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16 MONTH 2015 — pfonline.com NASF TECHNICAL PAPER EDITED BY DR. JAMES LINDSAY, NASF TECHNICAL EDITOR Federal Appeals Court Denies NASF and Activists' Legal Challenges: Upholds EPA's Chromium Electroplating Air Emissions Rule In late July, the U.S. DC Circuit Court of Appeals denied NASF's legal challenge to the Environmental Protection Agency (EPA) and upheld the fnal federal chromium air emissions rule in its entirety. NASF fled a legal challenge to the fnal rule claiming that the EPA has misapplied the requirements of the Clean Air Act and failed to provide any credible technical support for the new standard. In issuing its decision, the court relied upon the legal principle of granting the EPA broad deference in the issuance of the fnal rule (that is, giving the EPA the beneft of the doubt on all issues) and found that the EPA was not arbitrary and capri- cious in promulgating the fnal rule. The Sierra Club also challenged the EPA's fnal rule, claiming it was not stringent enough. However, the court also denied this challenge. NASF has developed a more detailed summary and analysis of the court's opinion, outlook for other related air regulatory topics and general compliance guidance. In the meantime, the industry's focus will be on compliance with the new regulatory requirements. The new housekeeping practices, emission limits and surface tension levels are now efective. The rule also bans the addition of PFOS-based fume suppressants in tanks subject to this rule as of September 2015. The Court's opinion can be accessed from NASF's website at nasf.org . If you have any questions or need additional informa- tion, please contact Jef Hannapel at jhannapel@thepolicy- group.com . In early August, the EPA issued a new set of reports that highlight concerns over metal fnishing wastewater discharges. The package, issued by the agency's Ofice of Water, summarizes the agency's progress on evaluating and potentially regulating several priority industries. It was formally issued as the Final 2014 Efluent Guidelines Program Plan and 2014 Annual Review Report. Over a decade ago, NASF challenged a major efort by the EPA to fnalize nationwide metal fnishing discharge standards as part of the Metal Products and Machinery rule. Based on several years of industry discussions and a large coalition efort led by the NASF to ensure the EPA performed a proper analysis of the industry's operations, the agency concluded then that no further regulations were needed. EPA Points to Changes in the Industry The EPA's recent review of the industry concluded that the industry has not grown signifcantly in the last 30 years, but has consolidated into larger companies that tend to compete better The Nucleation Dependent Growth Layer: A Structure Element in Electrocrystallization— The 10th William Blum Memorial Lecture (1969) Prof. Dr. Hellmuth Fischer, 1968 AES Scientifc Achievement Award Winner Of all the information contained in the surface technology litera- ture produced by the NASF and its predecessor organizations, perhaps none are as important - or timeless - in their relevance today as the lectures delivered at the AESF Technical Conferences (later SUR/FIN) by winners of the William Blum Scientifc Achievement Award. In the 1960s, a number of theoretical elec- trochemists began to make inroads into understanding the scien- tifc basis for practical electroplating. Among then was Professor Dr. Hellmuth Fischer, Full Professor of Electrochemistry at the Technische Hochschule Karlsruhe and Director of the Lehrstuhl fur Electrochemie. In his lecture, Dr. Fischer discussed the mechanism of the plating process, as it pertained to the atom- by-atom processes of electrodeposit growth on a substrate, and the efects of additives of the resulting electrodeposit structure. He provided microscopic cross-sections of deposits to correlate with the theoretical concepts that he described, taking the mathematical description to the deposit itself. The full report can be accessed and printed at short.pfonline. com/NASF15Sep1 . EPA Issues Update that Considers New Metal Finishing Restrictions 16 SEPTEMBER 2015 — pfonline.com NASF REPORT