### Table 1: An nual Respondent Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks

(40 CFR part 63, subpart N) (Renew al) 0.869565 $30.60 $55.67 $27.97 (A) Respondent Hours per Occurrence (Technical hours) (B)

Number of Occurences per Respondent per Year

(C) Hours per Respondent per Year (C=A x B) (D)

Number of Respondents per Yeara (E)

Technical Hours per Year @ $30.60 (E=C x D) (F)

Management Hours per Year @ $55.67 (F= E x 0.05) (G)

Clerical Hours per Year @ $27.97 (G= E x 0.1) Total

Labor Costs per Year b

1. APPLICATIONS N/A N/A N/A N/A N/A N/A N/A N/A 2. SURVEY AND STUDIES N/A N/A N/A N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A N/A N/A N/A 4. REPORTING REQUIREMENTS A. Read Instructions 1.00 1.00 1.00 0.00 0.00 0.00 0.00 $0.00 B. Required Activities
Monitoring of operations equipment d C. Create Information D. Gather Existing Information N/A E. W rite Report a,e Notification of compliance status 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of actual startup 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of construction / reconstruction 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of performance test 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Performance test report 4.00 1.00 4.00 0.00 0.00 0.00 0.00 $0.00 Operation and maintenance plan 10.00 1.00 10.00 0.00 0.00 0.00 0.00 $0.00 Annual compliance status reports for area sources f 4.00 1.00 4.00 1,357.00 5,428.00 271.40 542.80 $196,387.75 Semiannual reports of exceedances for area sources f, g 8.00 2.00 16.00 339.00 5,424.00 271.20 542.40 $196,243.03 Semiannual compliance status reports for major sources h 8.00 2.00 16.00 0.00 0.00 0.00 0.00 $0.00 Quarterly compliance status reports for major sources g,h 8.00 2.00 16.00 0.00 0.00 0.00 0.00 $0.00 Request to reduce report frequency g 2.00 1.00 2.00 170.00 340.00 17.00 34.00 $12,301.37 11192.00 559.60 1,119.20 $404,932.16 TOTAL REPORTING BURDEN 12,870.8 Hours $404,932 5. RECORDKEEPING REQUIREMENTS A. Read Instructions B. Plan Activities C. Implement Activities D. Develop Record System 40 1 40.00 0.00 0.00 0.00 0.00 $0.00 E. Time to Enter and Transmit Information

0.50 250.00 125.00 793.00 99,125.00 4,956.25 9,912.50 $3,586,392.06 0.25 1,000.00 250.00 73.40 18,350.00 917.50 1,835.00 $663,912.18 0.25 100.00 25.00 660.60 16,515.00 825.75 1,651.50 $597,520.96 0.25 4,000.00 1,000.00 0.00 0.00 0.00 0.00 $0.00 0.25 500.00 125.00 0.00 0.00 0.00 0.00 $0.00

1.00 4.00 4.00 793.00 3172.00 158.60 317.20 $114,764.55

0.50 12.00 6.00 74.00 444.00 22.20 44.40 $16,064.14 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 137,606 6,880 13,761 TOTAL RECORDKEEPING BURDEN 158,246.9 Hours $4,978,654

TOTAL ANNUAL BURDEN 171,118 Hours $5,383,586 Records of monitoring: 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS

------------------------Included in 4E--------------------------- ------------------------Included in 5E---------------------------

------------------------Included in 4B and 5E----------------------------

- Composite mesh pad/packed scrubber i

Records of operations: m - Operation and maintenance - Cumulative rectifier capacity ------------------------Included in 4E----------------------------

------------------------Included in 4E---------------------------- - Excess emissions

Total Reporting Hours by Labor Category - Records of trivalent chromium bath purchases n F. Time to train personnel G. Time for Audits - W etting agents (normal schedule) j,k - W etting agents (reduced frequency schedule) j,k - Foam Blankets (normal schedule) l - Foam Blankets (reduced frequency schedule) l REPORTING/RECORDKEEPING REQUIREMENT

Performance test c

------------------------Included in 4B and 5E----------------------------

------------------------Included in 4B---------------------------- ------------------------Included in 4B---------------------------- ------------------------Included in 4A---------------------------- Total Reporting Hours by Labor CategoryAssumptions:

f All sources, except decorative chromium electroplating plants using trivalent chromium bath (1,770 - 74 = 1,696), are required to submit compliance status reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report. However, we have assumed that 80 percent of the sources (0.80 x 1,696 = 1,357) will have no excess emissions and 20 percent of the sources (0.20 x 1,696 = 339) will have excess emissions.
gIf excess emissions occur at the plant, sources are required to submit these reports on a more frequent basis (i.e., semiannually for area sources and quarterly for major sources) until the regulatory agency has approved the source request to reduce frequency

of ongoing compliance status reports. We have further assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 339 = 170) will request the regulatory agency to approve a reduction in frequency

for ongoing compliance status reports (i.e., annual reporting).
h We have assumed that all sources are area sources.
iWe have assumed that the monitoring required for composite mesh pad/packed bed scrubbers occurs once per day , 5 five days a week, 50 weeks per year for all plants with add-on control devices. The number of facilities with add-on control devices is estimated to be 793 based on the assumption that 84 percent of hard chromium electroplating facilities (84% of 790 = 663.6), 13 percent of the decorative chromium electroplating that use hexavalent chromium bath (13% of 666 = 86.6) and 18 percent of chromium anodizing facilities (18% of 240 = 43.2) will use add-on control devices.

n We have assumed that 10 percent of the decorative chromium electroplating plants (10% of 740 = 74) use trivalent chromium baths. jWe have assumed that 85 percent of decorative chromium electroplating plants that use hexavalent chromium bath (85% of 666 = 566) and 70 percent of chromium anodizing plants (70% of 240 = 168) will use wetting agents for a total of 734 sources.
k We have assumed that area sources using wetting agents will be required to monitor once every four hours and at least twice per shift, five days a week, 50 weeks per year per operating schedule if the source is on a regular monitoring schedule. If the source is on a reduced monitoring schedule, it will be required to monitor once every 40 hours for 16-hour day, five days a week, 50 weeks per year per operating schedule. We have assumed that 90 percent of the sources (90% of 734 = 660.6) will be on a normal schedule and 10 percent of the sources (10% of 734 = 73.4) are on a reduced schedule. lWe have assumed that sources will not elect to use foam blankets because the rule requires them to do compliance testing. If sources elect to use foam blankets, the reduced monitoring schedule will required them to monitor once every 8 hours, per 16-hour day, five days a week, 50 weeks per year per operating schedule. If the source is on a normal monitoring schedule it will be required to monitor once every hour, per 16-hour day, five days a week, 50 weeks per year per operating schedule.

m We have assumed that all facilities with add-on control devices (793) would be required to have an approved Operation and Maintenance Plan for their operations. d Sources are required to follow work practice standards at composite-mesh-pad (CMP) systems, packed-bed scrubbers (PBS), PBS/CMP systems, fiber-bed mist eliminators, and other air pollution control devices not listed in the rule, as well as monitoring operational parameters (i.e., pressure drop for composite mesh pad systems and fiber bed mist eliminators; pressure drop and velocity pressure for packed bed scrubbers, surface tension for wetting agents, or the appropriate parameter for an alternative control option) and monitoring equipment. cSources are required to conduct performance tests using Methods 306 or 306A of Appendix A, or the California Air Resources Board (CARB) Method 425, as an alternative, Method 306B, and alternate methods if the method has been validated using Method 301 of Appendix A. a There are an estimated total of 1,770 chromium electroplating and anodizing operations nationwide. Of this total, approximately 790 are hard chromium electroplating operations, 740 are decorative chromium electroplating operations, and 240 are chromium anodizing operations. No net growth is predicted for this industry. It is expected that new tanks will only be added to replace or expand existing capacity. The ongoing monitoring, reporting, and recordkeeping for new tanks is the same as that for existing tanks.

eWe have assumed that all existing sources are in compliance with the initial rule requirements. bThis ICR uses the following labor rates: $55.67 per hour for Executive, Administrative, and Managerial labor; $30.60 per hour for Technical labor, and $48.53 per hour for Clerical labor. These rates are the United States Department of La bor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rate has been increased by 110 percent to account for the benefit packages available to those employ ed by private industry

.Table 2: Annual Agency Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and

Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal) 0.869565 $46.22 $62.27 $25.01 (A) EPA Hours per Occurence (Technical hours) (B)

Number of Occurences per Plant per Year (C)

EPA Hours per Year (C=A x B) (D)

Plants per Year a (E)

Technical Hours per Year @ $46.22 (E=C x D) (F)

Management Hours per Year @ $62.27 (F= E x 0.05) (G)

Clerical Hours per Year @ $25.01 (G= E x 0.1)

Costs per Year b

Notification of Compliance Status c 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of Actual Startup 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of construction/ reconstruction 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Operation and maintenance plan d 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Notification of Performance Test a 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Reports of Performance Test results a 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 2.00 1.00 2.00 1,357.00 2,714.00 135.70 271.40 $140,676.12 2.00 2.00 4.00 339.00 1,356.00 67.80 135.60 $70,286.23 Semiannual compliance status reports for major sources g 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Quarterly compliance status reports for major sources 2.00 1.00 2.00 0.00 0.00 0.00 0.00 $0.00 Request to reduce report frequency f 2.00 1.00 2.00 170.00 340.00 17.00 34.00 $17,623.39 TOTAL ANNUAL HOURS 4,410.00 220.50 441.00

TOTAL ANNUAL BURDEN 5,072 Hours $228,586
Assumptions: REPORTING/RECORDKEEPING REQUIREMENT

Semiannual reports of exceedances for area sources e, f Annual compliance status reports for area sources e

aThere are an estimated total of 1,770 chromium electroplating and anodizing operations nationwide. Of this total, approximately 790 are hard chromium electroplating operations, 740 are decorative chromium electroplating operations, and 240 are chromium anodizing operations. No net growth is predicted for this industry. It is expected that new tanks will only be added to replace or expand existing capacity. The ongoing monitoring, reporting, and recordkeeping for new tanks is the same as that for existing tanks.

f If excess emissions occur at the plant, sources are required to submit these reports on a more frequent basis (i.e., semiannually for area sources and quarterly for major sources) until the regulatory agency has approves the source request to reduce frequency of ongoing compliance status reports. We have further assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 339 = 170) will request the regulatory agency to approve a reduction in frequency for ongoing compliance status reports (i.e., annual reporting).

g We have assum

ed that all sources are area sources. bThis cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.22 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) "2009 General Schedule" which excludes locality rates of pay.

cAssumes that all existing sources are in compliance with the initial rule requirements.

d There will be no periodic burden for the regulatory agency associated with this requirement although we have assumed that all facilities with add-on control devices (793) would be required to have an approved Operation and Maintenance Plan for its operations.

eAll sources, except decorative chromium electroplating plants using trivalent chromium bath (1,770 - 74 = 1,696), are required to submit compliance status reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report. However, we have assumed that 80 percent of the sources (0.80 x 1,696 = 1,357) will have no excess emissions and 20 percent of the sources (0.20 x 1,696 = 339) will have excess em issions.