E MAMUFAOTJW© INDUSTRY
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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.
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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
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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
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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)
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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
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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.
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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.
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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:
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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.
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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.
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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.
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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
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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
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Additional Opportunities Identified in Your Plant in the
Area of Research and Development:
41
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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
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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.
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Additional Opportunities Identified in Your Plant in the
Area of Purchasing:
44
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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
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used to neutralize alkaline process waters in another. This procedure eliminates the
generation of a potential waste.
46
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Additional Opportunities Identified in Your Plant in the
Area of Inventory Control:
47
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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
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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
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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
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Additional Opportunities Identified in Your Plant in the
Area of Sales/Marketing:
51
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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.
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Additional Opportunities Identified in Your Plant in the
Area of Distribution:
53
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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
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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
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Additional Opportunities Identified in Your Plant in the
Area of Finance:
56
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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
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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
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Additional Opportunities Identified in Your Plant in the
Area of Engineering:
59
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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.
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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.
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Additional Opportunities Identified in Your Plant in the
Area of Utilities:
62
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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.
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APPENDIX A
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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