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PFAS Regulatory Alert: What Facilities Will Be Covered by EPA's PFAS Rulemaking for Surface Finishing Industry?

It is still too early to tell whether the proposed rule scheduled for release later next year will apply only to those facilities with certain chromium-based processes or more broadly to all metal finishing and electroplating operations. 

Christian Richter, Jeff Hannapel; NASF/The Policy Group

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EPA is moving through the early stages of its proposed rule to address PFAS wastewater discharges for the finishing industry.

EPA is Collecting Industry Data: This stage involves analyzing current data available on the industry from the states and wastewater utilities (e.g., Michigan and California), scheduling site visits to do sampling and evaluation of individual facilities and sending out a major survey questionnaire in the fall that could be sent to as many as 2000 finishing companies nationwide. More on the survey below.

NASF has discussed these and additional activities with EPA to ensure that the industry data collection and evaluation process properly characterizes the industry and its significant progress in reducing and eliminating PFAS over time.

Who Will Be Covered By the Proposed Rule: Among a long list of issues to be clarified in the coming year will be what type of facilities the rule will cover in the industry and what requirements will proposed for monitoring, sampling, control technology and other regulatory objectives.

It is still too early to tell whether the proposed rule scheduled for release later next year will apply ONLY to those facilities with certain chromium-based processes OR more broadly to ALL metal finishing and electroplating operations that operate under the 413 and 433 requirements in the Clean Water Act effluent guidelines program.

NASF’s advocacy team and association leaders will continue to closely engage with EPA headquarters and regions, key state and municipal wastewater treatment officials, Congress and industry allies.


This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.

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