Date: September 7, 2010

Subject: Emissions Reductions and Cost Effec tiveness of Composite Mesh Pads for Chromium Electroplating Emission Standards Technical Suppor t and Post Promulgation Activities EPA Contract No. EP-D-06-118; EPA Work Assignment No. 4-6 RTI Project No. 0210426.004.006

From: Cindy Hancy
Richard Marinshaw

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

The purpose of this memorandum is to presen t the estimated emissions reductions, costs, and cost effectiveness of retrofitting composite mesh pads (CMP) on existing sources subject to
the National Emission Standards for Chromium Em issions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium Electroplating NESHAP, 40 CFR 63, subpart N). Retrofitting CMPs is being considered as one regulatory option for reducing the
risk associated with chromium emissions from chromium electroplating and anodizing.

Section I of this memorandum discusses the estimated number of plants that would be affected by the CMP retrofit option. Baseline em issions and emissions reductions associated with retrofitting CMPs on existing affected sources are presented in Section II. Section III describes the basis for, and results of, the cost estimates for retrofitting CMP's on the affected
sources. The nationwide cost-effectiveness attribut ed to the CMP retrofit option is summarized in Section IV. References are provided in Section V.

I. Number of Affected Sources

The option of retrofitting CMPs on existing sources would affect all hard chromium electroplating, deco rative chromium el ectroplating, and ch romium anodizing ta nks that are not currently equipped with CMP's. Specifically, this option wo uld apply to the following:

1. Sources that use wetting agent fume suppressants (WAFS) as the only means of emission control;

2. Source equipped with add-on control devices, such as packed bed scrubbers (PBS) or mesh pad mist eliminators (MPME), that are not as effective as CMPs in controlling chromium compound emissions; and

3. For hard chromium electroplating, only those so urces at facilities th at are classified as small under Section §63.341 of the NESHAP.2

To estimate the number of affected sources by type and size, the dist ribution of plants by size was applied to the number of each type of plant. Table 1 summarizes the estimated number of chromium electroplating and an odizing plants nationwide.

Table 1. Estimated Number of Chromium Electroplating Plants a

Process Estimated No. of plants
Hard chromium electroplating 790
Decorative chromium electroplating 740
Chromium anodizing 240

Total 1,770

a Reference 1.

The numbers of chromium electroplating a nd anodizing plants by size were estimated using the model plants and plant distributions developed for the NESHAP and documented in Chromium Emissions from Chro mium Electroplating and Chromic Acid Anodizing Operations -- Background Information for Proposed Standards (Reference 2). Three sizes of model plants (small, medium, and large) were developed for hard and decorative chro mium electroplating, and two sizes of model plants (small and large) we re developed for chromium anodizing. Table 2 summarizes the resulting nationwid e breakdown of plants by type a nd size when the percentages of each type of plant are a pplied to the number of plants shown in Table 1.

Table 2. Distribution of Mode l Plants by Size and Type

Electroplating Type Size % of total a No. of plants
nationwide

Hard Chromium Small 70% 553
Medium 20% 158 Large 10% 79

Total 790

Decorative Chromium Small 80% 592
Medium 15% 111 Large 5% 37

Total 740

Chromium Anodizing Small 75% 180 Large 25% 60

Total 240 Total, all plants 1,770

a Reference 2.

The distribution of emissi on control methods among the various types of chromium electroplating plants and plant sizes was estimated based on gene ral knowledge of the industry. Large hard chromium electroplating plants gene rally are controlled with CMPs; some PBSs are3

also used. For medium and small hard chromium electroplating plants, PBSs are more common.
Some medium and small hard chromium elect roplating plants also use WAFS to control emissions. Wetting agent fume suppressants ar e the most commonly used control method for decorative chromium electroplating and chromium anodizing plants. However, other controls (PBS, MPME) also are used. To estimate the di stribution, the percentage of plants that use WAFS was first assumed; then the percentages of each type of add-on control devices were estimated. For example, for small hard chromium electroplating, it was assumed that 20 percent are controlled with WAFS. For the remaining 80 percent, it was assumed that 20 percent are controlled with CMP. Therefore, the ove rall percentage controlled with CMP is:

80% × 20% = 16%.

Since the control efficiencies for PBS and MPME are comparable, no distinctions were made between the two with respect to their distribution. Table 3 su mmarizes the assumed distribution of these controls among the various types of model plants. The re sulting numbers of plants are
summarized in Table 4. For the distribution shown in Table 4, th e number of plants that would be affected by the CMP retrofit option would be those that are controlle d with WAFS, PBS, or

MPME.

Table 3. Distribution of Emission Controls among Model Plants

Electroplating Type Model
Plant Size % of Total

CMP PBS/MPME WAFS

Hard Chromium Small 16 64 20
Medium 54 36 10 Large 90 10 0

Decorative Chromium Small 0 10 90
Medium 2 18 80 Large 8 32 60

Chromium Anodizing Small 0 10 90 Large 8 32 60

Table 4. Estimated Number of Model Plants for each Emission Control Method

Electroplating Type Model
Plant Size Number of Plants Nationwide

Total CMP PBS/MPME WAFS

Hard Chromium Small 88 354 111 553
Medium 85 57 16 158 Large 71 8 0 79

Total 790

Decorative Chromium Small 0 59 533 592
Medium 2 20 89 111 Large 3 12 22 37

Total 740

Chromium Anodizing Small 0 18 162 180 Large 5 19 36 604

Total 240

As noted previously, for hard chromium el ectroplating, it is assumed the CMP retrofit option would apply only to faciliti es classified as "small hard ch romium electroplating facilities"
under the NESHAP. Section 63.341 of the NESHAP defines "small hard chromium electroplating facility" as a facility with a ma ximum cumulative potential rectifier capacity less than 60 million ampere hours per year (A-hr/yr). The NESHAP defines the term "large hard chromium electroplating facility" as a facility that has a maximu m cumulative potential rectifier capacity greater than or equal to 60 million A-hr/y r. The reason for the assumption that the CMP retrofit option would not apply to large hard chromium facilities is that any such facility would need a control system at least as effective as a CMP to meet the more stringent emission limits for large hard chromium electroplating facilities.

It should be noted that are is a distinc tion between the hard ch romium electroplating facility size criteria specified in the NESH AP and the model plant sizes. Table 5 shows a comparison of these criteria.

Table 5. Size Criteria for Hard Chromium Electroplating

Model Plant Criteria a NESHAP Criteria b

Plant Size Cumulative rectifier capacity, Amp-hr/yr Plant Size Cumulative rectifier capacity, A-hr/yr
Small 5 million Small < 60 million

Medium 42 million NA NA Large 160 million Large ≥ 60 million

a Reference 2.

b §63.341. NA = not applicable.

It is clear from a comparison th at a small model plant would be classified as a small hard chromium electroplating facility under the NESHAP, and a large hard chromium electroplating model plant would be classified as a large ha rd chromium electropla ting facility under the NESHAP. However, the population of plants repr esented by the medium hard chromium model plant would be divided among the NESHAP categor ies for small and large facilities. For the purposes of estimating the number of sources an d impacts associated with medium size model plants, it was assumed that 33 per cent of the facilities that ar e represented by the medium size model plants are classified as large hard chromium electroplating f acilities under the NESHAP, and the remaining 67 percent of f acilities are classified as sma ll hard chromium electroplating
facilities under the NESHAP. Table 6 shows th e final breakdown of plants that would be affected by the CMP retrofit option after removing the medium size hard chromium model plants that would be classified as large under the NES HAP. As shown in the table, of the 73 medium size hard chromium plants nationwide, 24 plants would be classified as large hard chromium electroplating facilities, and 49 plants would be classified as small hard chromium electroplating facilities when these assumptions are used.5

Table 6. Summary of Plants Potentially Affected by CMP Retrofit Option

Electroplating Type Model
Plant Size No. of Plants Nationwide
Total Classified as Large under § 63.341 No. of
Affected

Plants PBS/MPME WAFS

Hard Chromium Small 354 111 465 0 465

Medium 57 16 73 24 49

Large 8 0 8 8 0

Total 514

Decorative Chromium Small 59 533 592 NA 592

Medium 20 89 109 NA 109

Large 12 22 34 NA 34

Total 735

Chromium Anodizing Small 18 162 180 NA 180 Large 19 36 55 NA 55
Total 235

II. Baseline Emissions

The basic methodology used to estimate baseline emissions from chromium electroplating and anodizing sour ces was to apply control effi ciencies to the uncontrolled emissions developed for the original NESH AP for each size model plant and sum up the
nationwide totals. Table 7 summarizes the unc ontrolled emissions for the model plants developed for the NESHAP.

Table 7. Uncontrolled Chromium Co mpound Emissions from Model Plants a

Electroplating Type Size Uncontrolled Cr emissions, lbs/yr

Hard Chromium Small 110
Medium 926

Decorative Chromium Small 13
Medium 53 Large 530

Chromium Anodizing Small 7.2 Large 88

a Reference 2.

Table 8 summarizes the control efficiencies applied to the uncontrolled chromium electroplating model plant emissi ons listed in Table 7. With the exception of CMP, these are
based on the control efficiencies used to esti mate the impacts of the NESHAP. For CMP, a control efficiency of 99.5 percent was used for estimating impacts. However, for the estimate presented in this memorandum, a control efficien cy of 99.9 percent is use d. The higher control efficiency was assumed because the CMP cost s are based on a 4-stage CMP, which should achieve a higher level of contro l than the 3-stage CMP design that was used for estimating the impacts of the NESHAP.6

Table 8. Efficiencies of Chromium Electroplating Emission Controls a

Control Method Efficiency, % Composite mesh pad (CMP) 99.9 Packed bed scrubber (PBS) 99.0 Mesh pad mist eliminator (MPME) 99.0 Wetting agent fume suppressant (WAFS) 99.5

a Reference 2, except for CMP.

Using the data and distributions discussed above and summarized in Tables 1 through 8,
nationwide baseline emissions of chromium com pounds were estimated for the facilities that would be affected by the CMP retrofit op tion. These emissions are summarized by electroplating plant type in Ta ble 9. Nationwide baseline emi ssions for these facilities are estimated to be 1,088 pounds per year (lbs/yr) (0. 54 tons per year [tons/yr]). This total is comprised of 850 lbs/yr for hard chromium elect roplating, 198 lbs/yr fo r decorative chromium electroplating, and 40 lbs/yr for chromium anodizing.

Table 9. Estimated Nationwide Baseline Emissions for CMP Retrofit Option

Electroplating Type Model Plant Size Nationwide Emissions, lbs/yr

Hard Chromium Small 450
Medium 401

Total 850

Decorative Chromium Small 42.3
Medium 34.2 Large 121

Total 198

Chromium Anodizing Small 7.1 Large 32.7

Total 39.9

Nationwide total 1,088

III. CMP Retrofit Costs

This section describes the methodology, data, an d assumptions used to estimate the costs of retrofitting CMPs on existing sources subject to the Chromium Electroplating NESHAP. In estimating costs, distinctions were made betweensources controlled with existing non-CMP addon controls, and sources that us e WAFS and are not equipped with add-on controls. For systems with existing add-on cont rols, a retrofit factor of 50 percent of the CMP system cost was incorporated into CMP installation costs. For sy stems without existing add-on controls, a retrofit factor was not applied to the costs. However, fo r those systems, it was necessary to include costs
associated with the installation of an exhaust a nd ventilation system. As noted previously, for hard chromium facilities, it was assumed that la rge facilities are already equipped with CMPs, and only small facilities (less th an 60 million A-hr/yr) would incur costs associated with retrofitting CMPs.7

Sources with Existing Add-On Controls

Cost quotes for 3-stage and 4-stage CMP syst ems were obtained for two different exhaust flow rates: 12,000 and 35,000 actual cubic feet per minute (acfm). The quotes did not include
the costs associated with ventil ation systems (i.e., hoods, duct wo rk, etc.). Because the quotes were for budgetary purposes, detailed itemizati on was not provided. For the cost components not provided by the CMP vendor, assumptions were based on quotes provided for HEPA filters
or the EPA Air Pollution Control Cost Manual

. 3 Presented in Table 10 ar e the capital and initial costs components and the basis for those costs.

Table 10. Cost Components and Assumptions Used to Estimate CMP Retrofit Costs

Cost Component Assumption System Included in quote

Instrumentation Not included; assumed 11% of equipment cost a

Sales tax Assumed 6% Freight Assumed $2,000 b

Installation Assumed plus $16,000 b
Performance testing Assumed 0.7% of installation cost a Contingencies Assumed 2.1% of installation cost a

Retrofit Cost Assumed 50% of capital cost a (Only for facilities with ex isting add-on control device; included in overall installation cost)

a Reference 3.

b Reference 4.

Table 11 presents the annual cost components considered in the estimate, the assumptions used, and the information source.

Table 11. Annual Cost Components and Assumptions Used for CMP Retrofit Costs

Cost Component Source/Method

Labor hours NESHAP BID a

Labor rates Department of Labor b
Mesh Pad Replacement Original NESHAP scaled to 2009 dollars c Electricity $0.14/kwhr d
Property Tax & Insurance 4% of capital cost e

a Reference 2.

b Reference 5.

c Reference 6.

d Reference 7.

e Reference 3.

For the purpose of this cost analysis, th e quotes for the 4-stage CMP system at design exhaust rates of 12,000 and 35,000 acfm were used. The capital costs for each design were8

annualized using an interest rate of 7 percent and 15-year lifetime. Annualized capital costs were added to the estimated annual costs presented in Table 11, and a cost cu rve was determined by plotting exhaust flow (independent variable) versus total annualized cost (dependent variable). The equation of the best-fit line was then used to determine the total annualized cost for the model facilities for hard chromium, decorative plating, and anodizing fac ilities. Presented in Figure 1 is the annualized cost curve for re trofitting a new CMP system on a chromium electroplating source with exis ting non-CMP add-on controls.

Figure 1. Annualized Cost Curve for Retr ofitting CMPs on Existing Chromium Electroplating Source with Existing Add-on Controls.

y = 1.288x + 9885.9

$0 $10,000 $20,000 $30,000 $40,000 $50,000 $60,000

‐ 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000

The cost curve was used to estimate the cost per model plant, which was then multiplied by the number of plants nationwide. Based on this methodology, the estimated annualized cost
to retrofit a new CMP on all sources with existin g add-on controls is $16.3 million. This cost is comprised of $11.0 million for hard chromium el ectroplating plants, $3.6 million for decorative chromium electroplating plants, and $1.6 million for chromium anodizing plants. Table 12 shows the detailed cost and number of facilities for each type of model plant.

Table 12. Nationwide Annualized Costs for CMP Retrofit - Sources with Existing non-CMP
Add-on Controls

Electroplating Type Number of
Facilities Nationwide Annualized Cost, $/yr Hard chromium electroplating 392 $11,049,600 Decorative chromium electroplating 91 $3,565,500 Chromium anodizing 37 $1,635,100

Total 520 $16,250,3009

Sources without Existing Add-On Controls

For existing chromium electroplating and anodizing sources that are controlled with WAFS and are not equipped with existing a dd-on controls, the same basic methodology was used as described in the previous paragraphs. However, the 50 per cent retrofit factor was excluded from the calculations, and the costs for installing an exhaust system and ductwork were included. Presented in Figure 2 is the annualized cost curve for retrof itting a new CMP system on a chromium electroplating source without existing add-on controls.

Figure 2. Annualized Cost Curve for Retr ofitting CMPs on Existing Chromium Electroplating Source without Existing Add-on Controls.

y = 1.0645x + 9658.4

$0 $10,000 $20,000 $30,000 $40,000 $50,000

‐ 10,000 20,000 30,000 40,000

The cost curve shown in Figure 2 was used to esti mate the cost per model plant, which was then multiplied by the number of plants nationwide. The resulting annualized cost to retrofit a new CMP system on all sources subject to the NE SHAP without existing add-on controls was estimated to be $29.9 million. Table 13 shows a breakdown of the annualized costs for these

sources.

Table 13. Nationwide Annualized Costs for CMP Retrofit - Sources without Add-on Controls

Electroplating Type Number of
Facilities Nationwide Annualized Cost, $/yr Hard chromium electroplating 122 $3,377,500 Decorative chromium electroplating 644 $19,875,700 Chromium anodizing 198 $6,623,700

Total 963 $29,876,900

As noted previously, the sour ces that are not equipped with add-on controls are currently controlled using WAFS. After these sources ar e equipped with CMPs, it is assumed that WAFS would no longer be used for emission control. T hus, the costs these facili ties currently incur for10

WAFS can be considered a savings after CMP retrofit. Table 14 summarizes the estimated annual WAFS cost per model plant. These co sts are based on a unit WAFS cost of $186 per gallon, an initial WAFS addition (dose) of 0.0025 gallons of WAFS per ga llon of electroplating tank solution, and maintenance additions of 0.0075 milliliters of WA FS per ampere-hour. Reference 8 provides the ba sis for these costs.

Table 14. WAFS Cost Savings Following CMP Retrofit

Electroplating Plant Type, Size Annual
Production rateper facility, Amphrs/yr a Tank capacity per facility, gal a Initial Addition WAFS Cost per facility, $ b Maintenance Cost per facility, $/yr b Annual Facility WAFS Cost, $/yr

Hard Chromium Electroplating

Small 5,000,000 1,730 $805 $1,843 $2,647

Medium 42,000,000 8,170 $3,800 $15,478 $19,278

Decorative Chromium Electroplating

Small 3,000,000 1,730 $805 $1,106 $1,910

Medium 12,000,000 3,460 $1,609 $4,422 $6,032

Large 120,000,000 22,890 $10,647 $44,222 $54,869

Chromium Anodizing

Small N/A 1,730 $805 $2,144 $2,949

Large N/A 19,070 $8,870 $5,528 $14,398

a Reference 2.

b See reference 8 for basis of these costs.

Using the annual WAFS costs summarized in Table 14, the net costs for retrofitting CMPs on tanks that are not equipped with a dd-on controls was determined. Table 15
summarizes these costs. The to tal annualized costs for these sources are $29.9 million/yr, total WAFS savings are estimated to be $4.26 million/ yr, and the net annualized CMP retrofit costs for sources without add-on controls is estimated to be $25.6 million/yr

Table 15. Nationwide Annualized Costs for CMP Retrofit - Sources without Add-on Controls

Electroplating Type CMP Retrofit Cost, $/yr WAFS Savings, $/yr Net Nationwide Annualized Cost, $/yr Hard chromium electroplating $3,377,489 $505,902 $2,871,600 Decorative chromium electroplating $19,875,671 $2,762,073 $17,113,600 Chromium anodizing $6,623,731 $996,019 $5,627,700

Total $29,876,900 $4,264,000 $25,612,900

Table 16 shows the combined annualized costs for existing sources with add-on controls
and for sources without add-on c ontrols. Total nationwide annualiz ed costs are estimated to be $41.8 million.11

Table 16. Nationwide Annualized Cost s for CMP Retrofit - All Sources

Electroplating Type With Add-on Controls, $/yr Without add-on controls, $/yr Total Nationwide Annualized Cost, $/yr Hard chromium electroplating $11,049,600 $2,871,600 $13,921,300 Decorative chromium electroplating $3,565,500 $17,113,600 $20,679,100 Chromium anodizing $1,635,100 $5,627,700 $7,262,900

Total $16,250,300 $25,612,900 $41,863,300

IV. Cost Effectiveness for CMP Retrofit

Table 17 presents the cost effectiveness for retrofitting CMP on all existing tanks that are subject to the Chromium Electroplating NESHAP. The cost effectiveness was estimated to be $36.9 million per ton for hard chromium electroplating plants, $249 million per ton for decorative chromium electroplating plants, and $431 million per ton for chromium anodizing plants. Overall cost effectiveness was estimated to be $87.7 million per ton.12Table 17. Cost Effectiveness for CMP RetrofitModelPlant SizeNon-CMP Add-on ControlWithout Add-on ControlAll Sources NationwideNationwideannualizedcosts, $/yrNationwideemissionreductions,lbs/yrCosteffectiveness,$/lbNationwideannualizedcosts, $/yrNationwideemissionreductions,lbs/yrCosteffectiveness,$/lbNationwideannualizedcosts, $/yrNationwideemissionreductions,lbs/yrCosteffectiveness,$/lbCosteffectiveness,$/tonHard ChromiumSmall$8,960,916350$25,600$2,506,19448.7$51,500$11,467,110399$28,800$57,500,000Medium$2,088,713317$6,600$365,43339.0$9,360$2,454,146356$6,900$13,800,000Total$11,049,600667$16,570$2,871,60087.7$32,740$13,921,300754$18,500$36,900,000Decorative ChromiumSmall$1,500,2406.9$216,600$12,426,91727.7$448,370$13,927,15835$402,000$804,000,000Medium$1,012,66210$106,260$3,952,98218.9$209,510$4,965,64428$174,900$349,700,000Large$1,052,64356$18,640$733,69946.6$15,750$1,786,342103$17,300$34,700,000Total$3,565,50073$48,890$17,113,60093.2$183,690$20,679,100166$124,500$249,000,000Chromium AnodizingSmall$456,1541.2$391,080$3,608,7914.7$773,490$4,064,9465.8$697,000$1,394,000,000Large$1,178,99315$77,530$2,018,92012.7$159,320$3,197,91428$114,700$229,400,000Total$1,635,10016$99,870$5,627,70017.3$324,600$7,262,90034$215,400$430,900,000All Source CategoriesTOTAL$16,250,300756$21,490$25,612,900198.2$129,220$41,863,300954$43,900$87,700,00013

V. References

1. Memorandum from R. Marinshaw, RTI Intern ational, to P. Mulrine, EPA/OAQPS.
Estimated Number of Chromium Electroplating Plants. May 24, 2010.

2. U.S. EPA. Chromium Emissions from Ch romium Electroplating and Chromic Acid Anodizing Operations -- Background Informati on for Proposed Standards, Volume I (EPA 453/R-93-030a). U.S. Environmental Protection Agency, Research Triangle Park, NC. July

1993.

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. Letter from E. Sithes, Oskar Envi ronmental Inc, to J. Cunningham, RTI Inte rnational. Cost of HEPA Filter. January 29, 2010.

5. U.S. Bureau of Labor Statistics. 2009. Employment and Wages for Plating and Coating Machine Setters, Operators and Te nders, Metal and Plastic. May.

6. U.S. EPA. Technical Assessment of New Emi ssion Control Technologies Used in the Hard Chromium Electroplating Industry, EPA/ 453/R-93-031. U.S. Environmental Protection Agency, Research Triangle Park, NC. July 1993.

7. South Coast Air Quality Mana gement District. Final Socioeconomic Assessment for Proposed Amendments to Rule 1469 – Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodi zing Operations and Proposed Rule 1426 – Emissions from Metal Finishing Operations. 2003.

8. Memorandum from R. Marinshaw, RTI Intern ational, to P. Mulrine, EPA/OAQPS.
Nationwide Costs for Conversion to Non- PFOS Fume Suppressants. August 16, 2010.