EXECUTIVE SUMMARY

This National Metal Finishing Environmental R&D Plan was developed under the auspices of the Common Sense Initiative (CSI). The Common Sense Initiative Council (CSIC) is a Federal Advisory Committee created to provide advice to the Administrator of the Environmental Protection Agency (EPA). The CSI Council has six industrial sector subcommittees--auto manufacturing, electronics and computers, iron and steel, metal finishing, petroleum refining, and printing. Each Subcommittee brings together stakeholders appointed by the EPA Administrator to identify important issues, conduct demonstration projects, and develop consensus policy recommendations which, with the endorsement of the CSIC, are forwarded to the Administrator. The stakeholders include industry, labor, environmental groups, environmental justice groups, State and local government, other Federal agencies, and other appropriate individuals. This Plan was endorsed by the Metal Finishing Subcommittee. It will be submitted to the CSIC for its consideration.

The Metal Finishing Subcommittee has created seven work groups--Regulatory and Reporting, Research and Technology, Promoting Improved Performance, Environmentally Responsible Transition, Compliance and Enforcement, Access to Capital, and Strategic Goals. This Plan was developed by the Research and Technology Work Group. Prior to the creation of CSI, the metal finishing industry and EPA's Office of Research and Development (ORD) had started to hold informal and formal meetings of metal finishing research funders and metal finishers to get a sense of what research was being conducted and what the research needs are. Once CSI was created, the Work Group and Subcommittee endorsed the continuation of those efforts in order to develop this Plan.

A sub-work group was created to work on the Plan. That group decided, based on input from industry and other stakeholders, that: (1) the Plan should focus on a few of the highest priority R&D areas and (2) it should concentrate on simple, low-cost, pollution prevention technologies that would be of direct benefit to small platers in meeting and exceeding Federal, State, and local environmental compliance standards. This approach directly supports the sector's strategic National Performance Goals.

The priority research areas included selected materials of concern: cadmium, cyanide, hexavalent chromium, and chlorinated solvents. Priority cross-cutting issues included: verification protocol development, wastewater treatment, emissions and risk characterization, off-site metal recovery processes, technical assistance projects, life cycle cost model development, and environmentally friendly strippers.

The Plan was outlined, draft inputs were submitted by sub-group members, and a number of possible criteria were developed for selection of research and development (R&D) projects. Progress and direction of the Plan were discussed at Research and Technology Work Group meetings that were held both in conjunction with the Subcommittee's periodic meetings and in conjunction with the AESF annual COMPLIANCE Week in Orlando, Florida, and annual SUR/FIN meetings in Baltimore, Maryland, and Cleveland, Ohio. These latter meetings enabled a much wider group of metal finishers and experts to attend and provide input, review, and comments on the direction and content of the Plan.

Based on these inputs, 74 possible research areas and projects were identified. Three summary criteria were created to simplify rating the projects. The criteria related to the likely impact of the project in achieving or exceeding compliance requirements; achieving widespread adoption within the industry; and reducing risks to workers, the surrounding community, and the environment. EPA sent rating forms to members of the Subcommittee and Work Group and other individuals who had previously participated in their meetings. The American Electroplaters and Surface Finishers Society (AESF) sent copies to their Research Board and Environmental Committee members. Ratings were received from 27 experts who reprensented all the stakeholder groups.

The consensus of the raters was that all the general areas for research were high priority, confirming the selection of these areas by the Work Group. The top approximately twenty-five percent of the rated projects was taken as the highest priority group. Based on these 18 projects, two general recommendations and eight specific recommendations were developed. The General Recommendations are: (1) EPA and other Federal agencies should use this Plan to coordinate and support R&D directed toward the needs of the metal finishing industry and (2) EPA should use this Plan as a possible approach for other sectoral environmental R&D plans.

The Specific Recommendations are: (1) Emissions and Risk Characterization. Highest priority should be given to developing and applying simple methods to characterize the emissions from plating operation and from them the risks to workers, surrounding communities, and the environment. (2) Hexavalent Chromium. Highest priority should be given to continuing and expanding R&D on various aspects of reducing and eliminating multi-media emissions from hexavalent chromium plating operations. (3) Cyanide. R&D should focus on reducing cyanide emissions and developing improved analytic methods to determine the presence, concentration, and impacts of cyanide in waste streams. (4) Off-Site Recovery. High priority should be given to demonstration of methods of off-site recovery of metals, acids, and cleaners. (5) Chorinated Solvents. R&D should focus on low emission and emissionless chlorinated solvent vapor degreasing systems for metal plating operations and on evaluating alternatives to chlorinated solvents for cleaning--especially new, alternative cleaners that have recently come on the market. (6) Rapid Verification Protocol. A Rapid Verification Protocol should be developed that would provide information on technology performance, cost, and maintenance requirements on which companies could base decisions to purchase technologies. The published protocol would be made available to interested parties. A process could be set up, perhaps with EPA authorization, to verify protocol results. (7) Cadmium. R&D should be carried out to reduce cadmium emissions and to seek alternatives to its use. (8) Technical Assistance. Increased technology assistance should be provided to the metal finishing industry through developing and disseminating a series of short, well-researched, peer-reviewed articles on the selection and use of simple technologies for improved environmental performance for each of the major metal finishing operations that utilize the materials of concern discussed in this Plan.

The Plan will be used to direct ORD research related to metal finishing. It will also permit the coordination and targeting of other public and private sector funding on the highest priority R&D areas. The Plan will be disseminated to appropriate parties. It will be revised in the future as progress is made in R&D on these priority areas and other concerns develop.