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.
Score | |
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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