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 Fi nishing 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 includ e 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 purcha sing marketing databases. NAS F 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 ar e 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 c omponents. 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 install ation of wastewater treatment technology in metal finishing facilities. It was noted that most facilities have limited space in which to install new

wastewater tre atment systems. NASF mentioned a facility in Milwaukee that recently installed a chemical p recipitation 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 be cause 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

N ASF.

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.