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 substitute 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 Maintenance (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 for 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-mail: 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/english
Fra: Chuck French [mailto: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>, "timo.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 baths 

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 contact 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-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/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 Standards

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 Almodovar/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 regulate 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 contain 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 chemical 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 measurements 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 revised 
standards, after considering public comments, by August 2012. 

We compiled data from several electroplating sources that demonstrate 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 data 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 suppressants.

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 suppressants.

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