Date: January 7, 2008 

Subject: Summary of Available Data on Chromium Electroplating Facilities 

Risk and Technology Review – Technical Support for the Metals, Minerals, & 

Energy Sectors 

 EPA Contract No. EP-D-06-118; WA No. 1-11 

 RTI Project No. 0210426.001.011 

From: Richard Marinshaw 

To: Phil Mulrine 

 EPA/SPPD/MMG (D243-05) 

 U.S. Environmental Protection Agency 

 Research Triangle Park, NC 27711 

I. Introduction

 The U.S. Environmental Protection Agency (EPA) is currently evaluating the residual 

risk associated with chromium emissions from facilities that are subject to the National Emission 

Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and 

Chromium Anodizing Tanks (40 CFR 63, subpart N), hereafter referred to as the Chromium 

Electroplating NESHAP. To facilitate this assessment, EPA has requested RTI International 

(RTI) to provide a summary of the available data on chromium electroplating facilities. This 

memorandum summarizes the data on file at RTI. 

II. Background

 RTI began compiling data on the chromium electroplating industry in June 2003 under 

Work Assignment 1-18 of EPA Contract No. 68-D-01-079. Data were obtained from EPA 

Regional Offices, State and local agencies, and several databases, including the National 

Emission Inventory (NEI) database, the Toxic Release Inventory (TRI) database, the National 

Metal Finishers Resource Center online database, and the Thomas Register On-line. The data 

obtained from many of these information sources consisted of plant names, addresses, and the 

type of electroplating performed. In some cases, data on electroplating tank operating 

parameters also were obtained. The data were compiled in an Access database, hereafter referred 

to as the Electroplating Database. The database has been periodically updated as new data have 

become available. Because the Chromium Electroplating NESHAP applies to both major and 

area sources, no effort was made to distinguish between the two in the database. 
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 In March 2004, RTI began working on the Plating and Polishing Area Source NESHAP. 

Because many of the processes and sources that are to be covered by the Plating and Polishing 

rule are colocated at facilities that are subject to the Chromium Electroplating NESHAP, the data 

collected for Plating and Polishing were entered into the Electroplating Database. An 

information collection request (ICR) was developed for the Plating and Polishing Source 

Category. The ICR requested information on electroplating and non-electroplating processes, 

tank design and operating data, use of plating chemicals and other materials, and emission 

controls. Because tanks subject to the Chromium Electroplating NESHAP would not be subject 

to a rule for Plating and Polishing, the ICR instructed plants to indicate if the plant performed 

chromium electroplating, but respondents were not required to provide any further data on 

chromium electroplating operations. 

When the Plating and Polishing ICR mailing list was developed, the Electroplating 

Database included information on approximately 2,600 plants. For about 1,200 of the plants, the 

available information indicated that the plant performed only chromium electroplating. Those 

plants were screened out of the mailing list for the Plating and Polishing ICR. After further 

screening of the data, a final mailing list was prepared. The mailing list included about 

1,150 companies, representing just over 1,200 plants. The ICR was transmitted in May 2006, 

and a total of 606 ICR questionnaires were completed and returned to EPA. In other words, data 

were received for approximately 50 percent of the plants that were sent ICRs. Approximately 

100 ICRs were returned to EPA as undeliverable; and EPA was informed that roughly another 

100 plants were either closed or did not perform plating or polishing; the status of the other 

400 plants that were sent ICRs is unknown. After updating the Electroplating Database to 

account for the 200 plants that are either closed, do not perform electroplating, or were 

undeliverable, the Electroplating Database currently includes information on 2,417 plants that 

are assumed to be in operation. 

III. Current Status of Chromium Electroplating Plant Data on File

A. Electroplating Database

 As noted above, the Electroplating Database has data on 2,417 plants that we either know 

are in operation or that we believe may be in operation because we have no data to indicate 

otherwise. It is unknown how many of these plants perform chromium electroplating, but it is 

believed that between 60 and 80 percent of these plants do some type of chromium electroplating 

or anodizing. For most plants, the database includes company name and address, and the general 

type of plating performed (e.g., chromium electroplating, nickel electroplating). For many 

plants, the database includes information on the number of employees, contact person, and 

telephone number. The database indicates the type of chromium electroplating for 816 plants: 

425 hard chromium electroplating; 424 decorative chromium electroplating, and 145 chromium 

anodizing plants. (Note that some plants do more than one type of chromium electroplating.) 

For most plants, the Electroplating Database does not include the data needed for 

estimating emissions. However, there are exceptions. For example, Region VII provided 

information on the type of chromium electroplating (hard, decorative, anodizing) performed, 

rectifier capacity, and major/area source status for 92 plants. With a few reasonable 

 
 

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assumptions, emissions estimates could be made for these facilities. The database also could be 

queried to provide a breakdown of plants by State or EPA Region. 

B. Emission Estimates

Responses to the Plating and Polishing ICR included estimates of chromium emissions 

for 188 plants. Without further review, it is unknown if these emissions are for chromium 

electroplating; other plating and polishing processes, such as chromate conversion coating; other 

colocated processes; or some combination of these. The level of detail, including estimation 

procedures, also varies considerably. These emission estimates have not yet been compiled, but 

are readily available. 

During the initial work on residual risk for the Chromium Electroplating Source 

Category, RTI collected information and estimated chromium emissions for 29 plants located in 

Chicago. Emission estimates for seven of the plants were presented in RTI’s August 3, 2007 

memorandum prior to the most recent risk modeling for the source category. The emission 

estimates for the other 22 Chicago plants are readily available and should be reliable. These 

plants also are included in the Electroplating Database. 

C. Operating Permits

 RTI has collected operating permits for 350 plants that perform some type of plating, and 

most of these plants perform chromium electroplating. Although most permits generally do not 

include enough detail on electroplating tanks and operation to estimate emissions, several of the 

permits may include enough information to make reasonably reliable estimates. 

D. Plating and Polishing ICR Responses

As noted above, 606 plants completed and returned the Plating and Polishing ICR. For 

each of these plants, general information on the type of plant, processes, and controls have been 

entered into the Electroplating Database. However, due to budget restrictions, tank- and processspecific data have been reviewed and entered into the database for only about 100 plants. 

Use of chromium was reported for 373 of the 606 plants. Many of these plants perform 

chromate conversion coating, so it cannot be assumed that all 373 plants do chromium 

electroplating. Although data on chromium electroplating was not requested, some plants did 

provide information on their chromium electroplating operations. Some of this information may 

be adequate for estimating emissions. The ICR responses for all of the 606 plants are on file and 

can be readily accessed. 

E. Emission Test Reports

 RTI has on file approximately 40 test reports for chromium electroplating sources. If 

additional information is available on the tested plants, it may be possible to estimate annual 

emissions for some of them.