NATIONAL METAL FINISHING ENVIRONMENTAL R&D PLAN

III. RECOMMENDATIONS

C. Findings

A number of the respondents made general and/or specific comments on the projects. One common thread was that the projects presented for rating were all or mainly on target in terms of being the most important ones for R&D to meet the industry's needs. No matter what a respondent may have thought about the overall list of projects, every respondent had at least some projects that he or she rated highly.

Perhaps one of the most revealing findings from these ratings is that on many projects established, recognizably knowledgeable people gave diametrically opposite ratings on specific projects. Not only that, they emphasized how strongly they felt by writing on the rating form comments such as "absolutely critical" in support of and "stupid" in opposition to doing R&D on that topic. More moderate comments in these modes were "great" and "good" or "lots of research has already been done on this." Again, such comments were made on the same projects or project areas.

The diversity of the opinions expressed in these ratings seems, in effect, to validate these findings. While this diversity of opinion may be healthy for the industry, it indicates how difficult yet important it is to get a good cross-section of input as this rating process did. Otherwise, any particular subset of this group that might be gathered in a meeting to determine R&D priorities could, with the best intentions in the world and with dedicated effort, come up with a wholly different set of recommendations than would a different subset of this group. In addition, if specific individuals were more likely to talk or be deferred to in such meetings and their preferences recorded as the priorities of the group, this diversity would not be captured.

Yet, for all the diversity in the extremes of the feelings and ratings of particular R&D areas and projects by different individuals, the rating process was able to produce clear prioritizations among the projects.

This may in part also be due to the fact that the rating process forced the respondents to consider the full range of criteria that had been suggested--as represented in the three surrogate criteria. This meant that no single criterion carried the day as far as overall priority for the projects is concerned. Rather R&D areas and projects had to have been rated high on all three criteria by many respondents to obtain an overall score high enough to put them in the top rank of projects.

There were some comments related to the role of the private sector--i.e., the suppliers--in doing the R&D being considered here. Others related to the role suppliers could play in providing input on what R&D has been done in certain R&D areas and what is already commercially available. These are good topics for future discussion.

The easiest way to see what recommendations make sense from these findings is to look at the highest scored R&D areas and projects from the ratings. There are 18 projects that received scores over 170. This is approximately one-quarter of the total of 74 projects, which many respondents considered the most important R&D topics to begin with. The top projects with their scores are the following.

TOP-RANKED R&D PROJECTS
Score
R&D Area/Project

193
Emissions Characterization. Characterization of air emissions from plating baths is needed for both compliance purposes and to better evaluate risk. Emissions modeling based on emissions sampling is needed for Toxic Release Inventory reporting. The data collected could also support risk characterization studies for estimating worker health and safety, community health, and ecological risks.

187
Chromium. Develop and demonstrate innovative closed-loop processes for chromium processing solutions.Evaluate methods to control discharges to air and water and to recycle chemicals back into the processing tanks in existing shops.

184
Risk Characterization. Contributors to this research plan often voiced concern that there is not enough data on risk characterization to support regulations. More research is needed to help establish risk levels; better understanding of risks imposed by emissions would help prioritize future research projects.

182
Chromium. Assess the risks before and consequent to application of technologies to meet the new CAAA chromium emissions MACT standard.

182
Chromium. Evaluate methods to control discharges to air and water and to recycle chemicals back into the processing tanks in new installations--concentrating on the best installations extant.

182
Cyanide. Determine how low cyanide can be measured in a wastewater matrix.

180
Chlorinated Solvents. Improvements to Vapor Degreasing. Investigate low-emission and emissionless chlorinated solvent vapor degreasing systems. Which do the best job? What are the emissions?

180
Cyanide Projects. Investigate recycle/reuse for existing cyanide baths.Study the optimization of existing baths for recovery and recycle of cyanide-containing solutions and chemicals. Drag-out tanks are often the simplest and least expensive method of recovery.

180
Cyanide. Analytical Methods. Develop improved analytical procedures for total and especially amenable cyanide in water and solid wastes.Determine whether complexed cyanide in F-006 wastes meet Hazardous Waste Identification Rule II (HWIR II) delisting requirements.

180
Cyanide. Cyanide environmental impact. Investigate environmental impact of complexed cyanide in F-006 waste under present stabilization/disposal practices.

180
Off-Site Metals Recovery Processes. Several plan contributors recommended that the plan consider the need for metals, acid, and cleaner recovery processes that are on-site or off-site, but not necessarily in-process (in-process meets the pollution prevention (p2) definition). Membrane systems, ion exchange, evaporation, and electrolytic systems were mentioned as in need of demonstration for metals recovery. Demonstration of acid recovery from pickling solutions waspointed to as an especially important need.

179
Chromium Projects. Develop simplified risk assessment methodologies to determine the risks associated with the use of chromium in surface finishing processes, as indicated below.Assess the risks to workers in different job classifications from exposures due to working in various plating processes that use hexavalent chromium.

178
Rapid Verification Protocol Development. Develop a rapid verification protocol that would provide information on technology performance, cost, and maintenance requirements on which companies could base decisions to pursue technologies. The RVP would result in a report that would be made available to interested parties. A process could be set up, perhaps with EPA authorization, to verify protocol results.

177
Cadmium. Evaluate the effectiveness of simple techniques such as ventilation, tank covers, floating balls, etc., to reduce airborne cadmium levels and similarly simple techniques to reduce water discharges of cadmium during manufacturing, use, and rework. Answer: Can simple techniques reduce air and waterborne cadmium levels to below the OSHA PEL?

176
Technical Assistance Projects Develop 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.

177
Chromium. Study and demonstrate closed-loop chromium shops. How do they do it?

174
Cadmium. Publicize already completed cadmium replacement research.Use a literature search to produce guidance (perhaps as an article in a journal) for when and how industries should replace cadmium coatings. The article should include successes, failures, and points-of-contact for additional information.

172
Chlorinated Solvents Projects. Evaluate alternatives to chlorinated solvents for cleaning.Evaluate new, alternative cleaners that have recently come on the market.

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