MEMORANDUM

TO: Metal Finishing Preliminary Category Review Record

FROM: Phillip Flanders, OW/OST/EAD

DATE: January 5, 2016

EPA met with the National Association of Surface Finishers (NASF) on August 19, 2015 

to discuss the Agency’s Preliminary Category Review of the Metal Finishing Point Source 

Category. The Review concerns the effluent limitation guidelines and standards (ELGs) for the 

metal finishing point source category (40 CFR Part 433) and the ELGs for the electroplating 

category (40 CFR Part 413).

Jan Goodwin and Phillip Flanders were in attendance from EPA. Jeff Hannapel and 

Christian Richter were in attendance from NASF.

EPA explained that it is seeking information about the demographics of the metal 

finishing industry that would include any available information on the number, location, size, 

finishing processes operated, products finished at metal finishing facilities. NASF mentioned 

that they do not currently have a good database of this kind of information, but has considered 

purchasing marketing databases. NASF estimates that the majority of metal finishing facilities 

have fewer than 10 employees. In addition, NASF mentioned that most metal finishers no longer 

operate as “captive facilities” but rather as “job shops” where they are often members of long 

and complicated supply chains. 

EPA and NASF discussed which industrial sectors and markets metal finishers in the 

U.S. are likely to be engaged in. NASF mentioned the automotive, defense aerospace, 

commercial aerospace, medical components. NASF noted that few shops operate in just one 

sector, rather most accept parts from many sectors. NASF anticipates that printed circuit board 

manufacture may be coming back to the U.S., however commodity and high volume products are 

processed in Mexico and China. Some U.S. original equipment manufacturers (OEM) are 

opening metal finishing operations in Mexico. U.S. facilities remain profitable by being flexible, 

innovative, and performing high quality work. 

EPA and NASF discussed the installation of wastewater treatment technology in metal 

finishing facilities. It was noted that most facilities have limited space in which to install new 

wastewater treatment systems. NASF mentioned a facility in Milwaukee that recently installed a 

chemical precipitation wastewater treatment system. 

NASF mentioned that there are only a few major suppliers for U.S. surface finishing and 

plating chemicals: Atotech, MacDermid, Enthone and Coventya. There are also a number of 

mid-size and smaller companies that supply chemicals. 

EPA and NASF also discussed the surface treatments that are being used today. In 

general, functional treatments are still a large market but decorative treatments are decreasing. 
Also fewer materials need finishing that in the past because of innovation of base materials and 

move to plastics and other non-metallic base materials. It was mentioned that facilities have 

moved away cobalt-phosphorous and switched zinc-nickel plating due to European Union 

regulations. 

NASF suggested that EPA compile a “wish list” of questions that it hopes to answer 

throughout the course of the metal finishing preliminary category review. EPA agreed with this 

course of action and plans supply NASF with a list of questions prior to the next meeting with 

NASF.

Lastly, NASF discussed their experience in the development of the NESHAP for PFOS 

and expressed a desire to work with EPA in crafting any new regulations that affect their 

industry.