III. RECOMMENDATIONS

E. Specific Recommendations

The Metal Finishing Subcommittee makes the following specific recommendations.

1. Emissions and Risk Characterizations. Highest priority should be given to developing and applying simple methods to characterize the emissions from plating operations and from them the risks to workers, surrounding communities, and the environment.

EPA should convene a group of Agency and non-Agency experts to review existing methods and develop an R&D plan for developing new, simple emissions and risk characterization methods that will be easy and inexpensive to use and the results of which will be easily understandable by metal finishers, regulatory staffs, and the public.

Some specific R&D projects that need to be carried out include:

a. developing simplified risk assessment procedures for hexavalent chromium emitted from surface finishing processes--e.g., to assess the risks before and consequent to application of technologies to meet the new CAAA chromium emissions MACT standard;


b. developing methods for determing cyanide concentrations in waste water and solids--e.g.,


i. to determine whether complexed cyanide in F-006 wastes meets HWIR II delisting requirements


ii. developing methods to measure low cyanide concentrations in a wastewater; and


c. developing methods to determine the environmental impact of complexed cyanide in F-006 waste under present stabilization/disposal practices.

2. Hexavalent Chromium. Highest priority should be given to continuing and expanding the R&D on various aspects of reducing and eliminating multi-media emissions from hexavalent chromium plating operations.

EPA should pursue the following steps.

a. EPA and AESF should focus their forthcoming FY97 joint research grant solicitation on the topic of hard chrome plating emissions reduction and elimination.


Other Federal agencies (e.g., NIST, DOD, DOE, and NSF), other EPA offices (e.g., OECA, OW, and OPPT), and private sector organizations (e.g., MFSA) should be invited to participate in the funding of this solicitation and any future solicitation.


b. EPA should convene a symposium of public and private sector funders, performers, and suppliers of chrome plating R&D and materials, as well as client users such as DOD and the automotive and aircraft industries, to set out a specific agenda for R&D in this area.


c. The R&D agenda should focus on:


i. studying the best existing closed-loop and no- or low-emission chrome plating processes to see how they achieve these objectives;


ii. developing and demonstrating new, preferably simple, approaches to achieve these ends; and


iii. developing and applying simplified risk assessment methods to determine the risks to workers, the community, and the environment of exposure to emissions from existing chrome plating operations and as before and after measures to determine the effectiveness of technologies to meet the new CAAA chromium emissions MACT standard.


d. The agenda should identify specific R&D objectives, specific R&D projects to meet those objectives, who should fund the various R&D projects, who should perform them, over what time period, and at what cost.


e. A Steering Committee of appropriate representatives from the organizations identified in b, above, should be created to oversee the development and carrying out of the R&D agenda for the period of time specified in d, above.

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. More specifically,

a. R&D should be carried out on recycle/reuse for existing cyanide baths. In particular, research on optimization of existing baths for recovery and recycle of cyanide-containing solutions and chemicals.


b. R&D should be conducted to develop improved analytical procedures for total and especially amenable cyanide in water and solid wastes, including:


i. determining how low concentrations of cyanide can be measured in wastewater,


ii. determining whether complexed cyanide in F-006 wastes meets HWIR II delisting requirements, and


iii. determining the environmental impact of complexed cyanide in F-006 waste under present stabilization and disposal practices.

4. Off-Site Recovery. High priority should be given to demonstration of methods of off-site recovery of metals, acids, and cleaners. These demonstrations should concentrate on:

a. on- or off-site recovery--not in-process recovery, which is defined as pollution prevention;


b. membrane, ion exchange, evaporation, and electrolytic systems; and


c. giving special attention to acid recovery from pickling solutions.

5. Chlorinated Solvents. The following R&D areas related to replacement and reduction in the use of chlorinated solvents were given high priority for further research:

a. Investigate low emission and emissionless chlorinated solvent vapor degreasing systems for metal plating operations. Which do the best job? What are the emissions?


b. Evaluate 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. In particular:

a. 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 should be evaluated. Can simple techniques reduce air and waterborne cadmium levels to below the OSHA PEL?


b. Already completed cadmium replacement R&D should be publicized. A literature search should be conducted 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 point-of-contact for additional information.

8. Technical Assistance. Increased technical 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.
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