From: Erin Newman/R5/USEPA/US

To: Phil Mulrine/RTP/USEPA/US@EPA, Toni

K rasnic/DC/USEPA/US@EPA, Bradley Grams/R5/USEPA/US@EPA

Cc: Kimberly Harris/R5/USEPA/US@EPA, Erin

Newman/R5/USEPA/US@EPA

Date: 06/16/2010 04:49 PM

Subject: Info on PFOS plating surfactants

Hi Phil:

Per my voicemail, Brad Grams and I just got back from the NASF meeting in Grand Rapids. NASF did a nice job of connecting us with the people we needed to meet. Based on our data gathering for the RTR issue, here are

the most re levant pieces.

1. There are no "PFC free" alternative surfactants available commercially,but PFOS - free surfactants are all over the market now. This means the product has changed from a long chain PFC (C8) to a shorter chain PFC (C6). NASF asked folks about when we might see a C4 surfactant, but it's still in the R&D phase. As we have discussed earlier, there is debate among scientists if a C6 is a "medium" or "short" chain PFC. But it's my understanding that OPPT is focused on

restriction of C8s and above. Therefore, these alternatives are a better move for us and Region 5 would like to see the RTR discuss "non PFOS

surfactants."

2. The costs are slightly higher, but facilities using non PFOS

s urfactants considered the increased cost to be negligib le, expressed no issues meeting the PEL, and maintained product quality. Superior Plating in the Twin Cities said the cost increase for them was about $0.21/hour, but their lines have about $400/hour in profit so it was very reasonable. The other example had a slightly higher cost, but again said it didn't really impact their profits significantly.

3. The non PFOS surfactants are on the market now and available in the quantities needed. Changing over is a zero time difference for the facilities. They just stop using one surfactant and start using the other. They do see the PFOS decrease over time, but it takes several months to see the full drop.

4. The non PFOS surfactants are an easy switch for decorative and hard chrome platers , with the exception of the aeronautics plating. Boeing and DOD would have significant issues with changing this process quickly because it takes them years to get their plating specs approved.

5. The anodizing the chromic acid etch processes do not hav e non PFOS surfactants available at this time.Region 5 would like to pursue a quick changeover to non PFOS surfactants for those industries which have market options readily available. I am going to suggest a 12

- 18 month phase out after rule promulgati on as a starting point. NASF thought this was reasonable. At least one of the major surfactant suppliers has a commitment to be "PFOS free" within a year, so it certainly seems realistic. They do much of their business abroad and pointed out that Japan, the EU and Canada have already phased out PFOS or are on a schedule to phase out now.

As far as the anodizing and chrome etch processes, I am going to contact folks and ask more questions. I am not clear if the lack of non PFOS

surfactants is because 1. they typically use another control technology or 2. their processes are too chemically harsh for shorter chain PFCs or 3. they are a smaller part of the market and so it's not as profitable for the surfactant manufacturers to produce alternative for them . It might be a little of all three. Phil, if you think they typically use another control option, please let me know. I would like to discuss our options for addressing the chrome etch, anodizing, and aeronautic sectors via the RTR. There was a sugge stion in the Region that we could use the proposed rule as an opportunity to fully gather information on

a lternative surfactants available for etch and anodizing. (ie. if it's just a market issue that we have a lack of product, we'd like to push forward with possible additional time for those sectors to comply.)

I know the proposed rule is August, but when do we have to have the final

issued?

Brad and Toni, if I characterized anything incorrectly on the OPPT side, please correct me.

Thanks,

Erin

**********************************

Erin W. Newman

Environmental Scientist

U.S. EPA 77 West Jackson Blvd. (AR

- 18J) Chicago, IL 60604 newman.erin@epa.gov

(T): 312

- 886

- 4587 (F): 312

- 692

- 2465