes of concern Soiree: MKI ------- PROCESS FLOW DIAGRAM * Make copies as needed to document ail processes. r-1 ------- - POLLUTION PREVENTION ASSESSMENT WORKSHEET - WASTE SOURCES SIGNIFICANCE AT PLANT (LOW) (MEDIUM) (HIGH) PRODUCTION RAW MATERIAL RECEIVING AND CHARGING/MATERIAL TRANSFER Empty container cleaning Empty container disposal Residual raw material in containers Spills during transfer operations collected in capture devices DYE SYNTHESIS Spills during charging operations Residual raw material in containers Improper time cycles, temperature and other procedures Equipment leaks , • Improper heating and cooling procedure Evaporative losses Other ISOLATION/FILTRATION Incorrect amount of precipitating agent used Poor temperature control Improper volume control niter media disposal Excess filter aid Fitter leakage Excessive fitter washing Fitter washwater disposal Spillage of filter cake in transfer Wash water Other C-6 ------- SIGNIFICANCE AT PLANT (LOW) (MEDIUM) (HIGH) DRYING Improper temperature control ', . Improper drying time . Heat loss from crying ovens Poor heat transfer ______ Material losses during dryer loading ; Material losses in air emissions Material losses during unloading Excess drv time due to excess water in presscake Wash water Other GRINDING Air emissions of dusts and fines . Use of excess deduster Waste from screen cleaning and replacement Material losses during grinder loading Leakage from DUmp and mill seals Wash water Coolina water Energy waste from overanndina Other BLENDING Spills during transfer Material losses as dust Use of excess deduster Wash water Other SAMPLE TAKING, WEIGHING Samole container dsoosal Samole disoosaJ Soills durina weiahina Wash water Other C-7 ------- SIGNIFICANCE AT PLANT (LOW) (MEDIUM) (HIGH) EQUIPMENT CLEANOUT PACKAGING Used container disposal Damaged container disposal Excessive small packages AJr emissions during packaging Spills during packaging Other RESEARCH AND DEVELOPMENT PRODUCT DEVELOPMENT Dve loss to the environment due to low substantivitv Filtration waste Waste of pilot olant oroducts Excess raw material used in reaction Solvent waste Material loss from spills and soill cleanup Poor product yield Other LABORATORY PRACTICES Excess sample size Sotvent waste Waste raw materials Materiaf loss from spills and soil I cleanup Disposal of lab eauioment Other PURCHASING ContainendisDOsaL Off-grade raw material Olher c-a ------- SIGNIFICANCE AT PLANT (LOW) (MEDIUM) (HIGH) INVENTORY CONTROL Aoed raw material disposal Spills damaged packages Disposal due to water or other damage Multiple materials purchased for the same purpose Other SALES/MARKETING Disposal of packaging Dust and handling waste Other DISTRIBUTION Waste from damaged gr gut-gf-date materials Disposal gf containers Waste packing materials Other FINANCE Ineffective cost accounting for waste Other ENGINEERING Waste from poortv designed or sized equipment Improper training of operators Waste from cleanout operations Waste from poortv maintained equipment Other UTILITIES Inappropriate utility for the iob Waste heal Waste coolinoLwater Energy inefficient equipment Other C-9 ------- POLLUTION PREVENTION GENERAL Are plant material balances routinely performed? yes no Are records kept of sources and destinations of individual wastes? yes no Are operators provided with detailed operating manuals or instructions? yes no Are all operator job functions well defined? yes no Are regularly scheduled training programs offered to operators? yes no Are there employee incentive programs related to pollution prevention? yes . no Is there an established pollution prevention program in place? yes no If yes, is a specific person or team assigned to oversee the program? yes no What are the goals of the program and results? Comments: C-10 ------- PRODUCTION RAW MATERIAL RECEIVING AND CHARGING/MATERIAL TRANSFER Are all containers properly labeled prior to filling? yes no Does operator training include proper handling of containers? yes no How is container re-use encouraged? Is bulk packaging used wherever possible? yes no Are containers emptied entirely? yes no What type of routine maintenance is conducted to identify leaks? Are transfer operations largely manual or automated? Is dust and vapor collection equipment dedicated to a single waste stream, to enable separation and recycle? yes no Comments: DYE SYNTHESIS Are excess intermediates used in reactions? yes no Can the excess be reduced by the introduction of better reaction control? yes no Can initial washwaters be collected and recycled for use in the next campaign? yes no Are there opportunities to reduce gaseous emissions at their source, or to recover and reuse them? Are cycling times excessive? yes no c-ll ------- Are processing and isolation operations conducted at the most efficient temperatures? yes no What byproducts are formed during processing? Are they recoverable? ' yes no Are spilled materials attempted to be recovered and reused? yes no Are excessive amounts of off-grade material produced? yes no What is the procedure for verifying the identity, quantity and quality of materials before use? Are containers emptied completely and rinsed into the reaction vessel? yes no Is equipment used in it's best application? yes no Can heating and cooling techniques be modified to save energy? yes no Do tank scrubbers use water efficiently? yes no Comments: ISOLATION/FILTRATION How is the proper amount and type of precipitating agent determined?. How is the optimal temperature for the isolation determined?. How is temperature controlled during isolation?. Is batch volume optimized? yes no Are filter media cleaned and reused? yes no C-12 ------- Does standard procedure for cleaning, resetting and closing filter presses successfully reduce leaks? . yes no Does press design allow for checks on individual chambers for leakage? yes no How is filter wash endpoint determined? ^^ Is dilute filter wash water reused? yes no How is cleaning of filtration equipment conducted? Are filter presses completely blown before being emptied? yes no What is the procedure for emptying filtration equipment? Does spillage often occur during filter cake removal? yes no Are dedicated bins, etc. used for the transfer of filter cake?. yes no Are any of the filter units dedicated to a particular product line? yes no Comments: DRYING Are periodic energy audits conducted? yes no How is optimal drying temperature determined? How is optimal drying time determined?. Have alternative drying processes been evaluated? yes no Is dryer heat recycled wherever feasible? yes no C-13 ------- Are ovens well insulated? yes no Is the maximum acceptable moisture content for the product identified? yes no Is filter cake distributed on trays to provide maximum surface area? yes no Is the solids content of the dryer feed stream optimized? yes no Are the heating elements free of deposits? yes no Have alternate dryer designs been evaluated to optimize performance? yes no Is there a preventive maintenance program for the dryers? yes no Is dryer loading done manually or is it automated? Are dust emissions segregated so they can be reworked into product? yes no Is production campaign scheduling optimized? yes no Is high-pressure water washing used? yes no Comments: GRINDING . Are collected fines recycled or sold? yes no Is product dustiness minimized? yes no Is the proper amount of deduster used in all applications? yes no How are product formulations, grinding conditions, equipment and milling media optimized? Does leakage occur from pumps and mill seals? yes no Is wash water collected and recycled whenever possible? yes no * Are excess volumes of wash water commonly used? yes no Are non-contact cooling waters reused? yes _no Is a wastewater monitoring system in place to detect spills and leaks? yes no Are product size requirements clearly defined, to avoid overgrinding? yes no Comments: c-14 ------- BLENDING • What type of employee training is conducted on material handling techniques and spill prevention? Are collected dusts carefully segregated so they can be recycled? yes no Are collected dusts recycled back into product? yes no Is the optimal blending equipment used for each application? yes no Is blend size optimized to be as large as possible? yes no Is deduster used in appropriate amounts? yes no Comments: SAMPLE TAKING/WEIGHING Are small sample quantities recycled into the production process? yes no Is a pre-shipment sample requested from the supplier? yes no Is the distance minimized between stock and weighing location? yes no What is the procedure for weighing and measuring? Do you see an opportunity for automating this system? yes no Comments: EQUIPMENT CLEANOUT How is completion of equipment washing determined?. C-15 ------- Is equipment flushed overnight? yes no Are high-pressure water sprays used in cleaning? yes no Is the same washwater sequenced through the system? yes no Are concentrated wash waters used in the next production batch? yes no Are dilute rinse waters reused to rinse other equipment? yes no Are campaigns run to minimize the need for cleaning? yes no Describe how waste from flushing is handled: Describe the cleaning sequence used: . Is all equipment cleaned promptly after use? yes no Are there established procedures for communication between cleaning and production crew? yes no Has the effect of reduced cleaning on product quality been investigated? yes no Comments: ____, PACKAGING Are recycled/recyclable packages used wherever possible? yes no Are customers encouraged to accept bulk deliveries in reusable containers? yes no Is market forecasting used to encourage bulk purchases? yes no Does package design minimize dusting? yes no Is bulk density of the product maximized? yes no Does package design minimize worker exposure during weighing? yes no Are storage areas designed to minimize potential container damage? yes no Are procedures clearly defined for proper transfer, palletizing, and stacking of product? yes no Is the need for repackaging minimized? yes no Are containers reused whenever possible? yes no 016 ------- RESEARCH AND DEVELOPMENT PRODUCT DEVELOPMENT In what way are waste reducing chemical substitutions considered in new product development? Are waste reducing properties considered in product development? yes no Is high substantivity a primary factor in the development of new dyes? yes no Is research conducted on more efficient application methods and improved dyeability? , yes no Are dyes produced and marketed at the highest acceptable concentrations? yes no Is the use of non-hazardous chemicals considered in the development of new dye molecules? yes no Are alternative synthesis routes considered which utilize less toxic reactants and generate less waste? yes no Are newer technologies constantly being compared to existing processes to determine their applicability? yes no Are pilot plant products incorporated into salable product, if possible? yes no Are solvents and reactants selected with consideration to their recyclability and hazardous nature? yes no Are production processes using the optimum quantity of reactant/additive?_yes no Are products produced at their maximum possible concentrations? yes no Are all reaction parameters maximum yield? yes no Comments: ____^__ C-17 ------- LABORATORY PRACTICES Is the amount of chemical needed for a project determined prior to obtaining it? yes no Are chemicals obtained from manufacturing, if available, rather than being purchased separately? yes no Are excess chemicals sent back to manufacturing? yes no Are solvents recycled? yes no Is lab equipment properly scaled for small-scale new product screening? yes no Is spill cleanup done efficiently and with the appropriate materials? yes no Are reusable lab supplies used as much as possible? yes no Comments: ' c-ia ------- PURCHASING Is there an explicit policy of purchasing from vendors who promote recycling in their products or packaging? yes no Are vendors requested to provide reusable or bulk containers? yes no Are the highest quality raw materials purchased, to minimize undesirable byproducts and wastes? yes no Are multiple products purchased for the same purpose? yes no What is the procedure for dealing with off-grade raw material? Do purchasers continually search for the best available suppliers? yes no Is outdated raw material a persistent problem? yes no Comments: ' INVENTORY CONTROL What type of storage problems lead to the creation of waste at your facility?. Is a first-in/first-out inventory scheme used? yes no In what way does the inventory staff communicate with the sales/marketing staff to assist in moving aging product? Is an inventory kept of process by-products and wastes which may be marketable? yes no Are all raw materials tested for quality before being accepted from suppliers? yes no Is the inventory system computerized? yes no C-19 ------- Is there a formal training program on raw material handling, spill prevention, proper storage techniques, and waste handling procedures? yes no How often is training conducted and by whom? Comments: C-20 ------- SALES/MARKETING Are the environmental characteristics of your products provided to customers? yes no Are customers encouraged to consider: Bulk deliveries? yes no Purchasing full containers? yes no Recycling or reusing containers? , , yes no Substantivity and exhaust rates in their product' selection? yes no Purchase of non-powder forms? yes no Parameters such as salt-loading? yes no More concentrated products? < yes no By-products such as heavy metals? yes no Training for proper dye application procedures? yes no Substituting new or improved products where appropriate? yes no New application techniques that minimize waste generation? yes no Is communication fostered between the customer, production, and R&D? yes no Are off-grade, slow-moving, or obsolete materials sold at a markdown price to avoid disposal or rework? . yes no Are special markets identified for dyes based on their by-products? yes no Are markets identified for what is considered waste? yes no Has the potential for waste exchange been explored? yes no Comments: C-21 ------- DISTRIBUTION Are materials stored at the proper temperature? yes no Is the material storage area kept dry? yes no Are packages stored with enough space to provide easy access? yes no In what ways are customers encouraged to purchase full containers or bulk containers, and to order early? Are reusable containers used? yes no Are packing materials reused or recycled? ' yes no Comments: C-22 ------- FINANCE Are waste management and disposal costs allocated to the area of generation? yes no When evaluating environmental costs, what "indirect costs", such as paperwork and liability costs, are included in the calculation? Does the finance department provide cost figures on waste management to the manufacturing and environmental staff? . yes no What records are kept on the amount of waste reduction achieved and the savings that resulted? ' Are any funds set aside to fund pollution prevention projects, with expenditures justified by the potential to reduce waste? , yes no Comments: ' , ' • C-23 ------- ENGINEERING Is external heating and cooling used whenever possible, to allow for recycle of the heating or cooling fluid? yes no Are mechanical seals used on pumps? yes no Is the size of equipment optimized for batch size? yes no Is mixing done adequately and for the proper length of time? yes no Is proper grinding equipment used? _. yes no Is new equipment start-up'properly supervised? yes no In what way are operators trained on the operation of new equipment? Are standard operating procedures analyzed and optimized? yes no In what ways is equipment designed to ease cleaning? Are recommended cleaning procedures included in the equipment's operating instructions? yes no What type of routine maintenance is conducted on equipment, instrumentation, piping connections, seals, and lining integrity? Are storage tanks routinely monitored for leaks? yes no Describe procedure and monitoring frequency for tanks: How are liquids in these tanks dispensed to the users? Comments: c- 24 ------- UTILITIES Is the proper utility selected for the job? yes no Are utilities used for multiple purposes if possible? yes no Is consideration given to solar heat or hot water when remodeling? yes no. Is energy efficiency considered when selecting equipment? yes no Are lights and equipment turned off when not in use? yes no Is cleaning conducted with consideration for water conservation? yes no Is routine maintenance conducted on equipment for peak efficiency? yes no Is aging equipment replaced with more energy efficient models? yes no Are lighting fixtures replaced with new, high efficiency products? yes no Comments: Other Comments: C-25 ------- APPENDIX D ------- Appendix D Weighted Sum Method The Weighted Sum Method is a quantitative method for screening and ranking waste minimization options. This method provides a means o1 quantifying the important criteria that affect waste management in a particular facility. This method involves three steps. 1. Determine what the important criteria are in terms of the WM assessment program goals a constraints, and the overall corporate goals an constraints. Examples of criteria are the following: • Reduction in waste quantity • Reduction in waste hazard (e.g., toxicity, flammabilrty, reactivity, conrosivity, etc.) • Reduction in waste treatment/disposal costs' • Reduction in raw material costs • Reduction in liability and insurance costs • Previous successful use within the company • Previous successful use in industry • Not detrimental to product quality • Low capital cost • Low operating and maintenance costs • Short implementation period (and minimal disruption of plant operations) • Ease of implementation i The weights (on a scale of 0 to 10, for example) are determined for each of the criteria in relation to their importance.For example, if reduction in waste treatment and disposal costs are very important, while previous successful use within the company is of minor importance, then the reduction in waste costs is given a weight of 10 and the previous use within the company is given a weight of 1 or 2. Criteria that are not important are not included (or given a weight of 0). 2. Each option is then rated on each of the criteria. Again, a scale of 0 to 10 can be used (0 for low and 10 for high). 3. Finally, the rating of each option from particular criteria is multiplied by the weight of the criteria. An option's overall rating is the sum of the products of rating times the weight of the criteria. The options with the best overall ratings are then selected for the technical and economic feasibility analyses. Worksheet 13 in Appendix A is used to rate options using the Weighted Sum method. Table G-1 presents an example using the Weighted Sum Method for screening and ranking options. Table G-1. Sample Weighted Sum Method Calculation using the ABC Corporation has determined that reduction in waste treatment costs is the most important criterion, with a weight factor of 10. Other significant criteria include reduction in .safety hazard (weight of 8), reduction in liability (weight of 7), and ease of implementation (weight of 5). Options X, Y, and Z are then each assigned effectiveness factors. For example, option X is expected to reduce waste by nearly 80%, and is given an rating of 8. It is given a rating of 6 for reducing safety hazards, 4 for reducing liability, and because it is somewhat difficult to implement, 2 for ease of implementation. The table below shows how the options are rated overall, with effectiveness factors estimated for options Y and Z. Ratines (or each option Rating Criteria , Reduce treatment costs Reduce safety hazards Reduce liability Ease of implementation Sum of weight times ratings Weight 10 8 7 5 X, 8 6 4 2 Y Z 6 3 3 8 4 5 2 8 166 122 169 From this screening, option Z rates the highest with a score of 169. Option X's score is 166 and option Y's score is 122. In this case, option Z and option X should both be selected for further evaluation because both of their scores are high and relatively close to each other. D-1 ------- APPENDIX E ------- Appendix E Evolutionary Operation (EVOP) E. HARVEY BARNETT Momanto Chemical Co., Organic Division, St. Louis 77, Mo. Introduction to Evolutionary Operation This i* the way to improve quality, increase throughput, or reduce cost during routine operation of a chemical plant i_j VOLUTION A RY onuATJOM, usually called EVOP, a a technique for improv- ing the operation of a proem. It it or- dinarily applied to chemical process**. Fini proposed by Dr. G. E. P. Box (7), it is now in use in many location) and if pointing the way to significant saving*. An illustration of the way EVOP works is duejo Box. Suppose a biologist captures lobsters off the coast of Maine. He measures two characteristics of these lobsters, length of daw and-pressure cxened between the dawj. The lobsters are tagged, and later samples tell which lobsters live long enough to reproduce. A rwo-dimen- lionaj plot of data is shown in Figure 1. Contours have been drawn which join those points having equal probability of survival. The contours arc of logical shape, for lobsters which have clawj too short or too weak cannot defend themselves against their enemies, nor can they gather food effectively. It is also known that lung daw* would make a lobster clumsy and the excessive leverage of long clawt and high pressure might cause the lobster to break his own claw: the beat con- figuration is represented by the inner closed contour. It is expected that offspring would tend to have the characteristics of the parents with minor variations. But the offspring with more favorable characteristics beget offspring with even more favorable char- acterisiics. A group which is initially on the side of the hill will move up the hUl in the course of several hundreds or thou- sands of generations and will eventually occupy the hilltop. If the environment change), location of the hilltop change* and the species must, and will, resume its climb to the top. The contours of Figure 1 might also represent the yield of a chemical reaction as a function of pressure and reactor length at constant flow. In this case, a different location of the contours would be caused by a different flow rate. Two things are necessary for this evolu- tionary process to occur in nature: mutation, or change, and selection of the most favorable offspring. These criteria suffice for improving the yield of the analogous chemical process. However, typical policy in chemical production ha* been to forbid change of a controlled variable in the plant without special permission. Sev- eral special license* may have been granted in a year, but only rarely for change of more than one variable at a time. Further, the method of determin- ing which condition was more favorable was often inadequate. This is not to say that processes were never improved. A foreman may have noticed that when the solvent was wet the yield was low. An operator may have observed that the centrifugal time cycle was shorter in the winter when the cool- ing water was colder. By these means most processes were im- proved gradually over a period of time and most were eventually operating at nearly optimum conditions. It has been tacitly assumed that a new process is never at optimum conditions— in fact, it ii possible that a new process will not operate at all. But assume for the mo- ment that all the combinations of possible conditions have been thoroughly ex- plored on the bench and the process has had a careful pilot-plant investigation. In spite of all the data and correlations which have been accumulated, most or- ganic reactions act differently in the large-scale plant. This is especially true when uncertain quantities as heat trans- fer, agitation, distillation column effi- ciency, others, arc important. It is, there- fore, necessary lo optimiie in the plant. Evolutionary Operation provides a »yi- tem for optimiring a plant; for exploring the relationships among independent and dependent variables. EVOP consists of the systematic introduction of very small changes in selected independent variable* LfNCTM Of CLAW Figure 1. Per .cent of lobster* which live to reproduce which affect a process, and the statistical selection of the best set of conditions. This system is one which can be used by operating personnel without special assignment of research chemists and tech- nical service engineers. In fact, the prin- cipal difficulty is the quantitative deter- mination of response which is often yield or concentration of wanted compounds. But given a process in which the impor- tant process variable* are controlled, and given a measurement of the critical re- sponse quantities, EVOP can be run and will usually result in improvements in cost or quality. To illustrate, let us show the course of a typical EVOP. Suppose the important independent (controlled) variable* are catalyst concentration and temperature, and the dependent variable which will be observed is yield. The real response corv- toun are shown in Figure 2. If the initial process ii at A, phase I may be run, then II, and finally III. "Which way.is up" is the only information hects»ary to follow this path. i Chemical processes have been operated for many years to produce materials use- ful to other industrie* and to consumers. Today these processes can also be op- erated to produce information useful in their own improvement. Experimental Design* Various experimental designs can be used and a statistician would select an ap- propriate design to fit the particular case. lie would weigh such factors as interac- tion, linearity, and the use of previous knowledge. M-. TtMF0UTU*C Figure ?. This it the course of o typi- cal evolutionary operation to im- prove yield *4 fra» MDUITIlAi AND INOINIUMO CMiMICTIT. V«L 32. f«t« 300, J«M It40 " E-1 ------- •L' Figure 3. These or* •xompUi of rwo- ond three-variable EVOP designs 1_ • -' C1M Figure 4. These comparisons are from the two variable EVOP designs The recommended deign for general use Li ba.irH on the time-tested rwo-leve) factorial in which each independent fac- tor will he held at a low and a high level. A'1 possible combination* of lowi and hifchi are run.. The graphs in Fijjure 3 •how that the two-variable design it a square; the three-variable, a cube. In each case the basic factorial is augmented by adding a center point. These EVOP designs can be extended to any number of dimensions. A let of experimental runs which in- dudes each of the designed combinations once is called a cycle. A/ter several cy- cles (replications) have been made, the genera] location of this pattern may be moved or variables may be dropped from the experiment or added to begin another phase. It must br understood that the mr»n- ing of "low" and "high" is relative. The changes made within a cycle of an EVOP areof imall magnitude; 10 imall that the effect on the observed variable is expected to be detectable only a/ter several cycles have been run. Another facet of design concerns inter- actions. These art all too common in chemical processes— for example, less catalyit is required at a higher tempera* ture. Second-order relationships may also be present within the experimental factors as well as among them. However, the limpler fint-order designs recom- mended here will lead generally upward. Anolytit of Data Thesr designs result in the usual com- pariv>m nf a factorial (2): all main ef- fects and first-order interactions can be imlr|>rndrnt)y estimated. In addition, a warning of curvature is obtained and the grand mean it useful-for comparing one block of runs with another. For the two- variable case shown in Figure 4, five ex- periments yield a total of five statistics: 1. Effect of A 2. Effect of B 3. Interaction effect AB 4. Change-in-mean effect (CIM) 5. Grand mean Data are rarely error-free. Hence ef- fect A—for example, which was obtained as the difference between the average re- iponse at the higher level of A and the average at the lower level of A—contains error. A number representing the amount of error is necessary for compari- son with the effect. If the effect is imall compared with the error, then the effect may not be real at all, but merely the re- sult of errors. If the effect is large com- pared with the error, it ii concluded that the effect is really present and that it op- erair* in the indicated direction. CALCULATION Of AVERAGES CALCULATION OF STANDARD DEVIATION O»I»*TIMI IUM '*O» »«tVIOU» CVCUC «€• O»«f«V»TIO«t »«"•"-» '"•»•' 1730 I'S.06 19 87 <5 94 fl 5 "fl flfll" 7 RE "I Ofif? - n 7 1729 864 n i-I.HS 944 97? - 1-19 . Q 3S . Q 416 ••Iii£ » * I. 601 9 ? 5 si 2 a 97 f • tun »/m- n 1.6 QI / 3-1 CALCULATIONS Ct EFFECTS U JA Q-flOQ I I fl«i • 7.86 • n frrtCT r 18.78 » 8.88 • !7 1? . * «; »1 Q.78 • l O 1 5 - • I'rtcr •l tr'fCT ALCJLA-ICNS CF LIMITS e I 0.18 • 7.86 « o Aft o a c n [384 \ fi 4 6 2 l * Afl ~&£ •786 • 8.60 cIr I fl t 9 SR i n n A I 9 2 6 ian4 2 1 O ? ? O.BQ •' 1.Q6 Q so •' i oe '* 0.80 •« 0.95 FACTORS -rtO.4 DESIGN CL 2 1.44 10.95 t.7< L 1.M I.It !.•• *.«• • M i.n t.n 1 11 .M 3 4A JTIME, hr». TRUE RESPONSE B significant 4- tVOLtfTIOHAUT TWO VAHI«*LI VOMM IMttT pi i Q rn 1 e Rflur* 5. Th«M two-variable example colcdaHora or* for cycle* 1 and 2 E-2 H a VOC It. NO. 4 • MM 19*0 501 ------- STATISTICS IN CHEMICAL PROCESSES Figure S ihowi a calculation form for obtaining the four comparisons and the error limits for the two-variable case. The error limia art obtained by replica- tion—that 15, by noting how well the re- sponse checks on repeated application of the same set of experimental condition!. This calculation is ba»ed on an estimation of the standard deviation from the range. Instruction! which accompany the form make it self explanatory. Note that no itandard deviation is obtained on the fint cycle. The forms in this article have been altered ilighdy from the original work of Box and Hunter ( -f 2.75. Zero is not a likely value for the effect of temperature. Run data for this example were ob- tained by adding random erron with a itandard deviation of 1.00 to the true re- sponse (Figure 6). This true response was obtained from a real proem by multi- ple regression methods. The signal re- ceived is approximately correct and esti- mate of standard deviation is very good. A minimum would be located by pro- ceeding in the oppoite direction. CALCULATION OP AVERAGES CALCULATION Of STANDARD DEVIATION OMftAYlNQ COttOltlOHt tvlnAOl ••OH »«tvlOul CTCLI o.rrc.e.ct. ...TCNI.O.H t 9 ^ fi -f|46 fi ft fi -174 1 I (14 +2? 9 n 4 7 9 17 »«fviOu! tun 1 9 4 fl 9 4 fl *o 4 a NIC ( > «»MOf • K ~ - 3 .95 . Q 3Q . I.I 85 iiisa- s - | ia5 "t- *vtn»0t S 4 | q 01 fl R4 "9 7? . I I R*> »g vom * v c» *c g 5 CALCULATIONS Of EFFECTS * tfrtct t"tCT CALCULATIONS CF 95^ ERROP LIMITS 753 = 994 • 7.53 iix! fil7 2 I 174 7 53 1747 0 6.64 ' 97 747 2 ip RQ - O 4 S 1.76 JA 1 .185- t 2.32 I.I SS"« ? 32 _m-»t»N cmcT 1 1 BS-t 2 09 FACTORS Of CCT DESIGN '18. • 7 58 •• 8.65 34 fiQ n »1 1 « Q ~T~ i.e* i.n t o» e.ee e.ee e.n e.n .1.1* t.M e.H e.i* t.i* e.et ? •». 2 5 - TIME, Krs ny OPCHATIOM TWO Vt«l«»LC BOOK IMICT pneouct Example HH^OMC Y 1 Figure 6. The**) two-variable example calculation* or* for cycle 3 502 vteunuM AND iNowuima OMMKTIT E-3 ------- Interpretation of Signals Informaiion it obtained from an Evo- lutionary Operation as to whether the ex- periment included variable! which had a significant influence on the response. If it did, theae effects arc found to exceed the 95% confidence interval for effects. If an effect is positive, and the response is to be maximized, the variable should be changed in a positive direction. If more than one variable is significant, these var- iables should be changed limultaneously by the amounts proportional to the effects (J). This rule applies as long as the change-in-mean (CIM) effect is small. Caution should be used in making changes when the CIM effect is not small and especially when it is significant. The possible relationships of the experi- mental location to the response surface are shown in Figure 7. The CIM effect is the differen.ee between the y value at the center-point and the averaee of the two y values for the extreme points. When EV'OP begins, asaume that the value of the independent variable A is not optimum (Figure 7,^). The A effect is found to be significant lince the slope is steep, but CIM effect is not significant. As later phases proceed closer to the peak, Figure 7,5 applies. Enough cycles are run to show A significant, but the CIM effect may or may not be significant depending on the spread of the experi- ment wiih respect to the actual response, the curvature uf the response curve, and size of experimental error. But, the CIM effect is not expected to be imail. When the response maximum it finally included within the experimental space, it is possible that the independent vari- able will still have a significant effect (Figure 1C}. The CIM effect should be significant. The usual picture is Figure ID where the slope of the independent variable (the effect) is near jero and the CIM rfTrct is significant. Note thai the CIM effect is negative for a convex surface. Figure 7/Tu also possible when the true maximum is a point on a relatively large plateau or when thr size of the experi- mental |i.itiern is too small in relation to the curvature. .Stated simply, the interaction effect measures nonlinearity or nnnplanarity. This is not always true, however, since the dr.MRn which straddles a peak sym- metrically h»s zero interaction. In gen- eral, tlir existence of an interaction means that .1 has a different effect on the re- sponse at the low level of B than it does at the higher level of B. Multiple Responses Any number of res|>onse variables can be observed for each run. Thes« are cal- culated separately. It will ordinarily be desired to maximize some of them, mini* mixe some, and hold some within limia. Figure 7. Here is an interpretation of the « chortge-in-meon ef- fect • /f I f ft is likely that conflicts will arise: To maximize the yield the temperature must be increased, but this will cause the for- mation of too much tar, for example. To resolve complex conflicts, it is ad- visable to determine the response surface and plot them all on the tame diagram or model with lines which represent the known limits. This technique (<5) is of great value when combined with a priori knowledge and wisdom of the production man and the chemist to select the condi- tions for future operations. Organization for EVOP An EV'OP can actually be designed, run, and calculated by a production fore- man or supervisor, or this can be done by the chemicaj statistician. Such factors as time available, background, and exist- ing line-staff relationships should be con- sidered before assigning responsibility in any particular case. On iwo thinrs, general agreement is: 1. Drsign and interpretation should uiiluc ill the iheoretical and practical kn<>w|rdqr which is available. 2. I he penrration of idr.is is of rruicrtl irnjxinancc (5). EV'OP points thr w,iy up only for the variable beine studird. If other variables are likely to !>c im|>ortant, they must bt studied. To these ends there should be an EV'OP committee or an informal group whirh will meet occasionally to review data, interpret signals, and select likely variables for investigation. This group may be composed of production su- pervisor, staff technical production ad- visor, technical services representative, re- search chemist, and chemical statistician. Early discussions should include the analytical methods development chem- ist, since it is often found that one or more ' analyses are required for which no stand- ard method exists. In fact, EVOP is ex- pected to require a significant number of new methods and special analyses. In tome cases, the prospect of signifi- cant improvement* will justify the pur* chase of a new analytical instrument'or plant stream analyzer. Training for EVOP Persons who will come into contact wiih EV'OP should understand at least what it is and what it does This includes production foremen, analytical chemists, the research group, technical services en- gineers, and management to the level of vice president or higher. For some it is enough to read a journal article or an in- tra-company report. Others ne«d, or want, first-hand knowledge. For these a course should be organized which covers the topics of this article and their statisti- cal background. The most effective training involves do- ing, and EV'OP can be done in the class- room through the use of an electrical analog (7, 9) of a process. literature Cited (1) Box, G. F. P., Affl. Slaliilici S, No. 2, 3-2} (1957). (2 i Hnx, O H. P., Connor, L. R., Couiint, W k.. Himtworth, F. R., SillHto, G. P., m " 1 he Orjiijn and Anily»u of Indu»- tn.il r.\pi-rin>enii," (O. L. Daviej, ed.), pp 247-67, Olivrr »nd Boyd, London, I9S4. (3i Ibid., Ch»p. 11. (4i Hn-,, G. E. P., Hunter, J. S., Statistic*] Techniques Research Croup Tech. Rept. 37, Princeton University (January 1959). (5) Box, G. E. P., Hunter, J. S., Tftfint- mtine, I, No. 1.77-95(1959). (61 Franklin, N. L., Pinchbeck, P. H., Pnpprr, F., Tram. list. Cfirm. F.ngti 34, 280-95 (1956). (7) Heigl, J. J., Wilion, J. A., "Description " of an FJectrical Analog of a Research Problem," F.uo Research and Engineer- ing Co., Products Research Div., Linden, N. J.(Oct. 13,1955). (8) Koehler, T. L., Ttffii 42, 261-4 (1959). (9) Moder, J. J., Jr., /iu/iu<. Qua/. Central 13, No. 4, 16-21 (October 1956). ' Riciivto for review September 22, 1959 Acotrno April 12, 1960 Division of Industrial and Engineering Chemistry. 136th Meeting, ACS, Atlantic City, N. J., September 1959. E-4 VOL 12, MO. • e JUNI i**o 503 -------