p.1 

OAR Box 1313 

Prepped by LaTeia Shed 

Document Number: 

36) ll-B-10 

Docket Number: 

A-88-02 

Primed 6/12/2008 9:03:29 AM Sheet 36 of 99 
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"W a<*" 

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A-88-02 

IT-ft-io 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

i Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

2 5 JUL 1986 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

THRU: 

Request fo r OMB Clearance of Information Collection Request 

f o r Chromium Plating and Anodizing Operat 

Gerald A. Emison, Director 

Office of Air Quality Planning 

Mary M. Allen , Director 

Office of Standards and Regulations (PM-223) 

Sharon 

Office 

Payne 

of Ai r and Radiation (ANR-443) 

Attached are the Standard Form SF-83 (four copies) and supporting 

statement (four copies) fo r requesting clearance of the information 

collection request for use in developing the technical bases for a 

national emission standard for hazardous air pollutant s fo r chromium 

plating and anodizing operations. 

Please review thi s request and forward i t t o the Office of Management 

and Budget. I f you have questions concerning thi s submittal, please contact 

Jim Crowder at FTS 629-5501. 

2 Attachments 

cc: James U. Crowder (MD-13) 

Norm Dunfee (MD-11) 

Robert R. Kolbinsky (MD-13) 

Harvey Nozick (ANR-443) 

Gilbert H. Wood (MD-13) 

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Standard Form 83 

(Rev. Seotember 1983) Request for OMB Review 

important 

Read instructions before completing form. Oo not use the same SF 83 

to request both an Executive Order 12291 review and approval under 

the Paperwork Reduction Act. 

Answer all questions in Part I. If this request is for review under E.O. 

12291. complete Part II and sign the regulatory certification. If this 

request is for approval under the Paperwork Reduction Act and 5 CFR 

1320, skip Part II. complete Part III and sign the paperwork certification. 

Send three copies of this form, the material to be reviewed ano for 

paperwork—three copies of the supporting statement, to: 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Attention: Docket Library, Room 3201 

Washington, OC 20503 

PART I.—Complete This Part for All Requests. 

1. Department/agency and Bureau/office originating request 

U. S. Environmental Protection Agency 

Office of Air and Radiation 

3. Name of person wno can best answer questions regarding this request 

Al Vervaert, MD-13 

2. Agency code 

0 6 

. Telephone numoer 

(919 , 541-5601 

4. Titie of information collection or rulemaking 

Information Request for Development of NESHAP for Chromium Plating and Anodizing Operations 

5. Legal authority tor information collection or rule (cite Un-ied States Coae. Public Law, or Executive Ordtr) 

42 7412 and 7414 

USC __; or 

6. Affected public (check all that apply) 

1 O Individuals or households 

2 D State or local governments 

3 Q Farms 

4 H Businesses or other tor-profit 

Federal agencies or employees 

6 Q Non-profit institutions 

7 GO Small businesses or organizations 

PART II.—Complete This Part Only if the Request is for OMB Review Under Executive Order 1229 1 

7. Regulation Identifier Number (RIN) 

or. None assigned O 

8. Type of suomission (cnecu one in eacn category) 

Clatattlcatlon 

1 • Major 

2 i_i Nonmajor 

Stage ot development 

1 LJ Prooosed or draft 

2 l_i Final or interim final, with prior proposal 

3 D Final or intenm final, without pnor proposal 

Type ol review requested 

1 • Standard 

2 D Pending 

3 l_i Emergency 

4 Cl Statutory or -udicial deadline 

9. CFR section affected 

r-TB 

10. Does tnis regulation contain reporting or recordkeeping requirements tnat require OMB approval under tne Paperwork Reduaion Act 

1 D Yes 2 L No 

Certification for Regulatory Submissions 

In submitting this request for OMB review, the authonzeo regulatory contact and the program official certify that the requirements of E.O. 12291 ano any apol'casle 

policy directives have been complied with. 

Signature of program official 

Signature of autnonzea regulatory contact 

Oate 

Oate 

12. (OMB ute only) 

Previous Milions oDMWte 

NSN 7540-00-634-4034 83 108 SUnure Form 83 (Rfv iii. 

P'tKUDtQ Oy Ot.'.S 

SCFR1320»r.a£C 122S1 

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SUPPORTING STATEMENT—SURVEY OF DATA FOR THE 

DEVELOPMENT OF NATIONAL EMISSION STANDARDS FOR HAZARDOUS 

AIR POLLUTANTS FOR CHROMIUM PLATING AND ANODIZING OPERATIONS 

A. JUSTIFICATION 

1. Need for the Information Collection. Section 112 of the Clean 

Air Act, as amended, requires that the U. S. Environmental Protection 

Agency (EPA) publish, and from time to time revise, a list of hazardous 

air pollutants for which it intends to establish emission standards and 

to actually establish emission standards for the pollutants within a 

prescribed period of time. Emission standards under Section 112 apply 

to both new and existing sources and must be set at levels which in the 

Administrator's judgment ".. . provide an ample margin of safety to the 

public health . . ." (Section 112(b)(1)(B)]. A copy of the full text of 

Section 112 is presented in Attachment 1. 

The EPA has published a notice announcing its intent to add either 

chromium or hexavalent chromium (Cr+ ) to the list of hazardous air 

pollutants under Section 112 of the Clean Air Act. The notice states 

EPA's belief that there is strong evidence to support the conclusion 

that at least some Cr+ compounds in air cause lung cancer in people. A 

final decision on the form of chromium to be listed and its actual 

listing will be coordinated with the proposal of regulations. 

A preliminary assessment performed by EPA has identified chromium 

electroplating and anodizing as a source category for which the 

development of a national emission standard under Section 112 appears to 

be warranted. There are several thousand facilities distributed across 

the U.S., many of which are uncontrolled. Collectively, these 

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facilities emit significant amounts of Cr+ to the atmosphere per 

year. The quantitative estimates of risks resulting from these 

emissions are very high. Finally, additional controls are available at 

what appear to be reasonable costs. 

The existing data base on the source category is very limited. 

Reliable information on the size, type, and distribution of existing 

chromium plating facilities as well as the level of control generally 

applied at these facilities is simply not available. Consequently, it 

is necessary to expand the current data base to formulate realistic 

regulatory alternatives and to assess the impacts of those alternatives 

accurately. 

The authority for EPA's information gathering is included in 

Section 114 of the Act. Among other things, Section 114 authorizes EPA 

to require owners and operators of emission sources to submit 

information reasonably required for the purpose of developing emission 

standards. The full text of Section 114 is reproduced in Attachment 2. 

2. Description and Practical Utility of the Information Collection 

Activity. 

a. Information Collection Activity for Chromium Plating and Anodizing 

Operations. Respondents will be the owners or operators of chromium 

plating and anodizing operations. Chromium plating and anodizing 

operations are used in the manufacture of a wide variety of industrial 

and consumer items. In general, chromium plating and anodizing 

operations are located at or near the industries they service, which are 

usually in or near industrialized areas. Many operations are "captive" 

processes performed within larger manufacturing facilities. Other 

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operations are "job shops" that provide custom plating services for many 

different clients. Hard and decorative plating and anodizing may be 

performed at the same shop. 

There may be as many as 4,500 chromium plating and anodizing 

facilities distributed nationwide. A total of 150 facilities will be 

selected to receive an information request. The information request 

will require the respondent to compile existing data, enter these data 

as responses to the appropriate part of the questionnaire, and submit 

the questionnaire to EPA within 42 days. The creation of new data or 

the analysis of existing data by the respondent will not be required. 

The written responses will be stored in a project file, and copies 

will be placed in the docket. The collected data also will be stored on 

computer disks and analyzed by EPA and the EPA contractor. All or a 

portion of the data provided will be used to develop a background 

information document to support the bases for recommending national 

emission standards for hazardous air pollutants (NESHAP). Any data 

identified by the respondents as trade secrets will be treated as 

confidential by EPA and will not be published or be made available to 

the public, as discussed in Section 10. However, all emission data will 

be considered public information. 

b. EPA Use of Data Collected. The information request is presented 

in Attachment 3. Its purpose is to obtain background information about 

chromium plating and anodizing operations. The information gathered 

will be used to formulate regulatory alternatives and to assess the 

energy, environmental, cost, and economic impacts of those alternatives. In addition, the information gathered will be used to confirm or 
P.7 

revise assumptions previously made that were based on limited data and 

that were used to calculate estimates of public health risks during the 

preliminary assessment for this source category. If this information 

collection activity is not carried out, the available data will be 

insufficient to perform these tasks properly. 

Part I of the information request asks for general information about 

the location and ownership of the plant. Information about chromic acid 

consumption, which is a measure of production capacity, may be one 

criteria for selecting model plant sizes for analysis. Information 

about the plant's parent company, type of shop, and number of employees 

will be used in the economic impact and Regulatory Flexibility Act 

analyses. Part II asks for detailed information about production 

equipment and process operations. This information will be used to 

characterize chromium plating and anodizing facilities for the purpose 

of developing representative model plants. These models will be used to 

analyze impacts associated with regulatory alternatives selected for 

consideration. 

Part III asks for information about the existing emission capture 

and control systems. This information will be used to identify 

candidate control options and evaluate the level of existing, or baseline, control applied across the industry. This estimate along with the 

estimate of potential emissions will be used to calculate a quantitative 

estimate of public health risks associated with current emissions from 

chromium plating and anodizing facilities. Cost data supplied will be 

compared with cost estimates to be developed by EPA for the candidate 

control options. Part IV will provide critical information about the 
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extent to which air pollution control devices contribute to increased 

effluents and wastewater treatment costs. Part V asks for available 

emissions test reports and applicable State or local air regulations. 

The test reports will be used to complement test data on control device 

performance to be obtained by EPA during the course of this standard 

development program. Information about State and local air regulations 

will be used to define a baseline alternative against which all other 

regulatory alternatives will be evaluated. 

Part VI asks for information about stack discharge parameters that 

will be used to develop model plant parameters for dispersion 

calculations that will be used to develop estimates of exposure and 

risks. Economic information obtained from Part VII will be used to 

confirm or revise source category economic profiles and assess the 

potential economic burdens associated with various regulatory 

alternatives that may be applied to the source category. 

3. Minimizing Burden. The burden to respondents has been 

minimized by requiring the collection of only that information which EPA 

considers essential for the development of a NESHAP. The questionnaire 

has been reviewed by EPA to make it as clear and concise as possible for 

the respondents and as complete as possible so that repeated followup 

contacts to clarify responses will not be necessary. 

4. Nonduplication. Other Federal agencies that have been 

contacted include the Office of Toxic Substances, the Occupational 

Safety and Health Administration, the National Institute of Occupational 

Safety and Health, and the Department of Defense. The Information 

Management Staff in the Office of Policy Planning and Evaluation has 

7 
P.9 

conducted a. search on the Federal Information Locator System and has 

determined that this collection does not duplicate any other information 

collection in the Federal government. 

The Effluent Guidelines Division (EGD) of EPA was contacted for 

information about chromium plating operations that were surveyed during 

the development of the Effluent Guidelines Standards. The chromium 

plating operations contacted by EGD comprised a portion of plating 

operations that were contacted 9 years ago. The 11st of these contacts 

is no longer computerized. The list was not obtained for use in this 

project because excessive resources would be required to separate the 

chromium plating operations from the other types of plating operations 

and to determine the chromium plating operations that are still 

operating. 

5. Consideration of Alternatives. Both the American Electroplaters and Surface Finishers Society and the National Association of 

Metal Finishers, which are trade organizations that represent owners or 

operators of chromium plating and anodizing operations, have been 

contacted by EPA to obtain needed information. The information 

requested in the information request is not available from either of 

these trade organizations. Therefore, the information must be provided 

by chromium plating or anodizing facilities. A written information 

request is the fastest and least expensive method for acquiring the 

extensive data that are required. 

The Office of Toxic Substances also was contacted to evaluate the 

feasibility of promulgating a rule under Section 8(a) of the Toxic 

Substance Control Act (TSCA), which would require owners or operators to 

f 
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respond to a specific list of questions contained in the rule. It was 

concluded that a rule under Section 8(a) of TSCA could not be 

promulgated in time to obtain the information needed for the development 

of the standards. 

6. Minimizing Burden for Small Businesses. The information 

request is a report that would be completed only once. As described in 

Section 3, steps have been taken to make the information request as 

clear and complete as possible so that the time necessary to fill it out 

will be as short as possible. Because the requested information 

concerns the routine operation of chromium plating and anodizing operations and should already be in company files, the questionnaire will be 

easy to complete. 

7. Consideration of Collection. Not applicable. This is a onetime information request, not a repeated reporting requirement. 

8. Paperwork Reduction Act (PRA) Guidelines. Only one of the 

PRA-imposed guidelines contained in Section 5 CFR 1320.6 may be violated 

because the survey may not produce data that can be generalized to the 

universe of study. The survey was designed to obtain the most representative sample possible of the total number of chromium plating and 

anodizing operations nationwide. However, the available information 

sources for developing the data base that will be used for the sampling 

frame contain biases that are not fully known. Also, the data needed to 

calculate an estimate of the accuracy of the survey are not available. 

The survey is being conducted to refine assumptions previously made 

about the source category. The survey will not be used for the purpose 

of obtaining data to publish for statistical use. 

7 
p.11 

9. Consultations. Table 1 presents the names of the non-EPA 

persons contacted to obtain the necessary data and develop the 

questionnaire. 

10. 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 39999, September 8, 

1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). A 

summary of the Emission Standards and Engineering Oivision procedures 

for safeguarding confidential business information is included in 

Attachment 4. This information collection complies with the Privacy Act 

of 1974 and OMB Circular A-108. 

11. Sensitive Questions. Not applicable. This ICR does not 

involve matters of a sensitive nature. Information to be collected for 

this project is limited to technical and economic data. 

12. Cost to the Government and Respondents. 

a. Cost to the Federal Government. The overall cost to the Federal 

government for this information request is estimated to be about 

$19,170. Elements of the cost estimate are itemized in Table 2. They 

include costs for the development and distribution of the information 

request and the collection, compilation, editing, and analysis of the 

responses to the information request. These costs include all EPA 

contractor and in-house EPA engineering resources required and are based 

on a direct labor charge of $14.50 per hour (Grade 10, Step 7). 

Overhead charges represent 110 percent of the direct labor charge and 

/<> 
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TABLE 1. NON-EPA PERSONS CONSULTED ON THE PROPOSED 

INFORMATION COLLECTION ACTIVITY 

Name Affiliation Telephone 

Fred Steward 

Rebecca Spearot 

Jeff Tanchon 

Cliff Popejoy 

Chairman: Environmental Committee, 

American Electroplaters and 

Surface Finishers Society 

Member: Environmental Committee, 

American Electroplaters and 

Surface Finishers Society 

National Association of Metal 

Finishers 

California Air Resources Board 

(412) 452-9360 

(313) 497-9100 

(312) 644-6610 

(916) 323-8503 

/ / 
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TABLE 2. SUMMARY WORKSHEET FOR FEDERAL COST OF INFORMATION REQUEST 

Developmental Costs 

Oesign 

Printing 

Implementation 

Operational Costs 

Distribution of ICR's 

Collection 

Compilation 

Editing, coding, 

and tabulating 

User Costs 

Analysis 

TOTAL COSTS 

(a) 

Direct 

personnel 

cost, $ 

638 

17 

208 

37 

14 

1,039 

4,785 

2,175 

(b) 

Overhead 

cost 

(110% 

of "a"), $ 

702 

19 

229 

41 

15 

1,143 

5,264 

2,393 

(c) 

Other direct 

costs (e.g., 

materials, 

etc.), $ 

450 

(a+b+c) 

Component 

total, $ 

1,340 

486 

437 

78 

29 

2,182 

10,049 

4,568 

19,169 

10 

/ > 
are based on the estimated time spent by EPA and contractor management, 

clerical, and support personnel. 

b. Cost to the Respondent. The estimated cost to the typical 

respondent is about $244 and includes the collection, analysis, transmission, and retention of the requested information. Table 3 itemizes 

the estimated costs to a typical respondent for this information 

request. Based on a maximum of 150 ICR's, the total cost to the 

industry is estimated to be $36,600. The labor cost and overhead rate 

for the Federal costs also were used in these calculations. 

13. Estimation of Respondent Burden. The information collection 

burden presented here represents an estimate of the maximum industry 

resources required to respond to this information request. The average 

time required for each respondent is estimated to be 8 person-hours. 

Table 4 itemizes the burden for each activity. Based on a maximum of 

150 ICR's, the total burden to industry is estimated at 1,200 personhours. This estimate assumes a 100 percent response rate. The average 

response time per information request is based on (1) the length and 

complexity of the questionnaire and (2) the assumptions that the 

requested information is readily available to the respondent and that 

the respondent is familiar with the information. 

14. Reason for Chanqe in Burden. Not applicable. This is a 

one-time survey. 

15. Scheduling. The information requests will be mailed by 

October 1986, and all responses should be received by December 1986. A 

recommended regulation and a draft background information document (BID) 

supporting the recommendation will be available by October 1987. Both 

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TABLE 3. SUMMARY WORKSHEET FOR A TYPICAL RESPONDENT'S COST 

Burden component 

Read instructions 

Gather information 

Process, compile, and review 

information for accuracy 

and appropriateness 

Complete written instruments 

TOTAL COSTS 

(a) 

Direct 

personnel 

cost, $ 

7.25 

72.50 

21.75 

14.50 

(b) 

Overhead 

cost 

(110% 

of "a"), $ 

8.00 

79.75 

23.90 

15.95 

(a+b) 

Component 

total, $ 

15.25 

152.25 

45.65 

30.45 

243.60 

12 

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TABLE 4. SUMMARY WORKSHEET FOR RESPONDENT'S BURDEN OF 

INFORMATION REQUEST 

Burden component Description of activity 

Direct 

personnel 

Read instructions 

Gather information 

Process, compile, and 

review information 

for accuracy and 

appropriateness 

Complete written 

instruments 

TOTAL HOURS 

Understanding all that is 

asked for 

Search records and files, 

talk to plant employees, 

observe operations, and 

obtain measurements for 

requested information 

Organize information in the 

format of the information 

request 

Fill out the forms and prepare 

all attachments 

0.5 

5.0 

1.5 

1.0 

8.0 

13 

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will be reviewed at a public meeting of the National Air Pollution 

Control Techniques Advisory Committee that will be held in December 1987 

to solicit comments on the recommended regulation and the BID. Comments 

will be considered and revisions will be made to the BID and/or 

recommended regulation by January 1988. The recommended regulation and 

supporting documentation, including the preamble to the regulation and 

the BID, will be submitted to OMB for review in May 1988. Proposal of 

the standards in the Federal Register is scheduled for June 1988 after 

several iterations of internal EPA review. Promulgation of the 

standards is scheduled for January 1990. 

16. Standard Industrial Classification (SIC) Code. The information 

request will be mailed to facilities that are included in but not 

limited to the following four-digit SIC codes: 

SIC code Industry Classification 

3423 Hand Tools 

3432 Plumbing Materials 

3465 Automobile Stampings 

3471 Electroplating 

3724 Aircraft Parts 

3554, 3555 Industrial Rolls 

3599 Hydraulic Cylinders 

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS 

1. Description of Activity. A total of 150 surveys will be sent 

to firms that operate chromium plating and/or anodizing facilities. 

Based on available EPA contractor resources, 150 surveys is the maximum 

number of surveys that can be managed within the budget allocated for 

the data collection phase of this project. The 150 surveys will provide 

a more representative and comprehensive sample of the source category 

than the preliminary information that has already been obtained for this 

project. 

14 

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P.18 

Estimates of the total number of firms nationwide that operate 

chromium plating and anodizing facilities range from 2,200 to 4,500. 

The sampling frame for the Section 114 survey will be based on firms 

that have been identified during Phase I (completed) and Phase II 

(ongoing) of this project. To date, 1,066 firms have been identified 

and entered into a data base. Information entered into the data base 

includes the name and address of each firm and, when available, information on whether the facility is a job or a captive shop, the type of 

plating and/or anodizing performed by the facility, and the type of 

product(s) plated and/or anodized by the facility. Information for the 

data base was obtained from the American Electroplaters and Surface 

Finishers shop guide, Thomas' Register, Harris Pennsylvania Industrial 

Directory, MacRae's Industrial Directory, Greater Delaware Valley 

Regional Industrial Guide, and telephone directories. 

A frequency distribution of the number of firms contained in the 

current data base is presented in Table 5. There are 751 shops 

classified as job, 126 shops, classified as captive, and 189 shops for 

which the type of shop is unknown. The ratio of job to captive shops in 

the data base is about 6 to 1. This ratio is inconsistent with 1982 

Bureau of Census data that indicate that the ratio of job to captive 

shops is about 1 to 1.6 for electroplating and metal finishing firms 

nationwide. The distribution of firms in the current data base is 

probably skewed toward job shops because captive shops are an integral 

part of manufacturing operations within plants and typically do not 

advertise in industrial guides, directories, and registers to attract 

custom plating or anodizing business. Therefore, for the purpose of 

15 

'7 
TABLE 5. NUMBER OF FIRMS STRATIFIED BY TYPE OF OPERATION WITHIN TYPE OF SHOP 

Type of 

Job 

Captive 

Unknown 

Total 

shop 

Decorative 

335 

63 

50 

448 

Decorative 

and 

anodizing 

25 

2 

0 

27 

Hard 

202 

36 

124 

362 

Type of operation 

Hard and 

anodizing 

21 

7 

0 

28 

Decorative 

and hard 

86 

16 

13 

115 

Decorative, 

hard and, 

anodizing 

77 

1 

0 

78 

Anodizing 

2 

1 

0 

3 

Unknown 

3 

0 

2 

5 

Total 

751 

126 

189 

1,066 

^C\ 

CO 
this information collection activity, the ratio of job to captive shops 

approximated by the Bureau of Census data for chromium plating and 

anodizing operations nationwide will be used rather than the ratio 

contained in the current data base. 

2. Procedures Used for the Collection of Information. The sample 

design for this survey will be based on stratified random sampling. 

Firms with similar characteristics will be grouped into strata to 

minimize the variability and obtain a more accurate estimate of the 

characteristics of the firms within each stratum. An example of the 

stratification approach using the current data base is shown in 

Table 5. The data base has been stratified at two levels: first, by 

the type of shop and, second, by the type of operation within the type 

of shop. Samples obtained from the data base by simple random sampling 

without stratification would not be as representative of the characteristics of firms as would samples obtained from each stratum in Table 5. 

If the number of firms contained in some of the strata is too small 

to obtain a representative sample of the strata, those strata would be 

combined with strata containing a large number of firms. Using the data 

presented in Table 5 as an example, the frequency distribution presented 

in Table 6 can be formed. The decorative plating and anodizing strata 

were combined with the decorative plating strata, and the hard plating 

and anodizing strata were combined with the hard plating strata. 

Combining these strata will minimize overlap between the strata because 

anodizing operations are believed to be smaller than decorative or hard 

plating operations at the same plant. Strata containing firms that 

perform a combination of decorative and hard plating and decorative and 

17 

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P.21 

TABLE 6. TOTAL NUMBER OF FIRMS STRATIFIED BY TYPE OF OPERATION WITHIN 

TYPE OF SHOP AND NUMBER OF FIRMS TO BE SAMPLED FROM EACH STRATUM 

Type of < 

No. of 

Job 

Total 

Sample 

Captive 

Total 

Sample 

Total 

• Total 

Sample 

>hop/ 

firms 

Decorative 

and 

decorative/ 

anodizing 

360 

28 

65 

46 

425 

74 

Type 

Hard 

and 

hard/ 

anodizing 

223 

17 

43 

30 

266 

47 

of operation 

Decorative/ 

hard and 

decorative/ 

hard/ 

anodizing 

163 

13 

17 

13 * 

180 

26 

Anodizing 

2 

2 

1 

1 

3 

3 

Total 

748 

60 

126 

90 

874 

150 

18 

£0 
hard plating and anodizing also were combined. Firms contained in the 

unknown strata were excluded from Table 6 because either the type of 

shop or the type of operation performed is unknown. 

Also presented in Table 6 is the total number of firms that would be 

sampled from each stratum using the current data base. Based on the 1 

to 1.6 ratio of job to captive shops approximated by the 1982 Bureau of 

Census data, 60 information requests would be sent to job shops and 

90 information requests to captive shops. 

It is assumed that the relative distribution of the types of operations within each shop type category presented in Table 6 is representative of the distribution of the types of operations performed by the 

total number of firms nationwide. Because very little information has 

been obtained for chromium anodizing operations, the three firms that 

perform chromium anodizing would be surveyed to ensure that information 

about these operations is obtained. The number of firms that would be 

sampled from the remaining stratum in each shop type category would be 

determined by calculating the percentage of firms in each stratum 

relative to the total number of firms for the shop type category 

multiplied by the total number of firms that would be sampled from each 

shop type category. For example, 48 percent of the firms are job shops 

that perform decorative plating or decorative plating and anodizing and 

a total of 58 firms (60 - 2 captive shops) are job shops would be 

surveyed. Therefore, 28 firms (0.48 x 58) from this stratum would be 

surveyed. 

The actual sample size that will be selected from each stratum is 

not fully known at this time because the data base currently is being 

19 

ai 
P.23 

updated to incorporate additional information obtained for the firms in 

the data base and for firms not included in the data base. Also, firms 

selected from the data base to receive the survey will be contacted to 

confirm the address, type of shop, type of operation, and willingness to 

respond to the survey before the mailing list is finalized. The data 

base will be updated based on information obtained from these 

contacts. Therefore, the actual sample sizes will be determined by 

using the stated approach based on the best available information 

obtained at the time the survey is conducted. 

The economic impact analysis of the regulatory alternatives 

considered in the development of the NESHAP will focus on (but will not 

be limited to) firms that perform decorative chromium plating of hand 

tools, plumbing materials, and automobile stampings; hard chromium 

plating of aircraft parts, industrial rolls, and hydraulic cylinders; 

and chromium anodizing of aircraft parts. The data base will not be 

stratified by the type of product(s) plated and/or anodized because this 

level of stratification is either highly variable within each stratum or 

the type of product(s) plated and/or anodized is unknown. Therefore, 

the firms selected for the survey will be evaluated to ensure that some 

of the firms perform chromium plating and/or anodizing of the products 

previously mentioned. 

The degree of the accuracy of this survey cannot be calculated 

because information about the variability of the responses to many of 

the questions in this survey is not available. For example, responses 

to questions about the chromic acid consumption and annual sales for the 

firm and its plating or anodizing operation, level of emissions control, 

20 

££-
P.24 

production rates, treatment of control device effluent discharge, and 

procedures used to estimate charges or costs for plating or anodizing 

different products are expected to be highly variable. Information is 

not available to make assumptions about the average response and the 

variability of the response to each of these questions. 

3. Nonresponse, Maximization of Response Rates, and Accuracy and 

Reliability. A response rate of 100 percent is expected because the 

information request is being sent under the authority of Section 114 of 

the Clean Air Act. Each information request received from a respondent 

will be reviewed to ensure that all questions are answered properly 

before the information is entered in a data base. 

4. Tests of Procedures. Some of the questions contained in the 

Phase II information request presented in Attachment 3 have been 

pretested during Phase I of this project. During Phase I, nine information requests were sent to job shops and nine to captive shops. Based 

on responses to those requests, general information requested for the 

plant and for chromium plating and anodizing tanks and questions about 

emission control systems and costs, emission data, and stack parameters 

have been modified to minimize the burden to the respondents and to 

improve the utility of the information for the project. However, 

questions about treatment of control device effluent discharge, annual 

sales for the firm and its plating or anodizing operation, and 

procedures used to estimate charges or costs for plating or anodizing 

different products have been added to the Phase II survey and have not 

been pretested. 

21 

£3 
P.25 

5. Other. Not applicable. The information collection results will 

not be published for statistical use. 

4 Attachments 

22 

At 
P.26 

Attachment 3 

NOT SUBJECT TO THE REQUIREMENTS Of 

SECTION 3507. PAPERWO.8. OUCTION ACT OF 1980 

INFORMATION REQUEST FORM 

CHROMIUM PLATING ANO ANODIZING OPERATIONS 

Please answer this information request as completely as possible from 

existing sources for your plant. The information requested 1s necessary to 

provide EPA with an accurate description of hard and decorative chromium 

electroplating operations and anodizing operations that use chromic acid. 

No additional emission or process testing is required by your company to 

answer this request. Attach drawings whenever appropriate and additional 

pages as needed. If you believe that any of the information requested 1s 

confidential, please submit this information on a separate sheet marked 

"CONFIDENTIAL." Your help in this effort will be greatly appreciated. 

I. General Information 

A. Name of plant: 

B. Street address: 

C. Name of parent company: 

0. Name and title of respondent: 

E. Telephone number of respondent: 

F. Type of shop: Job Captive Both 

G. Chromic acid consumption for 1985: 

1. Total for plant, lb/yr 

2. Hard chromium plating, % 

3. Decorative chromium plating, % 

4. Anodizing, % 

5. Other, % 

H. Number of employees for 1985 

1. For the plant: 

2. Directly involved in chromium plating or anodizing: 

3. For the entire parent company: 

as 
P.27 

2 

II. Information for Chromium Plating or Anodizing Tanks 

Please provide the following information for each chromium plating 

and anodizing tank. Cite typical values rather than ranges for operating 

and production parameters. If you have more than three tanks, make copies 

of the necessary additional pages before writing on the original. 

A. Tank identification 

B. Type of operation (e.g., 

hard plating, 

decorative plating, 

anodizing) 

C. Inside dimensions of 

tank (1 x w x h) , ft 

D. Tank capacity, gal 

E. Predominant substrate 

or base material 

plated or anodized 

(e.g., steel, brass, 

plastic, etc.) 

F. Concentration of chromic 

acid, oz/gal 

G. Catalyst(s) used 

H. Concentration of 

catalyst(s), oz/gal 

I. Temperature of plating 

solution, °F 

J. Operating voltage, volts 

K. Operating current, 

amperes 

L. Chromic acid consumption, lb/yr 

M. Total ampere-hours for 

a typical year 

N. Hours of operation, h/d; 

d/wk; and wk/yr 

0. Production rate 

1. Surface area2 

plated, ft /yr 

2. Chromium deposited, 

lb/yr 

^ 
P.28 

III. Emission Control System 

Please provide the following information for the emission control 

system used on each chromium plating or anodizing tank. If you have more 

than three control systems, make copies of the necessary additional pages 

before writing on the original. 

A. Tank identification 

(see Question III.A) 

B. Demisting agent used 

1. Type (e.g., 

wetting agent, 

foam, plastic 

balls, etc.) 

2. Manufacturer 

3. Brand name 

4. Usage, lb/yr 

5. Annual operating 

cost, $/yr 

C. Emission capture system 

1. Type of hood (e.g., 

one-side, 

two-sided, 

push-pull, 

canopy, etc.) 

2. Gas flow rate, scfm 

a. Exhaust fan 

b. Push fan 

3. If canopy or 

enclosing hood, 

dimensions of 

open sides above 

tank (1 x h), in. 

4. If push-pull 

a. Pull hood 

Face dimensions 

(1 x h), in. 

Slot dimensions, 

(1 x h), in. 

No. of slots 

b. Push hood 

Slot dimensions 

(1 x h), in. 

No. of slots 

No. and spacing 

of holes 

Diameter of 

holes, in. 

27 
P.29 

D. 

5. Cost of hood(s), 

fan(s), and duct-

work 

a. Total capital, $ 

b. Annual operat-

ing, $/yr 

Emission control device 

1. Type (e.g., mist 

eliminator, 

packed-bed 

scrubber, etc.) 

2. Manufacturer 

3. Model 

4. Gas flow rate, scfm 

5. Inlet gas tempera-

ture, °F 

6. Gas pressure drop 

across system, 

in. H

20 

7. Scrubbing liquid 

flow rate, 

gal/min 

8. Washdown a. Volume

, gal 

b. Frequency, 

times/d 

9. Effluent discharge, 

a. Rate, gal/d 

b. Chromic acid 

concentration, 

oz/gal 

10. Capital cost 

a. Base year 19 

b. Control 

device, $ 

c. Recirculation 

tank, $ 

d. Stack, $ 

e. Total, $ 

Ll. Annual operating 

cost 

a. Base year 19 

b. Maintenance, 

$/yr 

c. Utilities, $/yr 

d. Total, $/yr 

19 19 

19 19 

&1 
P.30 

IV. Control Device Effluent Discharge 

Please describe, or illustrate in a flow diagram, all of the 

intermediate and final destinations of the effluent discharged from each 

control device listed in IV.D.l. Indicate if the effluent is discharged 

directly to a wastewater treatment system; recycled to a plating, 

anodizing, or rinse tank; pumped to a holding tank and recirculated to a 

scrubber, etc. If effluent is recirculated, provide the chromic acid 

concentration of the resultant scrubbing liquid. If effluent is treated in 

a wastewater treatment system, indicate the amount treated and the 

annualized cost of treatment 1n 1985 dollars. 

V. Emissions Data and Requiations 

For each chromium plating or anodizing tank or associated control device, 

please provide any available emissions test data and copies of all applicable 

test reports. Also, provide information on any existing State and local air 

regulations with which your plant must comply that affect or limit the 

quantity of chromium allowed to be emitted to the atmosphere. 

VI. Stack Parameters 

For each discharge point, please provide the following information. 

A. Type (e.g., horizontal 

vent, vertical stack, 

etc.) 

B. Height of gas discharge above ground 

level, ft 

C. Inside diameter or 

dimensions, in. 

D. Volumetric flow, acfm 

E. Gas temperature, °F 

F. Number and identif ication of tanks vented 

to each stack (see 

Question III.A) 

M 
P.31 

VII. Economic Information 

A. For 1985, please provide an estimate of annual sales (value added 

or revenue) for (1) hard chromium plating, (2) decorative 

chromium plating, and (3) chromic acid anodizing operations. 

1. Total annual sales for the plant, $: 

2. Sales derived from hard chromium plating operations. 

$ % of Total 

3. Sales derived from decorative chromium plating operations. 

$ % of Total 

4. Sales derived from anodizing operations. 

$ % of Total 

5. Sales derived from custom (job) plating or anodizing 

operations. 

$ % of Total 

6. Sales derived from captive plating or anodizing operations. 

$ % of Total 

2,0 
V*. 

B. Based on 1985 revenues, please list the most significant items or products that were chromium plated 

or anodized in your plant. For each of these products, list the (1) estimated charges or costs per 

unit for plating and/or anodizing, (2) estimated charges or costs of plating and/or anodizing as a 

percentage of final product value, (3) total number of each of these products that were plated or 

anodized in your plant in 1985 and the required number of operating hours to perform the service, 

and (4) percentage of the total plating or anodizing capacity used to produce these products. 

Producta 

Plating or 

anodizing 

cost, $ 

per unit 

Charges or costs 

as percentage 

of final 

product value 

1985 Production 

Units 

processed, 

number 

Processing 

time, hours 

Percent 

of total 

capacity0 

1. 

2. 

3. 

4. 

5. 

aPlease list well-defined products and denote whether product is hard (H) or decorative (D) chromium 

plated or anodized (A). 

For job shops, service charge is relevant; for captive shops, value added is relevant. 

"Specify if based on number of units processed or hours of processing time. 

ta- ro 
, P.33 

.nclosure 4 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Emission Standards and Engineering Division 

June 1982 

Summary of ESED 

Procedures for Safeguarding Confidential Business Information 

1. Purpose 

This memorandum summarizes Agency policy and procedures pertaining to 

the handling and safeguarding of information that may be entitled to confidential 

treatment for reasons of business confidentiality by the Emission Standards 

and Engineering Division (ESED), Office of Air Quality Planning and Standards, 

Office of Air, Noise, and Radiation, U.S. Environmental Protection Agency. 

2. Other Applicable Documents: 

a. Clean Air Act as amended. 

b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business 

Information. 

c. EPA Security Manual, Part III, Chapters 8 and 9. 

3. Exception: 

This document was prepared as a summary of data gathering and handling 

procedures used by the Emission Standards and Engineering Division, Office of 

Air Quality Planning and Standards, EPA. Nothing in this document shall be 

construed as superseding or being in conflict with any applicable regulations, 

statutes, or policies to which EPA is subject. 

4. Definition: 

Confidential Business Information - Information as to which the source 

has asserted a claim of confidentiality. This information may be identified 

with such titles as trade secret, secret, administrative secret, company 

secret, secret proprietary, privileged, administrative confidential, company 

confidential, confidential proprietary, proprietary, etc. NOTE: These 

markings should not be confused with the classification markings of National 

Security information identified in Executive Order 11652. 

5^ 
P.34 

6. Procedures: 

a. Request for Information 

Each request originating in the Emission Standards and Engineering 

Division (ESED) for information made under the provisions of Section 114(a) 

is signed by the Division Director. The request includes ESED's standard 

enclosure "EPA's Information Gathering Authority Under Section 114 of the 

Clean Air Act," which was designed to meet the requirement of 40 CFR Part 2 

discussed above. 

b. Receipt of Confidential Business Information 

Upon receipt of information for which confidential treatment has been 

requested, the Office of the Director (OD) directs the logging of the 

material and the establishment of a permanent file. If confidential treatment 

is requested, but is not specifically marked, the material will be stamped 

"Subject to Confidentiality Claim." If part of the material is claimed to 

be confidential, that portion is marked "Subject to Confidentiality Claim." 

In compliance with Sections 2.204 and 2.208 of 40 CFR Part 2, the Branch 

Chief responsible for the requested information reviews the information to 

determine whether it is likely to be confidential, in contrast to being 

available in the open literature, and whether it likely provides its holder 

with a competitive advantage. If the information is clearly not confidential, 

the Branch chief prepares a letter for signature of the Division Director, 

ESED, to notify the business of this finding. If the information is possibly 

confidential, the Branch Chief sends a memorandum to inform the Office of the 

Director, ESED, of this finding, gives a brief description of the material 

(what it is, how many pages, etc.), identifies it with the correct ESED 

project number, and lists those persons who are authorized to have access to 

the information. The information and memorandum are hand carried to the OD 

and filed with the material. EPA Form 1480-21, "Privileged Information 

Control Record," (Enclosure A) is also filed with the folder containing the 

information. If confidential business information is received from the owner 

via an authorized representative or a third party, the same procedure is followed, 

with the addition of clearly identifying the information and its source. 

By regulation, information for which confidential treatment is requested 

must be so marked or designated by the submitter. EPA takes additional 

2,3 
P.35 

to honor the above-noted limitations. A copy of each such agreement must be 

furnished to EPA in a format substantially complying with that shown in 

Enclosure B before access is permitted. 

(3) the authorized contractor representative must agree that the conditions 

in the contract concerning the use and disclosure of confidential business 

information are included for the benefit of, and shall be enforceable by, 

both EPA and any affected business having a proprietary interest in the 

information. 

These requirements provide reasonable protection for the rights of 

owners of confidential business information. 

Information may be released to or accessed by employees of other EPA 

elements only upon approval by the Director, ESED, of a written justification 

signed by a Division Director, or equivalent. 

Requests from other Federal agencies, Congress, Comptroller General, 

Courts, etc., are handled by the Office of the Director, ESED. 

Requests under the Freedom of Information Act are handled in accordance 

with 40 CFR, Part 2, Subpart A. The ESED Freedom of Information Coordinator 

must be consulted prior to responding to any request for information where a 

claim of confidentiality has been asserted or where there is reason to believe 

that a claim might be made if the business knew release was intended. 

e. Use and Disclosure of Confidential Business Information 

Confidential business information as defined may not be used in 

publications, supporting documents, memoranda, etc., that become a part of 

the public domain, except as provided for in 40 CFR, Chapter 1, Part 2, 

Subpart B. 

Confidential business information may not be summarized, tabulated, 

photocopied, or in any other way reproduced without the express written 

approval of the Branch Chief responsible for the information request. Any 

authorized reproduction shall be sparing and all procedures herein, strictly 

followed. Further, all authorized reproductions must be introduced into the 

confidential business information control system and treated according to the 

same procedures applicable to the original confidential material. 

EPA generated documents or material, or extracts of information containing 

confidential business information, shall be stamped "For Official Use Only" 

and include on the first page and/or cover sheet the following statement: 

34 
"This document contains data claimed to be confidential business 

information and shall be handled and stored in accordance with Part III, 

Chapter 9 of the EPA Security Manual." 

f. Handling of Other Information 

Reports, memoranda, documents, etc., prepared by EPA or its authorized 

representatives are not normally circulated outside EPA for comment or review 

prior to publication except in such cases as described above (6.d.3) wherein 

confidential business information is expressly included. However, because 

industrial-data-gathering visits, plant inspections, and source testing can 

involve inadvertent receipt of confidential business information, it is the 

policy of ESED to protect all parties involved in the following manner. 

Prior to or at the inception of a plant inspection, data gathering 

visit, or source test, EPA or its authorized representatives discuss with a 

responsible industry official the information sought, how it is to be used, 

and how it is to be protected. A copy of this document may be provided upon 

request. 

Following an inspection, visit, or test, a trip report will be prepared 

to include, as practicable, all information received by EPA or its authorized 

representative during the visit or test. The report may be prepared by 

either EPA or its authorized representative. The draft of that report will 

be clearly identified, or an enclosed, colored cover sheet as "Confidential 

Business - Pending Company Review." A second copy of the draft trip report 

will be made. It will be forwarded by EPA to the responsible industry official 

for review. The responsible industry official will be requested by cover 

letter to review the report, clearly mark any information considered to be 

confidential, and return the marked report to the responsible EPA employee 

within two weeks of receipt. The original draft will be kept in the 

confidential business information file until the marked-up copy is returned 

by the business firm. 

When the reviewed copy of the report, as marked by the responsible plant 

official, is received by EPA, information designated confidential will be 

placed in the confidential business information files as described above. 

The original of the trip report will be edited to delete the confidential 

information and the trip report will be issued. 

# 
ENCLOSURE B 

TREATMENT OF CONFIDENTIAL INFORMATION 

It is understood that perfonnaace uader EPA Coatract No. 

will require the Coatractor ( ) 

aad its employees to have access to confidential iaformatioa obtained 

by EPA under sectioa of the Clean Air Act. Ia fulfillment of 

the coaditioas of disclosure contained in the Contract, I 

, hereby affirm that I personally will honor the 

limitations expressed in the contract concerning my access to such 

information. 

Specifically, I shall: 

1. use the information oaly for the purpose of carryiag out the 

work required by the Coatract; 

2. refraia from disclosing the iaformatioa to anyone other than 

EPA without the prior written approval of each affected business 

or of an EPA legal office; and 

3. return to EPA, through the Contractor, all copies of the informatioa (and any abstracts or excerpts therefrom) upon request 

by the EPA Program Office or whenever the information is no 

longer required by the Coatractor for the performaace of work 

required by the Contract. 

Dated this day of , 1976. 

Signature 

3b