From: Erin Newman/R5/USEPA/US 

 

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

Krasnic/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 relevant 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 

surfactants considered the increased cost to be negligible, 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 have non PFOS 

surfactants available at this time.

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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 promulgation 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 suggestion in the Region that we could use the 

proposed rule as an opportunity to fully gather information on 

alternative 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

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