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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 wor k 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 perflu orinated 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 Off ice of Air Quality Plann i ng and Standards (OAQPS) , Offic e 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 oper ations and the National Association of Clean Water Agencies (NACWA).

I

. General P roject Focus

The industry trade organizations propose a pilot project with EPA Region 5 that is primarily focused on f ive 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 educ ate companies, minimize barriers to change and acce lerate technology transition to “greener” chemistries; ( 3 ) inform ing agency multi

- media decision making at the Office of Air Quality Pla nning & Standards in determining a reasonable reduction/elimination strategy for long

- chain PFCs through the Risk & Technology Review/Res idual 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 f inishing industry’s use of fume suppressants containing PFCs has been required in order to c omply with strict ambient air emission standardsunder the federal chromium NESHAP as well as the federal OSHA chromium permissible exposure limit. Fume suppressan ts containing long

- chain PFCs have been highly effective in reducing chromic acid mist from electrochemical processes in the surface coatings industry.

S ince 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 pro cesses 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

– L imit long

- chain PFC releases to the
environment through a combination of: (1) introducing long

- chain PFC reduction and elimination measures, (2) utilizing alternativ e chemistries, and (3) applying industry best management practice s (BMP) ;

o Promote Green Chemistry and Alternatives Analysis in the Industry

– S upport the
commercialization and further research an d development of “green chemistry” and
alternatives for fume suppressants in the form of sustainable substitutes for long

chain PFCs ; and

o Minimize Potential Ris ks While Maintaining Compliance

– E nsure any potential
risks of PFCs are minimized

– along wit h potential substitution risks

– while alsomaintaining 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 tow ard 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 th at th ere are potenti ally five member companies in the
Twin Cities area that would participate in this pilot project. T hese five are the only surface finishing companies in the area known to have specific operations that involve

one of three processes that require mist suppr essants containing long

- chain PFCs:

( 1 ) Decorative chromium electroplating; ( 2 ) Chromic acid anodizing; ( 3 ) Chromic acid etch for plating on plastics.

Com mercially available substitute chemistries are already being used by at least 2 of
the se 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 s urface coatings community at large (approx. 30 companies) has the opportunit y 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 cost

effectively transition to substitute chemistries.

Collaboration and Testing

– The MnAMF and NASF will also continue discussions with,
track and share in dustry progress with the local municipal wastewater treatment community in the state and with POTWs in other EPA Region 5 states, such as Ohio, Comment [ MSOffice 1 ]: Answer to BRG, et al: There are estimated to be only 5 Cr6 using member

compan ies 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 wa rranting reduction via mist suppressants. The PFC issues is Cr6 process

specific.Illinois and Wisconsin. Industry representatives have already met with POTWs in Minnesota, as well as in Clevel and (NEORSD), Milwaukee (M ilwaukee M etropolitan
S ewerage D istrict ) and Chicago (Metropolitan Water Reclamation District of Greater Chicago)

. Where possible and if funding is available, t he industry will also evaluate

current trends , available data and spe cific 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 communit y, and
deliver presentations on the indu stry’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,

t he industry will track the progress of companies that vol untarily 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

- chai n PFCs. T he industry will develop a n article or technical report fo r publication highlighting the results of the pilot pr oject and partnership

.

V. Achieving USEPA Program Goals

The NASF is committed to working with EPA Region 5 and Headquarters to adva n ce 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 follo ws:

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 adopt ion of appropriate su bstitute 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 theAdministrator supports both traditional and innovative strategies to deal with c omplex 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 s urface fi nishing industry, with assistance
from key technical leadership in the chemical manufactur ing and process ing community

, is seeking to provide a viable regional ( and potentially national ) voluntary project that responds to the EPA OCSPP Chemical Action Plan s . The proposal also address es 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 m anagement, 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, plea se 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 ).