Date: January 24, 2012

Subject: Procedures for Determining Control Costs and Cost Effectiveness for Chromium 

Electroplating Supplemental Proposal

Contract No. EP-D-11-084; EPA Work Assignment No. 0-07

RTI Project No. 0213199.000.007

From: Richard Marinshaw

Cindy Hancy

To: Phil Mulrine, EPA/OAQPS/SPPD/MMG

Introduction

The purpose of this memorandum is to present the steps used to determine the baseline 

emissions, emission control costs, and cost effectiveness for the regulatory options included in the 

January 2012 Supplemental Proposal. The results of the cost analysis are also presented.

Procedures for Determining Control Costs and Cost Effectiveness for Chromium Electroplating 

Supplemental Proposal

1. Compile Emissions Data

The first steps in the analysis focused on current emissions levels in the industry. The available 

chromium emissions concentration data were compiled in units of milligrams per dry standard cubic 

meter (mg/dscm), which is the format of the emission limits in the Chromium Electroplating NESHAP. 

Data compiled included the plant name and location, process type, emission control method, and 

emissions concentration.

There are an estimated 1,454 chromium electroplating plants in the U.S. Of these, about 338 are 

located in California and 1,116 are located outside the State of California. Throughout the analysis, a 

distinction was made between the plants located in California and plants located elsewhere (i.e., the nonCalifornia plants). Chromium electroplating plants in California are subject to emission limits that are 

production-based rather than concentration-based and, for most facilities, are more stringent than the 

emission limits under the Chromium Electroplating NESHAP. As a result, emissions for California 

plants are not representative of emissions for non-California plants. Since the proposed amendments 

would impact facilities located outside of California, the data on California plants were not included in 

the analysis described below, and any reference to plants nationwide presumes that the plants in question 

are the non-California plants.
2

2. Group Emissions Data by Process

The data were grouped by process and current emissions limit, as shown in Table 1. Tables 2 

through 5 summarize the data on emissions concentrations for each process type. It should be noted that 

these data sets include all the available data on emissions concentration. These data sets are not the 

same data sets on annual emissions that were used to simulate and estimate actual emissions for the 

residual risk assessment. The reason is that, for annual emissions, data on flow rate and annual operating 

hours are used in addition to concentration data to convert emissions concentrations to annual emission 

rates (e.g., in units of pounds per year [lbs/yr]), and data on flow rate and annual hours were not 

necessarily available for all of the sources listed in Tables 2 through 5. On the other hand, data are 

available on annual emissions (in units of lbs/yr) for a number of other facilities for which concentration 

data are not available. In summary, for many plants data are available on both concentration and mass 

rate (lbs/yr), but for a number of other plants data are available only for one or the other of these two 

formats. So, the two data sets do not have all the same plants. 

3. Determine Percentage of Plants That Would Not Meet Proposed Emission Limits

The data listed in Tables 2 through 5 were assumed to represent the population of each type of 

non-California plant nationwide. For example, the 75 data points for hard chromium electroplating were 

assumed to represent the hard chromium electroplating industry outside of plants in California. 

The proposed emission limits were compared to the ranked emission data to determine the 

number or percentage of existing plants that would already meet the proposed emission limit. To allow 

for an additional compliance margin, a value of 85 percent of the proposed limit was used as the cutoff 

for sources that would or would not need to reduce emissions to comfortably meet the proposed 

emission limit. For example, for large hard chromium electroplating, 85 percent of the proposed limit of 

0.011 mg/dscm would be 0.0094 mg/dscm. Therefore, we assumed that any plant with emissions less 

than 0.0094 mg/dscm would comfortably meet the proposed limit and therefore would not need to 

reduce emissions. Based on the data in Table 2, 13 of the 75 sources (i.e., about 17.3 percent) outside of 

California would need to install additional controls or add wetting agent fume suppressant (WAFS) to 

meet 85 percent of the proposed emission limit for large hard chromium electroplating. There are an 

estimated 219 large hard chromium electroplating plants nationwide (outside of California). Of these, 

an estimated 4 plants use only WAFS to control emissions, and the other 215 plants use add-on control 

devices. Since the surface tension data analysis (described elsewhere) indicates that plants that use 

WAFS would readily meet the proposed limit of 0.011 mg/dscm, those plants were excluded from the 

determination of the number of plants that would have to install additional controls. Applying this 

methodology to large hard chromium electroplating plants results in 37 plants that would have to install 

additional controls or add WAFS (215 × 0.173 = 37 plants). 

4. Determine Controls Needed for Each Type of Plant

Of the plants that would need to reduce emissions, it was assumed that 90 percent could meet the 

proposed emission limit using WAFS, and the remaining 10 percent would have to install add-on 

controls. The data on emissions and controls indicate that many plants use a combination of add-on 

control devices and WAFS to ensure compliance with the emissions limit. In these cases, the add-on 

control device is the primary control technology, with WAFS used to further lower emissions. In most 
3

cases, facilities that would not meet the proposed emissions limits would need only small reductions in 

emissions to meet the proposed limits. Therefore, we concluded that nearly all of such plants could 

simply add WAFS to the electroplating tanks to comply. However, during discussions with industry 

representatives, they indicated that using WAFS may not be practical in some cases, due to customer 

specifications. Therefore, it is reasonable to assume that 90 percent of such plants could use WAFS to 

comply with the proposed emissions limits. It was further assumed that half of these plants could meet 

the proposed limit by installing a composite mesh pad (CMP), and the other half would have to install 

high efficiency particulate air (HEPA) filters. The data indicate that retrofitting CMPs should be 

adequate for meeting the proposed emission limits. However, there are cases where HEPA filters may 

be needed or preferred by the facility to ensure there is an adequate margin of compliance. 

Continuing with the above example, of the 37 plants that would need to reduce emissions, 33 of 

these plants would meet the proposed emission limit using WAFS, 2 plants would retrofit CMPs, and 

2 plants would retrofit HEPA filters (33 + 2 + 2 = 37 plants).

This same methodology was applied to the data sets for new and existing small hard chromium 

electroplating plants. For decorative chromium electroplating and chromium anodizing, the same 

methodology was used except it was assumed that all plants that currently use add-on controls to meet 

the current emission limit would be able to meet the proposed emission limit using WAFS, as indicated 

by the available data.

Table 6 shows the resulting number of plants that would need to install additional controls, or 

add WAFS, and the control method used for the cost analysis.

5. Determine Control Costs

To estimate the cost for retrofitting CMPs and retrofitting HEPA filters, the same basic 

methodology was used that was used to estimate control costs for the October 2010 proposal (see 

References 1 and 2). The basic steps consisted of the following:

• The cost quotes obtained from CMP and HEPA filter vendors in 2010 were used.

• To reflect 2011 costs, the quotes were scaled using cost indices from Chemical Engineering.

• To account for retrofit costs, it was assumed that the additional costs associated with retrofitting

a control on an existing system was equal to 30 percent of the equipment costs, based on the

EPA Air Pollution Control Cost Manual (Reference 3). 

• Operation and maintenance labor was estimated to be 100 to 110 hours per year per source,

depending on the size of the system.

• Electricity costs were estimated assuming that operating the retrofit system would require an 

additional 50 percent beyond the current electricity usage for the existing controls.

• Annualized capital costs were calculated assuming a 15 year life and 7 percent interest rate.

• Other factors for taxes, freight, etc. were taken from the EPA Air Pollution Control Cost Manual 

(Reference 3).

• The capital and annual costs were summed up and a regression equation was developed for each; 

the regression equation estimates annualized (or capital) costs as a function of exhaust flow rate.

To determine typical flow rates for each type of plant, the available data were compiled on each 
4

process, and the average flow rate for each was determined. 

To determine the costs of using WAFS, the same cost factors were used that were used for the 

2010 proposal (Reference 4). These factors estimate costs as a function of tank volume and energy input 

(ampere hours per year). To determine typical tank volumes and energy input values, the available data 

were compiled on each process, and the average values were determined. The cost factors were also 

updated from 2010 dollars to 2011 dollars using indices from Chemical Engineering (Reference 5).

Finally, the resulting cost per plant was increased by 15 percent to reflect the estimated additional costs 

for using WAFS that do not contain perfluorooctyl sulfonates (PFOS), also referred to as non-PFOS 

WAFS. Although the costs for non-PFOS WAFS are comparable to the costs of PFOS-based WAFS, 

non-PFOS WAFS are depleted more quickly in the electroplating bath. For plants, that regularly 

electroplate, the depletion of non-PFOS WAFS is negated by drag-out.1 However, for plants that do not 

electroplate regularly (i.e., do not electroplate daily for several hours per day), the depletion rate can be 

up to 20 percent. Estimating increased WAFS costs of 15 percent across the board for all electroplating 

plants that use WAFS provides estimated costs for non-PFOS WAFS that are conservatively high. 

Reference 5 provides additional details on the use and costs of non-PFOS WAFS. 

Table 7 summarizes typical plant costs for retrofitting CMPs, retrofitting HEPA filters, and using 

WAFS to meet the proposed emission limits.

6. Determine Testing Costs

Testing costs were estimated using the same generic spreadsheet developed by RTI for 

estimating testing costs for any facility based on the number of sources, number of test runs, test run 

duration, and laboratory costs. Table 8 shows an example of the output for testing a chromium 

electroplating plant with two stacks. Based on data compiled for the industry, the number of stacks that 

would need to be tested was estimated for each type of chromium electroplating process. Using the 

output from the testing cost spreadsheet referenced above, the testing costs for a typical chromium 

electroplating plant was estimated. 

The proposed rule would include a provision that allows plants to use any previous test that was 

done since January 1995 to demonstrate compliance as long as that test is representative of current 

controls and current operations and the test results would meet the proposed lower limits, as approved 

by the permitting authority. For each of the source categories and subcategories (i.e., large hard chrome, 

small hard chrome, decorative and anodizing) we estimated the number of facilities that would qualify 

for this provision and therefore not need to conduct a new test. It was assumed that the remainder would 

be required to conduct an emission test. Table 9 provides a summary of the calculations, estimates and 

resulting testing costs by process type.

7. Determine Baseline Emissions and Emissions Reductions

To determine baseline emissions, the data on actual emissions was combined with simulated 

actual emissions for those plants for which actual emissions data were not available. To simulate actual 

emissions, a Monte Carlo procedure was applied to the available data on emissions concentration, 

 1 Drag-out refers to electroplating solution that remains on the electroplated items when they are removed from the 

electroplating bath and is lost when the items are placed in a rinse tank. 
5

exhaust flow rate, and annual operating hours for each process type. A total of 5,000 simulations were 

performed for each facility, and the average of those simulated emissions was used as the actual 

emissions value for a specific facility. A detailed description of the data used and the analyses 

performed to simulate emissions is provided in Reference 6. Table 10 shows the resulting baseline 

emissions by process type.

To determine emissions reductions, the following assumptions were made:

• It was assumed that any plant that did not meet the proposed emission limit would be emitting at 

a level that, on average, was equal to the 80th percentile of the actual emissions rate.

• To this 80th percentile emissions level, it was assumed that the plants currently achieve a control 

efficiency of 99 percent.

• For plants that were expected to retrofit a CMP, the control efficiency of the retrofitted system 

was assumed to be 99.7 percent based on data reported by the California Air Resources Board 

(CARB).

• For plants that were expected to retrofit a HEPA filter, the control efficiency of the retrofitted 

system was assumed to be 99.97 percent based on the standard design criteria for HEPA filters.

• For plants that currently use WAFS to control emissions and would be subject to the proposed 

surface tension limit, it was assumed those plants would have emissions concentrations equal to 

0.0055 mg/dscm, based on the analysis of surface tension data (documentation provided 

separately in Reference 7).

Table 11 provides a summary of the resulting estimated emissions reductions.

8. Determine Cost Effectiveness

The number of nationwide sources that would be required to install a particular type of control 

(CMP, HEPA, and WAFS) was multiplied by the annualized costs for that control to determine 

nationwide costs. Testing costs were added to these annualized costs. For existing facilities that 

currently use WAFS, it was assumed that an additional 15 percent of WAFS would be required to meet 

the proposed surface tension limits. Cost effectiveness was calculated by dividing the estimated 

emissions reductions for each electroplating category by the sum of annualized nationwide cost for 

testing, retrofitting CMPs or HEPA filters, and/or using WAFS for the corresponding electroplating 

category. Table 11 summarizes the cost effectiveness. Table 12 provides an overall summary of the 

number of affected plants, costs, emissions reductions, and cost-effectiveness for the proposed options.

Additional details regarding the methodology applied to calculate these estimates are provided in 

Appendix A. 

9. Additional Options Analyzed

Additional regulatory options, in terms of more stringent emissions limits, also were analyzed for 

hard chromium electroplating facilities. The impacts and cost effectiveness of these options are 

summarized in Table 13.

References:
6

1. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Emissions Reductions and Cost Effectiveness of Composite Mesh Pads for 

Chromium Electroplating Emission Standards Technical Support and Post Promulgation 

Activities. September 7, 2010. EPA-HQ-OAR-2010-0600-0011

2. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Emissions Reductions and Cost Effectiveness of HEPA Filter Retrofits for 

Chromium Electroplating Emission Standards Technical Support and Post Promulgation 

Activities. September 8, 2010. EPA-HQ-OAR-2010-0600-0013

3. U.S. EPA. EPA Air Pollution Control Cost Manual, EPA/ 452/B-02-001. U.S. Environmental 

Protection Agency, Research Triangle Park, NC 2002. 

4. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Nationwide Costs for Conversion to Non-PFOS Fume Suppressants 

Emission Standards Technical Support and Post Promulgation Activities. August 16, 2010. EPAHQ-OAR-2010-0600-0016.

5. Chemical Engineering Plant Cost Index (CEPCI). Chemical Engineering Magazine. May 2011. 

6. Memorandum from B. Munoz, R. Marinshaw, and G. Raymond, RTI International, to P. 

Mulrine, U.S. Environmental Protection Agency. Simulation of Actual and Allowable 

Emissions for Chromium Electroplating Facilities. January 4, 2012.

7. Memorandum from B. Munoz, R. Marinshaw, and G. Raymond RTI International, to P. 

Mulrine, U.S. Environmental Protection Agency. Development of Revised Surface Tension 

Limits for Chromium Electroplating and Anodizing Tanks Controlled with Wetting Agent Fume 

Suppressants. December 22, 2011.
7

Table 1. Emission Data Groupings for Control Cost Analysis

Process Type Emission Limit (EL) No. of Data Points

Large hard chromium electroplating 0.015 mg/dscm 75

New small hard chromium electroplating 0.015 mg/dscm 38

Existing small hard chromium electroplating 0.030 mg/dscm 35

Decorative chromium electroplating 0.010 mg/dscm 14

Chromium anodizing 0.010 mg/dscm 1
8

Table 2. Summary of Actual Emission Concentration Data -- Large Hard Chromium Electroplating

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.000016 0.015 0.0010

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.00011 0.015 0.0073

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00012 0.015 0.0080

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00014 0.015 0.0091

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00014 0.015 0.0095

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00018 0.015 0.012

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.00027 0.015 0.018

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.00034 0.015 0.023

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.00062 0.015 0.041

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.00074 0.015 0.049

Delphi Chassis Systems –

Needmore

1435 Cincinnati Street Dayton OH CMP 0.00085 0.015 0.057

Quality Plating Company 420 S 500 W Salt Lake City UT MPME/HEPA 0.0011 0.015 0.071

McDowell Enterprises-North 2010 Superior Street Elkhart IN CMP 0.0011 0.015 0.073

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.0011 0.015 0.076

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0012 0.015 0.080

Tinker AFB Logistics Center 7701 Arnold Street Midwest City OK PBS/CMP 0.0012 0.015 0.08

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0012 0.015 0.081

Kyb Manufacturing North 

America, Inc.

2625 North Morton Franklin IN CMP 0.0013 0.015 0.084

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0014 0.015 0.093

Garrod Hydraulics, Inc. 1050 Locust Point Road York PA CMP 0.0015 0.015 0.10
9

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Whyco Finishing 

Technologies, Inc

670 Waterbury Road Thomaston CT WAFS/MPME 0.0016 0.015 0.10

Lasalle Steel 1045 East Main Street Griffith IN CMP 0.0016 0.015 0.10

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0017 0.015 0.11

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0019 0.015 0.13

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0021 0.015 0.14

NEO Industries 10 Technology Place Beaver Dam KY CMP 0.0024 0.015 0.16

Quebecor World – Franklin 300 Brown Road Franklin KY CMP 0.0025 0.015 0.17

Ultra Plating 345 S. Pearl Street Green Bay WI CMP 0.0026 0.015 0.17

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0027 0.015 0.18

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0028 0.015 0.19

Grove US L.L.C. 7677 Anthony Highway Quincy PA CMP 0.0030 0.015 0.20

Perfection Industries, Inc. 18571 Weaver Street Detroit MI CMP 0.0030 0.015 0.20

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0031 0.015 0.20

National Chromium Co. Inc. 10 Senexet Road Putnam CT CMP 0.0031 0.015 0.20

Hard Chrome 510 Dresden Evansville IN PBS/ CMP 0.0031 0.015 0.21

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0035 0.015 0.23

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0036 0.015 0.24

Tinker AFB Logistics Center 7701 Arnold Street Midwest City OK PBS/CMP 0.0039 0.015 0.26

National Chromium Co. Inc. 10 Senexet Road Putnam CT CMP 0.0040 0.015 0.26

Moyno, Inc. 1895 West Jefferson Street Springfield OH CMP 0.0040 0.015 0.27

McDowell Enterprises-South 2010 Superior Street Elkhart IN CMP 0.0040 AMR 

limit

N/A

KSI, Inc.-West Line 1500 Genesis Drive LaPorte IN CMP 0.0048 0.015 0.32
10

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.0053 0.015 0.35

Garrod Hydraulics, Inc. 1050 Locust Point Road York PA CMP 0.0053 0.015 0.36

Quebecor World – Franklin 300 Brown Road Franklin KY CMP 0.0055 0.015 0.37

Huntington Plating Inc. 625 Monroe Avenue Huntington WV CMP 0.0058 0.015 0.39

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.0059 0.015 0.39

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.0060 0.015 0.40

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.0060 0.015 0.40

KSI, Inc.-East Line 1500 Genesis Drive LaPorte IN CMP 0.0063 0.015 0.42

KBY Manufacturing North 

America, Inc.

2625 North Morton Franklin IN PBS/CMP 0.0066 0.015 0.44

NEO Industries 1465 North Park Drive Decatur AL CMP 0.0070 0.015 0.47

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0070 0.015 0.47

Parker Hannifin-Horizontal One Parker Drive Ashley IN PBS/CMP 0.0071 0.015 0.47

Grove US L.L.C. 7677 Anthony Highway Quincy PA CMP 0.0080 0.015 0.53

KBY Manufacturing North 

America, Inc.

2625 North Morton Franklin IN WS/CMP 0.0080 0.015 0.53

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.0080 0.015 0.53

Ultra Plating 345 S. Pearl Street Green Bay WI CMP? 0.0080 0.015 0.54

Harrision Engine 301 Detroit Street LaPorte IN PBS/CMP 0.0087 0.015 0.58

NEO Industries 1775 Willow Creek Road Portage IN PBS/CMP 0.0091 0.015 0.61

CCR, Inc. 1011 South Perkins Avenue Muncie IN CMP 0.0092 0.015 0.61

Delta Airlines 1775 Aviation Boulevard Atlanta GA CMP 0.0092 0.015 0.61

National Chromium Co., Inc. 10 Senexet Road Putnam CT CMP 0.0096 0.015 0.64

Parker Hannifin-New 

Horizontal

One Parker Drive Ashley IN PBS/CMP 0.0098 0.015 0.65

H&L Plating 410 E. Willard Street Muncie IN CMP 0.0099 0.015 0.66
11

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.010 0.015 0.67

Hohman Plating & Mfg, Inc. 814 Hillrose Avenue Dayton OH WAFS 0.012 0.015 0.77

Chromium Plating Co. 412 N. Cheyenne Tulsa OK CMP 0.012 0.015 0.78

Parker Hannifin-Vertical One Parker Drive Ashley IN PBS/CMP 0.012 0.015 0.80

Chromium Plating Co. 412 N. Cheyenne Tulsa OK CMP 0.013 0.015 0.84

Delta Airlines 1775 Aviation Boulevard Atlanta GA CMP 0.013 0.015 0.87

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.013 0.015 0.87

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.013 0.015 0.87

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.013 0.015 0.87

Hausner Hard-Chrome, Inc. 670 Greenleaf Avenue Elk Grove Village IL CMP 0.015 0.015 0.99
12

Table 3. Summary of Actual Emission Concentration Data -- New Small Hard Chromium Electroplating

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

PPI Aerospace Acquisition,

L.L.C.

23514 Groesbeck Hwy Warren MI PBS/CMP 0.00022 AMR limit N/A

D & B Metal Finishing 22803 Patmore Clinton Township MI WAFS/Cover 0.00060 0.015 0.040

Modern Hard Chrome Service 12880 East Nine Mile Road Warren MI CMP/HEPA 0.00067 0.015 0.044

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL MPME 0.00090 0.015 0.060

Diamond Hard Chrome 6110 Grand Avenue Cleveland IL CMP-PBS 0.0009 0.015 0.061

Bales Mold Service, Inc. 2824 Hitchcock Avenue Downers Grove IL CMP 0.0010 0.015 0.067

RR Donnelley 2801 West Old Route 30 Warsaw IN CMP/HEPA 0.0012 0.015 0.080

Hydra-Lock Corporation 25000 Joy Boulevard Mt. Clemens MI CMP 0.0014 0.015 0.093

H.V. Roll Center 1079 W. State Road 149 Chesterton IN CMP 0.0015 0.015 0.10

K&I Hard Chrome-System #1 

East Stack

1900 E. Main Street New Albany IN CMP 0.0017 0.015 0.11

Milac Manufacturing 165 S. Balfour Avenue Moultrie GA CMP 0.0017 0.015 0.11

D & B Metal Finishing 22803 Patmore Clinton Township MI WAFS/Cover 0.0020 0.015 0.13

Kings’ Mountain International 1755 South Battleground 

Avenue

King's Mountain NC PBS 0.0023 0.015 0.15

RR Donnelley and Sons 216 Greenfield Road Lancaster City PA CMP/HEPA 0.0023 0.015 0.15

AK Steel 6500 N US Hwy 21 Rockport IN CMP 0.0034 0.015 0.22

Southern Cylinder 1000 Bales Lane Clarksville IN CMP 0.0040 0.015 0.27

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL CMP 0.0042 0.015 0.28

Baycote 1302 Industrial Drive Mishawaka IN WAFS/CMP 0.0045 0.015 0.30

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL CMP 0.0047 0.015 0.31

SMS Millcraft 671 Colbert Avenue Oil City PA CMP 0.0050 0.015 0.33

K&I Hard Chrome-System #2 

West Stack

1900 E. Main Street New Albany IN CMP 0.0056 0.015 0.37

Roembke 1580 Baker Drive Ossian IN CMP 0.0057 0.015 0.38
13

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Elkhart Products 700 Rainbow Road Elkhart IN CMP 0.0057 0.015 0.38

Electro-Tech, Inc. 100 West Poplar Street Meadville PA WAFS/CMP 0.0063 0.015 0.42

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0063 0.015 0.42

Electro Plating Service, Inc. 945 E. Ten Mile Road Madison Heights MI CMP 0.0063 0.015 0.42

Diamond Hard Chrome 6110 Grand Avenue Cleveland IL CMP-PBS 0.0066 0.015 0.44

Xaloy, Inc., Tanner Plating 

Division

1399 Countyline Road New Castle PA CMP 0.0070 0.015 0.47

Allied Signal 717 North Bendix South Bend IN WAFS 0.0074 0.015 0.49

PPI Aerospace Acquisition,

L.L.C.

23514 Groesbeck Hwy Warren MI PBS/CMP 0.0076 0.015 0.51

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0077 0.015 0.51

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0082 0.015 0.55

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0097 0.015 0.64

Innovative Packaging 

Solutions

1405 West Missouri Street Evansville IN CMP 0.0099 0.015 0.66

Cope Brothers 5301 E SR 231 Leroy IN CMP 0.010 0.015 0.70

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.011 0.015 0.71

Xaloy, Inc., Tanner Plating 

Division

1399 Countyline Road New Castle PA CMP 0.012 0.015 0.80

Biddle Precision 701 South Main Street Sheridan IN PBS/CMP 0.013 0.015 0.87
14

Table 4. Chromium Electroplating -- Summary of Actual Emission Concentration Data -- Existing Small Hard Chromium 

Electroplating

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Allison Transmission 4700 West 10th Street Indianapolis IN CMP 0.00062 0.030 0.021

Integrity Hard Chrome, L.L.C. 1300 National Avenue Addison IL Scrubber 0.00075 0.030 0.025

Richards Industries, Inc. 3170 Wasson Road Cincinnati OH CMP 0.0015 0.030 0.050

Harsh International, Inc. 600 Oak Avenue Eaton CO WAFS/PBS 0.0016 0.030 0.053

Microprecision Textron 525 Berne Street Berne IN WAFS 0.0021 0.030 0.070

Hartzell Propeller, Inc. One Propeller Place Piqua OH PBS 0.0021 0.030 0.071

R&S Plating 2302 Bloyd Avenue Indianapolis IN PBS/CMP 0.0024 0.030 0.080

Crown Plating 4221 N.E. St. Johns 

Boulevard, Unit G

Vancouver WA WAFS/Cover 0.0027 0.030 0.090

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0030 0.030 0.10

Franke Plating Works, Inc. 2109 E. Washington Blvd Fort Wayne IN CMP 0.0037 0.030 0.12

Hi-Tech Plating Co, Inc. 1015 West 18th Street Erie PA WAFS/PBS 0.0039 0.030 0.13

Amcast, Geneva 700 Rainbow Road Geneva IN CMP 0.0043 0.030 0.14

Corning, Inc. 1025 Martin Street Greenville OH FB 0.0049 0.030 0.16

Gravure Process Company 4179 W Belmont Avenue Chicago IL CMP 0.0049 0.030 0.16

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0050 0.030 0.17

Freudenberg NOK (Tobin 

Tool)

1004 W. Washington Street Shelbyville IN CMP 0.0063 0.030 0.21

Denver Metal Finishing 3100 East 43rd Avenue Denver CO WAFS 0.0076 0.030 0.25

Tools for Bending, 

Incorporated

194 W Dakota Avenue Denver CO WAFS/PBS 0.0080 0.030 0.27

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.0083 0.030 0.28

CM Grinding 23550 Ardmore Trail South Bend IN WAFS 0.0087 0.030 0.29

Amcast, Elkhart 1255 Oak Street, P.O. Box 

1008

Elkhart IN CMP 0.0096 0.030 0.32

Muncie Precision 1001 East 18TH Street Muncie IN WAFS/FB 0.0098 0.030 0.33
15

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Toppan Interamerica, Inc. 1131 Hwy 155 South McDonough GA CMP 0.0099 0.030 0.33

CM Grinding 23550 Ardmore Trail South Bend IN WAFS 0.010 0.030 0.33

NOVA Chrome, Inc. 3200 N Wolf Rd Franklin Park IL PBS/CMP 0.010 0.030 0.34

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.010 0.030 0.34

Rolls Royce/Allison Engine 2100-2355 So. Tibbs Avenue Indianapolis IN CMP 0.011 0.030 0.36

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.014 0.030 0.46

Plating Perceptions, Inc. 8815 Herrick Road Twinsburg OH CMP 0.015 0.030 0.50

West Falls Machine, Co. 11692 East Main Street East Aurora NY WAFS 0.015 0.030 0.50

Dover Industrial 2929 North Campbell Avenue Chicago IL WAFS 0.015 0.030 0.50

Dover Industrial 2929 North Campbell Avenue Chicago IL WAFS 0.016 0.030 0.54

Plating Perceptions, Inc. 8815 Herrick Road Twinsburg OH CMP 0.017 0.030 0.56

Hard Chrome Enterprises, Inc. 220 10th Street Lake Park FL CMP 0.019 0.030 0.63

Nussmier Engraving 933 Main Street, Evansville Evansville IN PBS/CMP 0.023 0.030 0.77
16

Table 5. Chromium Electroplating -- Summary of Actual Emission Concentration Data -- Decorative Cr Electroplating and 

Chromium Anodizing

Company/Plant Name Street City State Process Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dsc

m Limit

Actual to 

MACT

Century Plating Co. Inc. 2939 N. Oakley Avenue Chicago IL Decorative Cr MPME 0.000052 0.010 0.0052

American Plating 504 NE 2nd Street Winlock WA Decorative Cr WAFS 0.00020 0.010 0.020

Whyco Finishing Technologies, Inc 670 Waterbury Road Thomaston CT Decorative Cr WAFS/MPME 0.00025 0.010 0.025

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00038 0.010 0.038

Lacks Enterprises Inc. - Barden 4375 52nd Street Kentwood MI Decorative Cr WAFS/CMP 0.00043 0.010 0.043

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00053 0.010 0.053

Lacks Enterprises Inc. - Barden 4375 52nd Street Kentwood MI Decorative Cr WAFS/CMP 0.00060 0.010 0.060

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00068 0.010 0.068

Deco Plate Manufacturing 

Company

395 Demille Road Lapeer MI Decorative Cr MPME 0.0030 0.010 0.30

Chem Processing Inc. - Linden 

Oaks

3910 Linden Oaks Drive Rockford IL Decorative Cr MPME 0.0038 0.010 0.38

Hohman Plating & Mfg Inc. 814 Hillrose Avenue Dayton OH Decorative Cr WAFS 0.0044 0.015 0.29

Component Repair Technologies, 

Inc.

8507 Tyler Blvd Mentor Ohio Decorative Cr CMP 0.0048 0.010 0.48

American Nickeloid Company 131 Cherry Walnutport PA Decorative Cr PBS 0.0065 0.010 0.65

Component Repair Technologies, 

Inc.

8507 Tyler Blvd Mentor Ohio Decorative Cr CMP 0.0066 0.010 0.66

LMI (Leonard Metals, Inc.) 2104 N 170th E Avenue Tulsa OK Cr anodizing WS 0.0016 0.010 0.16
17

Table 6. Summary of Affected Plants for Proposed Emission Limits

Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing 

No. of affected plants nationwide 219 271 480 146

No. of plants currently using WAFS 4 30 425 70

No. of plants currently using WAFS and can already 

meet proposed limits (i.e., do not need to add 

additional WAFS)

1 6 85 14

No. of plants that currently use WAFS and do not 

currently meet limit (i.e., plants that will need to add 

additional WAFS to meet proposed limits)

3 24 340 56

No. of plants that will begin using WAFS to meet 

the proposed limits 33 50 8 11

No. plants that will retrofit a CMP to meet the 

proposed limits 2 3 - -

No. plants that will retrofit a HEPA filter to meet the 

proposed limits 2 2 - -

No. of plants that will be required to complete 

performance test and have not previously performed 

testing that shows compliance with new limits

64 81 15 21
18

Table 7. Summary of Control Costs for Typical Chromium Electroplating Plants

Plant Type

Flow 

rate, 

ACFM

Total Tank 

Volume, 

gal

Energy Input, 

Amp-hr/yr

HEPA Filter Retrofit CMP Retrofit WAFS WAFS

Annualized 

Cost, $/yr

Capital 

Cost, $

Annualized 

Cost, $/yr

Capital 

Cost, $

Annualized 

Cost, $/yra

Capital 

Cost, $

Large, hard 

chromium

35,247 15,852 107,061,750 $64,319 $164,939 $43,613 $193,106 $55,513 $0

Small, hard 

chromium

10,618 2,938 14,560,000 $22,647 $65,956 $19,403 $72,918 $7,983 $0

Decorative 

chromium

15,817 1,021 5,250,000 $31,443 $86,848 $24,513 $98,286 $2,857 $0

Chromium 

anodizing

14,998 1,381 1,400,000 $30,058 $83,560 $23,708 $94,293 $1,377 $0

a Includes additional 15 percent to account for the use of non-PFOS WAFS.
19

 Table 8. Estimated Cost of Emission Test -- 2 Electroplating Systems/Stacks - 2 hr test runs

Hours of testing 12 Assumes M 306, 3 runs, 2 hours each

No. of tests

Method 5 - PM 1 kiln stack

Method 202 - Condensable PM 1 kiln stack

Method 26A - HF/HCl 1 kiln stack

Method 306 2 1 kiln stack

Method 23 - Dioxins/furans 1 kiln stack, 2 dryer stacks

Total No. of tests 2

Days 3 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 2

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

 volumetric flow sampler 150

 CO2/O2 analyzer 600

 Sample lines 225

 Trailer to haul equipment 600

 Rental truck 300

 Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

 labor 1,160

 lodging 450

 per diem 120

 vehicle rental 180 One car

Total travel cost 1,910

Testing cost

 Mobilization 460 4 hours for site manager and Technical II
20

 Setup equipment 580 Assume 4 hours for 3-man crew

 Perform test 2,314 Includes downtime, assumed to be 33% of testing time

 Take down equipment 290 Assume 2 hours for 3-man crew

 Onsite contingency 182 Approximately 5% of testing cost for short-term delays

Total testing cost 3,826

Standby/overtime fees Not applicable

Laboratory Analysis

Method 5 - PM 0

Method 202 - Condensable PM 0

Method 26A - HF/HCl 0

Method 29 - Metals 5,300

Method 23 - Dioxins/furans 0

Total 5,300

Test report

 Data reduction and review 240 2 hr + 2 hr/test

 Report preparation 340 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

 Report review 240 1 hr + 0.5 hr/test for project manager

 Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 920

SUMMARY

Total equipment rental cost 2,775

Total travel cost 1,910

Total testing cost 3,826

Standby/overtime fees 0

Laboratory analysis cost 5,300

Total test report cost 920

TOTAL 14,730
21

Table 9. Summary of Nationwide Testing Costs

Plant Type

Estimate 

No. of 

Facilities 

Breakdown of Plants by 

No. of Stacksa Cost Per No. of Stacks

Total

Annualized 

1 2 3 1 2 3 Cost

Hard Cr electroplating, large 64 50% 50% $0 $468,709 $636,400 $1,105,109 $121,335

Hard Cr electroplating, small 81 30% 70% $259,447 $834,944 1,094,391 $120,158

Deco Cr electroplating 15 70% 30% $115,130 $68,053 $0 $183,183 $20,113

Cr anodizing 21 80% 20% $181,816 $62,691 $0 $244,507 $26,846

a For example, it is assumed that 50% of large hard chromium electroplating plants have two stacks, and 50% have three stacks.
Table 10. Summary of Baseline Emissions for Non-California Plants

Process

Simulated Emissions Actual Emissions Total

Average, 

lbs/yr

No. of 

plants

Total emissions, 

lbs/yr No. of 

plants

Total emissions, 

lbs/yr No. of 

plants

Total emissions, 

lbs/yr

lbs/yr tons/yr lbs/yr tons/yr lbs/yr tons/yr

Hard Cr electroplating, large 180 488 0.24 36 73.0 0.036 216 561 0.280 2.60

Hard Cr electroplating, small 360 207 0.10 54 27.6 0.014 414 235 0.117 0.57

Decorative Cr electroplating 444 251 0.13 34 23.0 0.011 478 274 0.137 0.57

Cr anodizing 138 64 0.03 7 2.5 0.0013 145 66 0.033 0.46

Total 1,122 1,010 0.51 131 126.1 0.063 1,253 1,136 0.568 0.91
23

Table 11. Summary of Cost Effectiveness for Proposed Requirements

Process

No. of affected 

facilities Capital Cost, $

Annualized Cost, 

$/yr

Emissions 

reductions, lbs/yr

Cost 

Effectiveness, $/lb

Large, hard chromium electroplating 219 $1,821,199 $2,195,782 121.4 $18,087

Small, hard chromium electroplating 271 $1,445,056 $651,570 41.3 $15,777

Decorative chromium electroplating 480 $183,183 $188,689 39.4 $4,789

Chromium anodizing 146 $244,507 $53,556 5.9 $9,077

Total 1,116 $3,693,945 $3,089,597 208.0
24

Table 12. Summary of Costs and Emissions Reductions for Proposed Options

Parameter Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing Total

Emission Limit

Current Emission Limit 0.015 0.015/0.030 0.010 0.010

Proposed Emission Limit, existing sources 0.011 0.015 0.0070 0.0070

Proposed Emission Limit, new sources 0.0060 0.0060 0.0060 0.0060

No. of Plants

No. of Existing Plants Nationwide 233 450 588 183 1,454 

No. of Affected (Non-California) Plants

Total 219 271 480 146 1,116 

WAFS only (15%) 4 30 425 70 529 

% of Facilities that use WAFS and can already meet 

limit (do not need additional WAFS) 20% 20% 20% 20%

New WAFS (100%) 33 50 8 11 102

CMP Retrofit 2 3 - - 5 

HEPA Retrofit 

2 

2 - - 4 

% of facilities whose compliance test met revised limit 88% 83% 90% 90%

Assumed % of facilities that still operate as during test 80% 80% 80% 80%

Testing 64 81 15 21 181

Capital Cost

CMP Control Equipment $386,213 $218,754 $0 $0 $604,967

HEPA Control Equipment $329,877 $131,912 $0 $0 $461,789

Testing $1,105,109 $1,094,391 $183,183 $244,507 $2,627,189

Total $1,821,199 $1,445,056 $183,183 $244,507 $3,693,945

Capital Cost Per Plant $8,316 $5,332 $382 $1,675 $15,705
25

Parameter Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing Total

Annualized Cost

CMP Control Equipment $87,226 $58,208 $0 $0 $145,434

HEPA Control Equipment $128,638 $45,294 $0 $0 $173,932

Revised WAFS* $1,858,583 $427,909 $168,576 $26,711 $2,481,780

Testing $121,335 $120,158 $20,113 $26,846 $288,451

Total $2,195,782 $651,570 $188,689 $53,556 $3,089,597

Annualized Cost Per Plant $10,026 $2,404 $393 $367

Emissions

Non CA Baseline Emissions, lbs/yr 561 235 274 

 

66 1,136 

CA Baseline Emissions, lbs/yr 0.86 0.17 0.35 

 

0.12 1.5 

Total Baseline Emissions, lbs/yr 561.9 235.0 274.6 66.2 1,137.6 

Emissions Reductions, lbs/yr 121.4 41.3 39.4 5.9 208.0 

Cost Effectiveness, $/lb $16,090 $14,425 $4,231 $8,487

No. of plants that use only WAFS

and do not currently meet the 

proposed surface limits and will need 

to add additional WAFS (values 

obtained from row 5 of Table 6 

above) 3 24 340 56 423

Cost per plant $8,327 $1,197 $429 $207

No. of plants that only must test 27 26 7 10 70 

Cost per plant $1,907 $1,484 $1,306 $1,262

No. of plants that must use WAFS & 

test 33 50 8 

 

11 102 

WAFS cost per plant $55,513 $7,983 $2,857 $1,377

Testing cost per plant $1,907 $1,484 $1,306 $1,262

Total cost per plant $57,420 $9,467 $4,163 $2,638

No. of plants that must retrofit 4 5 - 9 
26

APCD & test - 

APCD cost $53,966 $20,700 $0 $0

Testing cost $1,907 $1,484 $0 $0

Average cost per plant $55,872 $22,184 $0 $0

No. of plants with add-on controls 

that will comply with the proposed 

standard by meeting the emissions 

limit and will not need additional 

controls and will not need to test 

(because they qualify for the 

provision described in section 6 

above based on previous test). 151 160 40 55

No. of plants with no additional 

requirements** 1 + 151 = 152 6 + 160 = 166 85 + 40 = 125 14 + 55 = 69 512

* Assume 20% of existing already meet 40/33 and the remaining plants have to add 15% more WAFS.

** Includes plants that would not have to install or use any additional add-on controls or add any additional WAFS to meet surface tension limits 

and would not be required to test (i.e., sum of values obtained from row immediately above in this table plus the values from row 4 of Table 6 

above) .
27

Table 13. Summary of Cost Effectiveness for Other Regulatory Options Considered1

Option Process

No. of 

affected 

facilities7 Capital Cost, $

Annualized Cost, 

$/yr

Emissions 

reductions, 

lbs/yr

Cost 

Effectiveness, 

$/lb

Option A2 New small hard Cr 34 $571,000 $243,000 7 $36,000 

Option B3 Large hard Cr 76 $2,847,000 $4,182,000 169 $24,700

Option C4 Existing small hard Cr 140 $2,447,000 $1,225,000 64 $19,200

Option D5 Large hard Cr 97 $3,414,000 $5,368,000 180 $29,900

Option E6 Existing small hard Cr 171 $3,161,000 $1,585,000 81 $19,700

Option F6 New small hard Cr 80 $1,268,000 $653,000 35 $18,800

1

All options assume that, of the plants that would need to reduce emissions, 10 percent would have to install add-on controls. Costs calculations account do 

not include testing costs for facilities that would be exempt from testing and assume that no facilities currently meet the new emissions limit. 

2 Option A reduces the emission limit to 67% of the current limit. 

3 Option B reduces the emission limit to 50% of the current limit. 

4 Option C reduces the emission limit to 33% of the current limit. 

5 Option D reduces the emission limit to 0.006 mg/dscm.

6 Option E reduces the emission limit to 0.006 mg/dscm.

7 Option F reduces the emission limit to 0.006 mg/dscm.

8 Number of plants that would have to install additional controls. 
28

Appendix A 

Methodology Used to Determine Number of Plants Subject to

the Requirements of the Proposed Amendments for Chromium Electroplating

No. Description Basis/Methodology

1 Number of Existing 

Plants

• For the October 2010 proposal, the relative percentages of each type of chromium electroplating plant were 

determined. (See Estimated Number of Chromium Electroplating Plants, May 25, 2010, which is available in the 

docket for the proposed rulemaking.)

• At that time, it was estimated there were about 1,770 plants nationwide.

• Between February 2011 and April 2011, extensive data gathering was conducted. The results of this effort 

indicated that many of the 1,770 plants were no longer in operation, and the resulting data set showed a total 

of 1,454 plants still in operation.

• For the supplemental proposal, these same percentages were applied to the number of plants in the current 

database of 1,454 plants to determine the number of each type of plant. 

• Some adjustments were made as we received new information, so the current estimated number of each type 

of plant no longer is exactly the same percentage as reported in the May 25, 2010 memo, but the percentages 

are close. For example, the memo indicated that approximately 45% of plants nationwide were hard chromium 

electroplating plants, and we currently estimate that 47% of plants nationwide are hard chromium 

electroplating plants.

• The resulting number of plants were:

o 233 large hard chromium plants

o 450 small hard chromium plants

o 588 decorative hard chromium plants

o 183 chromium anodizing plants

o 1,454 total plants

2 Number of Affected 

Plants

• For reasons explained elsewhere, the plants in California were separated from the list of plants in other States. 

• This resulted in the following numbers of non-California plants:

o 219 large hard chromium plants

o 271 small hard chromium plants

o 480 decorative hard chromium plants

o 146 chromium anodizing plants

o 1,116 total plants
29

No. Description Basis/Methodology

3

Plants that only use 

WAFS for emission 

control

• To determine control costs, it was necessary to determine the estimated number of plants in each category 

that use WAFS and that use add-on controls. Data from hundreds of permits and other documents were 

compiled on control methods and the percentages of each were calculated. These percentages are provided in 

Table 12 of the Profile of Chromium Electroplating Processes and Emissions, Emission Standards Technical 

Support and Post Promulgation Activities, January 6, 2012 (hereafter referred to as the Industry Profile).

• These percentages were applied to the number of affected plants to determine the number of plants that 

currently use WAFS for emission control, resulting in the following: 

o 4 large hard chromium plants

o 30 small hard chromium plants

o 425 decorative hard chromium plants

o 70 chromium anodizing plants

o 529 total plants

• It was assumed that these plants would continue to use WAFS to meet the proposed surface tension limits, and 

would not switch to add-on control devices. Plants that meet the surface tension limits are not subject to, and 

do not have to comply with, the emissions limits.

• Of these plants, we assume that 80% would need to add additional WAFS to meet the proposed lower surface 

tension limits. The data compiled for the surface tension analysis indicated that many plants already operate 

below the proposed surface tension limits. Therefore the assumption of 80% seemed reasonable. 

o 3 large hard chromium plants

o 24 small hard chromium plants

o 340 decorative chromium plants

o 56 chromium anodizing plants

• Of these plants, we assume that 20% would not need any additional WAFS to meet the proposed lower surface 

tension limits, thus would have no additional costs. 

o 1 large hard chromium plants

o 6 small hard chromium plants

o 85 decorative chromium plants

o 14 chromium anodizing plants
30

No. Description Basis/Methodology

4

Number of hard 

chromium 

electroplating plants 

that must use 

additional control to 

meet the proposed 

limits

• To determine the number of facilities that would be subject to the proposed emission limits and would need 

additional controls to meet those limits, the available emissions data for each process type were first ranked. 

These data are provided in Tables 1 through 4 of the Industry Profile. The data are also provided in Tables 2 

through 5 of Procedures for Determining Control Costs and Cost Effectiveness for Chromium Electroplating 

Supplemental Proposal, January 19, 2012 (hereafter referred to as the Cost Memo). 

• Next, the percentage of plants in the rankings that would not meet the proposed emission limit was 

determined by multiplying the proposed limit by 85% to allow for a compliance margin, and this value was used 

to determine the percentage of plants that would need additional control. For example, for large hard 

chromium, the proposed limit is 0.011 mg/dscm, and 85% of 0.011 is 0.0094. 

• The percentage of plants with emissions greater than this value was determined from the table of ranked 

sources. For hard chromium electroplating, these percentages were:

o 17% for large hard chromium

o 23% for existing small hard chromium

• After subtracting the number of plants that use WAFS from the total, these percentages were applied to the 

remainder, resulting in the following plants that would need additional control: 

o 37 large hard chromium plants

o 55 existing small hard chromium plants

o For the proposed option, new small hard chromium plants would not be required to meet a more stringent 

emission limit, but if they had, the same methodology would have been used.

5

Number of decorative 

chromium and 

chromium anodizing 

plants that must use 

additional control to 

meet the proposed 

limits

o The same methodology described above for hard chromium was use to determine the number of decorative 

chromium electroplating and chromium anodizing plants that would need additional control. 

• However, because the ranked emission data showed that all plants would meet the proposed limits, it was 

conservatively assumed that only 90% would meet the proposed limits. This resulted in the following number 

of plants that would need additional control: 

o 8 decorative chromium plants

o 11 chromium anodizing plants
31

No. Description Basis/Methodology

6

Number of plants that 

would use WAFS as the 

additional control to 

meet the proposed 

emission limits

• It was assumed that 90% of plants that needed additional control to meet the proposed limits could use WAFS 

to reduce emissions enough to meet those limits. The data indicate that many plants use WAFS to supplement 

the emissions reductions achieved using an add-on control device. Since most of the plants that would not 

meet the proposed limits would need relatively small reductions to be in compliance, it seemed reasonable to 

assume that 90% could use WAFS. This resulted in the following numbers of plants: 

o 33 large hard chromium plants

o 50 small hard chromium plants

o 8 decorative hard chromium plants

o 11 chromium anodizing plants

7

Number of plants that 

would retrofit add-on 

controls to meet the 

proposed emission 

limits

• The number of plants that would retrofit add-on controls was determined as the difference between the 

number needing additional controls (see Items 4 and 5 above) and the number of plants that would use WAFS 

as the additional control (see Item 6 above). This resulted in the following number of plants: 

o 4 large hard chromium plants

o 5 small hard chromium plants

o 0 (zero) decorative hard chromium plants

o 0 (zero) chromium anodizing plants

8

Number of plants that 

would retrofit CMPs 

and HEPA filters

• It was assumed that half of the plants listed in Item 7 above would retrofit CMPs and the remainder would 

retrofit HEPA filters (with rounding as needed). The available data show that most plants could meet the 

proposed limits using a CMP and would not need to retrofit a HEPA filter. However, it was conservatively 

assumed that half of these plants would retrofit a HEPA filter. This resulted in the following:

o 2 large hard chromium plants would retrofit CMPs

o 2 large hard chromium plants would retrofit HEPA filters

o 3 small hard chromium plants would retrofit CMPs

o 2 small hard chromium plants would retrofit HEPA filters
32

No. Description Basis/Methodology

9

Number of plants that 

would be required to 

conduct emission tests

• The proposed amendments would grant an exemption from testing for plants that previously demonstrated 

that their sources met the proposed emission limits. To determine the number of plants that satisfied this 

condition, the ranked data discussed in Item 4 were used.

• It was assumed that 20% of those that had previously met the proposed limit would have undergone changes 

that would have negated their exemption. Assuming 20% is a conservative estimate to help ensure that the 

additional testing costs would not be underestimated.

• The number of plants that would have to test was determined as the number of plants that had not met the 

proposed limits previously, plus the 20% with negated exemptions.

• For example, for large hard chromium, 12% had not met the proposed emission limit. This equates to 0.12 × 

215 plants = 26 plants. Of the 189 plants that did meet the proposed emission limit, 20% lost their exemption, 

or 189 × 0.20 = 38 plants, making the total 26 + 38 = 64 plants that must conduct an emission test. For small 

hard chromium, decorative, and anodizing the percentages that had not met the proposed limit were 17%, 

10%, and 10%, respectively. Applying this methodology to the source categories results in the following 

numbers of plants that must test:

o 64 large hard chromium plants

o 81 small hard chromium plants

o 15 decorative hard chromium plants

o 21 chromium anodizing plants

10

Number of plants that 

are required only to 

conduct emission tests

• Some plants would be subject to the emission limits and would be required to test, but would not be required 

to add additional controls. These numbers were determined by subtracting from the number of plants 

required to test (see Item 9 above), the number of plants required to install or use additional controls.

• For example, for large hard chromium, the calculation is: 

64 total - 33 (use WAFS) - 2 (retrofit CMP) - 2 (retrofit HEPA) = 27 plants

• Applying these assumptions to the source categories results in the following numbers of plants that are 

required only to test:

o 27 large hard chromium plants

o 26 small hard chromium plants

o 7 decorative hard chromium plants

o 10 chromium anodizing plants
33

No. Description Basis/Methodology

11 Number of plants with 

no requirements

• The number of plants with no requirements is simply the total number of plants in the category, minus the 

number of plants that already use WAFS as the control method and will need to add additional WAFS to meet 

the proposed limits (see Item 3 above), minus the number required to test. (Note that the numbers of plants 

that must use additional control are included among those that must test.) This results in the following 

numbers of plants:

o 152 large hard chromium plants (i.e., 219 - 3 - 64 = 152) 

o 166 small hard chromium plants (i.e., 271 - 24 - 81 = 166) 

o 125 decorative hard chromium plants (i.e., 480 - 340 - 15 = 125)

o 69 chromium anodizing plants (i.e., 146 - 56 - 21 = 69)