Metal and acid recovery options for the plating industry

conservation ELSEVIER

Resources, Conservationand RecyclingI9 (1997) 55-71

mcycUug

Metal and acid recovery options for the plating industry Susan M. Morgan a'*, Cindy M.

Lee b

aDepartment q[ Civil Engineering, Southern Illinois University at Edwardsville, Campus Box 1800, Edwardsville, IL 62026-1800, USA bDepartment of Environmental Systems Engineering, Clemson UniversiO,. Clemson, SC 29634-0919, USA

Abstract

The metal plating and finishing industry loses large amounts of raw materials, and while pollution prevention (P2) techniques and technologies are being used, there appears to be a disparity among platers in the extent of implementation. Surveys and interviews of South Carolina metal platers and finishers were conducted to explore the reasons for the lack of implementation of P2, to assess the extent of metal and acid recovery practiced, and to determine interest in various options for increasing recovery. Both standard recovery options (in-house recovery and centralized recovery facilities for sludge, spent solutions, and equipment rental) and innovative recovery options (rotating or shared recovery equipment and plating-industry specific and integrated industrial parks) were examined. All recovery options were compared with conventional treatment and each other based on technical, economic, and institutional factors. Although all the recovery options examined are conceptually feasible and have similar benefits, they are not all economically and institutionally feasible at this time for South Carolina platers. Based on the results of this research, it is recommended that platers, regulators, trade associations, and other parties in South Carolina focus on in-house recovery, including encouraging departments within captive plating shops to share recovery equipment. Platers in other regions as well as other industries will also find this research applicable. The two main variables that could change the results are geographic location, which affects transportation costs, and the political climate, which affects the desire to attract industry and the flexibility of the regulatory agencies. Copyright © 1997 Elsevier Science B.V. * Corresponding author. Tel.: + 1 618 6925014; fax: + l 618 6922555. 0921-3449/97/$17.00 Copyright ,~5 1997 Elsevier Science B.V. All rights reserved PII $092 1-3449(96)0 l 183-4

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Keywords: Pollution prevention; Metal and acid recovery; Recycling; Industrial waste

1. Introduction

Environmental management has evolved from simply complying with regulations to eliminating waste and, thus, the need for compliance. Pollution prevention (P2) offers a means to improve productivity and profits through decreased inefficiency in production processes as well as through decreased environmental management costs. There are also consequences for not pursuing P2. Klassen (1995) found that companies pursuing P2 reported 'significantly better manufacturing performance' while companies which were not pursuing P2 'had their competitive difficulties compounded - - they were left struggling on both manufacturing and environmental performance' [1]. Hirschhorn (1993) predicted that companies failing to refocus from end-of-pipe pollution control to P2 will not remain competitive in the global marketplace [2]. One industry in which there is a lack of P2 implementation is metal plating and finishing (Standard Industrial Classification, SIC, 34). This industry is critically important to the US. Kennedy and Gupta (1978) stated that: 'The strategic importance of the industry cannot be underestimated; indeed...there are [not] many industries which, if forced to cease production, could as effectively cripple the industrial productivity and capacity of the United States' [3]. Plating facilities contributed US$23.6 billion, or 0.5%, to the US gross domestic product (GDP) in 1993 while the total metal finishing industry, including suppliers, contributed nearly US$47 billion, or 1%, of the annual GDP [4]. Metal plating and finishing has been identified as an industry with wastes of significant potential for environmental impact and with opportunities for waste reduction [5]. Metal finishers and platers use a wide variety of chemicals, but 'only a very small percentage of the purchased chemicals wind up incorporated in the finished good[;]...the vast majority...currently wind up as 'waste" [6]. This situation corresponds to expensive waste treatment. In addition, the lost raw materials can represent a substantial investment; in 1980, the total cost of metals lost in the US electroplating industry amounted to approximately US$40 million [7,8]. Despite P2's proven effectiveness in many industries, including metal plating and finishing, many platers still rely heavily on conventional precipitation wastewater treatment systems. Of the respondents to a survey conducted by the National Center for Manufacturing Sciences and the National Association of Metal Finishers (NCMS/NAMF), only 50% had established P2 programs [9]. In addition, no more than 55% recovered metals and no more than 11% recovered acids despite the large quantities of metals and acids used (and lost) in the industry [9]. Foecke (1993) wrote that 'it's a peculiarity of the plating industry that many possibilities exist for source reduction, and yet implementation has remained limited' [10]. While Duke (1989) found that plating firms in California shipping

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more than 5 tons of RCRA-regulated hazardous waste were 'relatively active in attempting to minimize [their] hazardous waste', he also found that P2 had not fully permeated the industry and that, despite the simplicity of 'low-tech' P2 techniques (such as good housekeeping, longer workpiece drainage times, and reduced parts' loss), 'the typical plant has not implemented all routine operating procedures which are justified by the cost of hazardous waste management' [11]. Dane (1988) stated that 'even the most innovative [southeast Massachusetts jewelry plating] shops have not implemented all of the possible source reduction technologies' [12]. While this is confusing considering the benefits that can be realized through reduced hazardous waste generation, it must be realized that there are significant barriers to P2 implementation. As the US Environmental Protection Agency (EPA) is well aware, some of the more serious obstacles are generated by the regulatory environment. Carol Browner, EPA Administrator under President Clinton, stated that 'too many of our current regulations have the perverse effect of discouraging pollution prevention' [13]. Other barriers arise within the plating industry from insufficient allocation of capital resources, organizational inertia, internal politics, managerial and production concerns that block the use of innovative approaches, and a lack of management commitment. However, because waste management costs are escalating and discharge limits are decreasing, more platers are considering recovery options - - including inhouse recovery, rotating (or shared) recovery equipment, centralized recovery, and enhanced-recovery industrial parks. This research was undertaken to compare comprehensively these recovery options on their technical, economic, and institutional merits. Surveys mailed to and interviews with South Carolina metal platers and finishers measured their attitudes and practices regarding metal and acid recovery, ways to increase recovery, and the potential roles of other parties in increasing recovery by the plating industry. A survey of South Carolina industrial park developers and managers measured their interest in developing or managing enhanced-recovery industrial parks. Morgan (1995) discussed the development of the surveys, data collection and analysis, and errors [14]. Conventional precipitation was used as the baseline case against which the four recovery options were compared. In addition, the recovery options were compared against one another using ion exchange (because centralized recovery facilities typically use this technology). Table 1 presents the response rates to the two surveys conducted. The plating survey response rates compare favorably with response rates to other surveys of the plating industry [4,9]. Although the number of completed surveys was low, it is believed that the respondents were representative of both the South Carolina plating industry and South Carolina industrial park developers and managers. Therefore, the results, although not statistically analyzed, are indicative of prevalent attitudes.

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Table 1 Survey response rates Category

Plating industry survey a

Industrial park survey b

Respondents - - completed survey Respondents - - survey N/A c

18 (18%) 22 (22%)

19 (56%) (12%)

Subtotal

40 (40%)

23 (68%)

Non-respondents Total

58 (59%) 98 (99%)

11 (32%) 34 (100%)

aPercentages do not add to 100 due to rounding. bSome responses obtained from interviews were used to partially complete surveys. CThis category is for those who responded that they do not plate or that they do not develop or manage industrial parks.

2. Results and discussion 2.1. Conventional treatment

Option 1 is the baseline case of platers continuing to rely solely on conventional treatment and sludge landfilling. From the data collected in this research, 28% of South Carolina platers currently rely solely on conventional treatment and sludge landfilling. Nationally, average operating costs for systems (including sludge disposal, treatment reagents, and labor) are US$15 per 3785 1 processed; if sludge disposal is excluded, the costs are US$11.25 per 3785 1 [9]. The average operating cost for South Carolina platers (without sludge disposal) is almost US$7 more per 3785 1 - - at US$18 per 3785 1, with an outlier of US$200 per 3785 1 excluded. Annual maintenance costs typically are 6% of investment costs while taxes and insurance are 1% [15]. In addition, sewer fees are levied by local publicly-owned treatment works (POTWs), and charges for excess capacity may be added in the future to fund expansions and to force companies to relinquish capacity so other users can be connected [16]. It has been estimated that this type of charge could increase annual sewer fees by 30% for heavy users [16]. Nationally, the average cost for sludge disposal is US$1060/ton (median of US$500/ton) [9]. In South Carolina, the average cost is less - - at US$530/ton (median of US$400/ton). A new conventional treatment system will cost at least US$150000 to US$200 000, excluding installation costs (personal communication, US Filter Recovery Inc., 19 Oct. 1995). Nationally, the average total capital cost for treatment systems purchased between 1967 and 1993 was around US$250 000 [9]. Installation costs typically run 38% over basic equipment costs for a package system [9], but they can run 50-100% over basic equipment costs for a component system [15]. Conventional treatment offers the advantage of flexibility; it is a 'known quantity' and generally keeps companies in compliance. However, it is expensive and is likely to become more expensive. Costs for wastewater treatment at POTWs, and likely at industrial pretreatment plants, increased 7.9% per year from 1980 through

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1987; water supply costs increased 8.7% per year from 1980 to 1985, and transportation costs have increased at three times the general rate of inflation [17]. Wastewater treatment is also the most common source of routine hazardous waste generation [18]. Because many treatment systems are currently operating at flowrates greater than their design flowrates, either the systems will need to be upgraded or flowrates will have to be reduced in the future. It is unlikely that conventional treatment can remain the mainstay of environmental management within the metal plating and finishing industry. Although a recovery process may upset a treatment system, care taken before its implementation and integration with the plating operation can prevent problems [19]. 2.2. In-house recovery

Option 2 consists of platers practicing in-house recovery. Based on this research, only 50% of South Carolina platers are pursuing some type of metal or acid recovery, although another 22% are maintaining plating baths. This level of activity is consistent with what has been reported for the rest of the nation. Electrowinning and evaporation are the most popular recovery technologies in South Carolina, each used by 22% of the platers. These percentages compare favorably with national statistics, in which 19% of platers use electrowinning and no more than 29% use evaporation [9]. Electrodialysis and reverse osmosis were not used by any of the South Carolina platers surveyed - - similar, again, to national findings, in which less than 1% use electrodialysis and less than 2% use reverse osmosis. Ion exchange is used by 28% of South Carolina platers, but only 11% use it for recovery while 17% use it to produce deionized water. Likewise, 25% of platers nationally use ion exchange, but few of them use it for recovery. South Carolina platers did not provide any economic data for their ion exchange systems. Forrestal (1988) found costs between US$27 000 and US$140 000 with an average of US$85 000 [20]. Cushnie (1994) and Astaud (1993) [9,21] reported capital costs between US$30 000 and US$120 000 with installation costs adding from 5% to more than 40'70 of the equipment costs. Capital costs for acid recovery typically are lower than for metal recovery [9]. Operating costs range from US$5 to US$9 per 3785 1 [9]. If additional treatment (e.g., electrowinning) is needed to recover a usable or salable product, additional costs will be incurred. The major advantages to using ion exchange include more than 90% metal ion removal/recovery, 80 90% acid recovery, volume reduction, relatively pure water production, ability to control bath component ratios, and increased solution consistency. Although not an option for all waste streams, ion exchange may offer platers the chance to delist the sludge produced, which may be the 'greatest savings potential in sludge disposal costs' [17]. However, the process of delisting is expensive, time consuming, and subject to being reopened for review in the future if standards change or the definition of hazardous changes [22]. The major disadvantages to using ion exchange include a product more dilute than the plating bath, high capital cost, high sophistication, bath growth, resin fouling, and the importance of high quality water use to prevent resin overloading.

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Maintenance problems encountered by platers have included quality control problems, constant adjusting of sulfate levels to reduce acidity for reuse, leaks at joints and seals, filter changes, resin replacement, and repairs to pneumatically-operated valves [201. Even though additional operator training will be necessary and some production floor space will be required, ion exchange appears to be much more attractive than conventional treatment for appropriate waste streams. For new plants, capital costs will be less than half that for conventional treatment facilities, and installation costs will be less. For both existing and new plants, operating costs will be approximately half of the costs for conventional treatment. Ion exchange can reduce the impact of water and sewer fee increases. It will reduce sludge disposal costs, perhaps significantly if delisting can be accomplished. It can be used in attaining zero wastewater discharge, which over 25% of South Carolina platers are pursuing or considering. And future costs will not rise as dramatically because hazardous waste management costs will be a lower portion of total costs. However, shops implementing in-house recovery must be dedicated to finding a market in-house or offsite for the recovered product(s). In addition, care must be taken in equipment selection. The NCMS/NAMF survey revealed that approximately 30-40% of chemical recovery technology and advanced bath maintenance installations have been unsuccessful [9]. Although both equipment vendors and shop personnel contributed to the failures [9], Cherry (1982) contended that 'the single most important reason' for system failures is underestimating the variability of wastes [23]. 2.3. Rotating/shared recovery equipment

Option 3 is platers using rotating (or shared) recovery equipment (RRE). Based on this research, potentially 80% of South Carolina platers are interested in RRE if a third party owns the equipment; however, based on interviews, the interest appears to be weak - - for both third-party and plater ownership. Organizational and coordination issues appear to be the major obstacles to group ownership or sharing since scheduling, sizing, training, and maintenance issues could all be resolved through contract negotiations. Several departments within one captive shop may find sharing more feasible because there would be fewer organizational and coordination issues. Anti-trust regulations may present a problem if a plater or a group of platers owned or shared the equipment but should not be a problem for third-party ownership or departmental sharing. Proper crediting for recovery may be an issue in both group efforts and contract service [24]. A major barrier in group efforts for platers is the fear of revealing proprietary processes or customers to competitors. Liability associated with RRE should be of no greater concern than that associated with in-house recovery unless the contract service removes material from the shop. Gill et al. (1979) found that significant cost reductions occur in multicompany use of batch treatment and recovery equipment [24]. Therefore, this option could yield economic savings for platers if institutional obstacles can be overcome.

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Another important facet of group efforts that would not arise with third-party ownership is financing; at least one company must be financially strong enough to borrow funds [24]. Management and ownership also require consideration. Comfort et al. (1981) recommended that management and/or ownership be shared by some or all of the companies participating in such a way that the feasibility or the arrangement is not significantly dependent on the future business decisions of one participant [25]. However, if the venture shows an operating loss, only a firm owning at least 80'7, could consolidate financial statements and apply the loss against its business profits [24]. Firms not participating in ownership could use contracts to guarantee future access and fair charges, the same as contract service. Compared to conventional treatment, it is likely that there are economic savings and advantages similar to in-house recovery, especially for contract service. In fact, economy of scale should provide additional savings in capital costs for platers sharing equipment. There are, however, a host of institutional considerations that could increase costs substantially if recovery equipment were shared by platers. In contract service, the capital costs should be negligible - - possibly some piping and tanks. In addition, expertise to operate the system would be provided by the RRE company. However, finding a reputable company to provide contract service may be difficult if not impossible because this option is not currently used to recover metals and acids. Therefore, at this time, it does not appear that RRE is as feasible for South Carolina platers as in-house recovery, although it may be in the future.

2.4. Centralized facilities Option 4 is platers using centralized recovery facilities (CRFs) for sludge and/or solution reclamation. About 31"/o of South Carolina platers send sludge to a reclamation facility. Likewise, 31% of platers nationally use reclamation facilities [9]. South Carolina platers sending their sludge to a reclamation facility paid on average US$430/ton (median of US$400/ton) while platers sending sludge to landfills paid on average US$530/ton (median of US$400/ton). Nationally, platers sending sludge to a reclamation facility pay more at US$800/ton (median of US$600/ton) [9]. There are several potential reasons for the apparent small or nonexistent difference between the cost of landfilling and reclaiming sludge. From survey data, it appears that shops using landfilling receive quantity discounts that shops using reclamation may not receive. Another factor may be that recovery sites are often farther than disposal sites, which would increase transportation costs [9]. In addition, sludge reclamation facilities impose strict requirements on the composition of material they will accept and impose penalty fees for not meeting or for exceeding certain constituent levels [9]; these penalties will increase the cost of reclamation and decrease platers' ability to make changes. One South Carolina plater was hesitant to recover copper due to this problem; the reclaimer would not want the sludge without the copper, and the plater would be left with a sludge that contained other regulated metals. None of the South Carolina platers responded on the survey that they reclaimed spent solutions. However, at least one firm sends spent electroless nickel baths and

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spent nitric acid stripper to offsite facilities. The confusion may have resulted from different definitions of a CRF. Nationally, approximately 12% of platers send spent solutions for reclamation, with the average price paid at US$1780/ton (median of US$1200/ton) [9]. The advantages and disadvantages of sending solutions for recovery are similar to those discussed for sludge reclamation. Because the quality and quantity of spent solutions may not be as predictable as for sludge generation, strict requirements imposed on the platers may be difficult to attain consistently. There does exist the possibility in solution reclamation that the recovered solution could be returned to the plater for reuse at a lower price than virgin material. Due to the liquid form of plating solutions, however, transportation costs would likely be significant - which could make this option economically unfeasible unless the reclamation facility was local. Another option would be for the facility to recover for reuse only a portion of the solution, such as the metal salts, that could then be transported for lower cost. Another approach to metal recovery is for platers to rent recovery equipment, generally ion exchange canisters, from which the CRF recovers the metals. Again, none of the South Carolina survey respondents reported using such a facility, although 2.5% of platers nationally do [9]. About 72% of South Carolina platers indicated an interest in using centralized recovery. The major perceived barriers to a CRF by South Carolina platers were economic costs, benefits, demand, liability, responsibility, and distance. Operational and regulatory issues were other concerns. One plater noted that the facility would need to 'accept a wide range of wastes' and not just the 'gravy.' This plater also wrote that facilities currently operating are more expensive than disposal facilities (which can occur due to transportation costs and strict composition requirements enforced with fines). South Carolina platers also saw potential economic advantages to using a CRF including cost sharing, reduced costs, convenience, and savings. Regulatory relief and environmental considerations or reclamation of metals were seen as advantages. Other potential advantages for platers in using this option include: limited loss of floor space, access to P2 and laboratory services, limited in-house technical expertise required, and reduced capital costs. In fact, capital costs for platers are always cheaper by using a centralized facility - - generally by 1/4 to 1/3 (personal communication, US Filter Recovery Inc., 19 Oct. 1995). Platers' capital costs would arise from buying a pretreatment system for each waste stream at a cost of US$20 000 for each system (personal communication, US Filter Recovery Inc., 19 Oct. 1995). The NCMS/NAMF survey respondents reported capital costs between US$10 510 and US$133 000, with the average being US$80 774 [9]. Despite platers' capital costs always being cheaper by using a CRF, this is not the case for operating costs (personal communication, US Filter Recovery Inc., 19 Oct. 1995). Fully-burdened operating costs are a function of the complexity and volume of the waste stream, and thus, analysis must be conducted on a case-by-case basis to determine if centralized recovery is more economical (personal communication, US Filter Recovery Inc., 19 Oct. 1995). It is likely that more complex waste streams -

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could be treated more economically on a centralized basis. However, the situation is not as clear-cut for volume; larger volumes may require too much regeneration onsite to be economical, but Hunt and Schecter (1989) reported that in-house recovery of small quantities is not cost effective [26]. The costs for labor, chemicals, and sludge disposal must be compared to the service fee charged by the CRF. Respondents to the NCMS/NAMF survey reported service fees ranging from US$29 to U S $ 1 0 5 / f t 3 of resin [9]. Waste type and quantity are the major factors influencing the cost. Recovery of cyanides will be charged at the higher rates because they are expensive to recover while large flows will be given discounts. In addition, distance from the facility will play a part in determining the fee. One centralized facility includes transportation in its fee for shops within a 160-km radius but adds a charge for shops outside that radius. Often, transportation costs are also higher for smaller quantities of material [27]. (At least one German centralized facility used a transportation company that charged the same price regardless of distance; however, this arrangement was created to eliminate disagreement over siting the facility [28].) The service fee is the largest component of operating and maintenance costs for platers; utility, labor, and chemical costs should all be minor (personal communication, US Filter Recovery Inc., 19 Oct. 1995). Respondents to the NCMS/NAMF survey reported operating costs between US$2500 and US$216600 per year, averaging US$56 249/year [9]; although not stated, these figures presumably include the service fee. The labor component of those costs ranged from less than 1-25% of the non-labor component; the average (excluding the 25%) was less than 3%. One plater also reported paying a US$70/month rental fee on top of the service fee. Down time averaged less than 4'¼,. Reported savings ranged from US$0 to US$1000 on both treatment chemical and sludge disposal costs. It is unclear why there would be no savings when a metal-containing waste stream would no longer require treatment. Despite the relatively modest savings reported, most of the platers were relatively satisfied with manufacturer support and the technology, and 63% would purchase the technology again [9]. Although wastewater treatment costs for sludge reclamation and conventional treatment would be the same, sludge reclamation offers the "feel good factor' and possibly reduced disposal costs as benefits. However, there is the added responsibility of finding a reputable company and the requirement of maintaining a certain quantity and/or quality of sludge. Sludge reclamation appears to be more expensive than in-house recovery. Compared to conventional treatment, CRFs for spent solutions should have higher quality discharges than individual plating shops due to higher qualified personnel devoted full-time to operating the recovery and treatment processes and using better operating methods [24]. Capital costs for using a CRF are significantly less than for wastewater treatment. However, operating costs may not be less; one drum of spent 30% nitric acid stripper would cost slightly more than US$41 to treat in-house and landfill (including neutralization, precipitation, and labor costs) while offsite metal reclamation would cost more than US$110 to more than US$220 (personal communication, Capsule Environmental Engineering, 16 June 1995).

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However, solution reclamation offers reduced liability and the 'feel good factor' as benefits, which are difficult to quantify. Onsite treatment appears to be more economical for existing plants unless they have limited wastewater treatment capacity and complex or large volumes of spent solutions. Compared to in-house recovery, the quality of recovered material from a C R F is likely higher because more qualified personnel are devoted full-time to operating the centralized recovery processes using better operating methods. A C R F can also offer platers extra services, such as laboratory analyses and assistance in identifying P2 opportunities. Capital costs for using a C R F are significantly less than for in-house recovery. If a company's waste streams are complex and/or high volume, it is likely that centralized recovery would provide operating savings over in-house recovery if transportation costs were not too high. Minor and Batstone (1979) examined the effects of hauling distance and amount of solution hauled on the break-even point for using a centralized treatment facility [29]. They found that transportation costs are more important for larger waste loads because less gain is attributable to economy of scale. Although smaller loads (such as 19000-38000 1 per day) can be hauled as much as 2.5 times farther than larger loads (such as 151000 1 per day), Minor and Batstone's (1979) calculations found all break-even points to be less than about 130 km. It is likely that similar trends exist for hauling ion exchange canisters [29]. If there are enough customers, transportation can be coordinated to reduce transportation costs. Centralized recovery could, however, impose quantity and/or quality constraints on platers that they may not have with in-house recovery, and it is important to find a reputable company with which to conduct business. Although some South Carolina platers are willing to consider CRFs up to 2400 km away, economically, a C R F appears to be a better option than in-house recovery only for platers who are located within 160 km of the facility. Compared to a third-party-owned RRE firm, a centralized facility has more waste transportation risk but lower risk of malfunctions and accidents and no need for permits tied to each site [30]. Daley (1989) stated that costs for R R E are generally higher, but he did not specify what costs [30]. Transportation costs may be higher for a C R F because R R E companies are more likely to be local, especially for South Carolina platers. Daley (1989) recommended R R E when products can be reused onsite and when the demand is too small to justify permanent facilities but large enough to justify taking a unit to sites [30]. If the recovered product cannot be reused onsite, then a market for it will have to be identified, unlike when a C R F is used. Because RRE is not currently available for South Carolina platers, centralized recovery is more feasible at this time. However, if RRE does become available, it may offer significant advantages over centralized recovery, especially for companies which have small quantities of waste and can reuse the recovered material onsite.

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2.5. Enhanced-recovery industrial parks Option 5 is platers locating in enhanced-recovery industrial parks. A plating-industry specific industrial park would have a critical mass of platers (or other industries with similar waste streams) within it to make a CRF within the park feasible. There are no plating-industry specific industrial parks in South Carolina nor are there industrial parks with centralized facilities for park occupants. A planned electroplating industrial park in Japan has operated a successful group treatment/recovery facility with 19 plating firms [31]. South Carolina platers appear to have a high interest in this concept; between 70 and 92% of the survey respondents would consider moving to an industrial park with either or both a treatment plant or a recovery plant and over half thought that being located in an industrial park with such facilities would represent an advantage. The greatest interest was expressed in having both treatment and recovery facilities, likely due to the flexibility that would allow. Perhaps most significantly, all plating shops already located in industrial parks were willing to consider moving to another industrial park if it offered centralized treatment and/or recovery. The major barrier to moving to any type of industrial park was seen by South Carolina platers to be economics. Of less concern were regulatory issues and competitors (although 38% considered this to be a barrier in plating-industry specific parks, possibly because competitors could potentially learn whom each other's customers were). South Carolina industrial park developers and managers were not as interested as the platers in industrial parks with centralized facilities. This low interest was for all three types of industrial parks with centralized facilities-standard, plating-industry specific, and those with a high percentage of one industry. However, there is a bias against platers by some developers, who perceive them to be risky because they are still perceived to be a 'dirty' industry - - one that generates large quantities of hazardous waste. Some South Carolina industrial parks do not allow plating. The majority of the developers and managers considered the major barrier to industrial parks with centralized facilities and plating-industry specific parks to be economic issues. A concern about high capital costs may be valid; a CRF in Minnesota for 23 platers cost US$11 million to build in 1987. Other factors perceived as barriers were politics, regulatory issues, environmental issues, and technical capability. Besides actual costs, the issue of the number of platers or other firms with similar waste streams that would be required for an industrial park CRF is important. At least five to ten plants with appropriate waste streams are required to realize capital savings for centralized facilities, but the bulk of capital savings are realized with 25 plants [29]. However, South Carolina industrial parks do not contain many firms, let alone platers, per park. The total number of firms located in the 45 South Carolina industrial parks reported on in this research was 82. The range of number of firms was zero to 19; the average number was approximately four, and the median was two. Therefore, it is likely that there would not be enough firms with appropriate waste streams within an individual South Carolina industrial park to support a C R F without outside customers.

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Platers moving to this type of industrial park would require considerably less capital if individual in-house wastewater treatment plants were unnecessary. However, capital costs would only be approximately 10% less, according to Gill et al. (1979), if the CRF handled only a portion of the wastes [24]. Shops would be designed to include modern production processes that generate less waste; therefore, operating costs (including service fees) would be lower, and the firm would experience a competitive advantage over firms that did not move. Shops could be more easily designed as zero-discharge facilities (in terms of eliminating wastewater discharges) due to the proximity of a dedicated CRF. Modern facilities can also be showcased by firms for positive publicity. In addition, regulatory costs could be lowered because individual plants would no longer need individual pretreatment permits and previously dispersed firms would be located together, decreasing inspection costs. Gill et al. (1979) concluded that a group treatment project in Taunton, Massachusetts, would reduce the number of monitoring points for regulatory agencies [24]. South Carolina platers expressed some interest in integrated industrial parks. They considered economic issues and regulatory issues to be potential barriers. Unlike the case of plating-industry specific industrial parks, the majority of South Carolina industrial park developers and managers would consider developing or participating in developing integrated industrial parks. They perceived economics and business capability to be the major obstacles. Although this concept has been studied to a certain extent by others [32-34], there does not appear to have been a great deal of activity in this area. To be feasible, a group of industries would have to be identified that could use each other's waste products with limited pretreatment, that consistently produced a sufficient quantity and quality of waste at or below the cost of virgin material, that would be interested in locating in the same industrial park, and that would be willing to overcome organizational, institutional, and possibly production constraints to using waste products as raw materials. Because there does not appear to be a precedent for integrated industrial parks, some regulatory hurdles (such as the classification of the materials as hazardous waste) may have to be overcome by negotiating with state regulators. A potential way to avoid some of the regulatory and institutional constraints would be to develop an industrial park association with the occupants of the industrial parks as members - - similar to the recommendations for group treatment arrangements made by Gill et al. (1979) and Comfort et al. (1981) [24,25]. There would then be no wastes, just by-products that would be used as raw materials in another process, and disputes between companies could be resolved by the industrial park association board. If full integration could not be achieved, as one South Carolina industrial park developer/manager noted, 'at some point, centralized treatment...would likely be required.' While this event is not unlikely considering the extent of cooperation required, it could negate many of the potential benefits of the integrated park by adding complexity as well as cost. The comparison of plating-industry specific industrial parks offering centralized recovery facilities with conventional treatment, in-house recovery, and RRE (with

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third-party ownership) is similar to the comparison of standard CRFs with these options. Transportation costs would be much lower, possibly negligible, in the industrial park setting. Piping wastes may even be feasible; Comfort et al. (1981) found that piping was cheaper than hauling, even when cyanide and non-cyanide wastes were segregated and excess capacity was included [25]. For some wastes (such as low volume or complex wastes), the plater may find in-house recovery more economical; the lower operating costs may outweigh the higher capital costs. A centralized treatment or recovery facility within an industrial park would have several advantages over a standard centralized facility: (1) there would likely be less public concern over the siting of the facility (personal communication, South Carolina Department of Environmental Health and Control, 16 Oct. 1995), (2) its service fees could be lower because its processes could be tailored to meet the needs of park occupants, (3) new shops could be designed to maximize the feasibility of recovering materials at the centralized facility, and (4) it would have guaranteed business from the facilities located within the park. Although plating-specific industrial parks offering centralized recovery appear to be an attractive option for South Carolina platers, it is unlikely that they will be developed in the near future due to reluctance on the part of South Carolina industrial park developers and managers. Integrated industrial parks, as noted previously, would require a great deal of cooperation among developers and industries to be feasible. If (as is likely) pretreatment of the materials is required before transfer, then costs would be similar to those for in-house recovery. There would be no need to find a market for the recovered material since that would have already been done, but maintaining quantity and quality may be a larger concern. Any transportation costs would be negligible compared to standard CRFs and RREs. The institutional and organizational issues involved may make this option unattractive, if not unfeasible; therefore, it is not likely that this option will be available in the near future for South Carolina metal platers and finishers.

3. Summary and conclusions Although all the recovery options discussed are conceptually feasible and have similar benefits, they are not all economically feasible at this time for South Carolina platers. Hunt and Schecter (1989) reported that 'in most cases the best place to recycle process wastes is within the production facility' [26], and the majority of South Carolina platers agree: 80% believe that the area in which efforts could best be focused to encourage metal and acid recovery is in-house. The next closest area, centralized recovery facilities, was believed to be worth pursuing by only 47% of the platers, and there were few votes for any of the other options. Therefore, based on the opinions of South Carolina metal platers and finishers, the views of South Carolina industrial park developers and managers, and the current regulatory climate, it is recommended that platers, regulators, trade associations, and other parties currently focus on in-house recovery, including departments within a captive plating shop sharing recovery equipment.

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However, it should be recognized that in-house recovery will not be the answer in all situations and that the other options all have merits and interest among platers and should not be discarded summarily. A change in any influencing factor will change the options' relative feasibility. For example, RRE may be competitive with in-house recovery if a reputable, stable company locates in or near South Carolina. Centralized recovery, especially the rental of ion exchange canisters, may become competitive if enough platers are involved to reduce individual transportation costs through the use of 'milk runs.' Industrial parks designed to enhance recovery may be feasible in locations desiring industry but currently less attractive to industry. All options will become more feasible if zero discharge (or limits so low as to be in reality zero) were mandated, and in this event, it is likely that a mix of the options would be the best solution. South Carolina platers realize the need for P2 and metal and acid recovery. The vast majority of them desire economic incentives, such as tax credits, to increase implementation; however, tax credits may not be the most effective means of enhancing long-term P2 commitment. Similarly, although over half the platers believe that recovery will increase as younger platers move into management, other steps must be taken to ensure long-term P2 commitment. The most important criterion for successful P2 implementation is support at all levels of management (financially and verbally), which can effectively remove other obstacles - - time constraints, complacency, motivation, and in-house data availability. A close second is information availability - - data from within shops on waste characteristics and costs and from outside shops on the applicability, costs, and benefits of various P2 techniques and technologies. These factors must be addressed before successful recovery implementation will increase. Increased technology transfer to and education for platers can address these issues. In fact, the majority of South Carolina platers believe they will enhance the successful implementation of recovery technologies. To increase their effectiveness, they should be held in neutral settings throughout the state by people with good credentials who act in a professional manner to maximize participation by minimizing potential barriers caused by inconvenience, secretiveness, mistrustfulness, and risk-aversion. They should involve trade associations, target management (who the platers felt were in the best position to encourage metal and acid recovery), and take into account differences between the two types of firms involved in plating (job or contract shops and captive shops). Providing specific data on successful and unsuccessful recovery and reuse implementations as well as on methods to improve cost accounting and benefit analysis is especially important for job-shop platers, who perceived information availability to be a barrier to metal and acid recovery implementation. Linking P2 and total quality management (TQM) may be very effective, especially for captive platers. Technology demonstrations will decrease the risk platers associate with recovery technologies. Other avenues that platers view as having merit to increase recovery efforts are encouraging chemical supplier and equipment vendor research and development as well as supplier-plater partnerships. Again, local trade associations are seen as the most effective means to initiate these methods. While South Carolina platers

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expressed little interest in using electrodialysis and reverse osmosis for metal and acid recovery (possibly due to limited current use of these technologies in the industry), they were interested in using evaporation, ion exchange, and electrowinning, especially for recovering nickel, chromium, chromic acid, copper, and zinc. In general, trade associations should play a more prominent and active role in encouraging P2. They can act as sources of information and provide forums for platers to share information and cooperate. They can increase the use of nontraditional P2 methods (such as coordinating platers, POTWs, and unregulated industries to reduce metal discharges from unregulated industries) to decrease the costs of P2 while also decreasing waste discharges. They may also be able to institute educational campaigns to overcome consumer resistance to substitute finishes (such as trivalent chromium). Trade associations can also encourage a more open dialogue between state regulators and platers. Almost half of South Carolina platers believe that government agencies are in a position to encourage metal and acid recovery. Regulators should take advantage of their role to encourage P2. They should consistently enforce regulations to remove platers' fears of being at a competitive disadvantage, but they should also be more flexible - - allowing platers to pursue P2 projects without fear of repercussions from minor discharge violations. They should promote P2, especially in routine activities, such as site inspections, and they should publicize P2 successes (which is especially important to job-shop platers, who perceive community pressure to be a driving force for recovery). Although this research was based on the South Carolina plating industry, it should be applicable to the plating industry elsewhere as well a's to other industries. Most industries face similar barriers to and driving forces for pollution prevention. And most industries face similar economic constraints. There are two major areas of potential differences between the recommendations contained in this research for South Carolina platers and recommendations for other regions and other industries: (1) geographic location, which affects transportation costs and, thus, the feasibility of centralized recovery and (2) political climate, which affects the desire to attract industry in general or a particular industry through the use of incentives or enhanced-recovery industrial parks and affects the openness of regulatory agencies to experimenting with non-traditional options.

Acknowledgements This material is based on work supported under a National Science Foundation Graduate Research Fellowship and a grant from E.I. DuPont to Clemson University's Center for Policy and Legal Studies. References [1] Klassen, R.D., 1995. Executive Report: Manufacturing Competitiveness and Environmental Management, London, Ontario, Canada. Western Business School, University of Western Ontario.

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[2] Hirschhorn, J.S., 1993. How to remove obstacles to hazardous waste reduction. In: American Electroplaters and Surface Finishers Society, 9th AESF/EPA Conference on Environmental Control for the Metal Finishing Industry. American Electroplaters and Surface Finishers Society, Orlando, FL. [3] Kennedy, I.F.T. and Gupta, S.D., 1978. The electrochemical removal of trace metals for metal wastes with simultaneous cyanide destruction. In: US EPA, 1st Annual Conference on Advanced Pollution Control for the Metal Finishing Industry. US EPA, Cincinnati, OH, pp. 49-58. [4] Surface Finishing Market Research Board, 1994. Metal Finishing Industry Market Survey 1992 1993. Metal Finishing Suppliers' Association, Westmont, IL. [5] US EPA, 1991. Industrial Pollution Prevention Opportunities for the 1990s. EPA/600/8-91/052. US EPA, Cincinnati, OH. [6] Steward, F.A. and Ritzert, C.G., 1992. Waste minimization and recovery technologies. Metal Finish., 1A: 786-811. [7] Patterson, J.W., 1987. Metals separation and recovery. In: J.W. Patterson and R. Passino (Eds.), Metals Speciation, Separation, and Recovery. Lewis Publishers, Chelsea, MI, pp. 63 93. [8] Grosse, D.W., 1986. Treatment technologies for hazardous waste, Part IV: a review of alternative treatment processes for metal bearing hazardous waste streams. J. Air Pollut. Cont. Assoc., 5: 603-614. [9] Cushnie, G.C., 1994. Pollution Prevention and Control Technology for Plating Operations. Noyes Publications, Park Ridge, NJ. [10] Foecke, T.L., 1993. Source reduction opportunities in the plating industry. Pollut. Prey. S.C., 2: 10 12. [11] Duke, L.D., 1989. Hazardous waste minimization measures implemented by metal-plating plants in the San Francisco Bay area. In: C.A. Cole and D.A. Long (Eds.), Hazardous and Industrial Wastes: Proceedings of the 21st Mid-Atlantic Industrial Waste Conference. Technomic Publishing Co., Lancaster, PA, pp. 61-75. [12] Dane, L., I988. The southeast jewelry platers project source reduction in Massachusetts. In: American Electroplaters and Surface Finishers Society, 9th AESF/EPA Conference on Environmental Control for the Metal Finishing Industry. American Electroplaters and Surface Finishers Society, Orlando, FL. [13] National Society of Professional Engineers, 1994. EPA's new approach to pollution: industry by industry. Eng. Times, 9: 7. [14] Morgan, S,M., 1995. Metal and Acid Recovery Options for the South Carolina Plating Industry. Ph.D. Dissertation, Clemson University, SC. [15] US EPA, 1985. Environmental Pollution Control Alternatives: Reducing Water Pollution Control Costs in the Electroplating Industry. EPA/625/5-85-016. US EPA, Washington, DC. [16] Roberts, J., 1995. Waste not: new waste water billing system could boost heavy users' bills. The Greenville News, Upstate Business, 6: 4. [17] Daily, T., 1990. The economic analysis of wastewater system retrofits for the metal surface finisher. In: J.P. Martin, S. Cheng and M.A. Susavidge (Eds.), Hazardous and Industrial Wastes: Proceedings of the 22nd Mid-Atlantic Industrial Waste Conference. Technomic Publishing Co., Lancaster, PA, pp. 129-143. [18] US EPA, 1991. National Survey of Hazardous Waste Generators and Treatment, Storage, Disposal, and Recycling Facilities in 1986: Hazardous Waste Generation and Management. EPA/530-SW-91075. US EPA, Washington, DC. [19] Reinhard, F.P., 1988. Ion exchange as a tool for water and metal recycling. In: American Electroplaters and Surface Finishers Society (Ed.), 9th AESF/EPA Conference on Environmental Control Technology. American Electroplaters and Surface Finishers Society, Orlando, FL. [20] Forrestal, B., 1988. Factors which affect the success of metal/chemical recovery installations in the metal finishing industry - - survey results. In: American Electroplaters and Surface Finishers Society, 9th AESF/EPA Conference on Environmental Control Technology. American Electroplaters and Surface Finishers Society, Orlando, FL.

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[21] Astaud, S.A., 1993. Pollution Prevention in the Metal Finishing Industry Utilizing Heavy Metal Recovery Technologies. Ionic industries international, Woodbridge, VA. [22] Gasiorowski, J.B., Haley, D.L., Willis, S.P. and Yancey, P.S., 1986. One metal finishing company's experience with the hazardous waste delisting process. In: G.D. Boardman (Ed.), Hazardous and Industrial Wastes: Proceedings of the 18th Mid-Atlantic Industrial Waste Conference. Technomic Publishing Co., Lancaster, PA, pp. 291-303. [23] Cherry, K.F., 1982. Plating Waste Treatment. Ann Arbor Science Publishers, Ann Arbor, MI. [24] Gill, H.C., Shockcor, J.H. and Gorden, M., 1979. Group Treatment of Multicompany Plating Wastes: The Taunton Silver Project. EPA-600/2-79-102. US EPA, Cincinnati, OH. [25] Comfort, E., Harrison, D. and Sherman, D., 1981. Group Treatment Evaluation for Metal Finishers. EPA-600/2-81-143. US EPA, Cincinnati, OH. [26] Hunt, G.E. and Shecter, R.N., 1989. Minimization of hazardous-waste generation. In: H.M. Freeman (Ed.), Standard Handbook of Hazardous Waste Treatment and Disposal. McGraw-Hill. New York, NY, pp. 5.3 5.27. [27] Brooks, C.S., 1986. Metal recovery from industrial wastes. J. Metals, 7:50 57. [28] Roesler, N., 1981. Centralized treatment and disposal of special wastes in the Federal Republic of Germany. In: US EPA, 3rd Conference on Advanced Pollution Control for the Metal Finishing Industry. EPA-600/2-81/028. US EPA, Cincinnati, OH, pp. 104 114. [29] Minor, P.S. and Batstone, R.J., 1979. Applicability of the Federal Republic of Germanys centralized waste treatment approach in the United States. In: US EPA, 2nd Conference on Advanced Pollution Control for the Metal Finishing Industry. EPA-600/8-79-014. US EPA, Washington, DC, pp. 38 44. [30] Daley, P., 1989. Comprehensive hazardous-waste treatment facilities. In: H.M. Freeman (Ed.), Standard Handbook of Hazardous Waste Treatment and Disposal. McGraw-Hill, New York. NY. pp. 11.3 11.18. [31] US EPA, 1981. Research Summary: Group Treatment Evaluation for Metal Finishers. EPA-600: $2-81-143. US EPA, Washington, DC. [32] Decoplex, 1974. Decoplex: A Chance for Industry to Innovate. Site Selection Handbook. pp. 274 278. [33] Jones, K.D., Zinn, G.W., Patterson, D.W., Armstrong, J.P. and Moore, L.T., 1988. Design and Feasibility Analysis for a Wood Products Industrial Park. Economic Development Administration, Morgantown, WV. [34] National Society of Professional Engineers, 1995. Industries may share waste for fuel. stud5 says. Engr. Times, 7: 14.

Biographies Susan M. Morgan is an assistant professor of Civil Engineering at Southern Illinois University at Edwardsville in Edwardsville, IL. Cindy M. Lee is an assistant professor of Environmental Systems Engineering at Clemson University in Clemson, SC.