From: Christian Richter [crichter@thepolicygroup.com]

Sent: Thursday, June 03, 2010 12:02 AM

To: Mulrine.Phil@epamail.epa.gov

Cc: jhannapel@thepolicygroup.com; Marinshaw, Richard; Burns,

Sandra Subject: re: PFOS Phaseout
Attachments: 171172+CHROMKLAD+EMS[1].pdf; 187473+Minimist+Liquid[1].pdf; 187473+Minimist+US+Jan+09[1].pdf

Phil:

Here are some follow up MSDS sheets for the MacDermid alternatives that may also be helpful. Just let me know if additional information, again, might b e helpful.

Appreciate it.

Best regards,

Christian

From: "Christian Richter" <crichter@thepolicygroup.com>

Sent: Wednesday, June 02, 2010 11:45 PM

To: Mulrine.Phil@epamail.epa.gov Subject: re: PFOS Phaseout

Phil:

I wanted to get back to you on two items: (1) preliminary info on PFC alternatives in order to get feedback on what else may be helpful from the larger supplier community, and (2) status of information on actual vs. allowable concentrations of Cr6 for job shops. Re the latte r issue, we should have a better perspective by tomorrow sometime from a consensus of industry engineering experts.

On the PFC issue, let me know if the info below from additional suppliers may be meaningful. We may not be able to provide more detailed
i nformation at this point, but other suppliers may be able to get back to us as well in the coming days. I had sent it out some of our NASF committee members when I received it from you.

Best regards,

Christian

_______________________

· List of manufacturers or suppliers of substitutes for long

- chain PFOS

o MacDermid - Minimist Liquid (decorative chrome), Chromklad EMS (hard chrome)
o Atotech - Fumetrol 21
o EPi - E- mist 7
o Uyemura - Non

- Mist Lo H aviland - CRV

- 1

PFOS Mfg Info Request.doc

· For each manufacturer and each product that is a substitute for long

chain PFOS:

o Product name

- MINIMIST LIQUID, CHROMKLAD EMS o Material safety data sheet (MSDS) o General chemical formulation, category or family of ch emical, or some other term for classifying the chemical (if not specified on MSDS)

- Both are anionic fluorinated surfactant o Unit cost (e.g., $ per gallon, if liquid; $ per pound, if solid or powder)

v aries by container size and geography - $130 - $150 per gallon

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

TDS ATTACHED

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.) Minimist is for decorative chrome,

EMS for hard chrome and black chrome o Toxicity or other information that demonstrates why it is better for the environment than long

- chain PFOS
It is six fluorinated carbons that can't break down to PFOA. None of the components present in this material at concentrations equal to or greater than 0.1% are listed by IARC, NTP, OSHA or ACGIH as a carcinogen. 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.) Comparable for large users. Up to 20% increase for small or infrequent
users due to chemical b reakdown.

From: Mulrine.Phil@epamail.epa.gov Sent: Thursday, May 27, 2010 10:37 AM To: crichter@thepolicygroup.com Subject: PFOS Phaseout

Christian,

Previously you had mentioned that you could obtain some information on alternatives to PFOS fume suppressants. The attached file
summarizes the information we think we need to collect on alternatives to PFOS as a fume suppressant in chromium electroplating. We think we need to try to get all of the information listed. If we cannot, we can deal with it, but we should try to get it anyway. We are going to need to estimate nationwide costs, address the feasibility of the substitutes,and demonstrate that they are better for the environment than are long

chain PFOS. To do that, we are going to need some real data.

If you cannot provide it, could you at least provide names and contact information for the vendors of the products that account for most

of the marke t. We could then contact the vendors and request it from them ourselves. Maybe you could contact them and give them a head's up before we do. If it comes down to it, we can always use Section 114 authority to get the information. We can figure out how to deal with any information that is considered proprietary.

Please let me know if you have any questions or comments.

Thanks again,
Phil