Date: August 16, 2010

Subject: Nationwide Costs for Conversi on to Non-PFOS Fume Suppressants Emission Standards Technical Suppor t 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) ar e used in most decorative chromium electroplating and chromium anodizing tanks and in many hard chromium el ectroplating tanks to comply with the requirements of the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electropla ting and Chromium Anodi zing Tanks (Chromium Electroplating NESHAP, 40 CFR 63, subpart N). Historically, the most effective types of WAFS have been based on perfluorooctyl sulfona tes (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 ba sis for the costs of converting and operating tanks subject to the NESHAP to non-PFOS WA FS. The estimated nationwide costs are discussed in Section II, and refere nces 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 re quested from a trade association, an EPA Regional Office, and several WAFS suppliers. Initially, the Nati onal Association for Surface Finishing (NASF) was contacted for relevant information. Attach ment 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 issu e of PFOS use, a similar request was sent to the EPA Region V Office. Region V provided in formation regarding converting to non-PFOS WAFS and the relative costs for a chromium electroplating facility in the Region. 22

Information on the costs, usage rates, a nd 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 fi ve of the suppliers: MacDermid, Atotech, Enthone, EPI, and Haviland. The information cons isted technical data sheets, material safety data sheets (MSDS), and other information pr ovided 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 WA FS 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 informati on that was obtained from all

sources.

Table 1. Summary of Cost and Us age Information for Non-PFOS WAFS a

Company/ Organization Product Name Cost Initial addition Maintenance additions ($/gal) (gal/gal) (ml/A-hr) Other Units

MacDermid b Minimist Liquid $140 0.0025 0.100 -- -- Chromklad EMS $140 0.0025 0.075 -- -- Atotech c Fumetrol 21 LF

-- 0.0025 0.0075 -- -- Enthone d ANKOR PF1

-- 0.00175 0.010
EPI e Emist $55 -- -- 0.2 % by volume
Haviland f Chrome Mist Eliminator II $100 0.0005 -- 27.5 ml/day CRV1 $130 -- -- -- -- CARB g Fume suppressant (typical) $185 -- 0.0075 -- -- NAVFAC h 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/anodizi ng tank solution (gal/gal). Th is value was used to estimate nationwide costs. With respect to maintenan ce 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 pro duct (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 th at 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 th e 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 us ing 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 th e 5 percent rate, then scaled to 2009 dollars using the consumer price index, resulting in a uni t cost of $186/gal. Using a unit cost of $186/gal and an initial addition of 0.0025 gal/gal, th e average initial additi on unit cost would be $0.47/gal. Using the same unit cost of $186/ga l 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 WA FS. The NASF stated that, although there is no cost difference for most facilities, small f acilities 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 pe rcent of the total WAFS costs.

Table 2 shows the estimated distribution of chromium electroplating and anodizing plants nationwide, and Table 3 shows the correspond ing number of each size of model plant.4

Table 2. Estimated Number of Chromium Electroplating Plants a

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 Mode l Plants by Size and Type

Electroplating Type Size % of total a 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 numbe r 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 ch romium, and 162 small chromium anodizing plants use WAFS.

Table 4. Estimated Number of Plants Using WAFS

Electroplating Type Size No. of plants nationwide % using WAFS a 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 an d anodizing tanks, the annual cost per model plant was estimated using the model plant parame ters developed for the NESHAP and the cost information described previously. Table 5 summari zes 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 para meter 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, gal a Initial addition cost, $ b Rectifier capacity, A-hr/yr c Maintenance cost, $/yr d 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 cost s 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 na tionwide, then accounting for the fact that the additional costs would be approximately 15 % of the total cost s 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 Spra y 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. Barl ow, 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 surfact ant, Technical Data Sheet, Enthone, Inc March 2009.

8. Telephone contact report, L. Abbott, Electroch emical Products, Inc, with C. Hancy, RTI International. Cost of Use of Non-PF OS Fume Suppressant s. July 7, 2010.

9. Email and attachments from G. Torr, Haviland US A to C. Hancy, RTI International. Cost of Use of Non-PFOS Fume Suppressants. July 16, 2010.

10. Proposed Amendments to the Hexavalent Chro mium Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations. Califor nia 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 Comma nd, Port Hueneme, California. March 2004

12. Memorandum from R. Marinshaw, RTI Intern ational, to P. Mulrine, EPA/OAQPS. Estimated Number of Chromium Electroplating Plants. May 24, 2010.

13. Chromium Emissions from Chromium El ectroplating 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 fam ily of chemical, or some other term for classifying the chemical (if not specified on MSDS)

o Unit cost (e.g., $ per gallon, if liqui d; $ 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 m easure of how long it pe rsists 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 limitati ons (e.g., can it be used in a ll 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 demonstr ates 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.