Date: August 16, 2010 

Subject: Nationwide Costs for Conversion to Non-PFOS Fume Suppressants 

Emission Standards Technical Support and Post Promulgation Activities 

EPA Contract No. EP-D-06-118; EPA Work Assignment No. 4-6 

RTI Project No. 0210426.004.006 

From: Richard Marinshaw 

 Cindy Hancy 

To: Phil Mulrine, EPA/OAQPS/SPPD/MMG 

Wetting agent fume suppressants (WAFS) are used in most decorative chromium 

electroplating and chromium anodizing tanks and in many hard chromium electroplating tanks to 

comply with the requirements of the National Emission Standards for Chromium Emissions from 

Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium 

Electroplating NESHAP, 40 CFR 63, subpart N). Historically, the most effective types of 

WAFS have been based on perfluorooctyl sulfonates (PFOS). Due to concern about the health 

effects associated with PFOS-based WAFS, the U.S. Environmental Protection Agency (EPA) is 

proposing to eliminate the use of WAFS that contain PFOS2. The purpose of this memorandum 

is to estimate the costs associated with this proposed requirement. 

Section I of this memorandum presents the basis for the costs of converting and operating 

tanks subject to the NESHAP to non-PFOS WAFS. The estimated nationwide costs are 

discussed in Section II, and references are provided in Section III. 

I. Basis for Estimated Nationwide Costs

 

WAFS Costs

 To estimate the costs of converting and operating chromium electroplating tanks using 

non-PFOS WAFS, information was requested from a trade association, an EPA Regional Office, 

and several WAFS suppliers. Initially, the National Association for Surface Finishing (NASF) 

was contacted for relevant information. Attachment 1 lists the information requested. The 

NASF provided a list of non-PFOS WAFS suppliers, some cost and usage information, and the 

technical data sheets for one of the suppliers of non-PFOS WAFS.1 

 Because of their ongoing interest in the issue of PFOS use, a similar request was sent to 

the EPA Region V Office. Region V provided information regarding converting to non-PFOS 

WAFS and the relative costs for a chromium electroplating facility in the Region.2

 
2 

 Information on the costs, usage rates, and limitations on the use of non-PFOS WAFS for 

chromium electroplating was requested from the following six WAFS suppliers: 

• Electrochemical Products, Inc. (EPI) 

• Atotech USA Inc. (Atotech) 

• MacDermid Americas (MacDermid) 

• Enthone, Inc. 

• Uyemura USA 

• Haviland USA (Haviland) 

 Information on costs was received from five of the suppliers: MacDermid, Atotech, 

Enthone, EPI, and Haviland. The information consisted technical data sheets, material safety 

data sheets (MSDS), and other information provided in telephone calls and emails. The 

information included the cost per unit volume (e.g., dollars per gallon [$/gal]); the amount of 

WAFS needed initially when first converting or starting up a tank with non-PFOS WAFS; and 

the maintenance amount, or the amount needed to maintain an adequate concentration of WAFS 

in the tank bath to ensure that the surface tension remained below the required levels. 

 Additional information on the costs of WAFS was obtained from two reports: one 

prepared by the California Air Resources Board (CARB) and the other by the Naval Facilities 

Engineering Command. Table 1 summarizes the cost information that was obtained from all 

sources. 

Table 1. Summary of Cost and Usage Information for Non-PFOS WAFSa

Company/ 

Organization Product Name 

Cost Initial addition Maintenance additions 

($/gal) (gal/gal) (ml/A-hr) Other Units 

MacDermidb Minimist Liquid $140 0.0025 0.100 -- -- 

Chromklad EMS $140 0.0025 0.075 -- -- 

Atotechc Fumetrol 21 LF -- 0.0025 0.0075 -- -- 

Enthoned ANKOR PF1 -- 0.00175 0.010 

EPIe Emist $55 -- -- 0.2 % by volume 

Havilandf Chrome Mist Eliminator II $100 0.0005 -- 27.5 ml/day 

 CRV1 $130 -- -- -- -- 

CARBg Fume suppressant (typical) $185 -- 0.0075 -- -- 

NAVFACh Fumetrol 140 (PFOS-based) $150 -- -- -- -- a

 $/gal = dollars per gallon; gal/gal = gallon of product per gallon of tank solution; ml/A-hr = 

milliliters per ampere hour; ml/day = milliliters per day. 

b

 References 1, 3, and 4. 

c

 References 5 and 6. 

d

 Reference 7. 

e

 Reference 8. 

f

 Reference 9. 

g

 Reference 10. 

h

 Reference 11. 
3 

 In order to estimate the costs of using WAFS on an ongoing basis, information was 

needed on the unit cost, initial amount needed, and maintenance amount needed. The only 

products for which the information was complete were the MacDermid products and the Atotech 

product. Both suppliers provided the same initial addition amount of 0.0025 gallons of product 

per gallon of electroplating/anodizing tank solution (gal/gal). This value was used to estimate 

nationwide costs. With respect to maintenance additions, the amount needed for the MacDermid 

products (0.075 to 0.10 milliliters per ampere hour [ml/A-hr]) was about 10 times the 

maintenance amount needed for the Atotech product (0.0075 ml/A-hr). The maintenance amount 

reported by CARB was the same as for the Atotech product (0.0075 mL/A-hr). Since the 

MacDermid products cost per unit gallon was about the same as the Atotech product and the cost 

reported by CARB, the information indicated that using the MacDermid product would cost 

10 times as much as the Atotech product. (This seemed unlikely, but an attempt to clarify this 

with the supplier was unsuccessful). For this reason, the maintenance amount of 0.0075 ml/A-hr 

was used. 

 For the unit costs, the information from the CARB report was used because it represented 

a typical or average cost for WAFS. (Note that the unit costs for both PFOS-based and nonPFOS-based WAFS are reported to be comparable.1, 6) This unit cost ($185/gal) was actually 

based on 2003 dollars s that had been scaled up using an annual increase of 5 percent per year. 

To convert this unit cost to 2009 dollars, the 2006 unit cost reported by CARB ($185/gal) was 

converted back to a 2003 cost of $160/gal using the 5 percent rate, then scaled to 2009 dollars 

using the consumer price index, resulting in a unit cost of $186/gal. Using a unit cost of 

$186/gal and an initial addition of 0.0025 gal/gal, the average initial addition unit cost would be 

$0.47/gal. Using the same unit cost of $186/gal and maintenance amount of 0.0075 ml/A-hr, an 

average unit production cost of $0.00037/A-hr was calculated. 

Number of Affected Sources

 Communications from the NASF and Region V provided the only information comparing 

the relative costs of non-PFOS vs. PFOS-based WAFS. The NASF stated that, although there is 

no cost difference for most facilities, small facilities report that the non-PFOS-based WAFS can 

cost up to 20 percent more than PFOS-based products.1 According to Region V, the costs for 

non-PFOS WAFS are "slightly higher" than the costs for PFOS-based WAFS.2

 Based on this 

information, it was assumed that only small facilities would experience an increase in costs, and 

that those costs would average 15 percent of the total WAFS costs. 

 Table 2 shows the estimated distribution of chromium electroplating and anodizing plants 

nationwide, and Table 3 shows the corresponding number of each size of model plant. 
4 

Table 2. Estimated Number of Chromium Electroplating Plantsa

Process No. of plants 

Hard chromium electroplating 790 

Decorative chromium electroplating 740 

Chromium anodizing 240 

Total 1,770 a Reference 12. 

Table 3. Distribution of Model Plants by Size and Type 

Electroplating Type Size % of totala

No. of plants 

nationwide 

Hard Chromium 

Small 70% 553 

Medium 20% 158 

Large 10% 79 

Total 790 

Decorative Chromium 

Small 80% 592 

Medium 15% 111 

Large 5% 37 

Total 740 

Chromium Anodizing 

Small 75% 180 

Large 25% 60 

Total 240 

 Total, all plants 1,770 a

 Reference 13. 

 Table 4 shows the assumed percentage of each type of plant that uses WAFS for emission 

control. Table 4 also shows the resulting number of each size of model plant that would use 

WAFS to comply with the NESHAP, based on these assumptions. As indicated in the table, it is 

estimated that 111 small hard chromium, 533 small decorative chromium, and 162 small 

chromium anodizing plants use WAFS. 

Table 4. Estimated Number of Plants Using WAFS 

Electroplating Type Size 

No. of plants 

nationwide 

% using 

WAFSa 

No. of plants 

using WAFS 

Hard Chromium 

Small 553 20 111 

Medium 158 10 16 

Large 79 0 0 

Decorative Chromium 

Small 592 90 533 

Medium 111 80 89 

Large 37 60 22 

Chromium Anodizing Small 180 90 162 

Large 60 60 36 a Based on general knowledge of industry. 
5 

II . Estimated Nationwide Costs of Using Non-PFOS WAFS

 To estimate the nationwide costs associated with the proposed requirement to allow only 

non-PFOS WAFS in chromium electroplating and anodizing tanks, the annual cost per model 

plant was estimated using the model plant parameters developed for the NESHAP and the cost 

information described previously. Table 5 summarizes the estimated costs per model plant. (It 

should be noted that, for chromium anodizing, the electrical current varies throughout the 

anodizing cycle, and there is no model plant parameter for rectifier capacity. Instead, the same 

rectifier capacity for hard chromium electroplating was used for these estimates.) 

Table 5. Annual Non-PFOS WAFS Cost for Small Model Plants 

Electroplating Type 

Tank 

volume, gala

Initial 

addition 

cost, $b

Rectifier 

capacity, 

A-hr/yrc

Maintenance 

cost, $/yrd

Total cost, 

$/yr 

Hard Chromium 1,730 $805 5,000,000 $1,843 $2,647 

Decorative chromium 1,730 $805 3,000,000 $1,106 $1,910 

Chromium anodizing 1,730 $805 5,000,000 $1,843 $2,647 a

 Reference 13 

b

 Based on unit cost of $0.47/gal. 

c

 Reference 13. 

d

 Based on unit cost of $0.00037/A-hr. 

 Table 6 shows the estimated nationwide costs for the proposed amendment to allow only 

non-PFOS WAFS to comply with the NESHAP. These costs were estimated by multiplying the 

cost per plant by the number of small plants nationwide, then accounting for the fact that the 

additional costs would be approximately 15% of the total costs of using WAFS. 

Table 6. Estimated Nationwide Costs for Non-PFOS WAFS 

Electroplating Type 

No. of 

plants 

Cost per 

plant, $/yr 

15% of annual 

plant cost/$/yr 

Total cost, 

$/yr 

Hard Chromium 111 $2,647 $397 $44,080 

Decorative chromium 533 $1,910 $287 $152,720 

Chromium anodizing 162 $2,647 $397 $64,330 

Total 806 $261,130 

III. References

1. Email from C. Richter, The Policy Group to P. Mulrine, EPA/OAQPS. PFOS Phaseout. 

June 3, 2010. 

2. Email from E. Newman, EPA/Region V to P. Mulrine, EPA/OAQPS. Info on PFOS Plating 

Surfactants. June 16, 2010. 

3. ChromKlad EMS, PFOS Free Spray Suppressant for Hard Chromium Plating (171172), 

Technical Data Sheet, MacDermid Americas 2009. 
6 

4. MiniMist Liquid, PFOS Free Spray Suppressant for Decorative Chromium Plating (187473), 

Technical Data Sheet, MacDermid Americas 2009. 

5. Fumetrol 21 LF, Chromium Mist Suppressant, Data Sheet, Doc. No.: 7032-US. Atotech 

USA Inc. January 11, 2010 

6. Telephone contact report, G. Barlow, Atotech USA Inc., with C. Hancy, RTI International. 

Cost of Use of Non-PFOS Fume Suppressants. July 7, 2010. 

7. ANKOR PF1, PFOS free low foam chrome surfactant, Technical Data Sheet, Enthone, Inc 

March 2009. 

8. Telephone contact report, L. Abbott, Electrochemical Products, Inc, with C. Hancy, RTI 

International. Cost of Use of Non-PFOS Fume Suppressants. July 7, 2010. 

9. Email and attachments from G. Torr, Haviland USA to C. Hancy, RTI International. Cost of 

Use of Non-PFOS Fume Suppressants. July 16, 2010. 

10. Proposed Amendments to the Hexavalent Chromium Airborne Toxic Control Measure for 

Chrome Plating and Chromic Acid Anodizing Operations. California Air Resources Board. 

August 11, 2006. 

11. Final Report for the Use of Wetting Agents/Fume Suppressants for Minimizing the 

Atmospheric Emissions from Hard Chromium Electroplating Baths, Technical Report TR2243-ENV, Naval Facilities Engineering Command, Port Hueneme, California. March 2004 

12. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, EPA/OAQPS. 

Estimated Number of Chromium Electroplating Plants. May 24, 2010. 

13. Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing 

Operations -- Background Information for Proposed Standards, Volume I (EPA 453/R-93-

030a). U.S. EPA, Office of Air Quality Planning and Standards. July 1993. 

 
7 

Attachment 1 

Information Needed for Phase-Out PFOS-Based Fume Suppressants 

• List of manufacturers or suppliers of substitutes for long-chain PFOS 

o Company name and address 

o Contact person name, phone number, email address 

• For each manufacturer and each product that is a substitute for long-chain PFOS: 

o Product name 

o Material safety data sheet (MSDS) 

o General chemical formulation, category or family of chemical, or some other term for 

classifying the chemical (if not specified on MSDS) 

o Unit cost (e.g., $ per gallon, if liquid; $ per pound, if solid or powder) 

o Working concentration in plating bath (e.g., ounces per gallon of plating tank 

solution) 

 If it differs by process type (e.g., hard Cr vs. decorative Cr), provide concentration 

for each process 

o Lifetime or replenishment rate (i.e., some measure of how long it persists in the bath 

or how often must it be added to bath) 

 If it differs by process type (e.g. hard Cr vs. decorative Cr), provide concentration 

for each process 

o Process applications and limitations (e.g., can it be used in all plating baths, can it be 

used in Cr anodizing baths, can it be used in black chromium plating baths, etc.) 

o Toxicity or other information that demonstrates why it is better for the environment 

than long-chain PFOS 

o Comparison of annual cost vs. annual cost for long-chain PFOS fume suppressant 

 If appropriate, differentiate by type of process (hard Cr, decorative Cr, etc.) 

• Case studies, journal articles, or other information describing how and where a product 

has been used, product performance, cost comparison, etc.