DRAFT

Sustainable Technology Partnership

for Surface Finishing

A Multimedia Pilot Project to Address Emerging Chemical Concerns

The Minnesota Association of Metal Finishers (MnAMF) and the National Association for 

Surface Finishing (NASF) propose to work voluntarily with EPA Region 5, municipal 

wastewater treatment authorities in the State of Minnesota and the Minnesota 

Pollution Control Agency (MPCA) to reduce and, where technologically feasible, 

eliminate the Minnesota finishing industry’s use of long-chain perfluorinated 

compounds in fume suppressants.

This proposal points to a multimedia opportunity at the local level to address the mutual 

concerns and overlapping program objectives of EPA’s Office of Air Quality Planning and 

Standards (OAQPS), Office of Chemical Safety and Pollution Prevention (OCSPP), Office 

of Water (OW) and Office of Solid Waste & Emergency Response (OSWER). The 

proposal also includes outreach to and collaboration with the local and national POTW 

community through individual operations and the National Association of Clean Water 

Agencies (NACWA).

I. General Project Focus

The industry trade organizations propose a pilot project with EPA Region 5 that is 

primarily focused on five areas: (1) immediate actions that can be adopted by the end 

of 2010 by companies in Minnesota that have not yet transitioned to commercially 

available substitutes; (2) collaboration with EPA, and State and local authorities in order 

to educate companies, minimize barriers to change and accelerate technology transition 

to “greener” chemistries; (3) informing agency multi-media decision making at the 

Office of Air Quality Planning & Standards in determining a reasonable 

reduction/elimination strategy for long-chain PFCs through the Risk & Technology 

Review/Residual Risk (RTR) process now underway for the federal chromium NESHAP; 

(4) practical outreach and education, utilizing available data from actions the industry 

has already taken in Minnesota to eliminate long-chain PFCs, while also protecting air 

and water quality; (5) Development of a replicable project that can be used in other 

states in Region 5 or nationally.

II. Brief Background

Regulatory standards for long-chain PFCs have not been established at the federal, state 

or local levels. However, the finishing industry’s use of fume suppressants containing 

PFCs has been required in order to comply with strict ambient air emission standards 
under the federal chromium NESHAP as well as the federal OSHA chromium permissible 

exposure limit. Fume suppressants containing long-chain PFCs have been highly 

effective in reducing chromic acid mist from electrochemical processes in the surface 

coatings industry.

Since 2007, the MnAMF and NASF have been supportive of the finishing industry’s 

transition to non long-chain PFC alternative chemistries for: (1) decorative chromium 

plating and, where feasible, for (2) chromic acid etch processes for plating on plastics; 

and (3) chromic acid anodizing. The availability of effective alternatives for each of 

these three processes can be illustrated as follows:

Surface Coating 

Process

Status of Long-Chain PFC

Alternatives

Decorative Chromium Plating Available

Chromic Acid Etch Emerging

Chromic Acid Anodizing Not Yet Feasible

III. Specific Goals for Proposed Pilot Project

The industry’s proposed pilot project with EPA Region 5 will be focused on three key 

goals:

o Reduce PFC Releases to the Environment – Limit long-chain PFC releases to the 

environment through a combination of: (1) introducing long-chain PFC reduction and 

elimination measures, (2) utilizing alternative chemistries, and (3) applying industry 

best management practices (BMP);

o Promote Green Chemistry and Alternatives Analysis in the Industry – Support the 

commercialization and further research and development of “green chemistry” and 

alternatives for fume suppressants in the form of sustainable substitutes for longchain PFCs; and

o Minimize Potential Risks While Maintaining Compliance – Ensure any potential 

risks of PFCs are minimized – along with potential substitution risks – while also 
maintaining compliance with the federal Chromium NESHAP and other applicable 

standards.

The MnAMF and NASF, in consultation with EPA and MPCA, will initially establish 

appropriate metrics to measure progress toward and achievement of these three goals 

that acknowledge the resource limitations of the small businesses participating in the 

partnership.

IV. Minnesota and National Surface Finishing Industry Commitments

The MnAMF has identified that there are potentially five member companies in the 

Twin Cities area that would participate in this pilot project. These five are the only 

surface finishing companies in the area known to have specific operations that involve 

one of three processes that require mist suppressants containing long-chain PFCs:

(1) Decorative chromium electroplating;

(2) Chromic acid anodizing;

(3) Chromic acid etch for plating on plastics.

Commercially available substitute chemistries are already being used by at least 2 of 

these 5 companies that employ decorative chromium processes. MnAMF members will 

pledge to eliminate the use of long-chain PFC based mist suppressants by the end of 

2010.

In addition to addressing long-chain PFC education for a smaller universe of finishing 

companies, the Minnesota surface coatings community at large (approx. 30 companies) 

has the opportunity in this project to review a broader set of industry best practices on 

water use reduction and P2 goals overall. The MnAMF and NASF will work with EPA to 

develop and disseminate up-to-date educational materials and assistance to the 

Minnesota-based finishing industry as needed.

Outreach & Coordination

Industry Education and Outreach – In addition to ongoing education efforts within the 

MnAMF and NASF with member companies on the effectiveness of alternative 

chemistries and best management practices, the MnAMF and NASF, in coordination 

with EPA and MPCA and MnTAP, will also engage in an outreach effort in Minnesota to 

identify non-industry association member companies that may be using PFC-based mist 

suppressants, provide information and educate them on how to efficiently and costeffectively transition to substitute chemistries.

Collaboration and Testing – The MnAMF and NASF will also continue discussions with, 

track and share industry progress with the local municipal wastewater treatment 

community in the state and with POTWs in other EPA Region 5 states, such as Ohio, 

Comment [MSOffice1]: Answer to BRG, et al: 

There are estimated to be only 5 Cr6 using member 

companies out of 22 MNAMF members. The other 

17 member companies out of the 22 would have no 

reason to use PFCs, as they plate or surface treat 

with other non-Cr6 metals (nickel, precious metals, 

aluminum anodizing, etc) that don’t generate 

chromic acid mist warranting reduction via mist 

suppressants. The PFC issues is Cr6 processspecific.
Illinois and Wisconsin. Industry representatives have already met with POTWs in 

Minnesota, as well as in Cleveland (NEORSD), Milwaukee (Milwaukee Metropolitan 

Sewerage District) and Chicago (Metropolitan Water Reclamation District of Greater 

Chicago). Where possible and if funding is available, the industry will also evaluate 

current trends, available data and specific impacts of existing and future PFC elimination 

or reductions on POTW influent, effluent and biosolids. The NASF will present and share 

information with EPA Headquarters, other EPA Regions and the POTW community, and 

deliver presentations on the industry’s efforts on the partnership at key industry and 

NACWA technical and policy meetings during 2010.

Technical Report – In consultation with EPA and MPCA and where funding is available, 

the industry will track the progress of companies that voluntarily transition to 

alternative chemistries or incorporate best management practices. In collaboration 

with EPA, the MnAMF and NAMF will evaluate the relationship between the 

introduction of substitutes and the reduction of effluent concentrations for long-chain 

PFCs. The industry will develop an article or technical report for publication highlighting 

the results of the pilot project and partnership.

V. Achieving USEPA Program Goals

The NASF is committed to working with EPA Region 5 and Headquarters to advance a 

multimedia approach to emerging chemicals of concern that reflect the agency’s top 

priorities in 2010 and in the future. The proposed pilot project will help EPA meet its 

program objectives as well as achieve specific environmental outcomes as follows:

Air – The NASF will continue its effort to educate its corporate members on actions 

necessary to meet the requirements of the federal chromium NESHAP. In working with 

OAR on the chromium NESHAP RTR process, this proposal will assist in expanding the 

adoption of appropriate substitute chemistries. As a consequence, the NASF will be able 

to support a reasonable regulatory phase-out of long-chain PFCs as mist control 

technology in the context of the revised chromium NESHAP. 

The industry’s effort with EPA OAR will also identify which of the three specific finishing 

processes may not be amenable to emerging chemistries on the market. As an example,

substitutes for decorative chromium electroplating appear to be successful, but more 

work may be required to switch over to new chemistries for chromic acid etch and 

chromic acid anodizing processes). In voluntarily reducing long-chain PFCs in finishing 

processes, this proposal also addresses the agency’s greenhouse gas reduction goals and 

the Administrator’s priorities of improving air quality and taking action on climate 

change.

Water – One of the seven EPA priorities recently announced by EPA Administrator 

Jackson was protection of the nation’s waterbodies. This proposal recognizes that the 
Administrator supports both traditional and innovative strategies to deal with complex 

water quality issues. The MnAMF and NASF’s pilot project reflects the Administrator’s 

priority to protect America’s Waters.

Toxics – Through this proposal, the Minnesota surface finishing industry, with assistance 

from key technical leadership in the chemical manufacturing and processing community, 

is seeking to provide a viable regional (and potentially national) voluntary project that 

responds to the EPA OCSPP Chemical Action Plans. The proposal also addresses the 

Agency’s CRRR and CRM goals and the Administrator’s priorities in assuring the safety of 

chemicals, expanding the conversation on environmentalism and building strong State 

partnerships. 

In integrating water use and management, air emissions management, pollution 

prevention and climate change concerns with toxics reduction and exposure prevention, 

NASF creates an extremely high-priority and key voluntary program for OCSPP and for 

EPA.

For follow up and questions, please contact Christian Richter at the National Association 

for Surface Finishing (202-257-0250) or Mike McMonagle at the Minnesota Association 

of Metal Finishers (612-617-3220).