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SUPPORTING STATEMENT 

NATIONAL EMISSION STANDARDS FOR CHROMIUM EMISSIONS FROM HARD 

AND DECORATIVE CHROMIUM ELECTROPLATING AND CHROMIUM 

ANODIZING TANKS 

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection. 

“National Emission Standards for Chromium Emissions from Hard and Decorative 

Chromium Electroplating and Chromium Anodizing Tanks.” This is a new information 

collection request (ICR), and the EPA tracking number is ****. 

 (b) Short Characterization. 

 This ICR covers information collection requirements in the proposed amendments to the 

Chromium Electroplating NESHAP (40 CFR part 63, subpart N). 

 The potential respondents are owners or operators of any existing or new chromium 

electroplating or chromium anodizing tanks. There are an estimated 1,770 facilities subject to 

the Chromium Electroplating NESHAP. Of these, there are an estimated 790 hard chromium 

electroplating facilities, 740 decorative chromium electroplating facilities, and 240 chromium 

anodizing facilities. The affected source is any tank that is used for chromium electroplating or 

chromium anodizing. 

The proposed amendments would prohibit the use of certain types of chemical fume 

suppressants in affected chromium electroplating or anodizing tanks; require additional 

housekeeping procedures to minimize fugitive emissions of chromium compounds; specify 

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

flexibility in testing; and revise the reporting requirements. These amendments are explained 

further in the following paragraphs. 

Many chromium electroplating and anodizing sources comply with the NESHAP through 

the use of chemical fume suppressants to maintain the surface tension in tank baths below certain 

levels. The proposed amendments would prohibit the use of such fume suppressants that contain 
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perfluorooctyl sulfonates (PFOS). The proposed housekeeping procedures would specify 

requirements for storing hexavalent chromium chemicals, installing guards and trays to minimize 

spills of electroplating and anodizing tank solution, prompt cleanup of chromium chemical spills, 

installing barriers between certain types of operations and chromium electroplating and 

anodizing tanks, and disposing of chromium chemical wastes. The proposed amendments would 

require checking stalagmometers used for measuring surface tension, and cleaning the 

instrument, if necessary. The proposed amendments would allow testing by either Method 306 

or Method 306A for multiple sources controlled by a common add-on air pollution control 

device. Finally, the proposed amendments would correct a discrepancy between the NESHAP 

the General Provisions to part 63 by requiring owners or operators of affected sources to submit 

a semiannual report if the duration of excess emissions exceeds 1 percent of source operating 

time or the duration of air pollution control device malfunctions exceeds 5 percent of source 

operating time. For the proposed amendments, the only requirements associated with additional 

reporting and recordkeeping costs are the costs associated with reading the proposed 

amendments, revising Operation and Maintenance Plans, and checking and recalibrating certain 

types of instruments used to measure surface tension. 

The information collection requirements associated with the proposed amendments to the 

NESHAP are listed in Attachment 1. 

2. Need For and Use of the Collection

(a) Need/Authority for the Collection. 

 Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both 

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major 

source is a stationary source that emits or has the potential to emit more than 10 tons per year 

(tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a 

stationary source that is not a major source (i.e., an area source does not emit and does not have 

the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any 

combination of HAP). For major sources, these technology-based standards must reflect the 

maximum degree of emission reductions of HAP achievable (after considering cost, energy 

requirements, and non-air quality health and environmental impacts) and are commonly referred 

to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires 
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EPA to review these technology-based standards and to revise them “as necessary (taking into 

account developments in practices, processes, and control technologies)” no less frequently than 

every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source 

categories subject to certain CAA section 112(d) standards whether the emissions limitations 

provide an ample margin of safety to protect public health. For MACT standards for HAP 

“classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime 

excess cancer risks to the individual most exposed to emissions from a source in the category or 

subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the 

source category (or subcategory) as necessary to provide an ample margin of safety to protect 

public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA 

determines that the existing standards are sufficiently protective. EPA must also adopt more 

stringent standards, if necessary, to prevent an adverse environmental effect, but must consider 

cost, energy, safety, and other relevant factors in doing so. 

 Certain records and reports are necessary for the Administrator to confirm the 

compliance status of sources subject to NESHAP, identify any new or reconstructed sources 

subject to the standards, and confirm that the standards are being achieved on a continuous basis. 

These recordkeeping and reporting requirements are specifically authorized by section 114 of the 

Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The 

recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 

40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 

years following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record. 

 (b) Use/Users of the Data.

 The information will be used by the delegated authority (State agency, or Regional 

Administrator if there is no delegated State agency) to ensure that the standards and other 

requirements are being achieved. Based on review of the recorded information at the site and the 

reported information, the delegated permitting authority can identify facilities that may not be in 

compliance and decide which facilities, records, or processes may need inspection. 

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.
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A computer search of EPA’s ongoing ICRs revealed no duplication of informationgathering efforts. 

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

This section is not applicable because this is a rule-related ICR. 

(c) Consultations. 

The proposed amendments were developed in consultation with individual companies, 

State agencies, and trade associations. The non-EPA persons consulted on the information 

collection activities are identified in Table 1. 

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES 

Contact Organization Telephone No. 

Carla Takemoto California Air Resources Board (916) 324-8028 

Russell Yanagihara San Diego Air Pollution Control District (858) 586-2719 

Eugene Kang South Coast Air Quality Management District (909) 396-3524 

Jeff Hannapel The Policy Group/National Association for Surface 

Finishing 

(202) 457-0630 

Christian Richter The Policy Group/National Association for Surface 

Finishing 

(202) 457-0630 

(d) Effects of Less Frequent Collection.

 If the relevant information were collected less frequently, the delegated permitting 

authority (State or EPA) will not be reasonably assured that a facility is in compliance with the 

standards. 

(e) General Guidelines. 

 None of the guidelines in 5 CFR 1320.6 are being exceeded. 

(f) Confidentiality.

 All 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 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).
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(g) Sensitive Questions. 

 This section is not applicable because this ICR does not involve matters of a sensitive 

nature. 

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart N are owners or operators of any existing or new 

facility engaged in one or more of the following operations: hard chromium electroplating, 

decorative chromium electroplating, and chromium anodizing. Chromium electroplating and 

anodizing facilities are primarily classified under NAICS code 332813. However, chromium 

electroplating and anodizing operations are also collocated at many facilities that are classified 

under other NAICS codes. Examples include NAICS 33251, Hardware Manufacturing; 323111, 

Commercial Gravure Printing; 332116, Metal Stamping; 332722, Bolt, Nut, Screw, Rivet, and 

Washer Manufacturing; 332811, Metal Heat Treating; 332812, Metal Coating, Engraving 

(except Jewelry and Silverware), and Allied Services to Manufacturers; 332913, Plumbing 

Fixture Fitting and Trim Manufacturing; Other Metal Valve and Pipe Fitting Manufacturing; 

332999, All Other Miscellaneous Fabricated Metal Product Manufacturing; and 336412, Aircraft 

Engine and Engine Parts Manufacturing. 

There are an estimated 1,770 facilities that would be subject to the proposed amendments 

to the NESHAP, including about 790 hard chromium electroplating plants, 740 decorative 

chromium electroplating plants, and 240 chromium anodizing plants. No new chromium 

electroplating or anodizing sources are expected during the 3-year period of this ICR. 

 (b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information 

Requirements, summarizes the data items, including recordkeeping and reporting requirements, 

for the Chromium Electroplating Source Category. 

(ii) Respondent Activities. The respondent activities that will be required by the 

proposed amendments to the Chromium Electroplating NESHAP are identified in Table 2 and 

are introduced in section 6(a). 

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

Information Management
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(a) Agency Activities.

 The Agency activities associated with the proposed amendments to the Chromium 

Electroplating NESHAP are provided in Table 3 and are introduced in section 6(c). 

(b) Collection Methodology and Management. 

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

compliance and enforcement programs of the delegated permitting authority. EPA is the 

permitting authority until the State agency is delegated authority to implement the final 

amendments to the rule. Therefore, information contained in any report submitted to the 

Regional Administrator will be entered into the Air Facility System (AFS), which is operated 

and maintained by EPA’s Office of Compliance. AFS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

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

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

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

(c) Small Entity Flexibility.

 The Small Business Administration defines a small entity for the chromium 

electroplating and anodizing industry as a firm having no more than 500 to 1,000 employees 

(depending on the size definition for the affected NAICS code). The proposed amendments 

would not result in any adverse impacts on any small entities in the Chromium Electroplating 

Source Category. The proposed amendments would not create any new requirements or burdens 

for existing sources other than minimal notification requirements, recordkeeping, and reporting 

requirements. 

(d) Collection Schedule. 

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

shown in Table 2 for the Chromium Electroplating Source Category. 

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

 The annual burden estimates for the proposed amendments to the Chromium 

Electroplating NESHAP are shown in Table 2. These numbers were derived from estimates 

based on EPA’s experience with other standards. No burden estimates are provided for new 
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sources because no new facilities are expected to become affected sources during the 3-year 

period of this ICR. 

(b) Estimating Respondent Costs.

 The information collection activities for the proposed amendments to the Chromium 

Electroplating NESHAP are presented in Table 2. Because the data are already collected by 

respondents as part of normal operations, no respondent development costs are associated with 

the information collection activities. 

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of 

Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for 

private industry workers were taken from the United States Department of Labor, Bureau of 

Labor Statistics, Occupational Employment and Wages, May 2009 available at 

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

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

Plastic," with a total compensation of $14.57/hour. Wages for management labor are taken from 

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

compensation of $26.51/hour. Wages for clerical labor are based on "43-9061 Office Clerks, 

General," with a total compensation of $13.32/hour. These rates represent salaries plus fringe 

benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to 

account for these costs. The fully-burdened hourly wage rates used to represent respondent labor 

costs are: technical at $30.60/hour, management at $55.67/hour, and clerical at $27.97/hour. 

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. No capital costs 

are associated with the information collection requirements of the proposed amendments to the 

Chromium Electroplating NESHAP. The proposed amendments would not require affected 

facilities to purchase new monitoring systems or conduct new performance testing. The O&M 

costs associated with the proposed amendments to the Chromium Electroplating NESHAP 

consist of new requirements to check and clean, when necessary, instruments used to measure 

surface tension of the electroplating and anodizing solutions. These costs are estimated to be 

$533,600 per year. 

(iii) Annualizing Capital Costs. No capital costs associated with the information 

collection requirements of the proposed amendments to the Chromium Electroplating NESHAP. 
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(c) Estimating Agency Burden and Cost. 

 Because the information collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the 

part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal 

Government. Publication and distribution of the information are part of the Compliance Data 

System, with the result that no Federal costs can be directly attributed to the ICR. Examination 

of records to be maintained by the respondents will occur incidentally as part of the periodic 

inspection of sources that is part of EPA’s overall compliance and enforcement program, and, 

therefore, is not attributable to the ICR. The only costs that the Federal government will incur 

are user costs associated with the analysis of the reported information, as presented in Table 3. 

 The Agency labor rates are from the Office of Personnel Management (OPM) 2010 

General Schedule, which excludes locality rates of pay. These rates can be obtained from Salary 

Table 2010-GS available on the OPM website, http://www.opm.gov/oca/10tables/pdf/gs_h.pdf. 

The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for 

technical (GS-12, Step 1), and $38.92/hr for management (GS-13, Step 5). These rates were 

increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates 

used to represent Agency labor costs are: clerical at $25.01/hour; technical at $46.21/hour, and 

management at $62.27/hour. 

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

There are an estimated 1,770 existing facilities that are subject to the Chromium 

Electroplating NESHAP. No new sources are expected during the next 3 years. Consequently, 

the average number of chromium electroplating respondents during the 3-year period of this ICR 

is 590. 

For the proposed amendments to the Chromium Electroplating NESHAP, the 

components of the total annual burden attributable to this ICR include reading the amendments 

to the NESHAP and revising the Operation and Maintenance Plan; all other recordkeeping and 

reporting activities are already accounted for in the ICR for the NESHAP. 
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The proposed amendments to subpart N would not require any additional reporting. 

Therefore, the number of annual responses is 0. 

 (e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in 

Table 2 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. The average annual burden 

for the recordkeeping and reporting requirements in the proposed amendments to subpart N for 

the 1,770 existing facilities that are subject to the Chromium Electroplating NESHAP is 

5,428 person-hours, with an annual average cost of $170,772. No capital costs would be 

expected, but operation and maintenance costs would total $553,634 per year. 

(ii) The Agency tally. The average annual Federal Government cost is $14,200 for 

315 hours for the proposed amendments to subpart N. The bottom line Agency burden hours and 

costs presented in Table 3 are calculated by adding person-hours per year down each column for 

technical, managerial, and clerical staff, and by adding down the cost column. 

(iii) Variations in the annual bottom line. This section does not apply since no 

significant variation is anticipated. 

(f) Reasons for Change in Burden.

 This section does not apply because this is a new ICR. 

 (g) Burden Statement 

 The average annual respondent burden for the proposed amendments to the Chromium 

Electroplating NESHAP is estimated at 5,428 hours. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. 
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 An agency may not conduct or sponsor, and a person is not required to respond to a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9. 

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

burden estimates, and any suggestions for minimizing respondent burden, including through the 

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

Docket ID No. EPA-HQ-OAR-2010-0600, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room B-102, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

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

Air Docket is (202) 566-1927. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access 

the index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in one of 

the Docket ID Numbers identified above. Also, you can send comments to the Office of 

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

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

Number (EPA-HQ-OAR-2005-0084) in any correspondence. 

PART B

 This section is not applicable because statistical methods are not used in data collection 

associated with the proposed rule.
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TABLE 2. ANNUAL RESPONDENT BURDEN AND COST--AMENDMENTS TO CHROMIUM ELECTROPLAT

Burden item 

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent

(C) 

Person-hours 

per 

respondent 

(C=A*B) 

(D) 

Respondent

s per year 

(E) 

Technical 

person-hours 

per year 

(E=C*D) 

(F) 

Management 

person-hours 

per year 

 (E*0.05) 

1. Applications N/A 2. Surveys and Studies N/A 3. Acquisition, Installation, and Utilization of Technology  and Systems 

N/A 

4. Reporting Requirements A. Read instructionsb 4 1 4 590 2,360 118 B. Required activities N/A C. Create information N/A D. Gather existing information N/A E. Write report  Revise Operation and Maintenance Planc 4 1 4 590 2,360 118 5. Recordkeeping Requirements dA. Read instructions See 4A B. Plan activities N/A C. Implement activities N/A D. Develop record system N/A E. Time to enter information N/A F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously  applicable requirements 

N/A 

H. Time to transmit or disclose information N/A I. Time for audits N/A TOTAL LABOR BURDEN AND COST (SALARY) 4,720 236 TOTAL NUMBER OF ANNUAL RESPONSESi 0 ANNUAL CAPITAL COSTSeOPERATION & MAINTENANCE COSTSf TOTAL ANNUALIZED COSTS N/A = not applicable. a This ICR uses the following labor rates: $55.67 for managerial labor, $30.60 for technical labor, and $29.97 for clerical labor. These rates are base

Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2009. 

b There are an estimated 1,770 existing facilities; no new facilities are expected; the average number expected to read the rule during the 3-yr clearancc Operation & Maintenance Plan would have to be revised to incorporate proposed housekeeping requirements. d Proposed amendments would not require additional recordkeeping. e There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments. 
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f Consists of labor required to check stalagmometer calibration and clean stalagmometer when needed. 
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 3. ANNUAL BURDEN AND COST TO THE AGENCY----AMENDMENTS TO CHROMIUM ELECTROPLATING NESHA

Burden item 

(A) 

Person-hours 

per occurrence

(B) 

Occurrences 

per respondent

(C) 

EPA personhours/year 

(C=A*B) 

(D) 

Facilities 

per year 

(E) 

Technical personhours/year 

(D=A*B*C) 

(F) 

Management 

person-hours/year 

(E=0.05*D) 

Report Review:  Operation & Maintenance Planb 2 1 2 89 178 8.9  Plant records of fume suppressant usec 2 1 2 48 96 4.8 TOTAL BURDEN AND COST a This ICR uses the following average hourly labor rates: $62.27 for managerial (GS-13, Step 5), $46.21 (GS-12, Step 1) for technical, and $25.01 (G

These rates are from the Office of Personnel Management (OPM) 2010 General Schedule, which excludes locality rates of pay. 

b Assumes Agency will review 5% of revised O&M Plans (1,770 x 0.05 = 89). c Assumes Agency will review records of 5% of the 969 plants that use fume suppressants (969 x 0.05 = 48) to confirm that non-PFOS fume suppress
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ATTACHMENT 1. INFORMATION REQUIREMENTS----AMENDMENTS TO CHROMIUM ELECTROPLATING NESH

Requirement Citation for existing sources Citation for new sources General P

Monitoring § 63.343(c)(5) § 63.343(c)(5) N/A Notifications N/A N/A N/A Plans  Operation and Maintenance Plan § 63.342(f)(3) § 63.342(f)(3) N/A Records  Monitoring/inspection information § 63.346(b) § 63.346(b) 40 CFR 63.10 Reports N/A N/A N/A