DRAFT 

Date: August 3, 2007 

Subject: Recommendations on Emission Estimates for Chromium Electroplating 

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

 This memorandum presents recommendations on revising the estimated emissions of 

chromium compounds for several facilities that are subject to 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. Earlier this year, emissions from several chromium electroplating and anodizing 

facilities were modeled to assess the residual risk for the Chromium Electroplating Source 

Category. This memorandum focuses on a select group of plants for which the modeling 

indicated high risk. 

 The emission estimates used in the modeling were taken from the National Emission 

Inventory (NEI) Database. The actual pollutant modeled varied among the plants. For most 

plants, the modeled pollutant was hexavalent chromium. However, some plants were modeled 

for "chromium and compounds," some for "chromium," and one plant was modeled for 

"chromium trioxide." 

 The results of the risk assessment are presented in three documents: Risk and Technology 

Review–Phase II, Source Category Information Summary, Preliminary Draft, Chromic Acid 

Anodizing (June 2007); Risk and Technology Review – Phase II, Source Category Information 

Summary, Preliminary Draft, Decorative Chromium Electroplating (June 2007); and Risk and 

Technology Review – Phase II, Source Category Information Summary, Preliminary Draft, Hard 

Chromium Electroplating (June 2007). 

II. Background

 Section 112(f)(2) of the Clean Air Act (CAA) requires the Environmental Protection 

Agency (EPA) to assess the risk remaining (residual risk) after the application of maximum 
 

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achievable control technology (MACT) standards under Section 112(d) of the CAA. In response 

to the preliminary residual risk assessment of the Chromium Electroplating Source Category, 

RTI International (RTI) was asked to review the emissions estimates for several facilities that 

were indicated as high risk, and present recommendations on revising those emission estimates. 

Specifically, RTI reviewed the emission estimates for all plants for which the maximum 

individual lifetime cancer risk (MIR) was at least 10 per million, and for which RTI already had 

information on file. RTI also tried to obtain additional information for any plants with an MIR 

of at least 100 per million, and for which RTI did not have the data on file to estimate emissions. 

Finally, RTI identified any other of the modeled plants for which RTI had information on file 

indicating that the plant either was closed or no longer performed chromium electroplating or 

anodizing. 

 

III. Summary of Results and Recommendations for Revised Emissions Estimates

 The general approach used in this analysis was to present any available emission 

estimates developed either by the facility or regulatory agency; develop emission estimates based 

on the available design, operating, and emission test data; and recommend the estimates that 

appear to be most representative of actual emissions. Emissions were estimated based on 

emission test data, if available. If emission test data were not available, estimates were made 

using the available design and operating data and conservative assumptions, which should result 

in overestimates for most plants. Annual emissions were estimated using the actual or typical 

operating hours presented in the plant's permit or permit application. If actual or typical 

operating hours were unknown, it was assumed that the tank was operated continuously 

throughout the year (i.e., 8,760 hours per year). 

 The recommended emission rates are presented as chromium compounds, unless 

indicated otherwise (e.g., the facility or State agency estimated emissions as hexavalent 

chromium). However, with one exception, the form of chromium used in chromium 

electroplating baths is hexavalent chromium, and testing conducted during the development of 

the Chromium Electroplating NESHAP demonstrated that emissions are almost entirely in the 

form of hexavalent chromium. The only exception is for trivalent chromium baths, which are 

sometimes used in decorative chromium electroplating. 

 Table 1 summarizes the results of RTI's review and presents revised emission estimates 

for several of the decorative chromium electroplating plants that were included in the risk 

modeling; Table 2 presents the same information for several hard chromium electroplating 

plants. Details on the emission estimates for each of the subject facilities are provided in 

Attachment 1. Since the modeling did not indicate high cancer risk for any of the chromium 

anodizing plants included in the risk modeling, those emission data were not reviewed. 

 With a few exceptions, the NEI emission data used to model risk appear to be 

significantly higher than what would be expected for these types of sources. An example is the 

Empire Hard Chrome -- Kostner Avenue Plant (NEIIL03161). The NEI indicates emissions of 

395 pounds per year (lbs/yr) for this plant, whereas as RTI estimated 31.2 lbs/yr. RTI's estimate 

is based on emissions at the emission limit, and therefore is likely to overestimate actual 

emissions. This plant can also be used as a benchmark for hard chromium electroplating plants 
 

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because it reportedly is one of, if not the, largest hard chromium electroplating plant in the U.S. 

in terms of production. Consequently, any estimate of emissions for a hard chromium 

electroplating plant that is significantly greater than 30 lbs/yr should be scrutinized. Emissions 

from decorative chromium electroplating plants should be significantly lower than this level for 

two reasons: (1) electroplating emissions are largely a function of the electrical current applied, 

and hard chromium electroplating generally uses much higher electrical current levels than does 

decorative chromium electroplating; and (2) decorative chromium electroplating plants generally 

operate fewer chromium electroplating tanks than the 12 tanks operated by the Empire Hard 

Chrome plant. Our calculations indicate that emissions for most decorative chromium 

electroplating plants are less than 2 lbs/yr. 

 One final note concerns the Norbrook Plating Inc. facility (NEIMIB6660), located in 

Warren, Michigan. The modeling results indicated an MIR of 6,000 per million for this facility. 

Only one other of the modeled plants had an MIR value this high. RTI currently does not have 

the information needed to estimate emissions for this plant. We have made several attempts to 

contact the State agency for information, but have been unsuccessful. 
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Table 1. Summary of Emission Estimate Review for Decorative Chromium Electroplating 

NEISiteID Facility Name City State MIR 

Modeled 

pollutant 

NEI 

emissions, 

(lbs/yr) 

Revised 

emissions 

(lbs/yr)a Comments 

NEISC0671254 AVM INC MARION SC Chromium 

trioxide 

1,299 1.76 No MIR because emis

"chromium trioxide." Pchromium compounds chromium. 

NEI49228 BERTEAU-LOWELL 

PLATING WORKS 

CHICAGO IL 300 Hexavalent 

chromium 

63.6 0.588 

NEICA0732913 CA PLATING SAN DIEGO CA Hexavalent 

chromium 

0.00730 0.0 Plant closed. 

NEI22524 CHROME CRAFT SACRAMENTO CA 100 Hexavalent 

chromium 

11.8 No basis for changing 

emissions are likely to 

NEIMIA8830 CHROME CRAFT CORP HIGHLAND 

PARK 

MI 10 Hexavalent 

chromium 

3.00 No basis for changing 

emissions are likely to 

NEI11893 DECO'PLATE MFG 

COMPANY 

LAPEER MI 300 Hexavalent 

chromium 

919 1.27 

NEICO0129 DENVER METAL 

FINISHING 

DENVER CO 1,000 Chromium & 

compounds 

35.6 1.12 Plant operates hard an

chromium electroplatinemissions: 0.000357 temissions: 0.000202 t

NEI20872 KOTOFF & CO INC EL MONTE CA Hexavalent 

chromium 

0.126 0.0 Plant closed. 

NEI11509 MANUFACTURERS 

PLATING COMPANY, INCORPORATED 

CLEVELAND OH 6,000 Chromium 910 1.59 Comprised of 0.672 lb

chromium and 0.913 lbchromium. 

NEIMIB6660 NORBROOK PLATING, 

INC. 

WARREN MI 6,000 Hexavalent 

chromium 

1,061 Waiting on additional 

State agency. 

NEIIL0317010 P & H PLATING CO INC CHICAGO IL 1 Hexavalent 

chromium 

0.193 0.0 Plant closed. 

NEI2OH007477 QUALITY PLATING 

COMPANY, INCORPORATED 

CLEVELAND OH 200 Hexavalent 

chromium 

95.2 0.160 

NEISC2506 SPARTAN INDUSTRIES PACOLET SC 10 Chromium & 

compounds 

1.73 No data on facility, bu

be reasonable. 

NEI21339 STANDARD NICKEL 

CHROMIUM PLATING CO INC 

LOS ANGELES CA 100 Hexavalent 

chromium 

17.7 0.0 Plant closed. 

a Emissions estimated as chromium compounds unless otherwise indicated.
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Table 2. Summary of Emission Estimate Review for Hard Chromium Electroplating 

NEISiteID Facility Name City State MIR 

Modeled pollutant 

NEI 

emissions, 

(lbs/yr) 

Revised 

emissions 

(lbs/yr)a Comments 

NEIMIN6362 ARMORCLAD INC FARMINGTN 

HLS 

MI 20 Hexavalent 

chromium 

45.0 No basis for changing 

emissions are likely to 

NEIIL0317128 CHROMIUM 

INDUSTRIES INC 

CHICAGO IL 80 Hexavalent 

chromium 

29.2 3.80 

NEI2OH008143 DIAMOND HARD 

CHROME, INCORPORATED 

CLEVELAND OH 100 Chromium 19.4 1.80 

NEIIL0317425 DOVER INDUSTRIAL 

CHROME 

CHICAGO IL 90 Hexavalent 

chromium 

20.7 4.76 

NEIIL0317476 ECONOMY PLATING 

INC 

CHICAGO IL 200 Hexavalent 

chromium 

40.7 4.24 

NEIIL03161 EMPIRE HARD 

CHROME 

CHICAGO IL 900 Hexavalent 

chromium 

395 31.2 

NEIKY936 GENERAL ELECTRIC 

CO 

MADISONVILLE KY 600 Hexavalent 

chromium 

502 0.0 No emissions; plant do

chromium electroplatin

NEIIL0310GBT GRAVURE PROCESS 

CO 

CHICAGO IL 20 Hexavalent 

chromium 

3.77 0.260 

NEIKS1030001 HALLMARK CARDS, 

INC. (SELECT PRODUCTS) 

LEAVENWORTH KS 200 Chromium 395 0.894 

NEINJNJ34427 INDUSTRIAL HARD 

CHROMIUM CO. 

NEWARK NJ 90 Chromium 11.9 No basis for changing 

emissions are likely to 

NEI2OH001715 MASTER CHROME 

SERVICE 

CLEVELAND OH 30 Chromium 2.02 No data on facility, bu

be reasonable. 

NEI52502 QUEBECOR PRINTING MT. MORRIS IL 20 Hexavalent 

chromium 

21.5 No basis for changing 

emissions are likely to revised estimate to Ha

NEIWI1220499 SCOT INDUSTRIES MUSCODA WI 20 Hexavalent 

chromium 

8.71 0.240 

a Emissions estimated as chromium compounds unless otherwise indicated.
Attachment 1. 

Detailed Summary of Emission Estimate Review 
 

1

NEISiteID: NEISC0671254 

Facility Name: AVM Inc. 

Address: P.O. Box 729 

 Marion, SC 29571 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.65 tpy (1,300 lbs/yr) 

MIR: Not determined 

Summary of Analysis: 

The initial risk results indicated a hazard index of 7, but no cancer risk because the pollutant was 

listed in the NEI as chromium trioxide. Since the process is decorative chromium electroplating, 

the pollutant should be reported as either chromium compounds or hexavalent chromium. Based 

on an emission estimate obtained from the South Carolina Department of Environmental Control 

(SC DEHC), the potential annual emissions of chromium compounds from the facility's 

chromium electroplating operations are estimated to be 0.00088 tpy (1.76 lbs/yr). 

Recommendation: 

Use SC DEHC estimate of 0.00088 tpy (1.76 lbs/yr). 

References: 

1. South Carolina Department of Environmental Control. 2006. Engineering Calculation Sheet 

(Statement of Basis), AVM Industries, Permit No. 1660-0220-CD. Bureau of Air Quality, 

Engineering Services Division. April 6. 
 

2

NEISiteID: NEI49228 

Facility Name: Berteau-Lowell Plating Works 

Address: 2318 W. Fullerton Avenue 

 Chicago, IL 60647 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.0318 tpy (63.6 lbs/yr) 

MIR: 300 per million 

Summary of Analysis: 

Emissions reported to NEI are based on Illinois EPA estimated emissions for 2005. In their 2005 

Emission Inventory Report, the facility reported emissions of chromium compounds to be 

0.000294 tpy (0.588 lbs/yr). According to the permit and other information provided by the 

Illinois EPA, the plant operates one "small" decorative chromium electroplating tank. Based on 

data provided in the facility's permit application, which indicates that the plant operates two 

decorative chromium electroplating tanks, RTI estimated actual emissions for two tanks to be 

0.0000858 tpy (0.172 lbs/yr). 

Recommendation: 

Use facility estimate of 0.000294 tpy (0.588 lbs/yr). 

References: 

1. Illinois Environmental Protection Agency. 2005. DAPC Annual Emission Inventory Report 

- 2005, Berteau-Lowell Plating Works, Inc., Facility ID No. 031600EDI. Division of Air 

Pollution Control. December 13. 

2. Illinois Environmental Protection Agency. 2004. Federally Enforceable State Operation 

Permit – NESHAP Source, Berteau-Lowell Plating Works, Inc., Facility ID No. 031600EDI. 

Division of Air Pollution Control. September 28. 

3. Berteau-Lowell Plating Works. (undated). Permit Application for Decorative Chrome 

Plating, Berteau-Lowell Plating Works, Inc., 2320 West Fullerton Avenue, Chicago, Illinois. 

Submitted to Illinois Environmental Protection Agency, Division of Air Pollution Control. 

4. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

3

NEISiteID: NEI22524 

Facility Name: Chrome Craft 

Address: 1819 23rd Street 

 Sacramento, CA 95816 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.00588 tpy (11.8 lbs/yr) 

MIR: 100 per million 

Summary of Analysis: 

No information was available for this facility. However, emissions of more than 4.0 lbs/yr year 

for a decorative chromium electroplating plant should be considered unusually high. 

Recommendation: 

Additional plant-specific data should be obtained and evaluated.
 

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NEISiteID: NEI11893 

Facility name: Deco'Plate Manufacturing Company 

Address: 395 DeMille Road 

 Lapeer, MI 48446 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.46 tpy (919 lbs/yr) 

MIR: 300 per million 

Summary of Analysis: 

The permit for the facility specifies an emission limit for hexavalent chromium of 

2.9 micrograms per cubic meter (μg/m3

). Based on an air toxics study submitted to the State 

agency, the exhaust flow rate for the chromium electroplating tank is 13,300 actual cubic feet per 

minute (ACFM). Using this flow rate, and assuming that the electroplating tank was operated 

continuously (8,760 hr/yr), emissions of hexavalent chromium at the emission limit would be 

0.000633 tpy (1.27 lbs/yr). 

Recommendation: 

Use estimate of 0.000633 tpy (1.27 lbs/yr). 

References: 

1. Michigan Department of Environmental Quality. 1999. State of Michigan Renewable 

Operating Permit, Deco'Plate Manufacturing Company, Permit No. 199600451. Air Quality 

Division. June 2. 

2. Horizon Environmental Corporation. 2001. Technical Support Document, Application for a 

Permit to Install Proposed Modification to an Existing Decorative Chromium Plating 

Operation, Lapeer, Michigan, for Dott Industries, Inc. -- Deco Plate Manufacturing, 

395 DeMille Road, Lapeer, MI 48446. January 8. 
 

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NEISiteID: NEICO0129 

Facility name: Denver Metal Finishing 

Address: 3100 East 43rd Avenue 

 Denver, CO 80216 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

Source category: Decorative Chromium Electroplating 

NEI Emissions: 0.0178 tpy (35.6 lbs/yr) 

MIR: 1,000 per million 

Summary of Analysis: 

The plant submitted an ICR response for the Plating and Polishing industry, but the response 

does not include information on their chromium electroplating operation. The Colorado 

Department of Public Health and Environment (CO DPHE) was contacted on July 26, 2007 and 

provided an inspection report and stack test summary for the plant. Based on that information, 

the plant performs both decorative (one tank) and hard chromium electroplating (three tanks). 

Since typical operating hours were not known, RTI estimated emissions assuming continuous 

operation (8,760 hr/yr). Based on this assumption and the stack test data provided, combined 

emissions from all three hard chromium electroplating tanks are 0.000357 tpy (0.714 lbs/yr). 

No test data were available for the decorative chromium electroplating tank. Assuming the tank 

was operated continuously and emitted at the emission limit, annual emissions are estimated to 

be 0.000202 tpy (0.405 lb/yr). Total emissions for all tanks would be 0.000559 tpy (1.12 lbs/yr). 

It should also be noted that the facility has indicated to CO DPHE that they will be closing the 

Denver facility in 2007. 

Recommendation: 

Use the following estimates: 

0.000357 tpy (0.714 lbs/yr) for hard chromium electroplating 

0.000202 tpy (0.405 lb/yr) for decorative chromium electroplating 

0.000559 tpy (1.12 lbs/yr) for total plant emissions. 

References: 

1. Colorado Department of Public Health and Environment. 2006. Air Pollution Control 

Compliance Inspection Summary Sheet, Denver Metal Finishing. July 26. 

2. Facsimile from Joyce, Jackie, Colorado Department of Public Health and Environment, to 

Richard Marinshaw, RTI International. 2007. Stack test summary and APEN determination, 

Denver Metal Finishing. July 26. 
 

6

NEISiteID: NEI11509 

Facility name: Manufacturers Plating Company 

Address: 1859 East 63rd Street 

 Cleveland, OH 44103 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

Source category: Decorative Chromium Electroplating 

NEI Emissions: 0.455 tpy (910 lbs/yr) 

MIR: 6,000 per million 

Summary of Analysis: 

Based on information included in the operating permit and additional information obtained from 

the Cleveland Department of Public Health (DPH), this plant operates two decorative chromium 

electroplating tanks. One tank is controlled with a wetting agent fume suppressant and a 

composite mesh pad (CMP). The exhaust flow rate indicated in the permit application is 

34,000 ACFM, which is unusually high for a single electroplating tank. Based on this flow rate 

and the emission factor from AP-42 for decorative chromium electroplating tanks controlled with 

a wetting agent fume suppressant (the only emission factor in AP-42 for controlled decorative 

chromium electroplating), emissions are estimated to be 0.00109 tpy (2.18 lbs/yr). This value is 

likely to be an overestimate for two reasons: it is based on a concentration for an unrealistically 

high exhaust flow rate; and the emission factor for decorative chromium electroplating tank 

controlled with a wetting agent fume suppressant and a CMP should be lower than the AP-42 

emission factor used. Using a flow rate of 10,500 ACFM, which represents the design flow rate 

this size of tank and provides a more realistic estimate of emissions, emissions from this tank are 

estimated to be 0.000336 tpy (0.672 lbs/yr). 

 

The other chromium electroplating tank at this plant uses a trivalent chromium bath. That tank 

also is controlled with a fume suppressant. The Cleveland DPH has no information on the 

capacity of the rectifier for this tank. Since rectifier capacity is needed for estimating emissions, 

RTI assumed the rectifier capacity for the largest size decorative model electroplating tank 

developed for the Chromium Electroplating NESHAP. Using that value and other data provided 

by Cleveland DPH, emissions were estimated to be 0.000457 tpy (0.913 lbs/yr) of trivalent 

chromium. Because of the assumptions used, this estimate also is likely to be an overestimate of 

actual emissions from this tank. Total emissions of chromium compounds from both tanks are 

estimated to be: 0.000793 tpy (1.59 lbs/yr) of chromium compounds. 

 

Recommendation: 

Use the following estimates: 

0.000336 tpy (0.672 lbs/yr) of hexavalent chromium 

0.000457 tpy (0.913 lbs/yr) of trivalent chromium 

0.000793 tpy (1.59 lbs/yr) of chromium compounds. 
 

7

References: 

1. Ohio Environmental Protection Agency. 1999. Title V Permit, Manufacturers Plating 

Company, Inc., Facility ID:13-18-00-0838. April 8. 

2. Telecon. Dejanivoc, Z., Cleveland Department of Public Health, with R. Marinshaw, RTI 

International. Information on chromium electroplating operations at Manufacturers Plating 

Company, Cleveland, Ohio. August 2. 

3. U.S. Environmental Protection Agency. 1996. Electroplating, Section 12.20 in Compilation 

of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationary Point and 

Area Sources. July. 
 

8

NEISiteID: NEIMIB6660 

Facility name: Norbrook Plating, Inc. 

Address: 11400 Nine Mile Rd. 

 Warren, MI 48089 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

Source category: Decorative Chromium Electroplating 

NEI Emissions: 0.53 tpy (1,060 lbs/yr) 

MIR: 6,000 per million 

Summary of Analysis: 

The only information readily available for this plant is the permit, which does not provide 

adequate information for estimating emissions. Telephone calls were made to the State agency 

and messages left on July 19, 25, and 30, 2007. A request for information was sent by email on 

July 30, 2007. 

Recommendation: 

Pending receipt of additional information from State agency. 

References: 

1. Ohio Environmental Protection Agency. 1999. Title V Permit, Manufacturers Plating 

Company, Inc., Facility ID :13-18-00-0838. April 8. 
 

9

NEISiteID: NEI2OH007477 

Facility name: Quality Plating Company, Incorporated 

Address: 1443 East 40th Street 

 Cleveland, OH 44103 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

Source category: Decorative Chromium Electroplating 

NEI Emissions: 0.0476 tpy (95.2 lbs/yr) 

MIR: 200 per million 

Summary of Analysis: 

Based on information obtained from the Cleveland DPH, this facility operates one decorative 

chromium electroplating tank with a volume of 250 gallons. The capacity of the rectifier was not 

provided. However, based on data from other facilities, the rectifier capacity for a 250-gallon 

decorative chromium electroplating tank is typically no more than 2,000 amps. Assuming the 

rectifier for this tank has a capacity of 3,000 amps, which should result in an overestimate of 

emissions, using the operating hours reported, and assuming tank emissions were at the emission 

limit, annual emissions are estimated to be 0.0000798 tpy (0.160 lbs/yr). 

Recommendation: 

Use estimate of 0.0000798 tpy (0.160 lbs/yr). 

References: 

1. Cleveland Department of Public Health. 2001. Cleveland Local Air Agency Minor Source 

Inspection Report, Quality Plating Co., Inc. February 23. 

2. Ohio Environmental Protection Agency. 1987. Application for a Permit to Operate an Air 

Contaminant Source, Quality Plating Co. Inc. July 4. 

3. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

10

NEISiteID: NEI21339 

Facility name: Standard Nickel Chromium Plating Company, Inc. 

Address: 811-819 East 62nd Street 

 Los Angeles, CA 90001 

Source category: Decorative Chromium Electroplating 

Pollutant: Chromium compounds 

Source category: Decorative Chromium Electroplating 

NEI Emissions: 0.00885 tpy (17.7 lbs/yr) 

MIR: 100 per million 

Summary of Analysis: 

In a letter, dated July 5, 2006 to Dr. Donna Lee Jones, EPA/SPPD, a representative for the 

company stated that the facility stopped all plating operations in 1999. 

Recommendation: 

Eliminate facility from further analysis for the source category. 

References: 

1. Letter from George Dulgarian, Standard Nickel-Chromium Plating Company, to Dr. Donna 

Lee Jones, EPA/SPPD. 2006. Facility stopped all plating operations in 1999. July 5. 
 

11

NEISiteID: NEIIL0317128 

Facility name: Chromium Industries, Inc. 

Address: 4646 West Chicago Avenue 

 Chicago, IL 60651 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.0146 tpy (29.2 lbs/yr) 

MIR: 80 per million 

Summary of Analysis: 

This plant operates nine hard chromium electroplating tanks, all of which are controlled with 

CMPs. Based on data provided in the facility's permit application, RTI estimated chromium 

emissions at the emission limit for typical operating hours to be 0.00327 tpy (6.55 lbs/yr), and 

for emissions at the emission limit for the maximum allowable operating hours to be 0.00467 tpy 

(9.35 lbs/yr). Using the emission factor in AP-42 for CMP control, actual emissions are 

estimated to be 0.00190 tpy (3.80 lbs/yr). 

Recommendation: 

Use estimate of 0.00190 tpy (3.80 lbs/yr). 

References 

1. Illinois Environmental Protection Agency. 1996. Operating Permit NESHAP Source, 

Chromium Industries, Inc., 4645 West Chicago Avenue, Chicago, Illinois. Division of Air 

Pollution Control. May 15. 

2. Chromium Industries. 1994. Application for Smaller Source Permit Program, Chromium 

Industries, Inc., 4645 West Chicago Avenue, Chicago, Illinois. Submitted to Illinois 

Environmental Protection Agency, Division of Air Pollution Control. October 18. 

3. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 

4. U.S. Environmental Protection Agency. 1996. Electroplating, Section 12.20 in Compilation 

of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationary Point and 

Area Sources. July. 
 

12

NEISiteID: NEI2OH008143 

Facility name: Diamond Hard Chrome, Incorporated 

Address: 6110 Grand Avenue 

 Cleveland, OH 44104 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.0097 tpy (19.4 lbs/yr) 

MIR: 100 per million 

Summary of Analysis: 

The NEI data are based on an estimate of emissions calculated by the Cleveland DPH. The 

emissions are based on a mass balance of estimated chromium usage (specifically, a loss of 4%), 

a control efficiency of 98%, and typical operating hours. The plant operates seven hard 

chromium electroplating tanks that are controlled with three separate composite mesh padpacked bed scrubber (CMP-PBS) systems. Tanks 1, 2 and 3 are exhausted to one CMP-PBS; 

Tanks 3, 4, and 5 are exhausted to a second CMP-PBS; and Tank 7 is exhausted to the third 

CMP-PBS. Test reports were obtained for controlled emissions from Tanks 4, 5, and 6 

combined, and for controlled emissions from Tank 7. Using the emission test results, RTI 

estimated actual emissions to be 0.000535 tpy (0.107 lbs/yr) for Tanks 4, 5, and 6; and 

0.000123 tpy (0.246 lbs/yr) for Tank 7. Using data provided in the permit application for the 

plant, RTI estimated emissions at the emission limit for Tanks 1, 2, and 3 combined to be 

0.000725 tpy (1.45 lbs/yr). Summing these up, total actual emissions for the plant are estimated 

to be 0.000900 tpy (1.80 lbs/yr). 

Recommendation: 

Use estimate of 0.000900 tpy (1.80 lbs/yr). 

References 

1. Cleveland Department of Public Health. 2001. Cleveland Local Air Agency Minor Source 

Inspection Report, Diamond Hard Chrome, Inc. April 19. 

2. Envisage Environmental Incorporated. 1998. Source Evaluation Results, No. 2 Chrome 

Scrubber Exhaust, Diamond Hard Chrome Inc., on April 21, 1998. May 6. 

3. Envisage Environmental Incorporated. 1999. Source Evaluation Results, Exhaust Stack of 

No. 3 Scrubber, Diamond Hard Chrome Inc., on November 10, 1999. November 19. 

4. Diamond Hard Chrome, Inc. 1997. Application for a Permit to Install, Diamond Hard 

Chrome, Inc. Submitted to Ohio Environmental Protection Agency. December 18. 
 

13

NEISiteID: NEIIL0317425 

Facility name: Dover Industrial Chrome 

Address: 2929 North Campbell Avenue 

 Chicago, IL 60618-7903 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.0103 tpy (20.7 lbs/yr) 

MIR: 90 per million 

Summary of Analysis: 

Based on data provided in the facility's permit application, RTI estimated chromium compound 

emissions at the emission limit for typical operating hours to be 0.00455 tpy (9.11 lbs/yr) and for 

the maximum allowable operating hours to be 0.0109 (21.9 lbs/yr). Based on emission rates 

determined from the plant's initial performance test and assuming the typical annual operating 

hours reported in the permit application for the facility, actual emissions are estimated to be 

0.00238 tpy (4.76 lbs/yr). 

Recommendation: 

Use estimate of 0.00238 tpy (4.76 lbs/yr). 

References 

1. Illinois Environmental Protection Agency. 2004. Lifetime Operating Permit – Hard Chrome 

Electroplating Operation NESHAP Source, Dover Industrial Chrome, 2929 North Campbell, 

Chicago, Illinois. Division of Air Pollution Control. October 19. 

2. Schrodt, A.G. 1995. Permit Renewal Application. Letter and attachments from Ariel G. 

Schrodt, Dover Industrial Chrome, 2929 North Campbell, Chicago, Illinois. Submitted to 

Illinois Environmental Protection Agency, Division of Air Pollution Control. January 30. 

3. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

14

NEISiteID: NEIIL0317476 

Facility name: Economy Plating, Inc. 

Address: 2350 North Elston Avenue 

 Chicago, IL 60614-2929 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.0203 tpy (40.7 lbs/yr) 

MIR: 200 per million 

Summary of Analysis: 

Based on data provided in the facility's permit application, RTI estimated emissions of chromium 

compounds at the maximum allowable operating hours to be 0.00656 tpy (13.1 lbs/yr). 

Emissions based on typical operating hours could not be estimated because the permit 

application included only the maximum allowable operating hours. Based on emission rates 

determined from the plant's initial performance test and the maximum allowable operating hours, 

actual emissions are estimated to be 0.00212 tpy (4.24 lbs/yr). 

Recommendation: 

Use estimate of 0.00212 tpy (4.24 lbs/yr). 

References 

1. Illinois Environmental Protection Agency. 1998. Operating Permit for Hard Chrome 

Electroplating Operation NESHAP Source, Economy Plating, Inc., 2350 North Elston, 

Chicago, Illinois. Division of Air Pollution Control. March 31. 

2. Economy Plating. 1998. Application for Permit, Economy Plating, Inc., 2350 North Elston, 

Chicago, Illinois. Submitted to Illinois Environmental Protection Agency, Division of Air 

Pollution Control. January 9. 

3. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

15

NEISiteID: NEIIL03161 

Facility name: Empire Hard Chrome 

Address: 1615 Kostner Avenue 

 Chicago, IL 60623 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.198 tpy (395 lbs/yr) 

MIR: 900 per million 

Summary of Analysis: 

Based on data provided in the facility's permit application, RTI estimated emissions of chromium 

compounds at the emission limit for typical operating hours to be 0.0156 tpy (31.2 lbs/yr) and for 

the maximum allowable operating hours to be 0.0198 (39.7 lbs/yr). 

Recommendation: 

Use estimate of 0.0156 tpy (31.2 lbs/yr). 

References 

1. Illinois Environmental Protection Agency. 2003. Lifetime Operating Permit Hard Chrome 

Electroplating Operation – NESHAP Source, Empire Hard Chrome, Inc., 1615 South 

Kostner Avenue, Chicago, Illinois. Division of Air Pollution Control. February 18. 

2. Illinois Environmental Protection Agency. 1996. Operating Permit Hard Chrome 

Electroplating Operation – NESHAP Source, Empire Hard Chrome, Inc., 1615 South 

Kostner Avenue, Chicago, Illinois. Division of Air Pollution Control. March 21. 

3. Empire Hard Chrome. 1995. Application for Permit, Empire Hard Chrome, Inc.,1615 South 

Kostner Avenue, Chicago, Illinois. Submitted to Illinois Environmental Protection Agency, 

Division of Air Pollution Control. December 8. 

4. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

16

NEISiteID: NEIKY936 

Facility name: General Electric Co. 

Address: 3050 Nebo Road 

 Madisonville, KY 42431 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.251 tpy (502 lbs/yr) 

MIR: 600 per million 

Summary of Analysis: 

Based on the response by General Electric Company (GE) to the information collection request 

(ICR) for the Plating and Polishing Area Source Category, the Madisonville facility does not 

perform any chromium electroplating. The only type of electroplating performed at the plant is 

platinum electroplating. 

Recommendation: 

Eliminate facility from further analysis for this source category. 

References 

1. Email and attachments from Meyers, S., General Electric Company, to Dr. Donna Lee Jones, 

EPS/SPPD. 2006. Response to the Information Collection Request for the Plating and 

Polishing Area Source Category for the Madisonville, Auburn, Burlington, Mebane, 

Beaumont, Charleston, Denver, Minden, Schenectady, and Somersworth facilities. August 3. 
 

17

NEISiteID: NEIIL0310GBT 

Facility name: Gravure Process Co. 

Address: 4179 West Belmont Avenue 

 Chicago, IL 60641-4617 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.00189 tpy (3.77 lbs/yr) 

MIR: 20 per million 

Summary of Analysis: 

Based on data provided in the facility's permit application, RTI estimated emissions of chromium 

compounds at the emission limit for typical operating hours to be 0.000790 tpy (1.58 lbs/yr) and 

for the maximum allowable operating hours to be 0.000846 (1.69 lbs/yr). Based on emission 

rates determined from the plant's initial performance test and assuming the typical annual 

operating hours reported in the permit application for the plant, actual emissions are estimated to 

be 0.000130 tpy (0.260 lbs/yr). 

Recommendation: 

Use estimate of 0.000130 tpy (0.260 lbs/yr). 

References 

1. Illinois Environmental Protection Agency. 2002. Lifetime Operating Permit – NESHAP 

Source, Gravure Process Company, 4179 West Belmont Avenue, Chicago, Illinois. Illinois 

EPA, Division of Air Pollution Control. February 13. 

2. Gravure Process Company. 1997. Permit Application Information. Gravure Process 

Company, 4179 West Belmont Avenue, Chicago, Illinois. Submitted to Illinois 

Environmental Protection Agency, Division of Air Pollution Control. April 8. 

3. Memorandum, Marinshaw, R. and S. Burns, RTI International, to P. Mulrine, EPA/SPPD. 

2005. Risk Modeling Input Data for Chicago Chromium Electroplating Plants. 

September 28. 
 

18

NEISiteID: NEIKS103001 

Facility name: Hallmark Cards, Inc. (Select Products Facility) 

Address: 4901 Select Products Drive 

 Leavenworth, KS 66048 

Source category: Hard Chromium Electroplating 

Pollutant: Chromium compounds 

NEI Emissions: 0.197 tpy (395 lbs/yr) 

MIR: 200 per million 

Summary of Analysis: 

The 2005 Emission Inventory Report for this plant reported chromium compound emissions 

from chromium electroplating to be 0.13 tpy (260 lbs/yr), based on uncontrolled emissions of 

0.24 tpy (480 lbs/yr) and an overall control efficiency of 45 percent. The uncontrolled emission 

rate was based on a mass balance of chromium consumed in the electroplating process, but 

details of the calculation were not provided. Based on other information included in the 

Emission Inventory Report and additional information provided by the Kansas Department of 

Health and Environment, RTI estimated annual emissions of chromium compounds at the 

emission limit to be 0.000447 tpy (0.894 lbs/yr). 

Recommendation: 

Use estimate of 0.000447 tpy (0.894 lbs/yr). 

References 

1. Kansas Department of Health and Environment. 2006. 2005 Emissions Inventory and Fee 

Form for Class I Sources. Hallmark Cards, Inc., Source ID No. 1030013. May 17. 

2. Kansas Department of Health and Environment. 2003. Air Emission Source, Class I 

Operating Permit, Hallmark Cards, Inc., Source ID No. 1030013. February 25. 

3. Email from Allen, R., Kansas Department of Health and Environment, to R. Marinshaw, RTI 

International. 2007. Additional information on the chromium electroplating operation at the 

Hallmark Cards facility in Leavenworth, Kansas. August 1. 
 

19

NEISiteID: NEINJNJ34427 

Facility name: Industrial Hard Chromium Co. 

Address: 7 Rome Street 

 Newark, NJ 71019 

Pollutant: Chromium compounds 

Source category: Hard Chromium Electroplating 

NEI Emissions: 0.00595 tpy (11.9 lbs/yr) 

MIR: 90 per million 

Summary of Analysis: 

Based on information provided on the company's website, the plant operates nine hard chromium 

electroplating tanks that range in volume from 185 to 1,250 gallons. Emissions from the tanks 

are controlled with CMPs. Depending on the rectifier capacity and annual operating hours, the 

reported emission rate for the plant (11.9 lbs/yr) is not unreasonable, although actual emissions 

are likely to be lower. 

Recommendation: 

Use estimate of 0.00595 tpy (11.9 lbs/yr). 

References: 

1. Company website: http://www.ihcco.com. Accessed July 26, 2007.
 

20

NEISiteID: NEIOH001715 

Facility name: Master Chrome Service 

Address: 5709 Herman Avenue 

 Cleveland, OH 44102 

Pollutant: Chromium compounds 

Source category: Hard Chromium Electroplating 

NEI Emissions: 0.00101 tpy (2.02 lbs/yr) 

MIR: 30 per million 

Summary of Analysis: 

No information on this plant is on file. However, the emission estimate appears reasonable for a 

hard chromium electroplating facility. 

Recommendation: 

Use estimate of 0.00101 tpy (2.02 lbs/yr). 

References: 

None.
 

21

NEISiteID: NEI52502 

Facility name: Quebecor Printing 

Address: 404 N. Wesley Avenue 

 Mt. Morris, IL 61054 

Pollutant: Chromium compounds 

Source category: Hard Chromium Electroplating 

NEI Emissions: 0.0107 tpy (21.5 lbs/yr) 

MIR: 20 per million 

Summary of Analysis: 

No additional data was available, and none was obtained for this facility. However, the reported 

emissions are likely to be overestimates. For comparison purposes, the estimated emissions from 

chromium electroplating at the Hallmark Cards facility, another printing facility with a captive 

electroplating operation, are 0.00047 tpy (0.894 lbs/yr). 

Recommendation: 

Additional plant-specific data should be obtained and evaluated. 

References: 

1. Illinois Environmental Protection Agency. 2003. Title V Clean Air Act Permit and Title I 

Permit., Quebecor World, Mt, Morris, II, Inc. Division of Air Pollution Control. 

November 17. 
 

22

NEISiteID: NEIWI220499 

Facility name: Scot Industries 

Address: 810 East Nebraska Street 

 Muscoda, WI 53573 

Pollutant: Chromium compounds 

Source category: Hard Chromium Electroplating 

NEI Emissions: 0.00435 tpy (8.71 lbs/yr) 

MIR: 20 per million 

Summary of Analysis: 

The Analysis, Preliminary Determination, and Draft Permit issued by the Wisconsin Department 

of Natural Resources indicates the total potential to emit for all electroplating tanks is 

0.000120 tpy (0.240 lbs/yr) of total chromium and 0.000035 tpy (0.0700 lbs/yr) of hexavalent 

chromium. RTI estimated worst case emissions, assuming all tanks emitted at the emission limit 

and operated continuously (8,760 hrs/yr) to be 0.0150 tpy (30.0 lbs/yr). 

Recommendation: 

Use estimate of 0.000120 tpy (0.240 lbs/yr). 

References: 

1. Wisconsin Department of Natural Resources. 2005. Analysis, Preliminary Determination, 

and Draft Permit for the Renewal of Operation Permit Number 122049950-P02 for Scot 

Industries, Inc., Located at 810 Nebraska, Muscoda, Grant County, Wisconsin, on the 

Operations of Existing Chromium Plating, Honing, and Metal Cleaning. December 21.