Compliance in a Small Plating Shop

A small shop, in a small town, doing what is necessary to survive and hopefully prosper. This could describe a number of plating shops; however, it particularly describes Precision Hard Chrome in Canton, Ohio. Arlan Grace and a partner purchased the shop in 1978. Then there were few regulations governing air and water emissions. Still, Mr. Grace wanted a clean shop, even if his partner claimed you could never have a clean hard chromium plating shop.

By January 1995, Precision Hard Chrome was becoming a profitable plating shop. Then the EPA issued the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. According to the regulation, this nine-man shop was considered a large, hard chromium plating facility. This was determined using the EPA's formula for maximum cumulative potential rectifier capacity. The formula is amperes, multiplied by the maximum potential operating schedule of 8,400 hours per year and 0.7, which assumes that electrodes are energized 70% of the total operating time. The maximum potential operating schedule is based on operating 24 hours per day, seven days per week, 50 weeks per year.

This formula just does not work for Precision Hard Chrome. According to Mr. Grace, his rectifiers never run at greater than 50% capacity, 10 hours a day, six days a week. But, because of the rectifiers' potential capacity, Precision Hard Chrome is a large hexavalent chromium plating shop, according to the formula.

Because of this, Mr. Grace was faced with a difficult decision: close up shop, eliminate hard chromium plating and only plate electroless nickel or go to the bank.

Mr. Grace visited two banks to apply for a $175,000 loan. The loan would be used to install scrubber systems above the hard chromium plating tanks. Mr. Grace also received an additional $50,000 loan to install titanium-lined plating tanks, purchase two new and two rebuilt rectifiers and put down a chemically resistant floor.

With the loan the company sought out scrubbing system suppliers, stack testing companies and suppliers for the other shop improvements.

Precision Hard Chrome applied for and received a one-year extension to comply with the regulations. "The first four quotes I obtained for stack tests were exactly the price the EPA estimated, $4,500." By the end of the one-year extension (it was three years from the time the law was passed), Mr. Grace was able to have the tests done on the company's two stacks for $1,600 each. RMC Environmental did the stack testing.

The original scrubber systems were installed in the 1970s. "They would not have passed the requirements of the new law," Mr. Grace stated. Estimates for the two new scrubbers ranged from $60,000 to $131,000. Scrub Air Vent Systems in Wauconda, Illinois, installed two scrubbers above the hard chromium plating tanks. The scrubbers are manufactured from ½-inch PVC. The filters in the system only require maintenance every three years. Stack testing showed that Precision Hard Chrome met the 1.5 ppm limit on hard chromium emissions. Testing showed stack emissions at 0.007 and 0.0035 ppm. Since these initial readings showed compliance, Precision Hard Chrome simply has to record readings on the scrubber gages daily to prove it is staying within the limits set by the law.

The limits for hard chromium as published in the federal register are: All existing tanks—0.03 mg/dcsm; and All new tanks—0.015 mg/dcsm.

As much money as Mr. Grace borrowed and as much equipment as he installed, he still insists that his greatest asset is his employees. When he speaks of them, he sounds like a proud father bragging about his child. All nine employees have keys to the facility. Mr. Grace will pay them an hour's wages if they walk through the closed shop to make sure everything is ok.

Mr. Grace credits his employees' ingenuity in helping satisfy the company's biggest electroless nickel customer, Firestone/Bridgestone. Precision Hard Chrome applies electroless nickel to tire molds. A single tire has nine sections that require plating. On each section the tread part of the mold is brushed with maskant, allowed to dry and then the entire piece is plated. When Precision Hard Chrome first started plating these tire molds, it could only handle two per run. However, the two men running the electroless nickel area are "geniuses" according to Mr. Grace. These workers figured a way to rack the molds so that all nine pieces could be plated on the same run in the 350 gal tanks.

Precision Hard Chrome's biggest hard chromium customer manufactures wires for cutting bricks prior to baking. These 18 to 26 gauge wires receive 14 thousandths of an inch of chromium. Wires range from 9½ to 33 inches long. The plating increases the wires' usage approximately 10 times. This is highly beneficial to the customer, who has to shut down the entire brick manufacturing system if one wire breaks.

Mr. Grace admits that Precision Hard Chrome would never be able to provide a quality, on-time plating job if it were not for his dedicated, hard-working employees.

Mr. Grace commented, "It is the employee's enthusiasm and commitment to this company that keeps me going, even when all the regulations and paperwork seem to bury me."