From: Elisabeth Fadum <elisabeth.fadum@klif.no>

To: Chuck French/RTP/USEPA/US@EPA

Cc: Maria Delvin <Maria.Delvin@kemi.se>, "timo.seppala@environment.fi" <timo.seppala@environment.fi>, Liselott Sall <liselott.sall@klif.no>

Date: 05/21/2012 08:39 AM Subject: SV: SV: PFOS alternatives

- use in Electroplating industry

Dear Chuck

I have been in contact with our galvanoindustry.

For the electroplating industry with the Cromium VI baths, a branch contact told me that they have not found any substi tute as fume suppressant that work satisfactorily.

As for the decorative plating with the chromium III baths, they have fully substituted the use of PFOS.
The substitutes are; 1) Wetting Agent CR (polyfluorosulphonic acid 27619

- 97

- 2) 2) Fumetrol 21 LF Ma intenance (polyfluorosulphonic acid 27619

- 97

- 2) 3) Fumetrol 21 (polyfluorosulphonic acid 27619

- 97

- 2)

My industry contact said that this has been done without any difficulty and at no higher costs and these substitutes for decorative plating can be used fo r electroplating but they need to use double amount which will increase the costs. For further information, please contact Ms. Annasofia Grønqvist in Atotech,

Sweden. Contact details: Phone: +46

- 11 361170, Email: annasofia.gronqvist@atotech.com , Internet:

www.atotech.com

Best regards

Elisabeth Fadum Senior adviser, Climate and Pollution Agency

_____________________________________________________________

E

- ma il: elisabeth.fadum@klif.no

Phone: +47 22 57 34 42

– Fax: +47 22 67 67 06 Address: PO Box 8100 Dep, NO

- 0032 Oslo, Norway (Strømsveien 96)

Web: http://www.klif.no State of the Environment Norway: http://www.environment.no Guide to Regulations in Norway: http://www.regelhjelp.no/englishFra: Chuck French [ mai lto:French.Chuck@epamail.epa.gov ]

Sendt: 8. mai 2012 15:22

Til: Liselott Sall Kopi: Elisabeth Fadum; Maria Delvin; timo.seppala@environment.fi

Emne: Re: SV: PFOS alternatives

- use in Electroplating industry

Thank You!!!

Liselott Sall

--- 05/08/2012 04:12:52 AM

--- Dear Mr. Chuck French, We have banned use and production of PFOS in Norway in 2007. Use in decorativ

From: Liselott Sall < liselott.sall@klif.no > To: Chuck French/RTP/USEPA/US@EPA

Cc: Maria Delvin < Maria.Delvin@kemi.se >, " t imo.seppala@environment.fi "

< timo.seppala@environment.fi >, Elisabeth Fadum < elisabeth.fadum@klif.no > Date: 05/08/2012 04:12 AM Subject: SV: PFOS alternatives

- use in Electroplating industry

Dear Mr. Chuck French,

We have banned use and production of PFOS in Norway in 2007. Use in decorative plating is phased out, but our electroplating industry is still allowed to use PFOS as a fume suppressant for galvanic ba ths containing chromium in closed systems, and they are working towards a phase out of their use of PFOS. We have been in contact with our industry, and my colleague, Elisabeth Fadum, will pass on you inquiry to them and make contact with the wright contac t persons within the industrial associations and you.

In Sweden you can contact, Maria Delvin and in Finland, Timo Seppälä. If possible they will pass on you inquiry to the wright associations/contact persons in their countries.

Kind Regards,

Liselott Säll Senior Advisor, Climate and Pollution Agency

_____________________________________________________________

E

- mail: lis@klif.no

Phone: +47 22 57 35 77

– Fax: +47 22 67 67 06 Address: PO Box 8100 Dep, NO

- 003 2 Oslo, Norway (Strømsveien 96)

Web: http://www.klif.no State of the Environment Norway: http://www.environment.no Guide to Regulations in Norway: http://www.regelhjelp.no/english

_____________________________________________________________

The Climate and Pollution Agency is the former Norwegian Pollution Control Authority (SFT).Fra: Chuck French [ mailto:French.Chuck@epamail.epa.gov ]

Sendt: 8. mars 2012 02:07

Til: Chuck French Kopi: Liselott Sall

Emne: Re: PFOS alternatives

- use in Electroplating industry

Dear Ms. Liselott Sall,

In the last paragraph of this email below I wrote "Sweden", but I meant to say in "Norway or elsewhere..." Let me know if you have questions.

Thank You!!

Chuck French Group Leader Metals and Inorganic Chemicals Group Office of Air Quality Planning and Stand ards

U.S. EPA

Phone: 919

- 541

- 7912

----- Chuck French/RTP/USEPA/US wrote:

-----

To: liselott.sall@sft.no

From: Chuck French/RTP/USEPA/US

Date: 03/06/2012 09:10PM Cc: Phil Mulrine/RTP/USEPA/US@EPA, Paul Almodova r/RTP/USEPA/US@EPA Subject: PFOS alternatives

- use in Electroplating industry

Dear Ms. Liselott Sall,

I was informed by colleagues (in U.S. EPA) that you might be able to help us obtain information on the

use of non

- PFOS surfactants in the Electroplating industry. Therefore, I am sending you a request, as

described below.

We are in the process of revising the U.S. EPA National Emission Standards for Chromium Electroplating and Chromium Anodizing (i.e., Chromium Standards). The Chromium Standards regulat e chromium emissions from chromium electroplating and chromium anodizing tanks. Under the current standards, facilities that perform electroplating have two options: 1) they can limit the concentration of chromium in their emissions below specified levels; or 2) they can maintain the surface tension of the electroplating bath below specified limits. Most facilities in the U.S. that comply with the second option (i.e., surface tension limits) currently use chemical fume suppressants or surfactants that conta in perfluro

- octyl sulfonates (PFOS) to reduce surface tension.

However, the EPA recently proposed 2 changes to the Chromium Standards that relate to the use of fume suppressants. First, in October 2010 we proposed to prohibit the use of PFOS

- based chemic al fume suppressants. Secondly, in January 2012 we proposed to reduce the surface tension limits to reduce

chromium emissions.

The existing standards (established in 1995) include a surface tension limit of 35 dynes per centimeter (dynes/cm), based on me asurements of surface tension using a tensiometer. We proposed to reduce this limit to 33 dynes/cm. For facilities that use stalagmometers to measure surface tension, we proposed to reduce the surface tension limit from 45 dynes/cm to 40 dynes/cm. We will receive and review public comments on these proposed standards in the near future, and then we plan to publish final revisedstandards, after considering public comments, by August 2012.

We compiled data from several electroplating sources that demonstra te that by lowering the surface tension we can achieve significant reductions in chromium emissions. However, these data are from

facilities that use PFOS

- based fume suppressants. Industry representatives in the U.S. have questioned whether it is practical to reduce the surface tension to the proposed levels using fume suppressants that do not contain PFOS (i.e., non

- PFOS fume suppressants). They also questioned whether doing so would achieve significant emissions reductions. We are now trying to collect da ta on the use of non

- PFOS fume suppressants. Specifically, we are requesting data and information on the following:

1. The effectiveness of non

- PFOS fume suppressants at limiting surface tension in electroplating tanks compared to PFOS

- based fume suppress ants.

2. The relative costs of using non

- PFOS fume suppressants compared to the costs of PFOS

- based fume
suppressants.

3. Data that indicate non

- PFOS fume suppressants can consistently achieve surface tensions at or below 33 dynes/cm (based on tensiometer measurements) or 40 dynes/cm (based on stalagmometer measurements) in chromium electroplating or chromium anodizing baths.

4. Data that relate chromium emissions to surface tension levels for chromium electroplating tanks that

contain non

- PFOS fume suppres sants.

We would greatly appreciate your assistance in collecting this information. Please let us know if you have any data or information from Sweden or elsewhere on this topic that you can send to us, or if you can refer us to specific reports, websites, persons, or organizations where we may be able to find this information. If so, please send us such information by April 9, 2012.

Thank you and please let me know if you have any questions.

Chuck

Chuck French Group Leader Metals and Inorganic Chemicals Group Office of Air Quality Planning and Standards

U.S. EPA

Phone: 919

- 541

- 7912