Apply Heuristics to
Pollution Prevention
and Control Decisions
Waste treatment
and minimization
in a multiproduct
plant can present
formidable
challenges. These
heuristics will help
simplify the
complicated
requirements that
must be met.
Scott A. Berger,
Owens Corning
Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.
M
ultiproduct plants present
unique challenges to pollu-
tion prevention and waste
treatment efforts.
The products being made at any given
time vary widely in terms of materials
handled, air emissions released, and
wastes produced, and may change even
over the course of a day. By nature, the
products being made at any one time may
never have been produced in that combina-
tion before, and the product mix is likely
to change often. Startups and shutdowns
are the norm rather than the exception.
Multiproduct plants are often old and
crowded, and production equipment is
likely to have evolved to its present state
rather than having been designed opti-
mally for its present purposes. Even if it
was designed optimally, the optimum in-
volves trade-offs between what is best for
individual products vs. what is best for
the overall product mix.
Further complicating matters, the finan-
cial analysts may be tight with the cash,
since a product made in a multiproduct
plant, even one having a high return on in-
vestment, itself contributes only a small
fraction to the plant's overall cash flow.
Last, but not least, there's always
something going wrong, constantly drag-
ging us away from our goal of pollution
prevention.
This article presents a set of heuristics
that will help untangle the web of compli-
cated pollution-control requirements for
multiproduct plants and pave the way to
implementing improved pollution-preven-
tion and pollution-control solutions.
CHEMICAL ENGINEERING PROGRESS • APRIL 1999 •
It's a big job
The first heuristic is I: It's a big job,
so get started right away. This has two
corollaries - la: It's a big job, so it's
best not to stop; and lb: It's a big job,
so it's best to have lots of help.
Help can come from many sources:
fellow engineers and scientists, market-
ing and sales personnel, logistics staff,
operators, environmental professionals,
and maybe even environmental agen-
cies. We must tap into our networks.
Don't forget to take all advice seri-
ously, even if it is well-intentioned but
wrong. And, be prepared to withstand
slings and arrows.
Old dogs and new tricks
But, just where to start? Most of us
know to begin by taking inventory of
wastes and emissions, and address those
wastes and emissions where they are
created in the processes.
Before doing this, though, first har-
vest some ripe low-hanging fruit. The
ripest fruits in multiproducts plants are
often the same processes that are
renowned within the facility because of
their odor, rainbow-hued smoke plumes,
reportable emissions, or permit ex-
ceedances. Usually, these processes will
have been around longer than most of us
have.
This brings us to Heuristic Number
2: Get rid of the old dogs. If necessary,
trade the old dog in for a new puppy,
preferably one that has already been
trained.
Often, the products made by the "old
53
 ENVIRONMENTAL PROTECTION
dog" processes are themselves old
dogs and are suffering from waning
market, quality, or safety issues,
making this option easier. New pup-
pies can be designed more efficient-
ly, following the now-familiar low-
pollution process development
methodologies, such as those in
( 1-4).
Alternatively, it may be possible
to teach the old dogs some new
tricks (which will be addressed as
Heuristic Number 10).
Address off-grade product
Next, look at those processes that
generate a relatively high amount of
off-grade product. Off-spec material
must either be re-worked, blended
into other product, or purified. Each
of these activities generates some
kind of waste, as well as reduces
overall productivity. In the worst
case, the off-grade product must be
disposed of as waste. Solving signif-
icant off-spec problems is therefore
both an environmental and financial
win.
Heuristic Number 3 is therefore
3: Eliminate off-grade product. Solu-
tions are numerous and involve ad-
dressing such issues as process con-
trols, human error, raw material im-
purities, and mechanical failures.
Often, the solution to off-grade prod-
uct has the added benefit of reducing
waste and improving yields even rel-
ative to the best obtained before.
Optimize change-overs
Having gotten rid of old dogs and
ceased making off-grade product, it
is time to inventory and optimize.
In the multiproduct plant, start by
inventorying the waste produced in
the change-overs between different
production runs. Most change-overs
require the equipment to be cleaned,
and cleaning generates wastewater,
waste solvent, and/or chunks of
sludge, polymer, or other residue.
Change-overs may also produce a
transition product, that is, material
from the end of the old run contami-
nating material from the beginning
54 • APRIL 1999 • CHEMICAL ENGINEERING PROGRESS
Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.
of the next run. And, change-overs
can also produce as waste product
that is perfectly good but labeled
wrong.
Heuristic Number 4 is actually a
family of related heuristics. 4a:
Schedule production to reduce the
number of change-overs. This re-
quires increasing communication
and planning between the sales
force that projects sales and takes
orders and promises delivery, the lo-
gistics staff that schedules produc-
tion, and the warehouse staff that
builds and holds inventory. Logistics
software can be extremely helpful in
complex plants.
4b: Schedule products in a com-
patible sequence. For example, you
won't notice or even care if you
pour red wine into a glass contain-
ing a few drops of white wine. But,
you will ruin your glass of white
wine if you have left few drops of
red wine in the glass.
4c: If two or more products are
practically the same, replace them
with one product. You'll have to
brace yourself for this task, as mar-
keting and sales have created these
slight variations to please their best
customers. Ultimately, though, this
activity can have a huge impact on
change-over waste.
Inventory by classes and cases
The next step deals with the actual
processes themselves. Inventory the
waste streams generated by each pro-
Table 1. Classes that may be used for waste inventories.
Air Water
Acidic Strongly acidic
Basic Strongly basic
Combustible Weakly acidic
Condensible Weakly basic
Reactive Clean
Particulate Solids-containing
High Biochemical Oxygen Demand (BOD)
Low Biochemical Oxygen Demand (BOD)
cess, including all air, water, and
solid waste produced during produc-
tion, during clean-outs, and due to
off-grade product. Two heuristics
guide the inventorying process.
Heuristic Number 5: Inventory
wastes in as many possible similar
classes and even sub-classes as pos-
sible. Table l lists some examples of
classes that could be used; classes
may also be created according to ac-
tual chemical species contained.
Creating these classes and subclass-
es provides a convenient initial basis
for considering recycling and treat-
ment options.
Next, assign compositions and
flow rates to each waste stream. For
multiproduct plants, this may be
harder to do than it sounds.
Heuristic Number 6 should help.
6: Assign four flow rates to each
stream - the highest daily and an-
nual flow rate and the lowest daily
and annual flow rate. It may be pos-
sible to add two additional flow
rates, the typical daily and annual
flow rates. With these four to six
values, it is possible to prioritize
prevention and treatment activities
and better evaluate the possibility of
combining streams for treatment or
recycle.
Heuristic Number 7 is a re-
minder. 7: Don't forget to include
water, process steam, air, oxygen,
and nitrogen in the inventories.
With these four to six flow-rate
scenarios plus numerous product
Solid
Hazardous
Nonhazardous
Off-site recyclable
On-site recyclable
Fuel value
 combinations, it is now time (if it
has not be done already) to apply
Heuristic Number 8: Use a process
simulator. It could be either a full-
functioned process simulator or a
program that is specifically focused
on waste-stream management.
Prioritize
Based on the waste inventory,
identify which processes to start
with, and then proceed with various
means of process pollution preven-
tion and waste treatment. Prioritiza-
tion is governed by a sequence of
heuristics:
Heuristic Number 9a: Start by
preventing or addressing issues that
assure compliance ...
9b: . . . then those that have the
highest actual community risk ...
9c: ... then the highest communi-
ty perception (e.g., odor, visible
emissions, releases reported under
SARA Section 313, etc.) ...
9d: ... then the highest ecological
risk ...
9e: ... and finally those that re-
duce cost.
Some people may argue with the
order presented above. Remember,
though, that these are heuristics,
which by their nature apply in "typi-
cal" situations. If your "typical" sit-
uations are different than mine, rear-
range the order.
New tricks
Now it's time to address those
old dogs that couldn't be traded
in. Teach these old dogs some
new tricks by applying the widely
accepted hierarchy of pollution
prevention:
Heuristic Number JOa: Eliminate
waste or emissions at the source.
]Ob: Reduce the quantity or toxi-
city of waste or emissions.
10c: Recycle usable process ma-
terials from wastes to the process
that generates them.
JOd: Recycle usable process mate-
rials from wastes to another process.
In multiproduct plants, opportu-
nities for both types of recycle fre-
Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.
quently abound. The waste invento-
ry provides valuable information
that can be used to develop creative
ideas for recycling.
JOe: Recycle usable process ma-
terials by off-site recovery for on-
site re-use.
1Of: Obtain a useful, salable
byproduct from waste materials.
The corollary to heuristics
10c-10f is: If the wastewater (or air
emission) is cleaner than the fresh
water (or air) brought into the plant
in the first place, use it!
To ease
Treat it right
Pollution-prevention activities
should reduce the quantity and num-
ber of waste streams, so subsequent
treatment-improvement activities will
be more effective. Heuristics for de-
veloping treatment systems include:
lla: If the waste doesn't need to
be treated, don't treat it. Be careful
with this heuristic, because what
doesn't need to be treated today
might be subject to more-strict regu-
lations or treatment criteria in the
future. If new treatment require-
ments may be looming just over the
horizon, disregard this heuristic.
llb: Group similar or synergistic
waste streams together. Streams
may be grouped for such reasons as:
the streams need similar pretreat-
ment before being combined for
general treatment; the streams need
similar treatment before discharge;
CHEMICAL ENGINEERING PROGRESS • APRIL 1999 •
and the streams treat each other
when grouped together (e.g., acids
neutralize bases, oxidizers destroy
chemical oxygen demand (COD),
ammonia destroys NOx, precipitate
forms when streams are blended,
and so on).
Grouping waste streams in this
way can reduce treatment costs. For
example, in one extreme case, a
plant was generating a waste con-
taining hypochlorite and another
containing phosphite. The hypochlo-
rite was being subjected to a reduc-
tion treatment, while the phosphite
was being oxidized. By combining
the two, the resulting stream re-
quired no treatment. In another case,
two streams were being individually
treated to remove somewhat similar
large organic molecules. By com-
bining them, two separate opera-
tions were replaced with a single
lower-cost system for treating both
streams together.
llc: Avoid dilution with extrane-
ous water or air, unless safety dic-
tates otherwise. Generally speaking,
treatment costs depend more heavi-
ly on flow rate than on concentra-
tion, so any dilution increases cost.
In an extreme situation that happens
all too often, hoses and sinks are
left running, either due to careless-
ness or a false belief that dilution
makes wastewater treatment easier.
In fact, the dilution decreases the
hydraulic retention time of the
wastewater treatment facility and
thereby decreases the amount of
pollutant removed.
Note, however, that dilution may
be required to ensure safety. For ex-
ample, thermal oxidizers require
that the pollutant concentration be
diluted to less than 25% of the
lower-explosive limit (LEL).
lld: Pretreat concentrated wastes.
This might also be called the Pareto
Heuristic: Typically, most of the pol-
lution treatment load comes from a
small fraction of the waste stream vol-
ume. Taking advantage of the lower
cost of low-volume treatment, the ma-
jority of the pollution load can be
55
 ENVIRONMENTAL PROTECTION
Address
First
Second
Highest
Impact
To Find the First
Issue to Address
■ Figure I. "Swim upstream" to find the operation with the highest impact.
taken care of at a relatively low cost.
The remaining low-strength wastes
can be treated more simply and at a
lower cost. Numerous pretreatment
options are available, including floc-
culation, extraction, removal of large
molecules and polymers, sequencing
batch reactors for high concentrations
of readily biodegradable substances,
and many others.
lle: Avoid treating air by trans-
ferring pollutant to water, and avoid
treating water by transferring pollu-
tant to air. While such transferal
may work for a while, ultimately it
is a waste of money. It may be that
by moving the discharge from one
point to another, some permit flexi-
bility can be obtained. But, it is just
good stewardship - and good eco-
nomics - to not spend money on a
system that really doesn't accom-
plish an environmental benefit. If
solvent is air-stripped from water,
sooner or later the exhaust air will
need to be treated, at added capital
cost. Scrubbing may, in some cases,
not actually reduce emissions at all,
but rather just transfer the point of
emission from the process stack to
the aeration basin.
If all else fails ...
Developing the waste inventory
can often be difficult. Some multi-
56 • APRIL 1999 • CHEMICAL ENGINEERING PROGRESS
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Address I Address I
Second : First
1 clude the wastewater treatment
Path of
Highest
Impact
To Rnd the Second
Issue to Address
product plants know fairly well the
weights of the raw materials fed, the
products manufactured, and the
manifested wastes generated, but
don't know wastewater or exhaust
flows . Air and water flow rates may
not be accurately measured, and
even isolating one processes stream
from another can be confounded by
complicated chemical sewer or ex-
haust networks.
These plants should apply
Heuristic Number 12: Think like a
salmon. This means find where
streams come together at a common
point, and measure flow and con-
centration. Such common points in-
plant or publicly owned treatment
works (POTW) discharge, com-
bined process exhausts, scrubber or
oxidizer inlets, hazardous-waste
management areas, and storm-sewer
outfalls.
Then, "swim upstream." Take a
sample and flow measurement of
each branch upstream of the point
where the streams meet. Choose the
branch with the worst impact and
"swim" upstream again to the next
dividing point, and so on, until you
reach the highest impact source of
pollution. Address that source using
the other heuristics already dis-
cussed. Then, retreat to the next-
highest impact branch and repeat the
procedure. This process is dia-
grammed in Figure 1.
Concluding remarks
Since the challenges presented by
multiproduct plants involve pollu-
tion generated by activities other
than the routine manufacture of
products, the heuristics presented
here for addressing these challenges
also extend well beyond routine pro-
duction. It is hoped that these guide-
lines will be helpful to you in your
pollution prevention and waste treat-
ment efforts. It's a big job, so let's
get started. DD
S. le Sa1G£1 is laadernf.enviro,runental science
_:and engineering. et OWens Coming's Science
andTechnoloqy Center, Gra1Willa; OH_!Phone:
· 17401 :µNi!!!l2; Fax: ~40l 32l-7567; e;m,il:
_scott.berger@owe~corning.com). _~a has
_more than 20 ya•FSof experience in-pollution
pr!!veftlion, environmental .engineering; am!
prnc;6$$ research and d11valopmant. Ke
· .wo1ed tor Rohm and ~aasfor 1,8 years
. b.etor, joinl11g Owens .coming in 1~- He
, ~btained his ~Sand,MS in chemical _ ·
engineering ffOIJI ~as$8'chuselt$ lnSlitl!te of
Telihnnloov in 1978, Scott ln m.em~er of
AIChE and is tl'ie 1999 vice chair of AIChE's
C11nterfor Waste Reduction Technologies. _