EPA Will Send Nationwide PFAS Survey to Finishing Operations by October

EPA is preparing a formal survey to send to finishing operations nationwide as early as October to inform the agency’s analysis of the industry’s PFAS use and discharges. The survey is a significant undertaking and will be executed under the federal Clean Water Act’s authority, similar to the last major discharge survey of the industry over 20 years ago.

What questions will the survey include for companies? The questionnaire will cover two major areas – current wastewater treatment technology and performance for facilities, and an economic and financial profile of companies to determine affordability of new discharge standards for the industry that EPA would formally propose next year.

NASF will be reviewing the details of the survey with industry leaders to provide feedback to EPA before it is sent out.

NASF Discussions with EPA on Industry Profile: As EPA finalizes its list of finishing companies who will receive the survey, agency officials have asked the NASF advocacy team for additional input. In recent weeks, we've reached out to NASF chapter leaders and key committees to coordinate review of the list.

Conflicting Facility Estimates for EPA's Evaluation: Thus far, of the more than 2000 companies EPA has slated to receive the survey, over 300 have been identified as no longer operating or as never having chromium-based processes. NASF's position is that there is a much smaller universe of U.S.-based facilities associated with PFAS use.

This informed view is in stark contrast to an estimate last year from the Environmental Working Group of 4700 plating and finishing facilities that are "suspected dischargers" of PFAS.

NASF will continue to provide feedback to the agency to ensure it has a sufficient understanding of the profile of the finishing industry as the rulemaking analysis proceeds.

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