Pollution Prevention and Hazardous Waste Management in Two Industrial Metal Finishing Facilities

Pollution prevention for industrial hazardous wastes is a clear intent of U.S. regulations such as RCRA, wastewater discharge requirements, and the Pollution Prevention Act. Policies and regulations tend to rely on economic incentives to encourage pollution prevention, especially regarding hazardous wastes. Site-specific evaluations of two industrial metal-finishing facilities in California reveal a critical flaw in the strategy: the full array of market incentives and disincentives, institutional barriers, and conflicting requirements by multiple regulatory agencies do not uniformly encourage practices and technologies that would be most effective at pollution prevention for industrial generators of hazardous wastes. Indusmal facilities may identify a wide range of potential waste management practices that comply with federal, state, and local regulations; available P2 practices may not successfully compete with other waste management alternatives when financial incentives alone are considered. This paper analyzes factors that influence the choice of hazardous waste management methods in two selected facilities and concludes that financial incentives may not be sufficiently powerful to encourage P2 in some industrial facilities. Other inducements, including pressure from local agencies and desire to avoid long-term liability for offsite waste disposal. may be at least as important to encouraging P2 for industrial hazardous wastes