NASF Report June 2016: EPA—Zicronization is Covered by Metal Finishing ELG

The agency says that wastewater generated by the zirconium oxide process is subject to the Metal Finishing Effluent Limitation Guidelines.
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EPA: Zirconization is Covered by Metal Finishing ELG

The agency says that wastewater generated by the zirconium oxide process is subject to the Metal Finishing Effluent Limitation Guidelines.

On April 11, the U.S. Environmental Protection Agency (EPA) issued a memorandum stating that wastewater generated by Zirconization, a trade name for a process that applies a zirconium oxide finish to a metal substrate, is subject to the Metal Finishing Effluent Limitation Guidelines (ELG), 40 CFR Part 433. In the memorandum, EPA concluded that Zirconization is one of the six core metal finishing operations regulated by the Metal Finishing ELG: 1) electroplating, 2) electroless plating, 3) anodizing, 4) coating (chromating, phosphating and coloring), 5) chemical etching and milling, and 6) printed circuit board manufacture.

Specifically, EPA noted that based on limited comments in literature Zirconization is a zirconium oxide conversion coating that replaces iron phosphate and should, therefore, subject wastewater generated by this process to the Metal Finishing ELG. A copy of the memorandum is available on nasf.org.

EPA’s action, which the agency outlined in April for NASF members at the NASF Washington Forum, is related to its review of the Metal Finishing ELG. On August 5, 2015, EPA released its Final Report on 2014 ELG Program indicating that the Agency would continue to review the metal finishing category and the following topics:

Potential new pollutants of concern not currently regulated that are increasingly used in metal finishing processes.

Prevalence of potential pollutants of concern associated with wastewater generated from the use of wet air pollution control devices to control air emissions from metal finishing operations.

The application of advanced wastewater treatment technologies and the prevalence of zero discharge practices in the industry.

EPA is still in the process of determining whether it needs to issue revisions to the Metal Finishing ELG that include limits for cadmium, chromium, copper, cyanide, lead, nickel, silver and total toxic organics. A final decision to proceed is expected as early as this year.

 EPA’s memorandum may not impact many metal finishing operations, because they likely already have one of the six core metal finishing operations subject to the Metal Finishing ELG. Zirconization is an ecofriendly pretreatment process that is phosphate free and does not appear to present any significant environmental concerns. In addition, the National Association of Clean Water Agencies, which represents the publicly owned treatment works, has indicated that they are not concerned about discharges from the Zirconization process because it is more environmentally friendly than conventional metal finishing processes.

Facilities not currently subject to the Metal Finishing ELG that employ a Zirconization process may now have to meet the pretreatment limits of the Metal Finishing ELG. This could include facilities currently subject to the Electroplating ELG, 40 CFR Part 413, or facilities that currently are not subject to any ELG. Any facility that has a Zirconization process should review its wastewater treatment process to determine if the Metal Finishing ELG now applies.

Since EPA officials discussed these issues at the NASF Washington Forum, the association will continue to work closely with the agency on its review of the Metal Finishing ELG and whether its application is appropriate for new processes that were not considered when the ELG regulation was promulgated.

If you have any questions or would like additional information, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.


Environmental Working Group Demands Action from EPA on PFOA Contamination in Drinking Water

The Environmental Working Group submitted a letter on April 25 to the U.S. EPA regarding concerns about the agency’s handling of perfluorooctanoic acid (PFOA) contamination of drinking water. EWG is a national environmental health organization dedicated to empowering people to live healthier lives in a healthier environment. The organization has used research, education, and advocacy to shape public policy and protect communities from exposures to toxic chemicals.

The letter requested that EPA take the following actions:

  1. Act swiftly to establish an enforceable drinking water standard for PFOA as a contaminant under the federal Safe Drinking Water Act;
  2. At minimum, issue a uniform, health-protective health advisory level for PFOA;
  3. Utilize results from state-of-the-art testing capabilities to detect PFOA in water without discarding or discounting low-level findings; and
  4. Draw on available production, use and disposal information, as well as all available water testing results, to enhance and expand sample testing of community water systems to determine what other localities may be at risk and identify and remediate the sources of water contamination. The agency should not only use all available information, but employ the full extent of its regulatory authority to supplement that information with whatever additional manufacturing, processing, and use data it can compel from companies, voluntarily or otherwise.


A copy of the letter may be downloaded at nasf.org. This action is consistent with the multiple efforts to limit the use of PFOA and other PFCs and bring greater public awareness on the potential human health and environmental issues associated with PFCs, some of which have been used in surface finishing applications.


Autonomous Mobility and the Future Take Center Stage at Detroit Bright Design Challenge

NASF and its partners in the 2016 Spring Bright Design Challenge honored three top-performing students in April for their work at the Detroit-based College for Creative Studies (CCS). The awards program—and the selection and judging process beforehand—marked the outcome of a full university-level course in graphics, model design and surface finishing at CCS in Detroit, Michigan. 

In addition to students and faculty, key industry participants at the event included representatives from this year’s title program sponsor, Lacks Enterprises, along with supporting sponsors MacDermid Enthone, Atotech, Coventya, Dipsol and KC Jones Plating Co. NASF headquarters and Michigan NASF Chapter leaders from Haviland, KC Jones and Marsh Plating, joined CCS faculty to round out the group.

Each year, the NASF and the Bright Design Challenge provide a platform for design students to present their solutions to specific challenges within the surface finishing industry. The spring competition is hosted by the Michigan Chapter of NASF and begins in January. A second fall competition is hosted by the California Chapter of NASF beginning in October.

This year’s CCS spring competition invited students to focus on how surface finishing applications will remain relevant in a connected and electric mobility future. Students were required to design and build innovative vehicle configurations for the unmanned vehicles of the future and leverage new zero-emission powertrain technology. The challenge included the development of a well-conceived and executed clay model with supporting package description, concept documents and rendering – all completed well within a short semester.



First-place award winner, Jordan Taylor


Scholarship awards were presented to the following individuals and will be applied directly to the students’ tuition:

First Place: Jordan Taylor

Second Place: Jihun Park

Third Place: Hyeyoung Suh


Judges included representatives from NASF, Lacks Enterprises, General Motors, Ford, Fiat Chrysler Automotive and the College for Creative Studies.

The NASF is pleased to take further its leadership role in an effort to build more expertise in finishing through awareness of manufacturing careers. We strongly believe that it is the responsibility of those currently serving this industry to make students aware of the successful career opportunities in our industry.

For more information on Bright Design and NASF, or program sponsorship opportunities, please contact Matt Martz, NASF at mmartz@nasf.org.

National Association for Surface Finishing

Originally published in the June 2016 issue.