NASF Engages on PFAS Issues
State and Federal Relevant Regulatory Activities
USEPA
Chromium Electroplating: National Emission Standards for Hazardous Air Pollutants (NESHAP)
As of September 2015, chromium electroplating and anodizing operations subject to this NESHAP could no longer use fume suppressants containing PFOS.
PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024.
The roadmap sets timelines by which EPA plans to take specific actions and commits to new policies related to PFAS.
- Expand TRI reporting for PFAS (Spring 2022)
- Finalize new PFAS reporting rule under TSCA Section 8 (Winter 2022)
- Develop drinking water standard for PFOS & PFOA (Proposed – Fall 2022 & Final – Fall 2023)
- Proposed rule for Metal Finishing (Summer 2024)
- Use NPDES permits to reduce PFAS discharges into waterways (Winter 2022)
Preliminary Effluent Guidelines Program Plan:
The Preliminary Effluent Guidelines Program Plan 15 (Preliminary Plan 15), which describes the Agency’s analyses, studies, and rulemakings related to effluent limitations guidelines and pretreatment standards (ELGs). Preliminary Plan 15 provides initial results from EPA’s studies of multiple categories, including the Metal Products and Machinery, Explosives Manufacturing, and Landfills industries. EPA plans to conduct rulemaking to revise the Metal Finishing and Electroplating ELGs to address PFAS discharges from chromium plating facilities. EPA is scheduled to issue a proposed rule by Summer 2024.
Summary of USEPA actions on Per-and Polyfluoroalkyl Substances (PFAS)
This USEPA website explains the current understanding of PFAS, the actions taken to address different issues and provides tools and resources.
Description of technologies that may control releases of PFAS waste to protect human health and the environment.
Selected state activities specific to the metal plating industry
CALIFORNIA
Mandatory PFAS testing requirements for chrome plating facilities (October 2019)
- California State Water Resources Control Board issued order requiring mandatory environmental assessment at 271 chrome plating facilities.
NASF Members Only: For support in response to the orders, contact NASF for model work plan and comprehensive sampling and analysis plan.
California State Water Resources Control Board
The California Water Boards maintains a PFAS website with useful information related to state-specific regulatory actions and resources.
MICHIGAN
The Michigan Department of Environment, Great Lakes, and Energy (EGLE) conducted a study to investigate fume suppressants and chrome platers. Samples were collected in July 2019 and results showed no PFOS in the currently used fume suppressants. Most samples contained 6:2 FTS as the primary PFAS chemical used.
MPART
In 2017, the Michigan PFAS Action Response Team (MPART) was created as a temporary body by executive directive to investigate sources and locations of PFAS and protect drinking water and public health.
Occurrence and Source Identification
OTHER STATES
The Interstate Technology and Regulatory Council tracks state and international regulatory values for PFAS in groundwater, surface water and soil. The latest tracking table can be found under the link for “PFAS Water and Soil Values Table Excel file” on this website: https://pfas-1.itrcweb.org/fact-sheets/
The Environmental Council of States (ECOS) has developed a white paper that outlines state efforts and regulatory activities on PFAS. The most recent update of this document is available at: https://www.ecos.org/pfas/ .