It is still unclear when the U.S. Environmental Protection Agency will send out its survey to electroplating operations as part of its “Chrome Finishing Industry Data Collection.”
The questionnaire to electroplaters will collect data for the agency’s revision of the metal finishing and electroplating guidelines to address discharges of PFAS from the chrome finishing wastewater system.
The 84-question survey was expected to go out to 2,035 shops this summer but has been delayed because it is still being reviewed by the White House.
Approval Needed Under Paperwork Reduction Act
“EPA intends to distribute the survey shortly after review by the Office of Management and Budget is complete, as required under the Paperwork Reduction Act,” says Robert Daguillard, Public Affairs Officer for the EPA in Washington, DC.
The Paperwork Reduction Act (PRA) is a law governing how federal agencies collect information from the American public. The White House’s Office of Information and Regulatory Affairs, under the Office of Management and Budget, approves all PRA clearances.
“We want to be good stewards of the public’s time and not overwhelm them with unnecessary or duplicative requests for information,” says info on the PRA at digital.gov. “The PRA clearance process involves calculating burden hours. It’s important to understand how long it will take members of the public to complete your request.”
The EPA estimated it would take the 2,035 shops 15,406 hours per year to complete the survey, or roughly 7.5 hours per shop each year.
No More Than 20 Facilities to Conduct Samples
In addition, the EPA survey says, “All chrome finishing facilities in the U.S. will receive the questionnaire, and no more than 20 facilities will be asked to conduct specific wastewater sampling.”
Phillip Flanders, Engineering and Analysis Division for the EPA’s Office of Science and Technology, is the lead official on the survey project; he did not return a request from www.FinishingAndCoating.com for information on the status of the survey.
Public comments were previously requested via the Federal Register in November 2022; additional comments were requested in May 2023.
The EPA says it plans to conduct a rulemaking to address per- and poly-fluoroalkyl substances (PFAS) discharges from a subset of facilities in the metal finishing and electroplating point source categories. Specifically, they say facilities performing certain chromium operations that employ hexavalent chromium, including chromium plating, chromium anodizing, chromic acid etching, and chromate conversion coating that use or have used PFAS to control hexavalent chromium emissions.
Plating Considered Predominant Sources of PFAS Discharges
The EPA says, “these facilities are expected to be the predominant sources of PFAS discharges in the metal finishing and electroplating point source categories. Publicly available data on such facilities, including whether they perform chrome finishing operations and use and discharge of PFAS at the national scale, are limited. EPA reviewed the 2017 National Emissions Inventory (NEI), Compliance and Emissions Data Reporting Interface (CEDRI), Environmental Compliance History Online (ECHO), and Integrated Compliance Information System (ICIS), as well as data collected by several state environmental agencies. However, none of these data sources provide a complete population of chromium finishing facilities in the United States, nor do they provide detailed information on specific facility operations (including the use of hexavalent chromium or PFAS), generation and management of wastewater, or wastewater characteristics necessary for the complex technical and economic analyses required for the review and development of ELGs.”
The EPA says the questionnaire and wastewater sampling program is necessary for EPA to determine if the “current regulations remain appropriate and to develop new regulations if they are deemed to be warranted.”
EPA identified and compiled mailing addresses for approximately 2,035 potential chromium finishing facilities in the U.S., and they say, “all active metal finishing and electroplating facilities that conduct or have conducted one or more of the specified chromium finishing operations will be required to complete the questionnaire.”
Click HERE to see the list of 2,035 shops that are included in the survey list.
