D ate : June 2 7 , 2012

S ubject : Revised E stimated Costs for Proposed Housekeeping Requirements for Chromium Electroplating NESHAP Emission Standards Technical Support a nd Post Promulgation Activities

Contract No. EP

- D

- 11

- 084; EPA Work Assignment No. 0

- 07 RTI Project No. 0213199.000.007

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:

• D rip trays and splashguards on chromium electroplating and anodizing tanks

.

• Barriers to isolate buffing

, po lishing , and grinding operations from chromium electroplating and anodizing tanks

.

The following section describes the basis for the cost estimates. The housekeeping costs, which originally were estimated for the October 2010 proposal (75 FR 65068, October 21, 2010), ha ve been revised to reflect 2011 dollars . In addition, costs related to chromium storage and spill clean

- up have been eliminated because those measures are already required by Occupational Safety and Health Administration (OSHA) regulat ions codified under 29 CFR §1910.1026(j)

. Section II summarizes the costs. References are provided in Section III.

I. Ba s is for Annualized Housekeeping Costs

This section provides the basis for the costs associated with the proposed housekeeping requi rements. Annualized costs were estimated for installing drip trays and splashguards and barriers to isolate chromium electroplating operations.

N ationwide costs were estimated using typical plant tank characteristics, as presented in

Reference 1

. Sep arate estimates were made for four subcategories of electroplating facilities: large hard chromium electroplating, small hard chromium electroplating, decorative chromium electroplating, and chromium anodizing facilities. The number of affected plants inc ludes all chromium electroplating and chromium anodizing facilities located outside of the State of2

California. The California plants were excluded because those facilities are already required to perform the housekeeping requirements under the California Airborne Toxic Control Measure (ATCM) for Chromium Plating and Chromium Anodizing Facilities

.

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. 2 This cost was

scaled to 20 11 dollars using the Consumer Price Index (CPI). 3 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. 58 per hour. Th e labor rate is based on U.S. Bureau of Labor Statistics data for " Plating and Coating Machine Setters, Operators, and Tenders, Metal and P lastic, " with a total compensation of $14. 5 6 /hour. 4 An overhead rate of 110 percent was applied to th e total compensation

, resulting in

an average hourly rate of $30. 58

. Capital costs (installation labor and equipment) were

annualized a t an interest rate of 7 percent and an estimated 5

- year lifetime for equipment. This resulted in an annualized cost of $ 221 per year per affected plant.

Based on general knowledge of the industry, most tanks are already equipped with drip trays and splash guards. Therefo re, 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

, 620 . This was based

on a cost of $1,100 taken from a 2006 report by the C alifornia Air Resources Board. 5 This base

cost was scaled from 2006 to 20 11 dollars using the CPI. Estimated i nstallation costs were based

on 8.0 labor hours at a labor rate of $30. 58 per hour. Capital costs (installation labor and equipment) were annualized a t an interest rate of 7 percent and an estimated 5

- year lifetime for equipment. This resulted in an annualized cost of $ 395 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. 6 It was further assumed that 50 percent of facilities that perform

th o se operations would have to install a barrier.

Chromium Storage and Spill Cleanup

The cost for container s to store chromium chemicals in an enclosed area and c lean

- up

costs were n ot included in the housekeeping cost as plants are already performing these activities in order to comply with OSHA requirements.3

II. Summary of Estimated Annualized Housekeeping Costs

Table 1 summarizes the annualized costs for installing drip trays and splash guards on affected plants and Table 2 summarizes the annualized costs for installing barriers to isolate to isolate buffing

, polishing , and grinding processes from chromium electr oplating and anodizing

tanks

. Table 3 provides a summary of the nationwide capital and annualized costs for all proposed housekeeping measures. Nationwide annualized costs for the affected plants are estimated to be $227,500 per year.

III

. References

1

. Me morandum from C. Hancy and R. Marinshaw, RTI International, to P. Mulrine , U.S. Environmental Protection Agency

, Profile of Chromium Electroplating Processes and

Emissions

. June 27, 2012

.

2

. 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.

3

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

4

. 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.

5

. Calif ornia Air Resources Board. Proposed Amendments to the Hexavalent Chromium Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations

. August 11, 2006.

6

. U. S. Environmental Protec tion 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

affected

plants

nationwide a Average No. of tanks per plant a Estimated

% without drip trays & splash guards (a) No. of tanks without drip trays & splash guards Annualized drip tray

- splash guard cost per tank, $/yr Annualized

Nationwide

cost, $/yr
Hard chromium, large 188 5.70 25% 268 $221 $59,228

Hard chromium, small 394 2.61 25% 257 $221 $56,797

Decorative chromium 423 1.65 25% 174 $221 $38,454
Chromium Anodizing 140 1.26 25% 44 $221 $9,724

Nationwide Total 1,145 743 $164,203

a Reference 1.5

Table 2

. Estimated Annualized Costs for Installing Barriers for Buffing, Polishing, and Grinding Operations

Electroplating Type No. of

affected

plants

nationwide a Estimated % that perform

mechanical polishing (a) Estimated %

that need

barrier No. of facilities needing

barriers Annualized

barrier cost

per plant, $/yr Nationwide cost, $/yr
Hard chromium, large 188 28% 50% 26 $395 $10,396

Hard chromium, small 394 28% 50% 55 $395 $21,788

Decorative chromium 423 28% 50% 59 $395 $23,392
Chromium Anodizing 140 28% 50% 20 $395 $7,742

Nationwide Total 1,145 160 $63,319

a Reference 1.6

Table 3

. Summary of Nationwide Annualized Costs for Proposed Housekeeping Requirements

Electroplating Type No. of plants

nationwide a Drip trays

- splash guards Buffing

- Polishing

Grinding barriers Total Capital

Nationwide cost, $
Hard chromium, large 188 $59,228 $10,396 $69,624 $285,897

Hard chromium, small 394 $56,797 $21,788 $78,585 $322,654

Decorative chromium 423 $38,454 $23,392 $61,846 $253,901
Chromium Anodizing 140 $9,724 $7,742 $17,466 $71,700

Nationwide total 1,145 $164,203 $63,319 $227,522 $934,152

a Reference 1.