Project: Franklin Electro Plating 1995 Pollution Prevention Summer Internship Project -- Final Report Date: August 4, 1995 Name: Vickie Dycewicz 603-742-6357 Facility: Franklin Electro Plating Co., Inc. 519 Central Avenue Dover, NH 03820 Contact: John G. Cabral, President 603-742-6357 Executive Summary: Franklin's pollution prevention project involved compliance with environmental regulations. Regulatory compliance ensures Franklin's pollution is minimized. Hazardous waste regulations were reviewed and documentation developed for compliance. Background: Franklin Electro Plating is a metal finishing job shop that electroplates metal parts for numerous industries using chromium, nickel, copper and zinc metals. Franklin also anodizes and etches aluminum, buffs and polishes metal parts. These processes produce hazardous wastes such as spent plating baths and rinses, acids, and alkalines which are treated on-site through a wastewater treatment unit. This unit generates a metal hydroxide filter cake which is shipped off-site for chemical fixation and land disposal. Solvent trichloroethylene is used for cleaning parts and sent off-site for reclamation. Objectives Work Accomplished Compliance Assistance State and EPA waste rules were read and summarized (App 1). Storage areas received emergency postings (App 2) and spill cleanup material. The weekly inspection sheet was revised and an inspection plan developed (App 3). Reduction of Waste Flow diagrams for each process and a plating room flow using a tank layout developed (App 4). A Waste Reduction Assistance Report, prepared by Department of Environmental Services in 1993, was reviewed with John Cabral (App 5) and response to specific suggestions listed. -1- Safety Policies A safety meeting sign-in sheet (App 6) was developed to document safety meetings. A Joint Loss Management Committee has been formed and applicable documentation developed. OSHA requirements for a safety summary form does not apply due to <10 employees. Inventory MSDS A MSDS inventory was prepared on Excel (App 7). The inventory contains MSDS dates, chemical name, trade name, hazardous ingredients, supplier, uses, location & current inventory. Respirator Program Elaine Cabral is working on a respirator program to comply with OSHA requirements. Labeling Tanks All tanks were given identification numbers (App 8) and labeled with HMIS and overhead signs. Buffing Area The dirt removed from the buffing air exhaust has been profiled and ready for off-site shipment. Large or small Generator NH Hazardous waste regulations were read and summarized. Franklin is considered a large quantity generator based on past manifests (App 9). Additional Objectives Work Accomplished Sludge Weight The specific gravity of Franklin's metal hydroxide was determined (0.74) and future shipments will include this value (App 10); this will accurately quantify Franklin’s waste. Recycling of Tanks Tank filling & retention were reviewed to see how often dumping occurs. Rinse waters were reviewed to see if recycling is achievable (App 11). Chromium Emissions The new air regulation on chromium plating -2- was mailed to Franklin. These regulations were read and summarized (App 12). Initial Response to DES was mailed out. Work will continue on this section to help Franklin comply with 1/96 rules: bath operating time, surface tension measurements, and operation & maintenance plan. Wastewater Treatment A flow diagram of the wastewater treatment system was developed. Polymer calculations were done to find correct concentrations for good floccing in the wastewater treatment system (App 13). Floor Plan A new floor plan of the entire facility was developed (App 14). Emergency Planning and Community Right-to-Know Regulations were reviewed and determined that Franklin must comply. Work will continue to complete the Tier II forms. Chemical Usage: Franklin uses a high quantity of chemicals, which is expected with this type of work. Chemicals are added to tanks when part appearance warrants. Tanks are emptied and refilled differently as noted in Appendix 12. Recycling is not possible at Franklin because the small room does not allow each plating process a separate line for alkaline & acid rinses. Dead rinses for each plating bath are used for makeup of the bath. Wastes Generated: Franklin has a wastewater treatment system which treats all of the tanks. A metal hydroxide is precipitated out and dried. About 4 yd 3 per year of metal hydroxide are manifested and shipped to a landfill in Michigan. About 55 gallons per year of Resol Trichloroethylene is used as a degreaser and is manifested for reclamation. Pollution Prevention Benefits: Regulatory compliance for hazardous waste was accomplished. A cleanup of old drums, spent material, and unused chemicals was performed and removal ongoing. New air regulations will be addressed and compliance obtained. References: GZA GeoEnvironmental, Inc., Hazardous Waste and Materials Regulations: Handbook 1, EPA Regulations, 40 CFR Parts 265, 355, 370, 372, 1993 Edition. State of New Hampshire, Department of Environmental Services, Hazardous Waste Rules, January 24, 1991. Rudy Cartier, NH Department of Environmental Services, Small Business Ombudsman, Concord, NH. Waste Reduction Assistance Report, Department of Environmental Services, January 12, 1994, Paul L. Lockwood. -3- Professor James P. Malley, Civil Engineering, University of New Hampshire. Dawson & Mercier, Hazardous Waste Management, 1986, pg. 314-331. Appendices: 1 -- Summary from NH Hazardous Waste Rules, Hazardous Waste Storage 2 -- Emergency Alerting and Response Procedures, Emergency Phone Numbers 3 -- Hazardous Waste & Facility Inspection Record, Inspection Plan 4 -- Flow Diagrams & Plating Room Flow 5 -- Waste Reduction Assistance Report 6 -- Safety Meeting 7 -- MSDS Inventory 8 -- Tank ID #, Tank Contents 9 -- Generator Classification -- Full Quantity Generator 10 -- Metal Hydroxide Sludge Weight 11 -- Tank Filling & Retention, Rinse Waters 12 -- Chromium Emissions 13 -- Wastewater Treatment (WWT) Flow Diagram, WWT Summary, Polymer Concentration Mixing Formula, WWT Light Floc 14 -- Floor Plan Signed: Approved: __________________________ Vickie Dycewicz, Summer Intern Pollution Prevention Program __________________________ John Cabral, President Franklin Electro Plating Co., Inc. -4-