SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating 

and Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and 

Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal), EPA ICR Number 

1611.11, OMB Control Number 2060-0327. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chromium 

Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks 

were proposed on December 16, 1993, promulgated on January 25, 1995, and most recently 

amended on September 19, 2012. The 2012 final rule amends Subpart N by requiring affected 

facilities to meet more stringent emission limits or more stringent surface tension limits, 

depending on the compliance method selected by the facility. Some facilities will be required to 

conduct performance tests and submit notifications to demonstrate compliance with the revised 

limits. The final amendments also prohibit the use of certain types of chemical fume 

suppressants in affected chromium electroplating or anodizing tanks; require additional 

housekeeping procedures to minimize fugitive emissions of chromium compounds; specify

procedures for checking and maintaining instruments used for measuring surface tension; clarify

testing procedures; and revise the reporting requirements. The burden of the 2012 final rule is 

incorporated into this ICR renewal, although we expect the affected sources to have already met 

the initial requirements. 

These regulations apply to chromium electroplating or chromium anodizing tanks at 

existing and new facilities performing hard chromium electroplating, decorative chromium 

electroplating, and chromium anodizing. New facilities include those that commenced 

construction or reconstruction after the date of proposal. This information is being collected to 

ensure compliance with 40 CFR Part 63, Subpart N.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 
2

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

There are an estimated 1,343 facilities subject to the Chromium Electroplating NESHAP. 

Of these, there are an estimated 652 hard chromium electroplating facilities, 517 decorative 

chromium electroplating facilities, and 174 chromium anodizing facilities. The burden to the 

“Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – NESHAP for 

Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium 

Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal). The “Federal Government” burden is 

attributed entirely to work performed by federal employees or government contractors and can 

be found in Table 2: Average Annual EPA Burden and Cost – NESHAP for Chromium 

Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks 

(40 CFR Part 63, Subpart N) (Renewal).

Over the next three years, approximately 1,343 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. It is 

expected that new tanks will only be added to replace, or expand existing capacity. The ongoing 

monitoring, reporting, and recordkeeping for new tanks are the same as those for existing tanks. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.
3

In the Administrator's judgment, chromium emissions from hard and decorate chromium 

electroplating and chromium anodizing tanks cause or contribute to air pollution that may

reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were 

promulgated for this source category at 40 CFR Part 63, Subpart N.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard, and serve as a record of the operating 

conditions under which compliance was achieved. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. The ongoing compliance status 

reports (i.e., semiannual reports for major sources and annual reports for area sources) are used 

for problem identification, as a check on source operation and maintenance, and for compliance 

determinations. The information generated by the monitoring, recordkeeping and reporting 

requirements described in this ICR is used by the Agency to ensure that facilities affected by the 

NESHAP continue to operate the control equipment in compliance with the regulation. 

Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the 

applicable regulations, as required by the Clean Air Act. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated and the standard is being met. The performance test may also be 

observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

N.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 
4

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. 

Industry trade association and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted the National Association for Surface Finishing 

(NASF), at (202) 457-0630; and Coventya, at (216) 351-1500. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
5

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are sources performing 

hard chromium electroplating, decorative chromium electroplating, and chromium anodizing

operations. The United States Standard Industrial Classification (SIC) codes and the 

corresponding North American Industry Classification System (NAICS) codes for the 

respondents affected by the standards are listed below:

Standard (40 CFR Part 60, Subpart N) SIC Codes NAICS Codes

Electroplating, Plating, Polishing, Anodizing, and Coloring 3471 332813

Hand and Edge Tool Manufacturing 3423 332212

Metal Coating, Engraving (except Jewelry and Silverware), 

and Allied Services to Manufacturers 3479 332812

Power Cylinder and Actuator Manufacturing 3593 333995

4(b) Information Requested
6

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium 

Anodizing Tanks (40 CFR Part 63, Subpart N).

A source must make the following reports:

Notifications

Notification of construction/reconstruction 63.5(a); 63.5(b); 

63.5(e); 63.345 

Notification of initial startup 63.347(c)

Notification of initial performance test 63.347(d)

Reschedule of initial performance test 63.7(b)(2)

Notification of compliance status 63.347(e)

Request for extension of compliance status, adjustments to time 

periods, and changes in information

63.9(c); 63.9(i); 

63.9(j); 63.343(a)(6)

Reports

Initial performance test results 63.347(f)

Operation and maintenance plan 63.342(f)(3); 

63.347(g)(3)

Submission of site specific test plan upon request 63.344(a)

Ongoing semiannual compliance status reports for major sources, unless 

the source is required to submit it on a more frequent basis (e.g., 

quarterly reports are required when an emission limit is exceeded), 

except for sources using trivalent chromium baths

63.347(g)

Ongoing annual compliance status reports for area sources, unless the 

source is required to submit it on a more frequent basis (e.g., semiannual 

reports are required when the duration of an excess emissions is one 

percent or greater of the total operating time), except for sources using 

trivalent chromium baths

63.347(h)

Request to reduce reporting frequency of ongoing compliance status 

reports

63.347(g)(2); 

63.347(h)(2)

Reports associated with trivalent chromium baths 63.347(i)

A source must keep the following records:
7

Recordkeeping

General recordkeeping requirements (e.g., startups, shutdowns and 

malfunctions including process equipment, air pollution control 

equipment, maintenance performed, and actions taken outside of the 

scope of the existing plans, records of monitoring data used to 

demonstrate compliance, performance test results, documentation 

supporting notifications and reports)

63.346(a); 

63.346(b)(1)-(10)

Records of total process operating time of the affected source. 63.346(b)(11)

Records of actual cumulative rectifier capacity of hard chromium 

electroplating tanks expended during each month, and for 

owner/operators who use actual cumulative rectifier capacity to 

determine facility size, records of total capacity expended to date.

63.346(b)(12)

If using fume suppressants to comply, records of date and time that 

fume suppressants are added to the electroplating or anodizing bath, 

and records of product name and manufacturer.

63.346(b)(13)

For decorative chromium electroplating tanks using trivalent 

chromium bath, records of bath components purchased, including the 

wetting agent.

Records for sources with continuous monitoring systems 63.346(b)

Records are required to be retained for 5 years. The first 2 years of 

records must be kept on site. 

63.10(b)(1); 

63.346(c)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate monitoring system for pressure drop for composite 

mesh pad systems and fiber bed mist eliminators; pressure drop and velocity pressure for 

packed bed scrubbers, surface tension for wetting agents, or the appropriate parameter for an 

alternative control option.

Perform initial performance test, Reference Method 306, 306(a) or 306(b) tests, and repeat 
8

Respondent Activities

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard and note the operating conditions under which compliance was achieved. Data 
9

and records maintained by the respondents are tabulated and published for use in compliance and 

enforcement programs. The semiannual reports are used for problem identification, as a check 

on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

The majority of affected facilities subject to this regulation are small businesses. The 

recordkeeping and reporting requirements were selected within the context of this specific 

subpart and the specific process equipment and pollutant. The impact on small businesses was 

accounted for in the regulation development. Reduction in reporting was provided to small 

businesses subject to this regulation. Small (area source) businesses are only required to prepare 

annual compliance status reports and may retain these reports on site. These reports must be 

submitted to the Agency or a delegated authority on a semiannual basis only where the duration 

of excess emissions and air pollution control device malfunctions exceeds specified thresholds. 

Large (major source) facilities must prepare and submit these reports on a semiannual or 

quarterly basis depending on their performance. 

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Chromium 

Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks 

(40 CFR Part 63, Subpart N) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.
10

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 242,000 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $55.34 ($26.35+ 110%) 

Technical $31.42 ($14.96 + 110%)

Clerical $34.29 ($16.33 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

Occupational Employment and Wages, May 2014, available at: 

http://www.bls.gov/oes/current/naics4_332800.htm#51-0000. Wages for technical labor are 

based on "51-4193 Plating and Coating Machine Setters, Operators, and Tenders, Metal and 

Plastic," with a total compensation of $14.96/hour. Wages for management labor are taken from 

"51-1011 First-Line Supervisors/Managers of Production and Operating Workers," with a total 

compensation of $26.35/hour. Wages for clerical labor are based on "43-9061 Office Clerks, 

General," with a total compensation of $16.33/hour. These rates represent salaries plus fringe 

benefits and do not include the cost of overhead. The rates have been increased by 110 percent to 

account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/

Startup Cost 

for One 

(C)

Number of 

New

Respondents

(D)

Total Capital/

Startup Cost, 

(E)

Annual 

O&M Costs 

for One 

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)
11

Capital/Startup vs. Operation and Maintenance (O&M) Costs

Respondent (B X C) Respondent

Operating 

Parameter 

Monitoring 

Systems

$0 0 $0 $15,000 1,343 $20,100,000

Stalagmometer/ 

tensiometer 

calibration and 

cleaning

$213.96 1,343 $287,000

Total $20,400,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $20,400,000. This is 

the total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $20,400,000. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$178,000. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 

Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium 

Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal).
12

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

1,343 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 1,343 per year

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 1,292 52 0 1,343

2 0 1,292 52 0 1,343

3 0 1,292 52 0 1,343

Average 0 1,292 52 0 1,343

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 1,343. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

*

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Ongoing compliance status report 1,033 1 52 1,085

Reports of exceedances 258 2 0 516

Request to reduce frequency of 

ongoing compliance status reports 129 1 0 129

Total 1,730

 *We assume that all sources are area sources. Area sources, except for 52 decorative chromium electroplating 
13

plants using trivalent chromium bath, (1,343 – 52 = 1,291) are required to submit an annual compliance status 

report. However, sources are required to submit these reports on a more frequent basis if excess emissions 

occurs (i.e., semiannually for area sources). We further assume that 80 percent of the sources (0.80 times 1,291

yields 1,033) will have no excess emissions and 20 percent of the sources (0.20 times 1,291 yields 258) will have 

excess emissions. Half of the area sources submitting semiannual reports due to excess emissions (0.5 x 258 = 

129) will request the regulatory agency to approve a reduction in frequency for ongoing compliance status 

reports (i.e., annual reporting).

The number of Total Annual Responses is 1,730.

The total annual labor costs are $7,910,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Chromium 

Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks 

(40 CFR Part 63, Subpart N) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 242,000. Details regarding these estimates may be found 

in Table 1. Annual Respondent Burden and Cost – NESHAP for Chromium Emissions from 

Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR Part 

63, Subpart N) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 140 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $20,400,000. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

3,920 labor hours at a cost of $178,000. See Table 2: Average Annual EPA Burden and Cost –

NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and 

Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal).
14

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the respondent burden hours and a decrease in the number of 

annual responses and the annual cost burden. The burden currently approved by OMB is the sum 

of the burden from EPA ICR Number 1161.10 (2012 amendment) and EPA ICR Number 

1611.07 (existing rule). Changes to the OMB approved burden occurred because this ICR is 

updated to reflect the ongoing compliance burden and cost of the 2012 rule, and to use more 

recent estimate on the number of sources for all burden calculations. 

The increase in the respondent labor hours is primarily due to the correction of a data 

entry error, which was that the number of area sources using wetting agents monitoring on a 

regular schedule was switched with the number monitoring on a reduced schedule, and vice 

versa. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 140 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2009-0422. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 
15

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2009-0422 and OMB Control Number 2060-0327 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
16

Table 1: Annual Respondent Burden and Cost – NESHAP for Chromium Emissions from Hard and Decorative Chromium 

Electroplating and Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

Respondent 

Hours

per 

Occurrence

(Technical 

hours) 

(B)

Number of

Occurrences

per 

Respondent

per Year 

(C)

Hours

per 

Respondent

per Year

(C=A x B) 

(D)

Number of

Respondents 

per Yeara  

(E)

Technical 

Hours

per Year

(E=CxD) 

(F)

Management 

Hours per 

Year

(F=Ex0.05) 

(G)

Clerical 

Hours 

per Year

(G=Ex0.1) 

Total

Labor Costs

per Year b 

1. APPLICATIONS N/A N/A N/A N/A N/A N/A N/A N/A

2. SURVEY AND STUDIES N/A N/A N/A N/A N/A N/A N/A N/A

3. ACQUISITION, INSTALLATION, AND 

UTILIZATION OF TECHNOLOGY AND 

SYSTEMS N/A N/A N/A N/A N/A N/A N/A N/A

4. REPORTING REQUIREMENTS

A. Read and understand rule requirements 1 1 1 1,343 1,343 67.15 134.3 $50,518.29

B. Required Activities

Performance test c------------------------See 4E---------------------------

Monitoring of operations equipment d------------------------See 5E---------------------------

C. Create Information ------------------------See 4B and 5E----------------------------

D. Gather Existing Information ------------------------See 4B and 5E---------------------------- N/A

E. Write Report a ,e

Notification of compliance status 2 1 2 0 0 0 0 $0.00

Notification of actual startup 2 1 2 0 0 0 0 $0.00

Notification of construction / 

reconstruction 2 1 2 0 0 0 0 $0.00

Notification of performance test 2 1 2 0 0 0 0 $0.00

Performance test report 4 1 4 0 0 0 0 $0.00

Operation and maintenance plan 10 1 10 0 0 0 0 $0.00

Notification of performance test (2012 

amendment) N/A N/A N/A N/A N/A N/A N/A N/A

Performance test report (2012 

amendment) N/A N/A N/A N/A N/A N/A N/A N/A
17

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

Respondent 

Hours

per 

Occurrence

(Technical 

hours) 

(B)

Number of

Occurrences

per 

Respondent

per Year 

(C)

Hours

per 

Respondent

per Year

(C=A x B) 

(D)

Number of

Respondents 

per Yeara  

(E)

Technical 

Hours

per Year

(E=CxD) 

(F)

Management 

Hours per 

Year

(F=Ex0.05) 

(G)

Clerical 

Hours 

per Year

(G=Ex0.1) 

Total

Labor Costs

per Year b 

Revise operation and maintenance plan

(2012 amendment) N/A N/A N/A N/A N/A N/A N/A N/A

Annual compliance status reports for area 

sourcesf, g 4 1 4 1,033.04 4,132.16 206.61 413.22 $155,435.33

Semiannual reports of exceedances for 

area sources g8 2 16 258.26 4,132.16 206.61 413.22 $155,435.33

Semiannual compliance status reports for 

major sources h8 2 16 0 0 0 0 $0.00

Quarterly compliance status reports for 

major sources h8 2 16 0 0 0 0 $0.00

Request to reduce report frequency g2 1 2 129.13 258.26 12.91 25.83 $9,714.71

Subtotal for Reporting Requirements 11,345 $371,104

5. RECORDKEEPING REQUIREMENTS

A. Read and understand rule requirements ------------------------See 4A----------------------------

B. Plan Activities ------------------------See 4B----------------------------

C. Implement Activities ------------------------See 4B----------------------------

D. Develop Record System 40 1 40 0 0 0 0 $0.00

E. Time to Enter and Transmit Information 

Records of monitoring:

- Composite mesh pad/packed scrubber i0.5 250 125 639.49 79,936.13 3,996.81 7,993.61 $3,006,877.28

- Wetting agents (normal schedule) j, k 0.25 1,000 250 465.57 116,393.63 5,819.68 11,639.36 $4,378,262.60

- Wetting agents (reduced frequency 

schedule) j, k 0.25 100 25 51.73 1,293.26 64.66 129.33 $48,647.36

- Foam Blankets (normal schedule) l0.25 4,000 1,000 0 0 0 0 $0.00

- Foam Blankets (reduced frequency 

schedule) l0.25 500 125 0 0 0 0 $0.00

- Excess emissions ------------------------See 4E---------------------------

Records of operations: m
18

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

Respondent 

Hours

per 

Occurrence

(Technical 

hours) 

(B)

Number of

Occurrences

per 

Respondent

per Year 

(C)

Hours

per 

Respondent

per Year

(C=A x B) 

(D)

Number of

Respondents 

per Yeara  

(E)

Technical 

Hours

per Year

(E=CxD) 

(F)

Management 

Hours per 

Year

(F=Ex0.05) 

(G)

Clerical 

Hours 

per Year

(G=Ex0.1) 

Total

Labor Costs

per Year b 

- Operation and maintenance 1 4 4 639.49 2557.96 127.90 255.80 $96,220.07

- Cumulative rectifier capacity ------------------------See 4E---------------------------

- Records of trivalent chromium bath 

purchases n0.5 12 6 51.70 310.20 15.51 31.02 $11,668.48

F. Time to train personnel N/A N/A N/A N/A N/A N/A N/A N/A

G. Time for Audits N/A N/A N/A N/A N/A N/A N/A N/A

Subtotal for Recordkeeping Requirements 230,565 $7,541,676

TOTAL LABOR BURDEN AND COST (rounded)o242,000 $7,910,000

Total Capital/O&M Costs (rounded)o

$20,400,000

Grand Total (Labor and Capital/O&M Costs)(rounded)o$29,700,000

Assumptions:

a

 There are an estimated total of 1,343 chromium electroplating and anodizing operations nationwide. Of this total, approximately 652 are hard chromium 

electroplating operations, 517 are decorative chromium electroplating operations, and 174 are chromium anodizing operations. No net growth is predicted for this 

industry. It is expected that new tanks will only be added to replace or expand existing capacity. The ongoing monitoring, reporting, and recordkeeping for new 

tanks is the same as that for existing tanks.

b

 This ICR uses the following labor rates: $55.34 per hour for Executive, Administrative, and Managerial labor; $31.42 per hour for Technical labor, and $34.29 

per hour for Clerical labor. These rates are the United States Department of Labor, Bureau of Labor Statistics, May 2014, available at 

http://www.bls.gov/oes/current/naics4_332800.htm#51-0000. Wages for technical labor are based on "51-4193 Plating and Coating Machine Setters, Operators, 

and Tenders, Metal and Plastic," with a total compensation of $14.96/hour. Wages for management labor are taken from "51-1011 First-Line 

Supervisors/Managers of Production and Operating Workers," with a total compensation of $26.35/hour. Wages for clerical labor are based on "43-9061 Office 

Clerks, General," with a total compensation of $16.33/hour. These rates represent salaries plus fringe benefits and do not include the cost of overhead. The rates 

are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by 

private industry.

c

 Sources are required to conduct performance tests using Methods 306 or 306A of Appendix A, or the California Air Resources Board (CARB) Method 425, as 

an alternative, Method 306B, and alternate methods if the method has been validated using Method 301 of Appendix A. 
19

d

 Sources are required to follow work practice standards at composite-mesh-pad (CMP) systems, packed-bed scrubbers (PBS), PBS/CMP systems, fiber-bed mist 

eliminators, and other air pollution control devices not listed in the rule, as well as monitoring operational parameters (i.e., pressure drop for composite mesh pad 

systems and fiber bed mist eliminators; pressure drop and velocity pressure for packed bed scrubbers, surface tension for wetting agents, or the appropriate 

parameter for an alternative control option) and monitoring equipment.

e

 We have assumed that all existing sources are in compliance with the initial rule requirements.

f

 All sources, except decorative chromium electroplating plants using trivalent chromium bath (1,343 - 51.7 = 1,291.3), are required to submit compliance status 

reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report.

g

 If excess emissions occur at the plant, sources are required to submit reports on a more frequent basis (i.e., semiannually for area sources and quarterly for major 

sources) until the regulatory agency has approved the source request to reduce frequency of ongoing compliance status reports. We have assumed that 80 percent 

of the sources (0.80 x 1,291.3 = 1,033.04) will have no excess emissions and 20 percent of the sources (0.20 x 1,291.3 = 258.26) will have excess emissions. We 

have also assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 258 = 129.13) will request the regulatory agency to 

approve a reduction in frequency for ongoing compliance status reports (i.e., back to annual reporting). 

h

 We have assumed that all sources are area sources. 

i

 We have assumed that the monitoring required for composite mesh pad/packed bed scrubbers occurs once per day, 5 five days a week, 50 weeks per year for all 

plants with add-on control devices. The number of facilities with add-on control devices is estimated to be 639.49 based on the assumption that 84 percent of 

hard chromium electroplating facilities (84% of 652 = 547.68), 13 percent of the decorative chromium electroplating that use hexavalent chromium bath (13% of 

465.3 = 60.49) and 18 percent of chromium anodizing facilities (18% of 174 = 31.32) will use add-on control devices. 

j

 We have assumed that 85 percent of decorative chromium electroplating plants that use hexavalent chromium bath (85% of 465.3 = 395.51) and 70 percent of 

chromium anodizing plants (70% of 174 = 121.8) will use wetting agents for a total of 517.31 sources. 

k We have assumed that area sources using wetting agents will be required to monitor once every four hours for two 8-hours shifts (a 16-hour day), five days a 

week, 50 weeks per year per operating schedule if the source is on a regular monitoring schedule. If the source is on a reduced monitoring schedule, it will be 

required to monitor once every 40 hours for 16-hour day, five days a week, 50 weeks per year per operating schedule. We have assumed that 90 percent of the 

sources (90% of 517.31 = 465.57) will be on a normal schedule and 10 percent of the sources (10% of 517.31 = 51.73) are on a reduced schedule.

l

 We have assumed that sources will not elect to use foam blankets because the rule requires them to do compliance testing. If sources elect to use foam blankets, 

the reduced monitoring schedule will required them to monitor once every 8 hours, per 16-hour day, five days a week, 50 weeks per year per operating schedule. 

If the source is on a normal monitoring schedule it will be required to monitor once every hour, per 16-hour day, five days a week, 50 weeks per year per 

operating schedule. 

m

 We have assumed that all facilities with add-on control devices (639.49) would be required to have an approved Operation and Maintenance Plan for their 

operations.

n

 We have assumed that 10 percent of the decorative chromium electroplating plants (10% of 517 = 51.7) use trivalent chromium baths and 90 percent use 

hexavalent chromium baths (90% of 517 = 465.3).
20

o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
21

Table 2: Average Annual EPA Burden and Cost – NESHAP for Chromium Emissions from Hard and Decorative Chromium 

Electroplating and Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

EPA Hours 

per 

Occurrence 

(Technical 

hours) 

(B)

Number of 

Occurrences

per Plant per 

Year 

(C)

EPA 

Hours per 

Year

(C=A x B) 

(D)

Plants 

per Year 

a

(E) 

Technical 

Hours per 

Year 

@ $46.22 

(E=C x D) 

(F)

Management 

Hours per 

Year 

@ $62.27

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

@ $25.01

(G= E x 0.1) 

Costs per Year b

Notification of Compliance Status c2 1 2 0 0 0 0 $0.00

Notification of Actual Startup 2 1 2 0 0 0 0 $0.00

Notification of construction/ 

reconstruction 2 1 2 0 0 0 0 $0.00

Operation and maintenance plan d2 1 2 0 0 0 0 $0.00

Notification of Performance Test c2 1 2 0 0 0 0 $0.00

Reports of Performance Test results c2 1 2 0 0 0 0 $0.00

Report Review (2012 amendment)

Operation and maintenance plan (2012 

amendment) N/A

Plant records of fume suppressant use e

(2012 amendment) 2 1 2 26 52 2.6 5.2 $2,721.68

Annual compliance status reports for 

area sources f2 1 2 1033.04 2066.08 103.30 206.61 $108,138.63

Semiannual reports of exceedances 

for area sources f, g2 2 4 258.26 1033.04 51.65 103.30 $54,069.31

Semiannual compliance status reports 

for major sources h2 1 2 0 0 0 0 $0.00

Quarterly compliance status reports 

for major sources 2 1 2 0 0 0 0 $0.00

Request to reduce report frequency g2 1 2 129.13 258.26 12.91 25.83 $13,517.33

TOTAL ANNUAL BURDEN (rounded i) 3,920 $178,000
22

Assumptions:

a

 There are an estimated total of 1,770 chromium electroplating and anodizing operations nationwide. Of this total, approximately 652 are hard chromium 

electroplating operations, 517 are decorative chromium electroplating operations, and 174 are chromium anodizing operations. No net growth is predicted for this 

industry. It is expected that new tanks will only be added to replace or expand existing capacity. The ongoing monitoring, reporting, and recordkeeping for new 

tanks is the same as that for existing tanks.

b

 This cost is based on the following hourly labor rates: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.67 for Technical (GS-12, Step 1, $29.17 + 

60%) and $25.25 Clerical (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) "2014 General Schedule" which 

excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees.

c

 Assumes that all existing sources are in compliance with the initial rule requirements. 

d

 There will be no periodic burden for the regulatory agency associated with this requirement although we have assumed that all facilities with add-on control 

devices (676) would be required to have an approved Operation and Maintenance Plan for its operations. 

e Assumes Agency will review records of 5% of the 540 plants that use fume suppressants (540 x 0.05 = 26) to confirm that non-PFOS fume suppressants are 

being used.

f All sources, except decorative chromium electroplating plants using trivalent chromium bath (1,343 - 51.7 = 1,291.3), are required to submit compliance status 

reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report.

g

 If excess emissions occur at the plant, sources are required to submit reports on a more frequent basis (i.e., semiannually for area sources and quarterly for 

major sources) until the regulatory agency has approved the source request to reduce frequency of ongoing compliance status reports. We have assumed that 80 

percent of the sources (0.80 x 1,291.3 = 1,033.04) will have no excess emissions and 20 percent of the sources (0.20 x 1,291.3 = 258.26) will have excess 

emissions. We have also assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 258 = 129.13) will request the 

regulatory agency to approve a reduction in frequency for ongoing compliance status reports (i.e., back to annual reporting). 

h

 We have assumed that all sources are area sources. 

i

 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.