P2 Research and Implementation for Michigan Metal Finishers or PRIM. A project conducted by the National Center for Manufacturing Sciences (NCMS) and National Association for Surface Finishing (NASF). Users can access several project products, including capsule reports and an on-line rinsing manual. The Rinsing Manual is designed to help metal finishing facilities improve their rinsing processes. The manual is a step-by-step guide with plain language, graphics and video. A section of the manual contains a new method for calculating potential savings in dragout that would be expected if the rack drain time over the plating tank were extended by a few seconds.

Technical Articles. The articles focus on technical, scientific, regulatory, and practical issues for the finishing industry. All STERC users have free access to this feature.

PFAS Resource Center. The National Association for Surface Finishing has launched a new on-line resource. The site includes background information on the use of PFAS in the surface finishing industry and extensive technical resources.

NASF Public Policy Update December 2022

The NASF continues to be active over the winter on major regulatory and legislative issues at the federal and state level that specifically impact member companies. Several new developments should be of interest to the industry and are summarized below.

• EPA Seeks Information from Surface Finishing Industry for PFAS Water Discharge Rule
• EPA Issues Draft IRIS Human Health Assessment of Hexavalent Chromium
• EPA Issues Guidance for Reducing PFAS in Water Discharge Permits
• CARB to Hold Public Hearing on Rule to Phase Out Hexavalent Chromium Plating and Anodizing (More information)

NASF Public Policy Update October 2022

The NASF continues to be active over the fall on major regulatory and legislative issues at the federal and state level that specifically impact member companies. Several new developments should be of interest to the industry and are summarized below.

• EPA Releases Milestone Health Assessment for Hexavalent Chromium
• EPA Submits Proposed PFAS Drinking Water Standard to White House
• Congressional Letter Sent to Automakers Regarding Hexavalent Chromium
• EPA Creates New Environmental Justice and Civil Rights Office
• U.S. Supreme Court Hears Oral Argument on WOTUS Rulemaking. (More information)

Multi-Sector General Permit for Industrial Stormwater Discharges

On March 2, 2020 EPA published its proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) that authorizes stormwater discharges associated with industrial activity in areas where EPA is the NPDES permitting authority. (More information).

EPA’s Enforcement Policy Memorandum for the COVID-19 Pandemic

On March 26, 2020 the U.S. Environmental Protection Agency (EPA) issued a policy memorandum indicating that it will exercise enforcement discretion for any noncompliance that may result from the COVID-19 pandemic, provided that regulated entities take the steps that are set forth in the policy. “Enforcement discretion” is not a waiver of any environmental requirements. If, on a case-by-case basis, the EPA agrees that such noncompliance was caused by the COVID-19 public health emergency, discretion may be applied. Authorized states or tribes may take a different approach under their own authorities. Details of the policy are available at https://www.epa.gov/enforcement/enforcement-policy-guidance-publications#covid-19. See Q&As on the policy at https://www.epa.gov/enforcement/frequent-questions-about-temporary-covid-19-enforcement-policy#2.

With respect to the scope and applicability of the enforcement discretion policy, EPA laid out some brief summary points. 

• The enforcement discretion policy is temporary to accommodate regulated entities impacted by the unusual circumstances that are presented as a result of the COVID-19 pandemic. EPA will assess the continued need for and scope of this temporary policy on a regular basis and will update it if the EPA determines modifications are necessary.
• This policy will apply retroactively beginning on March 13, 2020.
• EPA has selected August 31, 2020, as the termination date for the temporary enforcement policy.
• The enforcement discretion does not apply to any criminal violations or conditions of probation in criminal sentences.
• This policy does not apply to activities that are carried out under Superfund and RCRA Corrective Action enforcement instruments.
• This policy does not apply to imports.

For potential civil violations, the enforcement discretion set forth in this temporary policy is subject to the following conditions (as quoted in the memorandum). 

1. Entities should make every effort to comply with their environmental compliance obligations. 
2. If compliance is not reasonably practicable, facilities with environmental compliance obligations should:

a. Act responsibly under the circumstances in order to minimize the effects and duration of any noncompliance caused by COVID-19;
b. Identify the specific nature and dates of the noncompliance; 
c. Identify how COVID-19 was the cause of the noncompliance, and the decisions and actions taken in response, including best efforts to comply and steps taken to come into compliance at the earliest opportunity;
d. Return to compliance as soon as possible; and 
e. Document the information, action, or condition specified in a. through d.”

In the policy memorandum, EPA states that it expects all regulated entities to continue to manage and operate their facilities in a manner that is safe and that protects the public and the environment.  Facilities are instructed to contact the appropriate regulatory authorities if facility operations impacted by the COVID-19 pandemic may create an acute risk or an imminent threat to human health or the environment.

NASF PFAS Resource Center is now live on the NASF web site

The National Association for Surface Finishing has launched a PFAS Resource Center. The site includes background information on the use of PFAS in the surface finishing industry and extensive technical resources.

Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA and PFOS, the latter of which was previously used in chrome plating fume suppressants. These chemicals are very persistent in the environment and in the human body and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.

Although PFOS use in the surface finishing industry represented less than one half of one percent of U.S. and global PFOS use, NASF has taken a very active role in addressing the PFAS issues. NASF proactively approached EPA and began a process that led to the industry itself requesting a national, industry-wide ban from EPA on the use of PFOS in chromium plating operations, which was finalized under a new federal Clean Air Act rule in 2012.

Visit the NASF PFAS Resource Center for historical information on PFAS use in the surface finishing industry, safer chemical substitutions, NASF actions and priorities, and extensive additional resources. All questions regarding the NASF and the surface plating industry’s environmental stewardship efforts to address PFOS in wastewater discharges should be directed to Christian Richter at crichter@thepolicygroup.com or Jeff Hannapel at jhannapel@thepolicygroup.com.

Additional resource: EPA's PFAS Website provides background information, tools and resources, and identifies actions EPA has taken to address PFAS.

NASF and U.S. EPA Region 5 Partnership to Reduce Halogenated Solvents

The U.S. Environmental Protection Agency's (EPA) Region 5's office has initiated a voluntary air toxic reduction effort with regulated industry sectors in the states of Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin. Facilities covered by the Degreasing Organic Cleaners Halogenated Solvent Cleaners standard (40 CFR Part 63, Subpart T) may receive a letter from EPA Region 5 requesting their participation to help reduce or eliminate the use of the regulated solvents.

Halogenated solvents include:

• Trichloroethylene (TCE)
• Methyl chloroform (TCA, 111- trichloroethane)
• Dichloromethane (DCM, methylene chloride)
• Perchloroethylene (PERC)
• Carbon Tetrachloride (CTC)
  

The National Association for Surface Finishing (NASF) and the surface finishing industry has made significant progress in reducing the use of halogenated solvents and air emissions from these solvents. Historically, these solvents have been used to clean parts prior to finishing. A clean surface is critical to apply a quality surface finish, particularly to meet customer specifications. In some cases halogenated solvents are still in use because it is not feasible to use substitute solvents for some applications. Where halogenated solvents continue to be used, facilities implement a variety of control technologies to minimize air emissions.

Even with the success in reducing emissions of halogenated solvents from the surface finishing industry, NASF is partnering with EPA to help members identify more options for product substitution and improved control technologies designed to reduce or eliminate air emissions from the use of halogenated solvents. Solvent substitution may allow the facility to reduce or eliminate permit or other compliance requirements under the federal standard, protect worker health and reduce costs.

More information on alternative solvents can be found on EPA's website: https://www.epa.gov/p2/case-studies-safer-alternatives-solvent-degreasing-applications. More information about this initiative is available in EPA Region 5’s fact sheet, found on the Great Lakes Pollution Prevention Roundtable's website at: https://www.in.gov/idem/ctap/files/p2_business_resources_safer_solvents.pdf. In addition, NASF and EPA are planning to develop a webinar to provide more details on this initiative in the near future. For more information regarding the NASF/EPA partnership on this initiative, please contact Jeff Hannapel with NASF at mailto:mjhannapel@thepolicygroup.com.

NASF Completes Metals Loading Study Highlighting Industry’s Clean Water Success

NASF has released a study pointing to the finishing industry’s major success in reducing metals discharges to local water treatment utilities in recent decades. The surface finishing industry is subject to two categorical standards for wastewater discharged to publicly owned treatment works (POTWs). In the past three years, the U.S. Environmental Protection Agency (EPA) has conducted a review of the categorical standards and discharge limits. During that time, the NASF has been working closely with EPA officials to provide information and analysis on the industry’s progress on wastewater discharge improvements.