California Chrome Shop Masters Tough Regulations James Bauer Manufacturing Engineering Manager Robbins & Myers, Inc. Fairfield, California

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1 By: California Chrome Shop Masters Tough Regulations James Bauer Manufacturing Engineering Manager Robbins & Myers, Inc. Fairfield, California Today, the rising demands of regulatory compliance is a major concern to practically every business and industry in the United States. And nowhere in the country - perhaps even the world - has any group felt the pressures of regulatory compliance more than chrome platers and chromic acid anodizers in California. Tough regulatory conditions in California have caused many chrome platers to reconsider their commitment to chrome processing and their willingness to continue operations in the state. Some chrome platers have converted to alternate finishing processes. Others have simply left. Still others have closed their doors forever. Rather than choose one of these options, the management of Robbins & Myers, inc. of Fairfield, California, decided to pursue a different course of action, one that would allow the company to continue its successful operation in California indefinitely. We decided to install a chrome plating system that would not only meet current California emissions standards, but also comply with several proposed riskbased regulations that are likely to adopted within the next two years. World Leader From our Fairfield location, we operate the world=s largest, most modern and well-equipped facility dedicated solely to engineering and manufacturing progressing cavity technology dates back to 1936 when we began manufacturing the Moyno7 progressing cavity pump. These pumps have earned a position as a world leader in fluids handling because of their performance, versatility and durability. Moyno Down-hole oil well pumps, introduced in 1981, are a vital part of this leadership position because of their premium quality and proven service life, even in wells with abrasive particles in the formation fluid. A chief ingredient of the Moyno Down-Hole pump=s extended service capabilities is the precision hard chrome plating of its rotor. To achieve this, Robbins & Myers operates several 20-foot-deep hard chrome plating tanks with an annual operating level that exceeds 70 million ampere-hours of plating. California Regulations In 1988, the Bay area Air Quality Management District (BAAQMD) adopted Regulation XI - Rule which mandates strict emission controls on all chrome plating and chromic acid anodizing tanks. This meant that large plating facilities such as Robbins & Myers= would be required to control hexavalent chrome emissions to below milligrams per ampere-hour. Compliance with this regulation had to be completed by July 1,1992. At the time Regulation XI - Rule 8 was adapted, Robbins & Myers exhausted its chrome plating tanks through adopted, Robbins & Myers developed a set of criteria that defined the Aideal@ chrome plating system. A paramount concern was identifying technology and equipment suppliers that could meet the new ampere-hour emission limit. The supplier eventually chosen would not only have to demonstrate proven experience in reaching that compliance level, but would also have to guarantee that we would be in full compliance once the installation of our

2 system was complete. Another important consideration was the potential for expansion. The company wanted the capability to introduce additional chrome plating tanks into the system in the future. A third critical need was the capability to meet the anticipated requirements of future EPA and California reglualtions. Other criteria included implementing a system that was cost-effective, configured in a Aclosedloop@(i.e. one not requiring waste treatment or the disposal of hazardous materials), reliable, and maintenance friendly. Table 1 contains an expanded Robbins & Myers equipment specification list. Equipment Selection After evaluating proposals from numerous suppliers, Robbins & Myers selected the Enforcer multi-stage eliminator from Midwest Air Products Company of Traverse City, Michigan. This four-stage mist eliminator had been installed in large number of industrial situations, and test results showed that it met the milligrams per ampere-hour requirement. The first stage of the system is a mesh pad housed in a specially constructed plenum as part of he exhaust hood. This stage is constructed of relatively course filaments and sis designed to remove the large mist particles. The next three stages are housed in the body of the unit and employ progressively finer filament mesh pads to remove progressively finer mist particles. Each stage is periodically washed with separate spray headers during short wash-down cycles of 1- to 30 seconds. The recirculation system is configured so that the latter two stages are washed with fresh water while the first two stages are washed with recirculated water from the wash down of earlier stages. This approach reduces by about two-thirds the amount of water that would otherwise be required to keep the mash pads clean. Design Refinements Before its new chrome plating equipment was constructed, Robbins & Myers visited the supplier to review the details of the final design. Suggested modifications from this review were incorporated into the deign to optimize the equipment to meet specific requirements. To reduce spare parts inventories and to simplify maintenance procedures, brand name motorized ball and float valves consistent with the valves used on other equipment in the Robbins & Myers plant were specified. To further reduce water consumption, an extra holding tank was added to the recirculation system. The control system was redesigned so that it could be integrated into the master panel used to control the entire plating operation. Among the other modifications made was a wash-down system to periodically clean the hood. Sheaves on the exhaust fan were set to permit operation a two-thirds capacity. Also, for faster access to the tank to make repairs or liner replacements. The exhaust rated selected for the system was based on the maximum exhaust recommended by

3 ACGIH (American Congress of Governmental Industrial Hygienists) for chrome plating tanks with 250 cfm per square foot of surface area. Since floating polyballs were to be excessive. However, Robbins & Myers= policy is that it is always better to lean on the side of employee health and safety. The reserve exhaust capacity would allow the company to add tanks at a future date and/or increase the current exhaust rate if needed. The Permit To Construct Prior to ordering its new chrome plating equipment, Robbins & Myers obtained a Permit to Construct from the local air quality district. This process can be time-consuming and costly if not properly executed, so we secured the services of Conserve Engineering of Laguna Beach, California, to prepare the engineering package fo its permit application. Installation, Start-up and Operation The company placed the order for its new chrome plating system with sufficient lead time so that it could schedule the optimum downtime for making the equipment changeover. System components that could be installed before the changeover without interrupting normal production operations were installed in the weeks prior to the changeover. The switch to the new system occurred over a three-day weekend. During that time, the old equipment was disassembled and removed and the new system was installed completely. Startup and operation of the new chrome plating system began the following work day with only minor difficulties encountered. During the first two months of operating the new system, only slight adjustments had to be made to the system=s wash-down sequencing to coincide with tank water demands. The system now operates in a closed loop with all collected chrome and wash-down water routed to the plating tanks when make-up water is required. Source Test After a two-month break-in period, the new equipment was source tested at three amperage levels to simulate low-, medium- and high plating loads. Each test lasted two hours, and collected samples were tested by a BAAQMD-approved laboratory for total chrome and hexavalent chrome content. The average results reported showed milligrams per amperehour for total chrome and milligrams per ampere-hour for hexavalent chrome. A series of air tests were also conducted inside the facility. Eight hour air samples were extracted form the area next to the tanks as well as from an air sampler on an operator. Test results showed emission levels below mg./cubic meter. Cal OSHA exposure limits are.05 mg./cubic meter. Additional Regulations

4 In addition to Regulation XI- Rule 8, the EPA and California have developed other environmental and risk-based regulations that already, or soon will, impact the stat=s chrome platers. The new Robbins & Myers chrome plating system is designed to take these into account as they occur. Regulation AB-2588, or the Air Toxics A hot Spot@ Act, requires all companies in California to inventory their toxic air emissions. Larger emitters must then prepare a risk assessment to determine the health risk their emissions pose to their neighbors. If the cancer risk is equal to or higher than10 in one million, the emitting company must send letters to each household in the effected area. To offset the cost of administering this program, the BAAQMD has established the 1992 permit fee schedule based on the 1991 calculated risk level. This greatly impacted chrome platers because hexavalent chrome has a high unit risk value. Robbins & Myers saw its fees increase form $28,000 to $30,000 from 1991 to Other California districts are one or two years behind the BAAQMD schedule. When the impact of its new system is factored into th risk calculations, Robbins & Myers should see its fee structure drop by approximately 90 percent. Title III of the Clean Air Act will specify that large chrome platers must employ MACT (Maximally Achievable Control Technology) to control chrome emissions. During 1992, the EPA is expected to announce that large chrome platers will have to limit total chrome emissions to below milligrams per cubic meter of exhaust air. The average emission from the new system has been detected to be under milligrams per cubic meter of exhaust air. Summary California chrome platers and chromic anodizers are currently the ones feeling the greatest pressure from tough regulatory conditions. However, this same situation will likely be experienced by chrome platers and chromic anodizers throughout the country during the next few years, and at that time, they, too, will have to choose whether they will change finishing processes, close their doors or comply with regulations. Robbins & Myers is please and proud that it decided to take a proactive approach regarding regulatory compliance. With its new chrome plating system, the emission levels are now well below the current requirements of Regulation XI - rule 8 and the anticipated requirements for the Clean Air Act and risk-based regulations that will likely be adopted within two years. By specifying equipment needs based on current and anticipated regulations and future production requirements. The company has been able to comply with the law, reduce permit fees and ensure expanded operations in the future. Table 1 A Ideal@ Equipment Specifications Criterion Proven Technology Description Equipment tested to mg/amp-hr. at numerous sites: capable of

5 meeting existing and anticipated regulations. Cost Competitively priced and within budget. No Effluent Closed-loop system to return all effluent to the plating tanks: no waste treatment requirements. No Toxic Disposal Minimum Footprint Minimum Downtime Operator Friendly No disposable filters requiring high replacement and disposal cost: no toxic disposal risk. Equipment to occupy approximately the same footprint as the replaced scrubber. Equipment installation to require less than five days of downtime. Capable of 24-hour/day automated operation with little or no operator attention. Maintenance Friendly Minimum maintenance requirements: easy accessibility for inspection, replacement or repair. Reliability Corrosion Resistance Expandable Capacity Performance and materials warranted: brand name components. All materials compatible with chromic acid. Capable of handling 30-percent additional air flow to cover future growth. Hood Improvements Higher ventilation rates; no hood or duct leaks; hood wash-down; modular hood design.

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