Reclaiming/Recovering Precious Metals from Metal-Finishing and Plating Operations
By: Kevin Beirne,
Sabin Metal Corp., E. Hampton, NY
Metal platers are under increasing pressure from many sources,
not the least of which are from environmental compliance enforcement agencies whose main concerns are proper handling and disposal of hazardous materials used in plating processes. More stringent environmental laws—and tougher enforcement policies—from regulatory agencies at all levels have forced closures of some plating facilities at worst, and consolidation of others at best to help minimize an organization’s exposure to stiff penalties. In this tightly structured business environment, add the pressures of higher operating costs, tighter labor markets, tougher competition, difficult operating conditions, and you have the makings of a steepening uphill curve towards success.
No doubt you are quite familiar with this scenario. And if you use precious metals in your plating process, you face one more serious issue with regard to recovering them (particularly important towards adding profits) from spent solutions and unusable plated parts. That issue is environmental liability, making you responsible—along with your refiner—for any atmospheric or effluent discharge which occurs whether your refiner is recovering your specific precious metals or anyone else’s. Regardless of fault, the "deep pockets" concept of liability—now virtually legal precedent—will be used and is enforceable.
AVOID LEGAL/ENVIRONMENTAL PROBLEMS WHEN SELECTING A REFINER
The precious metals refining industry does not enjoy an especially sterling reputation with regard to environmental responsibility. When selecting a refiner, you must be aware not only of how your materials will be processed but those of the refiner’s other customers as well. You must do diligent homework, since failure to do so could have serious negative consequences (a typical example of these consequences is shown below). For example, you should determine how solids, liquids, or gaseous byproducts are handled at the refiner’s facility.
Requesting documentation may also help you determine that the refiner you select does not violate any applicable environmental law or regulation. CERCLA (Comprehensive Environmental Response, Compensation and Liability Act), also known as the Superfund Act addresses the joint customer/refiner responsibility. This law mandates that both the company which is the source of the material for precious metal recovery and the precious metal refiner share in the "cradle to grave" responsibility as well as the future liability for the proper treatment of the material. Essentially the environment must be protected to avoid serious financial and legal consequences: your refiner’s violation of these laws or regulations could result in heavy fines and legal costs to you.
As an example of what can go wrong, consider this recent case:
The Defense Reutilization & Marketing Service (DRMS) of the U.S. Government is charged with the task of disposing of excess property of the Department of Defense (DOD). This program includes many functions, one of which is the recovery of precious metals from obsolete electronic equipment (i.e., instrumentation, computers, etc.). In the past DRMS has attempted to accomplish this objective by using a number of contractors without first verifying their environmental approval status. This lack of due diligence has resulted in the U.S. Environmental Protection Agency (EPA) assessing DRMS third- party cleanup costs in excess of $22 million under CERCLA.
An excellent way to determine if a facility meets these criteria is to look for the effective utilization of sophisticated technology such as afterburners, baghouses, wet scrubbers, and liquid effluent neutralizing equipment. Also evaluate the refiner’s approval status with local, state and federal agencies. A precious metal refiner should be willing to furnish copies of all required documentation. These include permits under the Clean Air and Clean Water Acts and proof whether the company qualifies as a bonafide precious metal refiner as specified in the preamble to the BIF rule (Boiler and Industrial Furnace) and its amendments.
Ideally, your goal is to select a "zero discharge" refiner: one that does not produce any effluent or hazardous waste by-products.
HOW TO SELECT A PRECIOUS METALS REFINER
To ensure that your relationship with a precious metals refiner will be mutually profitable and based upon trust and fair treatment, you must address several key questions. Does it use state-of-the-art techniques and equipment for measuring the precious metals content of the materials to be reclaimed? Does it enjoy a long track record and a good reputation within the industry? Who are the refiner’s other customers and can you obtain references? Does it have the financial resources to pay you in a timely manner?
You should also carefully evaluate the processing methods the refiner uses for reclaiming precious metals. To ensure maximum "yield", look for a refiner that maintains a modern, well-equipped analytical laboratory. The ideal facility would be one that utilizes classic volumetric, gravimetric, and fire assay techniques, advanced X-ray fluorescence equipment, atomic absorption, and Inductively Coupled Plasma (ICP) emission spectroscopy. These techniques have been approved by the American Bureau of Standards and by the New York Metal Exchange/Commodities Exchange (NYMEX/ COMEX). When used together, they provide the most exacting methods for determining precious metal content in spent materials, thus assuring you the highest possible returns.
Choose a refiner that has significant in-house capability and does not rely on subcontractors. The more it costs your refiner to process your materials, the less your overall return will be. Depending upon the specific precious metal bearing recyclable material to be reclaimed, refiners generally use a combination of pyro-metallurgical and hydrometallurgical processes to achieve the highest possible metal recovery at the lowest possible cost.
To cultivate trust, the refiner you select should be willing to provide you with detailed weight and analysis reports on your shipments. The most advanced laboratories typically assay sample materials in triplicate to assure precise precious metal measurements. A reputable organization will allow you to be present during the sampling of your materials and will permit you to conduct your own independent analysis if so desired.
Doing your own due diligence before you select a refiner will reduce the likelihood of problems down the road. And remember, whether you like it or not you are a "partner" of your precious metals refiner—at least that’s how the EPA may see it.
EXAMPLE OF AN EFFICIENT PROGRAM
Following is an example of how a productive, mutually rewarding precious metal recovery program works for a manufacturer of electronics and electrical products with a number of facilities around the country.
Panduit Corp. in Tinley Park, IL produces electronics and electrical products in a number of facilities around the country. Two of its facilities in Illinois—the Terminal Division in New Lenox and the Networks Division in Orland Park—have plating operations, both managed by Jim Brinsky, the company’s plating director. Panduit uses gold to plate contacts for electrical communications connectors. Because of high operating costs, in large part attributable to environmental compliance issues, Brinsky said it has been in the company’s best interest to minimize the number of plating facilities around the country. Panduit uses recycled water systems at both plating facilities to eliminate any possibility of accessing the public waterways. "We do all of our own water recycling and it can be very costly…the actual water treatment costs as much as the plating facility," Brinsky added.
Panduit is keenly aware of the implications associated with its precious metal recovery program, according to Brinsky. For example, a closed loop process for its recycled cyanide water is incorporated. Cyanide rinsing tanks, and spent gold plating baths are put into drums and sent out for refining; this is maintained in a liquid form because, according to Brinsky, "We found from experience in the past, we wanted to know how much gold we had. The accurate way you can know what you have prior to sending it to a refiner, is to keep it in liquid form. If you know what the concentration on a 55 gallon drum is, and you agree with the refiner on volume, then you have a real good idea, you know by atomic absorption spectrophotometry what to expect in return."
Obviously recovering maximum value for its recycled precious metals is important to any organization, and Brinsky agrees that no one likes surprises. "That’s the kind of control we want when we deal with a refiner," he added. In addition to the cyanide bath slurries, Panduit creates plated scrap metal waste from parts like connectors or other plated parts that have been rejected or are unusable for reasons such as obsolescence, engineering test samples, or are otherwise unusable. Even plated parts on the end of reels which can’t be put through an assembly machine are recycled for their precious metals, Brinsky added.
Panduit had been stripping the gold and generating liquid to determine exactly how much gold content there was in the scrap. This changed when we "established a relationship with a refiner that I was confident with," Brinsky said. Once this occurred, Brinsky was able to save labor and costs for chemicals used for stripping by sending plated parts without processing which saved substantial time and effort. "The main thing in selecting a refiner as far as we are concerned," Brinsky said, "is that we don’t get any surprises. When you’re dealing with the solids like manufactured products, that is a non-hazardous waste when it’s shipped out of our plant. In that case, the only thing you really expect is that the refiner will assist you to make sure the transportation is set up to get the shipment to his facility, and once it arrives at his facility that there is a prescribed amount of time that the refining is done." When asked about the importance of this, Brinsky pointed out that he likes to agree on a date for settlement, so that the "refiner cannot play the market as far as paying lower returns due to market declines for a particular day. You agree on a certain date that the settlement is going to occur — regardless of what happens in the market, whether something goes down or whatever; we believe this is a much better policy," Brinsky added.
Brinsky stressed the issue of transportation with regard to hazardous waste materials. Because the plated parts are not considered hazardous, but the slurry material is because it contains cyanide, "we rely on our refiner to help us set up a hazardous waste hauler to go across state lines and get the material to them." In all regards, the idea is to "minimize our involvement once we have a refiner who we consider to be fair and provide fair value for our returned precious metals," Brinsky concluded.