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OAR Box 1313 

Prepped by LaTeia Shed 

Document Number: 

38) ll-B-12 

Docket Number: 

A-88-02 

Printed 6/12/2008 9.03:29 AM Sheet 38 of 99 
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$ 

A-88-02 A-88-02 

MIDWEST RESEARCH INSTITUTI 

4505 Creedmoor Roa 

Raleigh. N.C. 2761 

Telephone (919) 781-575 

V 

Date: September 2, 1986 

(Finalized February 5, 1987) 

Subject: Site V1s1t--Br1ggs and Stratton 

Chromium Electroplating NESHAP i 

EPA Contract 68-02-3817; ESED Project 85/02* 

MRI Project 7717-K 

From: Robin Barker 

Charles Hester 

To: Al Vervaert 

ESED/ISB/SSS (MD-13) 

U. S. Environmental Protection Agency 

Research Triangle Park, N.C. 27711 

I. Purpose 

The purpose of the visits was to determine the suitability of the 

plant as a site for chromium emissions testing to assess the effectiveness 

of a mist suppressant 1n inhibiting misting. 

II. Place and Date 

Briggs and Stratton 

3333 West Good Hope Road 

Glendale, Wisconsin 53209 

(414) 352-3014 

Initial plant visit: June 5, 1986 

Followup testing visit: August 2, 1986 

III. Attendees 

Briggs and Stratton 

Cathy McConnell, Chemist (August 2, 1986) 

Alan Haase, Chief Chemist and Environmental Engineer 

(June 5 and August 2, 1986) 

Post Office Box 702 

Milwaukee, Wisconsin 53201 

Tom Drews, Plating Supervisor, Glendale (August 2, 1986) 

Peterson Associates 

Alberta Schumacher, (August 2, 1986) 

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U. S. Environmental Protection Aqency (EPA) 

Al Vervaert, ISB (June 5 and August 2, 1986) 

Midwest Research Institute (MRI) 

Charles Hester (June 5, 1986) 

Robin Barker (August 2, 1986) 

IV. Discussion 

Meetings were held with plant personnel to discuss the decorative 

chromium plating operation and possible emission testing at Briggs and 

Stratton. 

A. General 

The Briggs and Stratton facility 1s a captive shop primarily engaged 

1n decorative chromium plating of automotive door and Ignition locks for 

General Motors and others. The plant manufacturers about 180,000 locks 

per day. Decorative chromium plate 1s applied to zinc-cast lock 

components and keys. There are 840 employees at this plant, with 

approximately 22 1n the plating shop. The plating shop operating schedule 

1s 2 shifts/day, 5 days/week, 52 weeks/year. 

B. Process Description 

There 1s one decorative chromium plating Hne at this plant. The 

line is equipped with an automatic hoist that transfers each rack of parts 

through a series of tanks. It takes 70 to 80 minutes for each rack of 

parts to complete the plating cycle. The plating Hn e consists of the 

following tanks 1n series: 

( 1) alkaline soak clean* 

( 2) electroclean* 

( 3) add pickle 

( 4) copper strike 

(5) copper plate 

( 6) chlorinated water rinse* 

( 7) add pickle 

( 8) bright nickel plate* 

( 9) chromium plate 

(10) bisulfite rinse* 

•Following Tanks 1, 2, 3, 6, and 8 are a series of 2 to 3 countercurrent 

cold water rinse tanks. Following Tank 10 are a cold rinse tank and a 

hot rinse tank. 

The chromium plating tank 1s 2.4 meters (m) (8 feet [ft]) long, 

0.9 m (3 ft) wide, and 1.3 m (4.3 ft) high and has a capacity of about 

2,195 liters (i) (580 gallons) of plating solution. The plating tank 

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holds four racks at a time. Each rack holds about 100 work pieces. The 

plating time per rack per station 1s about 60 seconds. The normal 

operating voltage ranges from 4 to 5 volts and the amperage ranges from 

1,200 to 1,500 amperes of direct current. 

The plating solution 1s UDYLITE«'s CHROMYLITE* K-40-Z. The solution 

contains about 270 grams per Uter (36 ounces per gallon) of chromic add 

and a small amount of a fluoride catalyst. The normal operating 

temperature of the solution 1s 42°C (1078F). 

C. Emission Control 

Briggs and Stratton uses a chemical fume suppressant (FOAM L0K® L) 

In the chromium plating solution that 1s manufactured and supplied by 

UDYLITE*. The fume suppressant creates a layer of foam on the surface of 

the solution to Inhibit misting. The plating operator adds about 200 to 

500 milliliters (7 to 17 ounces) of FOAM-LOK* L to the bath every shift. 

The desired thickness of the foam layer 1s approximately 2.54 centimeters 

(1 inch) to control chromic ad d misting adequately without creating a 

foam drag-out problem from the plating tank. 

The chromium plating tank 1s equipped with a single-sided lateral 

hood with two offtakes. Any chromic ad d emissions are captured by the 

hood and ducted to a single packed-bed scrubber. The scrubber 1s 13 years 

old and was manufactured by Ceilcote. 

D. Conclusions 

Briggs and Stratton is a captive plating shop performing decorative 

chromium plating of locks. Emissions from the chromium plating tank are 

controlled by a mist suppressant and a packed-bed scrubber. There were no 

visible emissions from the chromium plating tank during the visits. 

Therefore, this plant 1s a candidate for emission testing to obtain 

uncontrolled emission data for a decorative chromium plating operation, 

Inlet testing would need to be performed when the fume suppressant was not 

1n use. However, plant personnel were very concerned that Occupational 

Safety and Health Administration guidelines for hexavalent chromium may be 

exceeded when the tank 1s tested for uncontrolled emissions without the 

foam blanket. As a result, Briggs and Stratton, the EPA, and MRI agreed 

to conduct ambient air sampling for chromium emissions Inside the plating 

shop while the plating tank was operated without a fume suppressant. It 

was agreed that Peterson Associates, a consultant to the Safety Department 

of Briggs and Stratton, would perform the ambient air sampling and provide 

EPA with a test report summarizing the test conditions and results of the 

ambient air sampling. On August 2, 1986, Ms. Alberta Schumacher of 

Peterson Associates conducted the ambient air sampling under the direction 

of Mr. Al Vervaert of EPA. 

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