Date: August 12, 2010 

Subject: Estimated Costs for Proposed Housekeeping Requirements for Chromium 

Electroplating NESHAP 

Emission Standards Technical Support 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 labor costs associated with: 

• Drip trays and splashguards on chromium electroplating and anodizing tanks; 

• Barriers to isolate buffing, polishing, and 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 costs associated with the proposed housekeeping 

requirements. Annualized costs were estimated for installing drip trays and splashguards, 

barriers to isolate chromium electroplating operations, 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 made for three subcategories of 

electroplating facilities: hard chromium electroplating, decorative 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 trays and splashguards on affected tanks, a unit 

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

collection request (ICR) for the Plating and Polishing Area Source NESHAP.1 This cost was 

scaled to 2009 dollars using the Consumer Price Index (CPI).2 It was assumed that splashguards 

would have a similar cost. 

 Installation costs were estimated assuming 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, Metal and Plastic," with a total compensation of 

$14.57/hour.3

 An overhead rate of 110 percent was applied to the total compensation, 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, most tanks are already equipped with drip 

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

facilities would have to install this equipment under the proposed housekeeping requirements. 

Buffing/Polishing/Grinding Barriers

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

from chromium electroplating and anodizing tanks 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 the CPI. Estimated installation costs were based 

on 8.0 labor hours at a labor rate of $30.60 per hour. 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 per year per affected plant. 

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

Source NESHAP, 28 percent of facilities that perform electroplating 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 chemicals 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-laden 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 the 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 for installing drip trays and splash guards on 

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

isolate buffing, polishing, and grinding processes from chromium electroplating and anodizing 

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

cleaning chromium-laden dust from facility surfaces. Table 4 provides a summary of the 

nationwide annualized costs for all proposed housekeeping measures. 

III. References

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

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

Source NESHAP. July 15, 2006. 

2. U.S. Department of Labor, Bureau of Labor 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 Machine 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 Chrome 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 Guards 

Electroplating Type 

No. of 

plants 

nationwide 

No. of 

tanks per 

plant 

% without 

drip trays or 

splash guards 

No. of tanks 

without drip trays 

or splash guards 

Annualized cost 

install drip tray

splash guards, $

Hard chromium electroplating 

Small 553 1 25% 138 $Medium 158 4 25% 158 $Large 79 8 25% 158 $

Total 790 454 

Decorative chromium electroplating 

Small 592 1 25% 148 $Medium 111 2 25% 56 $Large 37 5 25% 46 $

Total 740 250 

Chromium anodizing 

Small 180 1 25% 41 $Large 60 2 25% 30 $

Total 240 71 

Nationwide total 1,770 
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Table 2. Estimated Annualized Costs for Installing Barriers for Buffing, Polishing, and Grinding 

Electroplating Type 

No. of 

plants 

nationwide 

Estimated % 

that perform 

operations 

Estimated % 

that need 

barrier 

No. of plants 

that need 

barrier 

Annualized co

to install 

barrier, $/yr 

Hard chromium electroplating 

Small 553 28% 50% 77 $3Medium 158 28% 50% 22 $3Large 79 28% 50% 11 $3

Total 790 111 

Decorative chromium electroplating 

Small 592 28% 50% 83 $3Medium 111 28% 50% 16 $3Large 37 28% 50% 5 $3

Total 740 104 

Chromium anodizing 

Small 180 28% 50% 25 $3Large 60 28% 50% 8 $3

Total 240 34 

Nationwide total 1,770 
6 

Table 3. Estimated Annualized Costs for Chromium Chemical Storage and Clean-up 

Electroplating Type 

No. of plants 

nationwide 

Annualized storage, 

clean-up cost per 

plant, $/yr 

Nationwide 

cost, $/yr 

Hard Chromium Electroplating 

Small 553 $970 $536,410Medium 158 $970 $153,260Large 79 $970 $76,630

Total 790 $766,300

Decorative Chromium Electroplating 

Small 592 $970 $574,240Medium 111 $970 $107,670Large 37 $970 $35,890

Total 740 $717,800

Chromium Anodizing 

Small 180 $970 $174,600Large 60 $970 $58,200

Total 240 $970 $232,800

Nationwide total 1,770 $1,716,900
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Table 4. Summary of Nationwide Annualized Costs for Proposed Housekeeping Requirem

Electroplating Type 

Drip trays, 

splash guards 

Buffing/polishing/ 

grinding barriers 

Clean-up & 

storage Total 

Hard chromium electroplating 

Small $27,738 $26,710 $536,410 $590Medium $31,758 $7,631 $153,260 $192Large $31,758 $3,816 $76,630 $112

Total $91,254 $38,157 $766,300 $895

Decorative chromium electroplating 

Small $29,748 $28,594 $574,240 $632Medium $11,256 $5,361 $107,670 $124Large $9,246 $1,787 $35,890 $46

Total $50,250 $35,742 $717,800 $803

Chromium anodizing 

Small $8,241 $8,694 $174,600 $191Large $6,030 $2,898 $58,200 $67

Total $14,271 $11,592 $232,800 $258

Nationwide total $155,800 $85,500 $1,717,000 $1,958