Date: July 16, 2010 

(Revised: September 8, 2010) 

Subject: Emissions Reductions and Cost Effectiveness of HEPA Filter Retrofits for 

Chromium Electroplating 

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: James Cunningham 

 Richard Marinshaw 

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

The purpose of this memorandum is to present the estimated emissions reductions, costs, 

and cost effectiveness of retrofitting high efficiency particulate air (HEPA) filters on all existing 

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). Retrofitting HEPA filters 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 presents estimated baseline emissions of chromium 

compounds from existing electroplating and anodizing tanks subject to the NESHAP. Emissions 

reductions associated with retrofitting HEPA filters on all existing affected sources are presented 

in Section II. Section III describes the basis for, and results of, the cost estimates for HEPA filter 

retrofits nationwide, and the resulting cost-effectiveness is summarized in Section IV. 

References are provided in Section V. 

I. Baseline Emissions for Chromium Electroplating and Anodizing Sources

 The basic methodology used to estimate baseline emissions from chromium 

electroplating and anodizing sources was as follows: 

1. Estimate the number of plants of each type (hard chromium electroplating, decorative 

chromium electroplating, and chromium anodizing); 

2. For each type of plant, estimate the number of each size (small, medium, large); 

3. Estimate uncontrolled emissions from each plant type and size; 

4. Estimate control method distribution and apply control efficiencies; and 

5. Sum up the controlled emissions nationwide. 

 
2 

Estimated Number of Plants by Type

 Table 1 summarizes the estimated number of chromium electroplating and anodizing 

plants nationwide. The basis for these estimates is provided in Reference 1. 

Table 1. Estimated Number of Chromium Electroplating Plantsa

Process 

Estimated No. 

of plants 

Hard chromium electroplating 790 

Decorative chromium electroplating 740 

Chromium anodizing 240 

Total 1,770 a Reference 1. 

Estimated Number of Plants by Size

 The numbers of chromium electroplating and anodizing plants by size were estimated 

using the model plants and plant distributions developed for the NESHAP and documented in 

Chromium Emissions from Chromium 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 chromium electroplating, and 

two sizes of model plants (small and large) were developed for chromium anodizing. Table 2 

summarizes the resulting nationwide breakdown of plants by type and size. 

Table 2. Distribution of Model Plants by Size and Typea

Electroplating Type Size % of total 

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. 
3 

Uncontrolled Emissions from Model Plants

 The uncontrolled model plant emissions developed for the NESHAP were used in the 

determination of baseline chromium compound emissions. Table 3 summarizes these emissions. 

Table 3. Uncontrolled Chromium Compound Emissions from Model Plantsa

Electroplating Type Size 

Uncontrolled Cr 

emissions, lbs/yr 

Hard Chromium 

Small 110 

Medium 926 

Large 3,530 

Decorative Chromium 

Small 13 

Medium 53 

Large 530 

Chromium Anodizing Small 7.2 

Large 88 a

 Reference 2; emissions in units of pounds per year (lbs/yr). 

Control Efficiencies and Control Method Distribution

 To determine controlled (baseline) emissions nationwide, assumptions were made about 

the numbers and types of emission control technologies in use, and the control levels (control 

efficiencies) achieved by those technologies. For hard chromium electroplating tanks, the most 

commonly used controls are the composite mesh pad (CMP), packed bed scrubber (PBS), and 

mesh pad mist eliminator (MPME). In addition, as the result of the 2005 amendments to the 

NESHAP, some hard chromium electroplating tanks are controlled using only a wetting agent 

fume suppressant (WAFS). To estimate the impacts of the original NESHAP, the assumed 

control efficiencies for these devices were 99.5 percent for CMP and 99.0 percent for PBS and 

MPME. For WAFS, a control efficiency of 99.5 percent was used. For decorative chromium 

electroplating tanks and chromium anodizing tanks, the controls used include PBS, MPME, and 

CMP, but most tanks are controlled using WAFS. The same control efficiencies indicated above 

for hard chromium electroplating also apply to decorative chromium electroplating and 

chromium anodizing. A summary of the control efficiencies used is presented in Table 4. 

Table 4. Efficiencies of Chromium Electroplating Emission Controlsa

Control Method Efficiency, % 

Composite mesh pad (CMP) 99.5 

Packed bed scrubber (PBS) 99.0 

Mesh pad mist eliminator (MPME) 99.0 

Wetting agent fume suppressant (WAFS) 99.5 a Reference 2. 

 The distribution of emission control methods among the various types of chromium 

electroplating plants and plant sizes was estimated based on general knowledge of the industry. 

Large hard chromium electroplating plants generally are controlled with CMPs; some PBSs are 
4 

also used. For medium and small hard chromium electroplating plants, PBSs are more common. 

Some medium and small plants also use WAFS to control emissions. As noted above, WAFS is 

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 

distribution, the percentage of plants that use WAFS was first assumed; then the percentages of 

each type of add-on control devices were estimated. Since the control efficiencies for PBS and 

MPME are comparable, no distinctions were made between the two with respect to their 

distribution. Table 5 summarizes the assumed distribution of these controls among the various 

types of model plants. The resulting numbers of plants are summarized in Table 6. 

Table 5. Distribution of Emission Controls by Size and Type of Plant 

Electroplating Type 

Model 

Plant Size 

% of Total 

CMP PBS/MPME WAFS 

Hard Chromium 

Small 16 64 20 

Medium 56 37 7 

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 6. Distribution of Model Plants by 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 88 59 11 158 

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 60 

Total 240 

 

Controlled Emissions for Model Plants

 

 A review of the uncontrolled model plant emissions presented in Table 3, and the 

resulting emissions when controlled efficiencies are applied to those emissions, shows that the 

model plant emissions appear to be representative of existing chromium electroplating emissions 

for decorative chromium electroplating and for chromium anodizing plants. However, for hard 
5 

chromium electroplating plants, the uncontrolled emission rate for large model plants appears to 

overstate emissions. For example, if the control efficiency for a PBS (99 percent) is applied to 

the uncontrolled emissions, the resulting emission rate would be 35.3 lbs/yr. However, based on 

the model plant parameters developed for the NESHAP, a large size model plant operating at the 

emission limit would emit no more than 23.6 lbs/yr. A discussion of the basis for this conclusion 

is provided in Reference 3. For the reasons explained in Reference 3, an annual emission rate of 

9.26 lbs/yr is assumed for large hard chromium electroplating plants. This would correspond to 

uncontrolled emissions of 1,852 lbs/yr and a control efficiency of 99.5 percent. 

 With the exception of emissions for large hard chromium electroplating plants, the 

control efficiencies listed in Table 4 were applied to the uncontrolled emissions listed in Table 3 

to determine annual emission rates by model plant type, size, and emissions control method. 

Table 7 summarizes the resulting controlled emissions used to estimate nationwide baseline 

emissions from chromium electroplating and anodizing plants. 

Table 7. Controlled Chromium Compound Emissions from Model Plants 

Source type Control Method 

Model Plant Emissions, lbs/yr 

Large Medium Small 

Hard chromium 

 

 

PBS/MPME 9.26 9.26 1.10

WAFS 9.26 4.63 0.55

CMP 9.26 4.63 0.55

Decorative chromium 

 

 

PBS/MPME 5.30 0.53 0.13

WAFS 2.65 0.27 0.065

CMP 2.65 0.27 0.065

Chromium anodizing 

 

 

PBS/MPME 0.88 NA 0.072

WAFS 0.44 NA 0.036

CMP 0.44 NA 0.036

 NA = not applicable; no medium size model developed for NESHAP. 

Estimated Controlled Baseline Emissions

 

 Using the data and distributions discussed above and summarized in Tables 1 through 7, 

nationwide baseline emissions of chromium compounds were estimated to be 2,484 lbs/yr 

(1.24 tons per year [tons/yr]). This total is comprised of 2,235 lbs/yr (1.12 tons/yr) for hard 

chromium electroplating, 207 lbs/yr (0.10 tons/yr) for decorative chromium electroplating, and 

42 lbs/yr (0.021 tons/yr) for chromium anodizing. Table 8 summarizes the results by model 

plant type and size. 
6 

Table 8. Estimated Baseline Emissions of Chromium Compounds 

Electroplating Type Model Plant Size 

Nationwide Emissions 

lbs/yr tons/yr 

Hard Chromium 

Small 499 0.25 

Medium 1,005 0.50 

Large 732 0.37 

Total 2,235 1.12 

Decorative Chromium 

Small 42.3 0.021 

Medium 34.7 0.017 

Large 130 0.065 

Total 207 0.10 

Chromium Anodizing 

Small 7.1 0.0036 

Large 34.8 0.017 

Total 41.9 0.021 

Nationwide total 2,484 1.24 

I. Estimated Emissions Reductions for HEPA Filter Retrofit

 To estimate the emissions reductions that would be achieved by retrofitting HEPA filters 

on all existing sources subject to the Chromium Electroplating NESHAP, the control efficiency 

of HEPA filters was first applied to uncontrolled baseline emissions. By definition, HEPA filters 

are designed to remove at least 99.97 percent of airborne particles that are 0.3 micrometers (μm) 

or larger in diameter. The only available particle size data for uncontrolled emissions from 

chromium electroplating sources, as summarized in Table 9, indicates that chromic acid mist 

emitted from hard chromium electroplating is comprised almost entirely of particles larger than 

0.3 μm. On this basis, it was assumed that HEPA filters would generally remove 99.97 percent 

of uncontrolled emissions from hard chromium electroplating, decorative chromium 

electroplating, and chromium anodizing sources. 

Table 9. Particle Size Data for Uncontrolled Hard Chromium Electroplating Emissionsa

Particle Size, μm Cumulative % less than 

8 82.6% 

2.4 67.7% 

0.5 6.9% a

 Reference 4. 

 From a model plant perspective, Table 10 summarizes the resulting nationwide emissions 

of chromium compounds from hard chromium electroplating, decorative chromium 

electroplating, and chromium anodizing assuming all existing tanks are retrofit with HEPA 

filters. The table also shows the emissions reductions from baseline that would result from this 

option. Based on this analysis, retrofitting HEPA filters on all existing tanks subject to the 

NESHAP would reduce nationwide emissions by 2,366 lbs/yr (1.18 tons/yr) from 2,484 lbs/yr 

(1.24 tons/yr) to 118 lbs/yr (0.059 tons/yr). 
7 

Table 10. Estimated Emissions Reductions for HEPA Filter Retrofit - Model Plant Basis 

Electroplating Type 

Model Plant 

Size 

Nationwide Emissions, lbs/yr 

Baseline 

HEPA Filter 

Retrofit 

Net Emissions 

Reductions 

Hard Chromium 

Small 499 18.2 481 

Medium 1,005 43.9 961 

Large 732 43.9 688 

Total 2,235 106 2,129 

Decorative Chromium 

Small 42.3 2.3 40.0 

Medium 34.7 1.8 33.0 

Large 130 5.9 124 

Total 207 10.0 197 

Chromium Anodizing 

Small 7.1 0.39 6.7 

Large 34.8 1.6 33.2 

Total 41.9 2.0 39.9 

Nationwide total 2,484 118 2,366 

 With respect to emissions limits, the Chromium Electroplating NESHAP distinguishes 

between four types of plants: large hard chromium electroplating, small hard chromium 

electroplating, decorative chromium electroplating, and chromium anodizing. Large hard 

chromium electroplating plants are defined as those that have a maximum cumulative potential 

rectifier capacity of at least 60 million ampere-hours per year (amp-hr/yr), and small facilities are 

those with a maximum cumulative potential rectifier capacity less than 60 million amp-hr/yr. 

These size distinctions differ from the model plant sizes for hard chromium electroplating. All 

large model plants would be classified as large hard chromium plants under the NESHAP, and 

all small model plants would be classified as small hard chromium plants under the NESHAP. 

However, the larger portion of medium size model plants would be classified as small, and the 

remainder would be classified as large under the NESHAP. For this analysis, it was assumed 

that 67 percent of the medium size model plants are small hard chromium plants under the 

NESHAP, and that those plants account for 67 percent of the emissions from medium size model 

plants. The remaining medium size model plants, and the emissions attributed to those plants, 

are assumed to represent large hard chromium plants under the NESHAP. Table 11 summarizes 

baseline emissions, emissions under the HEPA filter retrofit option, and the corresponding 

emissions reductions based on these assumptions. 

Table 11. Estimated Emissions Reductions for HEPA Filter Retrofit - NESHAP Basis 

Plant Type 

No. of 

plants 

Nationwide Emissions, lbs/yr 

Baseline 

HEPA Filter 

Retrofit 

Net Emissions 

Reductions 

Large Hard Chromium 132 1,169 48 1,121 

Small Hard Chromium 658 1,066 59 1,008 

Decorative Chromium 740 207 10.0 197 

Chromium Anodizing 240 41.9 2.0 39.9 

Total 1,770 2,484 118 2,366 
8 

III. HEPA Filter Retrofit Costs

 This section describes the methodology, data, and assumptions used to estimate the costs 

of retrofitting HEPA filters on existing sources subject to the Chromium Electroplating 

NESHAP. In estimating costs, distinctions were made between emission control systems with 

existing add-on controls, and sources that use WAFS and are not equipped with add-on controls. 

For systems with existing add-on controls, a retrofit factor was incorporated into the basic HEPA 

filter system cost. For systems without existing add-on controls, a retrofit factor was not applied 

to the costs. However, it was necessary to include costs of an exhaust and ventilation system 

(hoods, ductwork, and fans) and a primary control device to remove the larger particles in the 

exhaust stream prior to the HEPA filter. The following sections provide additional details on 

how these costs were estimated. 

Sources with Existing Add-On Controls

 Cost estimates were requested from three vendors for the complete installation new 

HEPA filter systems on systems designed for four exhaust flow rates: 6,000, 12,000, 18,000, 

and 40,000 actual cubic feet per minute (ACFM). Estimates were received from Oskar 

Environmental Inc. of Youngsville, NC and Flanders/CSC of Washington, NC. Because the 

quotes were for budgetary purposes, detailed itemization was not provided. The Flanders quote 

included an itemized list of components, but only a total cost for each system. The Oskar quote 

was itemized by the following: 1) fan and HEPA housing; 2) ducting and installation; 

3) estimated freight; and 4) filter replacement cost. The estimated freight and filter replacement 

costs were assumed equal to normalize the quotes for comparison. The quotes are presented in 

Appendix A of this document. 

 The capital and annual costs for each system were determined by the methods described 

in the EPA Air Pollution Control Cost Manual (Reference 5). Presented in Table 12 are the 

capital costs categories and the source of those rates, if not provided in the cost quotes. 

Table 12. Cost Components and Assumptions Used to Estimate HEPA Filter Retrofit Costs 

Cost Component Oskar Environmental Flanders 

System Included Included 

Instrumentation Not included; assumed 11% of 

equipment cost 

Not included; assumed 11% of 

equipment cost 

Sales tax Assumed 6% Assumed 6% 

Freight Included Not included (used Oskar quote) 

Installation Included Included, but not itemized (used 

Oskar quote) 

Performance testing Not included; assumed 0.7% of 

installation cost 

Not included; assumed 0.7% of 

installation cost 

Contingencies Assumed 2.1% of installation cost Assumed 2.1% of installation cost 

Retrofit Cost Assumed 50% of capital cost Assumed 50% of capital cost 
9 

 Table 13 presents the annual cost categories considered in the estimate, the assumptions 

used, and the information source. The filter replacement costs were provided in each quote, 

while the additional information was derived from various sources. For electricity costs, a unit 

price of $0.14 per kilowatt hour (kW-hr) was used (Reference 6). 

Table 13. Annual Cost Components and Assumptions Used for HEPA Retrofit Costs 

Cost Component Source/Method 

Labor hours CA ARBa

Filter Replacement Quotes 

Filter Disposal $930/5000 ft3/min.a

Electricity $0.14/kwhr 

Property Tax & Insurance 4% of capital costb

 a

 Reference 7. 

 b Reference 5. 

 The average total annual cost for each system was determined from the two quotes, and 

the resulting cost curve was determined using an interest rate of 7% and 20-year lifetime. The 

cost curve plotted exhaust flow (independent variable) versus total annual cost (dependent 

variable) and resulted in a R2 value of 0.999. The equation of the best-fit line was then used to 

determine the total annual cost for the model facilities for hard plating, decorative plating, and 

anodizing facilities. Presented in Figure 1 is the cost curve for retrofitting a new HEPA filter 

system on a chromium electroplating source with existing add-on controls. 

y = 2.2309x + 13138

R2 = 0.9995

‐

20,000

40,000

60,000

80,000

100,000

120,000

‐ 10,000 20,000 30,000 40,000 50,000

Total Annual Cost, $

Exhaust Flow, ft3/min.

Figure 1. Annualized Cost Curve for Retrofitting new HEPA Filter on Existing 

Chromium Electroplating Source with Existing Add-on Controls. 

 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 
10 

to retrofit a new HEPA filter on all sources subject to the NESHAP with existing add-on controls 

is $54.1 million. Table 14 shows the detailed cost and number of facilities for each type of 

model plant. 

Table 14. Nationwide Annualized Costs for HEPA Retrofit - Sources with Add-on Controls 

Model 

Plant Size 

Exhaust Flow 

Rate, ACFM 

Number of 

Facilities 

Annualized Cost per 

Model Plant, $/yr 

Total Nationwide 

Annualized Cost, $/yr 

Hard Chromium Electroplating

Small 12,000 442 $39,909 17,640,000 

Medium 35,000 147 $91,220 13,409,000 

Large 70,000 79 $169,301 13,375,000 

Decorative Chromium Electroplating

Small 12,000 59 $39,909 $2,355,000 

Medium 24,000 22 $66,680 $1,467,000 

Large 76,000 15 $182,686 $2,740,000 

Chromium Anodizing

Small 12,000 18 $39,909 $718,000 

Large 40,000 24 $102,374 $2,457,000 

Total Nationwide Annualized Costs $54,161,000 

Sources without Existing Add-On Controls

 For existing chromium electroplating and anodizing sources that are not equipped with 

add-on controls, the same basic methodology was used as described in the previous paragraphs. 

However, the 50 percent retrofit factor was excluded from the calculations, and the costs for 

installing an exhaust system and a primary control device were included. For the primary control 

device, it was assumed that a mesh pad mist eliminator (MPME) would be used. To estimate the 

cost of installing an exhaust system and MPME, the cost model developed for the NESHAP 

(Reference 2) was used and converted to 2009 dollars using the Consumer Price Index 

(Reference 8). The cost of a new HEPA filter system was added to these costs and a similar cost 

curve was developed. Figure 2 shows the resulting cost curve. 
11 

y = 2.0635x + 12960

R2 = 0.9996

‐

20,000

40,000

60,000

80,000

100,000

120,000

‐ 10,000 20,000 30,000 40,000 50,000

Total Annual Cost, $

Exhaust Flow, ft3/min.

Figure 2. Annualized Cost Curve for Retrofitting new HEPA Filter on Existing 

Chromium Electroplating Source without Existing Add-on Controls. 

 The cost curve was used to estimate the cost per model plant, which was then multiplied 

by the number of plants nationwide. The resulting annualized cost to retrofit a new HEPA filter 

on all sources subject to the NESHAP without existing add-on controls was estimated to be 

$67.3 million. Table 15 shows a breakdown of the annualized costs for these sources. 

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

Model 

Plant Size 

Exhaust Flow 

Rate, ACFM 

Number of 

Facilities 

Annualized Cost per 

Model Plant, $/yr 

Total Nationwide 

Annualized Cost, $/yr 

Hard Chromium Electroplating

Small 12,000 111 $54,981 $6,102,900 

Medium 35,000 11 $138,286 $1,521,150 

Large 70,000 0 $271,566 $0 

Decorative Chromium Electroplating

Small 12,000 533 $55,524 $29,594,200 

Medium 24,000 89 $98,627 $8,777,800 

Large 76,000 22 $257,459 $5,664,100 

Chromium Anodizing

Small 12,000 162 $55,524 $8,994,900 

Large 40,000 36 $185,712 $6,685,600 

Total Nationwide Annualized Costs $67,341,000 

 As noted previously, the sources that are not equipped with add-on controls are currently 

controlled using WAFS. After these sources are equipped with CMPs, it is assumed that WAFS 

would no longer be used for emission control. Thus, the costs these facilities currently incur for 

WAFS can be considered a savings after CMP retrofit. Table 16 summarizes the estimated 
12 

annual WAFS cost per model plant. These costs are based on a unit WAFS cost of $186 per 

gallon, an initial WAFS addition (dose) of 0.0025 gallons of WAFS per gallon of electroplating 

tank solution, and maintenance additions of 0.0075 milliliters of WAFS per ampere-hour. 

Reference 9 provides the basis for these costs. 

Table 16. WAFS Cost Savings Following CMP Retrofit 

Electroplating 

Plant Type, Size 

Annual 

Production rate 

per facility, Amphrs/yra

Tank capacity 

per facility, 

gala

Initial Addition 

WAFS Cost per 

facility, $b

Maintenance 

Cost per 

facility, $/yrb

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 

Large 160,000,000 16,340 NAc NAc NAc

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 9 for basis of these costs. 

c

 Not applicable; it is assumed that no tanks at large hard chromium plants use WAFS. 

 The cost savings indicated in Table 16 were subtracted from the HEPA filter costs shown 

in Table 15 to result in the net annualized cost of $63.1 million, as shown in Table 17. 

 

Table 17. Net Annualized Costs for HEPA Filter Retrofit - Sources without Add-on Controls 

Model 

Plant Size 

Number of 

Facilities 

Total Nationwide 

Annualized Cost, $/yr 

WAFS 

Savings, $/yr 

Net Nationwide 

Annualized Cost, $/yr 

Hard Chromium Electroplating

Small 111 $6,102,900 $293,846 $5,809,091 

Medium 11 $1,521,150 $212,056 $1,309,094 

Large 0 $0 $0 $0 

Decorative Chromium Electroplating

Small 533 $29,594,200 $1,018,148 $28,576,094 

Medium 89 $8,777,800 $536,808 $8,241,027 

Large 22 $5,664,100 $1,207,117 $4,456,977 

Chromium Anodizing

Small 162 $8,994,900 $477,701 $8,517,172 

Large 36 $6,685,600 $518,318 $6,167,296 

Total Nationwide Annualized Costs $63,077,000 
13 

Table 18 shows the combined annualized costs by model plant type and size for existing sources 

with add-on controls and sources without add-on controls. Total nationwide annualized costs are 

estimated to be $117 million. Table 19 shows the same costs based on the source types and sizes 

specified in the NESHAP. 

Table 18. Nationwide Annualized Costs for HEPA Retrofit - All Sources 

Model Plant Size Number of 

Facilities 

Total Nationwide 

Annualized Cost, $/yr 

Hard Chromium Electroplating

Small 553 $23,448,800 

Medium 158 $14,718,400 

Large 79 $13,374,800 

Total $51,541,900 

Decorative Chromium Electroplating

Small 592 $30,930,700 

Medium 111 $9,708,000 

Large 37 $7,197,300 

Total $47,836,000 

Chromium Anodizing

Small 180 $9,235,500 

Large 60 $8,624,300 

Total $17,859,800 

Total Nationwide Annualized Costs $117,238,000 

Table 19. Nationwide Annualized Costs for HEPA Retrofit - NESHAP Basis 

Facility Typea Number of 

Facilities 

Total Nationwide 

Annualized Cost, $/yr 

Small Hard Chromium 658 $33,261,000 

Large Hard Chromium 132 $18,280,900 

Decorative Chromium 740 $47,836,000 

Chromium Anodizing 240 $17,859,800 

Total 1,770 $117,238,000 a As defined in NESHAP. 

IV. Cost Effectiveness for HEPA Filter Retrofit

 Table 20 presents the cost effectiveness for retrofitting HEPA filters on all existing tanks 

that are subject to the Chromium Electroplating NESHAP. The cost effectiveness ranges from 

$36.3 million per ton for large hard chromium electroplating plants to $895 million per ton for 

chromium anodizing plants. Overall cost effectiveness was estimated to be $99.1 million per 

ton. 
14 

Table 20. Cost Effectiveness for HEPA Filter Retrofit 

Facility Typea

Emissions 

reductions, 

tons/yr 

Annualized costs, 

$/yr 

Cost Effectiveness 

$/lb $/ton 

Small Hard Chromium 0.56 $33,261,000 $29,670 $59,334,000

Large Hard Chromium 0.50 $18,280,900 $18,140 $36,274,000

Total 1.06 $51,541,900 $24,210 $48,417,000

Decorative Chromium 0.098 $47,836,000 $242,920 $485,833,000

Chromium Anodizing 0.020 $17,859,800 $447,440 $894,887,000

Total 1.18 $117,238,000 $49,550 $99,106,000 a

 As defined in NESHAP. 

V. References

1. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, EPA/OAQPS. 

Estimated Number of Chromium Electroplating Plants. May 24, 2010. 

2. U.S. EPA. Chromium Emissions from Chromium Electroplating and Chromic Acid 

Anodizing Operations -- Background Information for Proposed Standards, Volume I (EPA 

453/R-93-030a). U.S. Environmental Protection Agency, Research Triangle Park, NC. July 

1993. 

3. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, EPA/OAQPS. Model 

Plant Data Used to Estimate Risk from Chromium Electroplating Sources. August 27, 2010. 

4. U.S. EPA. Compilation of Air Pollutant Emission Factors, Volume 1, Stationary Sources, 

Section 12.20, Electroplating. U.S. Environmental Protection Agency, Research Triangle 

Park, NC. June 2006. 

5. U.S. EPA. EPA Air Pollution Control Cost Manual, EPA/ 452/B-02-001. U.S. 

Environmental Protection Agency, Research Triangle Park, NC 2002. 

6. South Coast Air Quality Management District. Final Socioeconomic Assessment for 

Proposed Amendments to Rule 1469 – Hexavalent Chromium Emissions from Chrome 

Plating and Chromic Acid Anodizing Operations and Proposed Rule 1426 – Emissions from 

Metal Finishing Operations. 2003. 

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

Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing 

Operations. 2003 

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

9. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, EPA/OAQPS. 

Nationwide Costs for Conversion to Non-PFOS Fume Suppressants. August 16, 2010.
Appendix A 

 



Oskar Environmental Inc. 

95 Cypress Drive 

Youngsville, NC 27596 

www.oskarsales.com

ph: (919) 570-2862 

fx: (919) 570-2863 

mobile: (919) 971-2017 

esithes@oskarsales.com

Your solution to cleaner air... 

January 29, 2010 

James H. Cunningham, Ph.D. 

Senior Research Environmental Science Engineer 

RTI International 

919.541.8834 

Email: jcunningham@rti.org

Re: Budget Summary 

Dear James: 

The following budgetary project summary is broken out per your request. Industrial Air Quality, 

Inc. and Oskar Air Products, Inc. has formally joined together to become Oskar Environmental Inc. 

This allows us to offer better engineering and support to our customers. The numbers have 

slightly changed once we started to break the items out. We also included an estimated freight 

cost not previous provided. 

System #1 

• 6,000 CFM Fan, HEPA Housing $22,000.00 

• Ducting and installation $16,000.00 

• Estimated Freight $2,000.00 

• HEPA Replacement Costs $2,600.00 

System #2 

• 12,000 CFM Fan, HEPA Housing $25,000.00 

• Ducting and installation $18,000.00 

• Estimated Freight $3,800.00 

• HEPA Replacement Costs $4,800.00 

System #3 

• 18,000 CFM Fan, HEPA Housing $32,000.00 

• Ducting and installation $20,000.00 

• Estimated Freight $4,750.00 

• HEPA Replacement Costs $8,800.00 

System #4 

• 40,000 CFM Fan, HEPA Housing $62,000.00 

• Ducting and installation $22,000.00 

• Estimated Freight $8,000.00 

• HEPA Replacement Costs $12,600.00 

Does not include: 

• Electrical controls, components or labor 

• Lift equipment for installation 

• Mounting stands for HEPA housings 

• Removal of existing fans 

• Wall or ceiling penetrations 

• Freight, taxes and customs if required 
Oskar Environmental Inc. 

95 Cypress Drive 

Youngsville, NC 27596 

www.oskarsales.com

ph: (919) 570-2862 

fx: (919) 570-2863 

mobile: (919) 971-2017 

esithes@oskarsales.com

Your solution to cleaner air... 

General Description (Fans)

• Backward Incline 

• Class III, Arrangement 9 

• 304 Stainless on all parts in contact with gas stream 

• Drain with Plug 

• Quick inspection door 

• Slide gate discharge damper 

• Premium efficient motors 

General Description (HEPA Housings)

• 14/16 gauge, 304 Stainless Steel 

• Standard pressure rating of 4” W.G. (positive or negative) 

• Double inlet and outlet adapters 

• Access door (right & left side) 

• Lift-off doors with positive pressure knobs 

• ANSI/ SMACNA approved 

• Replaceable unit hardware and tracks 

• Magnehelic gauges 

General Description (Clamp Together Ducting):

• Stainless steel (304) welded seam ducting 

• Elbows, transitions, reducers, and Clamps 

Again, thanks for the opportunity to present this budgetary quote. If this project moves forward, I 

would suggest we schedule a plant visit along with one of my project engineers. We produce all 

AutoCAD drawings in house and can provide any of the component data per request. 

Regards, 

Ed Sithes 

President 

Oskar Environmental Inc. 

(919) 570-2862, office 

(919) 971-2017, cell