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EPA530-R-96-008
PB96-196 753
ERRATUM
PREFACE
This document was developed by the United States Environmental Protection Agency
(U.-S. EPA),, Office of Solid Waste, Waste Minimization Branch.
The Agency would like to acknowledge Dr. Keith Legg of BIRL, Northwestern .
University; Dr. Arnold H. Deutchman, BEAMALLOY Corporation; Canada, OECD Secretariat
staff; and the American Electroplaters and Surface Finishers Society for the helpful comments
they provided on this document.
For further information, please contact:
U.S. EPA
Hazardous Waste Minimization and Management Division
401 M Street, S.W., 5302W
Washington, DC 20460
Phone: (703)308-8414
Fax: (703)308-8433 ' '
DISCLAIMER
This document has been subjected to U.S. Environmental Protection Agency's peer and
administrative review and approved for publication. This document is intended as advisory
guidance only in developing approaches for pollution prevention. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
-------
-------
PREFACE
This document was developed by the United States Environmental Protection Agency
(U.S. EPA), Office of Solid Waste, Waste Minimization Branch.
The United States would like to acknowledge the American Petroleum Institute for the
helpful comments they provided on this document.
For further information, please contact:
U.S. EPA
Hazardous Waste Minimization and Management Division
401 M Street, S.W., 5302W
Washington, DC 20460
Phone: (703)308-8414
Fax: (703) 308-8433
DISCLAIMER
This document has been subjected to U.S. Environmental Protection Agency's peer and
administrative review and approved for publication. This document is intended as advisory
guidance only in developing approaches for pollution prevention. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
Waste Minimization for
Petroleum Refineries
August 1996
-------
TABLE OF CONTENTS
1.0 Industry Overview • • < '"'
1.1 Metal Plating Industry • • *~*
1.2 Overview of Metal Plating Processes • '"1
1.2.1 Electroplating , ' ' i ?
1.2.2 Chemical and Electrochemical Conversion 1-2
1.2.3 Case Hardening , 1-2
1.2.4 Metallic Coatings • 1'2
1.3 Waste Stream Characterization 1'2
1.4 Waste Minimization/Pollution Prevention Techniques 1-3
1.5 Policy Approaches Promoting Pollution Prevention and Cleaner
Production • • '^
1.5.1 U.S. Policy Approaches 1"3
1.5.2 International Policy 1-9
An Overview of Individual Country Programs 1-9
The European Community • '» • 1"9
The Nordic Council • , , • 1~9
International Programs ....... 1-14
1.5.3 NAFTA - 1-15
1.5.4 Future Trends • 1"16
1.5.5 Sustainable Development 1'16
1.6 Implications and Evaluation of Policies • 1~16
1.7 Technical Report Organization . . , 1-18
2.0 Waste Stream Characterization . • • • • 2~1
2.1 Life Cycle for Wastes from Metal Plating Operations 2-1
2.2 Air Emissions • • > • ' ' ' o"i
2.2.1 Waste Stream Identification 2"1
Solvents 2~1
Chromium 2"1
2.2.2 Waste Generation Mechanisms 2~1
Solvents . .,.....,., 2-1
Chromium 2-3
2.2.3 Waste Stream Quantities and Composition • • 2-3
Solvents . , . . 2-3
Chromium 2-3
2.2.4 Pollution Control and Treatment Methods 2-3
Solvents • • • • 2"3
Chromium ......... 2-4
2.3 Wastewater • • 2-5
2.3.1 Waste Stream Identification • 2-5
2.3.2 Waste Generation Mechanisms • 2~5
2.3.3 Waste Stream Quantities and Composition 2-5
2.3.4 Control and Treatment Methods 2-6
-------
TABLE OF CONTENTS (Continued)
2.4 Solid and Hazardous Waste 2-8
2.4.1 Waste Stream Identification 2-8
2.4.2 Waste Generation Mechanisms 2-8
2.4.3 Waste Stream Quantities and Composition 2-8
2.4.4 Pollution Control, Treatment, Recovery and Disposal Methods 2-9
2.5 Key Players/Stakeholders Involved with Metal Plating Waste
Generation and Management . . . 2-9
3.0 Waste Minimization/Pollution Prevention Techniques 3-1
3.1 General 3-1
3.2 Alternative Processes 3-1
3.2.1 Organization of this Section , 3-4
3.2.2 Thermal Spray Coatings . . r 3.4
Technology Description 3-4
Process Description . . . . , 3.4
Specific Technologies 3-5
Cost 3.5
Stage of Development , 3.5
Waste Generation/Environmental and Safety Considerations . . 3-5
3.2.3 Vapor Deposition 3.5
Technology Description 3-5
Physical Vapor Deposition 3.5
Waste Management/Environmental and Safety Considerations 3-5
— Chemical Vapor Deposition . . . ? 3-6
Waste Generation/Environmental and Safety Considerations . . 3-6
3.3 Product and Input Material Changes 3-6
3.3.1 Product Changes 3-6
3.3.2 Input Material Changes 3-6
Chlorinated Solvents 3-6
Cyanide . 3-8
Cadmium 3.3
Chromium . 3.9
3.4 General Waste Reduction Practices , 3-9
3.4.1 Improved Operating Procedures 3-9
Employee Education 3.9
Chemical Tracking, Inventory, and Purchasing Control ..... 3-10
3.4.2 Drag-Out Reduction , . . . 3-10
3,4.3 Rinse Water Use Reduction 3-10
3.4.4 Air Emissions Reduction . . . . , 3-10
3.5 Process Solution Maintenance 3-10
3.5.1 Conventional Maintenance Methods 3-10
3.5.2 Advanced Maintenance Technologies , 3-11
Microfiltration 3-11
Ion Exchange , 3-11
HI
-------
TABLE OF CONTENTS (Continued)
Acid Sorption 3-11
Ion Transfer 3-11
3.6 Chemical Recovery Technologies 3-11
3.6.1 Evaporation 3-11
3.6.2 Ion Exchange 3-14
3.6.3 Electrowinning 3-14
3.6.4 Electrodialysis 3-14
3.6.5 Reverse Osmosis 3-16
3.7 Off-Site Metals Recycling 3-16
3.7.1 Available Services 3-16
3.7.2 Recycling Costs 3-17
4.0 Examples of Waste Minimization/Pollution Prevention Techniques 4-1
4.1 Thermal Spray Technologies 4-1
4.1.1 Combustion Torch/Flame Spraying 4-1
Limits and Applicability 4-1
Specific Applications 4-1
4.1.2 Combustion Torch/High Velocity Oxy-Fuel (HVOF) 4-1
Limits and Applicability 4-1
Specific Applications 4-1
4.1.3 Combustion Torch/Detonation Gun 4-1
Limits and Applicability 4-1
Specific Applications 4-1
4.1.4 Electric Arc Spraying 4-1
Limits and Applicability 4-1
Specific Applications 4-2
4.1.5 Plasma Spraying 4-2
Limits and Applicability 4-2
Specific Applications 4-2
4.2 Physical Vapor Deposition Technologies 4-2
4.2.1 Ion Plating/Plasma Based 4-2
Limits and Applicability/Current Development 4-2
Current Uses/Specific Applications 4-2
Costs 4-2
4.2.2 Ion Plating/Ion Beam Enhanced Deposition (IBED) . 4-2
Limits and Applicability/Current Development 4-2
Current Uses/Specific Applications 4-3
Costs 4-3
4.2.3 Ion Implantation 4-3
Limits and Applicability/Current Development 4-3
Current Uses/Specific Applications 4-3
Costs 4-3
4.2.4 Sputtering and Sputter Deposition 4-3
Limits and Applicability/Current Development 4-4
IV
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TABLE OF CONTENTS (Continued)
Current Uses/Specific Applications ................... 4.4
Costs ............................ ...... ..... 4.4
4.2.5 Laser Surface Alloying .......................... 4.4
Limits and Applicability/Current Development ............ 4.4
Current Uses/Specific Applications ................... 4.5
Costs ................................... .... 4-5
4.3 Chemical Vapor Deposition .......................... 4.5
4.3.1 Process Description ............................ [ 4.5
Limits and Applicability .... ...................... " 4.5
Current Uses/Specific Applications ................... 4.5
Costs ................................... .... 4-5
4.4 Drag-Out Reduction Techniques .............. ......... ... 4.5
4.4.1 Plating Solution Control ................. '.'.'.'.'.'.'.'.'.'. 4-5
Impacts ................................. 4_5
4.4.2 Positioning Parts on Rack ..................... .... 4-6
Impacts ............................... 4_g
4.4.3 Withdrawal Rates and Drainage .................. ... 4.5
Impacts ................................. 4_g
4.4.4 Rinsing Over Process Tanks ................. ....... 4-6
Impacts ............................... 4_6
4.4.5 Drag-Out Tank ............... ............... . . . 4-6
Impacts ................................. 4_6
4.4.6 Drag-In Drag-Out tank ................... ......... 4-6
Impacts ............................... 4_6
4.5 Rinse Water Reduction Techniques ............... ......... 4-6
4.5.1 Tank Design .......................... ...... 4_6
Impacts .............................. ....... 4_6
4.5.2 Flow Controls ........................ ....... 4-6
Impacts ................................ • • • • ^ ^
4.5.3 Rinsing Configuration ...................... ...... 4-7
Impacts ........................... 4_y
4.6 Summary of Advanced Maintenance Technologies ........... 4.7
4.6.1 Microfiltration ..... ......... A-J
............................... **•- 1
Applications and Restrictions ............... 4.7
Costs ............................ ........... 4-7
4.6.2 Ion Exchange .......................... 4_8
Applications and Restrictions ............. 4_8
Costs ........................... ............ 4-8
4.6.3 Acid Sorption ......................... ' 4_g
Applications and Restrictions ..... ........ 4_8
Costs ...................... ................' 4-9
4.6.4 Ion Transfer ......................... ' 4_g
Applications and Restrictions ................... ... 4.9
Costs ................. . .......... ........... 4-9
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TABLE OF CONTENTS (Continued)
4.7 Chemical Recovery Technologies4-9
4.7.1 Atmospheric Evaporation • •
Applications and Restrictions
Costs
4.7.2 Vacuum Evaporators
Applications and Restrictions . • • -
Costs 4-11
4.7.3 Ion Exchange ~ ' '
Applications and Restrictions •
Costs.-..
4.7.4 Electrowmning
Applications and Restrictions "
Costs • 4-13
4.7.5 Electrodialysis A\A_
Applications and Restrictions 4-14
Costs • ' 4-14
4.7.6 Reverse Osmosis 4"J4
Applications and Restrictions • 4-15
Costs 4-15
5.0 Tools for Evaluating Pollution Prevention Opportunities 5-1
5.1 Cost Analysis ~~J
5.1.1 Traditional Accounting/Budgeting Approaches o-i
5.1.2 Ways To Improve Cost Analysis 5-1
Expanding Cost Inventories 5-1
Expanding Time Horizons 5-1
Definitions and Terms • 5"2
Evaluating Financial Performance 5-2
5.1.3 Application Of Improved Cost Analysis To The Metal Plating
Operations •• • ^
5.1.4 Overcoming Existing Challenges • 5-3
Proper Allocation of Cost Categories • 5-3
Placing Value on Future Costs and Benefits • 5-6
5.1.5 Getting Started ' ' K o
5.2 Conducting a Pollution Prevention Opportunity Assessment 5-8
5.3 Pollution Prevention Program Plan Development • • • 5-9
5.3.1 Introduction • • 5-JJ
5.3.2 Developing a Pollution Prevention Program Plan 5-10
Establishing Goals and Objectives 5-10
Obtain Management Commitment 5-10
K *1 C\
Team Building b^IU
Developing a Baseline 5-11
5.3.3 Identify Pollution Prevention Activities 5-11
VI
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TABLE OF CONTENTS (Continued)
5.3.4 Develop Criteria and Rank Pollution Prevention Activities . .
5.3.5 Conduct Management Review
5-12
5-12
APPENDIX A INTERNATIONAL POLICY APPROACHES
APPENDIX B IMPLICATION AND EVALUATION OF POLICIES
APPENDIX C U.S. FEDERAL AND STATE POLLUTION PREVENTION
POLICY/PLANS
APPENDIX D POLLUTION PREVENTION CONTACTS
vii
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LIST OF EXHIBITS
Exhibit 1-1. Overview of Chemical Use and Waste Generation in a Plating
Shop ]'*
Exhibit 1-2. Major Metal Plating Wastes and Constituents i-o
Exhibit 1-3. Waste Minimization Opportunities Available to the Metal
Plating Industry 1"6
Exhibit 1-4. Waste Minimization/Pollution Prevention Methods and
Technologies
Exhibit 1-5. Summary of U.S. Policies and Programs Relevant to Metal
Finishing Industry ]'J^
Exhibit 1-6. International Waste Minimization Programs 1-13
Exhibit 1-7. Listings of Materials Wanted and Materials Available by
Category from the National Material Exchange Network .... 1-15
Exhibit 1-8. TRI Release Data for SIC 3471 (1988 - 1992) 1-17
Exhibit 2-1. Overview of Chemical Use and Waste Generation in a Plating
Shop ; • l~*
Exhibit 2-2. Control Equipment Combinations and Idling Limits . ^-4
Exhibit 2-3. Effectiveness of Emission Control Techniques on Open-Top
Degreasers ~~^
Exhibit 2-4. Drag-Out Rate Estimates for Various Part Types 2-5
Exhibit 2-5. Average Plating Discharge Rate of Survey Respondents
(gallons per day) ^-6
Exhibit 2-6. Conventional End-Of-Pipe Treatment System 2-7
Exhibit 2-7. Analytical Data for F006 Sludges Provided by Respondents
to the Users Survey 2-10
Exhibit 2-8. Summary of Potential Stakeholders 2-' '
Exhibit 3-1. EPA's Environmental Management Hierarchy 3-2
Exhibit 1-3. Waste Minimization/Pollution Prevention Methods and
Technologies 3~3
Exhibit 3-3. Summary of Advanced Coating Technologies 3-4
Exhibit 3-4. Status of Material Substitution 3-7
Exhibit 3-5. Example of Microfiltration Application 3-12
Exhibit 3-6. Two Common Configurations of Ion Exchange for Bath
Maintenance 3-12
Exhibit 3-7. Typical Acid Sorption Configuration 3-13
Exhibit 3-8. Typical Ion Transfer Configuration 3-13
Exhibit 3-9. Two Common Configurations for the Application of
Atmospheric Evaporators 3-14
Exhibit 3-10. Common Ion Exchange Configurations for Chemical Recovery 3-15
Exhibit 3-11. Two Common Electrowinning Configurations for Metal
Recovery 3"15
Exhibit 3-12. Flow Schematic of Nickel Plating Line Before and After
Installation of Electrodialysis 3-16
Exhibit 3-13. Typical Reverse Osmosis Configuration for Nickel Recovery . . 3-17
VIII
-------
LIST OF EXHIBITS (Continued)
Exhibit 5-1. Cost Categories 5-2
Exhibit 5-2. Cost Savings from Metal Plating Waste Minimization 5-4
Exhibit 5-3. Ranked Options for a Hypothetical Metal Plating Shop 5-12
IX
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LIST OF ACRONYMS AND ABBREVIATIONS
ABC Activity-based costing
ACE Agriculture in Concert with the Environment
AESF American Electroplaters and Surface Finishers Society
AFB Air Force Base
BAT Best available technique/technology
BPC Biparting cover
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFC Chlorofluorocarbon
CFR Code of Federal Regulations
CTSAs Cleaner technology substitutes assessments
CVD Chemical vapor deposition
CVR Manual cover
CWA Clean Water Act
DEP Department of Environmental Protection
DOD U.S. Department of Defense
DOE Department of the Environment (United Kingdom)
DfE/DFE Design for the Environment
DTI Department of Trade and Industry
DWL Dwell
EC European Community
EEM Energy, Environment, and Manufacturing
EMAP Environmental Monitoring and Assessment Program
EO Executive Order
EPA U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ESP Electrostatic Precipitator
EST Eastern Standard Time
FBR Freeboard ratio
FR Federal Register
FRD Freeboard refrigeration device
gpd Gallons per day
HAP Hazardous air pollutant
HCFCs Hydrochlorofluorocarbons
HMD? Her Majesty's Inspectorate of Pollution
-------
LIST OF ACRONYMS AND ABBREVIATIONS (Continued)
HSWA
HVOF
HWRIC
IBED
ICOLP
ICPIC
IMOF
IRR
IPPG
LCC
LLCHD
LQG
MACT
MOE
MSW
NAFTA
NAMF
NESHAPS
NICE3
NMEN
NPDES
NPV
NRA
ODS
OECD
OTA
P2
PCB
PERC
PFCs
PG
PIES
POTW
PPA
PPCD
PPIC
Hazardous and Solid Waste Amendments
High velocity oxygenated fuel
Illinois Hazardous Waste Reduction Information Center
Iron beam enhanced deposition
Industry Cooperative for Ozone Layer Protection
International cleaner production information clearinghouse
Interim Multilateral Ozone Fund
Internal rate of return
Integrated pollution prevention and control
Life cycle costing
Lincoln-Lancaster County Health Department
Large quantity generator
Maximum achievable control technology
Ministry of the Environment
Municipal solid waste
North American Free Trade Agreement
National Association of Metal Finishers
National Emission Standards for Hazardous Air Pollutants
National Industrial Competitiveness Through Efficiency: Energy,
Environment and Economics
National Material Exchange Network
National Pollutant Discharge Elimination System
Net present value
National Rivers Authority
Ozone depleting substances
Organisation for Economic Cooperation and Development
Office of Technical Assistance
Pollution prevention
Polychlorinated biphenyl
Perchloroethylene
Perfluorocarbons
Provincial government
Pollution Prevention Information Exchange System
Publicly owned treatment work
Pollution Prevention Act
Pollution prevention control group
Pollution Prevention Information Clearinghouse
XI
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LIST OF ACRONYMS AND ABBREVIATIONS (Continued)
PPIS Pollution Prevention Incentives for States
PV Present valve
PVD Plasma vapor deposition
RCRA Resource Conservation and Recovery Act
RRD Reduced room draft
SARA Superfund Amendments and Reauthorization Act
SEDTJE Secretaria de Desarrollo Urbano y Ecologia
SEP Supplemental environmental program
SFT State Pollution Control Authority
SHV Superheated vapor
SIC Standard industrial code
SIP Sustainable industry project
SMEs Small and medium enterprises
SRRP Source reduction review project
TCA 1,1,1 trichloroethane
TCA Total cost assessment
TCE Trichloroethylene
TDS Total dissolved solids
TRI Toxics Release Inventory
TSCA Toxic Substances Control Act
U.K. United Kingdom
UNEP United Nations Environment Programme
US/U.S. United States
USC United States Code
USDA U.S. Department of Agriculture
USEPA U.S. Environmental Protection Agency
VOC Volatile organic carbon
WMPG Waste Management Policy Group
WRA Waste Regulation Authority
WREAFS Waste Reduction Evaluations at Federal Sites
WRITAR Waste Reduction Institute for Training and Applications Research, Inc.
XII
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1.0 INDUSTRY OVERVIEW
1.1 Metal Plating Industry
Metal finishing operations are employed at some
point during the manufacture of essentially all metal
products. The manufacturing industries that rely most
heavily on metal plating and finishing processes
include fabricated metal products (e.g., metal cans,
fasteners, tools, metal furniture), common machinery
(e.g., engines, farm equipment, construction equipment,
manufacturing machinery), electronic machinery (e.g.,
computers, office equipment, audio and visual elec-
tronics), household appliance (e.g., washing machines,
refrigerators, small kitchen appliances), ground and
water transportation equipment (e.g., automobiles,
trucks, rail vehicles, boats), aerospace equipment (e.g.,
aircraft, satellites), and miscellaneous manufacturing
(e.g., jewelry, musical instruments, toys).
Metal finishing operations are either captive shops
or job shops. Captive shops perform finishing
activities on the parts that they manufacture and/or that
they subsequently use in downstream manufacturing.
Job shops are separate entities that do not manufacture
parts or use their products in other manufacturing
applications. Job shops are a service industry that
provides metal finishing for manufacturers.
In the United States, there are approximately
10,000 captive metal finishing operations and 3,500
job shops. These facilities are overwhelmingly located
(80%) in highly industrialized regions of the northeast,
midwest, and far west. Most of the shops are small]
but a few large operations exist (the average shop
employs 65 people, and the median facility employs
just 35). Similarly, the average plant discharges
37,000 gpd of wastewater, and the median facility
discharges only 14,000 gpd. Most plating facilities are
reasonably new by industrial standards with the
average and median facility age of 28 years.
With the exception of leading edge technology,
relatively few technological differences exist between
the metal finishing processes used by different
countries. This is due to the following factors: sim-
plicity of conventional metal finishing technologies and
the limited requirement for skilled labor; expansion of
major chemical suppliers to a world-wide market;
world-wide trade organizations and other forms of
international cooperation; and open access to major
universities and" colleges where research is conducted.
Significant differences do exist in metal plating
operations, however, depending on the level of
economic development across nations, variations in
demand for sophisticated plating applications, the
availability of capital, and environmental law and
regulatory constraints. Over the past 10 to 20 years,
metal platers in developed countries have undergone a
major technological shift from decorative finishes, such
as nickel-chrome coatings on steel and zinc diecast
parts, to specialty finishes and more processing of
aerospace and electronic parts. Metal platers in less
developed nations have not been forced to respond to
these changes and have, as a result, experienced far
fewer and less rapid technological advancements.
Similarly, developed countries have stable or decreas-
ing needs for unskilled labor due to automation; these
trends have not occurred in less developed nations.
The scope and stringency of environmental
regulations applicable to the metal plating industry are
also increasing. Such changes have forced nearly all
metal platers to increase investments in pollution
control equipment, employee training, and waste
treatment and disposal services. The level of these
requirements and the ability of metal platers to respond
to these increased standards is not uniform, however.
In many countries, the struggle to comply with more
stringent environmental requirements has been difficult
due to the concurrent world-wide recession of the
1980's. In fact, some countries have witnessed the
demise of 30 to 50 percent of their plating industry
during the past decade. Even within developed
countries, platers are faced with non-uniform
requirements and enforcement.
1.2 Overview of Metal Plating Processes
Metal finishing comprises a broad range of
processes that are practiced by most industries engaged
in manufacturing operations using metal parts.
Typically, metal finishing is performed on manufac-
tured parts after they have been shaped, formed,
forged, drilled, turned, wrought, cast, etc. A "finish"
can be defined as any final operation applied to the
surface of a metal article in order to alter its surface
properties to achieve various goals. Metal finishing
operations are intended to increase corrosion or
abrasion resistance, alter appearance, serve as an
improved base for the adhesion of other materials (e.g.,
other metals, paints, lacquers, oils), enhance frictional
characteristics, add hardness, improve solderability,
add specific electrical properties, or improve the utility
of the product in some other way. Common metal
finishes include paint, lacquer, ceramic coatings, and
electroplating.
1-1
-------
Industry Overview
Plating and surface treatment processes are
typically batch operations, in which metal objects are
dipped into and then removed from baths containing
various reagents to achieve the desired surface
condition. The processes involve moving the object
being coated through a series of baths designed to
produce the desired end product. These processes can
be manual or highly automated operations, depending
on the level of sophistication and modernization of the
facility and the application.
Plating operations can generally be categorized as
electroplating and electroless plating processes. Sur-
face treatment includes chemical and electrochemical
conversion, case hardening, metallic coating, and
chemical coating. Most metal surface treatment and
plating operations have three basic steps: surface
cleaning or preparation, which involves the use of
solvents, alkaline cleaners, acid cleaners, abrasive
materials, and/or water; surface modification, which
involves some change in surface properties, such as
application of a metal layer or hardening; and rinsing
or other workpiece finishing operations to produce the
final product.
The following discussion briefly describes the
major plating and surface treatment processes to
provide a context for the more in-depth discussion of
waste minimization and pollution prevention opportun-
ities available to the industry.
1.2.1 Electroplating
Electroplating is achieved by passing an electrical
current through a solution containing dissolved metal
ions and the metal object to be plated. The metal
object serves as the cathode in an electrochemical cell,
attracting metal ions from the solution. Ferrous and
non-ferrous metal objects are plated with a variety of
metals, including aluminum, brass, bronze, cadmium,
copper, chromium, iron, lead, nickel, tin, and zinc, as
well as precious metals, such as gold, platinum, and
silver. The process is regulated by controlling a
variety of parameters, including the voltage and
amperage, temperature, residence times, and the purity
of bath solutions. Plating baths are almost always
aqueous solutions; therefore, only those metals that can
be reduced from aqueous solutions of their salts can be
electrodeposited. The only major exception is alumi-
num, which can be plated from organic electrolytes.
The sequence of unit operations in an electro-
plating operation typically involves various cleaning
steps, stripping of old plating or paint, electroplating
steps, and rinsing between and after each of these
operations. Electroless plating uses similar steps but
involves the deposition of metal on a substrate without
the use of external electrical energy.
1.2.2 Chemical and Electrochemical
Conversion
Chemical and electrochemical conversion treatments
deposit a protective and/or a decorative coating on a
metal surface. In some instances, these processes can
also be a preparatory step prior to painting. Chemical
and electrochemical conversion processes include
phosphating, chromating, anodizing, passivation, and
metal coloring.
1.2.3 Case Hardening
Case hardening processes result in a hard surface,
or case, over a metal core that remains relatively soft.
The case is wear resistant and durable; the core
remains strong and ductile. Case hardening methods
include carburizing, carbonitriding, nitriding, micro-
casing, and hardening using localized heating and
quenching.
1.2.4 Metallic Coatings
Metallic coatings provide a layer that changes the
surface properties of the workpiece to those of the
metal being applied. The workpiece becomes a
composite material exhibiting properties generally not
achievable by either material if used alone. The
coatings provide a durable, corrosion-resistant layer,
and the core material provides the load bearing capa-
bility. Metallic coatings include diffusion coatings,
spraying techniques, cladding, vapor deposition, and
vacuum coating. Because these processes do not
involve the use of aqueous solutions, they may offer
significant potential pollution prevention benefits over
conventional electroplating operations in specific
applications. As such, these techniques are discussed
in greater detail in Section 3, Waste Minimization/
Pollution Prevention Techniques.
1.3 Waste Stream Characterization
The plating industry is somewhat unusual among
manufacturing industries at present because the vast
majority of the chemicals used end up as waste. The
current inefficiency of material use is due to the
inherent characteristics of the processes employed
where parts are immersed into concentrated tanks of
chemicals and are subsequently rinsed in rinse tanks
that flow with fresh water. The resultant wastewater
makes up the greatest volume of waste material from
plating operations.
Wastewater is generated during rinsing operations.
Rinsing is necessary to remove the thin film of
concentrated chemicals (i.e., drag-out) that adheres to
parts after their removal from process baths (e.g.,
plating solution). Wastewaters are usually treated on-
site. This treatment generates a hazardous sludge that
must be disposed of in an approved landfill or sent to
1-2
-------
Industry Overview
a recovery site for metals reclamation. Exhibit 1-1
presents an overview of chemical use and waste
generation in the plating shop and a portion of their
life cycle.
Residual metals in wastewaters discharged by
plating shops to municipal sewer systems will be
partially removed by the biological treatment process
of the municipality (also generating a sludge) and the
remainder will be discharged to a water body. Process
baths are discharged periodically when they lose their
effectiveness due to chemical depletion or contamina-
tion. Accidental discharges of these chemicals occur
sometimes (e.g., when a tank is overfilled). These
concentrated wastes are either treated on-site or are
hauled to an off-site treatment or recovery facility.
With respect to air emissions, the greatest con-
cerns with plating shops are solvents and chromium.
Solvents are partly evaporated during degreasing
operations. Contaminated liquid solvents are either
recovered by distillation (on-site or off-site) or sent for
disposal (incineration). Chromium is released to the
air by plating and anodizing processes. Most shops do
not have controls for organics; however, some larger
plants use carbon adsorption units to remove hydro-
carbons. Chromium emissions and other heavy metals
are frequently controlled by the use of wet scrubbers.
The discharge of these systems is sent to the
wastewater treatment system and combined with other
wastewaters for processing.
Plating also generates other miscellaneous sources
of wastes, including floor wash waters, stormwater,
and chemical packaging wastes. Exhibit 1-2 identifies
the major waste streams from typical metal plating
operations, as well as the major waste constituents of
concern from both regulatory and environmental risk
perspectives.
1.4 Waste Minimization/Pollution
Prevention Techniques
During the past 10 to 15 years, innovative
members of the plating industry have made significant
strides in developing and implementing preventative
methods of pollution control. In some cases, waste
minimization methods and technologies have been
responsible for reducing waste volumes by up to 90
percent. Associated with the decrease in waste
generation are a reduction in end-of-pipe equipment
purchases, improvements in effluent compliance,
improvements in product quality, and significant cost
savings in raw materials.
In fact, metal plating and finishing operations
represent some of the best and most classic applica-
tions of pollution prevention approaches. Numerous
opportunities exist for source reduction ranging from
complex technological advances to relatively simple
and inexpensive operational changes. Exhibit 1-3
presents waste minimization opportunities applicable to
the metal plating industry in the context of the U.S.
Environmental Protection Agency's (USEPA) waste
management hierarchy (waste management via source
reduction, recycling and reuse, and, as a last resort,
environmentally sound treatment and disposal). It
should be noted that many lower technology waste
minimization options, including process recovery and
reuse, improved operating procedures, and use of
waste exchanges and off-site recovery options,
represent significant opportunities for waste reduction
often with relatively low investment requirements.
Similarly, options such as product replacement (e.g.,
paints, plastics) may represent the ultimate pollution
prevention option. Product replacement and similar
approaches are largely driven by end users and
consumer preferences and are not likely to be favored
by the plating industry.
Exhibit 1-4 presents a more detailed identification
of the specific waste reduction techniques that have
documented applicability to metal plating processes
and briefly describes the applications and limitations of
each. All of these methods are described in detail in
the body of the paper with discussions of the current
use and applicability, limitations, and costs associated
with purchasing, installing, and operating the various
technologies.
1.5 Policy Approaches Promoting
Pollution Prevention and Cleaner
Production
In the United States and abroad, there has been a rapid
expansion in the number and types of laws and
policies focusing on pollution prevention and cleaner
production. These laws and policies generally rely on
planning; the creation of incentives; imposition of
reporting requirements; and other indirect means of
fostering waste reduction. In most countries, these
policies work in tandem with traditional environmental
regulations that create financial and liability-based
incentives for industrial and manufacturing operations,
including metal finishers, to reduce waste generation.
1.5.1 U.S. Policy Approaches
Given the substantial environmental regulatory
framework that exists in the United States, the current
approach appears to rely on creating both positive and
negative incentives, as well as on developing the tools
needed to foster waste reduction.
The positive incentives being promoted take the
form of cost savings through improved efficiency,
1-3
-------
Exhibit 1-1. Overview of Chemical Use and Waste Generation in a Plating Shop
Miso.Wastewater
(e.g. floor wash)
Solvent
Evaporation
Decreasing
Contaminated Solvent
Disposed or Recovered
by Distillation
Process
Chemicals
Contaminated Bath
Hauled to Disposal
or Treated On-site
Air Emissions
Wastewater
Treatment
System
Municipal Landfill
or Land Application
Sludge Hauled
to Disposal Site
Accidental Overflows
or Leaking Tanks Can
Result in Concentrated
Wastes
Wastes Can Leach
into Groundwater
Improper Material Storage
Q.
I
615E-03
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Industry Overview
Exhibit 1-2. Major Metal Plating Wastes and Constituents
Air Emissions
Solvent releases from degreasing
operations
Chromium
Wastewaters
Rinse Water
Spent Baths
Scrubber Slowdown
Cooling Water
Solid and Hazardous Wastes
Solvent Wastes
• Spent contaminated solvents
• Still bottoms from solvent recovery
Spent Process Solutions
• Alkaline cleaners
• Acid etching solutions
• Plating solutions
Wastewater Treatment Sludge
Key Constituents
Solvents
1,1,1-Trichloroethane
Trichlorethylene
Perchloroethylene
Chlorofluorocarbons
Methylene chloride
Acetone
Toluene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Metals
Cyanide
Chromium
Cadmium
Nickel
Aluminum
Copper
Iron
Lead
Tin
Zinc
U.S. and International Waste Reduction
Policy Approaches
• Direct regulation of materials used by or
emissions produced by metal finishers
• Phase-out of harmful materials used by
metal finishers
• Grant programs
• Information clearinghouses and technology
transfer
• Reporting requirements
• Certification programs
• Creative enforcement programs
• Voluntary programs targeting specific
harmful chemicals
• Research and development assistance
• Federal facility programs
• Tax/economic incentives
• Waste exchanges
reduced liability, improved competitiveness, and a
positive public image. These benefits are being
promoted through participation in voluntary programs,
as well as through increased emphasis on more
efficient production by individual companies and
industry sectors. The waste reduction tools include
new technologies, materials, and practices that often
developed with the support of grants, technology
transfer, or information exchange. Mechanisms such
as the Toxics Release Inventory (TRI) also serve as
tools for measuring progress in waste reduction, a
necessary function if progress is to be quantified.
The negative incentives that are part of U.S. waste
reduction policy include the traditional burdens of
regulation: increased treatment and disposal costs and
increased potential liability. These burdens force metal
finishers and others to seriously consider waste
reduction opportunities.
Within the United States, much of the waste
reduction activity is occurring at the State level. States
have been willing to be more direct in addressing
pollution prevention—requiring industries to meet
planning requirements and promoting pollution preven-
tion through multi-media inspections and through
creative permit requirements. Some States, such as
Minnesota, Wisconsin, North Carolina, and Michigan,
have developed workshops and publications focusing
on pollution prevention within the metal finishing
industry.
Another important area of activity in the United
States is federal facilities. Federal facilities, which
encompass many types of production processes, includ-
ing metal finishing, are subject to recent Executive
1-5
-------
1
Exhibit 1-3. Waste Minimization Opportunities Available to the Metal Plating Industry
Category of Waste
Minimization Options
Examples
Applications
Limitations
General Waste Reduction
Practices
Improved operating procedures
Drag-out reduction
Rinse-water use reduction
Air emissions reduction
Applicable to all conventional plating
operations
Should be considered standard
operating procedures and/or good
design
Cost benefits typically outweigh any
necessary expenditures
Existing facilities may be able to
accommodate changes due to process
configuration, space constraints, etc.
Alternative Processes
Thermal Spray Coatings
• Combustion torch
• Electric arc
• Plasma sprays
Vapor Deposition
• Ion plating
• Ion implantation
• Sputtering and sputter deposition
• Laser surface alloying
Chemical Vapor Deposition
Primarily repair operations although
they are now being incorporated into
original manufacturing
Primarily high-technology applications
that can bear additional costs
Expected to improve product quality
and life
Technologies in varying states of
development; commercial availability
may be limited in certain cases
Expense often limits application to
expensive parts (e.g., aerospace,
electronics, military)
May require improved process controls,
employee training, and automation
3
a
c
O
CD
Process Substitution
Product changes
Input material changes
• Chlorinated solvents
• Cyanide
• Cadmium
• Chromium
Applicable to most conventional plating
operations
Captive shops/manufacturers may be
able to explore product changes
Job shops may have little control or
input in decisions
Product changes need to be evaluated
in terms of consumer preferences
Product specifications may eliminate
consideration of some process
substitutes
-------
Exhibit 1-3. Waste Minimization Opportunities Available to the Metal Plating Industry (Continued)
Category of Waste
Minimization Options
Examples
Applications
Limitations
Process Solution Maintenance
Conventional maintenance methods
Advanced maintenance methods
• Microfiltration
• Ion exchange
• Acid sorption
• Ion transfer
• Membrane electrolysis
• Process monitoring and control
Conventional methods applicable to all
plating operations
Advanced methods may require
significant changes in process design,
operation, and chemistry
Application limited for some plating
process/technology combinations (e.g.,
microfiltration not applicable to copper
or aluminum)
Chemical Recovery Technologies
Evaporation
Ion exchange
Electrowinning
Electrodialysis
Reverse osmosis
Requires significant engineering,
planning, and characterization of
process chemistry
Costs are highly variable for advanced
methods
Application must be carefully tailored to
process chemistry
3
a
I
O
CD
I
Off-Site Metals Recovery
Filtration
Ion exchange
Electrowinning
Electrolytic recovery
Metal-bearing wastewater treatment
sludge
Waste materials must be acceptable to
recyclers
-------
Exhibit 1-4. Waste Minimization/Pollution Prevention Methods and Technologies
LEAST PREFERRED OPTION
Product Changes
and Process
Substitution
00
Alternative
Products/
Processes
Reduce/Eliminate
use of Chlorinated
Solvents
Reduce/Eliminate
use of
Cyanide
Reduce/Eliminate
use of Cadmium
Reduce/Eliminate
use of
Chromium
Reduce/Eliminate
use of other
Hazardous
Materials
Operation ^^^i
Processes P^"|
-
Improve
Operating
Procedures
Reduce
Drag-out
Losses
Reduce
Rinse Water
Discharges
Reduce
Air
Emissions
Process .
Solution •••1
Maintenance
Conventional
Maintenance
Microfiltration
Ion Exchange
Acid
Sorption
Ion
Transfer
Membrane
Electrolysis
Chemical
Recovery
—
Evaporators
Ion Exchange
Electrowinning
Electrolysis
Recover
Organics
Treatment/
Off-site
Recycle
Physical/
Chemical
Treatment
Off-site Recycle
of Treatment
Residuals
a
c
a
o
I
I
615E-02
-------
Industry Overview
Orders regarding ozone protection, TRI participation,
and overall environmental compliance. Combined,
these requirements are prompting such facilities to
embrace pollution prevention and cleaner production
principles.
Although no single U.S. waste reduction policy
appears to be more effective than any other, several
are worth highlighting. Foremost may be the TRI,
which is not literally a pollution prevention statute but
a public right-to-know (i.e., reporting) law. By quanti-
fying and publicizing the toxic releases emitted by
industry, the TRI has motivated industry to reduce
such releases. The TRI has also become a major
mechanism for measuring progress in waste reduction
programs. It must be noted that TRI data only meas-
ure releases of toxic constituents to the environment
and using these data as a tool to measure waste reduc-
tion is subject to important limitations (e.g., limits on
applicability, changes in reporting requirements,
availability of release data to reporting facilities).
A second noteworthy program is USEPA's 33/50
program, a voluntary program that seeks the reduction
of 17 target toxics, including several used and released
by the metal finishing industry. Preliminary results
indicate that over a 33-percent reduction has been
achieved in the metal fabricating sub-category from the
1988 baseline to 1992. Exhibit 1-5 provides a
summary and overview of U.S. policies and options.
1.5.2 International Policy
An Overview of Individual Country Programs
Most of the policy approaches adopted by various
Organisation for Economic Cooperation and Develop-
ment (OECD) countries are similar to those used in the
United States, combining regulation, incentives, and
information transfer. Typically, these policies are
broad in scope, applying to all industries. For
example, the German federal air pollution law has
general provisions that require minimization of toxic
air emissions, which directly impact the metal finishing
industry. Another example is the recently enacted
United Kingdom (U.K.) Integrated Pollution Control
(IPC) statute that applies to the release of pollutants to
air, water, and land from certain processes. The U.K.
metal finishing industry was directly affected due to
certain prescribed activities, including industrial
cleaning and finishing.
Exhibit 1-6 provides an overview of general
international policy options but does not identify the
application specific to the metal plating industry.
OECD countries are somewhat different from the
United States with respect to the degree to which they
work with their governments on different issues,
including pollution prevention. Governments sponsor
research, develop waste management plans, implement
waste collection and management programs, and help
develop waste-specific reduction programs. Govern-
ments also provide certain funding for waste reduction
research. This close working relationship promotes
communication and understanding, which often results
in the government establishing acceptable waste reduc-
tion goals that achieve a high degree of voluntary com-
pliance. It also recognizes that the expertise regarding
source reduction ultimately resides in industry and
establishes a framework capable of accessing this
expertise. Of the OECD countries, Germany, Japan,
and Denmark are prominent in fostering this type of
public/private relationship.
The European Community
The European Community recently adopted a draft
directive aimed at reducing and controlling pollution
from industrial installations. The directive introduces
a system of integrated pollution prevention and control
(IPPC), which is similar to the integrated pollution
control system now operating in the U.K. under the
Environmental Protection Act of 1990. The distin-
guishing feature of these approaches is that they are
multi-media in scope.
The IPPC requires that operators of industrial
installations in specific categories with a high potential
to cause pollution obtain a permit in order to operate.
Permit applications must include a description of the
proposed measures to prevent or minimize emissions
from the installation and evidence that the installation
meets protective emission limits. The directive covers
the production and processing of metals, as well as
installations using more than 200 kg/h of organic sol-
vent. Smaller scale operations are generally excluded
from the scope of the directive.
The Nordic Council
The Nordic Council, which was formed to
promote cooperation among the parliaments and
governments of Denmark, Iceland, Norway, Sweden,
and Finland, met in March 1992 and developed the
Nordic Action Programme on Cleaner Technologies.
This program builds on the conclusions of the Brundt-
land Commission concerning the need to reduce energy
consumption and to develop cleaner technologies. The
program is divided into four areas: information
exchange, substitution of toxic components and pro-
ducts that impede recycling, employment of adminis-
trative control measures to encourage the use of clean
technologies, and education regarding clean techno-
logies. The Council has set up an industry network to
disseminate information on Nordic cleaner techno-
logies, hosted industry-specific seminars, established a
1-9
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Industry Overview
Exhibit 1-5. Summary of U.S. Policies and Programs
Relevant to Metal Finishing Industry
Policy Approach/
Mechanism
Application to
Metal Finishing
Policy
Implications
Direct Regulations
Pollution Prevention Act
Resource Conservation
and Recovery Act (RCRA)
Clean Water Act (CWA)
Clean Air Act (CAA)
Sets out a host of USEPA pollution
prevention activities.
Establishes pollution prevention grant
program.
Establishes a pollution prevention
clearinghouse.
Requires annual source reduction and
recycling report.
Requires a biennial Report to
Congress.
Is applicable to all industries,
including metal finishing.
Directly regulates several metal fin-
ishing wastes as hazardous waste.
Requires all hazardous waste
generators, including metal finishing,
to certify that they have a program in
place to reduce the volume or quanti-
ty and toxicity of waste they manage.
Imposes technology-based, industry-
specific effluent limits on pollutants
that a facility is allowed to discharge
into the Nation's waters; standards
may recommend in-plant controls.
USEPA required to regulate 189 air
toxics and has authority to require
pollution prevention measures
(installation of control equipment,
process changes, the substitution of
materials, changes to work practices,
and operator training/certification).
Industries addressed include metal
finishers and many others.
Requires phase-out of production and
sale of chlorofluorocarbons (CFCs)
and several other ozone-unfriendly
chemicals; imposes controls on CFC-
containing products.
New sources located in non-
attainment areas must use most
stringent controls and emissions
offsets that compensate for residual
emissions.
Institutionalizes pollution prevention
within USEPA.
Creates incentives for States to
pursue pollution prevention.
Promotes information transfer.
Starts to measure progress and
identify key issues.
Promotes broad-based pollution
prevention, including within the metal
finishing industry.
Rigorous regulatory scheme
applicable to metal finishing wastes
that are hazardous wastes creates
strong financial and liability incentives
to pursue source reduction.
Effluent limits raise cost of treatment
and disposal and thereby create
financial incentive for source
reduction.
In-house controls provide process/
procedural modifications that achieve
waste reduction.
Air toxic regulation increases the cost
of generating numerous air emissions
produced by metal finishers,
increasing incentives for waste
reduction.
Restrictions on CF:Cs limit some
chemicals used by metal finishers
and force use of environmentally
friendlier alternatives, including
aqueous and semi-aqueous
degreasers.
Offsets may be achieved through
pollution prevention.
1-10
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Industry Overview
Exhibit 1-5. Summary of U.S. Policies and Programs
Relevant to Metal Finishing Industry (Continued)
Policy Approach/
Mechanism
Application to
Metal Finishing
Policy
Implications
Direct Regulations
Emergency Planning and
Community Right-to-Know
Requires select industries to report
environmental releases of specified
toxic chemicals (TRI).
Applies to metal fabricating category
and other industries that conduct
metal finishing.
Reporting requirements have created
strong incentives to reduce waste
generation and releases for all
industries, including metal finishing.
Release data have spurred
increased industry and public
scrutiny of waste generation and
manufacturing operations.
Executive Orders
Executive Order 12843
Requires federal agencies to
implement Montreal Protocol and
prompt the phase-out of ozone
depleting substances, including
chemicals used by the metal
finishing industry.
Requires the phase-out of ozone-
depleting substances, such as 1,1,1-
trichloroethane; forced U.S. metal
plating operations to identify
replacements, which include
aqueous and semi-aqueous
degreasers.
Enforcement Projects
Supplemental
Environmental Projects
(SEPs)
USEPA 33/50
Waste Reductions
Evaluations at Federal
Sites
Common Sense Initiative
(CSI)
Allows USEPA enforcement actions
to mitigate portions of penalties in
exchange for respondent
undertaking pollution prevention
projects.
Reorients resources expended on
penalties toward waste reduction
across all regulated industries,
including metal finishing.
Promotes ambitious targeted
reduction of 17 key toxics.
Participants include members of
metal fabricating industry and
others conducting metal finishing.
Department of Defense/USEPA
initiative to evaluate pollution
prevention at federal facilities and to
promote technology transfer.
Projects have included metal
plating shops.
New USEPA effort designed to
create pollution control and
prevention strategies on an industry-
by-industry basis.
Prevents cross-media transfer of
pollutants.
Provides incentive for industries
subject to enforcement actions to
undertake pollution prevention.
Potentially applicable to metal
finishing industry due to its regula-
tion under RCRA, CAA, and CWA.
Promotes activity and commitment at
level closest to the manufacturing
process.
Preliminary results indicate that over
33-percent reduction achieved in
metal fabricating sub-category.
Creates waste reduction culture
within federal facilities.
Provides access to key pollution
prevention information.
Goal is to achieve greater environ-
mental protection at less cost by
fostering government-industry
cooperation in reviewing
environmental regulations.
The metal finishing industry is one of
six pilot projects.
1-11
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Industry Overview
Exhibit 1-5. Summary of U.S. Policies and Programs
Relevant to Metal Finishing Industry (Continued)
Policy Approach/
Mechanism
Application to
Metal Finishing
Policy
Implications
Voluntary Programs
Design for the Environment
Source Reduction Review
Project
Pollution Prevention Grants
Technology/Policy Transfer
Promotes considerations of waste
reduction and risk reduction in
process and product design stage.
Voluntary.
Uses clusters and cleaner
technology substitute assessments.
Major integration of source reduction
consideration within USEPA program
offices.
Specific rulemakings targeted to
encourage source reduction.
USEPA provides grants to States
and funds joint federal agency
projects.
Host of USEPA and State activities
focusing on promoting the
development and dissemination of
technical and non-technical pollution
prevention information.
Creates interest in waste and risk
reduction and recognition of specific
steps that can be achieved in
different industries.
USEPA has initiated joint metal
finishing Design for the
Environment (DfE) projects,
focusing on developing energy,
environment, and manufacturing
assessment methodology.
Increases use of multi-media
regulatory programs to promote
source reduction where possible.
Emission limit on solvent use and a
degreasing standard that would
impact metal finishers.
Promotes pollution prevention
activity at State and federal level,
some of which is targeted at
promoting waste reduction in metal
finishing industries.
Promotes education about the
availability and benefits of waste
reduction, as well as a network of
resources that can be used to
support specific projects, including
those with metal finishing
industries.
1-12
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Industry Overview
Exhibit 1-6. International Waste Minimization Programs
Country
Policy Approach
Scope
Implications
Australia • Best Available Technology
(BAT) Regulations
(permitting)
• Economic—financial
assistance
Municipal solid waste (MSW)
and industrial firms with less
than 250 people—some
specific waste streams
Specific industries, including
electroplating
BAT regulations allow
flexibility for emerging
technologies/job shops
escaping regulation
Financial assistance to induce
industry implementation of
Canada
Denmark
Finland
• "Green Plan"
• User charges and taxes
• Mandate federal government
waste reduction
• Statutory orders— packaging
and recycling
• Permitting
• Financial— taxes, duties, fees,
grants, subsidiary
• Sustainable development
statute and regulations
• Permitting
• Financial— surtax
— Grants
• Technical assistance for
reduction of all waste by 50%
by year 2000
• MSW and industrial
• Federal government— all
waste
• MSW
• All industry
• All waste
• Rational use of all national
resources
• Large industrial firms
• MSW, fuels, and waste oil
• Industry
• Strictly voluntary — results
hard to predict
• Involvement to reduce waste
• Provides example
• Reduces solid waste
• Limits emissions to all media
• Encourages use of clean
technologies
• Mandatory reduction of
industrial toxics
• Job shops escape regulation
• No effect on metal finishing
• Implement innovative clean
technology
Germany • Statutory and regulations
• Financial—disposal
—Low-interest loan
MSW and industrial
Costs for disposal of wastes,
such as metal finishing
Industrial
• Specific media regulations
require clean technologies to
eliminate emissions
• Grant incentive for clean
technology
• Covers cost up to 60% of
investment in cleaner
technologies
Italy • Financial—priority benefits
contributions
• Regulations
• Education/demonstration/
information
Industry
Industrial waste
All waste
Encourages use of clean
technologies
General not industry-specific
Encourages waste
minimization; not industry
specific
Norway • Statute & permits require-
ments—mandatory plans
• Financial—subsidiaries
Industry
Industries (also MSW)
Encourage waste
minimization generally
Financial incentive to invest in
clean technologies
1-13
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industry Overview
Exhibit 1-6. International Waste Minimization Programs (Continued)
Country
Policy Approach
Scope
Implications
U.K.
Voluntary
Statutory regulations (I PC)
Education/demonstration
Financial—grants
Industry
Industrial emission
standards
Disseminate case studies
to industries
Industrial (also MSW)
Not measurable
Mandates clean
technologies, especially
metal finishing; prohibited
clearing and finishing
technology
Technical transfer to teach
and encourage use of
clean technology
Pays up to 50% of
investment with clean
technology
EC
International directives and
regulations
BAT permits
Industrial in member
countries
Industrial
Binding on member
conditions, multi-media
focus on industrial waste
minimizaition
Limit industrial emission
Nordic
Council
• Regional Cooperative
Voluntary — education
• Industrial networks,
industrial seminars,
newsletters
• Technical transfer to
educate and hopefully
encourage individual to
voluntarily engage in
cleaner technology
Nordic newsletter, and coordinated with the United
Nations Environment Programme's cleaner production
activities. In addition, work is proceeding on standard-
izing the methodology of life cycle assessment.
International Programs
Waste Exchanges
Waste exchanges provide a mechanism for reusing
industrial waste by facilitating the transfer of waste
materials from generators to entities interested in
recycling or reusing the materials. Waste exchanges
operate by maintaining a printed and/or electronic list
of materials that generators or brokers have available.
Depending on the operating practices of a given
exchange, individuals or organizations interested in
obtaining any of the listed materials either directly
contact the lister to arrange a mutually agreeable
transaction or contact the exchange. In almost every
instance, waste exchanges do not take physical posses-
sion of the listed materials, nor do they warrant the
condition or usability of any listed materials for a
given purpose.
From 1972 to 1978, 12 waste exchanges were
established in Europe to serve industrial generators and
users (located in Austria, Denmark, Finland, France,
Germany, Italy, Norway, Sweden, and Switzerland).
Also during the 1970's, New Zealand, Australia, and
Israel established waste exchanges. The first North
American waste exchanges were established in 1973,
a recent USEPA study identified more than 50 waste
exchanges currently operating in North America.
Waste exchanges may represent a particularly
powerful tool for the metal plating industry and metal
plating wastes. As the data in Exhibit 1-7 illustrates,
many wastes typical of metal plating operations are
routinely listed by North American exchanges (e.g.,
acids, alkalis, metal and metal sludges, solvents).
Wastes such as spent acids, caustics, and solvents may
be readily used for less exacting applications. Wastes
containing valuable metals may be worthy of recovery
or used as feeds to other processes. Similarly, metal
platers may be able to use these waste streams as
feedstocks if the purity of the materials is adequate.
Montreal Protocol
The Montreal Protocol has been adopted by more
than 60 countries and took effect on January 1, 1989.
The goal of the Protocol is to protect the ozone layer
1-14
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Industry Overview
Exhibit 1-7. Listings of Materials Wanted and Materials Available by Category
from the National Material Exchange Network*
January 1, 1993, to May 19, 1993
Category
Acids
Alkali
Construction Material
Container and Pallet
Durable and Electronic
Glass
Laboratory Chemicals
Metal and Metal Sludge
Miscellaneous
Oil and Wax
Other Organic Chemicals
Other Inorganic Chemicals
Paint and Coating
Plastic and Rubber
Solvent
Textile and Leather
Wood and Paper
Materials
Number of
Listings
197
181
45
366
32
39
2,350
367
677
234
410
508
96
826
313
165
594
7,400
Available
Percentage of
Total
3%
2%
1%
5%
0%
1%
32%
5%
9%
3%
6%
7%
1%
11%
4%
2%
8%
Materials
Number of
Listings
50
51
27
79
45
15
8
234
278
84
82
97
11
505
67
70
196
1,899
Wanted
Percentage of
Total
3%
3%
1%
4%
2%
1%
0%
12%
15%
4%
4%
5%
1%
27%
4%
4%
10%
*These data do not include approximately 460 listings of available materials and
Industrial Exchange and the Southern Waste Information Exchange based on
150 wanted listings from the Southeast
recent catalog listings.
from man-made ozone depleting chemicals, some of
which have traditionally been utilized in the metal
finishing industry, such as the widely used cleaning
solvent methyl chloroform (1,1,1-trichloroethane). In
1990, the parties to the Protocol agreed to accelerate
the phaseout schedules for the substances already
controlled by the Protocol. They also added phaseout
requirements for other ozone depleting substances
(ODS) including methyl chloroform, carbon tetra-
chloride, and chlorofluorocarbons (CFCs).
In November 1992, the Protocol was again
amended in Copenhagen. The Copenhagen Amend-
ments further accelerated various phaseout schedules
and banned others. The amendment covers CFCs,
halons, carbon tetrachloride, methyl chloroform, and
hydrobromofluorocarbons. The changes, using 1986 as
a baseline, required a 75-percent reduction of CFCs in
1994 and elimination by January 1, 1996. Halons
were banned as of January I, 1994, and carbon tetra-
chloride was banned as of January 1, 1995. Methyl
chloroform faced a 50-percent reduction in 1994, an
85-percent reduction starting January 1, 1995, and a
100-percent elimination by January 1, 1996.
As a result of the Montreal Protocol, the metal
finishing industry's widely used cleaning solvent,
methyl chloroform (1,1,1-trichloroethane), came under
attack, and the ambitious phaseout schedule has led
many metal finishers to seek safer alternatives.
1.5.3 NAFTA
The recent passage of the North American Free
Trade Agreement (NAFTA) highlights a challenging
situation concerning how to reconcile international
trade and environmental policy issues. NAFTA raises
issues such as how trade agreements can be achieved
in the context of heavy environmental regulation and
how to harmonize international environmental and
trade laws.
Unlike media-specific statutes of the United States,
the environmental law of Mexico exists in a single
broad statute. The environmental enforcement agency
of Mexico, which is equivalent to the USEPA, is the
1-15
-------
Industry Overview
Sccrctaria de Desarrollo Urbano y Ecologia (SEDUE),
formed in 1982. While Mexico's law is comprehen-
sive in scope and sets reasonable ecological standards,
compliance is minimal because enforcement is mini-
mal. SEDUE estimates that 52 percent of the nation's
maquiladoras have generated hazardous waste and few
have obtained basic operating licenses. Mexico simply
docs not have the fiscal or human resources to ade-
quately enforce its comprehensive environmental law.
While it is impossible to predict what impact
NAFTA may ultimately have, its passage is likely to
attract even more industrial production facilities (such
as metal finishers) to Mexico and further compound
the compliance problem. This issue is not unique to
North America, but arises in any region with disparate
environmental policies.
1.5.4 Future Trends
Based on the information reviewed in this section,
the following observations can be made:
* Waste minimization programs that address metal
plating operations will increase in number due to
the toxic chemicals managed by this industry.
• These programs will be split among voluntary and
mandatory programs, with mandatory programs
being less "command and control" and more
incentive driven.
• The overall regulation of metal finishers will
continue to increase in scope and stringency,
creating greater incentives for legitimate operators
to pursue waste reduction/cleaner technologies and
driving noncompliant operations to regions of
minimal regulation or lax enforcement.
• International waste minimization currently focuses
more on industrial and solid waste than does U.S.
waste minimization.
• Small metal finishing operations appear to have
special needs as they are forced to decide whether
to pay the increasing cost of compliance, reduce
waste generation, or become fugitive operations.
1.5.5 Sustainable Development
According to the United Nations World Commis-
sion on Environment and Development, the term
"sustainable development" refers to development that
meets the needs of the present without compromising
the ability of future generations to meet their own
needs. While the precise definition of the term is still
the object of considerable international debate, consen-
sus exists on several fundamental issues. Sustainable
development requires a long-term perspective for
planning and policy development; dictates actions that
build on and reinforce the interdependence of our
economy and our environment; and calls for new inte-
grative approaches to achieve economic, social, and
environmental objectives.
Sustainable development has emerged in recent
years as a focal point for policy makers concerning the
long-term economic and environmental outlook. The
level of concern about sustainable development was
made evident in 1992 at a United Nations Conference
on Environment and Development. Representatives
from 180 countries gathered at this conference to
promote sustainable and environmentally sound devel-
opment.
Many of the past and present USEPA programs
have utilized tenets of sustainable development.
USEPA, however, has not employed the concept as an
overall policy framework or programmatic objective
until very recently. The limited use of sustainable
development concepts in USEPA policies is, in part,
due to a lack of these concepts in its statutory man-
dates. It is generally agreed that statistically and
scientifically credible environmental data and informa-
tion are needed to measure progress toward environ-
mental goals and sustainable development.
USEPA is implementing a program to gather and
provide statistical information about the status and
trends in the Nation's ecological systems. USEPA's
Environmental Monitoring and Assessment Program is
the first statistically based monitoring program to
assess ecosystems on a national scale. The program is
designed to advance the scientific knowledge of eco-
systems and how these ecosystems are changing and
responding to human activities.
1.6 Implications and Evaluation of
Policies
To understand the impacts of current policies on
the metal finishing industry, several points need to be
understood. Cleaner technologies and products already
exist in the metal finishing industry as a result of
extensive government and trade association cooperation
on product and process technology development and
technology transfer, as well as military research and
development. The metal finishing industry is very
diverse in terms of processes (e.g., electroplating,
plating, polishing, anodizing, and coloring) and size of
operations within the industry. As a result, metal
finishers can be categorized into firms that:
• Are in compliance with environmental requirements
and proactive in improving environmental perfor-
mance
• Seek to comply with applicable environmental
regulation
1-16
-------
Industry Overview
• Are older and outdated and would close except for
cleanup liability
• Are constantly out of compliance (i.e., renegade
firms).
The differences among these groups are important
in assessing pollution prevention policy, since the
impact of different policies varies depending on which
group is being targeted.
As discussed previously, numerous waste minimi-
zation policy initiatives are currently being pursued at
all levels of government in most major industrialized
countries. Many of these waste minimization initia-
tives affect the metal plating industry, although most
are much broader in scope. In examining the effec-
tiveness of these policies, several points should be
noted. First, waste minimization policies are relatively
new and it is difficult to assess the effects of programs
that have only existed for a brief period. Second,
given the broad array of policies and the lack of
precise mechanisms for measuring their effectiveness,
quantitative evaluation is not possible. Rather, it
appears much more likely that the results that have
been observed are the result of a combination of policy
approaches (i.e., regulation of emissions combined
with technology transfer, voluntary programs, and the
existence of a mechanism for measuring success, such
as the TRI). Despite these concerns, however, some
preliminary assessment can be performed.
Within the United States, the most broadly used
indicator of toxics loading to the environment is the
TRI. The TRI measures releases to the environment
of specific chemicals from specific industries (desig-
nated by Standard Industrial Classification [SIC]
codes). According to TRI data for SIC 3471 (Electro-
plating) from 1988 to 1992, releases of TRI chemicals
decreased 55 percent, from more than 22 million
pounds to less than 10 million pounds released
annually. This decrease is illustrated in Exhibit 1-8.
The TRI data provide some insight into how these
reductions are being achieved. As part of the TRI
reporting form, facilities are asked to indicate which,
if any, waste reduction techniques they have used
during the reporting period. The most common pollu-
tion prevention methods identified for SIC 3471
include the following:
Exhibit 1-8. TRI Release Data for SIC 3471 (1988 - 1992)
SIC 3471
CTotal Releases in Pounds}
1-17
-------
Industry Overview
• Improved maintenance, scheduling, recordkeeping,
or procedures
• Substituted raw materials
• Instituted recirculation within a process
• Changed to aqueous cleaners from solvents of other
materials
• Implemented other changes in operating practices
• Made other process modifications.
These pollution prevention activities were identi-
fied through internal pollution prevention opportunity
audits and vendor assistance, as well as through
numerous other means.
Generally, the TRI data indicate that the more
progressive portion of the metals fabricating industry
has substantially reduced its releases over a relatively
short period of time. Hence, some combination of
waste minimization policies (e.g., regulation and
incentives) is working for the proactive sector of the
industry. As direct regulation of the metal plating
industry or chemicals used by this industry increases,
the incentive to achieve additional waste reductions
will also increase. For marginal operations, policy
approaches may need to link stringent enforcement or
streamlined regulatory requirements with waste reduc-
tion opportunities to facilitate more environmentally
sound behavior.
Barriers to pollution prevention in the metals
finishing industry include regulatory and institutional
barriers, such as inconsistency in existing regulatory
requirements and enforcement actions (particularly
given the significant environmental liabilities and
clean-up costs some firms face if they discontinue
operations); economical and financial barriers, such as
the lack of the personnel and financial resources to
look beyond baseline compliance; and technological
barriers, such as a lack of access to newer, cost-
effective, cleaner technology. In addition, industrial
managers often do not appreciate the financial and
other benefits associated with waste minimization and
face significant psychological barriers when shifting to
unknown but cleaner technologies. All of these bar-
riers limit the use of pollution prevention in the metals
finishing industry.
1.7 Technical Report Organization
The paper consists of the following five technical
sections and five technical appendices:
• Section 2 - Waste Stream Characterization
• Section 3 - Waste Minimization/Pollution Preven-
tion Techniques
Section 4 - Examples of Waste Minimization/
Pollution Prevention Techniques
• Section 5 - Tools for Evaluating Pollution Preven-
tion Opportunities
• Appendix A - International Policy Approaches to
Encourage and Implement Pollution Prevention/
Cleaner Production
• Appendix B - Implications and Evaluation of
Policies
• Appendix C - U.S. Federal and State Pollution
Prevention Policy/Plans
• Appendix D - Pollution Prevention Contacts
1-18
-------
2.0 WASTE STREAM CHARACTERIZATION
As with any complex industrial activity, metal
plating processes result in a variety of wastes and
environmental releases. This section identifies and
describes major wastes and releases from typical
plating facilities, discusses waste generation mechan-
isms, provides waste composition and quantities to the
extent available, and describes typical waste recovery,
treatment, and disposal options. The remainder of this
section is organized to first discuss the life-cycle for
plating wastes. Waste characterizations are then pro-
vided for three broad categories of wastes: (1) air
emissions, (2) wastewater, and (3) solid and hazardous
wastes. The section concludes with a brief discussion
identifying the key stakeholders in waste generation
activities.
2.1 Life Cycle for Wastes from Metal
Plating Operations
Wastes from plating operations are generated by
normal production activities as well as by accident.
Accidental discharges can have highly acute impacts
due to the concentrated nature of the hazardous
materials in use, while normal processing wastes
present more of a chronic problem due to the control-
led and/or continuous nature of their discharge.
Exhibit 2-1 presents an overview of chemical use and
waste generation in the plating shop and a portion of
their life cycle.
Wastewater is primarily generated during rinsing
operations to remove the thin film of concentrated
chemicals (drag-out) that adhere to parts after they are
removed from process baths. Wastewaters are usually
treated on-site and discharged to municipal sewer sys-
tems rather than directly to water bodies. The on-site
treatment of wastewater generates a hazardous sludge
that must be disposed of in an approved landfill or
sent to a recovery site for metals reclamation.
Residual metals discharged by plating shops to
municipal sewer systems will be partially removed by
the biological treatment process of the municipality
and the remainder will be discharged to a water body.
A high concentration of metals, such as cadmium may
limit municipalities disposal options for their biological
treatment of sludge. Some local governments impose
strict limits on the effluent discharges from plating
shops in order to meet their discharge and sludge
disposal restrictions, which can be set at 10 to 20
percent of federal limits.
Process baths can be periodically discharged when
they lose their effectiveness due to chemical depletion
or contamination. Accidental discharges of these
chemicals occur, for example, when a tank is over-
filled. These concentrated wastes are either treated on-
site or are hauled to an off-site treatment or recovery
facility. On-site treatment of concentrated wastes is
not always possible because they can upset treatment
processes designed mainly for dilute wastewaters.
Also, some spent cleaning solutions contain chelating
compounds that prevent the complete precipitation of
heavy metals during treatment.
With respect to air emissions, the greatest
concerns with plating shops are solvents and chrom-
ium. Solvents are partly evaporated during degreasing
operations. Chromium is released to the air by plating
and anodizing processes.
Other miscellaneous sources of wastes from
plating include floor wash waters, stormwater, and
chemical packaging wastes.
2.2 Air Emissions
2.2.1 Waste Stream Identification
The primary air emissions problems for plating
operations are associated with the use of chlorinated
solvents and chromium. These are the only materials
for which U.S. regulations or proposed regulations
exist at this time.
Solvents
A number of solvents are used for metal cleaning,
the choice of which depends on the application, costs,
and preference of the user. Examples of solvents that
are commonly used for this purpose include 1,1,1-
trichloroethane (TCA), trichloroethylene (TCE),
tetrachloroethylene (or perchloroethylene [PERC]),
trichlorotrifluoroethane, acetone, toluene, methyl ethyl
ketone, methyl isobutyl ketone, and methylene
chloride.
Chromium
Since 1984, the U.S. Environmental Protection
Agency (USEPA) has been investigating chromium
electroplating operations as a source of chromium air
emissions. Hard and decorative chrome plating and
chromic acid anodizing are operated at elevated temp-
eratures and a dc current is applied. These operating
conditions result in the release of hexavalent chromium
mist.
2.2.2 Waste Generation Mechanisms
Solvents
Chlorinated solvents are evaporated during
degreasing operations. Vapor degreasing is performed
2-1
-------
Exhibit 2-1. Overview of Chemical Use and Waste Generation in a Plating Shop
Air Emissions
Misc.Wastewater
(e.g. floor wash)
Solvent
Evaporation
\
Scrubber
Slowdown
Contaminated Solvent
Disposed or Recovered
by Distillation
Sewage
Treatment Plant
Wastewater
Treatment
System
Process
Chemicals
Municipal landfill
or Land Application
Accidental Overflows
or Leaking Tanks Can
Result in Concentrated
Wastes
Sludge Hauled
to Disposal Site
Wastes Can Leach
into Groundwater
Improper Material Storage
Contaminated Bath
Hauled to Disposal
or Treated On-site
0>
B)
o
D>
5
I
o
615E-03
-------
Waste Stream Characterization
in a tank with a heated solvent reservoir at the bottom
and cooling zone near the top. Sufficient heat is
applied to boil the solvent to generate hot solvent
vapor. The hot vapor fills the tank but is prevented
from escaping by the upper cooling zone, which
condenses the vapor and the resulting liquid solvent
returns to the reservoir. During operation, parts are
introduced to the vapor zone. Solvent condenses on
the parts and dissolves the soils. The part eventually
reaches the temperature of the solvent vapor and the
condensing action stops. The part is then removed
from the degreaser in a clean and dry condition.
Solvent can be released to the air due to poor vapor
degreaser design or operating practices. Examples of
poor design include inadequate cooling zone and
inadequate freeboard. Examples of poor operating
practices include lowering or raising the parts too
quickly.
When the cleaning ability of the solvent is
diminished or becomes contaminated, the solvent must
be discarded/replaced or purified, on-site. Most spent
solvent is recovered at a solvent recycling facility.
On-site purification and off-site recycling operations
use solvent distillation equipment to separate the
solvent from its contaminants. When this is done, the
contaminants are concentrated into "still bottoms" and
the solvent is returned to service. Some vapor losses
may occur during distillation, depending mainly on the
design characteristics and operating procedures
employed.
Solvents are also used in a "cold" form (usually
slightly above room temperature) for degreasing. This
is usually performed in tanks by immersing the parts
into the solvent and/or by spraying. Solvents used for
this purpose include those used in vapor degreasers
plus aliphatic petroleums (e.g., kerosene and mineral
spirits) and alcohols. Ultrasonics or mechanical
agitation are sometimes used with cold cleaning to
improve soil removal mechanisms. The rate of solvent
emissions from cold cleaning depends mostly "on the
type of solvent employed, the temperature of the
process, and the application method (e.g., spraying will
increase evaporative losses).
With hand wiping, a small amount of solvent is
placed onto a rag or directly onto the part and the
surface of the part is wiped clean. The thin film of
solvent on the part evaporates into the workplace.
Most solvents used for vapor degreasing and cold
cleaning are also used in hand wiping.
When open top containers are used to immerse
parts or to dispense solvent for hand-wiping opera-
tions, significant solvent losses to the atmosphere and
workplace can occur.
Chromium
During the operation of chrome plating processes,
chromic acid is heated and a dc current is passed
through the solutions. The electrolytic process evolves
hydrogen and oxygen gases that bubble to the surface
of the solution and are released to the air above the
bath. This results in the formation of a humid chromic
mist or aerosol. Due to health concerns for operators
of these processes, forced air ventilation must be used.
The chromium mist is therefore pulled into an air
exhaust system. Wet air scrubber systems and mesh
pad mist eliminators can be used to remove the bulk of
the chromium from the air stream prior to exhausting
it to the atmosphere.
2.2.3 Waste Stream Quantities and
Composition
Solvents
A 1994 survey of U.S. plating shops (mostly job
shops) indicated that approximately 27 percent of the
shops use chlorinated solvent for degreasing, most
notably 1,1,1-TCA, TCE, PERC, chlorofluorocarbons
(CFCs), and methylene chloride. The typical plating
shop (as defined by 40 CFR 433.1 l(c)) purchases
16,000 Ibs/yr of solvent for degreasing operations.
This quantity of solvent is either evaporated during use
or contaminated and sent off-site for recovery or
disposal. The percentage of solvent lost to air
emissions is not known.
Chromium
There are an estimated 9,700 chromium electro-
plating operations in the United States. These opera-
tions emit about 140.7 Mg/yr (175 tons/yr) of hexa-
valent chromium per year, with approximately 80
percent generated by hard chrome plating. Individual
plating processes generate approximately 0.0094 kg
Cr+3 trivalent chromium and 0.00024 kg hexavalent
chromium (Cr+6) per kg of chromic acid (CrO3) used,
respectively, for hard and decorative chrome plating.
2.2.4 Pollution Control and Treatment
Methods
Solvents
Solvent emissions are presently controlled by
management practices and carbon adsorption treatment
systems. The proposed National Emissions Standards
for Hazardous Air Pollutants (NESHAP), however,
rely only on source-reduction methods and discourages
the use of end-of-pipe or other waste treatment
technologies, such as carbon adsorption units. The
control equipment combinations proposed in the
NESHAP are given in Exhibit 2-2.
2-3
-------
Waste Stream Characterization
Exhibit 2-2. Control Equipment Combinations and Idling Limits
Control Equipment
Combination Options1
Alternative Idling Limit
kg/hr
Batch Vapor2
(£1.21 sq. meters)
Batch Vapor
(>1.2sq. meters)
In-line existing3
In-line new3
Batch Cold
1. FBR = 1, FRD, RRD
2. FBR = 1, BPC, RRD
3. BPC, FRD, RRD
4. CVR, FRD, RRD
1. BPC, FRD, RRD
2. BPC, DWL, RRD
3. DWL, FRD, RRD
4. BPC, FRD, RRD
5. BPC, RRD, SHV
6. FBR = 1, RRD, SHV
7. DWL, RRD, SHV
FBR = 1
SHV, FRD
CVR, water layer
0.15
0.15
0.10
0.10
M/A
1FBR - freeboard ratio, FRD - freeboard refrigeration device, RRD - reduced room draft, BPC - biparting cover,
CVR - manual cover, DWL - dwell, SHV - superheated vapor
8New and existing equipment
3Vapor and cold cleaning
One source estimates that uncontrolled open-top
vapor degreaser can release as much as 0.3 Ibs/hr per
square foot of degreaser opening. A summary of the
effectiveness of emission control techniques on open-
top degreasers is shown in Exhibit 2-3. With the
controls listed in Exhibit 2-3 installed, a degreaser can
reduce emissions up to 0.05 Ibs/hr per square foot of
degreaser opening. In a typical degreaser running -at
4,000 hours per year, 1,800 Ibs of solvent would be
released compared to 10,800 Ibs uncontrolled.
Chromium
The most common methods to reduce chromium
emissions include (1) addition of chemical fume
suppressants, wetting agents (reduces surface tension),
and/or foam blankets to the bath to inhibit misting;
(2) packed-bed scrubbers; (3) chevron mist eliminators;
and (4) mesh pad mist eliminators. Some hard chrome
plating processes can be replaced by metal sprays,
nickel alloy plating, or other processes. Decorative
chromium performed using hexavalent chromium can
be converted to trivalent chromium. Chromic acid
anodizing can be replaced by sulfuric/boric acid
anodizing. Of the various technologies available for
reducing chromium emissions, the mesh pad mist
eliminator is the most effective. Also, due to the
design of these devices, the chromic acid that is
removed from the airstream can be returned to the
Exhibit 2-3. Effectiveness of Emission
Control Techniques on
Open-Top Degreasers
Device
Reduction in
Solvent Emissions
Lid/sliding cover 38% - 50%
Above freezing chiller 18% - 50%
Below freezing chiller 11 % - 58%
Refrigerated primary 18%-50%
condenser 25% - 39%
Increased freeboard ratio 25% - 30%
(0.5 to 1.0) 42%-54%
Controlled hoist speeds (10 42% - 67%
fpm or less) 40% - 90%
Lip exhaust/reduced room
drafts
Enclosed design
Carbon adsorption retrofit
plating or anodizing bath. The mist eliminator
removes chromic acid from the airstream by slowing
the velocity of the air and causing the entrained
chromic acid droplets to impinge onto fiber pads. The
pads are periodically washed with a small volume of
water, and the chromium-rich solution is returned to
the bath.
2-4
-------
Waste Stream Characterization
2.3 Wastewater
2.3.1 Waste Stream Identification
The primary use of water in a metal finishing shop
is rinsing to dilute and wash away the chemical film of
drag-out found on parts, racks, etc., after processing in
a chemical bath. Other sources of wastewater, which
include scrubber blowdown, cooling water, and spent
baths, make up only about 10 to 20 percent of the flow
from a typical plating shop.
2.3.2 Waste Generation Mechanisms
During processing, parts are hung on racks or
hooks or placed into barrels and then dipped into
various tanks using a prescribed sequence. Each
plating process typically consists of alkaline cleaning,
acid etching, and finishing. Rinsing is performed be-
tween each process step to remove drag-out. When a
sufficient volume of rinse water is used to perform
these functions, "good rinsing" is achieved.
The required flow of rinse water for a shop is
directly related to the quantity of drag-out generated.
The greater the drag-out rate, the more rinse water is
needed to maintain good rinsing criteria. Drag-out is
in turn a function of numerous factors related mainly
to the process type, shape of parts processed, produc-
tion equipment, bath concentration, bath temperature,
bath viscosity, part orientation, the rate of withdrawl
from the process tank, and the length of drain time
provided. Of these factors, the shape of the parts and
the type of transport device employed for the parts
(e.g., racks, baskets, barrels) usually exhibit the
greatest influence on drag-out rates. Exhibit 2-4
shows some drag-out rate estimations for various
shaped parts.
2.3.3 Waste Stream Quantities and
Composition
A recent survey of U.S. plating shops showed that
the wastewater discharge rates from plating shops
ranges from zero to more than one million gallons per
day (gpd) (see Exhibit 2-5). Approximately 8 percent
of the shops responding to the survey had achieved
zero discharge and the median flow rate for all shops
is 14,000 gpd. Companies with zero discharge are
typically small plating operations and most only
performed hard chrome plating. This particular pro-
cess is the easiest to operate at zero discharge because
drag-out recovery rinsing can be used effectively.
The composition of the wastewater will depend on
the type of processes performed and the rinsing
methods used. The concentration of the wastewater
components will generally be higher for shops that
employ pollution prevention due to the concentrating
effect of reducing water use. Data from the industry
survey show that the range of metals and cyanide
concentrations in wastewaters are from less than 1
mg/1 to more than 1,000 mg/1. However, the typical
waste stream contains between 50 and 100 mg/1 of
metals and cyanide (when used).
Most plating shops segregate their wastewaters
into three streams: cyanide bearing, chromium
bearing, and miscellaneous acid and alkaline. Cyanide
wastes cannot be mixed with acid wastes due to the
potential formation of hydrogen cyanide. Cyanide and
chromium wastes are treated by preliminary processes
prior to metals precipitation.
Exhibit 2-4. Drag-Out Rate Estimates for Various Part Types
Nature
Vertical
Horizontal
Cup Shapes
of Work Drainage
Well drained
Poorly drained
Very poorly drained
Well drained
Very poorly drained
Well drained
Very poorly drained
Drag-Out Rate (gal/1
0.4
2.0
4.0
0.8
10.0
8.0
24.0
,000 ft2)
2-5
-------
Waste Stream Characterization
Exhibit 2-5. Average Plating Discharge Rate of Survey Respondents (gallons per day)
18
16 h
14
O 12
(O
•S 10
I s
§ 6
615E-04
-------
Exhibit 2-6. Conventional End-Of-Pipe Treatment System
Sodium
Hypochloride
Caustic or Chlorine
Neutralization/Precipitation/Sludge Thickening
10
CN Wastestream -4>-
T T
Cyanide
Oxidation
Acid/Akaline Wastestre
1— >-
Sodium
Metabisulfite
Acid or SO2
1 1
Cr Wastestream — >-
Chromium
Reduction
-*-
61SE-01
Misc. Reagents
1
Mixing/
Pretreatment
Acid/Caustic Polymer
-
1
PH
Adjust
I
Floccu-
lation
-
Clarifi-
cation
\
\
Solids
i
^
Sand
Filter
_>. ToPOTW
or River
/ \ )
/ \ /
f \-/
f
Sludge
Thicken-
ing
\ /
' \
/
Solids
Filter
Press
Solids
Sludge
Dryer
Sludge to
— >• Recovery/
Disposal Site
B>
in
W
3
Si
3
o
3
2.
(D
2j_
§.
O
-------
Waste Stream Characterization
source) is added to the wastewater to oxidize cyanide
to cyanate at a pH of 10 or-higher. The pH is reduced
to approximately 8.5 and additional hypochlorite is
added. The cyanate is further oxidized to carbon diox-
ide and nitrogen. Alternatives to alkaline chlorination
are peroxide or ozone oxidation, ferrous sulfate precip-
itation, and electrochemical and thermal oxidation.
With the elimination of cyanide, the alkaline
chlorination is not longer needed.
During chromium reduction, Cr*6 is reduced to
trivalent chromium (Cr+3). This process is performed
since the hexavalent species cannot be precipitated
from wastewater, whereas the trivalent species is read-
ily removed. The most common method of chromium
reduction involves the addition of sulfur dioxide gas or
sodium metabisulfite at a pH between 2.0 and 3.0.
Alternative methods that are used include sacrificial
iron anode technology and ferrous sulfate reduction.
Following preliminary treatments, wastewaters are
combined and treated for metals removal. The con-
ventional method used in the plating industry is
hydroxide precipitation. This is accomplished by
adjusting the pH of the wastewater with an alkaline
reagent to reduce the solubility of the dissolved metals
and settling and removing the resultant metal hydrox-
ide precipitants. Flocculating agents (usually organic
polyelectrolytes) are added to the wastewater to cause
precipitated metal hydroxides to agglomerate and settle
more rapidly. The wastewater then enters a clarifier,
where the precipitated solids settle. The solids are
removed from the clarifier, thickened, and dewatered
by mechanical and thermal means. Most frequently,
recessed filter presses and sludge dryers are used to
perform this function. The clarified wastewater can be
further processed by filtration through a sand bed or
multimedia filter before discharge to remove fine
solids that do not settle in the clarifier. Alternative
treatment methods to conventional precipitation/
clarification include microfiltration, ion exchange, and
evaporation.
2.4 Solid and Hazardous Waste
2.4.1 Waste Stream Identification
The primary hazardous wastes generated by metal
finishing shops are solvent wastes, spent process
solutions, and wastewater treatment sludge. Solvent
wastes are usually in one of two forms: spent or
contaminated solvents that are removed from
degreasers or still bottoms from solvent recovery
operations. Both of these wastes are hazardous and
they are typically sent off-site for recovery or disposal.
The most common spent process solutions are alkaline
cleaners and acid etching solutions. These baths are
discarded on a regular basis by many shops. Plating
solutions (e.g., chrome and nickel plating baths) are
typically rejuvenated and kept in permanent operation.
Wastewater treatment sludge is usually the major solid
or hazardous waste byproduct from plating. It is
formed by the conventional hydroxide precipitation
treatment process.
2.4.2 Waste Generation Mechanisms
Wastewater treatment sludge is generated during
conventional treatment. The precipitated material
removed from the clarifier is very wet or dilute in
solids (approximately 97 to 99.5 percent water and
only 3 to 0.5 percent solids). Due to the high cost for
hauling and recovery/disposal, it is economically
advantageous for shops to remove as much water from
the sludge as possible. Therefore, shops typically
employ several steps to progressively remove water
from the sludge. The sludge is "thickened" to 2 to 5
percent, usually by gravity thickening (either a separate
thickening tank or a zone within the clarifier).
Mechanical dewatering is then used to increase the
solids concentration of the thickened sludge to 10 to
60 percent solids. The most common mechanical
device is the recessed plate filter press. Other
equipment includes the older plate and frame filter
press, centrifuges, and bag filters.
The solids content of the sludge dewatered on a
filter press represents approximately a 20 to 1 volume
reduction from the original sludge volume discharged
from the clarifier. Additional dewatering can be
accomplished with sludge dehydration equipment that
can produce sludge with a dryness of 90 percent
solids. This represents approximately a 4 to 1 volume
reduction above that achieved by the filter press.
Approximately 30 percent of U.S. shops have installed
dehydration equipment, with more than 80 percent of
these units being installed since 1988. Sludge dehy-
dration is accomplished by exposing the sludge to a
heat source that evaporates the excess water.
Typically, there is some means of agitating the sludge,
for example, with rotating blades, to improve the
drying process. Units are available with either batch
and continuous feed designs, and various heat sources
can be used (electric, electric infrared, steam, and gas).
2.4.3 Waste Stream Quantities and
Composition
The volume and composition of wastewater
treatment sludge depends on the volume and composi-
tion of the wastewater treated, the nature and
efficiency of the treatment process, the treatment
reagents employed, and the dewatering process. The
typical U.S. plater treats approximately 14,000 gpd of
wastewater and generates 50,000 Ibs/day of sludge
with a solids content of 54 percent. However, large
2-8
-------
Waste Stream Characterization
shops may generate more than 1 million Ibs/day of
sludge. Exhibit 2-7 presents analytical data for
sludges from various U.S. shops.
2.4.4 Pollution Control, Treatment, Recovery
and Disposal Methods
In the United States, wastewater treatment sludge
is generally disposed of in hazardous landfills or is
sent to a metals recycling facility. Due to land
disposal regulations, the sludge must be relatively
stable (i.e., will not leach toxic metals) before land
disposal. Some sludges must be processed before
landfilling. The most common method of stabilizing
sludges is solidification. With this process, cement or
cement-like materials are added to the sludge to bind
the hazardous metals and prevent leaching. An
alternative to landfilling of wastewater treatment
sludge is off-site metals recycling. According to a
recent study, 31 percent of U.S. plating shops send
sludge to a recycling facility. These sites are privately
owned processing plants that separate and recover the
metals from the sludges in forms that can be used as
feed material for manufacturing processes. The most
common end uses of the metal bearing materials
include copper, cadmium, and zinc feed materials for
primary metals manufacturing; chromium for stainless
steel manufacturing; and wood treatment chemical
reagents.
2.5 Key Players/Stakeholders Involved
with Metal Plating Waste Generation
and Management
Because of the variability in the size, application,
processes, and nature of metal plating operations,
numerous stakeholders may exist with both direct and
indirect interests in the life cycle of wastes generated,
as well as in any actions taken to reduce or eliminate
these wastes. Obviously, stakeholders include those
directly involved with metal plating operations.
Indirect stakeholders include individuals and organiza-
tions involved both upstream and downstream in the
life cycle of wastes and products derived from the
metal plating activities. Policymakers and regulators
responsible for protecting human health and the
environment, as well as those with oversight responsi-
bility for domestic and international commerce, also
can represent key players in the development and
implementation of policies aimed to force technology
and operational changes within these industrial sectors.
Exhibit 2-8 identifies potential stakeholders and
describes their involvement.
2-9
-------
Exhibit 2-7. Analytical Data for F006 Sludges Provided by Respondents to the Users Survey
Parameters
% Solids
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Cadmium
Calcium
Chromium (T)
Chloride*
Copper
Cyanide (T)
to Iron
r* Fluoride*
O
Lead
Manganese
Magnesium
Mercury
Nickel
Selenium
Silver
Sodium
Tin
Zinc
All values in mg/l
*Dry weight basis
PS018 PS043
98.0%
1,057
278
102,789 34,123 86,400 128,377 69,500 100,673 27,316 51,261 35,260 19,722 32,000 3
200 200 - 57,500 - 1,800 3,000 2,000 3-
411.0 2,298 <1,000 321 210 10,050 1,403 2,344 440 382 <1,000 g
1,000 ----- 1,000 0
(D
~7Q *7AA H
1 1 nno ----- 78,700 2.
— — — — I I,UUU ~
16.0 <0.004 - <0.006 - <0.38 <1.8 <5.0 1.08 0.37 - Bj.
2,500 48,065 <1,000 159,748 5,800 34,712 75,552 58,932 9,696 118,556 <1,000 O
0.2 6.6 <1,000 <0.006 <200 <9.61 <13.0 <5.68 <0.4 9.3 <1,000
332.0 0.0 - 0.0 <0.02 250.0 - <0.3 716.0 130.0
7,100 - 3,000 ----- 12,100
750 3,500 <1,000 2,000 1,260 39,827 <13.0 8,751 38.0 8,370 1,000
215055 2585 362,500 792 256,400 47,269 11,440 95,511 172,640 15,900 356,600
PSXXX-Survey Respondents.
-------
Waste Stream Characterization
Exhibit 2-8. Summary of Potential Stakeholders
Stakeholder
Affected Groups
Impacts
Metal Platers
Senior management
Mid-level management/environment
staff
Technicians and laborers
Select, evaluate, and implement waste
reduction options considering economic
impact, product quality, and efficiency.
Assess consumer willingness to accept
changes and to pay more for environmental
protection.
Assess changes in shop floor operations.
Assess availability of waste management to
handle new waste streams.
Implement changes.
Train all employee levels.
Upstream
Suppliers of raw materials,
feedstocks, equipment, and other
commodities
Generators of raw materials (ore
extraction, beneficiation, and
refining)
Respond to reduced demand for raw
materials and increased demand for
alternative materials.
Downstream
End-users
Waste management
Change technical design or specification for
product.
Prepare for reduced, eliminated, or altered
demand for services.
Policymakers and
Regulators
Environmental
Domestic/international trade and
commerce
• Assess impact of policy changes on all
relevant stakeholders.
• Assess consumer willingness to accept
changes and to pay more for environmental
protection.
Consumers
All consumers
Change attitude toward alternative materials
and green products.
2-11
-------
-------
3.0 WASTE MINIMIZATION/POLLUTION PREVENTION TECHNIQUES
3.1 General
This section presents an overview of the range of
pollution prevention/waste minimization options
available to metal finishers. The discussion is struc-
tured similarly to the U.S. Environmental Protection
Agency's (USEPA) Environmental Management
Options Hierarchy, shown in Exhibit 3-1. The highest
priorities are given to preventing pollution through
source reduction and recycling, including closed-loop
recycling. This strategy minimizes or eliminates the
need for off-site recycling or treatment and disposal.
Exhibit 3-2 indicates the optimal direction of a
pollution prevention plan.
Metal finishers have numerous opportunities for
source reduction, including environmental friendly
design of new products, product changes, and process
changes. Captive shops have a greater opportunity for
product changes than do job shops because they
control the design of the products. Both captive and
job shops have reduced waste generation through
process changes. Process changes have the greatest
impact in minimizing the use of chlorinated solvents,
cadmium, cyanide, and chromium. Numerous general
waste reduction methods can be used by plating shops
to reduce the formation of wastes. Often, these
methods are non-capital intensive methods of waste
reduction that can also reduce operating costs and
improve the working environment of the shop. Most
shops utilize conventional process solution mainte-
nance methods that reduce the disposal rate of
cleaning, plating, and other chemical baths. Advanced
process solution maintenance technologies, such as
microfiltration and membrane electrolysis, are also
being applied that can indefinitely extend the life span
of process solutions. Recovery of chemicals from
rinse waters using technologies such as evaporation,
ion exchange, and reverse osmosis can often be used
in a closed-loop manner. Plating shops also use off-
site recycling, where concentrated metal solutions and
sludges are processed into useful raw materials.
3.2 Alternative Processes
The deposition of metal coatings, such as
chromium, nickel, copper, and cadmium, is usually
achieved by wet chemical processes that have inherent
pollution control problems. Alternative metal deposi-
tion methods have replaced some of the wet processes
and may play a greater role in metal coating in the
future. This section discusses several of the more
common alternative metal deposition processes.
Many of these processes have very high unit
plating costs and, therefore, are currently used only for
special applications where the cost of coating is not a
major consideration. Also, the entire coating process
must be considered when evaluating technology
changes. In many cases, pre-cleaning and post-plating
processes are unaffected and, therefore, some conven-
tional tank processing is still required.
Alternative technologies for the metal finishing
industry have several features in common that distin-
guish them from conventional treatment technologies.
These features are described briefly below as a way of
providing a background for understanding the specific
technologies discussed in the remainder of this section:
• Energy—Surface treatment involves inputting
energy into the surface of the work piece in order
for adhesion to take place. Conventional surface
finishing methods involve heating an entire part.
The methods described in this section usually add
energy and material into the surface, keeping the
bulk of the object relatively cool and unchanged.
This allows surface properties to be modified with
minimal effect on the structure and properties of
the underlying material. [11]'
• Plasmas—The surface treatments described in this
section (except for thermal spray) use plasmas (i.e.,
clouds of electrons and ions from which particles
can be extracted). Plasmas are used to reduce
process temperatures by adding energy to the
surface in the form of kinetic energy of ions rather
than thermal energy. [11]
• Vacuum—Advanced surface treatments (except
most thermal spray and laser methods) require the
use of vacuum chambers to ensure proper clean-
liness and control. Vacuum processes are generally
more expensive and difficult to use than liquid or
air processes. Facilities can expect to see less com-
plicated vacuum systems appearing on the market
in the future. [11]
In general, use of the advanced surface treatments
is more appropriate for treating small components
(e.g., ion beam implantation, thermal spray) because
the treatment time for these processes is proportional
to the surface areas being covered. Facilities will also
have to address the following issues when considering
the new techniques [11]:
• Quality control methods: Appropriate quality
assurance tests need to be developed for evaluating
the performance of the newer treatment techniques.
3-1
-------
Waste Minimization/Pollution Prevention Techniques
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3-2
-------
Exhibit 3-2. Waste Minimization/Pollution Prevention Methods and Technologies
LEAST PREFERRED OPTION
Product Changes
and Process
Substitution
w
w
Alternative
Products/
Processes
Reduce/Eliminate
use of Chlorinated
Solvents
Reduce/Eliminate
use of
Cyanide
Reduce/Eliminate
use of Cadmium
Reduce/Eliminate
use of
Chromium
Reduce/Eliminate
use of other
Hazardous
Materials
Operation [
Processes mt^M
—
Improve
Operating
Procedures
Reduce
Drag-out
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Reduce
Rinse Water
Discharges
Reduce
Air
Emissions
Process
Solution
Maintenance
Conventi
Maintena
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Recovery
Electrolysis
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Electroly
Recove
Treatment/
Off-site
Recycle
Organics
Physical/
Chemical
Treatment
Off-site Recycle
of Treatment
Residuals
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615E-02
-------
Waste Minimization/Pollution Prevention Techniques
• Performance testing: New tribological tests must
be developed for measuring the performance of
surface engineered materials.
• Substitute cleaning and coating removal: The
advanced coatings provide excellent adhesion
between the substrate and the coating; as a result,
these coatings are much more difficult to strip than
conventional coatings. Many coating companies
have had to develop proprietary stripping tech-
niques, most of which have adverse environmental
or health risks.
• Process control and sensing: The use of advanced
processes requires improvements in the level of
control over day-to-day production operations, such
as enhanced computer-based control systems.
3.2.1 Organization of this Section
This section introduces some of the better known,
advanced coating processes. The discussion includes
a general overview of the technology's basic elements
and process steps, specific techniques that fall within
the broad technology class and their limitations and
applicability, and the technology's current uses, rela-
tive cost, and waste generation/environmental and
safety considerations. Exhibit 3-3 outlines the
advanced coating techniques presented in this section.
33.2 Thermal Spray Coatings
Technology Description
Coatings can be sprayed from rod or wire stock or
from powdered materials. The material (e.g., wire) is
fed into a flame where it is melted. The molten stock
is then stripped from the end of the wire and atomized
by a high velocity stream of compressed air or other
gas, which propels the material onto a prepared
substrate or workpiece. Depending on the substrate,
bonding occurs either due to mechanical interlock with
a roughened surface, due to localized diffusion and
alloying, and/or by means of Van der Waals forces
(i.e., mutual attraction and cohesion between two
surfaces.
Process Description
The basic steps involved in any thermal coating
process are substrate preparation, masking and
fixturing, coating, finishing, inspection, and stripping
(when necessary). Substrate preparation usually
involves scale and oil/grease removal, as well as
surface roughening. Roughening is necessary for most
of the thermal spray processes to ensure adequate
bonding of the coating to the substrate. The most
common method is grit blasting usually with alumina.
Masking and fixturing limit the amount of coating
applied to the work piece in order to remove the
overspray through time-consuming grinding and
stripping after deposition. [11]
The basic parameters in thermal spray deposition
are the particle's temperature, velocity, angle of
impact, and extent of reaction with gases during the
deposition process. The geometry of the part being
coated affects the surface coating since the specific
properties vary from point to point on each piece.
Facilities should standardize these properties in their
thermal spray process lines to minimize variations in
the surface coating. [11]
Exhibit 3-3. Summary of Advanced Coating Technologies
Technology
Applications
Limitations
Thermal Spray Coatings
• Combustion torch
• Electric arc
• Plasma sprays
Vapor Deposition
• Ion plating
• Ion implantation
• Sputtering and sputter
deposition
• Laser surface alloying
Chemical Vapor Deposition
Primarily repair operations although
they are now being incorporated into
original manufacturing
Primarily high-technology
applications that can bear additional
costs
Expected to improve product quality
and life
Used primarily for corrosion
resistance and wear resistance in
electronics
Technologies in varying states of
development; commercial availability
may be limited in certain cases
Expense often limits application to
expensive parts (e.g., aerospace,
electronics, military)
May require improved process
controls, employee training, and
automation
Start-up costs are typically very
expensive.
3-4
-------
Waste Minimization/Pollution Prevention Techniques
In many applications, workpieces must be finished
after the deposition process, the most common tech-
nique being grinding followed by lapping. The final
inspection of thermal spray coatings involves verifi-
cation of dimensions, an visual examination for pits,
cracks, etc. Nondestructive testing has largely proven
unsuccessful.
Unlike some of the other advanced coatings,
thermal coatings can be stripped chemically in acids or
bases, electrolytically, or in fused sales. If none of
these techniques are possible, mechanical removal by
grinding or grit blasting is necessary [11].
Specific Technologies
There are three basic categories of thermal spray
technologies: combustion torch (flame spray, high
velocity oxy-fuel, and detonation gun), electric (wire)
arc, and plasma arc. Section 4.1 presents a brief
description of each thermal spray technology, its
limitations and applicability, and examples of specific
applications.
Cost
Because the cost of using these systems depends
on many factors, including their application, it is
difficult to compare their costs. In general, it appears
that flame spraying and high velocity oxy-fuel are
relatively inexpensive in comparison to detonation gun,
electric-arc, and plasma spray. [9][11]
Stage of Development
Thermal spray processes are maturing, and the
technology is readily available. Coating manufacturers
are introducing new coating compositions with
improved microstructures. Improvement can still be
made in the area of epoxy sealants and nondestructive
testing.
Waste Generation/Environmental and Safety
Considerations
Environmental concerns include the generation of
dust, fumes, overspray, noise, and intense light. The
metal spray process is usually performed in front of a
"water curtain" or dry filter exhaust hood, which
captures the overspray and fumes. Water curtain
systems periodically discharge contaminated waste-
waters. Noise generated can vary from approximately
80 dB to more than 140 dB. With the higher noise
level processes, robotics are usually required for spray
application.
The use of metal spray processes may eliminate
some of the pollution associated with conventional
tank plating. In most cases, however, wet processes,
such as cleaning, are necessary in addition to the metal
coating process. Therefore, complete elimination of
tanks may not be possible.
Waste streams resulting from flame spray
techniques may include overspray, wastewaters, spent
exhaust filters, rejected parts, spent gas cylinders, air
emissions (dust, fumes), and wastes associated with the
grinding and finishing phases. For example, if chrom-
ium carbide is used with HVOF, disposal of the excess
material may be a problem.
3.2.3 Vapor Deposition
Technology Description
Vapor deposition refers to any process in which
materials in a vapor state are condensed through
condensation, chemical reaction, or conversion to form
a solid material. These processes are used to form
coatings to alter the mechanical, electrical, thermal,
optical, corrosion resistance, and wear properties of the
substrates. They are also used to form free-standing
bodies, films, and fibers and to infiltrate fabric to form
composite materials. [11]
This section describes two categories of vapor
deposition processes: physical (PVD) and chemical
(CVD). In PVD processes, the workpiece is subjected
to plasma bombardment. In CVD processes, thermal
energy heats the gases in the coating chamber and
drives the deposition reaction. Vapor deposition pro-
cesses usually take place within a vacuum chamber.
Physical Vapor Deposition
Physical vapor deposition methods are clean, dry
vacuum deposition methods in which the coating is
deposited over the entire object simultaneously, rather
than in localized areas. All reactive PVD hard coating
processes combine:
• A method for depositing the metal
• Combination with an active gas, such as nitrogen,
oxygen, or methane
• Plasma bombardment of the substrate to ensure a
dense, hard coating. [3]
PVD methods differ in the means for producing
the metal vapor and the details of plasma creation.
The primary PVD methods are ion plating, ion implan-
tation, sputtering, and laser surface alloying. Section
4.2 summarizes the four major PVD technologies in
use.
Waste Management/Environmental and Safety
Considerations
Wastestreams resulting from laser cladding are
identical to those resulting from high velocity oxy-
fuels and other physical deposition techniques:
blasting media and solvents, bounce and overspray
3-5
-------
Waste Minimization/Pollution Prevention Techniques
particles, and grinding particles. Generally speaking,
none of these waste streams are toxic. [3]
Chemical Vapor Deposition
CVD is a subset of the general surface treatment
process, vapor deposition. Over time, the distinction
between the terms "physical vapor deposition" and
"chemical vapor deposition" has blurred as new
technologies have been developed and the two terms
overlap. CVD includes sputtering, ion plating, plasma
enhanced chemical vapor deposition, low pressure
chemical vapor deposition, laser enhanced chemical
vapor deposition, active reactive evaporation, ion
beam, laser evaporation, and many other variations.
These variants are distinguished by the manner in
which precursor gases are converted into the reactive
gas mixtures. [11]
In CVD processes, a reactant gas mixture
impinges on the substrate upon which the deposit is to
be made. Gas precursors are heated to form a reactive
gas mixture. The coating species is delivered by a
precursor material, otherwise known as a reactive
vapor. It is usually in the form of a metal halide,
metal carbonyl, a hydride, or an organometallic
compound. The precursor may be in either gas, liquid,
or solid form. Gases are delivered to the chamber
under normal temperatures and pressures, while solids
and liquids require high temperatures and/or low
pressures in conjunction with a carrier gas. Once in
the chamber, energy is applied to the substrate to
facilitate the reaction of the precursor material upon
impact. The ligand species is liberated from the metal
species to be deposited upon the substrate to form the
coating. Since most CVD reactions are endothermic,
the reaction may be controlled by regulating the
amount of energy input. [9]
The steps in the generic CVD process are:
• Formation of the reactive gas mixture
• Mass transport of the reactant gases through a
boundary layer to the substrate
• Adsorption of the reactants on the substrate
• Reaction of the adsorbents to form the deposit
• Description of the gaseous decomposition products
of the deposition process.
Section 4.2 provides information on sputtering, ion
plating, and ion beam CVD. Section 4.3 describes the
overall CVD process and includes limits and applica-
bility and specific applications.
Waste Generation/Environmental and Safety
Considerations
The precursor chemicals should be selected with
care because potentially hazardous or toxic vapors may
result. The exhaust system should be designed to
handle any reacted and unreacted vapors that remain
after the coating process is complete.
Other waste effluents from the process must be
managed appropriately. Retrieval, recycle, and dis-
posal methods are dictated by the nature of the
chemical. For example, auxiliary chemical reactions
must be performed to render toxic or corrosive
materials harmless, condensates must be collected, and
flammable materials must be either combusted,
absorbed, or dissolved. The extent of these efforts is
determined by the efficiency of the process. [9]
3.3 Product and Input Material Changes
This section covers product changes and input
material changes, which are two key aspects of
pollution prevention for metal finishing operations.
3.3.1 Product Changes
Product changes can be implemented to reduce the
use of hazardous materials during finishing. Such
changes often involve changing the composition of the
base material. For example, changing from mild steel
construction to stainless steel construction may
eliminate all finishing steps for a given product.
The manufacturer is primarily responsible for
product changes because they have control over the
design and specification of the product. A recent
study indicates that some job shops have input on the
design of the parts that they pla.te and that they provide
customer education for part modification and design.
Some job shop plating companies indicated that they
would not bid on work that generates excessive
pollution.
3.3.2 Input Material Changes
Input material changes, such as using a less
hazardous coating, can be implemented by either the
manufacturer or metal finisher. Some input material
changes are restricted by specifications or aesthetic
preferences. Most input material changes made within
this industry have focused on chlorinated solvents,
cyanide, cadmium, and chromium.
Exhibit 3-4 summarizes key input material
changes in the metal finishing industry. The following
discussion highlights the industry's efforts in reducing
the use of chlorinated solvents, cyanide, cadmium, and
chromium.
Chlorinated Solvents
The most commonly used chlorinated degreasing
solvents include 1,1,1 trichloroethane (TCA), trichloro-
ethylene (TCE), perchloro-ethylene (PERC), chloro-
fluorocarbons (or solvent 113), and methylene
chloride. A variety of methods are employed for
3-6
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-4. Status of Material Substitution
Hazardous Material Conventional Process
Percent
Conversion
Alternative Processes
Chlorinated Solvents Vapor/Immersion Degreasing
Cyanide
Cadmium
Chromium
Zinc Cyanide Plating
Copper Cyanide Plating
Cadmium, Silver, and Gold Plating
Cadmium Plating
Decorative Chromium
Hard Chromium
Chromic Acid Anodizing
25-50
>75
25-75
<25
25 - 75*
25-50
<25
<25
Conversion Coating/ Desmut/Deox <50
- Aqueous Cleaning
- Semi-Aqueous Cleaning
- Alternative Solvents
- Salt Bath Cleaning
- Zinc Chloride
- Zinc Alkaline
- Zinc Sulfate
- Alkaline Non-Cyanide
- Acid Copper Baths
- Non-Cyanide Baths
- Zinc Plating
- Zinc Nickel
- Other Alloys
- Ion Vapor Deposition of
•Aluminum
- Trivalent Chromium
Plating
- Painting
- Electroless Nickel
- Nickel Alloys
- Metal Sprays
- Sulfuric Acid Anodizing
- Sulfuric/Boric Acid
Anodizing
- Trivalent Chromate
- Non-Chromium Solutions
* Success depends greatly on the application.
degreasing, the most popular being vapor degreasers,
immersion or spray operations, and hand wiping.
Data from a recent study show that approximately
one-quarter of the plating shops that used chlorinated
solvents in 1980 (approximately one-half of the U.S.
shops used chlorinated solvent in 1980) have elimi-
nated use of this material. The study also shows that
newer plating shops (i.e., those established since 1980)
are even less likely to use chlorinated solvents.
Moreover, the study indicates that the average quantity
of solvent used by shops has declined by approxi-
mately 25 percent since 1980. This reduction in the
usage rate is due to the implementation of equipment
and operational changes that reduce evaporative losses
of solvent and to the use of recovery devices.
Alternative cleaning methods substituted for
chlorinated solvents include:
• Tanks containing non-chlorinated materials, which
are replacing vapor degreasers. The tanks are used
like other metal finishing process tanks.
• Automatic parts washers.
Input material changes, including the ones given in the
following list, mostly focus on aqueous and semi-
aqueous cleaning substances:
• New cleaners that permit light oils to float and
heavy soils to sink, extending the life of the
cleaner.
• Equipment such as skimmers and filters that
separate the soils from the cleaning bath.
3-7
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Waste Minimization/Pollution Prevention Techniques
• Semi-aqueous cleaners, including water-immiscible
types (e.g., terpenes, esters, petroleum hydro-
carbons, and glycol ethers) and water-miscible
types (e.g., alcohols, ketones, and amines). Semi-
aqueous cleaners have better solvency properties
than do aqueous cleaners. However, there are some
drawbacks with their use, including oily films left
on parts, air emissions, and disposal problems. As
a result, the general preference is to use aqueous
cleaning rather than semi-aqueous cleaning. Some
soils are not adequately removed by aqueous
products (e.g., buffing compounds), however, and
semi-aqueous chemistry is needed.
Numerous other input material and equipment
substitutions are being used or investigated by the
metal finishing industry, including (1) non-ozone
depleting solvents that are used as drop-in replace-
ments in conventional chlorinated solvent equipment
(includes hydrochlorofluorocarbons [HCFCs], (2)
pcrfluorocarbons (PFCs), which are used in new vapor
degreasing tanks for cleaning heavily soiled parts or
parts requiring a high quality cleaning process, (3)
supercritical fluids (e.g., CO2), which are an emerging
technology with limited application, and (4) molten
salt baths, which are used widely but have limited
application.
Cost differences between conventional chlorinated
solvent cleaning and the alternative methods vary
widely depending on the specific application. In
addition, chlorinated solvent cleaning costs are
changing rapidly because of decreases in material
production and increases in disposal costs. Prior to
recent changes in environmental laws governing
chlorinated solvents, the cost of using these materials
was relatively low.
Cyanide
Cyanide-containing plating baths produce high-
quality coatings. However, these baths pose a problem
in terms of both pollution control compliance and
economics. In the United States, cyanide effluent
limitations are often set locally at concentrations far
below the federal standards.2 As a result, there has
been a significant effort to find and implement
cyanide-free plating processes since approximately
1975.
The greatest success so far in cyanide substitution
is the switch from zinc cyanide plating to zinc chloride
and zinc alkaline plating. One significant drawback
with regard to zinc cyanide plating substitution is that
some shops find it necessary to install both zinc
chloride and zinc alkaline baths to replace the single
cyanide bath. On a positive note, in addition reducing
the use of cyanide, some platers enjoy production
benefits from the substitution, including better and
brighter plating.
The second most complete non-cyanide plating
substitution is the switch from copper cyanide plating
to alkaline non-cyanide and acid copper baths. Similar
to zinc plating, shops switching to non-cyanide copper
must often implement two processes.
Cadmium, silver, and gold are almost exclusively
plated from cyanide baths, although non-cyanide
substitutes are available for all three metals. In each
case, the substitutes have limited application or are
significantly inferior in terms of deposit quality.
With the elimination of cyanide, so is the need to
chlorinate the cyanide for the treatment of cyanide.
This eliminates the cyanide complexes formed in the
plating bath and improves treatment efficiency. This
also eliminates the need for segregated cyanide
plumbing, reducing maintenance costs and hazard
exposure.
In summary, much of the plating workload that
was once processed in cyanide baths is now being pro-
cessed in non-cyanide baths. Overall, cyanide usage
by U.S. metal finishing shops has decreased by 50
percent or more since 1980. Marty plating shops have
completely eliminated the use of cyanide. Because
most non-cyanide substitutes do not cover the range of
applications of their cyanide counterparts, however, the
majority of these shops have had to reduce their cus-
tomer base to eliminate cyanide use.
Cadmium
Many alternatives to cadmium plating exist, with
no single universal substitute available. Some cad-
mium plating alternatives are zinc plating, tin or tin
alloy plating, cobalt-zinc plating, zinc-nickel plating,
zinc-iron plating, zinc-flake dispersion coating, metallic
ceramic coating, and ion vapor deposition of
aluminum. The most successful of these alternatives
has been zinc-nickel plating, which has a long history
in the electroplating industry. Generally, for
alternatives to be successful, they must provide
sufficient corrosion resistance, as measured by standard
tests (e.g., salt fog test). For certain military and
aerospace applications, the alternative deposits must
also provide other desired characteristics, such as
lubricity.
Many electroplating job shops have eliminated
cadmium plating because of a reduced market and the
enforcement of local discharge standards that are often
much more restrictive than the federal limitations. In
addition, many captive shops and military shops have
reduced or eliminated the use of cadmium plating (e.g.,
Tinker Air Force Base, Oklahoma).
3-8
-------
Waste Minimization/Pollution Prevention Techniques
Chromium
Chromium is used most often with decorative
chromium plating. This process is traditionally per-
formed with a hexavalent chromium bath, but trivalent
chromium plating has increased in use, especially
during the past 10 years. With either process, an
undercoat of nickel/copper or nickel is usually applied.
Instead of using chromium plating, some platers have
replaced steel parts with noncorrosive materials, such
as stainless steel, and used organic coatings (paint).
An example of chromium plating displacement is
automobile bumpers. Although some chromium
plating has been replaced, it is still one of the most
frequently applied electroplates.
Trivalent chromium plating is an economically
attractive alternative to hexavalent plating for some
applications. However, its use has been limited due to
a difference in appearance from the standard hexa-
valent bath. The trivalent bath chemistry is more
expensive to purchase than the hexavalent bath. The
cost savings are a result of reduced metal loadings on
the treatment system (the trivalent bath contains less
total chromium) and the avoidance of the hexavalent
chromium reduction step during treatment. One source
estimates that, considering treatment costs, the cost of
trivalent chromium plating is about one-third of the
costs for hexavalent solution (ref. 2).
Hard chromium plating is applied to tools,
hydraulic cylinders, and other metal surfaces that
require wear resistance. The major difference between
the hard chromium and decorative deposits is their
thickness. The hard chromium deposit is typically
hundreds of times thicker than decorative ones.
Although research efforts have aimed at a trivalent
chromium substitute for hard chromium plating, no
solutions are available commercially. Input material
changes for hard chromium have focused on alter-
native deposits. Alternative processes have also been
used. The most successful alternative input material is
electroless nickel (ref. 14). Other alternative input
materials under investigation are electroplated nickel
alloys (e.g., amplate) and nickel alloy composites (e.g.,
Boeing Ni-W-SiC). Alternative processes to hard
chromium plating include brush plating, vacuum
coating, and metal sprays (see Section 3.2 for discus-
sions of vacuum deposition and metal sprays).
During the past several years, the U.S. Air Force
has investigated alternative input materials and
processes for hard chromium. The results of these
efforts indicate that substitutions can be made on a
case-by-case basis.
Chromium use with aluminum finishing is perhaps
most common in the aerospace industry. Chromium
combines with aluminum on the surface of parts to
provide corrosion and wear resistance and a chemically
active surface for painting or coloring. The two most
common processes are chromic acid anodizing and
chromate conversion coating. These are not competing
processes, but rather each has a specific role. Both
processes are performed in hexavalent chromium baths.
The anodizing process is electrolytically performed and
the conversion coating process involves simple immer-
sion. Significant research efforts have been undertaken
during the past 10 years to find alternatives to these
processes. For many applications, alternatives have
been identified and implemented. For example,
chromic acid anodizing has been partially replaced by
common sulfuric acid anodizing and sulfuric/boric acid
anodizing, and chromium baths have been replaced to
a lesser extent by non-chromium conversion coatings
(e.g., permanganate, rare earth metals and zirconium
oxide) (ref. 15).
Another use of chromium during aluminum finish-
ing is for deoxidizing/desmutting. These preliminary
processes (sometimes a combined single step) remove
oxides and other inorganics that would interfere with
aluminum processing (e.g., anodizing). Alternatives to
the chromium-based products include iron and ammon-
ium salts or amines mixed with various oxidizers
and/or etchants. Owing to the extent of research for
non-chromium aluminum finishing and the success rate
of these efforts, it is feasible that chromium use will
eventually be eliminated from the aluminum finishing
area. One would expect to see large-scale substitutions
during the next 10 years. However, total elimination
will take considerable longer because of small residual
uses of chromium for which no satisfactory substitute
exists and because of the complexity of the military
and aerospace specifications that presently require the
use of chromium.
3.4 Genera) Waste Reduction Practices
3.4.1 Improved Operating Procedures
Employee Education
A high level of employee awareness and education
is an essential part of any company's overall
environmental program. The success or failure of
specific procedures depends largely on employee
attitudes toward that policy. The employees must
discern a company-wide effort supported at all levels
of management that affords the tools and data to
ensure success.
Employee training should cover minimization or
prevention of waste generation at the source, routine
process chemistry additions and sample-taking, hand-
ling of spills and leaks, and operation of pollution
3-9
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Waste Minimization/Pollution Prevention Techniques
prevention and control technologies. Background
information should be made available to employees,
such as an outline of the applicable regulations, overall
benefits to health and safety in and out of the work-
place, and overall costs of waste treatment before and
after the successful implementation of waste minimiza-
tion procedures. This training should be integrated
with normal operator training, and pollution prevention
and control procedures should be included in the
written operating procedures for each process.
Chemical Tracking, Inventory, and Purchasing
Control
Records of chemical purchases, inventory, bath
analyses, dumps and additions, water usage, waste-
water treatment chemical usage, and spent process bath
and sludge analyses must be kept in order to gather an
overview of a shop's material balance and waste
treatment costs. From these records, data can be
gathered and used to determine the success of an
overall minimization policy. Process-specific material
balance block diagrams can be drawn and shared with
operators. These diagrams illustrate origins of waste
production clearly and can also be used to re-engineer
plating lines to reduce chemical loss.
Standardization of materials used throughout a
shop can greatly reduce chemical inventory, thereby
reducing costs. Decisions to purchase one chemical
rather than another must consider technical require-
ments, environmental impacts, and cost.
3.4.2 Drag-Out Reduction
Drag-out of process fluid into rinse water is a
major source of pollution in any plating shop. The
volume of drag-out discharged from a process is deter-
mined by some factors that cannot be altered easily,
such as part shapes and process fluid concentrations.
The effects of many other contributing factors,
however, are readily reduced by common techniques.
Reduction of drag-out not only reduces the mass of
pollutants reaching the wastewater stream but also
reduces the amount of chemical loss suffered by the
process. Because most of the drag-out reduction
methods discussed in this section require only operator
training or small process changes, the cost savings and
other benefits realized quickly offset any implementa-
tion expenses incurred. Section 4.4 summarizes drag-
out reduction techniques.
3.4.3 Rinse Water Use Reduction
Reducing water usage offers several benefits,
including reduced water costs, higher waste treatment
efficiency, size reduction of future waste treatment and
pollution control technologies, and reduction in the use
of treatment chemicals. Water usage cannot be
reduced indiscriminately without risking process prob-
lems. Rinse tanks must maintain a target concentration
of contamination, above which part quality may suffer.
Several inexpensive methods can significantly reduce
water consumption, however, without affecting rinse
contaminant concentrations. Section 4.5 summarizes
techniques for reducing rinse water.
3.4.4 Air Emissions Reduction
The release of chlorinated solvents can be reduced
through design changes to degreasing equipment and
good operating practices. Examples of design changes
include increased freeboard, automatic rolltop, hoist
speed control, and refrigeration zone. Examples of
good operating practices include covering unused
degreasing and the "stop-and-go" part removal tech-
nique. Chromium air emissions can be reduced
through process changes and the use of capture/recycle
control devices.
3.5 Process Solution Maintenance
3.5.1 Conventional Maintenance Methods
The most common conventional bath maintenance
method is filtration. Nearly all plating baths require
filtration to remove suspended solids that would
otherwise adhere to the surface of parts and cause
rough plating. Small tanks can be filtered effectively
by in-tank designs also keeping tanks covered when
not in use; larger tanks usually require external pump
and filter assemblies. Disposable cartridge filters made
of wound or woven plastic are the most common filter
type, followed by sand and diatomaceous earth.
Electrolysis or "dummy plating" is a method of
reducing the mass of contaminant metals in a plating
bath by plating them onto a dummy panel. Dummy
plating can be performed directly in the plating tank
or, to prevent down time, it can be done inside the
tank. During dummy plating, a current density much
lower than that used for normal plating is applied.
The precise current density is determined by the
process bath and the contaminants.
Chemical treatment inducing the precipitation of
certain contaminants is effective for some plating
baths. Carbonates in potassium cyanide baths can be
precipitated with the addition of calcium hydroxide.
Sodium sulfide can be added to cyanide plating baths
to precipitate such metals as zinc or lead. Precipitation
is usually performed in a spare tank and the precipitate
is remove by filtration.
Carbonate freezing is applicable to sodium-based
cyanide plating baths. When cooled to a temperature
of approximately 3°C, sodium carbonate crystals form
and can be removed easily.
3-10
-------
Waste Minimization/Pollution Prevention Techniques
Carbon treatment is a common method of reducing
organic contamination in plating baths. Carbon treat-
ment may only consist of occasionally substituting
carbon for normal cartridges in the existing filtration
equipment.
Alternately, filter columns containing several
kilograms of bulk-activated carbon can be used for
heavy organic loading. Nickel and copper plating
solutions usually require regular carbon treatment.
3.5.2 Advanced Maintenance Technologies
This section discusses advanced maintenance
technologies: microfiltration, ion exchange, acid sorp-
tion, ion transfer. Section 4.6 presents these tech-
nologies in greater detail.
Microfiltration
Microfiltration is a relatively new, membrane-
based technology applied primarily to aqueous and
semi-aqueous cleaning solutions. Oil and grease that
accumulate in these baths degrade their cleaning
efficiency although most bath constituents remain
usable. This technology separates emulsified oils and
other colloids from the cleaner chemistry, thereby
extending the life of the process bath. Exhibit 3-5
presents a typical microfiltration application.
Ion Exchange
Ion exchange as a bath maintenance technology is
limited, for the most part, to cation removal from
chromic acid solutions. Cations, such as copper, zinc,
or iron, are introduced into chromic acid plating baths
from parts and racks. They are tolerated to a point,
beyond which plating performance is affected and the
bath must be purified or discarded. For chromic acid
purification, ion exchange competes with ion transfer
and membrane electrolysis. Exhibit 3-6 illustrates two
types of ion exchange configurations.
Acid Sorption
Acid sorption is an acid purification technology
applicable to various acid solutions, such as pickling or
sulfuric acid anodizing baths. Acid is purified by the
removal of dissolved metal. (Diffusion dialysis is
another method for purifying acid.) Acid sorption is
not commonly used by the plating industry. Exhibit
3-7 presents a typical acid sorption configuration.
Ion Transfer
Ion transfer is a common technology with appli-
cations generally restricted to chromic acid plating
baths, etches, and anodizing baths. Equipment can be
in-tank or external. Designs range from low-cost, in-
tank, small porous pots to large multi-cell automated
units with integrated rectifiers and transfer pumps. As
with the other chromic acid purification technologies,
the goal of this technology is to selectively remove
cations from chromic acid process fluids. Cr+3 oxida-
tion to Cr+6 occurs at the anode. Exhibit 3-8 shows a
typical ion transfer configuration.
3.6 Chemical Recovery Technologies
Chemical recovery technologies either recover
dragout and return it to the process (vacuum evapo-
ration, electrodialysis, and reverse osmosis) or recover
a constituent of the dragout chemistry, usually a
dissolved metal, and re-use or recycle it in another
process (electrowinning, metal scavenging, ion
exchange). Recovering drag-out reduces raw material
costs by returning otherwise lost components to the
process and reduces the mass of regulated ions
reaching the waste treatment system, which lowers
costs and aids in complying with discharge limits.
Recovery technologies discussed in this section
require at least some, and in many cases extensive,
engineering and planning. With the possible exception
of some electrowinning and evaporation applications,
the feed stream requires complete characterization. Ion
exchange and reverse osmosis equipment capacities
and other design characteristics must be customized to
these data. The level of customization and engineering
required for certain installations can represent a signifi-
cant portion of capital costs and can make small feed
stream volumes expensive to treat. Capital and opera-
ting costs mentioned in this section are typical; specific
costs can vary widely. Installation and set-up costs are
site- and application-specific and can match or exceed
equipment costs in some cases. Labor costs are
difficult to predict but are usually much higher than
expected with manual, undersized, or poorly planned
and engineered installations. Section 4.7 describes
chemical recovery technologies, including their typical
applications, restrictions, and costs.
3.6.1 Evaporation
Evaporation with atmospheric and vacuum systems
is the most common chemical recovery technology
used in the plating industry. Atmospheric evaporators
are most common, are relatively inexpensive to
purchase, and easy to operate. Vacuum evaporators
are mechanically more sophisticated and are more
energy efficient; therefore, they are usually the choice
for applications where evaporation rates greater than
50 to 70 gallons per hour (190-265 liters per hour) are
required. Additionally, with vacuum evaporators,
water lost as vapor can be recovered as a condensate
and re-used in the plant. Exhibit 3-9 shows two
typical evaporation designs.
3-11
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-5. Example of Microfiltration Application
Evaporation
• Dl Water
Primary
Dsgreaser
500/1-
Clean w-
85*C
Secondary
Degreaser
20g/L
Cteaner
Oil, Grease
..*
i i
'. I — ~
Working Tank
475 L
-47SU
1 , 475 L. ,
rtO mg/l.,
- ,Vf OB •
Three Stage Counter-Flowing Rinse
To Treatment
Microfiltration
Unit
Processed Cleaner
Dl Water
Exhibit 3-6. Two Common Configurations of Ion Exchange for Bath Maintenance
Evaporation
ADI Water
eld Regonerant
3-12
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-7. Typical Acid Sorption Configuration
arvoir
Cooling (If required)
Purified Acid
By-product
>• to Electrowinnlng
or Treatment
Exhibit 3-8. Typical Ion Transfer Configuration
1
Dl Water
1
Two Stage Counter-Flowing Rmse
1;
Dl Water
Catholyte to
Treatment
Ion Transfer
Unit
, Conc^ntratSj ^"
^Omifaul
3-13
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-9. Two Common Configurations for the Application
of Atmospheric Evaporators
SSUHr
Evap
SOUHr
High Temperature
f Evaporator J —
>
t.
\
iS
Process
- -> TanJc
JJh
JJL
1 i
i r*
Dl Water
125L/Hr
Three Stage Counter-Flowing Rinse
Evap
1L/Hr
Moderate Temperature
63UHr
>
\~
| Evaporator j —
>
t.
u.
' Process
Tank
.'. V 38'C.
Evap
1 L/Hr
\
lil
iv/'OIWirH
;:*jjfflrafe
iSfJ1111*
':>lo'50«t
«_
>'.
f
i
J:
f
^
I 1 U,
~^^~^~
^ti1:
Two Stage Counter-Flowing Rinse
Dl Water
65L/Hr
. To Treatment
3.6.2 /on Exchange
Ion exchange is a versatile technology that can be
a major component of a low- or zero-discharge confi-
guration or it can be employed to selectively remove
certain cations from a rinse, stream. In either case, ion
exchange can only be applied to relatively dilute
streams and is best employed in association with other
conventional drag-out recovery practices. In many
applications, ion exchange is used to recycle rinse
water. In a few cases, the ion exchange regenerant,
which contains the recovered process chemistry, can be
returned to the process tank directly. In most cases,
however, the regenerant is electrowinned or treated
conventionally. Exhibit 3-10 presents common ion
exchange system configurations.
3.6.3 Electrowinning
Electrowinning is a well-known and common
recovery technology. It is limited, however, because
only the metal portion of the process chemistry is
recovered, making direct return of the metal-depleted
drag-out usually impossible. The technology is gener-
ally inexpensive both to purchase and operate.
Electrowinning is applied to drag-out fluids, spent
process baths, or ion exchange regenerant, all of which
are relatively concentrated with metal ions. It is used
to reduce the mass of regulated metals being dis-
charged to a main treatment center, in turn reducing
the quantity of treatment reagents needed and sludge
produced. When applied to precious metals, the value
of the metal recovered may be the primary considera-
tion. For the less expensive recovered metals, the
value of the recovered metal is usually a secondary or
incidental benefit. Exhibit 3-11 illustrates two com-
mon electrowinning contributions.
3.6.4 Electrodialysis
Electrodialysis is employed with much less
frequency for metal recovery than some other techno-
logies, such as ion exchange or evaporation. The most
common application of electrodialysis is the recovery
of nickel from rinse water. A considerable portion of
the drag-out from a nickel process can be separated
from the rinse water and returned to the nickel bath.
One advantage unique to this technology is that
organic molecules are prevented from entering the
concentrate flow and therefore are not returned to the
3-14
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-10. Common Ion Exchange Configurations for Chemical Recovery
r
r
Dl Water
6SL/Hr
City Water
nil
J'sVa^f''
420L/Hr
Return Regenerant to Process
Evaporation
2. Water Recycling
r
D( Water
65UHr
D! Water
Acid Regenerant
Return Cation Regenerant to Process
^ y I ^* r I 4"+
To Treatment or
Electrowinning
To Treatment
Exhibit 3-11. Two Common Electrowinning Configurations for Metal Recovery
1 . Drag-out Tank
Drag-out
Drag-out
uL
Scrap
Metal
forRecy
:le
cL
•S-
t 4
Electrowin
Unit
"
iUj
Drag-out
3-15
-------
Waste Minimization/Pollution Prevention Techniques
process tank, making electrodialysis particularly
suitable for recovery of process fluids in which an
undesirable build-up of organics occurs. Exhibit 3-12
presents a schematic of a nickel plating line with
electrodialysis.
3.6.5 Reverse Osmosis
Reverse osmosis is a membrane filtration tech-
nology that has been applied to a single rinse stream
from a process or to a mixed stream from several
processes. The portion of the flow that passes through
the membrane is usually recycled as rinse water or the
portion of the flow rejected by the membrane and
containing most of the dissolved solids is often suitable
for direct return to the process tank. Reverse osmosis
is a good component of a low- or zero-discharge confi-
guration. Reverse osmosis equipment is usually more
expensive than ion exchange, and the quality of the
recycled water is somewhat lower. Exhibit 3-13
presents a typical reverse osomsis configuration for
nickel recovery.
3.7 Off-Site Metals Recycling
Approximately one-third of U.S. plating shops
send their metal bearing wastewater treatment sludges
to off-site metals recycling companies rather than to
land disposal. The recycling companies separate the
metals from the sludge and convert them to usable
materials. Some off-site facilities also accept and
process spent chemical solutions.
3.7.7 Available Services
Off-site metals recycling services in the United
States were previously limited to spent solvents,
precious metal wastes, and high purity common metal
wastes. Since 1985, there has been a steady increase
in the use of off-site recycling, primarily because of
the availability of recycling services for wastewater
treatment sludges, rising costs for land disposal, and
increased generator concern over the liability associ-
ated with land disposal.
Companies that recycle metals accept limited types
of wastes, depending on their permit issued by
USEPA. Of the companies identified as metals
recyclers, for example, only seven can accept waste-
water treatment sludge. One company specializes in
processing cyanide bearing wastes, and another accepts
mostly spent solutions from printed circuit board
manufacturing.
Exhibit 3-12. Flow Schematic of Nickel Plating Line
Before and After Installation of Electrodialysis
Evtp
IIUHr
Before
* Drag-in/Drag-out
j Arrangement
ijjj
"_ M Plata
! ''.' ^W / .
nil.
^Wi"
••'•• W .. . .;
L1 h
ifeOmg/l,
C '-;Nl w 'T
„..*
•"^rhgA,,
''. ,5s "i*.
City Water
511UHr
Throe Stage CounterrFlowing Rinse
500 L/Hr to Treatment
Ni loss 1800 g/Hr
Evap
IIL/Hr
After
Drag-ln/Drag-out
Arrangement
>
— '
JJu
';!i es.srt-'." "
01SE-12
511
UHr
[~FJ
"
]Ui
3^00 mgfl;1
..','-' Ml" . .
Ij
7mg/l'j
' Three Stage Counter-Flowing Rinse
[ Recycle
ter
J
>
i
^| Electrodialysis
— '-\ Unit
1 >Z6m
J Nlcke
/Hr
g/LNI to Treatment
ILoss: 127 g/Hr
City Water
511L/Hr
63g/LN!
3-16
-------
Waste Minimization/Pollution Prevention Techniques
Exhibit 3-13. Typical Reverse Osmosis Configuration for Nickel Recovery
Evap
19L/Hr
Drag-in/Drag-out
Arrangement
1
_/
.j-Nt Process-^
511
UHr
S15E-13
379 L/Hr
Feed
Reject (concentrate) 19 L/H
r
J
««w^-A.
Count
l,ft(ri
^,000
R.
Un
I
City Water
19UHr
City Water
38L/Hr
To Treatment
38L/Hr
The present U.S. capacity for recycling wastewater
treatment sludges has been estimated to be 1.1 million
tons per year. At present, approximately one-third of
this capacity is being used. Various recovery pro-
cesses are employed by the off-site recycling compan-
ies to convert wastewater treatment sludge into usable
products. Most of these processes can be categorized
as pyrometallurgical or hydrometallurgical processes.
A typical facility processes 25,000 to 150,000 tons of
waste material per year.
3.7.2 Recycling Costs
Various factors affect the price charged by off-site
recyclers. These factors include competition, sludge
type (hydroxide sludges are preferred to sulfide
sludges), metal constituents of the waste (mono-metal
sludges are preferred to mixed metal sludges), moisture
content (preferred content varies from facility to
facility depending on equipment type), waste volume
(higher volumes mean lower prices), chemical consis-
tency from shipping to shipment, and hauling distance
(average U.S. distance is approximately 700 miles).
Prices charged by off-site recycling companies vary
widely with the median price being $0.30 per pound,
including transportation. By comparison, the cost for
land disposal of sludges is $0.25 per pound, including
transportation. Many plating companies appear willing
to pay a slightly higher price for recycling perhaps
because of the liability associated with land disposal,
since waste generators can be financially responsible
for the clean-up costs of Superfund sites. One source
estimated a liability factor of $0.02/lb.
References
1. Spearot, Rebecca M., Peck, John V., "Environ-
mental and Safety Consequences - The Hidden
Value in New Metal Finishing Processes," AESF,
72nd Annual Technical Conference, July 1985.
2. Ko, C.H., et al., "A Comparison of Cadmium
Electroplate and Some Alternatives," Plating and
Surface Finishing, October 1991.
3. Jeanmenne, Robert A., "EN for Hard Chromium,"
Products Finishing, January 1990.
Hinton, Bruce R.W., "Corrosion Prevention and
Chromates: The End of an Era?," Metal
Finishing, October 1991.
Werner, Douglas B. and Mertens, James A.,
"Replacing 1,1,1-Trichloroethane: Consider Other
Chlorinated Solvents," Plating and Surface
Finishing, November 1991.
Mandich, N.V. and Krulik, G.A., "Substitution of
Nonhazardous for Hazardous Process Chemicals
in the Printed Circuit Industry," Metal Finishing,
November 1992.
Holmes, V.L. et. al., "The Substitution of IVD
Aluminum for Cadmium," Air Force Engineering
and Service Center, Tyndall Air Force Base,
August 1989.
Wang, Victor and Merchant, Abid N., "Metal
Cleaning Alternatives for the 1990s," Metal
Finishing, April 1993.
Graves, Beverly, "Industrial Toxics Project: The
33/50 Program," Products Finishing, June 1992.
10. Wood, William G. (Coordinator), "The New
Metals Handbook, Vol. 5. Surface Cleaning,
Finishing, and Coating," American Society for
Metals, May 1990.
Tsai, Eric Chai-Ei and Nixon, Roy, "Simple
Techniques for Source Reduction of Wastes from
Metal Plating Operations," Hazardous Waste &
Hazardous Materials, Vol. 6, No. 1, 1989.
4.
5.
6.
7.
9.
11
3-17
-------
Waste Minimization/Pollution Prevention Techniques
12. Cushnie, George, Pollution Prevention and
Control Technology for Plating Operations,
National Center for Manufacturing Science, Ann
Arbor, MI, 1994.
13. United Nations, Environmental Aspects of the
Metal Finishing Industry: A Technical Guide,
UNEP/IEO, 1989.
Deutchman, Arnold and Partyka, Robert, Ion
Beam Enhanced Deposition of Hard Chrome
Coatings.
14. Murphy, Michael (ed), "Metal Finishing
Guidebook and Directory Issue '93," Metal
Finishing, January 1993.
15. Wood, William G. (Coordinator), "The New
Metals Handbook, Vol. 5. Surface Cleaning,
Finishing, and Coating," American Society for
Metals, May 1990.
16. Baker, Gary, Cushnie, George, Patterson, Craig
and Waltzer, Sam, High Velocity Oxy Fuel Final
Results Report, Science Applications International
Corporation, DEP Contract No. F09603-90-D2215,
Cincinnati, OH, 1994.
17. U.S. Department of Commerce, Opportunities for
Advanced Surface Engineering, NIST GCR
94-640-1, May 1994.
18. National Defense Center for Environmental
Excellence, Environmental Technology Survey,
An Overview of Selected Inorganic Coating
Processes.
19. B.A. Manty, M.L. Weis. Characterization of
Current Electroplating Processes, for U.S. ARMY
Armament Research Development and Engineer-
ing Center, Picatinny Arsenal, 1994.
20. National Defense Center for Environmental
Excellence. Technology Abstract. Ion implanta-
tion.
21. Low Energy Ion Implantation and Deposition.
Spectrum Sciences Inc. no date, no author
22. Hard Chrome Coatings: Advanced Technology for
Waste Elimination. First Annual Report (March I,
1993 - February 28, 1994), BIRL Northwestern
University for The Advanced Research Projects
Agency.
23. Low Energy Ion Implantation and Deposition.
Spectrum Sciences Inc. no date, no author.
24. Low Energy Ion Implantation/Deposition as a
Film Synthesis and Bonding Tool. A. Anders,
S. Anders, I.G. Brown, I.C. Ivanov. Spectrum
Sciences Inc., paper presented at Meeting of the
Materials Research Society. November 29 -
December 3, 1993.
25. Hard Chrome Coatings: Advanced Technology for
Waste Elimination. First Annual Report (March 1,
1993 - February 28, 1994). BIRL Northwestern
University for The Advanced Research Projects
Agency.
26. J.W. Dini, Alternatives to Chromium Plating,
paper presented at AeroMat 94 ASM International.
June 7, 1994.
27. National Defense Center for Environmental
Excellence, Technology Abstract, Cadmium
Electroplating Alternatives.
28. National Defense Center for Environmental
Excellence, Technology Abstract, Ion
Implantation.
29. National Defense Center for Environmental
Excellence, Technology Abstract, Chromic Acid
Anodizing Alternatives.
30. National Defense Center for Environmental
Excellence, Technology Abstract, Metal Coating
and Finishing Processes.
31. National Defense Center for Environmental Ex-
cellence, Environmental Technology Survey, An
Overview of Selected Inorganic Coating
Processes.
32. B.A. Manty, M.L. Weis, Characterization of
Current Electroplating Processes, for U.S. ARMY
Armament Research Development and Engin-
eering Center, Picatinny Arsenal, 1994.
33. U.S. Department of Commerce, Opportunities for
Advanced Surface Engineering, NIST GCR
94-640-1, May 1994.
Endnotes
1 See reference #11; for this section on thermal
spraying, the particular chapter of reference #11 is
called "Thermal Spray Coatings" and was written by
Robert C. Tucker, Jr., of Praxair Surface Technology,
Inc. pp. 161-177.
2 There is an emotional factor involved with cyanide
because it is widely been regarded as a deadly poison.
Because of its notoriety, cyanide is probably feared
more by the general public than many compounds that
pose significantly greater environmental and health
risks.
3-18
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4.0 EXAMPLES OF WASTE MINIMIZATION/
POLLUTION PREVENTION TECHNIQUES
4.1 Thermal Spray Technologies
4-. 1.1 Combustion Torch/Flame Spraying
Flame spraying involves the use of a combustion
flame spray torch in which a fuel gas and oxygen are
fed through the torch and burned with the coating
material in a powder or wire form and fed into the
flame. The coating is heated to near or above its
melting point and accelerated to speeds of 30 to 90
m/s. The molten droplets impinge on the surface
where they flow together to form the coating.
Limits and Applicability
Flame spraying is noted for its relatively high as-
deposited porosity, significant oxidation of the metallic
components, low resistance to impact or point loading,
and limited thickness (typically 0.5 to 3.5 mm).
Advantages include the low capital cost of the equip-
ment, its simplicity, and the relative ease of training
the operators. In addition, the technique uses
materials efficiently and has low associated main-
tenance costs.
Specific Applications
This technique can be used to deposit ferrous-,
nickel-, as well as cobalt-based alloys, and some
ceramics. It is used in the repair of machine bearing
surfaces, piston and shaft bearing or seal areas, and
corrosion and wear resistance for boilers and
structures (e.g., bridges).
4.1.2 Combustion Torch/High Velocity Oxy-
Fuel (HVOFJ
With HVOF, the coating is heated to near or
above its melting point and accelerated in a high-
velocity combustion gas stream. Continuous combus-
tion of oxygen fuels typically occurs in a combustion
chamber, which enables higher gas velocities (550 to
800 m/s). Typical fuels include propane, propylene,
MAPP, or hydrogen.
Limits and Applicability
This technique has very high velocity impact, and
coatings exhibit little or no porosity. Deposition rates
are relatively high, and the coatings have acceptable
bond strength. Coating thicknesses range from
0.000013 to 3 mm. Some oxidation of metallics or
reduction of some oxides may occur, altering the
coating's properties.
Specific Applications
This technique may be an effective substitute for
hard chromium plating for certain jet engine compo-
nents. Typical applications include reclamation of
worn parts and machine element build-up, abradable
seals, and ceramic hard facings.
4. 7.3 Combustion Torch/Detonation Gun
Using a detonation gun, a mixture of oxygen and
acetylene with a pulse of powder is introduced into a
water-cooled barrel about 1 meter long and 25 mm in
diameter. A spark initiates detonation, resulting in
hot, expanding gas that heats and accelerates the
powder materials (containing carbides, metal binders,
oxides) so that they are converted into a plastic-like
state at temperatures ranging from 1,100 to 19,000°C.
A complete coating is built up through repeated,
controlled detonations.
Limits and Applicability
This technical produces some the densest of the
thermal coatings. Almost any metallic, ceramic, or
cement materials that melt without decomposing can
be used to produce a coating. Typical coating thick-
nesses range from 0.05 to 0.5 mm, but both thinner
and thicker coatings are used. Because of the high
velocities, the properties of the coatings are much less
sensitive to the angle of deposition than most other
thermal spray coatings.
Specific Applications
This can only be used for a narrow range of
materials, both for the choice of coating materials and
as substrates. Oxides and carbides are commonly
deposited. The high-velocity impact of materials such
as tungsten carbide and chromium carbide restricts
application to metal surfaces.
4.1.4 Electric Arc Spraying
During electric arc spraying, an electric arc
between the ends of two wires continuously melts the
ends while a jet of gas (air, nitrogen, etc.) blows the
molten droplets toward the substrate at speeds of 30 to
150 m/s.
Limits and Applicability
Coating thicknesses can range from a few
hundredths of a mm to almost unlimited thickness,
depending on the end use. Electric arc spraying can
be used for simple metallic coatings, such as copper
and zinc, and for some ferrous alloys. The coatings
have high porosity and low bond strength.
4-1
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Examples of Waste Minimization/Pollution Prevention Techniques
Specific Applications
Industrial applications include coating paper,
plastics, and other heat sensitive materials for the
production of electromagnetic shielding devices and
mold making.
4.1.5 Plasma Spraying
A flow of gas (usually based on argon) is intro-
duced between a water-cooled copper anode and a
tungsten cathode. A direct current arc passes through
the body of the gun and the cathode. As the gas
passes through the arc, it is ionized and forms plasma.
The plasma (at temperatures exceeding 30,000°C)
heats the powder coating to a molten state and com-
pressed gas propels the material to the workpiece at
very high speeds that may exceed 550 m/s.
Limits and Applicability
Plasma spraying can be used to achieve thick-
nesses from 0.3 to 6 mm, depending on the coating
and the substrate materials. Sprayed materials include
aluminum, zinc, copper alloys, tin, molybdenum,
some steels, and numerous ceramic materials. With
proper process controls, this technique can produce
coatings with a wide range of selected physical
properties, such as coatings with porosities ranging
from essentially zero to high porosity.
Specific Applications
This techniques can be used to deposit molyb-
denum and chromium on piston rings, cobalt alloys on
jet-engine combustion chambers, tungsten carbide on
blades of electric knives, and wear coatings for
computer parts.
4.2 Physical Vapor Deposition
Technologies
4.2.1 Ion Plating/Plasma Based
Plasma-based plating is the most common form of
ion plating. The substrate is in proximity to a plasma
and ions are accelerated from the plasma by a negative
bias on the substrate. The accelerated ions and high-
energy neutrals from charge exchange processes in the
plasma arrive at the surface with a spectrum of ener-
gies. In addition, the surface is exposed to chemically
"activated" species from the plasma and adsorption of
gaseous species form the plasma environment.
Limits and Applicability/Current Development
This technique produces coatings that typically
range from 0.008 to 0.025 mm. Advantages include
a wide variety of processes as sources of the
depositing material; in-situ cleaning of the substrate
prior to film deposition; excellent surface covering
ability; good adhesion; flexibility in tailoring film
properties such as morphology, density, and residual
film stress; and equipment requirements and costs
equivalent to sputter deposition. Disadvantages in-
clude many processing parameters must be controlled;
contamination may be released and "activated in the
plasma; and bombarding gas species may be incor-
porated in the substrate and coating
Current Uses/Specific Applications
Coating materials include alloys of titanium,
aluminum, copper, gold, and palladium. Plasma-
based ion plating is used in the production of x-ray
tubes; space applications; threads for piping used in
chemical environments; aircraft engine turbine blades;
tool steel drill bits; gear teeth; high tolerance injection
molds; aluminum vacuum sealing flanges; decorative
coatings; corrosion protection in nuclear reactors;
metallizing of semi-conductors, ferrites, glass, and
ceramics; and body implants. In addition, it is widely
used for applying corrosion resistant aluminum
coatings as an alternative to cadmium.
Capital costs are high for this technology, creating
the biggest barrier for ion plating use. It is used
where high value-added equipment is being coated
such as expensive injection molds instead of
inexpensive drill bits.
4.2.2 Ion Plating/Ion Beam Enhanced
Deposition (IBED)
During IBED, both the deposition and bombard-
ment occur in a vacuum. The bombarding species are
either ions from an ion gun or other sources. While
ions are bombarding the substrate, neutral species of
the coating material are delivered to the substrate via
a physical vapor deposition technique such as evapora-
tion or sputtering. Since the secondary ion beam is
independently controllable, the energy particles in the
beam can be varied over a wide range and chosen
with a very narrow window. This allows the energies
of deposition to be varied to enhance coating
properties such as interfacia.1 adhesion, density,
morphology, and internal stresses. The ions form
nucleation sites for the neutral species resulting in
islands of coating which grow together to form the
coating.
Limits and Applinabilitv/Current Development
Advantages include increased adhesion; increased
coating density; decreased coating porosity and preva-
lence of pinholes; and increased control of internal
stress, morphology, density, and composition. Disad-
vantages include high equipment and processing costs;
limited coating thicknesses; part geometry and size are
limited; and gas precursors used for some implantation
species are toxic. This technique can produce a
4-2
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Examples of Waste Minimization/Pollution Prevention Techniques
chromium deposit 10 microns thick with greater thick-
nesses attained by layering. Such thicknesses are too
thin for most hard chrome requirements (25 to 75
microns with some dimensional restoration work
requiring 750 microns) and layering would signifi-
cantly add to the cost of the process. IBED provides
some surface cleaning when surface is initially
illuminated with a flux of high energy inert gas ions;
however, the process will still require precleaning
(e.g., degreasing).
Current Uses/Specific Applications
Although still an emerging technology, IBED is
used for depositing dense optically transparent coatings
for specialized optical applications, such as infrared
optics.
Costs
Capital costs are high for this technology, creating
the biggest barrier for ion plating use. Equipment for
IBED processing could be improved by the develop-
ment of low-cost, high-current, large-area reactive ion
beam sources.
4.2.3 Ion Implantation
Ion implantation does not produce a discrete
coating; the process alters the elemental chemical
composition of the surface of the substrate by forming
an alloy with energetic ions (10-200 keV in energy).
A beam of charged ions of the desired element (gas)
is formed by feeding the gas into the ion source where
electrons, emitted from a hot filament, ionize the gas
and form a plasma. The ions are focused into a beam
using an electrically biased extraction electrode. If the
energy is high enough, the ions will go into the
surface, not onto the surface, changing the surface
composition. Three variations have been developed
that differ in methods of plasma formation and ion
acceleration: beamline implantation, direct ion
implantation, and plasma source implantation. Pre-
treatment (degreasing, rinse, ultrasonic cleaner) is
required to remove any surface contaminants prior to
implantation. Process is performed at room tempera-
ture, and time depends on the temperature resistance
of the workpiece, and the required dose.
Limits and Applicability/Current Development
Ion implantation can be used for any element that
can be vaporized and ionized in a vacuum chamber.
Since material is added to the surface, rather than onto
the surface, there is no significant dimensional change
or problems with adhesion. The process is easily
controlled, offers high reliability and reproducibility,
requires no post-treatment, and generates minimal
waste. If exposed to high temperatures, however,
implanted ions may diffuse away from the surface due
to limited depth of penetration and penetration does
not always withstand severe abrasive wear. Implanta-
tion is used to alter surface properties, such as hard-
ness, friction, wear resistance, conductance, optical
properties, corrosion resistance, and catalysis.
Commercial availability is limited by general unfamil-
iarity with the technology, scarcity of equipment, lack
of quality control and assurance, and competition with
other surface modification techniques. Areas of
research includes ion implantation of ceramic materials
for high temperature internal combustion engines,
glass to reduce infrared radiation transmission and
reduce corrosion, as well as automotive parts (piston
rings, cylinder liners) to reduce wear.
Current Uses/Specific Applications
Nitrogen is commonly implanted to increase the
wear resistance of metals since ion beams are
produced easily. In addition, metallic elements, such
as titanium, yttrium, chromium, and nickel, may be
implanted into a variety of materials to produce a
wider range of surface modifications. Implantation is
primarily used as an antiwear treatment for compo-
nents of high value such as biomedical devices
(prostheses), tools (molds, dies, punches, cutting
tools, inserts), and gears and ball bearings used in the
aerospace industry. Other industrial applications
include the semiconductor industry for depositing
gold, ceramics, and other materials into plastic,
ceramic, and silicon and gallium arsenide substrates.
The U.S. Navy has demonstrated that chromium ion
implantation could increase the life of ball bearings for
jet engines with a benefit to cost ratio of 20:1.
However, the Navy has not equipped its jets with ion-
implanted bearings. The U.S. Army is investigating
the possibility of ion-implanted helicopter components
and other applications as a substitute for chromium
electrodeposits. A treated forming die resulted in the
production of nearly 5,000 automobile parts compared
to the normal 2,000 part life from a similar tool hard
faced with tank plated chromium.
Costs
The initial capital cost is relatively high, although
large-scale systems have proven cost effective. An
analysis of six systems manufactured by three com-
panies found that coating costs range form $0.04 to
$0.28 per square centimeter. Depending on through-
put, capital costs ranges from $400,000 to
$1,400,000, and operating costs were estimated to
range from $125,000 to $250,000.
4.2.4 Sputtering and Sputter Deposition
Sputtering is an etching process for altering the
physical properties of the surface. The substrate is
4-3
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Examples of Waste Minimization/Pollution Prevention Techniques
eroded by the bombardment of energetic particles,
exposing the underlying layers of the material. The
incident particles dislodge atoms from the surface or
near-surface region of the solid by momentum transfer
form the fast, incident particle to the surface atoms.
The substrate is contained in a vacuum and placed
directly in the path of the neutral atoms. The neutral
species collides with gas atoms, causing the material
to strike the substrate from different directions with a
variety of energies. As atoms adhere to the substrate,
a film is formed. The deposits are thin, ranging from
0.00005 to 0.01 mm. The most commonly applied
materials are chromium, titanium, aluminum, copper,
molybdenum, tungsten, gold, silver, and tantalum.
Three techniques for generating the plasma needed for
sputtering are available: diode plasmas, RF diodes,
magnetron enhanced sputtering.
Limits and Applicability/Current Development
This technique is a versatile process for depositing
coatings of metals, alloys, compounds, and dielectrics
on surfaces. The process has been applied in
industrial hard and protective coatings. Primarily
TiN, as well as other nitrides and carbides, has
demonstrated high hardness, low porosity, good
chemical inertness, good conductivity, and attractive
appearance.
Sputtering is capable of producing dense films,
often with near bulk quantities. Areas requiring future
research and development include better methods for
in-situ process control; methods for removing
deposited TiN and other hard, ceramic-like coatings
from poorly coated or worn components without
damage to the product; and improved understanding of
the factors the affect film properties.
Current Uses/Specific Applications
Sputter-deposited films are routinely used simply
as decorative coatings on watchbands, eyeglasses, and
jewelry. The electronics industry relies heavily on
sputtered coatings and films (e.g., thin film wiring on
chips and recording heads, magnetic and
magneto-optic recording media). Other current
applications for the electronics industry are
wear-resistant surfaces, corrosion resistant layers,
diffusion barriers, and adhesion layers. Sputtered
coatings are also used to produce reflective films on
large pieces of architectural glass, and for the coating
of decorative films on plastic in the automotive
industry. The food packaging industry uses sputtering
for coating thin plastic films for packaging pretzels,
potato chips, and other products.
Compared to other deposition processes, sputter
deposition is relatively inexpensive.
4.2.5 Laser Surface Allo ying
The industrial use of lasers for surface modifi-
cations is increasingly widespread. Surface alloying
is one of many kinds of alteration processes achieved
through the use of lasers. It is similar to surface
melting but it promotes alloying by injecting another
material into the melt pool, so that the new material
alloys into the melt layer.
Laser cladding is one of several surface alloying
techniques performed by lasers. The overall goal is to
selectively coat a defined area. In laser cladding, a
thin layer of metal (or powder metal) is bonded with
a base metal by a combination of heat and pressure.
Specifically, ceramic or metal powder is fed into a
carbon dioxide laser beam above a surface, melts in
the beam, and transfers heat to the surface. The beam
welds the material directly into the surface region,
providing a strong metallurgical bond. Powder
feeding is performed by using a carrier gas in a
manner similar to that used for thermal spray systems.
Large areas are covered by moving the substrate under
the beam and overlapping disposition tracks. Shafts
and other circular objects are coated by rotating the
beam. Depending on the powder and substrate
metallurgy, the microstructure of the surface layer can
be controlled, using the interaction time and laser
parameters.
Pretreatment is not as vital to successful perfor-
mance of laser cladding processes as it is for other
physical deposition methods. The surface may require
roughening prior to deposition. Grinding and polishing
are generally required post-treatments.
Limits and Applicability/Current Development
This technique can be used to apply most of the
same materials that can be applied via thermal spray
techniques; the powders used for both methods are
generally the same. Materials that are easily oxidized,
however, will prove difficult to deposit without
recourse to inert gas streams and envelopes.
Deposition rates depend on laser power, powder
feed rates, and traverse speed. The rates are typically
in the region of 2x10-4 cm3 for a 500 watt beam.
Thicknesses of several hundred microns can be laid
down on each pass of the laser beam allowing
thicknesses of several millimeters to accumulate. If
the powder density is too high, this thermal cycling
causes cracking and delamination of earlier layers,
severely limiting the attainable build-up.
The Advanced Research Products Agency at
Northwestern University has found that easily oxidized
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Examples of Waste Minimization/Pollution Prevention Techniques
materials, such as aluminum, cannot be laser clad
because the brittle oxide causes cracking and
delamination. Some steels may be difficult to coat
effectively. The small size of the laser's beam limits
the size of the workpieces that can be treated cost
effectively. Shapes are restricted to those that prevent
line-of-sight access to the region to be coated.
Current Uses/Specific Applications
Although laser processing technologies have been
in existence for many years, industrial applications are
relatively limited.
Uses of laser cladding include to change the
surface composition to produce a required structure
for better wear, high temperature performance; build
up a worn part; provide better corrosion resistance;
impact better mechanical properties; and enhance the
appearance of metal parts.
Costs
The high capital investment required for using
laser cladding has been a barrier for its widespread
adoption by industry.
4.3 Chemical Vapor Deposition
4.3.1 Process Description
Substrate pretreatment is important in vapor
deposition processes particularly in the case of CVD.
Pretreatment of the surface involves minimizing con-
tamination by mechanical and chemical means before
mounting the substrate in the deposition reactor.
Substrates must be cleaned just prior to deposition and
the deposition reactor chamber itself must be clean,
leak-tight, and free from dust and moisture. During
coating, surface cleanliness is maintained to prevent
particulates from accumulating in the deposit.
Cleaning is usually performed using ultrasonic
cleaning and/or vapor degreasing. Vapor honing may
follow to improve adhesion. Mild acids or gases are
used to remove oxide layers formed during heat-up.
Post treatment may include a heat treatment to
facilitate diffusion of the coating material into the
material.
Limits and Applicability
CVD is used mainly for purposes of corrosion
resistance and wear resistance. CVD processes are
also usually applied in cases where specific properties
of materials of interest are difficult to obtain by other
means. CVD is unique because it controls the micro-
structure and/or chemistry of the deposited material.
The microstructure of CVD deposits depends on
chemical makeup and energy of atoms, ions, or
molecular fragments impinging on the substrate;
chemical composition and surface properties of the
substrate; substrate temperature; and presence or
absence of a substrate bias voltage.
The most useful CVD coatings are nickel,
tungsten, chromium, and titanium carbide. Titanium
carbide is used for coating punching and embossing
tools to impart wear resistance.
Current Uses/Specific Applications
CVD processes are used to deposit coatings and
to form foils, powders, composite materials,
free-standing bodies, spherical particles, filaments,
and whiskers. CVD applications are expanding both
in number and sophistication. The U.S. market in
1998 for CVD applications was $1.2 billion, 77.6
percent of which was for electronics and other large
users, including structural applications, optical,
optoelectronics, photovoltaic, and chemical. Analysts
anticipate that future growth for CVD technologies
will continue to be in the area of electronics. CVD
will also continue to be an important method for
solving difficult materials problems.
CVD processes are commercial realities for only
a few materials and applications.
Costs
Start-up costs are typically very expensive.
4.4 Drag-Out Reduction Techniques
4.4.1 Plating Solution Control
Plating solutions can be controlled to minimize
drag-out by:
• Reducing bath viscosity can decrease drag-out
between baths. One of the most common methods
is to operate the plating process at the lowest con-
centration possible. Another common method is to
operate at the highest temperature possible.
• Adding wetting agents to reduce surface tension
and minimized drag-out.
• Preventing the build-up of contaminants in process
tanks improves performance. Contaminants such
as carbonate must be removed in order to minimize
drag-out. One method is to monitor carbonate
accumulation in cyanide baths and keep levels as
low as possible.
• Keeping solution covered to reduce contamination.
• Use high purity electrode to reduce impurities from
falling out and contaminating the solution.
Impacts
Plating solution control has the following impacts:
• Lower viscosity reduces the volume of drag-out
generated, and lowers the mass of constituents hi
the drag-out.
4-5
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Examples of Waste Minimization/Pollution Prevention Techniques
• Drag-out volume can be reduced up to 50 percent.
• Reduction of plating bath viscosities reduces drag-
out.
4.4.2 Positioning Parts on Rack
Properly positioning the parts on the rack is
important both for quality as well as drag-out
reduction considerations. The best position is
typically determined by experimentation. Common
practices include: parts should not be racked over one
another; they should be positioned to consolidate the
runoff streams and oriented so that the lowest profile
emerges from the fluid as the rack is removed.
Impacts
Properly positioning the parts on the rack reduces
drag-out and maintains quality.
4.4.3 Withdrawal Rates and Drainage
One of the most critical factors is the speed with
which the part is withdrawn from the bath. Three
techniques are:
• Maximizing drip time
• Using drip shields or boards to capture and return
drag-out as a rack or barrel is transported away
from the process; using drip tanks to collect drag-
out
• Utilizing air knives to enhance drainage
Impacts
Withdrawal rates and drainage can:
• Reduce drag-out volume, but loses time.
However, lost time is made up because less time is
needed for drainage over the tank
• Maximum drag-out volume is directly returned to
tank
• Capture additional drag-out for return to plating
tank
• Enhance drainage but may have ventilation prob-
lems as well as accelerated oxidation and passiva-
tion. Parts may dry completely in spots causing
staining.
4.4.4 Rinsing Over Process Tanks
Fog or spray rinsing over the process tank where
heated processes provide enough evaporative
headroom to accept additional fluid. Automatic or
manual sprayers are effective. Fog rinsing is used
when limited evaporative headroom is available.
Impacts
This techniques reduces drag-out volume. It can
cause complications with ventilation systems by possi-
bly increasing the airborne pollutant load. Positioning
of the spray nozzles is critical.
4.4.5 Drag-Out Tank
A drag-out tank is a rinse tank that is initially
filled with water but is stagnant and drag-out accumu-
lates in the tank. The contents of the tank are used to
replenish drag-out and evaporative losses occurring in
the process tank. Water is added to the drag-out tank
to maintain the operating level.
Impacts
Effective when used after heated process tanks
that can tolerate the return of diluted process chemis-
try. Little benefit if evaporative headroom is not
created in the process tank.
4.4.6 Drag-In Drag-Out tank
Positioning a drag-in drag-out rinse before and
after the plating tank ensures that drag-out is returned
to the process at the same rate at v/hich it is removed.
Impacts
More effective in low-temperature processes than
drag-out rinsing alone. Requires an extra processing
step, and build up of contaminants is accelerated.
4.5 Rinse Water Reduction Techniques
4.5.7 Tank Design
Tanks should be sized to allow for the rinsing of
the largest parts, and all tanks (rinse and process)
should be the same size. Inlet and outlet points should
be at opposite sides of the tank and the flow into the
tank should be distributed. Agitation may be achieved
through air spaying or other methods.
Impacts
Optimum rinse tank design removes drag-out from
the parts quickly, and rapidly disperses the drag-out in
the rinse water. Allows for shorter dwell times and
lower the concentration of contaminants that may
remain on the part surface after rinsing. Spray rinsing
may be preferred for flat parts.
4.5.2 Flow Controls
Flow through the rinse tanks should be closely
monitored and/or controlled. Install flow restrictors
to regulate flow. Install conductivity controller to
regulate flow based on rinse water conductivity.
When the conductivity reaches a set point, the valve is
opened and water flows through the tank. When the
conductivity falls below the set point, the valve is shut
off. Timer release controls typically consist of a
button, when pressed, opens the valve for a pre-
determined length of time. After the time has
expired, the valve is automatically shut. The timer
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Examples of Waste Minimization/Pollution Prevention Techniques
may require manual activation by the operator or may
be activated by the action of racks and hoists.
Impacts
Some sort of flow control will reduce waste.
Rinse tanks with manual valves are impossible to
control. Flow restrictors maintain constant flow
regardless of pressure and are available to control
rates from <0.5 to 40 liters per minute. Flow
controls are most effective when used in processes
requiring continuous rinse flow. Intermittent rinsing
operations are best controlled with timer rinse
controllers. Conductive controllers are more
sophisticated, but require additional parameters must
be considered: daily/seasonal conductivity
fluctuations; non-ionic contaminants and suspended
solids are not sensed; and instruments require
maintenance, calibration, and replacement probes.
When timer controls are used in conjunction with flow
restrictors, flow can be completely controlled.
4.5.3 Rinsing Configuration
A simple overflow rinse is very inefficient. Insert
a drag-out rinse or counterflowing rinse series
between the overflow rinse and the process. A
counterflowing rinse series consists of a series of tanks
were fresh water enters the tank furthest from the
process tank and overflows into the next tank closer to
the process tank, in the opposite direction of the work
flow. As work runs through a counterflowing series,
the first tank becomes more concentrated than the
next. The flow rate is calibrated to achieve the
desired concentration in the last, or cleanest tank.
Impacts
Rinsing configurations can reduce the amount of
water required for rinsing. The flow in a two-stage
counterflowing rinse can be calculated by multiplying
the drag-out by the square root of the rinsing ratio.
Thus, if 2,500 liters are required to dilute a liter of
drag-out in an overflowing rinse, only 50 liters are
required in a two-stage counterflowing rinse.
Cascade rinsing will eliminate the water usage in
the rinse system that uses the recycled water. Addi-
tional benefits may be realized from the specific con-
tamination present. For example, rinses after alkaline
cleaners are more efficient if they are acidic, thus,
acidic rinse water is cascaded to alkaline cleaner
rinses.
Spray rinsing generally uses one-fourth the water
of an overflow rinse, but is limited to flat parts. An
effective configuration is a combination drag-out spray
rinse where the parts are lowered below the fluid level
in the tank, then sprayed over the tank as they exit
Determining the optimum combination depends on
the evaporation rate of the process tank, the drag-out
rate, the desired rinse water quality, various cost
factors, and available floor space.
4.6 Summary of Advanced
Maintenance Technologies
4.6.1 Microfiltration
The feed stream entering a microfiltration unit is
typically filtered by conventional methods (e.g., car-
tridge filter) to remove large particulates. Various
holding tank designs are then employed to trap or
skim off floating oils and to allow heavier solids to
settle. The fluid is then pumped into the membrane
compartment of the unit where remaining oils and
grease are rejected by the membrane while water,
solvent and other cleaning bath constituents pass
through. The fluid flows parallel to the membrane
with enough velocity to sweep the reject off the
surface.
Ceramic membranes are available in various pore
sizes ranging from several hundred angstroms to over
0.2 microns. The appropriate pore size is determined
by the specific cleaner to be filtered. The capacity of
a unit is based on the total area and flux rate of the
membrane. Flux rates range from 17 to more than 40
liters per m2 per day, depending largely on pore size.
Commercially available units range in capacity from
less than 1,000 to more than 5,000 liters per day.
Applications and Restrictions
Not all cleaners are good candidates and a shop
may be forced to change bath chemistry in order to
employ microfiltration. High silicate cleaners are
known to plug membranes. Dissolved metal ions,
such as aluminum or copper, are not removed by
microfiltration membranes. Cleaners that accumulate
metal ions are generally not appropriate microfiltration
applications because the bath life remains limited by
rising metal concentration.
Capital costs range from $15,000 to $20,000 for
a 1,000 liter per day unit to $25,000 to $30,000 for a
5,000 liter per day unit. Sizing is based on the bath
volume and contaminant loading of the bath. A 1,000
liter per day unit will maintain a cleaning bath that
processes approximately 1,000 m2 of oil coated parts.
Operating costs consist of electricity, membrane and
other parts replacement, and labor. Membrane life is
at least several and perhaps more than 10 years.
Little data exists quantifying other costs, but they are
generally expected to be low. For most applications,
reduced chemistry usage and lower waste production
lead to cost savings that more than offset operating
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Examples of Waste Minimization/Pollution Prevention Techniques
costs and payback periods of 1 year to 2 years may be
expected.
4.6.2 Ion Exchange
These units are constructed similarly to those
described for recovery applications and consist of a
resin column and a pump which circulates the process
fluid. A selective cation resin is employed for
chromic acid applications. The resin has an affinity
for all cations, including Cr+3. Cr+3 is dislodged from
resin sites, however, by several other common tramp
metal species. If enough fluid is pumped through the
resin, most of the Cr+3 that was initially bound to the
resin will be dislodged and returned to the process
bath along with Cr+6 (which behaves as an anion and
is not attracted by the resin), leaving the resin loaded
with tramp metals. This specific selectivity of certain
resins permit the application of ion exchange to tri-
valent chromium plating baths as well.
A typical system would include 0.03 to 0.2 m3 of
resin contained in one or two columns. Multi-column
configurations are not usually necessary because
continuous service is not required. Flow rates of 3 to
10 liters per minute through the resin column are
typical. Most units are semi-automatic and regenera-
tion is initiated by the operator. The regeneration
station may be elsewhere in the shop to preserve space
near the plating tank, and the column is brought to the
station by forklift or hand truck. Regeneration timing
is usually calculated based on estimates of bath con-
tamination and is considerably less important than for
recovery applications of ion exchange because when
fully loaded the ion exchange resin will have no effect
on the process fluid and all constituents are simply
returned to the bath. For hexavalent chromic acid
plating baths, sulfuric acid is the most common regen-
erant. The regenerant volume is 150 liters or more
per 0.1 m3 of resin (combined sulfuric acid and rinse
water).
Applications and Restrictions
The typical resin capacity is approximately 2,000
grams per 0.1 m3. Units are sized to require
relatively infrequent regenerations but also to maintain
the process bath at low concentrations of tramp metals
(usually less than 3 grams/liter of combined metals).
Ion exchange does not re-oxidize trivalent
chrome. Conventional methods of oxidation, such as
dummy plating, will be necessary if tri-valent
chromium accumulation occurs. There is also some
chrome loss with this technology. Even when run to
exhaustion, a small proportion of chromium to tramp
metals still remains and is discharged from the process
during regeneration.
Capital costs depend on the capacity and auto-
mation level of the system. The resin used for
chromic acid applications is quite expensive, approxi-
mately $2,000/0.1 m2. A unit with 0.1 m3 of resin
will cost approximately $50,000 with a regeneration
station. A major component of operating costs is
resin replacement. Resin life depends on the
application but is generally 1 year or less. Labor
costs vary with installation but are not usually high
when compared to other technologies in this section.
Savings are generated from reduced chromic acid
usage and waste.
4.6.3 Acid Sorption
A bed of strongly basic anion exchange resin
separates the acid from the metal ions. The acid is
taken up by the resin while the metal ions pass. The
acid is then desorbed from the resin by water. The
flow through the resin bed alternates between acid and
water. First, spent acid is pumped upward through
the bed. A metal-rich, mildly acidic solution passes
and is collected at the top of the bed. Then, water is
pumped downward through the bed and desorbs the
acid from the resin and the purified acid solution is
collected at the bottom of the bed. Approximately 80
percent of the free acid remaining in a spent acid
solution can be recovered with this technology.
Purification can be done in a batch mode, but the
advantage of having a steady metal concentration is
realized when employed in a continuous flow mode.
Capacity is determined by the size of the resin bed and
is usually expressed in terms of the mass of metal
removed from the acid solution. Equipment capacities
range from 100 grams/hour to several thousand
grams/hour. Units are sized to remove metal near or
above the rate at which metal is being introduced.
Typically, a target level of metal concentration is
determined and the unit is sized to maintain that level.
Applications and Restrictions
Many acid solutions common in plating shops are
potential applications of acid sorption. Filtration is
usually necessary while cooling is required for hot
solutions and those containing oxidizers, which can
generate heat as they enter the resin bed. The by-
product, or the metal-rich solution which passes the
resin bed, is sent to treatment. Some by-product solu-
tions are suitable for electrowinning. In addition to
anodizing and pickling baths, ion transfer can be
applied to non-chromic acid copper and brass etch and
bright dips, nitric acid strippers, aluminum bright dips
and cation ion exchange regenerant. Chromates, very
concentrated acids, and some hydrochloric acid
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Examples of Waste Minimization/Pollution Prevention Techniques
processes are generally not good candidates for this
technology.
Costs
Capital costs range from $30,000 to $40,000 for
capacities under 200 grams/hour up to over $100,000
for capacities in the range of 1 kilogram per hour.
Larger units are also manufactured. Little data are
available on operating costs but they consist of labor,
electricity, parts, and resin replacement.
4.6.4 Ion Transfer
Ion transfer unit consists of one or several
membrane compartments which separate the cathode
from the anode of an electrolytic cell. The membrane
is usually a porous ceramic pot and the cathode is
contained within the pot while the anode surrounds it.
Alternately, the membrane may be constructed of
polyfluorocarbon material and the catholyte compart-
ment is re-enforced with polyethylene. The anode is
in direct contact with the process fluid, while the
cathode is separated from the process fluid by the
membrane.
Small in-tank units often use the process rectifier
and operate only while parts are being plated. These
units must be removed when the rectifier is switched
off because the membrane will leak cations back into
the process tank. When current is flowing through the
cell, cations in the process fluid are driven through the
pores in the membrane and precipitate in the cathode
compartment, plate onto the cathode, or remain in
solution in the catholyte. The catholyte is initially
made up as chromic acid, and usually taken directly
from the bath. The efficiency of the cell gradually
falls as Cr+6 is reduced to Cr+3 in the catholyte and
tramp metals rise in concentration. The catholyte is
replaced at regular intervals, usually ranging from
several hours to several days, depending on the
concentration of cations in the bath and the volume of
the catholyte. Automated units will replenish the
catholyte with fresh fluid at regular intervals. Catho-
lyte volume usually ranges from only 5 to 10 liters or
less in a single cell unit to 50 or more liters in a large,
multi-cell unit. The anodic oxidation of Cr+3 to Cr+6
has the effect of lowering the overall Cr"1"3 concen-
tration in the bath.
Cation removal rates are determined by the
membrane area, the amperage applied to the cell, and
the concentration of cations in the process fluid.
Small units remove on the order of 10 to 50 grams of
cations per day, whereas a multi-cell unit can remove
up to 1,000 grams or more per day. Generally,
removal rates fall sharply as the concentration of
cations in the process fluid falls below 3 grams per
liter. Cr+3 oxidation rates are determined by the
anode area and the amperage applied to the cell and
also range from a few to several hundred grams per
day. Units are sized to remove cations at a rate near
or somewhat faster than the introduction rate.
Applications and Restrictions
Because of the relatively low cation removal rates,
this technology is best suited to maintaining relatively
clean baths rather than attempting to clean highly
contaminated ones. Tramp metal concentrations of 4
grams per liter can be achieved with this technology.
Achieving lower concentrations, if possible at all, will
result in higher energy costs and an increase in the
volume of waste catholyte produced. The waste
catholyte contains some chromium which is lost during
catholyte changes.
Aluminum and other cation removal from chromic
acid etch or anodizing solutions has been accomplished
with this technology, though applications other than
chrome plating baths are relatively rare. In etch solu-
tions, the introduction rate is quite high and a multi-
celled external unit is required.
Costs
In-tank ceramic pot styles that operate off of the
tank rectifier can be purchased for $1,000 or less.
External units with 400 grams per day removal capa-
city cost $30,000 or more depending on automation
and instrumentation. Operating costs consist of elec-
tricity, labor, and membrane or pot replacement.
Membrane life is several years. Ceramic pot life is
also several years, but the pots can be broken during
cleaning and handling. Labor associated with cleaning
can be considerable. Manual systems require frequent
catholyte changes and cleaning of the pot is usually
performed during these changes. Sludge build-up in
the catholyte creates the need for frequent clean outs
that can require considerable effort. Savings result
from extended bath life which reduces chemistry usage
and waste production.
4.7 Chemical Recovery Technologies
4.7.7 Atmospheric Evaporation
Most atmospheric evaporators use a forced air
system. These units consist of a heater to pre-heat the
fluid being evaporated (in most cases, this is the
process or evaporation tank's heating system), a pump
to transfer the fluid to the evaporation chamber, a
blower that provides a source of non-saturated air to
the evaporation chamber, and the chamber itself,
which consists of fins or a packing surface to increase
the surface area of the air-fluid interface. Evaporation
rates are dependant on the size of the chamber, the
solution temperature, and the temperature and
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Examples of Waste Minimization/Pollution Prevention Techniques
humidity of the air blown across the chamber. The
solution being evaporated must be heated to a
minimum of 29°C, below which evaporation rates are
inefficient. Commercial units with evaporation rates
from 40 to 340 liters per hour are available with most
units designed for less than 150 liters per hour.
Construction usually consists of polyethylene but
specialty evaporators are made from materials specific
to the application. For example, high temperature
PVDF units can operate on fluids heated up to 82°C.
Applications and Restrictions
Atmospheric evaporators are found on a wide
variety of processes, including nickel plating, chrome
plating, and acid zinc plating. They are commonly
applied to a heated process bath to increase its evapo-
ration rate to make headroom for the direct return of
an associated recovery rinse system. The rinse system
is usually a multi-stage counter-flowing rinse that
flows directly into the bath. Its flow rate is adjusted
to equal the surface evaporation of the bath plus the
evaporation rate achieved by the evaporator. For
lower temperature process baths, the rinse water
exiting the counterflowing series is directed to an
offline tank where it is heated and circulated through
the evaporator. Most of the flow is evaporated, and
the concentrated fluid in the off-line tank is returned
to the process bath at a rate equal to its evaporation
and drag-out rate. Ambient temperature baths require
a similar configuration, but some process fluid must
be circulated to the off-line tank and evaporator to
create headroom in the process tank.
Process fluids that degrade with heat are not
appropriate for atmospheric evaporation. Most
efficient are fluids, such as nickel plating baths, which
are already heated to approximately 49°C to 65°C,
making the energy requirements small. A disad-
vantage of evaporation-based recovery is that all drag-
out, including unwanted components are returned and
accumulate in the process tank. De-ionized water is
necessary as rinse water to prevent the introduction of
new contaminants. Also, solutions degraded by aera-
tion, such as cyanide or tin plating baths, are not
candidates for atmospheric evaporation.
Costs
Capital costs vary depending on several factors,
including the unit's processing capacity. A Typical
atmospheric evaporator that can process 40 to 75 liters
per hour costs less than $10,000. Installation costs
can be significant because plumbing and duct
modifications may be necessary. Operating costs
(i.e., electricity and labor) average $0.25 to $0.35 per
gallon ($0.07 to $0.09 per liter).
4.7.2 Vacuum Evaporators
Vacuum evaporators take advantage of the boiling
point depression of water as air pressure decreases.
In practice, pre-heated fluid is pumped into the
vacuum chamber where it quickly vaporizes. Because
of the boiling point depression at low pressures, high
evaporation rates can be.achieved at temperatures
considerably lower than those required for atmospheric
evaporators. The vapor can be discharged to the
atmosphere or distilled and re-used. Types of vacuum
evaporators include thin film, flash, and mechanical
vapor recompression. Thin film evaporators operate
by distributing an extremely thin film of fluid across
the heat exchanger surface. Rising film, falling film
and wiped film evaporators are variations of this basic
type and offer different advantages for specific
applications. With flash evaporators, appropriate for
concentrated or calcium-rich streams, the liquor
flashes as it enters the vacuum chamber, causing
crystallization and creating a slurry. Other designs
which limit or eliminate the need for steam or other
heat source include a heat-pump type, which employs
a refrigerant and compressor to provide and reuse heat
for evaporation, and mechanical vapor recompression,
which captures and re-uses the heat released during
condensation. Mechanical vapor recompression
evaporators are the most expensive but most efficient
type.
Applications and Restrictions
Vacuum evaporators are typically used in applica-
tions where atmospheric evaporators are not practical.
Operating energy expenses favor the selection of
vacuum evaporators when rates of 190 to 265 liters
per hour or more are required. Vacuum evaporators
require less heating and aeration, making them the
choice for fluids that are technically incompatible with
atmospheric evaporators. Vacuum evaporators
provide a major advantage when they are configured
to re-use the condensate as rinse water and return the
concentration to the process bath in a closed-loop.
A typical configuration is a multi-staged counter-
flowing rinse which discharges to the vacuum
evaporator. The condensate, which is 90 to 95
percent of the feed flow, is returned to the last stage
of the counterflowing series, and the loss is made up
with a small de-ionized water stream. The condensate
is returned to the bath. This arrangement assumes a
moderately heated bath that has an evaporative loss
equal to 5 to 10 percent of the rinse flow. If the bath
has no appreciable evaporative loss, a small volume of
the bath must be passed through the evaporator along
with the rinse flow to create some headroom for
return.
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Examples of Waste Minimization/Pollution Prevention Techniques
Neither type of evaporator is able to compete with
ion exchange or reverse osmosis for recovery of large
flow volumes of dilute rinse water.
Costs
The capital costs for vacuum evaporators ranges
from $125,000 to $175,000 (for units processing 760
liters per hour). Operating costs are lower than those
for atmospheric evaporators averaging $0.05 to $0.12
per gallons ($0.01 to $0.03 per liter). Repair costs
for vacuum evaporators are reportedly higher than
those for atmospheric evaporators.
4.7.3 Ion Exchange
Ion exchange refers to chemical reactions that
occur at exchange sites on the surface of an ion
exchange resin. Cation resins exchange hydrogen ions
for cations in the stream; anion resins exchange
hydroxyl ions for other anions. The reaction is
reversible and the resin is regenerated by passing an
acid through the cation column or a base through the
anion column, which strips the captured ions and
returns the resins to their initial states. The ions
removed from the rinse stream are concentrated in the
spent regenerants. Several selective cation resins,
often referred to as metal scavenging or metal polish-
ing resins, have been developed that preferentially
exchange for only multi-valent cations, such as
copper, nickel, or lead, and do not exchange for
common monovalent cations such as potassium and
sodium.
The basic unit of ion exchange equipment is the
vessel, or column, which contains the ion exchange
resin. Rinse water is pumped through the column
where it contacts and reacts with the resin. The
equipment may consist of a single column or several
columns in series depending on the flow rate and type
of resin. Columns range in size from 28 to over 300
liters of resin capacity. Typically, a minimum of 30
liters of resin is required for every 7 to 10 liters per
minute of flow. The capacity of ion exchange resin is
expressed in terms of ion equivalent (i.e., molecular
weight divided by valence) per liter of resin.
Complete deionization of the wastestream requires
at least two columns, one cation and one anion. If the
operation cannot be suspended during regeneration,
two like columns (i.e., two cation and two anion
columns) are necessary to alternate the columns.
Some manufacturers recommend three like columns
since, in practice, columns begin leading ions before
the resin's theoretical capacity has been reached.
With two columns always on-line, leakage is captured
by the second column and the first can remain in
service until maximum capacity is reached.
Fully automatic units initiate regeneration based
on accumulated flow volume, or more sophisticated
methods such as metal ion detection, redirect the flow
to a fresh column, and begin regeneration on the spent
column. Semi-automatic units require operator-initia-
tion of regeneration. Manual systems require pre-mix-
ing of regenerant, manual valving, and fluid transport.
Applications and Restrictions
Ion exchange is applied in two basic configura-
tions. De-ionizing installations completely remove all
cations and anions from a relatively dilute rinse stream
and recycle the de-ionized water back to the rinsing
process. Generally, the total dissolved solids concen-
tration of such streams must be below 500 mg/1, to
maintain an efficient regeneration frequency. Since all
of the process dragout is present in the regenerants,
some processes will tolerate the direct return of the
regenerant and a closed loop is set up. Usually,
however, the regenerant is too dilute or incompatible
with the process chemistry and it cannot be re-used.
Recovery in these cases is performed by electro-
winning. Aggressive conventional means of drag-out
recovery including drag-out tanks and countercurrent
rinsing are usually required or desirable to enhance the
efficiency of the recovery process.
Metal scavenging installations recover only the
metal portion of the drag-out. This arrangement is
efficient if the metal ions being scavenged are the only
regulated ions in the stream. In these cases, the
stream can be discharged without further treatment.
Scavenging can also be efficient in terms of resin
capacity. The metal content of the stream may only
be a small fraction of the total dissolved solids present
in the stream, making scavenging suitable over a
wider range of TDS. Scavenging also provides a very
metal-rich regenerant, particularly suitable for
electrowinning. Water recycling is not possible since
only a portion of the cations and none of the anions
are removed. Effluent metal concentrations of under
0.5 mg/1 are typically achieved with standard
installations. Scavenging resin systems can also be
used to polish discharge from a conventional waste
treatment system that is unable to remain consistently
in compliance. The offending ion or ions are
selectively captured by the resin but the non-regulated,
concentrated salts used for pH neutralization pass
through. The regenerant may be sent to an
electrowinner to recover metal, or returned back
upstream to the conventional waste treatment system.
Either configuration may be employed on a mixed
stream from two or more processes or installed as an
end-of-pipe treatment for an entire plating room.
With such arrangements, no direct return of the drag-
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Examples of Waste Minimization/Pollution Prevention Techniques
out is possible and the regenerant will contain two or
more different metal ions. Recovery is again
performed by electrowinning. Filtration and pre-
treatment of the feed stream may be necessary. Many
resins are sensitive to organic molecules and carbon
filtration is often required prior to ion exchange.
Deciding which configuration is most advan-
tageous in a particular shop depends upon the nature
of the processes present, the possibility of returning
the regenerant to the process tank, the cost of water,
cost of the equipment and (often more importantly)
installation, and the need to limit discharge volume.
Mixed streams require careful characterization;
estimates of flow volumes and concentrations become
more difficult to make as the number of sources
increase. Many streams are not efficiently mixed.
Streams containing lead or gold, for example, are not
usually mixed with streams containing metal ions such
as copper or nickel due to different regeneration
methods or chemistries.
Many processes are excellent candidates for ion
exchange. Successful applications Include the rinse
water from plating processes of copper, cadmium,
gold, lead, nickel, tin, tin-lead, and zinc. Gold-
bearing resins are frequently incinerated and the gold
content recovered. Lead is also difficult to recover
from ion exchange resins; only methane sulfonic acid
(very expensive) and flouboric acid (usually not
suitable for electrowinning) are effective regenerants,
and these resins may be replaced when exhausted
rather than ever regenerated. Cyanide bath rinse
waters can be ion exchanged; cation resins are capable
of breaking the metal-cyanide complex and the cyanide
is removed in the anion column. The cation
regenerant can be electrowinned, and the cyanide
present in the anion regenerant can be returned to the
process or destroyed conventionally.
Costs
Capital costs depend on the volume of flow being
serviced and the level of automation required. A third
capital cost factor, frequently overlooked, are the
installation costs, which may be considerable in
certain applications. Small, manual units, applied to
flows of 20 liters per minute or less, may be
purchased and installed for less than $15,000. A fully
automatic, 75 liter per minute unit, with an integrated
electrowinner, will cost approximately $75,000 with
installation.
Operation and maintenance costs are generally
low. A major expense is resin replacement which can
be quite expensive. Resin should, however, be
expected to last for 3 years or more. Resin costs
range from $7 to over $22 per liter. Labor costs are
dependant on the level of automation included with the
unit and can range from over $1 per 1,000 liters for
manual or undersized installations to less than $0.25
per thousand liters for fully automatic systems.
Upstream components, such as sand, polypropylene
and carbon filters also contribute to operational costs.
4.7.4 Electro winning
An electrowinning unit consists of a main vessel
or tank, which houses a number of electrodes, a recti-
fier to provide a direct current source, and the pumps
and plumbing necessary to transport the fluid being
treated to and from its source. Fluid is pumped from
a reservoir or drag-out tank to the main tank where it
flows through or around the charged electrodes and
then is caused, usually by gravity, to return to the
reservoir. While in the main tank, positively charged
metal ions are attracted to and reduced to metal form
on the negatively charged cathode. Most anodic reac-
tions are of little interest with the exception of cyanide
oxidation to cyanate, which is an important benefit of
electrowinning cyanide-bearing drag-out or spent
process fluids.
A variety of cathode designs are available, the
choice of which depends mostly on the concentration
of metal in the electrolyte and the preferred form of
recovered metal. The three most common are flat
sheet, wire mesh, and reticulated designs. Flat plate
cathodes are used with high metal concentrations.
Below 1,000 mg/1 of metal ions, they present poor
plating efficiency due to their low surface area. For
high metal concentrations, they are usually the design
of choice because the plated metal can be easily
removed by mechanical means (scraping or peeling)
and the cathodes can be reused. Wire mesh cathodes
offer a greater surface area than flat plate cathodes of
the same dimensions and can be used with lower metal
concentrations than flat plate types. However, metal
deposited onto the wire mesh must be chemically
stripped. Typically, the wire mesh cathodes are used
as anode material in an applicable plating tank. The
reticulate cathodes offer the greatest surface area per
square meter of material. They are used mostly for
low to moderate concentrations of metal and can be
effective below 10 mg/1 of metal ions. The reticulate
cathodes are not reusable and are typically sent
directly to scrap dealers.
Anodes are usually wire-mesh, and constructed of
various metals, typically stainless steel or titanium.
Some manufactures offer low-cost graphite anodes.
For oxidizing electrolytes (e.g., persulfates, nitric
acid-based solutions, or fluoborates), platinum-coated
titanium along with other, proprietary rare-earth oxide
coatings are available. While cathodes are generally
4-12
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Examples of Waste Minimization/Pollution Prevention Techniques
inexpensive, anodes can represent a significant
percentage of the unit's entire purchase price.
Cathodes and anodes are closely spaced, usually
less than one inch apart. Both sides of each cathode
directly faces an anode, thus units will have one more
anode than cathode. During operation, the concentra-
tion of metal ions can be depleted in the vicinity of the
cathodes. This effect is countered by designs that
include a high fluid flow past the electrodes and a
means of agitation, such as air sparging.
The capacity of an electrowinning unit can be
expressed in terms of cathode area, maximum rectifier
output (in amperes), or metal recovery rate (such as
pounds of metal plated per day) and all these
quantities are inter-related. Since electrowinning is
operated in a window of optimum current density
(expressed in amps per square foot of cathode area),
the size of the rectifier must be matched to the number
and size of the cathodes. Manufacturers design units
with enough cathode area so that the window of
optimum current density is not exceeded when the
rectifier operates at or near maximum output.
Commercially available units range from 0.2 m2 or
less of cathode area to well over 10 m2 and rectifiers
range from less than 100 amperes maximum output to
over 2,000 amperes. The recovery rate is largely
dependant on the concentration of metal ions in the
electrolyte being electrowinned. The theoretical
maximum plating rate is governed by Faraday's law
and ranges from 1.19 grams/amp-hour for copper to
7.35 grams/amp-hour for gold. Units equipped with
reticulated cathodes and operating on electrolytes
containing several grams/liter of metal ion
concentration may approach the theoretical maximum
plating rate. At concentrations below 100 mg/1, the
plating rate will fall dramatically to below 10 percent
of the theoretical maximum in most cases.
Applications and Restrictions
The unit must be sized to have a metal removal
rate equal or greater than that of the metal
introduction rate into the drag-out tank. The
electrowinning unit will cause the metal concentration
of the drag-out tank to average much lower than
before; rising briefly immediately after a drag-out
event, then falling gradually until additional parts are
rinsed. The resulting low average metal concentration
leads to a considerably lower mass of metal entering
and being discharged from the flowing rinses.
Typically, a drag-out tank may be maintained below
100 mg/1 of metal concentration.
The application of electrowinning to a drag-out
tank usually precludes the direct return of the drag-out
to the process tank due not only to the metal depletion
but also to possible chemistry-altering anodic
reactions. Also, other (non-metal) constituents build
in concentration and may eventually force disposal of
the fluid.
In many cases, ion exchange regenerant from a
cation resin column is suitable for electrowinning. It
may contain several grams per liter of mixed heavy
metals that are readily plated. A batch spent regen-
erant is pumped to a reservoir near the electrowinner
and circulated through the unit until the desired con-
centration is reached. In some cases, electrowinning
is allowed to proceed until the metal concentration
reaches compliance levels and the electrolyte is dis-
charged. This is possible only when the metal ions
being plated out of the solution are the only regulated
ions present. Furthermore, the plating rate will drop
dramatically as the concentration of metal ions falls
below 100 mg/1. It may take much longer for the
electrolyte to drop from 100 mg/1 to 1 mg/1 than from
10 g/1 to 1 g/1. Usually, the desired concentration is
near 100 mg/I and when reached, the fluid is sent to
conventional treatment or adjusted and re-used as fresh
regenerant.
Strongly oxidizing substances such as nitric acid
or flouboric acid are generally not good candidates for
electrowinning due primarily to the very short life of
the anodes in such environments. Hydrochloric acid
or other compounds containing the chloride ion may
present the problem of chlorine gas evolution at the
anodes.
Costs
In general, the capital costs of electrowinning
equipment are low. A unit equipped with a 100
ampere rectifier and 0.2 m2 of cathode area may carry
a purchase price of between $8,000 and $15,000,
depending largely on the type of anodes and cathodes.
Such a unit may remove up to 500 grams of metal per
day from a drag-out tank.
Significant operating cost components are electric-
ity, electrode replacement and operating and mainte-
nance labor. Electricity costs per unit mass of metal
recovered varies with the concentration of metal In the
electrolyte. Low concentration of metal ions leads to
lower efficiency to higher costs for electricity. Flat
plate steel cathodes are re-used after being scraped
free of metal deposits and are therefore rarely
replaced. Wire mesh and reticulate cathodes usually
are rated to hold more than 1 kilogram of metal and
generally cost less than $100/m2. Anodes vary widely
in cost, from $600/m2 to more than $3,000/m2 for
platinum coated-titanium types. Anodes require
replacement every 1 to 5 years depending on the
nature of the electrolytes being electrowinned. Labor
4-13
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Examples of Waste Minimization/Pollution Prevention Techniques
costs are low. Besides daily checks for electrical
settings and overall operation, many installations
require little scheduled attention.
4.7.5 Electrodialysis
The feed stream entering an electrodialysis unit is
split into two streams, a concentrate and a diluate.
This is accomplished by a stack of selective mem-
branes, across which is applied a direct current. The
membranes in the stack are alternately cation- and
anion-specific. Between the membranes in the stack
are compartments, which alternately consist of concen-
trate or diluate. The feed stream is pumped into the
diluate compartments. Cations in one diluate compart-
ment traverse one cation-specific membrane in the
direction of the cathode but are trapped in that
compartment by the next membrane which is anion-
specific. Anions from the neighboring diluate com-
partment traverse the anion membrane hi the direction
of the anode, joining the cations, and are likewise
trapped by the next cation-specific membrane. In this
way, the diluate is further diluted of ions, and in each
concentrate compartment, both anions and cations are
trapped. The concentrate is perhaps 10 times more
concentrated than the feed stream, but is usually not as
concentrated as the process bath.
Capacity is determined by the stack size, or mem-
brane area, and the rectifier. The unit must be sized
to capture the drag-out from the diluate to the
concentrate at the rate at which it is being introduced
into the rinse water. Under-sized units will result in
a greater residual concentration remaining in the
diluate, which is usually discharged for conventional
treatment. Most units are custom-sized for each
application and range from less than 1 m2 to well over
10 m2 of membrane area.
Applications and Restrictions
For electrodialysis to offer any advantage over
competing technologies, the process fluid must tolerate
the direct return of the concentrate. Since the concen-
trate is usually less concentrated than the bath itself,
only heated fluids with some evaporative headroom
are candidates. Manufacturers have described
applications recovering the drag-out from Watts
nickel, copper cyanide, cadmium cyanide and zinc
phosphate.
If the feed stream is from a drag-out rinse, the
diluate may be re-used and pumped back to the drag-
out tank. In this configuration, the technology com-
petes with electrowinning. Although more expensive,
unlike electrowinning, the dragout recovered is
returned to the process tank and process chemistry
does not rapidly accumulate in the drag-out tank.
Costs
Capital costs are related to membrane surface area
or to feed flow volume and characterization. Most
units are customized to a particular application. In
general, the technology is more expensive than other
recovery technologies. Units range from $75,000 for
20 ft2 of membrane area to several hundred thousand
for units of 150 ft2. For Watts nickel, a 20 ft2 unit
would be expected to have a capacity of 0.5 to 1 gal-
lon of drag-out recovery per hour. Little information
is available on operational and maiintenance costs, but
they are known to consist of membrane replacement,
electricity and labor.
4.7.6 Reverse Osmosis
The basic component of reverse osmosis equip-
ment is the membrane, which may be tubular, hollow
fiber, or spiral wound. The feed stream is pumped
continuously into the membrane-containing vessel
where it flows parallel to the membrane surface,
unlike conventional filtration, where the filtering
substance is positioned as a barrier to the flow.
Under pressures of up to 1,000 pig, relatively pure
water is forced through the membrane, while dissolved
solids are chemically repulsed. Suspended solids are
larger than the membrane's pore size and cannot
cross. The membrane rejection rate, or the portion of
the feed stream's dissolved solids unable to cross the
membrane, is less than 99 percent of multi-valent ions
and 90 to 94 percent of mono-valent ions such as
sodium or chloride. Because a portion of the mono-
valent ions in the feed stream manage to cross the
membrane, the permeate is of lower purity than the
effluent of common ion exchange equipment in terms
of conductivity. Metal and other ions of regulatory
interest have very high rejection rates.
The concentrate stream from standard reverse
osmosis equipment is usually no higher than 20 g/1
TDS. Higher concentrations can be achieved by
adding "stages," or additional membrane vessels. The
concentrate from stage one is sent to stage two and so
on. Concentrates approaching process bath concentra-
tions are possible with multi-stage units.
The flow volume handled by a unit is dependent
on several inter-related factors. Generally, capacity is
increased by increasing the surface area of the
membrane. If the feed flow is increased without a
corresponding increase in membrane surface area, the
volume of permeate and the concentration of the con-
centrate drops. Operation at higher pressures will
increase the permeate volume. Capacity is therefore
determined by the membrane surface area, operating
pressure, and the requirements of the application.
4-14
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Examples of Waste Minimization/Pollution Prevention Techniques
Reverse osmosis equipment does not require the
automation of other technologies due to the facts that
it runs essentially in one mode at all times and
electricity is not involved in the fluid separation.
Units may include instrumentation that indicate the
condition of the membrane by measuring the flux, or
permeate flow per unit area of membrane. If the
membrane fouls or clogs, the flux rate will drop and
membrane replacement will be necessary. Pressure
and other flow gauges are common.
Pre-filtration and pre-treatment of the feed stream
may be necessary in some applications to lengthen
membrane life or reduce the frequency of fouling.
Filtration to remove suspended solids is usually
necessary. pH adjustment may prevent precipitation
from occurring as the feed stream is concentrated, but
it may make the concentrate unfit for return to the
plating bath.
Applications and Restrictions
Reverse osmosis is commonly applied to nickel
plating processes. The feed stream is typically a
series of counter-flowing rinses. The permeate is
returned to the rinses and the concentrate is returned
to the nickel bath. Fluid balances must be maintained.
The permeate will be 2 to 10 percent less volume than
the feed stream and a steady supply of city water must
enter the counterflowing rinses to balance this loss.
The concentrate flow entering the nickel plating bath
replaces evaporative loss, but the two are precisely
balanced. A storage tank for concentrate may be
necessary, or, if the loss is greater than the
concentrate flow, other means of replenishment may
be required. For heated baths with considerable
evaporation, the concentration of the concentrate can
be significantly below that of the bath. If the
concentrate is replacing drag-out from a ambient bath,
it must be near the same concentration as the bath.
Considerable engineering and customization is
required for each application.
Other successful applications described by equip-
ment manufacturers include zinc, cadmium and copper
cyanides and non-cyanide zinc. For some
applications, no attempt to return the concentrate to
the process bath is made and recovery, if any, is done
by another technology such as electrowinning.
Mixed stream and end-of-pipe after precipitation
configurations also exist. Mixed-stream applications,
not unlike those employing ion exchange, require
alternate recovery technologies, usually
electrowinning. End-of-pipe installations provide the
benefit of recycling water that is otherwise discharged
due to high concentrations of salts used for pH
neutralization. The concentrate is discharged (some
care must be taken to ensure that the concentrate
remains below compliance levels where concentration-
based discharge limit exist; concentrations 20 times
that of the feed stream are typical) and the diluate is
distributed to various rinsing operations.
Costs
Since flux rates vary from application to appli-
cation and customization and special engineering can
be necessary, cost estimates based simply on flow or
flux volume are very rough. Reverse osmosis units
start at $50,000 to $75,000 for flow rates of 75 liters
per minute or less to over $300,000 for flows of 800
liters per minute. Operating cost components are
labor, energy and membrane replacement.
4-15
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5.0 TOOLS FOR EVALUATING
POLLUTION PREVENTION OPPORTUNITIES
5.1 Cost Analysis
Industry has been slow to invest in pollution
prevention projects in part because traditional invest-
ment review tools do not account for the true cost and
environmental savings from pollution prevention. For
most businesses, including the metal plating industry,
gauging economic performance has been the underpin-
ning of the investment review process. Unfortunately,
traditional economic analyses have minimized or
ignored the economic benefits of pollution prevention
investments by either incorporating too few cost areas
in the analysis of by examining costs over a too short
period of time. Pollution prevention investments must
be able to stand up to every other funding request to
effectively compete for funding.
The following sections discuss how to expand
upon traditional economic analysis to identify all costs
associated with a particular operation or process at a
facility. The approach is designed to allow managers
to incrementally expand their traditional economic
analysis framework, adding new cost elements to their
existing modeling, as appropriate, given available
resources. This approach gives flexibility to the eco-
nomic analysis process and allows each analysis to be
tailored in scope and detail to reflect both available
data and specific investment review needs. Further-
more, basic cost data already embedded in existing
facility-level models can be used to minimize the
effort needed to secure required data.
The following sections first discuss how to
expand upon traditional investment analysis procedures
to more accurately reflect the true economic costs and
benefits of investing in pollution prevention. Next,
step-by-step instructions and a cost analysis worksheet
are provided using these new concepts. Together, this
discussion will provide the framework necessary to
begin using economic analysis principles to evaluate
the investment viability of pollution prevention pro-
jects.
5.1.1 Traditional Accounting/Budgeting
Approaches
Economic analysis involves tabulating the
financial costs and benefits that a project is expected
to generate. These estimates provide the data neces-
sary to evaluate the economic advantages of competing
projects.
The easiest and most common economic evalua-
tion is one that compares the up-front purchase price
of competing investment alternatives. However,
experience has shown that the up-front purchase price
is a poor measure of a project's total cost. Costs such
as those associated with maintainability, reliability,
disposal/salvage value, and training/education must
also be weighted in the financial decision-making
process. Not surprisingly, methods to improve econ-
omic justification for pollution prevention investments
involve addressing these shortcomings.
5. 1.2 Ways To Improve Cost Analysis
Expanding Cost Inventories
For pollution prevention investments to compete
fairly with pollution control and other investments, all
potential costs and savings must be considered. In
addition to including direct costs, a cost inventory
should also include indirect costs, liability costs, and
less tangible benefits. Exhibit 5-1 lists many of the
categories that can be used to accurately determine the
financial costs associated with a particular investment
opportunity.
The challenge for any manager seeking to use
an expanded cost inventory for investment analysis is
that all of the costs associated with a particular piece
of equipment or process may be difficult to identify.
Quantifying these costs may be a challenge because
they may be grouped with other cost items in existing
overhead accounts. For example waste disposal costs
of current processes are often placed into a facility
overhead account, whereas an expanded cost inventory
would require these costs to be directly allocated to
the product or process that produces them.
Consequently, it is not expected that information for
all the cost categories will be easily identified.
Environmental managers should use this list of
categories to help incrementally expand their existing
financial analyses whenever possible.
Expanding Time Horizons
In addition to a more comprehensive cost inven-
tory, a second concept that is helpful in uncovering
the true economic benefits of pollution prevention
investments is a longer time horizon, usually five or
more years. This is because many of the costs and
savings from pollution prevention take years to
materialize, or because the savings occur each and
every year for an extended period of time. For
example, some pollution prevention investments may
result in a significantly decreased liability risk in the
future. Others may result in recurrent savings as a
result of less wastes needing to be managed and
disposed of every year. Conventional proj ect analysis,
5-1
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Tools for Evaluating Pollution Prevention Opportunities
Exhibit 5-1. Cost Categories
Direct Costs
• Capital expenditures
- buildings
- equipment
- utility connections
- equipment installation
- project engineering
• Operational and maintenance expenses
- raw materials
- labor
- waste disposal
- utilities: energy, water, sewerage §
Liability Costs
• Penalties and fines
• Personal injury and property damage
Indirect Costs
• Compliance costs
- permitting
- reporting
- monitoring
- manifesting
- record keeping
- insurance
- on-site waste management
- operation of on-site pollution control
equipment .
Less Tangible Benefits ______
• Increased revenue from enhanced product
quality
• Enhanced community and product image
• Avoided future regulatory costs
• Reduced health maintenance and absenteeism
costs from improved employee health
• Increased productivity from improved
employee relations _____
however, often confines costs and savings to a three to
five year time period. Using this traditional time
frame in project evaluation will lose track of many
costs and benefits that pollution prevention options are
designed to produce.
Managers of metal plating facilities hi the
developing world seeking to justify investments hi pol-
lution prevention on the basis of costs face challenges
due to the comparatively low current costs associated
with hazardous waste disposal and regulatory com-
pliance. In these cases, expanding the time horizon
for the investment analysis may allow managers to
realistically project increased cost savings that will
occur as a result of future regulatory and waste
disposal infrastructure improvements.
Definitions and Terms
Over the last few years, researchers and
managers working to promote pollution prevention
have been developing ways to evaluate investments
that account for the economic benefits of pollution
prevention. Various systems and models have been
developed, and numerous terms are currently used to
define these systems. These systems and models all
involve expanding traditional investment evaluation
methods to address the issues stated above. For the
sake of clarity, the following section provides a short
description of the three most common approaches.
These definitions were developed by the United States
Environmental Protection Agency (USEPA).
Managers may be familiar with these approaches, yet
call them by a different name.
The U.S. Postal Service is currently piloting the
use of TCA to justify pollution prevention project
at the facility level. The pilot study involves
using a computerized spreadsheet to help track
costs and measure performance.
Total Cost Assessment. Total Cost Assessment
(TCA) refers to the long-term, comprehensive analysis
of the full range of costs and savings of an investment
that are or would be experienced directly by the
organizations making or contemplating the investment.
Activity-Based Costing. Activity-Based Costing
(ABC) is a process in which all environmental costs
incurred by an organization, both direct and indirect,
are allocated to the products or processes which gener-
ate them. Many of these costs are traditionally allo-
cated to facility or corporate overhead accounts. By
applying them directly to processes or products,
managers can gain a more accurate picture of the true
costs associated with manufacturing operations.
Life Cycle Costing. Life Cycle Costing (LCC) is a
method in which all costs are identified with a
product, process, or activity throughout its lifetime,
from raw material acquisition to disposal, regardless
of whether these costs are borne by the organization
making the investment, other organizations, or society
as a whole.
Evaluating Financial Performance
While expanding cost inventories and time hori-
zons greatly enhance the ability to accurately portray
the economic consequences of a single pollution pre-
vention investment, financial performance indicators
are needed to allow comparisons to be made between
5-2
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Tools for Evaluating Pollution Prevention Opportunities
competing investment alternatives. Three financial
performance indicators are currently in widespread
use. The simplest approach is to conduct a payback
analysis estimating the amount of time it will take to
recover the funds expended on capital projects. The
other approaches, net present value and internal rate
of return, use the concept of the time value of money.
These approaches are advocated by many economists
as more accurate ways to evaluate investments, includ-
ing environmental projects. Each of these techniques
offer specific advantages and drawbacks for facility
environmental managers.
Payback Period. Payback period analysis is the
investment performance indicator used historically by
many federal agencies. The purpose of a payback
analysis is to determine the length of time it will take
before the costs of a new investment are recouped.
For example:
Payback Period _ start up costs
(in years) annual benefits - annual costs
Payback =
$800
$600 - $400
= 4 years
Those investments that recoup their costs before
a set "threshold" period of time (usually 3-5 years)
are determined to be investments worth funding.
Payback period analysis does not discount costs and
savings occurring in future years. In addition, costs
and savings are not considered if they occur in years
later than the threshold time in which an investment
must pay back its costs in order to be funded.
Many private sector companies and some govern-
ment agencies currently use NPV to analyze
financial performance of environmental
investments.
Hyde Tools Company used NPV analysis to docu-
ment over $15,000 in benefits from a pollution
prevention project that involved a rinse water
recycling project.
Tektronix Corporation used NPV calculations to
document over $90,000 in benefits' from a
process modification to its painting system that
Net Present Value. The Net Present Value (NPV)
method is based upon the concept that a dollar today
is worth more than a dollar in the future (commonly
referred to as the time value of money). Specifically,
this method discounts the value of future costs and
revenues (i.e., cash flows). These discounted cash
flows are then added together to calculate the "Net
Present Value" of the investment. This method is
particularly useful when comparing pollution preven-
tion investments against alternatives that result in
higher annual waste management and disposal costs.
The increased costs of current operations or of invest-
ment options that do not reduce wastes will tend to
lower the net present value of these options. Also,
this method easily accommodates the use of an
expanded cost inventory when calculating all costs and
benefits.
Discounted savings - discounted costs = NPV
$300,000 discounted savings
- $200,000 discounted costs
= $100,000
Internal Rate of Return. The Internal Rate of
Return (IRR) method is a method that calculates the
rate at which a stream of cash flows must be
discounted so that the present value of the cash flows
is equal to the initial investment. Organizations using
the IRR method to evaluate investment options specify
a "cutoff rate" (sometimes referred to as a "hurdle
rate"). Projects are pursued if the internal rates of
return exceed the cutoff rate and are rejected if the
internal rates of return fall below the cutoff rate.
5.1.3 Application Of Improved Cost Analysis
To The Metal Plating Operations
Investments in pollution prevention hi the metal
plating Industry can result in significant cost savings,
if the investment analysis process is sufficiently comp-
rehensive. Exhibit 5-2 identifies areas of significant
potential cost savings resulting from the use of
pollution prevention strategies identified in Chapter 3.
5.1.4 Overcoming Existing Challenges
Businesses that have begun to implement the
investment review methodologies discussed within this
chapter have encountered challenges that required the
development of Innovative solutions. The following
section highlights some of the challenges facilities
have encountered and discusses possible solutions.
Proper Allocation of Cost Categories
Compared with the traditional investment
analysis processes, expanding the analysis to include
broader cost inventories requires a more detailed data
tracking system. Currently, many organizations utilize
tracking systems that will group together many cost
categories into facility-wide overhead accounts. These
types of tracking methods make it very difficult to
identify all of the discreet costs that will be impacted
by proposed investment alternatives. Pollution
prevention activities in particular are at a disadvantage
because many of the savings that result from these
5-3
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Tools for Evaluating Pollution Prevention Opportunities
Exhibit 5-2. Cost Savings from Metal Plating Waste Minimization
Product Changes
Cost Impacts
Description
Environmentally Friendly Product Design
- reduce or eliminate coating requirements
- include drain holes in product
longer product life
reduced coating material purchases
reduced chemical purchases
reduced water use
reduced dragout/rinse water
reduced use of treatment reagents
reduced treatment sludge
lower hazardous waste management and disposal costs
lower compliance costs
Input Material Changes
Description
Reduce or Replace Chlorinated Solvents
Reduce or Replace Cyanide
Reduce or Replace Cadmium
Reduce or Replace Chromium
reduced use of treatment reagents
reduced treatment sludge
lower hazardous waste management and disposal costs
lower compliance costs
Process Changes
Description
Vacuum Deposition to replace cadmium or
chromium plating
• very high capital costs
• reduced chemical purchases
• reduced water use
• reduced drag out/rinse water
• reduced use of treatment reagents
• reduced treatment sludge
• lower hazardous waste management and disposal costs
• lower compliance costs
Thermal Spray coatings to replace hard
chromium plating
Chemical Vapor Deposition
• longer product life
• lower compliance costs
• capital and operating cost increased to control air
emissions
• reduced chemical purchases
• reduced water use
• reduced drag out/rinse water
• reduced use of treatment reagents
• reduced treatment sludge
• lower hazardous waste management and disposal costs
• lower compliance costs
• reduced potential liability
Ion Implantation
• longer product life
• reduced potential liability
5-4
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Tools for Evaluating Pollution Prevention Opportunities
Exhibit 5-2. Cost Savings from Metal Plating Waste Minimization (Continued)
Product Changes
Cost Impacts
Maintenance Methods
Conventional Maintenance Methods
- Filtration of suspended solids to remove
contaminants from the baths solutions and
reduce frequency of dumping concentrated
chemicals into baths
- Carbon treatment
- Carbonate freezing (lowering the
temperature of cyanide baths)
Advanced Maintenance Methods
- Microfiltration
- Ion Transfer (chrome baths)
- Membrane Electrolysis
- Ion Exchange (chrome baths)
- Acid Sorption (anodizing solutions)
- Process Monitoring and Control
General Waste Reduction Practices
Description
Drag Out Reduction
reduced Chemical Purchases
reduced use of treatment reagents
reduced treatment sludge
lower hazardous waste management and disposal costs
fewer product rejects
• reduced processing time
• extended bathlife
• improved product quality
• less processing time
Rinse Water Reduction
Chemical Recovery Technologies
Evaporation
Ion Exchange
Electrowinning
Electrodialysis
Reverse Osmosis
Reduced water use
Reduced rinse water
Reduced use of treatment reagents
Reduced treatment sludge
Lower hazardous waste management and disposal costs
• Reduced use of treatment reagents
Reduced chemical purchases
Reduced water use
Reduced use of treatment reagents
Reduced treatment sludge
Lower hazardous waste management and disposal costs
Lower compliance costs
investments (e.g., energy, sewage, water, permitting,
and waste disposal) often occur in areas lumped into
overhead accounts.
To overcome this, staff performing investment
analyses must first identify the exact data needs for the
project under review. Then, a comparison can be
made to information available from traditional record
keeping systems in order to identify information gaps
resulting from items being lumped together or
reported on a facility-wide basis. To eliminate the
data gaps, one of several approaches can be employed:
• For the simplest of challenges where several inven-
tory categories have been combined, a review of
the input data developed by each department in a
facility may reveal the data for the particular
project in question. For example, while the
accounting department indicates on its books only
the total quantity of copier paper used at the entire
facility, a review of department specific expenses
may reveal a more detailed account of paper use by
location.
• For categories that are aggregated for the whole
facility and not by specific project (e.g., water
usage), engineering estimates or a facility walk
5-5
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Tools for Evaluating Pollution Prevention Opportunities
through can often be used to generate an estimate
allocation to specific projects.
• For aggregated categories that cannot be easily
allocated on a project specific basis by either of the
above two methods, it may be worthwhile to
discuss the data needs both with the vendors that
supplied the original equipment to see if any base-
line consumption data exist and/or with auditing
professionals to identify what types of measurement
devices or meters could be located at the specific
project to meet the data needs.
Placing Value on Future Costs and Benefits
Estimating future costs and benefits can become
a difficult task for anyone conducting investment
analyses. Quantitatively estimating future costs for
items such as the decommissioning property clean-up
and environmental compliance can be a very difficult
task. A useful approach is to group future costs into
one of two categories; recurring costs, or contingent
costs.
Recurring costs include items that are currently
occurring and are anticipated to continue into the fore-
seeable future based upon regulatory requirements.
These include permits, monitoring costs, and compli-
ance with regulatory requirements. The first step in
estimating the future costs of these items is to deter-
mine what the facility is currently paying. Then
estimate how much the cost can reasonably be expect-
ed to escalate in the future. For example, if monitor-
ing costs are currently $100 and are expected to rise
with inflation, a conservative estimate would be a
4-percent annual increase. Consequently, the moni-
toring costs a year from now would be estimated at
S104, assuming that monitoring requirements do not
become more stringent. Note, if using the enclosed
worksheet, you do not have to escalate these values
because the worksheet already takes inflation into
account when calculating present values.
Contingent costs include those catastrophic
future liabilities such as remediation and clean-up
costs. While current activities can lead to these future
costs, quantitative estimates of these liabilities are
difficult to obtain. Quite often the only way to include
these future liabilities in the budgeting process is to
qualitatively describe estimated liabilities, without
attempting to reduce these costs to a dollar amount.
If a pollution prevention option is being considered, a
comparison highlighting the areas in which future
liability would be reduced by implementing the
pollution prevention option should be included. An
example of this approach could be used in describing
the future benefit of switching from lead-based paint
to water based paint. Most likely, the best option may
be to fully describe the potential liability if the change
is not made and, if possible, document the remediation
cost that could result if a liability event was to occur
today.
5.7.5 Getting Started
The concepts discussed above can be used to
help identify, calculate, and demonstrate the economic
benefits that result from investing in pollution
prevention. They can be used to provide a fair and
complete comparison of two or more competing
investment alternatives, or can be used to compare
proposed investments to the costs of continuing
existing operation unchanged.
As discussed earlier, managers seeking to
expand their existing economic analysis methods to
better capture the benefits of pollution prevention
should incorporate as much of the concepts discussed
in this chapter as their particular situation allows.
Managers who cannot isolate and quantify all of the
items they have identified in their expanded cost
inventory should nevertheless research and include
cost data on all of the items for which they can collect
reliable data. Similarly, the time horizon for the
analysis should be extended as far as possible, given
available data and the type of investment evaluation
method in use at their facility. Incorporating these
concepts is often an incremental process. Even small
steps toward expanding inventories and extending time
horizons can result in funding approval for pollution
prevention investments that would otherwise face
rejection.
A worksheet has been provided on the following
page to assist in better analyzing the costs and benefits
associated with environmentally-based investment
options. The worksheet incorporates the concepts dis-
cussed in this chapter: capturing more cost categories
by better allocating costs to specific activities and by
expanding the cost areas included in the analysis; and
expanding the time horizon over which competing
investments are analyzed. The worksheet also pro-
vides for the ability to calculate two measures of
financial performance, a simple payback analysis and
a net present value calculation which incorporates the
time value of money. Both of these calculations can
help in making comparisons between competing
investment options or in comparing a proposed
investment against current operations.
The following instructions are designed to assist
in completing the investment analysis worksheet.
When completing the worksheet, do not worry if data
are not available to complete all requested
information. Even by just completing a few sections
of the worksheet with data that otherwise would not
5-6
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PROJECT ANALYSIS WORKSHEET
Section
CASH OUTFLOWS
1
2
CAPITAL COSTS
Equipment
Utility Connections
Construction
Engineering
Training
Other
Subtotal Section 1
OPERATING COSTS
Materials
Labor
Utilities
Waste Mgmt.
Compliance
Liability
Other
Subtotal Section 2
ESTIMATED CASH FLOW IN EACH YEAR
Start-Up
1
2
3
4
5
6
7
8
9
10
CASH
INFLOWS
3
REVENUES
Sale of products
Sale of by-products
Sale of recyclables
Other
Subtotal Section 3
4 PAYBACK
6 CASHFLOW
6 CF X PV
7 NET PRESENT VALUE
I Years | Equals Section 1 divided by (Section 2 - Section 3) NOTE, USE THE VALUES FROM THE SHADED BOXES ABOVE
Cash flow is calculated by subtracting Cash Outtflows from Cash Inflows during each year of the investment (i e Sec 3 - Sec 2
-Sec 1)
Equals the sum of all values in Section 7
-------
Tools for Evaluating Pollution Prevention Opportunities
have been collected, the information recorded will be
useful in enhancing the accuracy in evaluating
investment opportunities. Specific instructions follow:
Begin by determining the purpose of the
analysis, the audience to whom it will be directed, the
facility's decision making criteria, and the format in
which the analysis must be presented. This
information will be critical in ensuring that the scope
of the analysis is appropriate, and that the completed
analysis will be presented in a readily understood and
accepted manner.
Sections 1-5. Identify the economic consequences
associated with the activity under review. The
specific items (i.e., cost categories) mentioned in the
worksheet may not be a complete list of costs incurred
at your facility, add new categories as appropriate. If
you are conducting a payback analysis, completing
information for only the initial year is acceptable
provided that data are available to describe annual
costs and annual savings. If you plan to analyze the
financial performance of the investment using a NPV
calculation, you need to estimate future costs and
benefits.
To allow comparisons with other investment
options or existing investment guidelines, two mea-
sures of economic performance are included in the
worksheet. To conduct a payback analysis, refer to
section 6. To conduct a net present value analysis,
refer to sections 7 through 10.
Section 6. Complete section 6 if you wish to
calculate the Payback Period of an investment. This
section calculates the amount of years it will take to
recoup the initial capital expenditure. This value is
obtained by dividing the total capital expenditures to
establish the project by the net annual benefits (e.g.,
obtained by subtracting the expected annual expenses
from the expected annual revenues). If only a
payback analysis is needed, skip the following steps.
Section 7. Complete sections 7 through 10 if you
wish to calculate an investment's Net Present Value.
For each year included in the evaluation, calculate the
annual net cash flow by subtracting the capital expen-
ditures (section 1) and annual expenses (subtotals from
sections 3,4,5) from the annual revenues (section 2).
Section 8. To calculate the NPV requires determining
the value of future cash flows today. To do this,
present value factors are used to discount future cash
flows. Typically, this percentage rate reflects the
return the company could expect to get by investing its
resources elsewhere (e.g., another project). If you do
not know the rate used by your company, we
recommend using 15 percent.
Section 9. Multiply the cash flows (section 7) by the
PV factors (section 8) to determine the present value
today of the cash flow in each year.
Section 10 (NPV). Sum all the annual discounted
cash flows to determine the Net Present Value of the
process. If the value is ipositive, the investment is
cost-beneficial. If more than one investment is being
analyzed, the investment with the greatest NPV is the
most cost-beneficial.
After completing the analysis, write a narrative
to accompany the investment analysis explaining the
results of the analysis. Be sure to include a discussion
of the economic benefits of the proposed pollution
prevention investments that were not able to be quanti-
fied, and a discussion of the non-economic benefits
that may tip the scales in favor of the pollution
prevention estimate if the economic analysis is too
close to call. This narrative is particularly important
is the economic analysis is unable to capture the
potential costs associated with future regulatory com-
pliance and waste management requirements.
5.2 Conducting a Pollution Prevention
Opportunity Assessment
The pollution prevention opportunity assessment
is one of the most important activities that a facility
will perform in the planning and implementation of a
facility pollution prevention program. The opportunity
assessment is a tool used to define the specific charac-
teristics of a single operation that create environmental
impacts (e.g., wastes, releases of toxic chemicals to
the environment, power/water usage, habitat
destruction). Specifically, the pollution prevention
opportunity assessment is a systematic evaluation of
processes and operations to:
• Characterize all aspects of the process or operation
including process flow, waste generation patterns,
material and power consumption, costs, manpower,
reliance on toxic chemicals.
• Define the impacts that the process and related
wastes have on the air, water and land.
• Associate impacts and wastes to specific unit opera-
tions.
• Assign related costs and liabilities with specific
wastes and management practices.
This detailed process information is them used
to identify, refine and plan the implementation of
pollution prevention activities that will reduce the
environmental impacts associated with the process.
Pollution prevention opportunity assessments
will be performed after the baselining activity. An
opportunity assessment can be performed anytime after
5-8
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Tools for Evaluating Pollution Prevention Opportunities
Common Pollution Prevention Opportunities
When conducting an opportunity assessment,
it is important to consider all types of
activities. While it may be easier to focus on
source reduction technologies, the pollution
prevention team may end up ignoring inex-
pensive and easy fixes that can result in
significant reductions. Changes in policy and
modifications to outdated procedures often
reduce waste generation as well as
equipment purchase or process changes.
Furthermore, training and awareness may
also yield significant reductions. Training an
equipment operator to properly operate a
machine or increasing worker awareness
about a particular procedure may eliminate an
environmental or cost concern. All of the
following types of activities may provide the
means to reduce an environmental impact:
• Policy changes
• Procedural changes
• Equipment modifications
• Material substitution
• Training
• Efficiency improvements
• Waste stream segregation
• Housekeeping practices
• Inventory control
• Reuse of materials
A pollution prevention opportunity
assessment should consider any of these
the baseline is developed to augment baseline data.
Hence, opportunity assessments can be performed as
part of the planning process or any time after the
planning process. In general, detailed, process-
specific opportunity assessments are typically
performed after completion of the facility pollution
prevention program plan so that environmental staff
can develop priorities in conducting opportunity
assessments for all candidate operations. That is,
complete the facility-plan before diving into the
detailed pollution prevention opportunity assessments.
The steps involved in conducting an opportunity
assessment are:
• Select operations of interest based on facility goals
and objectives and existing data.
• Conduct a preliminary review of the operation
using existing data to prepare for the site visit.
• Conduct a site visit of the operation to identify pol-
lution prevention opportunities, and identify imple-
mentation issues.
• Define pollution prevention options.
• Perform a feasibility analysis.
The most common problem arises from staff
who don't understand why you're asking all of these
questions. You need their help, so solicit their
participation by:
• Explaining what you are doing and why
• Asking for their input
• Building consensus
• Being considerate of their other duties
Keys to Success in Conducting Opportunity
Assessments
* Solicit the assistance and input of staff who
operate the process. They are the experts.
* Build consensus among these staff on the
best pollution prevention options for their
processes.
* Explain why this process is important to all
staff involved.
* Don't rule out any options until the team has
had time to actually consider its merits and
potentials.
* Don't rush. If the team has to go back for
more information, do so.
* Use information sources, data systems and
technical assistance services to generate
ideas.
• Giving examples of how pollution prevention will
make their job easier.
Remember, you can't do this alone. The staff
who generate the waste will ultimately have to reduce
it. They must be involved from the very beginning.
5.3 Pollution Prevention Program Plan
Development
5.3.7 Introduction
A pollution prevention program plan is a tool
for ensuring that pollution prevention is integrated into
facility operations in a logical, cost-effective, and
timely manner. Facility managers rely on program
plans to provide a stepwise process for the identifica-
tion and implementation of source reduction opportuni-
ties. The pollution prevention program plan serves as
a map describing pollution prevention program goals,
status, activities, and results. As such, the plan
encapsulates a facility's environmental future with
respect to all environmental impacts and governing
compliance programs.
5-9
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Tools for Evaluating Pollution Prevention Opportunities
There are many different ways to prepare a
pollution prevention program. The exact approach
adopted by a specific facility will depend upon the
type of operations (e.g., manufacturing, service
sector), the organizational structure, and management
style. This discussion presents an overview of the
basic steps involved in designing a program plan.
5.3.2 Developing a Pollution Prevention
Program Plan
Establishing Goals and Objectives
A facility is most likely to develop a successful
program plan if it clearly establishes its pollution
prevention goals and objectives at the project's outset.
In most cases, facilities' pollution prevention goals are
closely linked to their overall environmental goals
such as remaining in compliance with specific
regulations. Over time, the pollution prevention goals
may become the backbone of the environmental
program providing a solid framework for reducing
environmental problems to a minimum, and complying
with present and future regulations. Examples of
basic pollution prevention goals are:
Environmental Issues Potentially Considered
under the Pollution Prevention Program Plan
Various environmental issues may be
addressed under your pollution prevention
program. A comprehensive, multi-media
pollution prevention program plan might
include:
• Hazardous Materials Use
• Hazardous Waste Generation
• Solid Waste Generation
• Air Emissions
• Discharges to Municipal Sewers
• Discharges to Storm Sewers
• Stormwater Runoff
• Raw Material Storage and Spills
• Land Use Planning and Management
• Energy and Water Consumption
• Mobile Air Emissions
• Affirmative Procurement
• Toxic Material Use Reduction
• Habitat and Wildlife Preservation
• Reductions in release and use of toxic and extreme-
ly hazardous chemicals
• Reductions in the unnecessary purchase of toxic
and hazardous chemicals
• Affirmative procurement practices to ensure the
purchase of recycled content materials
• Increases in the volumes of materials captured for
recycle
• Reductions in the generation of solid wastes
• Reductions in the consumption of materials, water
and power
• Minimization of direct, adverse environmental
impacts through land use activities and direct
release of chemicals to the environment.
Obtain Management Commitment
The first step in establishing a pollution
prevention program is to obtain a commitment from
upper management. When management is committed
to pollution prevention, the development (and ultimate
implementation) of the program plan should proceed
more smoothly. As with any new project, obtaining
management support for pollution prevention involves
providing managers with the information they need to
make decisions. Managers should understand the
goals of pollution prevention, the reasons for
developing a pollution prevention program and the
elements of a pollution prevention program. Most
importantly, the facility managers should understand
all of the potential benefits that they might reap in
developing and implementing a pollution prevention
program.
Once upper management agrees to developing a
pollution prevention program plan, the facility director
should sign a formal policy statement that expresses
approval for the pollution prevention program. In
addition to the policy statement, the upper
management must provide the authority for the
environmental staff to develop and implement a
pollution prevention program. They should also
pledge funds to finance the program.
Team Building
A pollution prevention program cannot succeed
without the support of all facility staff. As such, the
pollution prevention program should be developed by
facility staff who work in a team with the environ-
mental personnel who are responsible for the pollution
prevention program plan. To ensure staff acceptance
of any changes that will result from implementing the
pollution prevention plan, the facility should involve
as many people as possible during the planning
process. Plan development will require input from
many staff who understand and operate different
processes or missions at the facility. The team may
also enlist the support of staff who support the entire
facility like maintenance engineers, supply staff,
utilities staff and others. These staff will be
invaluable in defining facility-wide characteristics and
pollution prevention opportunities. Building support
for the program can be achieved by:
• Enlisting middle management support
5-10
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Tools for Evaluating Pollution Prevention Opportunities
• Establishing an oversight group
• Publicizing the program
• Creating employee incentives.
Developing a Baseline
After enlisting support, the first major activity
is the development of an environmental baseline.
Baseline development involves building a comprehen-
sive picture of the materials usage patterns and
environmental impacts associated with the facility. To
develop a complete baseline, the pollution prevention
team will integrate environmental data into a unified,
multi-media description of the facility's environmental
impacts. The baseline will define materials usage
patterns and the environmental problems that arise
from these usage patterns. To obtain this information,
the team will search through records and talk with
people involved with all of the operations. The team
may also use a survey sent to each activity at the
facility to collect the needed data. Examples of the
kind of questions to ask are:
• What volumes of chemicals are released?
• How does the purchasing and supply department
order, receive, and distribute materials for the
facility?
• What products or services are being conducted at
the facility that consume materials?
• What wastes and pollutants are being generated by
the use of the materials?
• What processes are generating these wastes and
pollutants?
• What are the volumes and characteristics of the
wastes being generated?
• How are wastes managed following their genera-
tion?
• What problems are associated with the management
or mismanagement of these wastes, and how they
are disposed of?
• What are the annual disposal costs?
• What impacts are these activities having on the
natural resources and land, not only on the
facility's property, but beyond its borders as well?
Baseline development can be a time-consuming
process especially if the quality of existing environ-
mental facility data is poor. The pollution prevention
team should begin by developing the baseline for areas
that help satisfy the facility's primary goals and
objectives. Over time, the team can complete the
baseline for other areas. As part of this process the
team will identify pollution prevention opportunities.
It should document these opportunities and incorporate
them into the facility pollution prevention plan.
5.3.3 Identify Pollution Prevention Activities
Using the baseline data, the pollution prevention
team can identify the pollution prevention activities of
greatest concern. For example, the baseline may
indicate that water usage is a critical issue for a
facility. If water is a critical issue, what activities can
be initiated to reduce usage, waste and overall cost?
For every issue documented under the baseline, the
team should identify activities that will promote
pollution prevention. In general, these activities will
include the following.
• Additional Analysis—The baseline may illustrate
that a process or environmental impact is not fully
understood. That is, more complete information or
data is needed. To fully characterize the problem,
the environmental staff will have to conduct
analyses, analytical measurements or studies.
Upon completion of these analyses, the staff will
assess pollution prevention opportunities.
• Immediate Implementation—The baseline may
illustrate applications of existing pollution preven-
tion strategies, techniques or technologies that can
be implemented immediately to reduce environ-
mental impacts. In such cases, the facility may
seek to implement pollution prevention options
immediately.
• Pollution Prevention Opportunity Assessments-
the baseline may also illustrate that processes may
be amenable to pollution prevention options. To
define the best option, the staff will want to
conduct a pollution prevention opportunity assess-
ment.
To set priorities among all of the types of activi-
ties, the team should focus on those processes which
are responsible for the environmental issues or impacts
of greatest concern and the most appropriate type of
action. Setting priorities requires weighing different
objectives, such as toxic use reduction, cost reduction,
or water use minimization. Each facility will have its
own objectives depending on its overall pollution
prevention goals and site-specific conditions.
The pollution prevention program plan will a list
of all of the pollution prevention activities identified in
this step. The facility pollution prevention plan will
act as a road map that ties all of the additional
analyses, immediate implementation and opportunity
assessment activities together. As activities are
completed or new ones identified through pollution
prevention opportunity assessments, the list of
prevention activities will change.
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Tools for Evaluating Pollution Prevention Opportunities
5.3.4 Develop Criteria and Rank Pollution
Prevention Activities
The next step is to develop priorities and rank
the pollution prevention activities. That is, develop a
list of action items to integrate pollution prevention
into the facility's activities. The order in which the
facility chooses to initiate pollution prevention
activities and projects will depend upon
facility-specific considerations and environmental
goals. These considerations will be used to rank all of
the pollution prevention activities identified previously.
The following are commonly used in ranking such
activities:
• Mission Impact—The project's potential impact on
the facility's mission (e.g, will project implemen-
tation jeopardize the mission by making it more
difficult for a shop to cany out its work).
• Environmental benefits—The project's environ-
mental benefits (e.g., air emission reduction from
the plating line, hazardous waste minimization of
metal bearing sludges).
• Environmental compliance—The project's impact
on the facility's overall environmental compliance
status.
• Ease of implementation—A measure of the ease
of implementing the project. Complex changes
that require additional effort by staff may not be as
easily accepted as simpler changes.
• Cost savings—The potential cost savings associated
with project implementation. Pollution prevention
techniques that result in improved efficiency and
cost savings are usually accepted more readily than
options that result in increased costs.
After the team has identified ranking criteria, it
should rank all pollution prevention activities identified
on a numerical scale by assigning a value that reflects
how the activity matches each criterion. The activity
which ranks highest in all criteria (i.e., the
opportunity with the highest total score) should be
considered first for implementation. Often, one
criterion is considered to be more important than the
others. In this case, a weighting factor should be
applied to the criteria that are valued more highly.
An example of a hypothetical decision matrix
for a metal finishing shop is presented in Exhibit 5-3.
The product of this activity is a list of pollution
prevention action items that the team plans to pursue
to implement the pollution prevention program. The
list may include a combination of additional analyses,
immediate implementation and opportunity assessment
activities. This list, once approved by management,
will become the implementation plan for the pollution
prevention program.
5.3.5 Conduct Management Review
Once the pollution prevention team has devel-
oped a ranked list of pollution prevention activities, it
should secure upper management and senior staff sup-
port. This is an important opportunity for upper
management to reaffirm its support for the pollution
prevention program. To do this, the team should
convene a management review committee to include
representatives from all of the organizations that will
be affected by the pollution prevention program.
Upper management should understand the relationship
between the pollution prevention program activities
and their impact on the facility mission and existing
environmental programs. The end product of all the
pollution prevention projects should be a coherent,
integrated pollution prevention program that supple-
ments other facility programs (e.g., health and safety,
environmental compliance, training and development).
Exhibit 5-3. Ranked Options for a Hypothetical Metal Plating Shop
Option
Use a less toxic degreaser
Reduce volume of
hazardous materials
stored on-site
Install counter-current
rinsing
Provide pollution
prevention training
for operators
Cost
Savings
5
4
5
4
Environmental
Benefit
5
4
4
4
Worker
Health
4
3
3
4
Effect on
Compliance
4
4
4
5
Totals
18
18
14
16
5-12
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APPENDIX A - INTERNATIONAL POLICY APPROACHES TO ENCOURAGE
AND IMPLEMENT POLLUTION PREVENTION/CLEANER PRODUCTION
A.I U.S. Policy Approaches to Pollution
Prevention
The U.S. Environmental Protection Agency
(USEPA) defines pollution prevention as any practice
that reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste streams
or otherwise released into the environment (including
fugitive emissions) prior to recycling, treatment, or
disposal and reduces hazards to public health and the
environment associated with the release of such
substances, pollutants, or contaminants. It includes
practices that result in increased efficiency in the use
of raw materials, energy, water, or other resources, or
protection of natural resources by conservation. [19]
Similarly, cleaner production is defined as
including those practices that reduce the amounts of
energy and raw materials based on natural resources
needed to produce, market, and use products. At the
same time, production, marketing, and disposal of
these products should also be such that releases of
potentially harmful contaminants to environmental
media are kept as low as practicable. [8]
It is apparent that the same basic tenets apply to
what most Organisation for Economic Cooperation and
Development (OECD) governments refer to as either
pollution prevention or cleaner production. In the past
decade, many of these countries have been applying
increased scrutiny to environmental issues in general
and to pollution prevention/cleaner production tech-
niques specifically.
The following sections examine the pollution
prevention/cleaner production policy and
programmatic options employed in the United States
and other OECD member countries as they relate to
the metal finishing industry. Section 4.2 discusses the
U.S. policy options as enacted through various federal
statutes and Presidential Executive Orders and
provides an evaluation of these policies as they relate
to the industry. Section 4.3 provides an overview of
State and local programs in the United States. Section
4.4 characterizes international pollution
prevention/cleaner production programs, including
both an overview of individual country programs and
regional policies where available. Appendix A
provides a list of pollution prevention contacts who
have further information on U.S. and OECD policy
approaches.'
Exhibit A-l provides a summary and overview of
U.S. policies and options. For a detailed description
of these policy approaches, see Appendix C.
A.2 Federal Pollution Prevention
Executive Orders
In addition to the federal statutory law in the
United States, numerous recent Executive Orders also
require or promote pollution prevention. Generally,
these Executive Orders are binding on the federal
government and affiliated entities. For the most part,
these Executive Orders are broad in scope and not
industry-specific. Therefore, these Executive Orders
are simply summarized in Exhibit A-2. These Execu-
tive Orders will affect federal facilities where Metal
Finishing is conducted, as well as other facilities.
However, Executive Order 12843 (4/21/93), which
concerns the procurement requirements and policies
for federal agencies for ozone-depleting substances,
will have a greater impact on facilities that conduct
metal finishing than on many others.
A. 2.1 Executive Order 12843
Executive Order 12843, Procurement Require-
ments and Policies for Federal Agencies for Ozone-
depleting Substances (April 21, 1993), recognizes the
importance of addressing the current depletion of the
ozone layer caused by the worldwide use of various
ozone depleting substances (ODS). This issue is
addressed in the U.S. Clean Air Act and also in the
Montreal Protocol to which the United States is a
signatory.
The Montreal Protocol calls for a phaseout of the
production and consumption of ODS and, as a signa-
tory, the United States is using Executive Order 12843
as another tool in achieving this goal. Agencies are
directed to accomplish several important objectives.
Procurement regulations and policies must be revised
to conform with the requirements of Title VI of the
Clean Air Act that address stratospheric ozone protec-
tion. Agencies are also directed to maximize their use
of alternatives to ODS by evaluating current and
future uses of ODS to identify opportunities for
recycling. Procurement specifications and practices
must be modified, whenever economically practicable,
to substitute non-ODS for those ODS that are
currently purchased and used. In addition, agencies
were directed to submit a report summarizing efforts
to implement the specific provisions of this order to
A-1
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International Policy Approaches
Exhibit A-1. Summary of U.S. Policies and Programs
Policy Approach/
Mechanism
Application to Metal Finishing
Policy Implications
Direct Regulation
Pollution Prevention Act
Resource Conservation and
Recovery Act
Clean Water Act
Clean Air Act
Emergency Planning and
Community Right-to-Know
• Sets out USEPA activities to promote
pollution prevention.
• Establishes pollution prevention grant
program.
• Establishes clearinghouse to promote
information transfer.
• Requires annual source reduction and
recycling report.
• Requires biennial Report to Congress.
• Establishes source reduction as key
component of National policy.
• Requires all hazardous waste generators
to certify that they have a program in
place to reduce the volume or quantity
and toxicity of hazardous waste that they
manage.
• Regulates several metal finishing wastes
as hazardous waste.
• Authorizes technology-based, industry-
specific national limits on amount of
regulated pollutants a facility can
discharge to water.
» Regulates 189 air toxics and requires
pollution prevention measures, including
control equipment, process changes,
substitution of materials, changes to
work practices, and operator training and
certification.
• Requires the phase-out of production and
sale of chlorofluorocarbons (CFCs) that
contribute to destruction of ozone layer.
• New sources located in non-attainment
areas must use most stringent controls
and emissions offsets.
• Requires select industries to report
environmental releases of specified toxic
chemicals (Toxic Release Inventory [TRI]).
• Applies to metal fabricating category and
other industries that conduct metal
finishing.
• Institutionalizes pollution prevention in all
programs.
• Creates incentives for States to pursue
pollution prevention.
* Initiates activity addressing federal
pollution prevention issues.
• Starts to measure progress and identify
key issues.
• Promotes broad-based pollution
prevention.
* Fosters source reduction and recycling
among all hazardous waste generators.
• Rigorous regulatory scheme applicable to
metal finishing wastes that are hazardous
wastes create strong financial and liability
incentives to pursue source reduction.
• Raises cost of treatment and disposal and
creates financial incentives for source
reduction.
• Achieves waste reduction through in-
plant controls.
• Increases cost of generating air emissions
produced by metal finishers, increasing
incentives for waste reduction.
• Restrictions on CFCs limit some
chemicals used by metal finishers.
• Offsets may be achieved through
pollution prevention.
• Reporting requirements create strong
incentives to reduce waste generation
and toxics releases.
• Release data increased industry and
public scrutiny of waste generation and
manufacturing operations.
• Used to measure waste reduction.
A-2
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International Policy Approaches
Exhibit A-1. Summary of U.S. Policies and Programs (Continued)
Policy Approach/
Mechanism
Application to Metal Finishing
Policy Implications
Executive Orders
Executive Order 12843
• Requires federal agencies to implement
Montreal Protocol.
• Requires the phase-out of such chemicals
as 1,1,1-trichloro-ethane and replacement
with less harmful substances.
Enforcement
Supplemental Environmental
Projects (SEPs)
Allows USEPA enforcement actions to
mitigate portions of fines or penalties in
exchange for respondent undertaking
pollution prevention projects.
Provides a major incentive for industries
subject to enforcement actions to
undertake pollution prevention projects.
Voluntary Programs
USEPA 33/50
Waste Reduction Evaluations
at Federal Sites
Design for the Environment
Source Reduction Review
Project
Pollution Prevention Grants
Technology/Policy Transfer
• Promotes ambitious targeted reduction of
17 key toxics by participants, including
members of metal fabricating industry
and others conducting metal finishing.
• DoD/USEPA initiative to evaluate
pollution prevention at federal facilities
and to promote technology transfer using
reports, project summaries, conferences,
and workshops.
• Promotes voluntary consideration of
waste in and risk in to process and
product design stage.
• Integrates source reduction
considerations across USEPA program
offices through specific rulemakings.
• Provides of EPA grants to States and
funds joint federal agency projects.
• Promotes development and dissemination
of technical and non-technical pollution
prevention information.
• Promotes activity and commitment at
level closest to the manufacturing
process.
• Creates waste reduction culture within
federal facilities.
• Provides access to key pollution
prevention information.
» Creates interest in waste and risk
reduction. USEPA initiated metal
finishing projects to develop energy,
environment, and manufacturing
assessment methodology.
• Increases use of media-specific regulatory
programs to promote source reduction
where possible.
• Promotes pollution prevention activity at
State and federal level, including waste
reduction in metal finishing industries.
• Promotes availability and benefits of
waste reduction. Provides network of
resources to used for specific projects.
the Office of Management and Budget by October 23,
1993. A more detailed discussion of the Montreal
Protocol is presented in Section 4.4.2.
A 2.2 Implication and Evaluation of Policy
Executive Order 12843 has impacted and will
continue to affect the metals plating industry. The
most prominent effect has been the requirement to
phase out solvents used for metal cleaning, such as
1,1,1-trichloroethane. These requirements have forced
U.S. metal plating operations to identify replacements,
which include aqueous and semi-aqueous degreasers.
A.3 State and Local Programs
A. 3.1 Introduction
Over the past 7 years, the number of State and
local pollution prevention programs has grown
tremendously. In USEPA's 1986 report to Congress,
the agency identified 19 states as having some form of
program for providing technical assistance or infor-
mation to companies attempting to minimize hazardous
waste. Now, in 1995, almost every state has some
form of limited program or support for pollution
prevention.
A-3
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International Policy Approaches
Exhibit A-2. Summary of Executive Orders Addressing Pollution Prevention
Executive Order
Summary of Major Provisions
EO 12759(4-17-91)
Federal energy management
EO 12780(10-31-91)
Federal agency recycling and the Council
on Federal Recycling and Procurement
Policy
EO 12843 (4-21-93)
Procurement requirements and policies for
federal agencies for ozone-depleting
substances
EO 12856(8-3-93)
Federal compliance with right-to-know
laws and pollution prevention
requirements
EO 12902 (3-9-94)
Energy efficiency and water conservation
at federal facilities
Encourages Federal agency energy management, including use
of alternative, less-polluting fuel, reduced petroleum product
use, and employee outreach.
Directs federal agencies to promote cost-effective waste
reduction and recycling activities. Requires all federal agencies
to develop an affirmative procurement program to purchase
products with recycled content. Creates the Council on Federal
Recycling and Procurement Policy, which encourages Federal
agencies to purchase products that reduce waste generation,
assists in the development of ..waste reduction and recycling
programs, and collects and disseminates information on waste
reduction methodologies, costs and savings, and recycled
content products prices.
Directs all federal agencies to maximize their use of alternatives
to ozone-depleting substances, evaluate present and future
needs for ozone-depleting substances, develop recycling
initiatives to reduce and prevent ozone-layer degradation, and
modify procurement specifications and practices to require non-
ozone depleting substances for ozone-depleting substances.
Requires toxic chemical and hazardous substance reporting.
Procurement process revisions to reflect source reduction
principles and on-site innovative pollution prevention
technologies testing for market development.
Requires federal agencies to develop and implement programs
to reduce energy consumption and increase energy efficiency at
their facilities and buildings using prioritization studies, facility
audits, and energy efficient, water conserving, and renewable
energy technologies, including solar power and petroleum
product alternatives.
A wide variety of approaches to pollution preven-
tion has been adopted by State and local programs
reflecting differences in industrial profiles, environ-
mental releases, business cycles, and the political
climate. Pollution prevention has gained support
relatively quickly because it is seen as a unique
philosophy enabling States to pursue both economic
development and environmental quality objectives-
objectives that are more commonly seen as irreconcil-
able. Public pressure combined with the activities of
both national and locally based environmental groups
have helped move pollution prevention legislation
through State legislatures.
As a gross generalization, State/local programs
can be classified Into regulatory programs and non-
regulatory programs. Under a regulatory approach,
State legislation gives environmental agencies the
authority to require industry to comply with require-
ments such as mandatory facility planning. In addi-
tion, environmental agencies may integrate pollution
prevention into traditional regulatory activities, such as
inspections, permit writing, and enforcement actions.
Under a non-regulatory approach, States establish a
voluntary program for encouraging industry to reduce
environmental releases to all media. Many non-
regulatory States still maintain a pollution prevention
staff in their regulatory agencies to run a technical
assistance program and/or to incorporate pollution
prevention concepts into existing media-specific
programs.
A.3.2 Overview of State and Local
Approaches to Pollution Prevention
As of 1994, 24 States have legislation or regu-
lation promoting or mandating pollution prevention
facility planning, and more are considering (or have
considered) such legislation. Only 16 of the 24 States,
however, require companies to develop plans. In
A-4
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International Policy Approaches
The Massachusetts Blackstone project is the best
known pilot multi-media inspection. The project
focused on electroplating and metal-finishing
facilities in the area served by the Upper
Blackstone Publicly Owned Treatment Works. A
team would inspect the entire facility for
violations affecting all media. If violations were
found, Department of Environmental Protection
(DEP) inspectors would take the appropriate level
of enforcement and, within the context of the
enforcement action, recommend that the facility
seek source reduction technical assistance from
the non-regulatory Office of Technical Assistance
(OTA). OTA developed an active technical
assistance program for companies in coordination
with DEP's inspections, including regular
meetings with an Advisory Board of local
electroplaters and metal finishers, on-site assess-
ments, and workshops. Interestingly, 97 percent
of the firms receiving notices of noncompliance
made use of the OTA program.
addition, most States do not have enforcement
provisions to assure implementation of the plans.
Although there are significant differences in planning
requirements, the plans share certain elements. States
have begun taking action in the following regulatory
areas: facility planning, multi-media inspections,
enforcement, and permit writing. The activities in
each of these areas are summarized in Exhibit A-3.
Many States have both regulatory and non-regulatory
elements in their pollution prevention programs with
the latter serving to assist the regulated community
through technical assistance and outreach (e.g., New
Jersey, Minnesota, Tennessee, Indiana). The basic
philosophy underlying the non-regulatory approach is
that government should not dictate to private compa-
nies how to run their businesses through envi-
ronmental requirements. The philosophy assumes that
left on their own, most companies will reduce their
environmental releases because of rising compliance
costs and other incentives. The primary goal of the
technical assistance programs is to overcome the bar-
riers to pollution prevention. In terms of their scope,
the non-regulatory programs provide assistance in a
wide range of areas such as compliance, hazardous
waste minimization, solid waste recycling, wastewater,
and air emissions reductions.
State and local pollution prevention programs are
still in their infancy, and most analysts agree that it is
too early to draw conclusions as to whether a regula-
tory or a voluntary approach is more effective. Since
each OECD member country has its own regulatory
context and its own government-industry dynamics,
evaluating U.S. successes and failures with these two
approaches may not be very informative. Instead, the
remainder of this section describes some of the
activities and approaches of State and local govern-
ments.
Appendix C summarizes the common elements of
State pollution prevention programs. Several states,
including Minnesota, Wisconsin, North Carolina, and
Michigan, have held workshops and prepared publica-
tions to specifically assist metal finishers.
The Water Services Department of Phoenix,
Arizona, established a pollution prevention
program to develop best management practices
for industrial and commercial facilities that
discharge one or more pollutants of concern and
to implement a public outreach program to reduce
the discharge of toxic substances to the
wastewater treatment plants.
The pollution prevention program has created two
innovative games designed to improve awareness
of pollution prevention. The game created for
industrial facilities, "Pollution Prevention Pays,"
asks participants a series of questions in different
industrial categories, including metal finishing,
printed circuit boards, and metal fabrication.
Participants score points for correct responses.
The game for the general public, "Be a Pollution
Solution," includes questions in various
categories, including environmental awareness,
product substitution, and household hazardous
waste.
City and county level governments increasingly
are active in pollution prevention. As more and more
landfills reach capacity, governments view pollution
prevention as an important method for extending the
operating lives of their local landfills. Examples of
local initiatives are highlighted in this section. In
addition, many counties are working with State regu-
latory agencies and local environmental groups to
make pollution prevention part of the wastewater
pretreatment program. Wastewater treatment plants
identify the source of toxics in the system and provide
technical advice and other assistance to help the
discharger implement toxic use reduction and other
pollution prevention measures as a way to meet pre-
treatment requirements. A few of the states with local
governments active in this area are Massachusetts,
Arizona, New York, New Mexico, and California.
The City of New York's Department of Sanitation
is in the process of launching a major pollution pre-
vention initiative, which involves conducting more
than 25 assessments in eight industrial categories,
public education, and implementation followup. Also
in New York State, the Erie County Office of Pollu-
tion Prevention's technical assistance program has
A-5
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International Policy Approaches
Exhibit A-3. State Pollution Prevention Activities
Activity/Elements
«3
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A detailed schedule for implementing selected options, and procedures for measuring and m
progress in achieving reductions.
> A description of opportunities for employee involvement and training.
» Certification by responsible corporate officials or facility managers.
. State facility planning legislation/regulations differ as to the regulated community the rnedii
covered by the requirement, targets for reductions, State required approval of facility plans,
enforceability, and measuring progress against a baseline.
• Several States (MA, KY, MN, Wl, NY, VT) are using (or planning on using) compliance insp!
promoting pollution prevention.
• By training inspectors to identify pollution prevention opportunities during the inspection S
agencies hope to create leverage for pollution prevention through stringent evaluations of c
with directing facility operators toward technical assistance programs.
CO
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—
-------
International Policy Approaches
Exhibit A-3. State Pollution Prevention Activities (Continued)
Activity/Elements
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• Reducing penalties where toxics use reduction or source reduction is chosen as
• Requiring facilities with compliance violations to undertake a pollution preventioi
prevention planning process.
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New Jersey established a pilot project for 10 to 15 industrial facilities in facility-
» Assist private companies with pollution prevention
Assist private companies with regulatory interpretation
» Provide training for State regulatory staff, POTW operators
> Develop curriculum for students
> Promote recycling
' Facilitate information exchange
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' Funded by USEPA competitive grant awards, annual USEPA hazardous waste pn
waste disposal taxes (e.g., Community Right to Know (NJ), hazardous waste ma
environmental budget established under legislation.
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Prepare State environmental staff for pollution prevention work (e.g., the Toxics
of Massachusetts at Lowell).
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Incorporate pollution prevention into the activities of State agricultural extension
Promote pollution prevention through small business economic assistance prograi
local chapters of industry and trade associations.
Staff the technical assistance programs with retired engineers.
Summary and Current Trends. Draft. USEPA. March 1994, p. 12.
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A-7
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International Policy Approaches
Lincoln-Lancaster County Health Department
(LLCHD) in Nebraska developed a program to
reduce toxicity through pollution prevention by
increasing public understanding of chemical
toxicity in relation to decisions made on product
purchase, use, handling, storage, and disposal.
By ordinance, all businesses in the county need to
fill out a waste inventory; those who wish to
dispose of special waste need a permit. This
process educates businesses in appropriate
disposal methods and gives the county an
opportunity to identify pollution prevention
options for the business owner. The LLCHD
offers all businesses on-site assistance in
developing waste reduction strategies. LLCHD
covers pollution prevention in air,
worked with metal finishers. The office has assisted
public development programs in incorporating pollu-
tion prevention into their funding approval criteria. It
also works with local wastewater treatment plants to
incorporate pollution prevention into routine inspec-
tions.
California has the widest variety of local govern-
ment units active in pollution prevention. Several of
the large coastal metropolitan areas have their own
programs (e.g., Irvine, Berkeley, San Diego, San
Francisco, Los Angeles, California). The Sanitation
District of Los Angeles County has its own program
to work with businesses that discharge to the
wastewater treatment plant and dispose of waste at the
landfill facility.
A.3.3 Regulatory vs. Voluntary Approaches
The focus of State/local pollution prevention
programs has slowly shifted away from the voluntary
approach toward the regulatory approach, particularly
in the case of States with large releases of toxic
substances to the environment. States with relatively
limited industrial bases have generally chosen to
remain with the voluntary approach. In crafting their
programs, State policy makers have wrestled with a
number of fundamental issues that other countries may
also encounter:
• Economic Growth and Environmental Quality
Goals. Up-front investments in process modifica-
tions and new technologies can lead to long-term
savings in raw material costs, energy and water
cost reductions and labor, as well as waste
management and disposal. The challenge is to
ensure that as many companies as possible not only
identify cost savings opportunities but implement
pollution prevention measures. States could target
industries under economic stress because
management may be more interested in making
money-saving changes when other options are
limited than when their profit levels are
comfortably acceptable. Alternatively, States could
target industries on the volume of waste generated,
air emissions, or wastewater discharges.
Legislation in some States is aimed specifically at
reducing hazardous waste rather than releases of
toxics to all media while other States target toxics
reductions. The decision, as to whether a
regulatory or a voluntary approach is more appro-
priate in a particular State depends on several
factors, including environmental protection goals,
funding, prior voluntary reductions, the
relationship between stakeholders, and macro-
economic and social policy considerations.
• Leveling the Playing Field. Although State and
federal pollution prevention policies have been
established only recently, some companies have
been practicing pollution prevention for many
years. States that considered requiring all
industries to reduce their wastes by a certain
percentage by a specified year met fierce resistance
from companies that had already made costly
investments in pollution prevention and argued that
they should receive credit for earlier reductions.
In addition, smaller companies, such as many
metal finishers, typically lack the potential cost
savings, public image incentives, and capital to
invest in new equipment or to research process
changes. (A summary of the barriers and
incentives to pollution prevention from the
perspective of private industry is presented in
Exhibit A-4.)
• Relationship Between the Regulated Community
and the Regulators. Most company managers are
not willing to allow a pollution prevention
specialist from a regulatory agency to conduct an
on-site assessment because they are concerned that
the representative may identify compliance
violations during the assessment that would be
reported. This is particularly true in a heavily
regulated industry, such as metal plating. States
with active, high-profile enforcement programs
have found that the technical assistance and
outreach elements of the pollution prevention
program are better handled by a non-regulatory
agency, such as a university.
• Organizational Structure. Environmental agencies'
responsibilities are partitioned according to
environmental media. Agencies must break
through the institutional barriers that have
traditionally separated individual program areas,
reconsidering the way in which information about
individual facilities is collected and managed by
A-8
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International Policy Approaches
Exhibit A-4. Barriers and Incentives to Pollution Prevention
Barriers to Pollution Prevention
Incentives for Pollution Prevention
Regulatory
- Restrictive regulations
- Uncertainty
- Overlap of requirements
Economic
- Lack of capital
- Current cost accounting practices
- Financial risk
Technological
- Unproven technologies
- Lack of technical expertise
- Industry diversity
Corporate Management
- Resistance to change
- Lack of senior management support
- Organizational difficulties
- Short-term planning frame
Cultural
- Perception of risk
- Poor dialogue
Availability of Information
- Lack of methods to measure progress
- Lack of trust in available information
Enforcement
- Inconsistent enforcement
Regulatory
- Stringent regulations
- Mandated pollution prevention
Financial
- Reduced compliance costs
- Reduced raw material and utility costs
- Federal and state loans and grants
Technological
- Off the shelf technologies
Corporate Management
- Support
Cultural
- Corporate image
Availability of Information
- Information networks
Enforcement
- Flexible enforcement strategies
each department, the way in which inspectors and
other environmental staff are trained, separate
annual program budgets and staff resources, and
political territories.
A. 3.4 Conclusion
One of the greatest challenges facing State and
local programs is the need to document program
successes in some cases to ensure ongoing funding.
The National Roundtable of State Pollution Prevention
Programs, a nationwide consortium of regulatory and
non-regulatory representatives, has grappled with this
issue. The most commonly reported methods for
quantifying program success are summarized in
Exhibit A-5. While quantifying progress in waste
reduction will always be challenging, the Toxic
Release Inventory (TRI) reports should help State and
local governments collect data on progress made by at
least the larger companies. Attributing companies'
pollution prevention achievements solely to State pro-
gram activities, however, may be taking too much
credit because, as this section discussed, many factors
are involved in a company's decision to invest in
pollution prevention.
Looking to the future, State and local
governments should expand their sharing of
experiences, resources, and information through
A-9
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International Policy Approaches
Exhibit A-5. Commonly Reported Methods for Quantifying Program Success
Regulatory Programs
Non-Regulatory Programs
Number of:
• Multi-media inspections/enforcement actions
• Permits issued
• Grants or loans issued
• Reduction in waste generated as reported on State
annual reports and facility plans
Number of:
• Client contacts (e.g., hotline phone calls, on-site
Workshops given and participants
Publications distributed
exch transactions
programs such as the National Roundtable. Improved
cooperation will enable programs to use their limited
resources efficiently. Specific areas may include
experiences with facility planning implementation,
database development of proven technologies, and
publications and training. Similarly, federal agencies
have much to share with State and local government,
as well as with the private sector. Agencies such as
the Department of Defense and the Department of
Energy are investing in pollution prevention research
and training development. Some of their work is
relevant to the private sector.
A.4 International Programs
A.4.1 Waste Exchanges
Waste Exchange Characteristics
• Operates as clearinghouse with printed and/or
electronic list of materials available.
• Serves as intermediary between lister and
interested entity or provides direct access to
lister, but does not solicit matches.
• Does not take possession of material or
warrant condition/usability of material.
• Funded by federal. State, and local govern-
ments, private donations, or listing/subscription
fees.
• Covers limited geographical area but may
participate electronically in regional or national
databases.
Waste exchanges provide a mechanism for facili-
tating the transfer of waste materials from generators
to entities interested in recycling or reusing these
materials. Generators reduce their disposal costs,
reduce disposal quantities, and possibly receive reve-
nues. Entities accepting waste materials obtain inex-
pensive raw materials, thus lowering operating and
production costs. Exchanges successfully facilitate the
transfer of tons of industrial waste annually
worldwide. Evaluating and measuring their success is
extremely difficult due to a lack of data.
Waste exchanges may represent a particularly
powerful tool for the metal plating industry and metal
plating wastes. As the data in Exhibit A-6 illustrate,
many wastes typical of metal plating operations (e.g.,
acids, alkalis, metal and metal sludges, solvents) are
routinely listed by North American exchanges.
Wastes such as spent acids, caustics, and solvents may
be readily used for less exacting applications. Wastes
containing valuable metals may be worthy of recovery
or used as feeds to other processes. Similarly, metal
platers may b& able to use these waste streams as
feedstocks if the purity of the materials is adequate.
A.4.2 Montreal Protocol
The Montreal Protocol2 is one of the most influ-
ential international environmental directives affecting
the metal finishing industry. The goal of the Montreal
Protocol is to protect the ozone layer from man-made
ODS, some of which traditionally have been utilized
in the metal finishing industry (e.g., 1,1,1-trichloro-
ethane), by phasing out their use.
USEPA has pursued numerous activities that will
aid in the phaseout, including the identification of
substitute chemicals, products, and technologies;
promulgation of regulations to implement the Protocol;
and publication of a list of approved alternatives to
ODS.
The Heads of Delegations representing Sweden,
Finland, Norway, Switzerland, Austria, Germany, and
Denmark called for more stringent control measures,
including a phase out on the production and consump-
tion of CFCs, halons, and carbon tetrachloride as soon
as possible, but no later than 1997; a phase out of
methyl chloroform as soon as possible, but no later
than the year 2000; and further limits on HCFCs. In
November 1992, the Protocol was again amended to
accelerate various phaseout schedules and banned
other chemicals. The amendment covers CFCs,
halons, carbon tetrachloride, methyl chloroform, and
hydrobromofluorocarbons. Methyl chloroform faces
A-10
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International Policy Approaches
Exhibit A-6. Listings of Materials Wanted and Materials Available by Category from the
National Material Exchange Network* - January 1 to May 19, 1993
Category
Materials Available
Number of Percentage of
Listings
Total
Materials Wanted
Number of Percentage of
Listings
Total
Acids
Alkali
Construction Material
Container and Pallet
Durable and Electronic
Glass
Laboratory Chemicals
Metal and Metal Sludge
Miscellaneous
Oil and Wax
Other Organic Chemicals
Other Inorganic Chemicals
Paint and Coating
Plastic and Rubber
Solvent
Textile and Leather
Wood and Paper
197
181
45
366
32
39
2,350
367
677
234
410
508
96
826
313
165
594
7,400
3%
2%
1%
5%
0%
1%
32%
5%
9%
3%
6%
7%
1%
11%
4%
2%
8%
50
51
27
79
45
15
8
234
278
84
82
97
11
505
67
70
196
1,899
3%
3%
1%
4%
2%
1%
0%
12%
15%
4%
4%
5%
1%
27%
4%
4%
10%
* These data do not include approximately 460 listings of available materials and 150 wanted listings from the
Southeast Industrial Exchange and the Southern Waste Information Exchange based on recent catalog listings.
a 50-percent reduction in 1994, an 85-percent
reduction starting January 1, 1995, and a 100-percent
elimination by January 1, 1996.
As a result of the Montreal Protocol's ambitious
phaseout schedule, the metal finishing industry's
widely used cleaning solvent, methyl chloroform
(1,1,1-trichloroethane), will be prohibited, leaving
many metal finishers to seek safer alternatives.
A.4.3 An Overview of Individual Country
Programs
Thfe $>ai(icia$ and. pt&gisans of various jndMdaal
ccHiotriss are^saaaflSanzed i» Apjpaadix A. Exhibit A-
7 provides an overview of these policies.
A.4.4 The European Community
The European Community (EC) is a unique inter-
national organization that has the power to promulgate
regulations that are binding on member nations or
directives that leave each member nation free to
choose the particular means of implementation.
The EC recently adopted a directive aimed at
reducing and controlling pollution from industrial
installations. The directive introduces a system of
integrated pollution prevention and control (IPPC),
which is distinguished by its cross environmental
media approach. Until recently, pollution control in
many European countries was based on an approach
that considered emissions to air, water, and land
separately. Member states are expected to incorporate
IPPC into their national laws by June 30, 1995.
The IPPC requires that operators of industrial
installations in specific categories with a high potential
to cause pollution to obtain a permit in order to
operate. The directive covers the production and
processing of metals, as well as installations using
more than 200 kg/h of organic solvent. Smaller scale
operations are generally excluded from the scope of
the directive. Permit applications must describe pro-
posed measures to prevent or minimize emissions
from the installation and provide evidence that the
installation meets at least the emission limit values
A-11
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International Policy Approaches
Exhibit A-7. International Waste Minimization Programs
Policy Approach
Scope
Implications
Australia • Best available technology
(BAT) regulations
(permitting)
• Economic—financial
assistance
Municipal solid waste (MSW)
and industrial firms with less
than 250 people—some
specific waste streams
Specific industries, including
electroplating
• BAT regulations allow
flexibility for emerging
technologies/job shops
escaping regulation
• Financial assistance to
induce industry
implementation of waste
minimization
Canada
Denmark
Finland
Germany
• "Green Plan"
• User charges and taxes
• Mandate Federal
Government waste reduction
• Statutory orders— packaging
and recycling
• Permitting
• Financial-taxes, duties, fees,
grants, subsidiary
• Sustainable development
statute and regulations
• Permitting
• Financial-surtax
—Grants
• Statutory and regulations
• Technical assistance for
reduction of all waste by
50% by year 2000
• MSW and industrial
• Federal Government— all
waste
• MSW
• All industry
• All waste
• Rational use of all national
resources
• Large industrial firms
• MSW, fuels, and waste oil
• Industry
• MSW and industrial
• Strictly voluntary— results
hard to predict
• Involvement to reduce waste
• Provides example
• Reduces solid waste
• Limits emissions to all media
• Encourages use of clean
technologies
• Mandatory reduction of
industrial toxics
• Job shops escape regulation
• No effect on metal finishing
• Implement innovative clean
technology
• Specific media regulations
require clean technologies to
eliminate emissions
Financial-disposal
—Low interest loan
Costs for disposal of wastes
such as metal finishing
Industrial
• Grant incentive for clean
technology
• Covers cost up to 60% of
investment in cleaner
technologies
Italy • Financial-priority benefits
contributions
• Regulations
• Education/demonstration/
information
• Industry
• Industrial waste
• All waste
• Encourages use of clean
technologies
• General not industry-specific
• Encourages waste
minimization-not industry
specific
Norway • Statute & permits
requirements—mandatory
plans
• Financial-subsidiaries
Industry
• Industries (also MSW)
• Encourage waste
minimization generally
• Financial incentive to invest
in clean technologies
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Exhibit A-7. International Waste Minimization Programs (Continued)
Policy Approach
Scope
Implications
U.K. • Voluntary
• Statutory regulations (IPC)
Education/demonstration
Financial-grants
• Industry
• Industrial emission standards
• Disseminate case studies to
industries
• Industrial (also MSW)
• Not measurable
• Mandates clean
technologies, especially
metal finishing; prohibited
clearing and finishing
technology
• Technical transfer to teach
and encourage use of clean
technology
• Pays up to 50% of
investment with clean
technology
EC
International directives and
regulations
BAT permits
Industrial in member
countries
Industrial
Binding on member
conditions, multimedia focus
on industrial waste
minimization
Nordic
Council
required t
• Regional Cooperative • Industrial networks,
Voluntary-education industrial seminars,
newsletters
0 give a high level or protection to the A.4.6 NAFTA "
• Technical transfer to educate
and encourage individual to
voluntarily engage in cleaner
technology
environment.
A.4.5 The Nordic Council
The Nordic Council was formed to promote
cooperation among the parliaments and governments
of Denmark, Iceland, Norway, Sweden, and Finland.
The Nordic Council of Ministers met in March 1992
and developed the Nordic Action Programme on
Cleaner Technologies. The program is divided into
the following four areas: promotion of the use of
cleaner technologies through exchange of experience
and results, substitution of toxic components and of
products that impede recycling, employment of
administrative control measures to encourage the use
of clean technologies, and education on clean
technologies.
To further the above goals, the Council set up an
industry network to disseminate information on Nordic
cleaner technologies, hosted industry-specific
seminars, established a Nordic newsletter, and
established closer ties with the United Nations
Environment Programme's cleaner production
activities. In addition, work is being carried out on
standardizing the methodology of life cycle
assessment.
The recent passage of the North American Free
Trade Agreement (NAFTA) highlights a challenging
situation concerning how to reconcile international
trade and environmental policy issues. NAFTA raises
issues such as how trade agreements can be achieved
in the context of heavy environmental regulation and
how to harmonize international environmental and
trade laws.
Unlike media-specific statutes of the United
States, the environmental law of Mexico exists in a
single broad statute. The environmental enforcement
agency of Mexico, which is equivalent to the USEPA,
is the Secretaria de Desarrollo Urbano y Ecologia
(SEDUE), formed in 1982. While Mexico's law is
comprehensive in scope and sets reasonable ecological
standards, compliance is minimal because enforcement
is minimal. SEDUE estimates that 52 percent of the
nation's maquiladoras have generated hazardous waste
and few have obtained basic operating licenses.
Mexico simply does not have the fiscal or human
resources to adequately enforce its comprehensive
environmental law.
While it is impossible to predict what impact
NAFTA may ultimately have, its passage is likely to
attract even more industrial production facilities (such
as metal finishers) to Mexico and further compound
the compliance problem. This issue is not unique to
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North America, but arises in any region with disparate
environmental policies.
A.4.7 Future Trends
Based on the information reviewed in this section,
the following observations can be made:
• Waste minimization programs that address metal
plating operations will increase in number due to
the toxic chemicals managed by this industry.
• These programs will be split among voluntary and
mandatory programs, with mandatory programs
being less "command and control" and more
incentive driven.
• The overall regulation of metal finishers will
continue to increase in scope and stringency,
creating greater incentives for legitimate operators
to pursue waste reduction/cleaner technologies and
driving noncompliant operations to regions of
minimal regulation or lax enforcement.
• International waste minimization currently focuses
more on industrial and solid waste than does U.S.
waste minimization.
• Small metal finishing operations appear to have
special needs as they are forced to decide whether
to pay the increasing cost of compliance, reduce
waste generation, or become fugitive operations.
A.4.8 Sustainable Development
According to the United Nations World Commis-
sion on Environment and Development, the term
"sustainable development" refers to development that
meets the needs of the present without compromising
the ability of future generations to meet their own
needs. While the precise definition of the term is still
the object of considerable international debate, consen-
sus exists on several fundamental issues. Sustainable
development requires a long-term perspective for
planning and policy development; dictates actions that
build on and reinforce the interdependence of our
economy and our environment; and calls for new inte-
grative approaches to achieve economic, social, and
environmental objectives.
Sustainable development has emerged in recent
years as a focal point for policy makers concerning the
long-term economic and environmental outlook. The
level of concern about sustainable development was
made evident in 1992 at a United Nations Conference
on Environment and Development. Representatives
from 180 countries gathered at this conference to
promote sustainable and environmentally sound devel-
opment.
Many of the past and present USEPA programs
have utilized tenets of sustainable development.
USEPA, however, has not employed the concept as an
overall policy framework or programmatic objective
until very recently. The limited use of sustainable
development concepts in USEPA policies is, in part,
due to a lack of these concepts in its statutory man-
dates. It is generally agreed that statistically and
scientifically credible environmental data and informa-
tion are needed to measure progress toward environ-
mental goals and sustainable development.
USEPA is implementing a program to gather and
provide statistical information about the status and
trends in the Nation's ecological systems. USEPA's
Environmental Monitoring and Assessment Program
is the first statistically based monitoring program to
assess ecosystems on a national scale. The program
is designed to advance the scientific knowledge of eco-
systems and how these ecosystems are changing and
responding to human activities.
A.5 Austria
A.5.1 Organizational Structure
Austria's responsibility for environmental protec-
tion is under the Ministry of Environment, Youth and
Family Affairs. The Minister is responsible for
setting waste generation rates and creating strategies
for waste minimization.
According to the provisions of the Austrian Waste
Management Act, the federal government's principle
role is to set up technical standards for hazardous
waste collection facilities. The provincial government
gives consent as to which groups of waste require
collection, and the municipalities make the detailed
plan for when, where, and how the collection takes
place.
Regulations and Laws
The Austrian waste management act influences
waste minimization. Section 9 of the act requires
legal permission for the installation and operation of
plants, as well as for the modifications of old plants.
Best available technology (BAT) is to be used. To
gain permission, the description and amounts of waste
and waste minimization strategy are required.
Firms with more than 250 people are required to
employ a waste expert.
Similar to the German regulations, Austria has
drafted a number of ordinances aimed at specific
waste streams. Targets are set and it is up to those
parties concerned to meet the targets. If the targets
are not met within the specified time period, the
government is free to set up compulsory measures.
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Demonstration and Assistance
The Ministry of the Environment is in charge of
task forces to facilitate specific waste management
plans for several industry waste streams. These plans
are meant to encompass waste avoidance, waste recy-
cling, etc. These plans form the basis for any
financial assistance. Members of these task forces
come from Federal Chamber of Economy, relevant
professional association, the Federal Environment
Protection Agency, and industries.
Plans have been completed for the following
waste streams or industry: paints and lacquers, wood
preserving, tanning wastes (chromium), foundry,
organic halogenated and non-halogenated,
electroplating, garage (autos), medical, agriculture.
A.6 Canada
In 1990, the Canadian Government released its
"Green Plan," which contains targets and schedules
that will drive environmental initiatives within the
federal jurisdiction for many years. The Green Plan
outlines the National Waste Reduction Plan, which
aims to reduce the amount of waste needing special
treatment or disposal by 50 percent by the year 2000.
A.6.1 Organizational Structure
For the most part, the collection, management,
and disposal of waste is under provincial and/or local
legislation. Provincial governments are responsible
for water, sewage treatment, waste collection, and dis-
posal, as well as land-use planning.
The federal government provides leadership,
support, and national action on hazardous and solid
waste problems. In particular, the federal government
does the following:
• Provides technical support, research, and data
necessary for informed decision-making by con-
sumers and industry (e.g., national packaging
protocol)
• Promotes and develops national standards and
guidelines (e.g., export and import of hazardous
wastes
• Supports the development, testing, and demonstra-
tion of effective technologies.
Regulations and Laws
The key environmental legislation at the federal
level is the Canadian Environmental Protection Act
(1988). This act sets environmental quality objectives,
guidelines, and regulations to prevent the contamina-
tion of water, soil, and air.
Current federal legislation that deals with wastes
include the following:
• Ocean Dumping Regulations
• Contaminated Fuel Regulations
• Export and Import of Hazardous Wastes Regula-
tions
• Storage of PCB Materials Regulations
• Chlorobiphenyl Regulations
• Transportation of Dangerous Goods Regulations
• Federal Mobile PCB Treatment & Destruction
Regulations.
Each province has complimentary waste manage-
ment legislation as it applies to areas under their
jurisdiction.
Fiscal Measures
Fiscal measures are used by provincial govern-
ments to promote environmental protection. User
charges and taxes on treatment and disposal of wastes
and product charges and taxes, including deposit
refund systems on beverage containers, are used.
Demonstration and Assistance
To meet the targets set out in the National Waste
Reduction Plan, the federal government, in
conjunction with provincial and territorial
governments, the private sector, and community
groups, will promote the four R's of waste
management—reduce, reuse, recycle, and
recover—and will:
• Through the National Packaging Protocol Program,
reduce waste from packaging materials by 50 per-
cent by the year 2000.
• By 1994, for other components of the waste
stream, develop national standards, codes, policies,
and regulations for the reduction, reuse, and
recycling of wastes.
• Support technological innovations aimed at waste
reduction, recycling, and reuse.
• Support community action through an expansion of
the Environmental Partners Fund.
• Provide information to individuals and businesses
through new and existing programs.
• Commit the federal government to reducing waste
from its own operations by 50 percent by the year
2000.
« Expand the National Waste Exchange Program to
improve the market opportunities for the reuse and
recycling of industrial and large-volume wastes.
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A.7 Denmark
A. 7.1 Organizational Structure
The Ministry of Environment is responsible for
environmental protection, including waste manage-
ment; however, the executive responsibility for waste
management lies with the municipalities.
In accordance with the Environmental Protection
Act, the municipal authorities are responsible for
directing waste to appropriate treatment or disposal
facilities and for the adequate provision of such facil-
ities. The authorities are also responsible for the prac-
tical aspects of household waste collection, the sepa-
rate collection of glass and paper from households for
recycling, and the collection of paper from trade
premises and public institutions for recycling. These
duties are either performed by the municipal services
themselves or by private contractors on the behalf of
the municipalities.
Action plans for both cleaner technology and
waste and recycling (see below) are administered by
the National Agency of Environmental Protection.
The funding of individual projects, however, is the
responsibility of the Danish Recycling and Cleaner
Technology Council. This council comprises
representatives from the Ministry of the Environment,
industrial organizations, municipalities, counties,
nongovernmental organizations, and two experts on
recycling and cleaner technology.
Regulations and Laws
Several statutory orders under the Environmental
Protection Act address waste disposal:
• Reuse of packaging for beer and soft drinks
• Recycling of newspapers/magazines and glass from
private households
• Recycling of paper/board from commercial and
institutional sources
• Recycling of food waste from catering centers
• Recovery of slags and chemical waste.
The legislation framework for environmental
protection has been revised recently. Not only does
the Act call for preventing and reducing pollution of
the air, water, and earth but also the waste of raw
materials and energy through the adoption of cleaner
technology.
Pollution permits are an integral part of this Act.
The environmental authorities, either county or
municipal, explicitly state the conditions for polluting,
including industrial process used, waste amount, water
discharges, air emissions, and waste handling for
listed activities.
The overall waste management policy for 1993-
1997 is described in two separate action plans, one for
waste and recycling and the other for cleaner tech-
nology. According to these plans, the adoption of
cleaner technology is expected to stabilize waste
quantities by the end of the 1990's. Increased waste
recycling is expected to produce a 50-percent
reduction in waste sent for final disposal.
In the new Environmental Protection Act, the
Minister for Environment can negotiate "voluntary
agreements" with industry.
Fiscal Measures
In Denmark, financial instruments concerning
waste minimization are taxes, duties, and fees, as well
as grants and subsidies.
There is a duty on raw materials. Also, there are
several duties on waste (not including materials for
recycling or recovery), bpth on waste that is inciner-
ated and on waste that is disposed of in landfill.
The treatment of sewage is also meant to be self
sustaining by users. Therefore, charges differ from
user to user depending on the contribution of polluted
effluent.
While previous recycling plans used subsidies to
promote new collection and processing schemes,
future solutions must be based on market-oriented
tools. Government subsidies for capital investments
are, therefore, no longer granted. Local services,
such as waste collection, separation, and treatment,
must become self supporting. Private companies will
be encouraged to finance some collection and
processing schemes in the future. These investments
may need to be financed via the product price.
Demonstration and Assistance
In the cleaner technology action plan of 1993-
1997, various industrial sectors (e.g., slaughterhouses,
dairies, fish processing, chemical) and products (e.g.,
building materials, furniture) are targeted for sector
mapping projects, development of technology,
research studies, etc., and these are largely financed
through the budgets for the action plans. Metal
plating is not addressed specifically.
The Ministry of Industry also administers a pro-
gram to support the commercial exploitation and
development of environmental technology, including
cleaner technology. The current program runs from
1991 to 1994.
In waste management and recycling, regular
followup measures on material flow analyses, etc. is
being studied in order to provide feedback for imple-
menting targets and/or voluntary agreements. So that
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recycling is both economic and environmentally
viable, more development on collection systems and
treatment and processing plants are planned. Investi-
gations will also be carried out to identify recycling
options or needs for special treatment with oil and
chemical wastes.
A.8 Finland
A.8.1 Organizational Structure
The focal points for waste management are the
Ministry of the Environment (MOE), the Provincial
Governments (PGs), and the municipal authorities.
The Waste Act (came into force on January 1, 1994)
covers nationwide and provincial waste planning,
which is the task of the MOE and the PGs.
Regulations and Laws
The Waste Act aims at promoting sustainable
development through the rational use of natural
resources and through preventing and abating hazard
and inconvenience to human health and the environ-
ment caused by waste. Regulations on the prevention
of waste generation and on the reduction of the
amount and hazard of waste are introduced in the Act.
The government (Council of State) may issue general
regulations on prohibitions and restrictions and other
general regulations related to products and wastes of
these products.
Waste permits are required for industrial and
professional waste recovery and disposal, as well as
for professional collection of hazardous wastes. Also
larger industrial plants, power plants, central heating
plants, and remediation of contaminated sites need a
waste permit according to the Waste Decree.
Fiscal Measures
The government has instituted a surtax on some
items. Disposable packaging for beverage containers
are charged. This has enabled Finland to maintain a
high use of reusable containers. Only 5 to 8 percent
of all beer and soft drinks consumed are packaged in
one way containers. There are also surtaxes on fuels,
fertilizers, and oil products, including waste oil.
According to the Waste Act, municipalities have
the right to charge the costs for waste management
efforts that they organize and must charge full costs
for waste disposal activities that they organize. This
is expected to have a positive effect on waste minimi-
zation.
Demonstration and Assistance
The MOE provides assistance for experimental
projects aimed at waste avoidance or recycling.
Under the Department of Trade & Industry,
grants may be given to projects and product planning
related to clean technology.
The MOE also finances studies in various
branches of industry on best available technology.
Studies have recently been completed on car repair
and engineering industry, as well as on the paint and
pharmaceutical industries.
The new Waste Act expands the concept of waste
management to cover production and full life cycle of
products. In order to fulfill the aim of sustainable
development, the government (Council of State) may
issue, under certain conditions, general regulations on:
• Production and manufacturing processes
• Limitations in or prohibition against use of
products
• Obligations of manufacturers and importers to
arrange management of wastes generated from their
products.
With the entry of Finland into the European
Economic Area Treaty from 1 January 1994, close
attention has to be paid to EC directives.
A.9 Germany
A.9.1 Organizational Structure
The Federal Ministry for the Environment, Nature
Conservation and Nuclear Safety is responsible for all
fundamental matters of environmental policy,
including transfrontier co-operation, water
management, waste management, air management,
noise abatement, environmental health, protection
against substances, nature conservation, soil protection
and contaminated sites, safety of nuclear facilities and
protection against radiation, and disposal of nuclear
matters.
The principal agencies that support the Ministry
of the Environment include:
• The Federal Environmental Agency, which
provides scientific advice on drawing up legal and
administrative positions and regulations in the
fields of air pollution control, noise abatement, and
waste and water management, as well as general
aspects of environmental protection. The Agency
collects environmental data and is responsible for
information dissemination and outreach to the
public and for implementing and enforcing
provisions contained in the Chemicals Act, the
Pesticides Act, and the Gene Technology Act.
• The Federal Research Centre for Nature Conserva-
tion and Landscape Ecology, which is responsible
for research and development and for the progress
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of scientific concepts for the protection and
management of nature reserves and specially
protected areas.
• The Federal Office for Radiological Protection, a
new body that is responsible for implementing and
enforcing provisions contained in the Atomic
Energy Act and the Precautionary Radiological
Protection Act.
The German Constitution determines that the
Lander (Provinces) bear responsibility for the
implementation of environmental protection laws. The
Lander determines the precise institutional forms of
enforcement, which may vary among them. Often,
tasks are delegated to lower levels of Lander adminis-
tration or to the municipal level.
The administration of environmental protection in
the Lander is structured according to environmental
sectors: water, waste, air, and nature conservation.
At the local level (municipality), typical tasks carried
out are urban traffic planning and regulation,
municipal waste management, cleanup of contaminated
soil, waste water management, and noise protection.
Regulations and Laws
Germany has enacted legislation affecting both
industrial and municipal solid waste (MSW), In 1986,
a new waste avoidance and management act was
adopted. Under this act, statutory regulations could
be implemented if voluntary targets did not work. In
1987 and 1989, there were ordinances on waste oil
and halogenated hydrocarbons. These products now
require separate collection, reacceptance of used
products by producers, and distributors for recycling
or disposal. These new ordinances brought new
responsibility to the generator of the waste.
German law requires certain wastes (e.g., organic
solvents, and other organic liquids) to be destroyed,
and these wastes cannot be legally disposed of on
land. There is also very stringent design and
monitoring requirements for landfills. This has
greatly increased the cost of disposal for the metal
plating industry, as well as for other industries. For
example, western Germany landfill prices for metal
sludges, oily sludges, and asbestos were roughly
double the median price in the rest of Europe.
The German federal air pollution law has general
provisions for the protection of the environment and
for the minimization of toxic emissions. To accom-
plish specific goals, ordinances and regulations are
promulgated under the law. The most comprehensive
and well known law is the TA Luft. The TA Luft
spells out source-specific emissions standards for total
particulate matter, as well as for certain metallic
components of the particulate matter. In addition,
there are emission limits for 12 inorganic and 145
organic gases (which also impact metal platers). The
substances are grouped into different classes according
to general level of toxicity, with each class having a
different allowable emission level. The TA Luft
contains some general emission control provisions. It
requires that state-of-the-art pollution control tech-
nology be used. Also, all plant workers are required
to undergo practical and theoretical training in
resource recovery.
Fiscal Measures
Currently, three Landers have imposed a
surcharge on industrial waste generators. The German
government is proposing a federal waste charge,
where a portion of the money would be directed at
helping the new Lander deal with the waste problems
created in the past. Deposit schemes for containers,
direct charges for household waste collection, and
disposal are measures used in some Lander.
Demonstration and Assistance
The government provides aid for small and
medium-sized enterprises (SMEs) to help them reduce
wastes. For example, low-interest loans are available
for up to 60 percent of investment costs of techno-
logies for cleaner production and products. Also, the
German government and the Confederation of German
Industry act together to provide advice and some
professional consultation services at no charge to
SMEs seeking ways of reducing waste generation.
There are also requirements for reporting quan-
tities of waste generated.
A. 10 Italy
A. 10.1 Organizational Structure
The Italian Ministry of Environment (MOE),
created in 1986, is responsible for protecting the
environment. With waste management, regulations
and enforcement are shared with the Ministry of
Industry and the Ministry of Health.
Waste minimization responsibility rests primarily
with the MOE; however, the Ministry of Industry also
has a coordinating and funding role in this area,
principally oriented at creating incentives for the
introduction of clean technologies.
A Commission on Industry and the Environment
was established in 1990 with the specific aim of
identifying forms of sustainable development, includ-
ing, of course, reducing waste generation. The mem-
bers of this commission include scientists and techno-
logists from the industry and environment ministries.
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Regulations and Laws
Law 441, which came into force in 1987, was the
first law to permit the application of waste minimiza-
tion in Italy. Article 14 establishes that "Industrial
companies which intend to modify their production
processes in order to reduce the quantity of the hazard
level of the waste produced or to encourage recovery
of the materials are, provisionally, to be given priority
for benefits under Article 14ff of Law 46 of 17-02-
82..." Furthermore, the law indicates that the
changes in production processes that also bring about
energy saving are also eligible for contributions from
the Ministry of Industry, Commerce and Trade
together with the Ministry of the Environment under
Law 308 of 29-5-82.
Law 475 of 1988 sets out a number of regulations
for industrial waste treatment that encourage waste
minimization, particularly the post-consumption
phases. Article 9(iv) of this law calls for the
establishment of three authorized consortia for
recycling packaging used for liquids (glass, metal,
plastic, and composite materials). Minimum recycling
quotas have been established—50 percent for glass and
metals and 40 percent for plastics and coupled
materials. Energy and/or heat recovery from this
waste cannot exceed 50 percent of the established
objective.
Article 9(v) also mandates the establishment of a
consortium for spent lead batteries, which are to be
collected separately and recycled.
In 1990, another resolution granted financial
assistance from the Technology Innovation funds (Law
No. 46 of 17-02-82) to those programs with environ-
mental objectives (e.g., clean technology and end-of-
pipe technologies).
In terms of post production interventions, DL
443, issued in the second half of 1993, encourages
both reuse in production processes and combustion of
production and post-production consumption residues
through the establishment of a simplified authorization
procedure. This authorization covers waste collection,
stockpiling, and transportation.
Demonstration and Assistance
The MOE has developed voluntary agreements
with certain industry sectors aimed at encouraging the
use of clean technologies and waste minimization.
In the second half of 1993 under the Three Year
Program for Environmental Protection, the MOE
organized an information program on waste manage-
ment, principally aimed at public bodies, local author-
ities, small enterprises, and private industrials. This
program is designed primarily to identify measures
suitable for correct waste management, particularly in
terms of waste reduction.
Waste streams that either represent a large volume
or are highly toxic are being identified and studied in
collaboration with the Commission of the European
Community. This should provide better information
on the origin, type, quantities, characteristics, and
hazardousness of the waste. From this information,
realistic possibilities for reuse, recycling, and recovery
can be determined for both production and post-
consumption waste.
A. 11 Norway
A. 11.1 Organizational Structure
Waste management in Norway is ultimately the
responsibility of the Ministry of Environment (MOE).
The MOE, however, delegates some of that responsi-
bility among the State Pollution Control Authority
(SFT), the County Departments of Environmental
Affairs, and the municipalities.
The MOE ensures environmentally sound treat-
ment of waste and establishes goals, strategies, and
classifications. SFT is a directorate under the MOE
with a role in enforcing regulations on pollution, waste
management (hazardous and non-hazardous), and
noise. It also has the responsibility for regulating
waste incineration, issuing any other waste
management guidelines for the county departments and
administering subsidies for waste minimization
projects. The county departments are responsible for
regulating municipal landfills and other facilities and
giving information to the municipalities regarding
waste management issues. The municipalities are
responsible for providing a collection and treatment
system for municipal waste.
Regulations and Laws
Two significant acts affect waste minimization in
Norway—the Pollution Control Act and the Product
Control Act.
The Pollution Control Act aims to protect the
external environment from pollution by trying to
reduce the existing pollution, as well as promoting
better treatment of waste. The law covers the
following legal requirements regarding waste:
• Permits for incineration and landfilling, as well as
for various polluting industries
• Imposition of demands for waste reduction and
recycling in private industry and municipalities
• Requirement for waste plans from the municipal-
ities, including requiring municipalities to charge
full costs for waste management activities.
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The Pollution Control Act also contains four
specific regulations regarding hazardous waste. These
regulations cover specific waste requirements on
hazardous products and processes, as well as the
import and export of hazardous wastes.
The Product Control Act is meant to prevent
products causing damage to health or environment
(e.g., pollution, waste, noise). This law includes legal
permission to make decisions concerning return and
deposit arrangements, recycling, and treatment of
waste.
Demonstration and Assistance
Subsidies are given to both industry and
municipalities. Subsidies to industry encourage clean
technologies projects, and subsidies to municipalities
are for investment in material recovery facilities and
other separation schemes.
SFT is also striving to provide better statistics and
make those statistics available to the public. They are
also initiating information campaigns on waste reduc-
tion and recycling.
The government is working with industry in
achieving voluntary agreements on waste minimization
as much as possible but will use legal measures if
needed.
A.12 United Kingdom
A. 12.1 Organizational Structure
The Department of the Environment (DOE) has a
number of functions, one of which is responsibility for
environmental protection. The Department's Environ-
mental Protection Group inter-alia both develops
policy and legislation on waste and enforces parts of
the legislation through Her Majesty's Inspectorate of
Pollution (HMIP). HMIP is responsible for enforcing
laws relating to pollution from industrial processes.
Responsibility for enforcing other waste management
legislation rests with other agencies, primarily the
National Rivers Authority (NRA) and the Waste
Regulation Authorities (WRAs). The NRA is not part
of the DOE but is sponsored by it. It is responsible
for the control of pollution of the aquatic environment.
The WRAs are local authorities responsible for
enforcing legislation relating to the management of
controlled waste. The government is considering
bringing HMIP, NRA, and the WRAs together in one
organization—The Environmental Agency—possibly in
1995. At present, however, this is only a proposal
and much preparative work remains.
The DOE is also responsible for encouraging
domestic waste recycling and minimization. The
Department of Trade & Industry (DTI) is responsible
for encouraging sound waste management practices,
especially waste minimization and recycling, in the
industrial sector. The DOE, the NRA, and the DTI
all have substantial research programs to underpin
their policies and activities on the management of
waste.
Regulations and Laws
The key regulatory measure for waste minimiza-
tion is part 1 of the Environmental Protection Act of
1990. This introduces the concept of IPC, which
applies to the release of pollutants to air, water, and
land from certain processes. Certain processes will
have to apply to HMIP and be required to meet
statutory emission standards.
Grants are also available to support the develop-
ment of clean technology. The Government will pay
up to 50 percent of the costs for suitable projects.
DTI has produced a booklet of case studies that
emphasize the economic benefits of waste minimiza-
tion through the adoption of cleaner technologies.
The adoption of the Environment Protection Act
of 1991 significantly changed how industry operates
many of manufacturing processes in the U.K. The
metal finishing industry was directly affected because
of certain prescribed activities, including industrial
cleaning and finishing. To operate many of the pre-
scribed processes, a company needs to obtain a license
for which there is a fee and annual policing charge.
To obtain and keep this license, the company must
demonstrate that the process meets the environmental
standards. The legislation allows for regulations to be
gradually tightened to take into account emerging
technologies, such as cleaner technologies.
References
1. AESF/USEPA, 13th AESF/EPA Conference on
Environmental Control for the Surface Finishing
Industry. January 27-29, 1992.
2. Kelly, Michael, "Environmental Implications of
the North American Free Trade Agreement," 3
Indiana International & Comparative Law Review
361, Spring 1993.
3. McLeod, Glen and John O'Hara, "EC Proposals
for Integrated Pollution Prevention and Control,"
21 Chemistry and Industry Journal, 3, November
1, 1993.
4. OECD - (Hugh Carr Harris), Waste Management
Policy Group, Background Paper on Waste Mini-
mization, Paris, 1994. (ENV/EPOC/WMP(94)1).
5. OECD - Environmental Monographs, No. 9, The
Promotion and Diffusion of Clean Technologies in
Industries, Paris, June 1987.
A-20
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International Policy Approaches
6.
7.
8.
OECD - Environmental Monographs, No. 53,
Managing Wastes Containing Cyanide, Paris,
1992. (OCDE/GD(92)83).
OECD - The OECD Environment Industry:
Situation, Prospects and Government Policies,
Paris, 1992. (OCDE/GD(92)1).
OECD - Technology and Environment: Govern-
ment Policy Options to Encourage Cleaner
Production and Products in the 1990s, Paris,
1992. (OCDE/GD(92)127).
9. Sakai, Susan and Marney Buchanan, "Federal
CFC Labeling Requirements and Their Impact on
Business," BNA Chemical Regulation Daily June
3, 1993.
10. Sanwal, Mukul, "Sustainable Development, The
RIO Declaration and Multilateral Cooperation," 4
Colorado Journal of International Law and Poli-
cy, 45, University Press of Colorado, Winter
1993.
11. Somheil, Timothy, "Green Preparation: Environ-
mental Issues Concerning the Protective Coating
of Metal Products," Dana Chase Publications,
Int, November 1992.
12. Thurber, James and Peter Sherman, "Pollution
Prevention Requirements in the United States
Environmental Laws," published in Industrial
Pollution Prevention Handbook, edited by Harry
Freeman. Fall 1994.
13. USEPA, Office of Pollution Prevention, Pollution
Prevention 1991: Progress on Reducing
Industrial Pollutants, Washington, DC, October
1991. (EPA 21 P-3003).
14. USEPA, Office of the Administrator, Source
Reduction Review Project: A Status Report -
Spring 1993, Washington, DC, April 1993.
(EPA 100-B-93-002).
15. USEPA, Office of Policy, Planning, and
Evaluation and Industrial Economics, Inc.,
Sustainable Industry: Promoting Strategic
Environmental Protection in the Industrial Sector,
Washington, DC, June 1994.
16. USEPA, Office of Policy, Planning, and Evalu-
ation, Sustainable Development and The Environ-
mental Protection Agency, Washington, DC, June
1993. (EPA 230-R-93-005).
17. USEPA, Office of Pollution Prevention and
Toxics, EPA's 33/50 Program: Fourth Progress
Update, Washington, DC, September 1993
(EPA-745-R-93-005).
18. USEPA (Jean Parker, Beverly Boyd, and Lori
Lacy), An Introduction to EPA's Design for the
Environment Program, Washington, DC, undated.
19. Memorandum: USEPA Definition of "Pollution
Prevention," to all USEPA Personnel, from
Henry Habicht, Deputy Administrator [USEPA],
May 28, 1992.
20. USEPA Office of Solid Waste. State Pollution
Prevention Programs: Summary and Current
Trends. Submitted by Science Applications
International Corporation and Kerr & Associates.
March 1994.
Endnotes
1 For descriptions of specific tools for developing and
implementing pollution prevention at the facility-level,
see Appendix B.
Growing international concern over stratospheric
ozone depletion culminated in an international agree-
ment known as the Montreal Protocol on Substances
That Deplete the Ozone Layer. The Protocol has been
adopted by more than 60 countries and took effect on
January 1, 1989. In 1990, due to mounting scientific
evidence indicating greater than expected stratospheric
ozone depletion, the parties to the Protocol met in
London and agreed to accelerate the phaseout sched-
ules for the substances already controlled by the
Protocol. They also added phaseout requirements for
other ODS, including methyl chloroform, carbon tetra-
chloride and CFCs.
A-21
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APPENDIX B - IMPLICATIONS AND EVALUATION OF POLICIES
B.1 Introduction
This section presents an overview of the effects
of pollution prevention policies on waste generation in,
and the environmental impacts caused by, metal
plating industries.1 The discussion examines these
effects in historic, current, and future terms. It also
aggregates the information presented in the previous
section into broad categories of policy options and
examines the implications of these basic categories of
pollution prevention policies.
As USEPA points out in its report entitled
Sustainable Industry: Promoting Strategic Environ-
mental Protection in the Industrial Sector: Metal
Finishing Industry, Office of Policy, Planning, and
Evaluation, USEPA, June 1994 (hereinafter referred
to as SIP Report), a key step in characterizing the
selected industries is to identify the factors and
barriers that influence corporate decision-making and
environmental performance. These factors represent
the key leverage points for an industry such as metal
finishing. It is important to understand the regulatory,
informational, economic, or other factors that provide
the greatest incentives and impose the largest barriers
to improved environmental performance. These are
the factors that influence investments in pollution
prevention in the metal finishing industry.
The following sections will briefly characterize
the metal plating industry (including trends), describe
the impact pollution prevention measures have had on
the metal finishing industry, and identify the barriers
to improved environmental performance in this indus-
try. A summary of the section's highlights is
provided in Exhibit B-l. These sections will draw on
conclusions from an examination of the U.S. and
international policy sections, as well as a summary of
USEPA's findings in the SIP Report.
B.2 Industry Characterization
It is clear from Section 3 of this report that
cleaner technologies and products already exist in the
metal finishing industry as a result of extensive gov-
ernment and trade association cooperation on product
and process technology development and technology
transfer, as well as military research and development.
These technologies do not address every envi-
ronmental issue encountered by the metal plating
industry, but they do provide the potential for
improvement in many areas. The availability these
technologies is an important factor in promoting waste
reduction.
A second fundamental point is that the metal
finishing industry is very diverse in terms of processes
(e.g., electroplating, plating, polishing, anodizing, and
coloring) and size of operations within the industry.
Metal finishing "job shops" tend to be small and gen-
erally have fewer resources available to address envi-
ronmental concerns. In addition, they are usually less
specialized than many captive operations. The captive
metal finishers tend to have greater access to financial
and organizational resources and, consequently, tend
to be more proactive with their environmental
programs.
Due to the diverse nature of this industry, it is
useful in assessing policy implications to subdivide the
metal finishing industry to better understand the policy
implications- and barriers to waste reduction. For
example, the USEPA SIP Report subdivided the metal
finishing industry into four groups or "tiers." These
groups are characterized according to environmental
performance and differ according to key factors that
influence decision-making, as described in Exhibit
B-2.
Some metal finishers from groups 3 and 4 have
an incentive to remain operational despite declining
profits due to potentially high environmental cleanup
costs associated with shutting down and liquidating a
business. Since these firms lack the money or moti-
vation to improve environmental performance, they
continue to pollute and represent a problem for the
environment. These operations are typically not
pursuing waste reduction and may require innovative
policies to achieve meaningful change.
B.3 Impact of Policies
As discussed in the previous chapter, numerous
waste minimization policy initiatives are currently
being pursued at all levels of government in most
major industrialized countries. This represents a fun-
damental shift in the focus of environmental policy
toward reducing the regulatory compliance and
liability burdens faced by industry, while increasing
operational efficiency and protecting the public.
As discussed, many of these waste minimization
initiatives affect the metals plating industry, although
most, quite understandably, are much broader in
scope. Overall, these waste minimization policies can
be grouped into voluntary and mandatory programs.
Voluntary programs include those that rely on estab-
lishing waste reduction goals, information and techno-
logy transfer, grants, voluntary participation, incen-
tives, or public sentiment to achieve waste minimiza-
tion objectives (e.g., Nordic Council vs. European
B-1
-------
Implications and Evaluation of Policies
Exhibit B-1. Policy Approaches and Implications
Policy Approach/
Mechanism
Application to
Metal Finishing
Policy Implications
Direct Regulation
• Clean Air Act, Clean Water Act, and
Resource Conservation and
Recovery Act regulations that
directly impact the cost of
generating, treating, and disposing
of wastes in the metal finishing
industry.
Increase the cost of generating
waste and create greater financial
incentives for industry to improve
efficiency and reduce waste
generation.
Planning Requirements
Pollution Prevention Act reporting
and State planning requirements
apply to broad categories of
industries, including metal finishing
operations.
Force industry to examine
opportunities for waste reduction
without imposing inflexible goals.
Reporting
• Pollution Prevention Act and State
reporting requirements monitor
waste reduction activity.
• Prompts waste reduction activity and
provides a measure of activity and
progress.
Enforcement
ESP SEPs and analogous State
Programs.
Provide additional incentive for
industry subject to enforcement
action to pursue pollution prevention
as means of coming into compliance
and prompting future compliance and
efficiency.
Financial Incentives
Federal and State grants, as well as
tax incentives and market-based
regulatory initiatives, affecting
numerous industries, including metal
finishing.
• Promote the development and
dissemination of waste reduction
information.
• Create financial incentives for metal
finishing industry to pursue pollution
prevention.
Technology Transfer
Pollution Prevention Act and State
initiatives promote development and
sharing of pollution prevention
information for a broad spectrum of
industries.
• Provides the data base for large and
small metal finishers to initiate waste
reduction initiatives.
Community Directives). Mandatory policies include
direct regulation (e.g., effluent limits or hazardous
waste listings that create strong incentives for
reduction, as well as waste reduction planning and
certification requirements), the use of permitting
authority, and the imposition of supplemental environ-
mental projects (SEPs). No waste minimization pro-
grams have directly mandated specific industries to
change their operations and to achieve specified goals,
but 'there are signs that some programs (e.g., that
National Emissions Standards for Hazardous Air
Pollutants under the U.S. Clean Air Act) may move
further in this direction if control technologies cannot
achieve requisite levels of environmental protection.
In addition, restrictions imposed under programs not
aimed at the metal plating industry, such as the ozone
protection requirements, may affect the plating
industry by restricting its access to certain chemicals.
Given that these waste minimization policies are
relatively new, most governments are attempting to
foster a new waste reduction ethic through less
prescriptive policies, which rely in part on the
inherent attractiveness of prevention-oriented policies
for industry (e.g., reduced regulation, increased
efficiency). Governments and industry both
understand that waste minimization policies are very
attractive from a cost-benefit perspective when
compared to traditional regulatory approaches (i.e.,
command and control).
B-2
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Implications and Evaluation of Policies
Exhibit B-2. Metal Plating Groups/Key Decision-Making Factors
Tier
Group Characteristics
Decision-Making Factor
Firms constantly in compliance with regulatory
requirements and proactive in making
environmental improvements beyond baseline
compliance.
Firms with the primary objective of complying
with existing regulations. These firms either
lack motivation or resources to improve beyond
this baseline level.
Firms that consist of old and outdated shops
that are not profitable enough to justify
investments in new pollution controls. Many of
these firms would like to close, but remain
open for fear of cleanup liability.
IV Firms that are consistently out of compliance
and make no attempt to improve yet escape
enforcement attention. These "renegade" firms
are not substantial competitors but compete
with other firms by avoiding the costs of
environmental investments.
Ill
Firms in the first group are driven by recognition
and pride in industry performance. These firms
tend to be forward looking and are motivated by
anticipated payoffs from strategic environmental
investments.
Firms in the second group are driven more by a
strong desire to achieve and maintain compliance
with federal. State, and local environmental
requirements. This second group represents the
largest segment of the industry.
The old outdated shops in the third group have a
strong fear of liability. They have little interest in
improving their environmental performance
because they lack the capital, information, and
often even the space to do so.
The renegade shops have no incentive to improve.
They do not fear enforcement because they are
difficult to track down. These firms profit by
undercutting firms in the top groups.
Overall, waste minimization policies that affect
the metal finishing industry are continually being
expanded. As discussed previously, these policies
take several forms. However, these policies typically
do not dictate the terms of waste reduction; rather,
they attempt to create waste reduction incentives,
develop and share waste reduction information, and
promote reduction-oriented thinking. Such polices are
not as prescriptive as they might be due to a hesitancy
on the part of regulators to meddle with the
manufacturing process itself, as well as their
understanding that, in many instances, rigorous
regulatory schemes already create strong incentives for
waste reduction. In addition, such regulations are
generally being made more stringent across nearly all
media. These incentives do not apply to operations in
group 4, because these firms tend to disregard
applicable regulations. Hence, group 4 operations
(and some group 3 operations) do not participate in
waste reduction activities with the same vigor as
groups 1 and 2.
Waste reduction policies are a relatively recent
phenomenon, and effort is being spent examining how
such policies can be implemented most effectively, as
well as how such policies promote reduction among
small or minimally compliant companies that may not
have the same needs or incentives as larger operations.
Industry appears to be sharing waste reduction infor-
mation and assessing the costs associated with process
or material changes, the availability of effective tech-
nology, and the time necessary for implementation.
However, communication problems still exist within
developing countries and smaller job shops. Given the
diversity of the metal finishing industry, progress will
vary dramatically.
B.3.1 Cumulative Effect of Existing Policy on
Volume and Hazard Reduction
For several reasons, it is difficult to quantify the
effects of existing waste minimization policies on the
metal plating industry. First, it is difficult to measure
waste reduction and, as a result, many policies are in
place that lack mechanisms to measure their effec-
tiveness. Without these mechanisms, limited data
have been generated documenting waste minimization.
A second factor that makes quantifying effects difficult
is the existence of many different policies at different
levels of government that affect production, waste
generation, and waste management. Finally, assessing
the effects of waste minimization policy on metal
plating is complicated by the difficulty of establishing
cause and effect (i.e., that waste reduction policies
caused any reduction in waste generated). All of these
issues require additional attention. Yet, despite these
obstacles, some preliminary assessment can be
performed.
Within the United States, the most broadly used
indicator of toxics loading to the environment is the
B-3
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Implications and Evaluation of Policies
Toxics Release Inventory (TRI). The TRI measures
releases to the environment of specific chemicals from
specific industries (designated by Standard Industrial
Classification [SIC] codes). The TRI applies to U.S.
companies only.
According to progress reports assessing the
effectiveness of USEPA's 33/50 program (described
in Section 4), releases and transfers of 33/50
chemicals from all U.S. fabricated metals companies
(1,525 reporting) decreased by 31 percent between
1988 and 1991 (based on TRI data).2 Nine of the
chemicals monitored under the 33/50 program are
typically generated by metal plating operations.3 For
those fabricated metals companies that have committed
to participate in the 33/50 program, this reduction was
an even more significant 41 percent. Note that
companies participating in the 33/50 program typically
are the larger, more progressive companies within
groups I and 2.
Since the TRI data include movement of waste
off-site for treatment or disposal, the data indicating
an industry-wide reduction of releases of 31 percent
suggest that metal plating operations are reducing the
quantity of toxic constituents generated. Such reduc-
tions are arguably the result of a mix of waste minimi-
zation efforts. However, beyond attesting to the effec-
tiveness of the public reporting requirements imposed
under the TRI, these data do not identify any specific
waste minimization policy as more effective than any
other.
Reporting required under the TRI has made
many industries aware, often for the first time, of the
character and magnitude of their environmental
releases. This awareness has prompted all industries
subject to TRI requirements to seek to reduce these
releases, and these reductions have taken many forms.
Unquestionably, the vigorous promotion of waste
minimization policy has contributed to these reduc-
tions. However, other than acknowledging that the
TRI has created a major incentive for industry to
reduce releases, the industry-wide data are not
sufficient to correlate the magnitude of these
reductions with specific waste minimization policies.
In contrast, the additional incremental reductions
achieved by those metal fabricators participating in the
33/50 program suggest that a well conceived voluntary
waste minimization program can be effective in
reducing toxic releases. These companies, which
consist of 175 companies that made commitments to
participating in the voluntary program, achieved a 10
percent greater reduction than others companies in the
industry. Note that the target of the 33/50 program is
reductions of 33 percent by 1992 and 50 percent by
1995. Thus, the metal plating industry (as represented
by SIC 34) has exceeded the reduction goal by 8
percent, 1 year early. Considering its voluntary
nature, this must be viewed as an effective program
(at least for group 1 and 2 operations). Key
characteristics of the 33/50 program include its ability
to get participants to commit, at, a senior level, to
pursuing waste reduction objectives, the availability to
the TRI as a mechanism to identify inefficiencies and
measure progress, and the flexible environment
created that allows companies to use in-house
expertise and available waste minimization resources
as the situation warrants.
Generally, the TRI data indicate that the more
progressive portion of the metals fabricating industry
has substantially reduced its releases over a relatively
short period of time. Hence, some combination of
waste minimization policies (and perhaps other
policies as well) is working for the proactive sector of
the industry. As direct regulation of the metal plating
industry or chemicals used by this industry increases,
the incentive to achieve additional waste reductions
will also increase. For marginal operations, policy
approaches may need to link stringent enforcement or
streamlined regulatory requirements with waste
reduction opportunities to facilitate more environ-
mentally sound behavior.
A final point raised by the TRI data concerns
the quantity of releases from the metal fabricating
industry that are still occurring. In 1991, all U.S.
metal fabricators reporting in the TRI released
74,148,919 pounds of the 17 chemicals targeted under
the 33/50 program. Clearly, this suggests that signif-
icant opportunities for additional waste reductions
remain.
With regard to the degrees of hazard posed by
wastes generated and released by the metal plating
industry, little quantitative data are available. The
significant decrease in emissions of 33/50 chemicals
by the metal fabricators suggests that some reduction
in hazard has occurred., For example, a recent study
indicates that cyanide and chlorinated solvent usage in
U.S. plating shops has decreased by 50 and 25
percent, respectively, since 1980. Many plating shops
have completely eliminated the use of cyanide, and,
with continued improvements in non-cyanide metal
finishing, it is reasonable to expect nearly complete
substitution for cyanide processing within the next 10
to 20 years. Certainly, such changes will reduce the
hazard posed by metal finishing, although quantifying
such reduction may still prove challenging.
B.4 Barriers to Waste Minimization
B-4
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Implications and Evaluation of Policies
The most significant barriers to waste mini-
mization, as evidenced from the preceding sections
and described in the USEPA SIP Report, are
discussed in this section.
B.4.1 Regulatory and Institutional
Inconsistency in existing regulatory
requirements and enforcement actions at the
international, federal, State, and local level creates
uncertainty and possible competitive imbalances
throughout the industry. This tends to create distrust
of the regulating industry and inhibits communication.
A large number of metal finishing firms face
significant environmental liabilities and clean-up costs
if they discontinue operations and attempt to liquidate
their operations, which eliminates any access to
outside capital resources that might be used to fund
pollution prevention projects.
B.4.2 Economic and Financial
Many job shops lack the personnel and financial
resources to look beyond baseline compliance and
examine innovative techniques to prevent pollution. In
addition, there is a clear lack of full cost accounting
techniques in most countries. As a result, the evalua-
tion of the full cost-benefit impacts of waste minimiza-
tion are not realized and, therefore, not implemented.
B.4.3 Technological
Smaller shops are not active in trade association
activities and are not aware of changes in product/
process technology, including inexpensive, cost-
effective cleaner technology changes that can
dramatically improve environmental performance. In
some countries a lack of resources to enforce statutory
and/or regulatory compliance creates no incentive for
firms to look for cleaner technologies, and there is a
lack of investment in basic research on industrial
waste minimization.
B. 4.4 Industrial and Managerial
Industrial managers do not have a clear
understanding of the financial and other benefits
associated with waste minimization. In addition,
adoption of cleaner technologies often carries a greater
degree of uncertainty and risk than end-of-pipe techno-
logies. This often creates a reluctance to substitute for
cleaner products or processes.
B. 4.5 Socio-Cultural
There are significant psychological barriers to
shifting to cleaner technologies. Some companies
would rather not risk a newer technology when it is
easier to simply remain in baseline compliance. They
fear tighter regulatory standards and negative govern-
ment impacts on production, as well as enforcement
actions and loss of trade secrets when "confidential"
information is released.
B.5 Summary of Policies and Trends
International policy options to encourage or
enforce waste minimization take many forms. For
example, many countries utilize regulatory programs.
The regulatory process is complex, and each
regulatory program tends to reflect a process of
conflict and negotiation among interested parties.
Two forms of regulatory style toward the industrial
sector are used. One form relies on specified and
precise rules, such as the U.S. Clean Air Act
regulations. A second compliance style seeks to
obtain compliance with legislative goals using flexible
guidelines, allowing for situational factors, such as the
European Community's IPPC. No country appears to
rely totally on one approach or the other.
Economic instruments have been used interna-
tionally to create incentives or disincentives through
tax provisions, subsidies, fees for permits, etc. The
main purpose of these economic instruments is to
create a behavioral change by creating a financial
punishment or reward.
Information and training are critical elements
necessary to provide industry with the knowledge that
is essential to implementing waste minimization. Most
countries have programs that provide for information
and training (e.g., Nordic Council) and citizens from
more than a dozen OECD countries have logged-on
and utilized electronic information/technology transfer
from the International Cleaner Production Information
Clearinghouse (ICPIC) or the Pollution Prevention
Information Exchange System (PIES).
Ecolabeling programs have been used in many
OECD countries (e.g., Germany) to provide an
indication of the most environmentally benign product.
The market advantage of a product having an
approved eco-label often acts as a stimulus for cleaner
production (e.g., Clean Air Act labeling requirement).
Voluntary agreements are a pledge to achieve
certain environmental goals (e.g., USEPA's 33/50
program) and have met with great success. These
have advantages over command and control type
regulations because they may be implemented rapidly
and they tend to be more reflective of mutual cooper-
ation between industry and government.
In addition, liability impositions impose a strict
liability for any damage due to environmental causes.
These can act as a strong incentive to prevent the
release of toxics to all environmental media. Africa
recently negotiated the Bamako Convention, which
calls for strict and unlimited liability for hazardous
B-5
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Implications and Evaluation of Policies
waste damages. The EC has made similar proposals,
and liability impositions appear to be a growing inter-
national trend.
While historical problems still remain and have
prevented full utilization of waste minimization meth-
ods, progress has been made in most countries,
particularly among companies in groups 1 and 2.
These historical problems have been characterized by
many observers in the following ways: the generation
of waste has been regarded as peripheral to the
production process; regulatory efforts to manage the
problem have focused on end-of-pipe treatment;
regulations have taken a media-specific approach,
often resulting in the transfer of toxics from one
medium to another; the true costs of waste
management has been externalized.
Nevertheless, many countries have begun to
move beyond these outdated historical views and have
attacked the problem through a variety of policy
options. Most countries have based waste minimiza-
tion policies on laws and regulations, many of which
focus primarily on solid and municipal waste minimi-
zation. Even in the more proactive countries that have
adopted policies to address industrial waste, minimiza-
tion policies have focused on larger firms. It is
apparent that the smaller job shops are escaping a
great deal of scrutiny around the globe. Another
international trend is that many countries abdicate
responsibility to State or local levels, often resulting in
inconsistent regulation of wastes. In addition, it is
increasingly clear that despite the primary focus on
domestic waste minimization policy, international
policies such as trade (e.g., the North American Free
Trade Agreement) also have an impact on international
environmental policies.
While most OECD countries rely on many of
the policies described herein, two trends stand out as
rapidly growing. These trends are sustainable
development/sustainable industry, which relies on an
in-depth review and understanding of the unique
features of each industry in order to remove barriers
to technologies such as pollution prevention. Also,
the imposition of strict liability policies looms on the
horizon, if more environmental progress is not
evidenced in the near term. Both of these trends will
have a greater effect on the smaller "job shops" that
tend to escape notice and enforcement.
Endnotes
1 In preparing this discussion, selected information
was drawn from the U.S. Environmental Protection
Agency's (USEPA) Sustainable Industry Project (SIP).
This project represents a new approach to developing
environmental policy within the United States because
it requires industrial environmental policies to be
developed based on an in-depth understanding of the
characteristics and decision-making factors unique to
each industrial sector.
2 Based on release data for the fabricated metals
industry, SIC 34. Due to the diversity of the metal
plating industry, this SIC does not represent the entire
industry. However, it is provided here because it
represents a significant portion of the industry and it
is representative of reductions in releases that may be
achieved by metal plating.
3 Cadmium/cadmium compounds, carbon tetrachloride,
chromium/chromium compounds, cyanide/cyanide
compounds, methylene chloride, nickel/nickel com-
pounds, tetrachloroethylene, 1,1,1 trichloroethane, and
trichloroethylene.
B-6
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APPENDIX C—U.S. FEDERAL AND STATE POLLUTION PREVENTION
POLICY/PLANS
C.1 Federal Pollution Prevention Statutes
The United States has traditionally enacted envi-
ronmental legislation that tends to focus on pollution
control targeted at specific media. With the passage
of the Pollution Prevention Act (1990) and the
continuing reauthorization of the major media statutes,
this focus is shifting more and more toward pollution
prevention. At the same time, implementation of the
major U.S. laws is also shifting towards preventative
approaches where possible. The discussion below
summaries key prevention-oriented requirements of
select major U.S. laws.
C. 1. 7 The Pollution Prevention Act
A growing trend and national shift toward
reducing rather than treating waste led to the
enactment of the Pollution Prevention Act of 1990 (42
USC 13101-13109)(PPA) in October of 1990. In its
findings, Congress stated that source reduction oppor-
tunities often went unexploited because of a variety of
factors including the fact that existing regulations and
industrial resources were focused on treatment and
disposal, applicable regulations did not require or
address a multimedia approach to pollution prevention,
and there was a lack of essential information on
source reduction technologies that industry needed to
overcome institutional barriers to source reduction.
This statute established in the United States a
national policy that pollution should be prevented or
reduced at the source whenever feasible. Pollution
that cannot be prevented should be addressed through
recycling programs, and if these options are not
viable, then pollution should be treated and disposed
in an environmentally protective manner.
The PPA directed EPA to establish a source
reduction program that collects and disseminates infor-
mation, provide fiscal assistance to the states, and
become the primary federal agency responsible for
implementing the Act. The EPA issued a Pollution
Prevention Strategy in February 1991 (56 PR 7649) to
clarify its pollution prevention mission and objectives
to be accomplished. The Strategy is designed to
accomplish two primary goals: (1) to provide guid-
ance and focus for current and future efforts to incor-
porate pollution prevention principles and programs in
existing EPA regulatory and nonregulatory programs,
and (2) to set forth a program that will achieve
specific pollution prevention objectives within a rea-
sonable timeframe.
The PPA has five major provisions (Sections
6604-6608) that address developing and implementing
a national source reduction program. Section 6604
sets out a comprehensive list of activities that the EPA
Administrator is to develop as part of a strategy to
promote source reduction. Some of these activities
include:
• Developing standardized methods of measuring
source reduction
• Coordinating source reduction activities within
EPA and with other federal agencies
• Facilitating the adoption of source reduction pro-
grams by industry using the Pollution Prevention
Clearinghouse and state matching grants
• Identifying measurable source reduction goals and
an implementation strategy for the goals
• Identifying current barriers to achieving source
reduction and making recommendations to Con-
gress for overcoming these barriers
• Developing source reduction auditing procedures to
help identify source reduction opportunities in the
public and private sectors.
Section 6605 of the PPA directs EPA to establish
a matching grant program for states to promote the
use of source reduction by industry.
Section 6606 requires EPA to establish a pollution
prevention clearinghouse to compile information on
management, technical, and operational approaches to
source reduction in a computerized format. The
Clearinghouse was directed to serve as a center for
source reduction technology transfer; develop and
implement outreach and source reduction programs to
encourage states to adopt source reduction practices;
and collect and compile information on the operation
and success of state source reduction programs
operated under the matching grant program.
Section 6607 requires each owner and operator of
a facility required to comply with the reporting
requirements of SARA, Sec. 313 (toxic chemicals) to
file an annual toxic chemical source reduction and
recycling report with EPA. The report must address
such topics as: the quantity of chemical entering any
wastestream; the amount of chemical that is recycled
and the process used; any source reduction activities
associated with specific chemicals; projected amounts
of the chemical(s) that will be reported for the next
two calendar years; a comparison of chemical produc-
tion figures from the previous and current reporting
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years; any techniques used to identify source reduction
opportunities; the quantity of chemicals released as a
result of catastrophic events, remedial actions, or
other one-time events; and a comparison with similar
data from the previous reporting year.
Section 6608 requires EPA to provide a biennial
report to Congress that summarizes the data collected
under the provisions of PPA section 6607. The
congressional report must contain industry-specific
evaluations of source reduction trends by industry;
usefulness and validity of data in measuring trends in
source reduction, and the adoption of source reduction
programs by businesses; identification of regulatory
and nonregulatory barriers to source reduction, and
opportunities to use existing regulations and programs
to encourage source reduction; identification of both
industries and pollutants that require assistance in
multimedia source reduction; identification of incen-
tives needed to encourage research and development
in source reduction technologies; and an evaluation of
the technical feasibility and associated costs of source
reduction, and the identification of those specific
industries for which there exist significant barriers to
source reduction.
A significant amount of progress has been made
in implementing the PPA. In addition to reorienting
U.S. environmental programs, the PPA has prompted
the creation of programs such as the 33/50 program,
which promotes waste reduction in the metal plating
industry as well as others, and is responsible for the
development and exchange of a substantial quantity of
technical and cost data pertaining to pollution preven-
tion. The information exchange system contains
numerous case studies assessing specific pollution
prevention projects undertaken by, or applicable to,
the metals plating industry.
C. 1.2 The Resource Recovery &
Conservation Act
The Resource Conservation and Recovery Act
(RCRA) addresses the management of solid waste,
hazardous waste, and underground storage tanks that
contain petroleum or hazardous substances. RCRA
establishes a comprehensive cradle-to-grave regulatory
scheme applicable to hazardous wastes. RCRA's
hazardous waste provisions regulate wastes after they
are generated and generally do not authorize EPA to
regulate in-process materials. As such, RCRA does
not provide extensive authority to mandate pollution
prevention. RCRA does, however, provide some
authority and incentives for addressing pollution
prevention. In 1984, the Hazardous and Solid Waste
Amendments (HSWA) added several new provisions
to RCRA, some of which address pollution
prevention. These provisions make it clear that
pollution prevention is a fundamental element of U.S.
hazardous waste management policy.
HSWA established prevention of the generation of
hazardous waste as the national policy of the United
States. This policy states that "wherever feasible, the
generation of hazardous waste is to be reduced or
eliminated as expeditiously as possible." This policy
was clearly amplified in the Pollution Prevention Act
of 1990. HSWA also mandated that hazardous waste
generators and treatment, storage, and disposal facili-
ties have waste minimization programs in place.
Under RCRA Sec. 6923(b) and Sec. 6925(h),
hazardous waste generators and facilities that treat,
store, or dispose of hazardous waste generated on-site
are required to certify that they have a program in
place to reduce the volume or quantity and toxicity of
the materials that they manage. Such programs must
exist to the extent that they are economically practical.
Generators, including metal plating operations, must
include such certifications on every hazardous waste
manifest. Treatment, storage, and disposal facilities
must have a requirement for such a program as a
condition for their RCRA permit.
Wastewater treatment sludges are one of the waste
products created during the metal finishing process.
RCRA classifies these wastes and imposes technical
standards for the treatment, storage, and disposal of
each waste classification. Within RCRA Subtitle C,
EPA has subcategorized hazardous wastes from non-
specific sources in a series of "F" listings. For
example, F006 includes wastewa.ter treatment sludges
from electroplating operations (specified processes are
excluded). It is listed due to the presence of
cadmium, hexavalent, chromium, nickel, and cyanide
in the sludge. Other metal plating listed hazardous
wastes include F001 (specified spent halogenated
solvents used in degreasing), and F019 (wastewater
treatment sludges from the chemical conversion
coating of aluminum). Metal plating wastes can also
be regulated as hazardous wastes if they posses a
hazardous characteristic (per 40 CFR 261, Subpart C),
particularly toxicity.
Under Subtitle C, hazardous wastes must meet
stringent treatment standards prior to being land-dis-
posed. In November 1992, EPA promulgated
revisions to the treatment standards for spent solvents
and electroplating wastewater treatment sludges. The
revisions encourage recycling the metals in the sludge
by allowing chromium and/or nickel-bearing
electroplating sludges in high-temperature metal
recovery units to meet land ban restrictions (as an
alternative treatment standard).
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C. 1.3 The Clean Water Act
The Clean Water Act (CWA) was enacted to
restore and maintain the chemical, physical, and
biological integrity of the of the nation's waters. The
act has five main components aimed at supporting
these goals. The components are as follows: (1)
technology-based, industry specific minimum national
effluent (water discharge) standards; (2) water quality
standards; (3) a permit program for discharges to U.S.
water bodies; (4) specific provisions applicable to
certain toxic and other pollutant discharges such as
hazardous chemicals; and (5) a revolving Publicly
Owned Treatment Works (POTW) construction loan
program.
The primary purpose of these provisions is to
ensure that toxic levels of pollutants are not discharged
into the nation's waters by restricting the types and
amounts of pollutants that are discharged. These
restrictions are imposed through the use of enforceable
effluent standards specified in National Pollution
Discharge Elimination System (NPDES) permits. The
NPDES permit program relies primarily on treatment
to achieve compliance with discharge restrictions.
The CWA does, however, contain provisions that are
used to promote pollution prevention.
The most significant CWA components that
encourage pollution prevention are the effluent dis-
charge standards. These standards, which are devel-
oped for major industries, force regulated industries
such as metal finishers to either reduce the amount of
waterborne pollution that they generate or pay the cost
of treatment. To facilitate waste reduction, EPA
generally publishes in-plant controls as part of each
effluent standard development document. In-plant
controls include recommended changes to process
engineering, process management, equipment, and
manufacturing or processing systems.
The effluent guidelines and Standards for
Electroplaters (40 CFR Part 413) and Metal Finishers
(40 CFR Part 433) are under review. EPA is also
currently developing effluent guidelines and standards
for a related industry, the Metal Products and Machin-
ery Industry (40 CFR Part 438), which are due by
May 1996. Although this industry contains only
cleaning and finishing operations as captive processes,
it appears that EPA will integrate new regulatory
options for the metal finishing industry processes into
this guideline. Following the enactment of the
Pollution Prevention Act, there is a renewed emphasis
on fostering source reduction opportunities through
these effluent guidelines.
C. 1.4 The Clean Air Act
The Clean Air Act (CAA) was originally passed
in 1967 and was last amended in 1990. The CAA was
enacted to protect U.S. air quality by imposing emis-
sion standards on stationary and mobile sources of air
pollution. Compliance with the requirements imposed
under the CAA has generally relied upon the use of
end-of-pipe controls. However, several provisions
under the act do require or provide authority for
pollution prevention.
As amended in 1990, the CAA established a list
of 189 hazardous air pollutants (HAPs). Of the 56
substances from the Metal Finishing industry that were
reported in the TRI database in 1990, 33 are included
on the list of HAPs. Under the CAA, Congress
required EPA to identify major and area source cate-
gories associated with the emission of one or more
listed HAPs. To date, EPA has identified 174 catego-
ries of sources. Congress also required EPA to
promulgate emission standards for listed source
categories within 10 years of enactment of the CAA
amendments (by November 15, 2000). These stan-
dards are known as National Emission Standards for
Hazardous Air Pollutants (NESHAPs).
EPA is currently working on two NESHAPS that
will directly affect the metal finishing industry and
will provide clear opportunities for pollution
prevention. These two activities are chromium
electroplating and organic solvent degreasing/cleaning.
Chromium Electroplating - NESHAP
The chromium electroplating process emits a
chromic acid mist in the form of hexavalent chromium
and smaller amounts of trivalent chromium. Human
health studies suggest that various adverse effects
result from acute, immediate, and chronic exposure to
hexavalent chromium. As a result, EPA has proposed
a NESHAP (58 FR 65768, 12/16/93) for chromium
emissions from hard and decorative chromium
electroplating and chromium anodizing tanks.
These standards propose to limit the air emissions
of chromium compounds in an effort to protect public
health. The proposed regulation will be based on
Maximum Achievable Control Technology (MACT)
and will impose a performance standard limit on chro-
mium and chromium compounds emissions based upon
concentrations in the waste stream.
EPA suggests that these proposed performance
standards allow a degree of flexibility since facilities
may chose their own technology as long as the emis-
sions standards (established by MACT) are achieved.
The proposed standards differ according to the sources
(e.g., old sources of chromium emissions will have
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different standards than new ones), further reducing
the standards' rigidity through the recognition of
diverse sources.
Organic Solvent Depressing/Cleaning -
NESHAP
EPA has also proposed a NESHAP (58 FR 62566,
11/29/93) for the source category of halogenated sol-
vent degreasing/cleaning that will directly affect the
metal finishing industry. This proposed standard aims
at reducing halogenated solvent emissions to a MACT-
equivalent level, and will apply to new and existing
organic halogenated solvent cleaners (degreasers)
using any of the HAPS listed in the CAA. EPA is
specifically targeting vapor degreasers that use the
following HAPs: methylene chloride,
perchloroethylene, trichloroethylene, 1,1,1-
trichloroethane (see also the International Section
4.7.1 concerning a ban under the Montreal Protocol),
carbon tetrachloride, and chloroform.
This NESHAP proposes to implement a MACT-
based equipment and work practice compliance stan-
dard (the CAA provides EPA with authority to
establish stringent emissions limits as well as to
require process or material modification as necessary
to reduce risk). This would require that a facility use
a designated type of pollution prevention technology
along with proper operating procedures. However,
EPA has also provided an alternative compliance
standard. Existing operations, which utilize perfor-
mance-based standards, can continue in place if they
can be shown to reach the same limit as the equipment
and work practice compliance standard.
Ozone Depleting Substances
The CAA also contains provisions addressing
ozone protection requirements. The Act creates Class
1 and Class II substances and a phaseout schedule for
each. The phaseout dates for Class I substances are
the year 2000 for CFCs, halon, and carbon tetrachlo-
ride; 2002 for methyl chloroform (1,1,1-Trichloro-
ethane). Class H substances (HCFCs) would be
phased out by 2030. (President Bush mandated an
acceleration of the phaseout schedule in 1992.) The
CAA also mandates warning labels on products
containing Class I or II substances and calls for the
establishment of a safe alternatives program.
Numerous EPA regulations affecting the metal
finishing industry have been promulgated under the
CAA. For example regulations to implement the
requirements of the Montreal Protocol were published
in 1992 (57 FR 33754). The final rule concerning
warning labels for Class I and II ODS was published
by EPA in 1993 (58 FR 8136) and EPA's list of
approved alternatives was published on March 18,
1994 (59 FR 13044). A listing of the industries affec-
ted by the warning label requirement was released by
the EPA and included a broad range of manufacturing
operations including metal finishing. Manufacturing
facilities are required to determine if any Class I or II
substances are used in their manufacturing operations
and label their products accordingly. Many businesses
are opting to substitute non-ODS Siubstances for Class
I or II substances to avoid the stigma of the labeling
requirement.
C. 1.5 Emergency Planning and Community
Right-to-Know Act
Under the Emergency Planning and Community
Right-to-Know Act (EPCRA), EPA has implemented
the Toxics Release Inventory (Tin). This program,
although not primarily focused on achieving pollution
prevention, has created strong incentives for
companies to reduce waste generation. The TRI
requires companies within specified standard industrial
classifications to report the quantities of certain toxic
chemicals released to the environment. The release
data, cumulatively known as the Toxic Release
Inventory, is published by EPA. The TRI is intended
to inform the public and industry of the nature and
magnitude of toxic releases and to prompt increased
scrutiny of such releases. It has resulted in substantial
public pressure on companies to improve
environmental performance as well as increased efforts
by industry to improve efficiency, often through
pollution prevention-based approaches. The TRI has
also emerged as a primary mechanism used to
measure pollution prevention, although there are
acknowledged limits to its use in this capacity. The
TRI indicates that between 1988 and 1992 the
fabricated metals industry (SIC 34) reduced releases of
TRI chemicals by 26.1 percent (137 million pounds to
101 million pounds). TRI data also identifies at least
one chemical used by the metal plating industry as
among the 10 chemicals released in the greatest
quantity in the United States (1,1,1-Trichloroethane).
C.2 Enforcement
C.2.1 Innovative Environmental Enforcement
Programs (SEPs)
EPA's commitment to vigorous enforcement of
environmental law is reflected both in the significant
expansion in recent years of its civil, criminal, and
federal facility enforcement activities and its move-
ment beyond traditional enforcement measures. EPA
has moved beyond enforcement of media-specific laws
to emphasize cross-program, multi-media
enforcement. In addition, EPA has increased its use
of creative enforcement techniques that use
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environmental enforcement authority to promote
pollution prevention.
EPA's strong enforcement program encourages
pollution prevention by providing incentives for
industries to find ways to reduce its potential liabilities
and response costs. In addition, the enforcement
process is used directly against noncompliers to
promote pollution prevention.
In 1990, EPA's Office of Enforcement developed
a draft policy on including pollution prevention
conditions in Agency settlements. When conducting
negotiation the EPA may consider whether there are
opportunities to correct an environmental violation
through single or multi-media source reduction
activities (e.g., reducing the source of emissions
through changes in the industrial process or by
production process input substitutions). Settlements
are also used to encourage the respondent to undertake
additional pollution prevention activities. Such
innovative settlements are known as "supplemental
environmental projects" (SEPs).
In February of 1991, James Strock, EPA
Assistant Administrator, issued a memorandum to
clarify the new Agency policy on the use of SEPs in
Agency consent orders and decrees. This
memorandum indicated that in settling environmental
enforcement cases, the United States will insist upon
terms which require defendants to achieve and
maintain compliance with federal environmental laws
and regulation. In certain instances, additional relief
in the form of projects remediating the adverse public
health or environmental consequences of the violations
at issue may be included in the settlement to offset the
effects of the particular violation which prompted the
suit. As part of the settlement, the size of the final
assessed penalty may reflect the commitment of the
respondent to undertake SEPs. (Memorandum:
Policy on the Use of Supplemental Enforcement
Projects in EPA Settlements, to Regional
Administrators, et al., from James Strock, February
12, 1991.)
In recent years, EPA has increasingly relied on
the use of SEPs and a number of cross-media
pollution prevention consent orders and decrees have
been negotiated. For example, as part of a TSCA
consent order, the 3-V Chemical Corporation agreed
to install a solvent recycling system that is expected to
reduce by 50 percent the point source emissions of
1,1,1 -trichloroethane and dichloromethane. Although
SEPs have been used most often in settlement of
EPCRA violations, they have potential application to
the metal finishing industry since it is subject to
RCRA regulation and amenable to ample source
reduction opportunities.
C.3 Voluntary Programs
USEPA has numerous voluntary programs aimed
at educating, encouraging, and assisting industry and
other entities in implementing pollution prevention
programs and activities. A description of these pro-
grams follows.
C. 3.1 EPA's 33/50 Program
EPA's 33/50 Program was announced early in
1991 as a voluntary pollution prevention initiative
seeking to achieve significant reductions in pollution
in a relatively short period of time. Under this
program, EPA identified 17 high priority toxic
chemicals selected from the Toxic Release Inventory
(TRI) based on factors including high production
volume, high releases and offsite transfers of the
chemical relative to total production, opportunities for
pollution prevention, and their potential for causing
detrimental health and environmental effects.
EPA established a goal of reducing the total
amount of these 17 chemicals released into the
environment and transferred offsite by 33 percent by
the end of 1992 and 50 percent by the end of 1995
(using 1988 as a baseline). EPA's goal is to achieve
these reductions primarily through pollution prevention
practices going beyond regulatory requirements. EPA
is also encouraging industry to develop a source
reduction approach and seeking to continue pollution
prevention programs even beyond these chemicals and
levels of reduction.
Success in the program will be measured by
nationwide reductions rather than results at individual
facilities or companies. EPA has contacted numerous
companies, both large and small, with information on
the 33/50 Program and to solicit their participation.
Companies are being asked to identify and implement
cost-effective pollution prevention practices related to
the 17 chemicals and to develop written commitments
stating their goals and plans to achieve them.
All of the 33/50 Program chemicals are regulated
under one or more of the existing environmental
statutes. The 33/50 Program is intended to comple-
ment, not replace ongoing programs. All 17 of the
chemicals will be subject to the Maximum Achievable
Control Technology (MACT) standards of the CAA.
EPA believes that the incentive for early reductions
offered by the MACT provisions will further the
progress of the 33/50 Program.
The 17 target chemicals are list below (those in
bold are chemicals typically generated by the metal
plating industry):
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• Benzene
• Cadmium & Cadmium Compounds
• Carbon Tetrachloride
• Chloroform (Trichloromethane)
• Chromium & Chromium Compounds
• Cyanide & Cyanide Compounds
• Lead & Lead Compounds
• Mercury & Mercury Compounds
• Methyl Ethyl Ketone
• Methyl Isobutyl Ketone
• Methylene Chloride (Dichloromethane)
• Nickel and Nickel Compounds
• Tetrachloroethylene (Perchloroethane)
• Toluene
• 1,1,1-Trichloroethane (Methyl Chloroform)
• Trichloroethylene
• Xylene.
It should be noted that on May 25, 1993, EPA
officially released the TRI reporting data for 1991.
One of the noteworthy findings revealed that releases
and transfers of 33/50 Program chemicals declined by
34 percent from the 1988 baseline. That is to say,
EPA surpassed the Program interim national goal of
33 percent reduction a full year ahead of schedule.
C.3.2 Waste Reduction Evaluations at
Federal Sites (WREAFS)
The Department of Defense is cooperating with
EPA and other federal agencies in the Waste
Reduction Evaluation at Federal Sites (WREAFS)
Program. The WREAFS Program has two primary
objective. These objectives are to evaluate pollution
generating processes at federal facilities for source
reduction and recycling opportunities. The second
objective is to enhance the adoption of pollution
prevention and recycling through technology transfer
to the public and private sector using project reports,
project summaries, conference presentations, and
workshops.
The WREAFS Program is essentially a series of
assessments to find ways to reduce or prevent
pollution. Some of the opportunities can be imple-
mented by the facility without significant engineering
changes. Other opportunities require research, devel-
opment, and demonstration projects before options can
be implemented. The technical and economic feasibil-
ity are also considered. Adoption of any
recommendation is at the sole discretion of the
facility.
Waste minimization opportunities have been
identified under the WREAFS Program for numerous
military and industrial processes for various federal
agencies and DoD facilities. Some of these
opportunities involve metal plating operations.
C.3.3 Design for the Environment
Since pollution prevention has gained in popularity,
many firms are directing their environmental efforts
earlier in the production cycle, often as far upstream
as the product design process. The design stage is the
most critical and effective time to address the environ-
mental impacts. The design phase affords the greatest
amount of flexibility in choosing everything from raw
materials to manufacturing technique. Many aspects
of Design for the Environment (DIE) have evolved out
of the field of Industrial Ecology.
Recently, interest in Industrial Ecology and DfE
have become more pronounced following the adoption
of German legislation that requires manufacturers and
retailers to collect and recycle packaging for a wide
range of products. Firms will have to recycle 80 per-
cent beginning in 1995. This type of policy develop-
ment has led to increased scrutiny of how products are
designed.
Major redesign efforts in international manufac-
turing have also been identified as a result of the
Montreal Protocol, a treaty which requires industrial
nations to discontinue production and use of most
CFCs by 2000.
The DfE Program focuses on pollution prevention
and environmental risk. DfE promotes the incorpora-
tion of environmental considerations and risk reduction
in the design of products and services. The Program
works on a voluntary basis through partnerships with
industry and the public. It builds on voluntary EPA
programs like the 33/50 Program.
The DfE Program has initiated a number of wide-
ranging projects which operate through three levels of
involvement:
1. Infrastructure projects are the broadest in scope
and aimed at changing general business practices hi
order to remove barriers to behavioral change and
to provide incentives for undertaking environmental
design and pollution prevention efforts.
2. Industry projects are joint efforts with trade associ-
ations and businesses in specific industry segments
to evaluate comparative risks, performance and
costs of alternatives.
3. Facility-based program activities will help indi-
vidual businesses undertake environmental design
efforts of their own through the development and
application of specific methods, tools, and models.
DfE uses analytical tools such as "use clusters"
and "substitutes assessments" to examine alternatives.
The DfE Program has developed a methodology for
examining substitute chemicals, processes, andtechno-
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logies. Through a process of collecting information
on currently existing alternatives and through a search
for other promising options the DfE Program lists all
alternatives in a "use cluster tree" for chemicals,
processes, and technologies that can substitute for one
another in performing a particular function. In this
way DfE systematically compares the trade-offs
associated with given alternatives.
Cleaner Technology Substitutes Assessments
(CTSAs) are intended to provide a flexible format for
systematically comparing the trade-off issues associ-
ated with alternatives. Traditional trade-offs such as
cost and performance are brought together with envi-
ronmental trade-offs, including comparative risk,
releases, energy impact and resource conservation for
each alternative. EPA is working industry to provide
guidance through the DfE Program. Several industry
specific cooperative projects have already been
undertaken.
EPA has begun a joint Metal Finishing DfE
project with the Industrial Technology Institute and the
Cleveland Advanced Manufacturing Program. This
project is funded as a Technology Reinvestment
Project, and its purpose is to develop an integrated
Energy, Environment, and Manufacturing (EEM)
assessment methodology for the metalworking
industry.
The EEM assessment methodology is intended to
be an auditing tool that will allow businesses to
conduct energy, environment, and manufacturing
audits. DfE will concentrate its efforts on metal
finishing and will evaluate the comparative, multi-
media risks of alternative chemicals, processes, and
technologies. The DfE process begins with an
evaluation of specific steps in metal finishing
processes to target those of highest risk. In order to
do this DfE will work through the Industrial
Technology Institute to engage the metal finishing
industry as a partner in the project. A metal finishing
industry profile will be developed which will provide
background information on the industry and help select
target areas.
C.3.4 The Source Reduction Review Project
(SRRP)
Section 4(b) of the Pollution Prevention Act of
1990 required EPA to "review regulations of the
Agency prior and subsequent to their proposal to
determine their effect on source reduction." In
response to this charge, EPA created the Source
Reduction Review Project (SRRP). SRRP is a major,
Agency-wide initiative that is demonstrating the value
and feasibility of taking a source reduction approach
in designing environmental regulations. The Agency
is conducting an in-depth analysis of source reduction
measures and cross-media issues in the development of
24 rule-makings for air toxics (MACT standards),
water pollution (effluent guidelines), and hazardous
wastes (listing determinations).
The goal of the SRRP is to foster the use of
source reduction measures as the preferred approach
for achieving environmental protection, followed in
descending order by recycling, treatment, and, as a
last resort, disposal. The project will initially ensure
that source reduction measures and multi-media issues
are considered in the development of forthcoming air,
water, and hazardous waste standards affecting 17
industrial categories.
Notwithstanding the inclusion of source reduction
approaches in the past, SRRP will emphasize rigorous
technical and economical analysis as the means for
incorporating source reduction into regulations, as
well as on coordinating a multi-media approach to
rulemaking.
For the Degreasing MACT Standard, SRRP is
considering a regulatory option of an equipment/work
practice standard with a solvent consumption indicator.
Also, an alternative under consideration is an idling
emissions limit with an overall solvent use limit.
Almost all measures that are being considered as the
basis of the equipment standard option are source
reduction measures. The alternative standard would
provide flexibility to encourage technological innova-
tion.
C.3.5 Pollution Prevention Grants
USEPA provides grants to support pollution
prevention efforts to states and initiates jointly funded
grant programs with other federal agencies. The
centerpiece of EPA's pollution prevention grant acti-
vities for the last several years is an ongoing program
know as Pollution Prevention Incentives for States
(PPIS). PPIS is intended to build and support state
pollution prevention capabilities and to provide an
opportunity to test innovative approaches and metho-
dologies at the State level.
Section 5 of the Pollution Prevention Act of 1990
authorizes EPA to make matching grants to states to
promote the use of source reduction techniques by
business. Eligible participants include states
(including State Universities) and federally recognized
Indian tribes. Local governments, private universities,
private non-profit groups, businesses, and individuals
are not eligible. However, organizations excluded
from applying directly are encouraged to work with
eligible State agencies in developing proposals that
would include them as participants in the projects.
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EPA strongly encourages this type of cooperative
arrangement.
In general, the purpose of PPIS is to support the
establishment and expansion of State-based pollution
prevention programs. Organizations receiving grants
are required to match federal funds by at least 50
percent. State contribution may include dollars and/or
in-kind goods and services. For example, the State of
Massachusetts, Department of Environmental Manage-
ment has awarded a grant to expand their technical
assistance source reduction program. Their pilot
project included training, workshops and development
of a financial feasibility model for use by company
managers to determine the cost effectiveness of source
reduction and recycling alternatives focusing on
electroplaters and metal finishers.
In addition, EPA provides between 600 and 800
million dollars each year for specific media grants to
states and/or regions. These grants help support states
to implement federal programs like the Clean Water
Act, the Clean Air Act, and RCRA. Pollution
Prevention Grant Guidance, in effect since November
of 1992, provides states with the flexibility to use
these funds to support multi-media pollution
prevention initiatives to the extent permitted by statute
or regulation.
EPA also enters into jointly funded grants with
other federal agencies. One example is EPA's Nation-
al Industrial Competitiveness Through Efficiency:
Energy, Environment and Economics (NICE3).
NICE3 is a joint project with the Department of
Energy and EPA to provide grants to improve energy
efficiency, advance industrial competitiveness, and
reduce environmental emissions by industry. Large-
scale research and demonstration projects are targeted
at industries with the highest energy consumption and
greatest levels of toxics and chemicals released. An
example is a recent NICE3 project to develop UV-
curable coatings for aluminum can production.
C.3.6 Technology/Policy Transfer - PPIC/
ICPIC/OzonActon
Section 6606 of the Pollution Prevention Act of
1990 required EPA to establish a pollution prevention
clearinghouse to compile information on management,
technical, and operational approaches to source reduc-
tion in a computerized format. The clearinghouse was
directed to serve as a center for source reduction tech-
nology transfer, develop and implement outreach and
source reduction programs to encourage states to adopt
source reduction practices, and collect and compile
information on the operation and success of source
reduction programs.
New technologies are emerging daily and regula-
tory pressures on industry create the need for a rapid
and efficient transfer of information. The Pollution
Prevention Information Clearinghouse (PPIC) and its
on-line bulletin board/database component called the
Pollution Prevention Information Exchange System
(PIES) were created by EPA to facilitate this flow of
information to industry, government policy makers,
and the public.
PPIC is a free clearinghouse service that consists
of a repository of technical, policy, legislative, and
programmatic information concerning pollution
prevention and recycling. The PPIC repository also
contains a hotline service to refer questions and take
document orders. PIES is a 24-hour electronic
network accessible by personal computer and modem
which is free to all users. PIES contains an
interactive message center where pollution prevention
professionals can communicate; bulletins; a calendar
of events concerning cleaner production and pollution
prevention seminars, workshops, and conferences;
program summaries; a directory of experts; and
technical information in the form of fact sheets and
case studies highlighting pollution prevention
techniques. Numerous case studies and fact sheets
relevant to the metal finishing industry are available
through PPIC and PIES.
PIES has become a global information network
and provides a unified access point for related elec-
tronic networks. PIES is now electronically linked to
similar systems such as the United Nations Environ-
mental Programme's (UNEP) International Cleaner
Production Information Clearinghouse (ICPIC) and the
UNEP OzonAction Information Clearinghouse. These
systems support global exchange of pollution preven-
tion information and alternatives to ozone depleting
substance alternatives and technologies. All of these
systems contain technical and policy information
relevant to the plating industry for large and small
applications.
C.4 State Programs
State programs are summarized by State in
Exhibit C-l. This exhibit provides the State's status,
program definition, materials, priorities, who is
covered, policies, what information is accessible, and
the funding.
C-8
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C-10
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Exhibit C-1. Common Elements of State Pollution Prevention Plans (Continued)
State/Status
Georgia
Mandatory
enacted '90
Illinois
Voluntary
enacted '89
Indiana
Voluntary
enacted '90
Definitions
Reduction:
- hazardous waste
No statewide numeric
goals
Prevention:
- toxic pollution
No statewide numeric
goals
Prevention js
reduction of:
- toxic material use
- waste release
^Jo statewide numeric
goals
Materials
Georgia
hazardous and
acute hazardous
waste
SARA toxic
substances and
Illinois lists
CERCLA
lazardous
substances and
ndiana
^environmental
wastes"
Priorities
Includes:
- input, process,
product change in-
house recycle
Excludes:
- treatment
- media transfer
- volume change
- incineration
Includes:
- input, process,
product change in-
house recycle
Excludes:
- treatment
- media transfer
- volume change
- incineration
Includes:
- input, process,
product change in-
house recycle
Excludes:
- off-site recycle
- media transfer
- incineration
Coverage
Includes:
- large quantity
generators
- out-of-state large
quantity
generators using
Georgia TSDs
Voluntary and pilot
(Cooperation on
permits)
- generators
Voluntary and pilot
Policies
- Technical
assistance
- Facility planning
- Technical
assistance
- Innovation
- Inspectors' manual
- Explore
enforcement
- Research (HWRIC)
- Technical
assistance
- Research
- Grants
- Generator planning
manual
Access
Plans/reports
available to public;
trade secrets
available only to
state
Trade secrets
protected
Trade secrets
protected
Funding
Not based on
fees
General fund
and money
raised by
HWRIC activity
General fund
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Exhibit C-1. Common Elements of State Pollution Prevention Plans (Continued)
State/Status
Wisconsin
Voluntary
enacted '89
Definitions
Use and Release
Reduction'
- toxic pollutants
- hazardous waste
and substances
Pollution Prevention
No statewide numeric
goals
Materials
SARA, RCRA
Priorities
Includes:
- input, process,
product change,
closed-loop
recycling
Excludes:
- incineration
- treatment
- out-of process
recycling
- media transfer
Coverage
Voluntary
Includes:
- hazardous waste
generators
- hazardous
substance users
Policies
Voluntary
- Waste audits
- Research
- Grants
Mandatory
- Waste min.
documentation on
manifests and
reports
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APPENDIX D—POLLUTION PREVENTION CONTACTS
D.1 U.S. EPA Program Contacts
D. 1.1 Agriculture in Concert With the
Environment (ACE)
For general information on the ACE program,
contact:
Harry Wells
Office of Pollution Prevention (7409)
U.S. EPA
401 M. Street, SW
Washington, DC 20460
202-260-4472
G.W. Bird
Director, USDA Sustainable Agriculture
Research and Education Program
342 Aerospace Building
14th and Independence Avenues
Washington, DC 20250
Patrick Madden Ph.D.
Associate Director, USDA Sustainable Agriculture
Research and Education Program
P.O. Box 10338
Glendale, CA 91209
D. 1.2 National Industrial Competiveness
Through Efficiency: Energy,
Environment and Economics (NICE3)
Eligible industries are in SIC Codes 26 (paper),
28 (chemicals), 29 (petroleum and coal products), and
33 (primary metal industries).
For more information, contact:
David Bassett
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street, SW (7409)
Washington, DC 20460
202-260-2720
D. 1.3 Pollution Prevention Incentives for
States (PPIS)
National Eligibility Criteria
• Must be pollution prevention as defined by the Act.
• Multimedia opportunities and impacts should be
identified.
• Areas for significant risk reduction should be
targeted.
• Other pollution prevention efforts in the state
should be leveraged and integrated into the project.
• Measures of success are identified.
• A plan for dissemination of project results should
be identified.
Along with the National Eligibility Criteria,
regional pollution prevention offices may develop their
own region specific guidance. Interested applicants
should contact their regional pollution prevention
coordinator for more information.
Headquarters contact:
Lena Hann
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M. Street, SW (TS-779)
Washington, D.C. 20460
202-260-2237
D. 1.4 33/50 Program
Announced early in 1991, EPA's 33/50 Program
is a voluntary pollution prevention in a relatively short
period of time.
Under this program, EPA has identified 17 high
priority toxic chemicals. EPA's Administrator has set
a goal of reducing the total amount of these chemicals
released into the environment and transferred offsite
by 33 percent at the end of 1992 and by 50 percent at
the end of 1995.
For More Information:
For copies of a brochure on the 33/50 Program or
other information, fax your request to the TSCA
Assistance Service at 202-554-5603. Or call the
TSCA Hotline at 202-554-1404 from 8:30 a.m. to
4:00 p.m. EST. Also, computer users may access the
33/50 mini-exchange in PIES (see Section 7 on PIES).
D. 1.5 Design for the Environment (DfE)
Established in October 1992, EPA's Design for the
Environment Program (DfE) is a voluntary
cooperative program which promotes the incorporation
of environmental considerations, and especially risk
reduction, at the earliest stages of product design.
DfE Program has initiated a number of wide-
ranging projects which operate through two levels of
involvement. Industry Cooperative projects work with
specific industry segments to apply substitute assess-
ment methodology, share regulatory and comparative
risk information, and invoke behavioral change Infra-
structure projects are aimed at changing aspects of the
general business environment which affect all indus-
tries in order to remove barriers to behavior change
and provide models which encourage businesses to
adopt green design strategies.
D-1
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Pollution Prevention Contacts
EPA's DfE Program is working closely with trade
associates and individuals- in three-specific industry
segments. These cooperative projects will develop
Substitutes Assessments, which compare risk and
environmental trade-offs associated with alternative
chemicals, processes, and technologies and which will
provide models for other businesses to follow when
including environmental objectives in their designs.
The DfE Program has awarded 6 grants to
universities which fund research into alternate syn-
thesis of important industrial chemical pathways.
Results of the research will provide the chemical
industry with tools for production which reduce risk
and prevent pollution. The grants are providing a
model for further National Science Foundation grants.
For more information contact:
Pollution Prevention Information Clearinghouse
U.S. Environmental Protection Agency
401 M. Street, SW (PM-211A)
Washington, DC 20460
202-260-1023
DfE Metal Finishing Project
Contact: Brian Sweeney, 202-260-0702
Source Reduction Review Project
Degreasing MACT Standard: Analysis of Potential
substitutes to halogenated solvents will inform industry
of any potential cross-media impacts that might result
from solvent substitution.
Contact: Paul Almodovar, 919-541-0283;
Chuck Darvin, 919-541-7633
Office of Solid Waste:
Haile Marian
U.S. EPA
401 M Street, S.W. 5302W
Washington, DC 20460
Phone: (703)308-8439
Fax: (703)308-8433
D.2 U.S. EPA Regional Office Pollution
Prevention Contacts
Tlie individuals identified below are the official
contacts for pollution prevention matters concerning
the EPA Regional Office initiatives and the 33/50
Program. Summaries of each Region's pollution pre-
vention activities can be found in the Pollution
Prevention Information Exchange System (described in
section 7).
Region I
Mark Mahoney, Manager
Abby Swaine, Manager
Pollution Prevention Program
U.S. EPA Region I (PAS)
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Mahoney: Phone: 617-565-1155
Fax: 617-565-3346
Swaine: Phone: 617-565-4523
Fax: 617-565-3346
Dwight Peavey
33/50 and ENERGI Programs
U.S. EPA Region I (ATR)
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Phone: 617-565-3230
Fax: 617-565-4939
Norman Willard
Green Lights and ENERGI Programs
U.S. EPA Region I (ADA)
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Phone: 617-565-3243
D.2.1 Region II
Janet Sapadin, Pollution Prevention Coordinator
U.S. EPA Region II
26 Federal Plaza, Rm. 900
New York, New York 10278
Phone: 212-264-1925
Fax: 212-264-9695
Nora Lopez
33/50 Program
U.S. EPA Region H (MS: 105)
2890 Woodbridge Avenue, Building 10
Edison, New Jersey 08837-3679
Phone: 908-906-6890
Fax: 908-321-6788
D.2.2 Region III
Lorraine Urbiet
Pollution Prevention Coordinator
Environmental Assessment Branch
Environmental Services Division
U.S. EPA Region HI
841 Chestnut Building (3ES43)
Philadelphia, Pennsylvania 19107
Phone: 215-597-6289
Fax: 212-597-7906
Billy Reilly
33/50 Program
Special Assistant, Air, Radiation, & Toxics Division
U.S. EPA Region ffl (3AT01)
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Phone: 215-597-9302
Fax: 215-349-2011
D-2
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Pollution Prevention Contacts
D.2.3 Region IV
Carol Monell
Chief, Pollution Prevention Unit
Policy, Planning, and Evaluation Branch
Office of Policy and Management
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Phone: 404-347-7109
Fax: 404-347-1043
Beverly Mosely
33/50 Program
U.S. EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
Phone: 404-347-1033
Fax: 404-347-1681
D.2.4 Region V
Kathy Allon
Pollution Prevention Coordinator
Planning and Budgeting Branch
Policy and Management Division
U.S. EPA Region V
77 West Jackson Blvd.
Chicago, Illinois 60604-3590
Phone: 312-886-2910
Fax: 312-886-5374
Dennis Wesolowski
33/50 Program
Acting Chief, Asbestos Control Section
Environmental Science Division
U.S. EPA Region V (MS: SP-14J)
77 W. Jackson Blvd.
Chicago, Illinois 60604
Phone: 312-353-5907
Fax: 312-353-4342
D.2.5 Region VI
Dick Watkins, Pollution Prevention Coordinator
Donna Tisdall, Grants Coordinator
Office of Planning and Evaluation
U.S. EPA Region VI
1445 Ross Avenue (6M-P)
Dallas, Texas 75270
Watkins: Phone: 214-655-6580
Fax: 214-655-2146
Tisdall: Phone: 214-655-6528
Fax: 214-655-2146
Lewis Robertson
33/50 Program
U.S. EPA Region VI (MS: 6T-P)
Dallas, Texas 75202
Phone: 214-655-7582
Fax: 214-655-2164
D.2.6 Region VII
Steve Wurtz, Pollution Prevention Manager
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
Phone: 913-551-7050
Fax: 913-551-7063
Carl Walter
33/50 Program
Deputy Director, Air and Toxics Division
U.S. EPA Region VH (MS: ARTX)
726 Minnesota Avenue
Kansas City, Kansas 66101
Phone: 913-551-7600
Fax: 913-551-7065
D.2.7 Region VIII
Don Patton, Chief
Sharon Childs, Program Analyst
Policy Office
U.S. EPA Region VII
999 18th Street, Suite 500
Denver, Colorado 80202-2405
Patton: Phone: 303-293-1627
Fax: 303-293-1198
Childs: Phone: 303-293-1454
Fax: 303-293-1198
Kerry Whitford
33/50 Program
Toxic Release Inventory Program
U.S. EPA Region VIII(MS: 8ART-AP)
999 18th Street, Suite 600
Denver, Colorado 80202-2405
Phone: 303-294-7684
Fax: 303-293-1229
D.2.8 Region IX
Jesse Baskir, Program Coordinator
Hilary Lauer, Program Coordinator
Pollution Prevention Program
U.S. EPA Region IX
75 Hawthorne Street (H-l-B)
San Francisco, California 94105
Baskir: Phone: 415-744-2190
Fax: 415-744-1796
Lauer: Phone: 415-744-2189
Fax: 415-744-1796
D-3
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Pollution Prevention Contacts
Helen Burke
33/50 Program
TRI Coordinator
U.S. EPA Region IX (MS: A-4-3)
75 Hawthorne Street
San Francisco, California 94105
Phone: 415-744-2189
Fax: 415-744-2153
Bill Wilson, Waste Minimization Coordinator
Hazardous Waste Management Division
75 Hawthorne Street (H-l-W)
San Francisco, California 94105
Phone: 415-744-2153
Mike Stenburg
Green Lights Coordinator
Air and Toxics Division
78 Hawthorne Street A-l
San Francisco, California 94105
Phone: 415-744-1102
D.2.9 Region X
Carolyn Gangmark
Pollution Prevention Coordinator
Policy, Planning and Evaluation Branch
U.S. EPA Region X
1200 Sixth Avenue (MD-142)
Seattle, Washington 98101
Phone: 206-399-4072
Fax: 206-553-4957
Claire Rowlett, Environmental Protection Specialist
Community Relations Policy Section
Hazardous Waste Policy Division
U.S. EPA Region X
1200 Sixth Avenue (HW-113)
Seattle, Washington 98101
Phone: 206-553-1099
Jayne Carlin
33/50 Program
U.S. EPA Region X (MS: AT-083)
1200 6th Avenue
Seattle, Washington 98101
Phone: 206-553-0890
Fax: 206-553-8338
D.3 Pollution Prevention Information
Clearinghouse
The Pollution Prevention Information Clearing-
house (PPIC) is dedicated to reducing or eliminating
industrial pollutants through technology transfer,
education, and public awareness. It is a free, nonreg-
ulatory service of the U.S. EPA, and consists of: a
repository, a telephone reference and referral service
and a computerized information exchange system.
Phone:
Fax:
Mail:
Telephone service is available to answer or refer
questions on pollution prevention or the PPIC and take
orders for documents distributed by the PPIC.
202-260-1023
292-260-0178
Pollution Prevention Information
Clearinghouse
Environmental Protection Agency,
PM211-A
401 M Street, SW
Washington, DC 20460
D.3.1 Enviro$en$e
Anyone can access Enviro$en$e using either an
IBM PC (or compatible), Apple, or a dumb terminal
equipped with a modem (2400 or 14,400 baud), and
appropriate communications software. Enviro$en$e is
accessible through a regular telephone call, the
SprintNet network and the EPA X .25 wide area
network (for EPA employees only). The following
communications software settings are required if you
are calling Enviro$en$e on a regular telephone line:
Phone Number: 703-908-2092
Speed:
Data Bits:
Parity:
Stop Bits:
Emulation:
2400 or 14,400
8
None
1
ANSI or VT-100
A short, 2-page, "Enviro$en$e Quick Reference
Guide" was written to help new users log-on to and
use the system. This guide can be requested by
calling the Enviro$en$e technical support office. An
Enviro$en$e User Guide is available and may be
obtained free of charge by leaving a message on the
system addressed to "Sysop", or by writing or calling
the Clearinghouse.
Phone: 703-821-4800
Fax: 703-821-4775
D.3.2 Internationa/ Cleaner Production
Information Clearinghouse (ICPIC)
The International Cleaner Production Information
Clearinghouse (ICPIC) is the PPIC's sister clearing-
house operated by the United Nations Environment
Program (UNEP). The ICPIC provides information
to the international community on all aspects of low-
and non-waste technologies and methods. Patterned
after the PPIC, the ICPIC has similar functions and
components, including an electronic information
exchange system that is indirectly accessible to PIES
users through nightly exchange of messages on the
PIES Main Menu message center. For more informa-
tion about the ICPIC, contact the PPIC (see above) or
the ICPIC at the address below.
D-4
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Pollution Prevention Contacts
Jacqueline Aloisi de Larderl, Director
United Nations Industry and Environment Office
39-43 quai Andre" Citroen
75739 Paris CEDEX 15
France
33-1-44-3714-50
33-1-44-3714-74 Fax
D.3.3 OzonAction
OzonAction was newly established by UNEP in
1992 under the Interim Multilateral Ozone Fund
(IMOF) of the Montreal Protocol Agreements. Ozon-
Action relays technical and programmatic information
on alternatives to all ozone depleting substances
identified by the IMOF. OzonAction contains inform-
ation on five industry sectors: solvents, coatings and
adhesives; halons; aerosols and sterilants;
refrigeration; and foams. Later this year OzonAction
will contain the OZONET data bases on solvent
substitutes, compiled by the Industry Cooperative for
Ozone Layer Protection (ICOLP). For more
information on OzonAction, contact the director,
UNEP Industry and Environment Office listed above.
Jacqueline Alois de Larderl, Director
United Nations Industry and Environment Office
39-43 quai Andre Citroen
75739 Paris CEDEX 15
France
33-1-44-3714-50
33-1-44-3714-74 Fax
D.3.4 American Institute for Pollution
Prevention (AIPP)
The AIPP was founded jointly by U.S. EPA and
the University of Cincinnati in 1989 to assist EPA in
promoting the widespread and expeditious adoption of
pollution prevention concepts. The institute accomp-
lishes this mission through developing informational
and educational materials; participating in waste reduc-
tion demonstration projects; conducting economic,
programmatic, and technological analyses; and assist-
ing government, universities, and industry in identify-
ing and resolving various pollution prevention issues.
The institute consists of a group of 25 volunteer
experts selected by their professional societies,
agencies, and trade associations. These experts parti-
cipate in four councils that undertake various tasks:
Economics Council, Education council, Imple-
mentation Council, and Technology Council.
Thomas R. Hauser, Ph.D., Executive Director
American Institute for Pollution Prevention
Department of Civil and Environmental Engineering
University of Cincinnati
Cincinnati, Ohio 45221-0071
Phone: 513-556-3693
D.3.5 The National Roundtable of State
Pollution Prevention Programs
(Roundtable)
The Roundtable is a group of pollution prevention
programs at the State and local level in both the public
and academic sectors. Typically, member programs
are engaged in a broad range of activities, including
multi audience training and primary to post-secondary
pollution prevention education, supported by a variety
of State and Federal funding sources. The roundtable
is coordinated through biannual conferences as well as
ongoing activities. Conferences serve in part as
opportunities for updates on member programs'
progress, including their training efforts. The first
conference in 1993 is scheduled for April 28-30.
(October conference TEA) The Roundtable is funded
through a U.S. EPA grant.
David Thomas
National Roundtable of Pollution Prevention Programs
One East Hazelwood Drive
Champaign, Illinois 61820
Phone: 217-333-8940
Fax: 217-333-8944
D.3.6 Waste Reduction institute for Training
and Applications Research, Inc.
(WRITARJ
WRITAR is a private, independent, nonprofit
organization designed to identify waste reduction
problems, help find their solutions, and facilitate the
dissemination of this information to a variety of public
and private organizations. The institute is also the
current administrator of the U.S. EPA grant to the
National Roundtable of State Pollution Prevention
Programs (see above). WRITAR has an extensive
background in designing and delivering persuasive
pollution prevention training to Federal, State, and
local regulators, inspectors, and administrative
staffers, and well as to corporate and public
audiences. This existing activity is supplemented by
a 1991 grant from the U.S. EPA Office of Pollution
Prevention to support pollution prevention training for
the States through U.S. EPA Regional staff.
WRITAR also conducts industry-specific training
(primarily in metal finishing) for more narrowly
defined audiences.
Terry Foecke or Al Innes
Waste Reduction Institute for Training and Applica-
tions Research
1313 5th Street, S.E.
Minneapolis, Minnesota 55414-4502
Phone: 612-379-5995
D-5
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Pollution Prevention Contacts
Fax: 619-379-5996
D.4 OECD Waste Minimization Workshop
Participants
OECD/OCDE PREPARATORY MEETING FOR
THE WASTE MINIMIZATION WORKSHOP, 26
July 1994
DA. 7 List of Participants
CANADA
Mr. Dave Campbell
Environment Canada
Waste Management Branch
351 St. Joseph Boulevard
Hull, Quebec
Tel. 1-819-953-1119
Fax. 1-819-997-3068
FRANCE
Mr. Gerard Bertolini
Centre National de la Recherche Scientifique
University Claude Bernard Lyon I
43 Bd. du 11 Novembre 1918-Batiment 101
69622 Villeurbanne Cedex
Tel. 33-72.44.82.64
Fax. 33-72.44.05.73
Mr. Francis Chalot
Sous Direction des Produits et des Dechets
Ministere de 1'environnement
20 av. de Segur
75007 Paris
Tel. 33-1.42.19.15.47
Fax. 33-1.42.19.14.68
GERMANY (ALLEMAGNE)
Mr. Berthold Goeke
Ministry for Environment, Nature Conservation and
Nuclear Safety
Kennedy Alice 5
53175 Bonn
Tel. 49-228.305.25.71
Fax. 49-228.305.23.99
NETHERLANDS (PAYS-BAS)
Mr. Melchior Bus
Ministry of Public Housing Physical Planning and
Environmental Protection
Directorate of Waste Management Policy/645
P.O. Box 30945
2500 GX The Hague
Tel. 31-70.339.41.88
Fax. 31-70.339.12.84
UNITED STATES (ETATS-UNIS)
Mr. Haile B. Mariam
Waste Minimization Branch - Mail Code 5302W
U.S. EPA
401 M. Street, S.W.
Washington, D.C. 20460
Tel. 1-703.308.84.39
Fax. 1-703.308.84.33
CEC (ECE)
Mr. Etienne Le Roy
Commission of the European Communities
DG XI A.4
200 rue de la Loi
B-1049 Bruxelles
Tel. 32-2.299.03.67
Fax. 32.2.299.10.68
UNEP (PNUE)
Mr. Fritz Balkau
Programme des Nations Unies Pour 1'environment
Tour Mirabeau
39-43 Quai Andre Citroen
75739 Paris Cedex 15
Tel. 33-1.44.37.14.39
Fax. 33-1.44.37.14.74
OECD Secretariat
Ms. Rebecca HANMER, Head
Pollution Prevention and Control Division
Tel. 33.1.45.24.98.70
Mr. Harvey YAKOWITZ, Administrator
Tel. 33.1.45.24.78.80
Ms. Soizick de TILLY, Consultant
Tel. 33.1.45.24.79.06
Ms. Michele ANDERS, Consultant
Tel. 33.1.45.24.96.96
Mr. Hugh CARR-HARRIS, Consultant
Mr. Fabio VANCINI, Consultant
Tel. 33.1.45.24.76.95
D-6
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