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NASF POLICY UPDATE

Date: October 23, 2024
Category: Chapter News, Events, NASF National, Regulation

 

October 2024

 

 

EPA Delays PFAS Proposed Rule for Wastewater Discharges from Surface Finishing ‎Operations: Key EPA Activities Ahead‎

 

We noted in recent weeks during the NASF Washington Forum and in association chapter ‎meetings that EPA’s schedule for the proposed rule to address PFAS in wastewater discharges ‎from surface finishing operations has been delayed from December 2024 until May 2026. EPA ‎is currently in the process of reviewing, evaluating, and analyzing the data from the surveys. In ‎addition, the agency must take additional key steps during this period, including:‎

  • conducting further follow up on survey responses;‎
  • completing site visits and onsite sampling for a small group of facilities;‎
  • reviewing industry discharge data and treatment technology options;‎
  • evaluating financial and economic data;‎
  • assembling a small business impact panel to assess potential impacts on small ‎operations; and
  • developing proposed rule language.‎

With respect to site visits, the agency plans to conduct single grab samples of wastewater at 20 ‎facilities and multiple samples at another five facilities. EPA does not expect to begin site ‎visits and sampling until after the first of the year. ‎

 

The NASF Government & Industry Affairs team continues to meet with EPA officials on these ‎and other developments in the PFAS wastewater discharge rule. If you have any questions ‎regarding EPA’s rulemaking for discharges of PFAS in wastewater from surface finishing ‎operations, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎

 

EPA Identifies 27 Candidates for “Priority” Selections Under Federal Chemicals Program: ‎Organics and 4 Metals Included

 

In a significant new development, EPA in late September named 27 candidate chemicals from ‎which they will choose five substances to “prioritize” under the Toxic Substances Control Act ‎‎(TSCA) for risk evaluation and ultimately regulation. The list included 10 chemicals that were ‎identified last year and 17 chemicals that were included for the first time. For the first time ‎ever, four metals were included on the candidate list: antimony, arsenic, cobalt and lead, and ‎their compounds. ‎

 

The 10 substances from last year are 4-tert-octylphenol [also known as (4-(1,1,3,3-‎tetramethylbutyl)-phenol)]; the high-profile plastic additive bisphenol-A (BPA); hydrogen ‎fluoride (HF); the anti-cracking chemical in vehicle tires known as 6PPD; styrene; benzene; ‎ethylbenzene; naphthalene; tribromomethane; and triglycidyl isocyanurate.‎

 

The 17 new candidates are 1-hexadecanol; 2-ethylhexyl 2,3,4,5-tetrabromobenzoate (TBB); ‎creosote; di-n-octyl phthalate (DnOP); n-nitroso-diphenylamine; p,p’-oxybis (benzenesulfonyl ‎hydrazide); m-xylene; o-xylene; n-xylene; antimony and antimony compounds; arsenic and ‎arsenic compounds; cobalt and cobalt compounds; lead and lead compounds; long-chain ‎chlorinated paraffins (C18-20); medium-chain chlorinated paraffins (C14-17); and bisphenol-S ‎‎(BPS).‎

 

Under TSCA, the existing chemicals EPA selects for its risk evaluation process must first go ‎through a “prioritization” process lasting nine to 12 months, where the agency considers ‎available data on uses, risks and other properties of the chemical or chemical group. The agency ‎then designates each as either high- or low-priority, and then must immediately begin risk ‎evaluations for high-priority chemicals. Based on the risk evaluation EPA will identify any ‎‎“unreasonable risks” associated with the use of the chemical, and propose regulations and ‎management options to address those risks.‎

 

This year EPA also decided to release the candidate list in a more public forum and has ‎promised to expand public input and data-gathering in the pre-prioritization process, including a ‎public comment period. Last year, EPA released 20 candidates for TSCA review only at ‎closed-door stakeholder meetings and faced complaints over the process from environmental ‎and industry groups not invited to those sessions. ‎

 

If you have any questions regarding EPA’s candidate list or the TSCA risk evaluation process ‎for existing chemical, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎

 

EPA Proposes to Expand List of PFAS Subject to TRI Reporting

 

EPA in early October proposed to add 16 individually listed per- and polyfluoroalkyl substances ‎‎(PFAS) and 15 PFAS categories representing more than 100 individual chemicals to the Toxic ‎Release Inventory (TRI) list of toxic chemicals subject to reporting requirements. The proposed ‎PFAS chemical categories are comprised of an acid, associated salts, associated acyl/sulfonyl ‎halides, and an anhydride. ‎

 

EPA proposed to set a manufacturing, processing, and otherwise use reporting threshold of 100 ‎pounds for each individually listed PFAS and PFAS category being proposed for listing by this ‎rulemaking and to designate all PFAS listed under this action as chemicals of special concern. ‎Fortunately, most surface finishing operations would not typically exceed the reporting ‎threshold of 100 pounds of PFAS. Facilities should, however, make a determination whether ‎the reporting threshold is met, especially chemical suppliers of PFAS products.‎

 

Finally, EPA also addressed what events may trigger the automatic addition of PFAS to the TRI ‎list, such as where EPA has identified a specific toxic value for a PFAS substance. For ‎example, a facility must now report 6:2 FTS under TRI if the reporting threshold of 100 pounds ‎is exceeded.‎

 

EPA also announced that it plans to designate the new additions as “chemicals of special ‎concern” that would prevents the de minimis exemption from applying to the chemicals. Under ‎TRI’s de minimis exemption, facilities that report to the inventory are allowed to disregard ‎minimal concentrations of chemicals in mixtures or trade name products in reporting releases ‎and other waste management calculations. But the de minimis exemption, which EPA ‎characterizes as a burden-reduction tool, does apply to chemicals classified as “chemicals of ‎special concern.”‎

 

The comment deadline for the proposed rule is November 7, 2024, but several industry trade ‎groups have requested extensions of the comment deadline. More information on the proposed ‎rule and a complete list of new PFAS that may be subject to TRI reporting are available on the ‎EPA website here.

 

EPA Changes Name of RCRA Cleanup Program

 

On October 21, 2024, EPA announced that it is renaming its former Corrective Action Program ‎to the “Hazardous Waste Cleanup Program.” The program is responsible for remediation under ‎the Resource Conservation and Recovery Act (RCRA). According to EPA officials, renaming ‎the program is part of an effort to better explain the program’s goals in “plain English.” The ‎term “corrective action” is used in the RCRA statute and regulations to mean the cleanup of ‎hazardous waste and constituents, but in common use it has many other meanings, so the public ‎does not immediately connect it with cleanup. ‎

 

The new name for the program is not a change from a regulatory standpoint, as EPA will ‎continue to use the term “corrective action” as a regulatory and legal term. The rebrand is ‎simply intended to communicate more clearly the purpose and goals of the hazardous waste ‎cleanup program. ‎

 

NASF 1000

 

The NASF 1000 program was established to ensure that the surface finishing industry would ‎have resources to effectively address regulatory, legislative and legal actions impacting the ‎industry, NASF members and their workplaces. All funds from the NASF 1000 program are used ‎exclusively to support specific projects and initiatives that fall outside the association’s day-to-‎day public policy activities. The commitment to this program is one of the most vital ‎contributions made in support of surface finishing and directly shapes the future of the ‎industry. ‎

 

The sustained commitment from industry leaders has helped the NASF remain strong and ‎credible in informing regulatory decisions across the nation. Specific projects funded through ‎the NASF 1000 make a measurable difference in how the industry navigates emerging ‎challenges, communicates credibly with policy makers, and advocates for a strong science base ‎for rules or standards that affect surface finishing. ‎

 

Please consider supporting the NASF 1000 program. For more information, contact: Christian Richter (202-257-‎‎0250) or Jeff Hannapel (202 257-3756) with NASF.‎

 

 

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL FALL SEMINAR

Date: September 20, 2024
Category: Events, NASF Chapters, Regulation

NENASF logo

 

On September 18, 2024 the New England Chapter of NASF hosted their annual Fall Webinar for the benefit of their membership and the entire non-NENASF metal finishing community. This year’s event featured a cross section of varied technical presentations designed to enhance and broaden the knowledge of Wastewater Professionals as well as all interested members of the metal finishing community.   The event was presented free of charge to NENASF members, and at a modest fee for other interested parties, as an educational and bonding opportunity for the metal finishing community.

 

The Webinar was conducted by means of Zoom format and attracted about three dozen attendees. It consisted of three segments featuring three presenters over a two-hour period from 10:00am to 12:00 pm offering a user-friendly Zoom format for all attendees. In addition to offering vital regulatory and technical information the event also made available two Continuing Education Wastewater Treatment Operator Contact Hours needed for WWT Operator License renewal.

 

Fernando Carminholi from Hubbard-Hall opened the Webinar with a presentation on Membrane Filtration for a Cleaner and More Sustainable Future. His presentation showed factual technical data on the use of microfiltration as a means of removing saturated oil from cleaning solutions, thus adding to the life of the cleaning solution resulting in chemical make-up cost savings and disposal cost savings, thus reducing the impact to the environment with beneficial cost savings to the company. Fernando offered case studies that resulted in 35 to 45 % cost savings using membrane filtration over a multi-year period.

This was followed by a presentation by Brian Morrill, vice president of GZA GeoEnvironmental giving a detailed update on the rapidly evolving PFAS discharge regulation front. The EPA has already issued regulations on PFAS in public drinking water supplies, and wastewater discharge PFAS limit regulations are being mandated in the near future. The EPA is using the data accumulated by the comprehensive PFAS Survey that most metal finishers completed in early 2024 as a basis for promulgating PFAS discharge limits for our industry.

The webinar was concluded with a presentation by James Mitchell, R & D Associate chemist for PAVCO, who spoke on the use of inert Ion-Exchange Membrane Anodes used in acid zinc and zinc-nickel solutions as a means of minimizing metal growth in bathes thus offering cost and environmental savings resulting from not having to “cut” and dispose of plating solutions over time.

 

Once again, we want to give special thanks to Chris Capalbo, moderator, all the member of the NENASF who contributed to this successful Program, and a special thanks to the talented speakers who offered their time and talent to make this presentation come to fruition for the benefit of the Metal Finishing Community.

NENASF ANNUAL RCRA AND ENVIRO UPDATE SEMINAR WITH A NEW TWIST

Date: May 18, 2024
Category: Chapter News, Events, NASF Chapters, Regulation

NENASF LOGOMCTA

The New England Chapter of the NASF was pleased once again to offer a Seminar for the benefit of its members, and the metal finishing community, featuring annual mandatory RCRA training as well as environmental updates on hot button issues impacting the metal finishers. This year, for the first time, the Seminar was offered free of charge to all New England Chapter members in good standing as an extra membership benefit and a means of thanking loyal members for their support of NASF ideals at both the local and national level. The event took place on May 15, 2024 at the Courtyard Marriott in Marlborough Massachusetts.

The more than thirty-five attendees first received their mandatory RCRA training by Jorge Bejarano of HRP Associates. This training is a requirement for all personnel who are responsible for hazardous chemicals and waste handling, storing and offering for transportation. Jorge gave a fast paced and thorough presentation covering all aspects of safe and proper hazardous chemical handling.

The second segment of the Seminar was dedicated to Environmental Issues. Three  speakers who were present from the Department of Energy & Environmental Affairs, along with one via video link, offered an enlightening look into the newly emerging Environmental Justice initiatives which involve community interaction between industry and residents of communities that are disproportionately impacted by industrial pollutants. This was followed by a presentation by MCTA Executive Director Katherine Robertson who gave insight into the legislative activities on Capitol Hill in Boston with special emphasis on updating TURA activities and potential industry impact. The closing speaker was Brian Morrill, Associate Principal and Vice President of GZA GeoEnvironmental, informing attendees about the latest PFAS regulatory happenings that could have future impact on the Metal Finishing Community.

This well attended event is another way that membership in the NASF, at both the Local and National level, can benefit metal finishers at all levels. Once again, thank you to all NENASF Board Members, NENASF membership as a whole, and talented members of the Metal Finishing Community for offering their time and talent to making beneficial events like this a reality.

Summer 2024 NASF Online Courses Free to Members!

Date: April 19, 2024
Category: Chapter News, Events, NASF Chapters, NASF National

 

NASF Logo

New Courses – Summer 2024

INTRODUCTION: PLATING 101
Recommended Time & Experience: No experience or knowledge of the surface finishing industry required.
Description: This online, self-paced course covers the base concepts of Plating and the importance of personal and environmental safety in the workplace.
Designed For: Those who want to better understand when and how surface plating is used. Ideal for those new to the industry or as part of a new employee orientation.
Content Level: Introductory (100 Series)
Approx Hours to Complete: >1 Hour
Learning Objectives: Those completing this course will be able to:
• Describe the three methods and types of metal plating.
• Outline the steps in Plating: Loading, Pre-Treatment, the Electroplating Process, and Post-Treatment.
• Recognize and understand the elements and importance of personal and environmental safety in the workplace.
Registration Fee:
Online Course Member: $0 Non-Member: $175

CHEMISTRY REFRESHER
Designed for: Individuals who scored less than 100% on the Chem Test Your Knowledge test and need a refresher and intending to take the CAF, CEF, or one of the plating specific courses listed below.
• Aluminum Finishing
• Chromium Plating
• Electroless Deposition
• Wastewater Management
• Industrial & Precious Metals
• Plating Essentials
• Zinc & Zinc Alloy
Course Description: This online, self-paced course will cover important concepts that must be mastered to be successful in the courses listed above and on any of the respective exams where a demonstration of knowledge will be required. It covers basic chemistry concepts including definitions, chemical reactions and chemical properties as they relate to the industry.
Content Level: Introductory (100 Series)
Approx Hours to Complete: 1 Hour
Learning Objectives: Those completing this course will be able to:
1. Understand the atomic structures for the most used elements in the pla􀆟ng process.
2. Properly apply the principles of Ohm’s and Faraday’s Law.
3. Recognize and iden􀆟fy various chemical reac􀆟ons including water & salt, acids & bases,
anodes & cathodes.
Registration Fee:
Online Course Member: $0 Non-Member: $175

MATH BASICS (New course. Available July 1, 2024)
Designed For: Individuals who scored less than 100% on the Math Test Your Knowledge test and need a refresher and intending to take the CAF, CEF, or one of the plating specific courses listed below.
• Chromium Plating
• Electroless Deposition
• Wastewater Management
• Industrial & Precious Metals
• Plating Essentials
• Zinc & Zinc Alloy
Course Description: This online, self-paced course provides the learner a refresher in the math basics critical to understanding and fulfilling their role in the plating process. It includes basic and intermediate mathematical functions including scientific notations, solving algebraic and proportional equations, and units of measure.
Content Level: Introductory (100 Series)
Approx Hours to Complete: 1 Hour
Learning Objectives: Those completing this course will be able to:
• Those completing this course will be able to: Recognize mathema􀆟cal symbols, conven􀆟ons, and defini􀆟ons.
• U􀆟lize scien􀆟fic nota􀆟on and units of measure to solve algebraic and propor􀆟onal equa􀆟ons.
• Properly calculate surface areas.
Registration Fee:
Online Course Member: $0 Non-Member: $175

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL MARCH SEMINAR

Date: March 23, 2024
Category: Events, Member News, NASF Chapters, NASF National, Regulation

NENASF logo

The New England Chapter of NASF was, once again, pleased to host a virtual Wastewater Continuing Education Webinar for the benefit of our membership and the entire metal finishing community. This event was offered via Zoom format, at no charge to NENASF members, over a two-hour period from 10:00 am to 12:00 pm on Wednesday March 20, 2024.

 

The program, comprised of three speakers, offered vital technical and regulatory compliance information to the metal finishing community. Attendees also qualified for two Continuing Education Wastewater Treatment Contact Hours to be used towards Wastewater license renewal.

 

Frank DeSilva of Resin Tech opened the Webinar with an update on the current status of the very hot button PFAS issue and regulatory efforts by the EPA. After giving us some very helpful facts, he then offered remediation techniques and technologies for successful PFAS removal from waste streams.

This presentation was followed by one from Mark Schario of Columbia Chemicals who enlightened attendees with a history of Trivalent Chrome plating baths and how they have greatly improved in appearance and durability over the last three or four decades. The substitution of Hex Chrome plating baths with trivalent baths is a very timely presentation given the TSCA chemical banning frenzy that is taking place across all chemical user and manufacturer sectors, especially in the metal finishing community.

The closing speaker was Dave Calnan of CCI-A Chemicals offering practical solutions and techniques for, and benefits of, oxidizing wastewater prior to reduction and precipitation.

 

Special thanks, once again, to Chris Capalbo, Dev Massimi and Ralph Capalbo as Program Moderators and Speaker Facilitators for their contributions, and to the combined efforts of NASF Board Members, Committee Members, Chapter Membership and dedicated and talented members of the Metal Finishing Community as a whole for making events such as this available for the benefit of our membership.  Over thirty members of the NENASF and metal finishing community were in attendance and benefited from this program.

NENASF Partners with HRP Associates

Date: March 9, 2024
Category: Chapter News, Events, Member News, NASF Chapters, Regulation

                                                        NENASF LOGO

HRP Logo

The NENASF is pleased to announce that we have partnered with HRP Associates.  HRP has for years organized and run our Annual HAZMAT, RCRA, and DOT TRAINING seminars and will once again be doing so on May 15th, 2024!  

Please visit their sight to see what they have to offer!

HRP Associates

EXAMPLES OF TRAININGS OFFERED

RCRA Hazardous Waste ManagementDOT Hazardous Materials Transportation / IATA (Air) / IMDG (Vessel)

EHS Management Systems / ISO 14001:2015 / OHSAS 18001:2007

OSHA Health and Safety

8-Hour HAZWOPER Refresher

Asbestos AwarenessProcess Safety Management

Brownfields Opportunities / Environmental Due Diligence

Environmental Compliance Overview

Spill (SPCC) and Stormwater (SWPPP)

Company specific EHS Training

UST A/B Operator Training

The 2023 New England Surface Finishing Regional in Newport, Rhode Island

Date: November 11, 2023
Category: Chapter News, Events, NASF Chapters, Regulation

NE Surface Finishing Regional Logo

The New England Surface Finishing Regional took place this past November 3rd in Newport, Rhode Island. It was a huge success with a 120 people in attendance. There were speakers from all over the country that delivered educational and thoughtful presentations to all in attendance.

The New England Surface Finishing Regional is honored to have presented the 7th Annual Foundation Award to longtime supporter Alex Price of Luster-On Products. The award was created to recognize a metal finishing supplier that has demonstrated outstanding contributions, support, and dedication to the annual regional event.

The 2024 the New England Surface Finishing Regional will be held November 8th in Hyannis, Cape Cod Massachusetts.

Please continue to follow www.nensaf.org all year for news and events throughout the New England metal finishing industry.

 

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL FALL SEMINAR

Date: October 4, 2023
Category: Chapter News, Events, Member News, NASF Chapters, NASF National, Regulation

NENASF LOGO

The New England Chapter of NASF hosted a virtual seminar for the benefit of their membership and the entire non-NENASF metal finishing community. The event was held on Wednesday September 13, 2023.  The event was presented free of charge to NENASF members, and at a modest fee for other interested parties, as an educational and bonding opportunity for the metal finishing community.

 

The Webinar was conducted by means of Zoom format and attracted about forty attendees. It was made up of three segments featuring three presenters over a two-hour period from 10:00am to 12:00 pm offering a user-friendly format for all attendees. In addition to offering vital regulatory and technical information the event also made available two Continuing Education Wastewater Treatment Operator Contact Hours needed for WWT Operator License renewal.

 

Ethan Ware of Williams Mullen Law Group opened the Webinar with a presentation on the upcoming EPA PSFAS Survey that will be sent out to nearly 2000 metal finishers this fall. He stressed that the demographics would not only include chrome platers but chromate conversion coaters as well. This is a very detailed Survey and asks many complex questions through eight sections over seventy-one pages. He covered the answering/data requirements both from a technical as well as a legal perspective. He very much stressed that the information gathered in this Survey will shape the future of Wastewater Discharge Permits for years to come.

This was followed by a presentation by Jeremy Riley of Omega Research giving a detailed description of how proper finishing specification required test sample preparation can make a difference in acceptable test results, while poorly prepared samples can fail causing ripple effects with customer job acceptance.

The webinar was concluded with a presentation by Tony Oriti on Zinc-Nickel and Zinc-Tin as an alternative to Cadmium Plating. Tony not only presented the latest technological advances in these two finishes as they try to replace a long-time exceptional performing and defense and aerospace specified finish, cadmium, but also gave the attendees a look at emerging technology in the form a triple alloy finish that is in the developmental stages.

 

Once again we want to give special thanks to Chris Capalbo for moderating, and to Dev Massimi and Ralph Capalbo as Program Speaker Facilitators for their contributions, and to the combined efforts of NASF Board Members, Committee Members, Chapter Membership and dedicated and talented members of the Metal Finishing Community as a whole for making events such as this available for the benefit of our membership.

MCTA Members Meeting &  Program

Date: June 5, 2023
Category: Events, Regulation

MCTA

Registration Open

Pre-Approved for 2.5 CE Credits

Season Opener – Do You Have Your [Regulatory] Bases Covered?

Speaker:

This & That: A Regulatory UpdateBrian Morrill, Associate Principal, GZA

Panel Discussion Speakers:

ModeratorAtty: Robert Cox Bowditch & Dewey

Speakers

Chris Rascher, EPA Region 1, TRI Compliance & Program  Coordinator

Stephen Klosz, MassDEP, Central Region Compliance Enforcement Analyst

When: June 15, 2023, 10 AM -12:30. Lunch to Follow

Where: DuPont Electronics and Industrial
New England Manufacturing and Technology Center
455 Forest Street, Marlborough, MA

Cost (Hybrid & In-Person): $50 Members, $100

Pre-registration required

To register for this event, please contact Katherine Robertson at katherine@masscta.org or 508-572-9113

CLICK HERE FOR MORE INFORMATION

Reminder: MCTA’s PFAS Strategy Group Meets Thursday, June 1, 11 a

Date: May 31, 2023
Category: Events, Regulation

Contact us for Access Information

At some point in the near future, the Legislature is expected to hold hearings on House Bill 2197 and Senate Bill 1356, both entitled “An Act to protect public health from PFAS.”

There is enormous traction behind moving PFAS legislation in the 2023-2024 session. Of the many PFAS bills filed, we believe H2197/S1356 have the best chance of passage.

MCTA’s goal through the strategy sessions is to develop a roadmap highlighting the major issues of concern, alternative approaches, and the unintended consequences of the sweeping legislation on public safety, human health and the economy. It will guide us when crafting testimony, meeting with Public Health Committee members, and House and Senate Leadership

Our first Planning Session is June 1 at 11. If you haven’t already signed up, please email Katherine Robertson at katherine@masscta.org for access information.

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