Date: June 27, 2012

Subject: Revised Estimated Costs for Proposed Housekeeping Requirements for 

Chromium Electroplating NESHAP

Emission Standards Technical Support and 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: 

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

• Barriers to isolate buffing, polishing, 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), have 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) regulations codified under 29 CFR 

§1910.1026(j). 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 and

barriers to isolate chromium electroplating operations.

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

Reference 1. Separate 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 includes all 

chromium electroplating and chromium anodizing facilities located outside of the State of 
2

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 2011 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. 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 

$14.56/hour.4 An overhead rate of 110 percent was applied to the total compensation, resulting in 

an average hourly rate of $30.58. 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 $221 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 $1,620. This was based 

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

cost was scaled from 2006 to 2011 dollars using the CPI. Estimated installation 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 at 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 

those operations would have to install a barrier. 

Chromium Storage and Spill Cleanup

The cost for containers to store chromium chemicals in an enclosed area and clean-up 

costs were not included in the housekeeping cost as plants are already performing these activities 

in order to comply with OSHA requirements. 
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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 electroplating 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. Memorandum 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. 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. 

6. 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 

affected 

plants 

nationwidea

Average No. 

of tanks per 

planta

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.
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Table 2. Estimated Annualized Costs for Installing Barriers for Buffing, Polishing, and Grinding Operations

Electroplating Type

No. of 

affected 

plants 

nationwidea

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.
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Table 3. Summary of Nationwide Annualized Costs for Proposed Housekeeping Requirements

Electroplating Type

No. of 

plants 

nationwidea

Drip trays -

splash guards

Buffing-PolishingGrinding 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.