I. R&D GOALS

B. BACKGROUND

This Plan has been prepared under the auspices of the EPA Common Sense Initiative (CSI). The Common Sense Initiative brings together all relevant stakeholders for a particular industrial sector to develop and implement cleaner, cheaper, and smarter environmental management for that sector. Two of the key elements of this effort, as identified by the EPA Administrator, are pollution prevention and innovative technology. The purpose of this Plan is to set some priorities for research and development (R&D) on pollution prevention and innovative technologies that will enable the metal finishing sector to achieve the CSI goals of cleaner, cheaper, and smarter environmental management.

CSI has been organized under the Federal Advisory Committee Act (FACA) as an Advisory Council to the EPA Administrator that is called the CSI Council. The Council has a subcommittee for each of the six industrial sectors that are part of CSI. The Metal Finishing Sector is co-chaired by the EPA Assistant Administrator for Research and Development, the EPA Assistant Administrator for Policy, Planning, and Evaluation and the Regional Administrator for the Northeast Region. The Metal Finishing Subcommittee has created five work groups, one of which is the Research and Technology Work Group. This plan is being prepared under the authority of the Metal Finishing FACA Subcommittee and the direction of the Research and Technology Work Group (see the list of the Work Group members in the Appendix).

EPA has adopted a hierarchy for environmental management that places pollution prevention as the most desirable approach. Preventing pollution requires a knowledge of the inputs to, operations of, and emissions from industrial operations. Preventing pollution may be accompanied by, or if that is not possible, replaced by recycling. In-process recycling is considered pollution prevention; recycling that goes to different processes in the same facility or to different facilities on- or off-site is considered next best to pollution prevention and is the second level of the hierarchy. In the past, environmental management largely consisted of the next lower levels in the hierarchy which are, respectively, treatment and responsible disposal. This plan will focus on pollution prevention, but recognizes that these other elements of environmental management will be appropriate at times for the metal finishing industry.

The term R&D has a broad meaning as applied to the needs of the metal finishing sector. R&D as used here includes the following components:

Characterizing emissions and risks. Platers, environmental groups, community groups, labor, and regulators all need and want to know what emissions are coming out and in what amounts from metal finishing operations and what risks those emissions create for workers, the surrounding communities, and the environment. To answer these questions it is necessary to the inputs to and emissions from the plating operation(s) of concern. Emissions and, preferably risk, reduction are the best ways to evaluate the effectiveness of pollution prevention and control technologies in meeting compliance standards and in going beyond compliance.

Development of new technologies. New technologies are constantly needed for preventing, recycling, treating, disposing of, and remediating pollution. They are necessary to cost-effectively meet existing and new environmental standards. As used here, new technology means both creating innovative technologies that enable an entirely new way of doing things and modification of existing technologies for new applications. As a result, the R&D can range from laboratory development to pilot scale testing to field trials of a technology. The intent of this Plan is to weigh more heavily on the applied type of research, although it is recognized that completely new approaches can provide valuable solutions to pollution problems.

Demonstration of existing technologies. One of the main problems that small metal finishers face addressing pollution problems in their plants is what technologies to select and from which vendor. There is currently a paucity of verified testing results on the effectiveness and efficiency of various environmental technologies. Demonstrations are most valuable if they are performed in a working metal finishing operation. Next best is demonstrations using the same, or similar, equipment to that used in actual metal finishing operations, but in a non-operational setting. Providing performance verification through demonstration and evaluation is a high priority for this R&D Plan. The focus will be on evaluation and modification of typical processes so that the results will be as widely applicable to the industry as possible.

Documenting and optimizing industrial operations. The metal finishing industry can be divided into tiers according to the environmental performance of various companies. It is important to document the nature, effectiveness, and cost of the pollution prevention and other environmental management methods that companies use to achieve different levels of environmental performance given the different metal finishing processes that they use. This information can be analyzed and shared with other companies that want to improve their environmental performance. It is also important to see how existing processes can be optimized to reduce toxic inputs and pollution created.

Developing and/or applying tools for doing R&D. Conducting R&D that will be useful to industry and other users requires tools and techniques that ensure that accurate, reliable, reproducible, and usable data will be developed. In assessing the performance of new and existing technologies, for example, it is necessary to have testing protocols that will meet the highest standards of test plan development and data collection and analysis. Similarly, these high quality procedures are important when collecting baseline performance data for benchmarking purposes. Having agreed-upon analytic tools and procedures for the industry will enable vendors, testers, and users to know how the information they are creating or using fits within a broader set of similar information for the industry.

Transfer of technology and diffusion of technical information. Because the metal finishing industry is made up of many small companies, it is vital that information about the availability, use, effectiveness, and cost of pollution management technologies be made easily available to these companies. Developing strategies for disseminating the information created as a result of the R&D carried out under this Plan is an essential part of the Plan itself. This information must be presented, packaged, and transmitted in a very user-friendly manner. The transfer should largely take advantage of existing dissemination vehicles and, if possible, allow for interactive question-and-answer mechanisms by the user.

To be consistent with the general thrust of the CSI Metal Finishing Subcommittee this R&D Plan is limited in scope to the definition of metal finishing as encompassed by SIC Code 3471. This includes inorganic coatings and related cleaning and rinsing operations, but excludes painting.

It is intended that this Plan will mainly be of interest to metal finishers and their professional and industrial associations and to Federal and private sector metal finishing R&D funders and performers. It is likely, however, that both the Plan and the resulting R&D also will be of interest to vendors of chemicals and equipment to the metal finishing industry, Federal and private sector clients of the metal finishing industry, regulators of and technical assistance providers to the metal finishing industry, and other stakeholders who have a concern about the risks from metal finishing operations.