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 indus try 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, a nd several databases, including the National Emission Inventory (NEI) database, the Toxic Re lease 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 perfor med. In some cases, data on electroplating tank operating parameters also were obtained. The data were co mpiled in an Access databa se, hereafter referred to as the Electroplating Database. The database has been periodically updated as new data have

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

area sources, no effort was made to disti nguish between the two in the database.2

In March 2004, RTI began working on the Pl ating 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 deve loped for the Plating and Polishing Source Category. The ICR requested information on electroplating and non-elec troplating processes, tank design and operating data, use of plating chemicals and other materials, and emission controls. Because tanks subject to the Chromi um Electroplating NESHAP would not be subject to a rule for Plating and Polishi ng, 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 maili ng 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 fo r the Plating and Polishi ng ICR. After further screening of the data, a final mailing list wa s prepared. The maili ng 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 th e 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 perfor m plating or polishing; th e 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 clos ed, do not perform electroplating, or were undeliverable, the Electroplating Database curr ently includes information on 2,417 plants that are assumed to be in operation.

III. Current Status of Chromium El ectroplating Plant Data on File

A. Electroplating Database

As noted above, the Electroplating Database ha s 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 plan ts perform chromium el ectroplating, but it is believed that between 60 and 80 pe rcent of these plants do some t ype of chromium electroplating or anodizing. For most plants, the database incl udes company name and ad dress, and the general type of plating performed (e.g., chromium elect roplating, nickel elec troplating). For many plants, the database includes information on th e number of employees , contact person, and telephone number. The database in dicates the type of chromium electroplating for 816 plants: 425 hard chromium electroplating; 424 decorati ve chromium electropl ating, and 145 chromium anodizing plants. (Note that some plants do more than one type of chromi um electroplating.)

For most plants, the Electroplating Database does not include the data needed for estimating emissions. However, there are ex ceptions. For example, Region VII provided information on the type of chromium electropl ating (hard, decorative, anodizing) performed, rectifier capacity, and major/area source stat us for 92 plants. With a few reasonable3

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 th ese. The level of de tail, including estimation procedures, also varies considerably. These em ission 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 m odeling for the source category. The emission estimates for the other 22 Chicago plants are r eadily available and shoul d be reliable. These plants also are included in the Electroplating Database.

C. Operating Permits

RTI has collected operating permits for 350 plan ts that perform some type of plating, and most of these plants perform chromium electro plating. Although most permits generally do not include enough detail on electroplating tanks an d 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 retu rned 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. Howeve r, 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 electropla ting operations. Some of this information may be adequate for estimating emissions. The ICR res ponses 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.