SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal)
1. Identification of the Information Collection 1(a) Title of the Information Collection NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal) , EPA I CR Number 1611.07, OMB Control Number 2060

- 0327 1(b) Short Char acterization/Abstract The national emission standards for hazardous air pollutants (NESHAP) using maximum achievable control technology (MACT) for control of chromium emissions from hard and decorative chromium electroplating and chromium anodizing tanks were proposed on December 16, 1993 , and promulgated on January 25, 1995. This rule applies to sources performing hard chromium electroplating, decorative chromium electroplating, and chromium anodizing. The affected source is each chromium electroplating , or chromium anodizing tank. This information is being collected to assure compliance with these regulations

. There are approximately 1,770 chromium electroplating and anodizing operations nationwide. Of this total, approximately 790 are hard chromium electroplating operations, 740 are decorative chromium electroplating operations, and 240 are chromium anodizing operations. No net growth is predicted for this industry . It is expected that new tanks will only be added to replace, or expand existing cap acity and that few new facilities will be constructed. The ongoing monitoring, reporting, and recordkeeping for new tanks are the same as those for existing tanks. The Office of Management and Budget (OMB) approved the currently active In formation Coll ection Request (I CR) without any “ Terms of Clearance. ”
2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each c ategory , or subcategory of major sources and area sources of hazardous air pollutants . These standards are applicable to new, or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, section 114(a) states that the Administrator may require any

owner, or operator subject to any requirement of this Act to:2 (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such aud it procedures, or methods; (D) sample such emissions (in accordance with such procedures, or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables, or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasona bly require.
Inthe Admi nistrator’ s judgment, chromium emissions from hard and decorative chromium electroplating and chromium anodizing tanks cause or contribute to air pollution that may reasonably

be antici pated to endanger public health or welfare. T herefore, the NESHAP standards were promulgated for this source category at 40 CFR part 63, subpart N. 2(b) Practical Utility/Users of the Data The recordkeeping and reporting requirements in the standard(s) ensure compliance with the applicable regulat ions which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’s initial capability to comply with the emission standards, and serve as a record of the operating conditions under which compliance was achieved. The ongoing compliance status reports (i.e., semiannual reports for major sources and annual reports for area sources) are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. The information generated by

the monitoring, recordkeeping and reporting requirements described in this I CR is used by the Agency

to e nsure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary

to ensure compliance with the applicable regulations, as required by the Clean Air Act. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and the standard(s) are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facil ity , verify operation/maintenance procedures and for compliance determinations.3

3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 63, subpart N. 3(a) Non
- duplicat ion If the subject standards have not been delegated, the information is sent directly to the appropriate EPA R egional O ffice. Otherwise, the information is sent directly to the delegated state or local agency . I f a state or local agency has adopted it s own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. 3(b) Publ ic Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register on July 8, 2009 ( 74 FR 3258 1 ) . No comments were received on the burden published in the Federal Register

. 3(c) Consultations For this information collection, the Agency has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three ye ars. The primary

sources of inform ation are Section 114 Survey s from the Plating and Polishin g Area Source NESHAP , EPA's National Emission Inventory (NEI ) database , and industry trade association.
Itis our policy

to respond after a thorough review of comments received since the last I C R renewal as well as those subm itted in response to the f irst Federal Register n otice. Inthis ca se, no comments were received. 3(d) Effects of Less Frequent Collection Less frequent information collection would decrease the margin of assurance that f acilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information requir ed by these standards was collected less frequently , the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. 3(e) General Guidelines
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB under 5 CFR part 1320, section 1320.5.4

3(f) Confidentiality Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies se t forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI ) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by

43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions The reporting or recordkeeping requirements in the standard do not include sensitive questions. 4. The Respondents and the Information Requested 4(a) Respondents/NAICS Codes The respondents to the recordkeeping and reporting req uirements are sources performing hard chromium electroplating, decorative chromium electroplating, and chromium anodizing. The SI C ( United States Standard Industrial Classification ) codes for the respondents affected by the standard with the corresponding North American Industry Classification Sy stem (NAI CS) codes are listed below.
Standard SIC

Code NAICS

Code Source Description 40 CFR part 63, subpart N 3471 332813 Electroplating, Plating, Polishing, Anodizing, and Coloring 3423 332212 Hand and Edge Tool Manufacturing 3479 332812 Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers 3593 333995 Power Cylinder and Actuator Manufacturing To compare the SI C and NAI CS codes, see the website at http://www. census.gov/epcd/www/naics.html

. 4(b) Information Requested (i) Data Items All data recorded and/or reported in this I CR are required by NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N). A source must make the following reports:5 Notification s Notification of construction/reconstruction 63.5(a); 63.5(b); 63.5(e); 63.345 Notification of initial performance test 63.347(d) Reschedule of initial performance test 63.7 (b)(2) Notification of compliance status 63.347(e) Request for extension of compliance status, adjustments to time periods, and changes in information 63.9(c); 63.9(i); 63.9(j); 63.343(a)(6) Reports In itial performance test results 63.347(f) Operatio n and maintenance plan 63.342(f)(3); 63.347(g)(3) Submission of site specific test plan upon request 63.344(a) Ongoing semiannual compliance status reports for major sources, unless the source is required to submit it a more frequent basis (e.g., quarterly reports are required when an emission limit is exceeded), except for sources using trivalent chromium baths 63.347(g)

Ongoing annual compliance status reports for area sources, unless th e source is required to submit it on a more frequent basis (e.g., semiannual reports are required when the duration of an excess emissions is one percent or greater of the total operating time), except for sources using trivalent chromium baths 63.347(h)

Request to reduce reporting frequency of ongoing compliance status reports 63.347(g)(2); 63.347(h)(2) Reports associated with trivalent chromium baths 63.347(i) A source must keep the following records: Recordkeeping General recordkeeping requirements (e.g., startups, shutdowns and malfunctions including process equ ipment, air pollution control equipment, maintenance performed, and actions taken outside of the scope of the existing plans, records of monitoring data used to demonstrate compliance, performance test results, documentation supporting notifications and re ports) 63.346(a); 63.346(b)

Records for sources with continuous monitoring sy stems 63.346(b) Records are required to be retained for 5 years. The first 2 years of records must be kept on site. 63.10(b)(1); 63.346(c)6

Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the source still need to evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents, continue to create reporting sy stems to transmit data electronically . However, electronic reporting sy stems are still not widely used. At this time, it is estimated that ap proximately 10 percent of the respondents use electronic reporting. (ii) Respondent Activities Respondent Activities Read instructions. In stall, calibrate, maintain, and operate monitoring sy stem for pressure drop for composite mesh pad sy stems and fi ber bed mist eliminators; pressure drop and velocity pressure for packed bed scrubbers, surface tension for wetting agents, or the appropriate parameter for an alternative control option. Perform initial performance test, Reference Method 306, 306(a) or 3 06(b), and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously

applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose th e information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities EPA conducts the following activities in connection with the acquisition, analy sis, storage,7

and distribution of the required information. Agency Activities Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by i ndustry

. Audit facility

records. Input, analy

ze, and maintain data in the Air Facility Sy stem (AFS). 5(b) Collection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by

the Agency

to discern a source’s initial capability to comply

with the emission standard and to note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance and for compl iance determinations.
In formation contained in the reports is entered into the Air Facility Sy stem (AFS), which is operated and maintained by EPA ’s Of fice of Compliance. AFS is EPA ’s database for the collection, maintenance, and retrieval of compliance d ata for approximately 125,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by

local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Auth orities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner/ operator for five ye ars. 5(c) Small Entity Flexibility The majority

of affected facilities subject to this regulation are sma ll businesses. The recordkeeping and reporting requirements were selected within the context of this specific subpart and the specific process equipment and pollutant. The impact on small businesses was accounted for in the regulation development. Reduc tion in reporting was provided to small businesses subject to this regulation. Small (area source) businesses are only required to prepare annual compliance status reports and may retain these reports on site. These reports must be submitted to the Agenc y or a delegated authority on a semiannual basis only where the duration of excess emissions and air pollution control device malfunctions exceeds specified thresholds. L arge (major source) facilities must prepare and submit these reports on a semiannual or quarterly basis depending on their performance.8

5(d) Collection Schedule The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost for NESHAP for Chromium Emiss ions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal)

. 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individual burdens for the recordkeeping a nd reporting requirements applicable to the industry for the subpart included in this I CR . The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appr opriate, the specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct, or sponsor, and a person is not required to respond to, a collection of information unless it disp lay s a currently valid OMB Control Number. 6(a) Estimating Respondent Burden The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 171,118 hours (Total L abor Hours from Tab le 1). The recordkeeping hours shown below in Table 1 are 158,247 and the reporting requirement hours , also shown below in Table 1 , are 12,871

. These hours are based on Agency studies and background documents available from the development of the regulat ion, Agency knowledge and experience with the NESHAP program, the previously approved I CR, and any

comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs
This I CR uses the following labor rates: Managerial $ 55.67 ($ 26.51 + 110%) Technical $ 30.60 ($ 14.57 + 110%) Clerical $ 27.97 ($ 13. 32 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employ

ment and Wages, May

2009

. The mean hourly

wage for “ First

- Li ne Supervisor s/Managers of Office and Administrative Support Workers ” was used for the m anagerial rate, “ Plating and Coating Machine Setters, Operators, and Tenders, Metal and Plastic ” for technical, Office Clerks, General for the clerical rate. The rates have been in creased by 110 percent to account for the benefit packages available to those employed by private industry

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(ii) Estimating Capital/Startup and Operation and Maintenance Costs The ty pes of industry

costs associated with the information collection activ ity in the standards are both labor costs, which are addressed elsewhere in this I CR, and the costs associated with continuous monitoring of operating parameters associated with the following control options: fume suppressants; packed bed scrubbers; compos ite mesh pads; and fiber bed mist eliminators. The capital startup costs are one time costs incurred when a facility becomes subject to the standard. The annual operations and maintenance costs are the ongoing costs to maintain the monitors and other cos ts such as photocopying and postage. The total respondent costs have been calculated on the addition of the capital start up costs and the annual operations and maintenance costs. (iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs (A) Continuous Monitoring Device (B)

Capital / Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital / Startup Cost (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

Operating Parameter Monitoring Systems $0.00 0 $0.00 $15,000 1,770 $ 26,550 ,000

The total capital/startup costs for this I CR are $ 0 since we have assumed that there will be no industry

growth over the period o f this I CR. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 26,55 0,000. This is the total of column G. The combined average annual cost for capital/startup and operation and maintenan ce (O&M) costs to industry

over the next three years of the I CR is estimated to be $ 26,55 0,000. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported information. EPA’ s overall compliance and enforcement program includes activities such as reviewing records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the I CR is estimated to be $ 228,586. This cost is based on the average hourly labor rate as follows:10 Managerial $6 2.27 (GS

- 13, Step 5, $38. 92 + 60%) Technical $4 6

. 21 (GS

- 12, Step 1, $28. 88 + 60%) Clerical $2 5.01 (GS

- 6, Step 3, $15. 63 + 60%) These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality

rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Annual Agency Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs We estimate that there are approximately 1,770 chromium electroplating and anodizing operations nationwide which currently are subject to the standard. Of this total, approximately 790 are h ard chromium electroplating operations, 740 are decorative chromium electroplating operations, and 240 are chromium anodizing operations. It is estimated that no new sources per ye ar will become subject to the regulation in the next three years, since no net growth is predicted for this industry

. The number of respondents is calculated using the following table that addresses the three ye ars covered by

this I CR. Number of Respondents Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 1,696 74 0 1,770 2 0 1,696 74 0 1,770 3 0 1,696 74 0 1,770 Average 0 1,696 74 0 1,770
Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three year period of this I CR is 1,770

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The total number of annual responses per year is calculated using the following table: Total Annual Responses (A) Num ber of New Respondents (B)

Num ber of Reports for New Respondents (C)

Num ber of Existing Respondents (D)

Num ber of Repor ts for Existing Respondents * (F)

Num ber of Existing Respondents That Keep Records But Do Not Subm it Reports (E)

Total Annual Responses E=(AxB)+(CxD)+F

0 6 1,357 1 74 2,2 78 .5 339 2 .5 *W e assume that all sources are area sources. Area sources, ex cept for chromium anodizing plants 1,696 ), are required to submit an annual compliance status report. However, sources are required to submit these reports on a mo re frequent basis if excess emissions occurs (i.e., semiannually for area sources). We furt her assume that 80 percent of the sources (0.80 times 1,696 yields 1,357 ) w ill have no excess emissions and 20 percent of the sources (0.20 times 1,696 yields 339 ) w ill have excess emissions. H alf of the area sources submitting semiannual reports due to ex cess emissions (0.5 x 339 = 170 ) w ill request the regulatory agency to approve a reduction in frequency for ongoing compliance status reports (i.e., annual reporting) The number of Total Annual Responses is 2,2 78 .5

. The total annual labor costs are $ 5 , 3 83,586

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Renewal )

. 6(e) Bottom Line Burden Hours Burden Hours and Cost Tables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively , and summarized below. (i) Respondent Tally The total annual labor hours are 171,118 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) ( Renewal ). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 7 5.08 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $ 26,55 0,000

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally The average annual Agency burden and cost over next three years is estimated to be 5,07212

la bor hours at a cost of $ 228,586 . See below Table 2. Annual Agency Burden and Cost for NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) ( Renewal ). 6(f) Reasons for Ch ange in Burden There was a decrease in burden hours, costs, and number of responses currently identified in the OMB Inventory

of Approved Burdens. This is due to a change in the number of estimated chromium electroplating and anodizing operations affecte d by I CR since the last renewal which decreased from 5,020 to 1,770 sources. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information are estimated to average 75.08 hours per response. Burdens means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose, or provide information to, or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit, or otherwise disclose the information. An Agency

may not conduct, or sponsor, and a person is not required to respond to, a collection of information unless it display s a valid OMB control number. The OMB control numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency ’ s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OE CA

- 2009

- 0422

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket I D number identified in this document. The documents are also available for public viewing at the E nforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52 . Also, comments can be sent to the Office of In formation and Regulatory Affairs, Office of Manageme nt and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0422 and OMB Control Number 2060

- 0327 in any13

correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.