NASF Report: Jan. 2017

In early December, the U.S. Environmental Protection Agency proposed a new Superfund cleanup rule that surface finishing should watch closely. The proposal stems from an agency hazardous waste initiative under the Obama Administration that covers metal finishing as well as several other manufacturing sectors.

The latest proposal would subject hard rock mining companies to cleanup responsibilities and require companies to obtain bonds, insurance or self-assure to cover cleanup costs.

A few years ago, EPA listed metal finishing on the list of sectors that would be targeted for what would be new, extreme requirements under the federal Superfund law that could potentially bankrupt both small and large companies.

NASF advises dropping financial assurance requirements, arguing that the agency’s approach was misguided on several fronts. EPA recently expanded the metal finishing category to cover more facilities in the larger fabricated metals sector.

Outgoing EPA assistant administrator Mathy Stanislaus, who heads the federal hazardous waste program, argues that the agency’s approach of requiring a company to secure a bond, letter of credit or other financial assurance mechanisms would lead to more cleanups in the U.S. “This proposed rule, once finalized, would remove the financial burden from taxpayers and ensure that the industry assumes responsibility for these cleanups,” Stanislaus says. “This would also give companies an incentive to use environmentally protective practices that can help prevent future releases.”

Attendees at the 2016 NASF Washington Forum heard from National Mining Association’s Tawny Bridgeford, who highlighted the mining industry’s experience as a case study. She noted that the onerous EPA requirements in the pipeline for miners would severely impact surface finishing facilities if the rules weren’t curbed early in the process.

The proposed rule, not yet published in the Federal Register at press time, formally identified the next group of sectors in the pipeline for financial assurance rules, specifically electric power generation, transmission and distribution, petroleum and coal products manufacturing. The results of the presidential election, however, are expected to have an impact on regulations in 2017. Because the agency released its proposal so late in the year, it is possible that a new EPA under the Trump administration will not finalize the rule in the new year.

For more information, please contact Christian Richter with NASF at crichter@thepolicygroup.com.

Training Offered for EPA Region 5 and SBEAP Officials on Plating, Polishing Area Source Rule

EPA Region 5 Office of Enforcement recently identified some common problems with compliance with the plating and polishing NESHAP rule for area sources.

It also suggested working with the industry to facilitate compliance in collaboration with the state Small Business Environmental Assistance Programs (SBEAPs) in Region 5, which comprises Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin.

The SBEAP representatives contacted NASF representatives in each state inviting them to participate in developing further compliance with the plating and polishing area source rule.

NASF representatives noted that some of the compliance issues identified by EPA may be the result of confusion regarding the implementation of the rule requirements. They indicated the industry’s willingness to assist in developing guidance to ensure continued compliance with the requirements of the plating and polishing rule. NASF agreed to present a compliance training session on the rule for SBEAP and EPA officials.

In November, NASF representatives Joelie Zak and Jeff Zak of Scientific Control Laboratories along with Jeff Hannapel of The Policy Group went to the EPA Region 5 offices in Chicago and provided a training session and discussion on the plating and polishing rule for a small group of SBEAP and EPA Region 5 officials.

The group included SBEAP representatives from Illinois, Indiana, Ohio, Michigan, Minnesota, and Wisconsin and officials from EPA Region 5 enforcement and air toxics offices.

The training sessions focused on fundamental plating processes and the requirements of the rule, particularly how the industry demonstrates compliance with the management practices and the use of wetting agents and fume suppressants.

While EPA enforcement officials did not necessarily agree with NASF and SBEAP representatives on the scope of potential compliance issues with the rule requirements, all parties agreed to develop guidance that could provide further clarification for industry and agency inspectors on how the rule must be implemented.

For more information regarding the plating polishing area source rule and the industry’s efforts to promote compliance with EPA and the states, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.

NASF Technical Papers

Calculating Applied Media Force During Vibratory Finishing
William P. Nebiolo, REM Chemicals Inc., Southington, Connecticut

Despite conscientious attempts to equilibrate vibratory variables such as bowl amplitude, roll angle, media species, media volume, part loading, process liquid concentration and flow rate, what appear to be identically set-up vibratory bowls will nonetheless finish identical loads of parts in varying time cycles.

Why is this so? This paper will explore this phenomenon. Techniques will be introduced that will allow operators to capture operational characteristics that aren't typically apparent. A formula will then be introduced that will allow operators to apply this new data to calculate the amount of force that the media is actually applying to the parts. It is the efficiency of the force applied to the parts during vibratory finishing that controls the efficiency and speed of the refinement cycle. The full paper can be accessed at short.pfonline.com/NASF17Jan1.

Crack Formation during Electrodeposition and Post-deposition Aging of Thin Film Coatings -
3rd Quarter Report
Prof. Stanko R. Brankovic, University of Houston, Houston, Texas

The NASF Research Board has funded a new research grant directed by Professor Stanko R. Brankovic studying fundamental aspects of crack formation in electrodeposited thin films. The aim is to identify and quantify key parameters of the electrodeposition process affecting the crack formation in thin films, emphasizing chromium electrodeposits. The study hopes to develop a strategy applicable when electrodeposition for crack-free films is needed. The third quarter focused on initial studies of electrodeposition of chromium thin films of arbitrary thickness on polycrystalline copper substrates from Cr+3-containing electrolytes. In this quarter, in situ impedance and deposit stress measurements were made during chromium film aging in air at room temperature and during annealing at 250°C. The full paper can be accessed at short.pfonline.com/NASF17Jan2.