Pollution Prevention and Control Technologies
for Plating Operations
Section 2 - General Waste Reduction Practices
2.2 POLLUTION PREVENTION AND SOURCE CONTROL
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
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
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.
Next Section|Main Table of Contents|Section 2