# Date: August 12, 2010

Subject: Estimated Costs for Proposed Housekeeping Requirements for Chromium

Electroplating NESHAP

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

This memorandum presents the estimated annualized costs for the housekeeping

requirements proposed for sources subject to the National Emission Standards for Chromium

Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks

(Chromium Electroplating NESHAP, 40 CFR 63, subpart N). The annualized costs include the

equipment, installation, and la bor costs associated with:

• Drip trays and splashguards on chromi um electroplating and anodizing tanks;

• Barriers to isolate buffing, polishing, a nd grinding operations from chromium

electroplating and anodizing tanks;

• Storage for chromium chemicals; and

• Clean up of chromium-laden dust from facility surfaces.

The following section describes the basis for the cost estimates. Section II summarizes

the costs. References are provided in Section III.

I. Basis for Annualized Housekeeping Costs

This section provides the basis for the cost s associated with the proposed housekeeping

requirements. Annualized costs were estimate d for installing drip tr ays and splashguards,

barriers to isolate chromium electroplating ope rations, and chromium chemical storage and

cleanup.

To estimate nationwide costs, the parameters developed for the Chromium Electroplating

NESHAP model plants were used. Separate estimates were ma de for three subcategories of

electroplating facilities: hard chromium electroplating, de corative chromium electroplating, and

chromium anodizing facilities. Each subcategory was then further divided into small, medium,

and large facilities.

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Drip Tray/Splashguards

To estimate the cost of installing drip tr ays and splashguards on affected tanks, a unit

capital cost of $265 for splashguards was use d, based on a response to the 2005 information

collection request (ICR) for the Pla ting and Polishing Area Source NESHAP. 1 

# This cost was

scaled to 2009 dollars using th e Consumer Price Index (CPI). 2 

# It was assumed that splashguards

would have a similar cost.

Installation costs were estimated assumi ng 8.0 labor hours and a labor rate of $30.60 per

hour. The labor rate is based on U.S. Bureau of Labor Statistics data for "Plating and Coating

Machine Setters, Operators, and Tenders, Meta l and Plastic," with a total compensation of

$14.57/hour. 3 

# An overhead rate of 110 percent was applie d to the total compen sation, resulting in

an average hourly rate of $30.60. Capital costs (installation labor and equipment) were

annualized at an interest rate of 7 percent and an estimated 5-year lifetime for equipment. This

resulted in an annualized cost of $201 per year per affected plant.

Based on general knowledge of the industry, mo st tanks are already equipped with drip

trays and splash guards. Therefore, for this anal ysis, it was estimated that 25 percent of existing

facilities would have to instal l this equipment under the propose d housekeeping requirements.

Buffing/Polishing/Grinding Barriers

The equipment cost for a barrier to isol ate buffing, polishing, and grinding operations

from chromium electroplating and anodizing tank s was estimated to be $1,168. This was based

on a cost of $1,100 taken from a 2006 report by the California Air Resources Board. 4 

# This base

cost was scaled from 2006 to 2009 dollars using th e CPI. Estimated installation costs were based

on 8.0 labor hours at a labor rate of $30.60 per ho ur. Capital costs (installation labor and

equipment) were annualized at an interest rate of 7 percent and an estimated 5-year lifetime for

equipment. This resulted in an annualized cost of $345 pe r year per affected plant.

Based on information provided in ICR re sponses to the Plating and Polishing Area

Source NESHAP, 28 percent of fac ilities that perform electroplati ng or anodizing also perform

buffing, polishing, or grinding. 5 

# It was further assumed that 50 percent of facilities that perform

those operations would have to install a barrier.

Chromium Storage and Spill Cleanup

The cost for a container to store chromium ch emicals in an enclosed area was assumed to

be $100 per facility. This cost was annualized at an interest rate of 7 percent and a 5-year

lifetime.

Clean-up costs were based on the estimated labor hours for cleaning up spills and for

cleaning surfaces that may accumulate chromium-l aden dust. The labor required for spill cleanups was estimated to be 6 hours per year, based on the assumption that one spill would occur per

month and it would take 0.5 hour to clean up th e spill. The labor for cleaning surfaces was

assumed to be 25 hours per year, based on an average of 0.5 hours per week for 50 weeks. The

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labor rate for cleaning was also assumed to be $30.60 per hour. This resulted in an annual cost

of $970 per year per affected plant.

II. Summary of Estimated Annualized Housekeeping Costs

Table 1 summarizes the annualized costs fo r installing drip trays and splash guards on

affected plants; Table 2 summarizes the annualized costs for installing ba rriers to isolate to

isolate buffing, polishing, and grinding processe s from chromium electroplating and anodizing

tanks; and Table 3 summarizes the annualized cost s for storage for chromium chemicals and for

cleaning chromium-laden dust from facility su rfaces. Table 4 provi des a summary of the

nationwide annualized costs for all proposed housekeeping measures.

III. References

1. Letter and attachments from Patrick Bradford, Oper ations Manager, Armoloy of Illinois, Inc.

DeKalb, IL. Response to Information Collecti on Request for the Plating and Polishing Area

Source NESHAP. July 15, 2006.

2. U.S. Department of Labor, Bureau of La bor Statistics. http ://www.bls.gov/CPI/.

3. United States Department of Labor, Bureau of Labor Statistics, Occupational Employment

and Wages, 51-4193 Plating and Coating Machin e Setters, Operators, and Tenders, Metal

and Plastic, available at http:// www.bls.gov/oes/current/naics4_332800.htm#51-0000.

Accessed May 2009.

4. California Air Resources Board. Proposed Amendments to the Hexavalent Chromium

Airborne Toxic Control Measure for Chro me Plating and Chromic Acid Anodizing

Operations. August 11, 2006.

5. U. S. Environmental Protection Agency. Plating and Polishing Area Source NESHAP

Database. 2007.Table 1. Estimated Annualized Costs for Installing Drip Trays and Splash GuardsElectroplatingTypeNo. ofplantsnationwideNo. oftanks perplant% withoutdrip trays orsplash guardsNo. of tankswithout drip traysor splash guardsAnnualized cost toinstall drip trays,splash guards, $/yrNationwidecost, $/yrHard chromium electroplatingSmall553125%138$201$27,738Medium158425%158$201$31,758Large79825%158$201$31,758Total790454$91,254Decorative chromium electroplatingSmall592125%148$201$29,748Medium111225%56$201$11,256Large37525%46$201$9,246Total740250$50,250Chromium anodizingSmall180125%41$201$8,241Large60225%30$201$6,030Total24071$14,271Nationwide total1,770$155,7755Table 2. Estimated Annualized Costs for Installing Barriers for Buffing, Polishing, and Grinding OperationsElectroplatingTypeNo. ofplantsnationwideEstimated %that performoperationsEstimated %that needbarrierNo. of plantsthat needbarrierAnnualized costto installbarrier, $/yrNationwidecost, $/yrHard chromium electroplatingSmall55328%50%77$345$26,710Medium15828%50%22$345$7,631Large7928%50%11$345$3,816Total790111$38,157Decorative chromium electroplatingSmall59228%50%83$345$28,594Medium11128%50%16$345$5,361Large3728%50%5$345$1,787Total740104$35,742Chromium anodizingSmall18028%50%25$345$8,694Large6028%50%8$345$2,898Total24034$11,592Nationwide total1,770$85,4916Table 3. Estimated Annualized Costs for Chromium Chemical Storage and Clean-upElectroplatingTypeNo. of plantsnationwideAnnualized storage,clean-up cost perplant, $/yrNationwidecost, $/yrHard Chromium ElectroplatingSmall553$970$536,410Medium158$970$153,260Large79$970$76,630Total790$766,300Decorative Chromium ElectroplatingSmall592$970$574,240Medium111$970$107,670Large37$970$35,890Total740$717,800Chromium AnodizingSmall180$970$174,600Large60$970$58,200Total240$970$232,800Nationwide total1,770$1,716,9007Table 4. Summary of Nationwide Annualized Costs for Proposed Housekeeping RequirementsElectroplatingTypeDrip trays,splash guardsBuffing/polishing/grinding barriersClean-up &storageTotalHard chromium electroplatingSmall$27,738$26,710$536,410$590,858Medium$31,758$7,631$153,260$192,649Large$31,758$3,816$76,630$112,204Total$91,254$38,157$766,300$895,711Decorative chromium electroplatingSmall$29,748$28,594$574,240$632,582Medium$11,256$5,361$107,670$124,287Large$9,246$1,787$35,890$46,923Total$50,250$35,742$717,800$803,792Chromium anodizingSmall$8,241$8,694$174,600$191,535Large$6,030$2,898$58,200$67,128Total$14,271$11,592$232,800$258,663Nationwide total$155,800$85,500$1,717,000$1,958,000