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Pollution Prevention and Control Technologies for Plating Operations
Section 2 - General Waste Reduction Practices
2.2 POLLUTION PREVENTION AND SOURCE CONTROL
2.2.1 Definitions
Pollution prevention, as defined by EPA, is the maximum feasible reduction of all wastes (wastewater, solid waste and air emissions) generated at production sites. It involves the judicious use of resources through source reduction, energy efficiency, reuse of input materials during production and reduced water consumption. Source reduction is the highest priority in the U.S. EPA's Environmental Management Options Hierarchy (Exhibit 2-1). It is defined as the use of materials, processes, or practices that reduce or eliminate the creation of pollutants or wastes at the source (ref. 26, 302).
There are two general methods of source reduction that can be used in a pollution prevention program: product changes and process changes. Product changes are changes in the composition or use of the intermediate or end products that are performed by the manufacturer with the purpose of reducing waste from manufacture, use, or ultimate disposal of the products. This method of pollution prevention is addressed in Section 5. Process changes are manufacturing modifications that impact how the product is produced. These methods of pollution prevention are discussed in this section and in Section 5. Process changes include: input material changes, technology changes and improved operating practices. Typically, improved operating practices can be implemented more quickly and at less expense than input material and technology changes. Examples of these source reduction options are shown in Exhibit 2-2.
There are a number of pollution control measures that are applied only after wastes are generated. They are, therefore, not correctly categorized as pollution prevention. Exhibit 2-3 provides some examples of procedures that are waste handling, not source reduction measures. Because these procedures are classified as waste handling, their implementation may not provide pollution prevention credits under certain state or Federal statutes. However, their implementation may be beneficial both in terms of environmental protection and cost reduction and therefore should not be overlooked.
Facilities are required to have pollution prevention programs for wastes classified as hazardous. The applicable Federal regulations include:
The Resource Conservation and Recovery Act (RCRA) requires that facilities with permits for treatment, storage, or disposal implement a program to reduce the volume or quantity and toxicity of these wastes.
The Pollution Prevention Act (PPA), specifies that facilities required to report releases to the U.S. EPA for the Toxic Release Inventory (TRI) provide documentation of their procedures for preventing the release of these materials or for reusing these materials. The PPA encourages that the preferred method of preventing pollution is to reduce the volume of waste generated at the source and to perform reuse (closed-loop recycling) whenever possible.
- The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), requires generators of hazardous waste to evaluate and document their operations.
- In addition to Federal regulations covering this topic, many states have enacted legislation that requires pollution prevention. As of March 1992, a total of 26 states had passed such legislation (ref. 302). These states are listed in Exhibit 2-4.
- Source reduction methods have been well documented and utilized within the metal finishing industry for more than 20 years to: (1) reduce input material use, waste generation, energy use, and production costs; (2) minimize worker exposure to hazardous chemicals; and (3) improve product quality (ref. 1).
EPA has developed a systematic procedure for identifying, evaluating and implementing source reduction and other pollution control methods (Exhibit 2-5), which is termed the Pollution Prevention Assessment Procedure. Published materials are available that specifically relate this methodology to the metal finishing industry (ref. 25, 378).