Date: July 16, 2010 (Revised: September 8, 2010)

Subject: Emissions Reductions and Cost Effectiveness of HEPA Filter Retrofits for Chromium Electroplating 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: James Cunningham Richard Marinshaw

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

The purpose of this memorandum is to presen t the estimated emissions reductions, costs, and cost effectiveness of retrofitting high efficien cy particulate air (HEPA) filters on all existing sources subject to the National Emission Standa rds for Chromium Emissions from Hard and Decorative Chromium Electroplating a nd Chromium Anodizing Tanks (Chromium Electroplating NESHAP, 40 CFR 63, subpart N). Re trofitting 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 electroplat ing and anodizing tanks subjec t to the NESHAP. Emissions reductions associated with retrofitting HEPA filte rs 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 numb er of each size (small, medium, large); 3. Estimate uncontrolled emissions from each plant type and size; 4. Estimate control method distribution a nd 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 thes e estimates is provided in Reference 1.

Table 1. Estimated Number of Chromium Electroplating Plants a

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 a nd anodizing plants by size were estimated using the model plants and plant distributions developed for the NESHAP and documented in Chromium Emissions from Chro mium 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 chro mium electroplating, and two sizes of model plants (small and large) we re developed for chromium anodizing. Table 2 summarizes the resulting nationwide brea kdown of plants by type and size.

Table 2. Distribution of Mode l Plants by Size and Type a

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 emi ssions. Table 3 summarizes these emissions.

Table 3. Uncontrolled Chromium Co mpound Emissions from Model Plants a

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 technol ogies in use, and the control levels (control efficiencies) achieved by those technologies. Fo r hard chromium electroplating tanks, the most commonly used controls are the composite mesh pad (CMP), p acked bed scrubber (PBS), and mesh pad mist eliminator (MPME). In additi on, as the result of the 2005 amendments to the NESHAP, some hard chromium electroplating ta nks 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. Fo r decorative chromium electroplating tanks and chromium anodizing tanks, the contro ls used include PBS, MPME, and CMP, but most tanks are controlled using WAFS. The same contro l efficiencies indicated above for hard chromium electroplating also appl y 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 Controls a

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 emissi on control methods among the various types of chromium electroplating plants and plant sizes was estimated based on gene ral knowledge of the industry. Large hard chromium electroplating plants gene rally are controlled with CMPs; some PBSs are4

also used. For medium and small hard chromium electroplating plants, PBSs are more common. Some medium and small plants also use WAFS to control emissi ons. As noted above, WAFS is the most commonly used control method for deco rative chromium electroplating and chromium anodizing plants. However, other controls (P BS, MPME) also are used. To estimate the distribution, the percentage of pl ants that use WAFS was first assumed; then the percentages of each type of add-on control devices were estimate d. Since the control efficiencies for PBS and MPME are comparable, no distin ctions were made between th e two with respect to their distribution. Table 5 summarizes the assumed di stribution 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 Co ntrols 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 Pl ants 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 controlle d efficiencies are applied to those emissions, shows that the model plant emissions appear to be representati ve of existing chromium electroplating emissions for decorative chromium electroplating and for ch romium anodizing plants. However, for hard5

chromium electroplating plants, the uncontrolled em ission 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 expl ained 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 Ta ble 4 were applied to the uncontrolled emissions listed in Table 3 to determine annual emission rate s by model plant type, size, and emissions control method. Table 7 summarizes the resulting controlled em issions used to estimate nationwide baseline emissions from chromium electroplating and anodizing plants.

Table 7. Controlled Chromium Comp ound 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/y r) for decorative chromium electroplating, and 42 lbs/yr (0.021 tons/yr) for chromium anodizi ng. 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 woul d be achieved by retrofitting HEPA filters on all existing sources subject to the Chromium Electroplating NESHAP, the control efficiency of HEPA filters was first applie d to uncontrolled baseline emissi ons. By definition, HEPA filters are designed to remove at least 99.97 percent of ai rborne particles that are 0.3 micrometers (μm) or larger in diameter. The onl y 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 HE PA filters would generally remove 99.97 percent of uncontrolled emissions from hard chro mium electroplating, decorative chromium electroplating, and chromi um anodizing sources.

Table 9. Particle Size Data for Uncontroll ed Hard Chromium Electroplating Emissions a 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 chromi um electroplating, decorative chromium electroplating, and chro mium anodizing assuming all existing tanks are retrofit with HEPA filters. The table also shows the emissions reducti ons 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 Chro mium Electroplating NE SHAP distinguishes between four types of plants: large hard chromium electro plating, small hard chromium electroplating, decorativ e chromium electroplat ing, 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 rectif ier capacity less than 60 million amp-hr/yr. These size distinctions differ from the model pl ant sizes for hard chromium electroplating. All large model plants would be classified as larg e hard chromium plants under the NESHAP, and all small model plants would be classified as small hard chromium pl ants under the NESHAP. However, the larger portion of me dium 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 2,3668

III. HEPA Filter Retrofit Costs

This section describes the methodology, data, an d assumptions used to estimate the costs of retrofitting HEPA filters on existing sour ces subject to the Chromium Electroplating NESHAP. In estimating costs, distinctions we re made between emission control systems with existing add-on controls, and sources that use WA FS and are not equipped with add-on controls. For systems with existing add-on co ntrols, a retrofit factor was incorporated into the basic HEPA filter system cost. For systems without existing a dd-on controls, a retrofit factor was not applied to the costs. However, it was necessary to in clude costs of an exhaus t 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 thr ee 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 Fl anders/CSC of Washingt on, 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) ducti ng and installation; 3) estimated freight; and 4) filter replacement co st. The estimated freight and filter replacement costs were assumed equal to no rmalize 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 thos e rates, if not provide d 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 installati on cost Assumed 2.1% of installation cost Retrofit Cost Assumed 50% of capital cost Assumed 50% of capital cost9

Table 13 presents the annual cost categories considered in the estimate, the assumptions used, and the information source. The filter re placement 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 (k W-hr) was used (Reference 6).

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

Cost Component Source/Method Labor hours CA ARB a Filter Replacement Quotes Filter Disposal $930/5000 ft 3 /min. a Electricity $0.14/kwhr Property Tax & Insurance 4% of capital cost b

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% a nd 20-year lifetime. The cost curve plotted exhaust flow (independent va riable) versus total a nnual cost (dependent variable) and resulted in a R 2 value of 0.999. The equation of the best-fit line was then used to determine the total annual cost fo r the model facilities for hard plating, decorative plating, and anodizing facilities. Presented in Figure 1 is the cost curve fo r 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 50,000TotalAnnualCost,$

Exhaust Flow, ft 3 /min.

Figure 1. Annualized Cost Curve for Retr ofitting new HEPA Filter on Existing Chromium Electroplating Source wi th 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 cost10

to retrofit a new HEPA filter on all sources subj ect 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 a nodizing 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 elim inator (MPME) would be used. To estimate the cost of installing an exhaust system and MP ME, the cost model developed for the NESHAP (Reference 2) was used and converted to 2009 dollars using the C onsumer Price Index (Reference 8). The cost of a new HEPA filter syst em 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 50,000TotalAnnualCost,$

Exhaust Flow, ft 3 /min.

Figure 2. Annualized Cost Curve for Retr ofitting 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 ex isting 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 sour ces that are not equipped with add-on controls are currently controlled using WAFS. After these sources ar e equipped with CMPs, it is assumed that WAFS would no longer be used for emission control. T hus, the costs these facili ties currently incur for WAFS can be considered a savings after CMP retrofit. Table 16 summarizes the estimated12

annual WAFS cost per model plant. These co sts are based on a unit WAFS cost of $186 per gallon, an initial WAFS addition (dose) of 0.0025 gallons of WAFS per ga llon of electroplating tank solution, and maintenance additions of 0.0075 milliliters of WA FS per ampere-hour. Reference 9 provides the ba sis for these costs.

Table 16. WAFS Cost Savings Following CMP Retrofit

Electroplating Plant Type, Size Annual Production rateper facility, Amphrs/yr a Tank capacity per facility, gal a Initial Addition WAFS Cost per facility, $ b Maintenance Cost per facility, $/yr b 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 NA c NA c NA c 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 $63,077,00013

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 nationw ide 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 Cost s 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 Type a 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 elect roplating plants to $895 million per ton for chromium anodizing plants. Overall cost eff ectiveness was estimated to be $99.1 million per
ton.14

Table 20. Cost Effectiveness for HEPA Filter Retrofit

Facility Type a 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 Intern ational, to P. Mulrine, EPA/OAQPS. Estimated Number of Chromium Electroplating Plants. May 24, 2010.

2. U.S. EPA. Chromium Emissions from Ch romium Electroplating and Chromic Acid Anodizing Operations -- Background Informati on 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 Internat ional, to P. Mulrine, EPA/OAQPS. Model Plant Data Used to Estimate Risk from Ch romium 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 – Hexava lent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operati ons 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 Ch rome Plating and Chromic Acid Anodizing Operations . 2003

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

9. Memorandum from R. Marinshaw, RTI Intern ational, to P. Mulrine, EPA/OAQPS. Nationwide Costs for Conversion to Non- PFOS Fume Suppressants. August 16, 2010.Appendix AOskar 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 ou t 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 requiredOskar 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