Date: July 27, 2012

Subject: Revised Procedures for Determining Control Costs and Cost Effectiveness for Chromium 

Electroplating and Anodizing

Contract No. EP-D-11-084; EPA Work Assignment No. 0-07

RTI Project No. 0213199.000.007

From: Richard Marinshaw

Cindy Hancy

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

Introduction

The purpose of this memorandum is to describe the steps used to estimate the baseline emissions, 

emission control costs, and cost effectiveness for the regulatory requirements of the final amendments to 

the Chromium Electroplating National Emissions Standard for Hazardous Air Pollutants (NESHAP). 

The results of the cost analysis are also presented.

Procedures for Determining Control Costs and Cost Effectiveness for Chromium Electroplating 

NESHAP Final Amendments

1. Compile Emissions Data

The first steps in the analysis focused on current emissions levels in the industry. The available 

chromium emissions concentration data were compiled in units of milligrams per dry standard cubic 

meter (mg/dscm), which is the format of the emission limits in the Chromium Electroplating NESHAP. 

Data compiled included the plant name and location, process type, emission control method, and 

emissions concentration.

There are an estimated 1,343 chromium electroplating plants in the U.S. Of these, about 198 are 

located in California and 1,145 are located outside the State of California. Throughout the analysis, a 

distinction was made between the plants located in California and plants located elsewhere (i.e., the nonCalifornia plants). Chromium electroplating plants in California are subject to emission limits that are 

production-based rather than concentration-based and, for most facilities, are more stringent than the 

emission limits required by the Chromium Electroplating NESHAP. As a result, emissions for 

California plants are not representative of emissions for non-California plants. Since the final 

amendments impact facilities located outside of California, the data on California plants were not 

included in the analysis described below, and any reference to plants nationwide presumes that the 

plants in question are the non-California plants.

The estimated number of electroplating plants in the U.S. was updated since the February 2012 

supplemental proposal to reflect several comments regarding current facility information; including
2

closures, operating hours, and corrected facility process types. The data that EPA determined to be valid 

are incorporated in the analysis described in this memorandum. 

2. Group Emissions Data by Process

The data were grouped by process and current emissions limit, as shown in Table 1. Tables 2 

through 5 summarize the data on emissions concentrations for each process type. It should be noted that 

these data sets include all the available data on emissions concentration. These data sets are not the 

same data sets on annual emissions that were used to simulate and estimate actual emissions for the 

residual risk assessment. The reason is that, for annual emissions, data on flow rate and annual operating 

hours are used in addition to concentration data to convert emissions concentrations to annual emission 

rates (e.g., in units of pounds per year [lbs/yr]), and data on flow rate and annual hours were not 

necessarily available for all of the sources listed in Tables 2 through 5. On the other hand, data are 

available on annual emissions (in units of lbs/yr) for a number of other facilities for which concentration 

data are not available. In summary, for many plants, emission data are available on both concentration 

and mass rate (lbs/yr), but for a number of other plants data are available only for one or the other of 

these two formats. So, the two data sets do not have all the same plants. 

3. Determine Percentage of Plants That Would Not Meet Proposed Emission Limits

The data listed in Tables 2 through 5 were assumed to represent the population of each type of 

non-California plant nationwide. For example, the 75 data points for large hard chromium electroplating 

were assumed to represent the large hard chromium electroplating industry outside of plants in 

California. 

The proposed emission limits were compared to the ranked emission data to determine the 

number or percentage of existing plants that would already meet the proposed emission limit. To 

provide a conservative estimate of the number of plants impacted, a value of 85 percent of the proposed 

limit was used as the cutoff for sources that would or would not need to reduce emissions to meet the 

proposed emission limit. For example, for large hard chromium electroplating, 85 percent of the 

amended limit of 0.011 mg/dscm would be 0.0094 mg/dscm. Therefore, we assumed that any plant with 

emissions less than 0.0094 mg/dscm would meet the amended limit and therefore would not need to 

reduce emissions. Based on the data in Table 2, 13 of the 75 sources (i.e., about 17.3 percent) outside of 

California would need to install additional controls or add wetting agent fume suppressant (WAFS) to 

meet 85 percent of the amended emission limit for large hard chromium electroplating. There are an 

estimated 188 large hard chromium electroplating plants nationwide (outside of California). Of these, 

an estimated 4 plants use only WAFS to control emissions, and the other 184 plants use add-on control 

devices. Since the surface tension data analysis (described elsewhere) indicates that plants that use 

WAFS would readily meet the proposed limit of 0.011 mg/dscm, those plants were excluded from the 

determination of the number of plants that would have to install additional controls. Applying this 

methodology to large hard chromium electroplating plants results in 32 plants that would have to install 

additional controls or add WAFS (188 × 0.173 = 32 plants). Applying this same method to “existing” 

small hard chromium plants, we estimate that 33 plants of the 263 (or about 13%) would need to install 

additional controls or add WAFS to meet the amended emissions limit. 

4. Determine Controls Needed for Each Type of Plant
3

For the supplemental proposal, it was assumed that 90 percent of the plants that would need to 

reduce emissions could meet the proposed emission limit using WAFS, and the remaining 10 percent 

would have to install add-on controls. The basis for this assumption is that the data on emissions and 

controls indicate that many plants use a combination of add-on control devices and WAFS to ensure 

compliance with the emissions limit. In these cases, the add-on control device is the primary control

technology, with WAFS used to further lower emissions. In most cases, facilities that would not meet 

the final emissions limits would need only small reductions in emissions to meet the final amended 

limits. Therefore, it was concluded that nearly all of such plants could simply add WAFS to the 

electroplating tanks to comply. However, based on public comments and discussions with industry 

representatives, it was concluded that using WAFS may not be practical in some cases, due to customer 

specifications. As a result, it was assumed that only 10 percent of large hard chromium electroplating 

sources that would need to reduce emissions to meet the amended limit and 80 percent small hard 

chromium sources that would need to reduce emissions to meet the amended limit could use WAFS to 

achieve the additional emissions reductions needed to comply with the final emissions limits. We 

assumed the other plants that would need to reduce emissions would do so by improving their add-on 

controls. It was further assumed that 80 percent of the large and small hard plants that would need to 

reduce emissions with add-on control devices to meet the amended limit would do so by installing a new 

or retrofitted composite mesh pad (CMP), and the remaining 20 percent of this subset would install high 

efficiency particulate air (HEPA) filters. The data indicate that retrofitting CMPs should be adequate for 

meeting the final emission limits. However, there are cases where HEPA filters may be needed or 

preferred by the facility to ensure there is an adequate margin of compliance.

As an example, applying the approach described above for the 32 large hard chromium 

electroplating plants that would need to reduce emissions, 3 (10%) of these plants would meet the 

proposed emission limit using WAFS, and 29 plants (90% of the 32 plants) would retrofit their add-on 

controls. Of the 29 plants that retrofit add-on controls, 23 (80%) of these plants would retrofit CMPs, 

and 6 (20%) of these 29 plants would retrofit HEPA filters (3 + 23 + 6 = 32 plants).

With regard to Decorative and Anodizing plants, most of these sources comply with the rule by 

maintaining surface tension limits by using WAFS. However, some plants rely on add-on controls (at 

least in part) and comply with the rule by meeting the emissions limits.

The same methodology described above for hard chromium electroplating sources was applied to 

decorative chromium electroplating and chromium anodizing to estimate costs except that we assumed 

that any plant that relies on add-on controls and might need to reduce emissions to comply with the 

amended emissions limit would be able to do so by reducing emissions a bit further by adding WAFS. 

Based on the data we have (shown in table 5), we think most plants that currently use add-on

controls to meet the current emission limit will be able to meet the amended emissions limit with no 

additional controls. As shown in table 5, all plants for which we have data already meet the limit and 

some of these plants have emissions far below the amended limit. In fact, based on the data we have 

received, we are not aware of any plant that would not meet the amended limit. However, to be 

conservative (i.e., more likely to overestimate costs rather than underestimate costs), we assumed that 

14.3% of the Decorative and Anodizing plants that rely on add-on controls to meet the emissions limit 

would need some reductions to meet the amended emissions limits. We assumed that all of these plants 
4

would be able to meet the amended emission limit by reducing emissions a bit further using WAFS, as 

indicated by the available data. 

Table 6 shows the resulting estimated number of plants that would need to install additional 

controls, or add WAFS, and the control method used for the cost analysis.

5. Determine Control Costs

To estimate the cost for retrofitting CMPs and retrofitting HEPA filters, the same basic 

methodology was used that was used to estimate control costs for the October 2010 proposal (see 

References 1 and 2). The basic steps consisted of the following:

• The cost quotes obtained from CMP and HEPA filter vendors in 2010 were used.

• To reflect 2011 costs, the quotes were scaled using cost indices from Chemical Engineering.

• To account for retrofit costs, it was assumed that the additional costs associated with retrofitting

a control on an existing system was equal to 30 percent of the equipment costs, based on the

EPA Air Pollution Control Cost Manual (Reference 3). 

• Operation and maintenance labor was estimated to be 100 to 110 hours per year per source,

depending on the size of the system.

• Electricity costs were estimated assuming that operating the retrofit system would require an 

additional 50 percent beyond the current electricity usage for the existing controls.

• Annualized capital costs were calculated assuming a 15 year life and 7 percent interest rate.

• Other factors for taxes, freight, etc. were taken from the EPA Air Pollution Control Cost Manual 

(Reference 3).

• The capital and annual costs were summed up and a regression equation was developed for each; 

the regression equation estimates annualized (or capital) costs as a function of exhaust flow rate.

To determine typical flow rates for each type of plant, the available data were compiled on each 

process, and the average flow rate for each was determined. 

To determine the costs of using WAFS, the same cost factors were used that were used for the 

2010 proposal (Reference 4). These factors estimate costs as a function of tank volume and energy input 

(ampere hours per year). To determine typical tank volumes and energy input values, the available data 

were compiled on each process, and the average values were determined. The cost factors were also 

updated from 2010 dollars to 2011 dollars using indices from Chemical Engineering (Reference 5).

Finally, the resulting cost per plant was increased by 15 percent to reflect the estimated additional costs 

for using WAFS that do not contain perfluorooctyl sulfonates (PFOS), also referred to as non-PFOS 

WAFS. Although the costs for non-PFOS WAFS are comparable to the costs of PFOS-based WAFS, 

available information indicates that non-PFOS WAFS are generally depleted more quickly in the 

electroplating bath. For plants, that regularly electroplate, the depletion of non-PFOS WAFS is negated 

by drag-out.1

 However, for plants that do not electroplate regularly (i.e., do not electroplate daily for 

several hours per day), the depletion rate can be up to 20 percent. To account for this, the estimate 

WAFS costs were increased by 15 percent across the board, which provides estimated costs for non-

 1 Drag-out refers to electroplating solution that remains on the electroplated items when they are removed from the 

electroplating bath and is lost when the items are placed in a rinse tank. 
5

PFOS WAFS that are conservatively high (i.e., costs are more likely overestimated rather than 

underestimated).. Reference 5 provides additional details on the use and costs of non-PFOS WAFS. 

Table 7 summarizes typical plant costs for retrofitting CMPs, retrofitting HEPA filters, and using 

WAFS to meet the proposed emission limits.

6. Determine Testing Costs

Testing costs were estimated using the same generic spreadsheet developed by RTI for 

estimating testing costs for any facility based on the number of sources, number of test runs, test run 

duration, and laboratory costs. Table 8 shows an example of the output for testing a chromium 

electroplating plant with two stacks. Based on data compiled for the industry, the number of stacks that 

would need to be tested was estimated for each type of chromium electroplating process. Using the 

output from the testing cost spreadsheet referenced above, the testing costs for a typical chromium 

electroplating plant were estimated. 

The final amendments include a provision that allows plants to use any previous test that was 

performed after January 1995 to demonstrate compliance as long as that test is representative of current 

controls and current operations and the test results would meet the proposed lower limits, as approved 

by the permitting authority. For each of the source categories and subcategories covered by the 

NESHAP (i.e., large hard chromium, small hard chromium, decorative chromium and chromium 

anodizing), the number of facilities that would qualify for this provision and therefore not need to 

conduct a new test was estimated based on the percentage of plants that currently meet the 

corresponding emissions limit. It was assumed that the remainder would be required to conduct an 

emission test. Table 9 provides a summary of the calculations, estimates and resulting testing costs by 

process type.

7. Determine Baseline Emissions and Emissions Reductions

The basic procedure used to determine emissions reductions was to first estimate the baseline 

emissions associated with the impacted plants (i.e., the plants that would be required to install additional 

controls to meet the more stringent emissions limits). Then, the control efficiency associated with each 

specific type of control measure was applied to those baseline emissions.

Baseline emissions for the impacted plants were estimated using a cumulative distribution curve 

for each source category. The curves plot cumulative percentage of plants (y axis) against cumulative 

percentage of total emissions (x axis). The cumulative distributions for large hard chromium 

electroplating, decorative chromium electroplating, and chromium anodizing, were based the data on 

actual and simulated emissions for all plants. For small hard chromium electroplating, it was necessary 

to distinguish between existing and new plants. Since the simulated emissions data for small hard 

chromium electroplating do not distinguish between existing and new sources, only actual emissions 

data were used and the distribution curve was simulated. Figures 1 through 4 show the curves for large 

hard chromium electroplating, small existing hard chromium electroplating, decorative chromium 

electroplating, and chromium anodizing, respectively. Appendix B presents the data plotted used to 

generate each curve.

The curves were used as follows:
6

1. The percentage of plants that would not be impacted was first determined from the analysis.

2. The curve was then used to determine the percentage of total emissions that corresponds to the 

plants that were not impacted. 

3. The balance of emissions (in terms of percentage) was then determined as the difference between 

total nationwide emissions and emissions for the unaffected plants. For example, for large hard 

chromium electroplating, it was estimated that about 80.9 percent of plants would be unaffected. 

Based on Figure 1 (or to be more exact, the data table in Appendix B), these plants, which 

generally represent the lowest emitters, account for about 45.3 percent of emissions, and the 

affected plants, which generally represent the highest emitters, account for the balance (i.e., 

about 54.7 percent of emissions). 

4. Because it is not necessarily true that all of the affected plants would be the absolute highest 

emitting plants, a factor was included that varied from 80 to 95 percent, depending on the 

estimated percentage of plants affected. Continuing with the example using the data for large 

hard chromium electroplating, baseline emissions are estimated to be 453.7 lbs/yr. The affected 

plants account for about 54.7 percent or about 248 lbs/yr if they are all the highest emitters. 

Since some of these plants are not necessarily the highest emitters, a factor of 80 percent was 

applied, and the resulting estimate is 198 lbs/yr. This figure represents the estimated baseline 

emissions for the affected large hard chromium electroplating plants. 

Once baseline emissions were determined for each source category, the following assumptions were 

used to estimate emissions reductions:

• It was assumed that the plants impacted currently achieve a control efficiency of 99 percent.

• For plants that were expected to retrofit a CMP, the control efficiency of the retrofitted system 

was assumed to be 99.7 percent, based on data reported by the California Air Resources Board 

(CARB).

• For plants that were expected to retrofit a HEPA filter, the control efficiency of the retrofitted 

system was assumed to be 99.97 percent, based on the standard design criteria for HEPA filters.

• For plants that currently use WAFS to control emissions and would be subject to the proposed 

surface tension limit, it was assumed those plants would have emissions concentrations equal to 

0.0055 mg/dscm, based on the analysis of surface tension data (documentation provided 

separately in Reference 7).

Table 11 provides a summary of the resulting estimated emissions reductions.

8. Determine Cost Effectiveness

The number of nationwide sources that would be required to install a particular type of control 

(CMP, HEPA, and WAFS) was multiplied by the annualized costs for that control to determine 

nationwide costs. Testing costs were added to these annualized costs. For existing facilities that 

currently use WAFS, it was assumed that an additional 15 percent of WAFS would be required to meet 

the final amended surface tension limits. Cost effectiveness was calculated by dividing the estimated 

emissions reductions for each electroplating category by the sum of annualized nationwide cost for 

testing, retrofitting CMPs or HEPA filters, and/or using WAFS for the corresponding electroplating 

category. Table 11 summarizes the cost effectiveness. Table 12 provides an overall summary of the 

number of affected plants, costs, emissions reductions, and cost-effectiveness for the final emissions and 
7

surface tension limits. Additional details regarding the methodology applied to calculate these estimates 

are provided in Appendix A. 

9. Additional Options Analyzed

For the supplemental proposal, additional regulatory options, in terms of more stringent 

emissions limits, also were analyzed for hard chromium electroplating facilities. The impacts and cost 

effectiveness of these options are summarized in Table 13.

If the same methodology and assumptions used to estimate the costs for retrofitting HEPA filters 

on existing sources are applied to all hard chromium electroplating plants outside of California, similar 

to the option considered for the October 2010 proposal, the resulting annualized costs and cost 

effectiveness would be $12.4 million per year and $27,400 per pound for large hard chromium 

electroplating, and $9.5 million per year and $42,700 per pound for small hard chromium electroplating, 

respectively. These cost effectiveness values are significantly higher than the values determined for the 

final amendments to the NESHAP because they reflect the fact that all sources, including those with 

very low emissions, would still incur the retrofitting costs. On the other hand, the final amendments 

generally target the plants with the highest emissions and therefore greater emissions reductions per 

plant and lower overall cost effectiveness. Furthermore, the cost effectiveness values for retrofitting 

HEPA filters across the board are likely to be lower bounds since it is assumed that all retrofitted HEPA 

filters would achieve 99.97 percent control, and, if the existing control device upstream of the HEPA 

filter is already achieving a high level of control and removing a significant fraction of the very fine mist 

droplets, the efficiency of the HEPA filter would be less.

References:

1. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Emissions Reductions and Cost Effectiveness of Composite Mesh Pads for 

Chromium Electroplating Emission Standards Technical Support and Post Promulgation 

Activities. September 7, 2010. EPA-HQ-OAR-2010-0600-0011

2. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Emissions Reductions and Cost Effectiveness of HEPA Filter Retrofits for 

Chromium Electroplating Emission Standards Technical Support and Post Promulgation 

Activities. September 8, 2010. EPA-HQ-OAR-2010-0600-0013

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

Protection Agency, Research Triangle Park, NC 2002. 

4. Memorandum from R. Marinshaw, RTI International, to P. Mulrine, U.S. Environmental 

Protection Agency. Nationwide Costs for Conversion to Non-PFOS Fume Suppressants 

Emission Standards Technical Support and Post Promulgation Activities. August 16, 2010. EPAHQ-OAR-2010-0600-0016.

5. Chemical Engineering Plant Cost Index (CEPCI). Chemical Engineering Magazine 2011. 
8

6. Memorandum from B. Munoz, R. Marinshaw, and G. Raymond, RTI International, to P. 

Mulrine, U.S. Environmental Protection Agency. Simulation of Actual and Allowable 

Emissions for Chromium Electroplating Facilities. January 4, 2012.

7. Memorandum from B. Munoz, R. Marinshaw, and G. Raymond RTI International, to P. 

Mulrine, U.S. Environmental Protection Agency. Development of Revised Surface Tension 

Limits for Chromium Electroplating and Anodizing Tanks Controlled with Wetting Agent Fume 

Suppressants. December 22, 2011.
9

Table 1. Emission Data Groupings for Control Cost Analysis

Process Type Emission Limit (EL) No. of Data Points

Large hard chromium electroplating 0.015 mg/dscm 75

New small hard chromium electroplating 0.015 mg/dscm 38

Existing small hard chromium electroplating 0.030 mg/dscm 35

Decorative chromium electroplating 0.010 mg/dscm 14

Chromium anodizing 0.010 mg/dscm 1
10

Table 2. Summary of Actual Emission Concentration Data -- Large Hard Chromium Electroplating1

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.000016 0.015 0.0010

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.00011 0.015 0.0073

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00012 0.015 0.0080

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00014 0.015 0.0091

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00014 0.015 0.0095

Rock Island Arsenal –Stack 1 Rock Island Arsenal, 

Amsta-RI-Pwn

Rock Island IL PBS/MPME 0.00018 0.015 0.012

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.00027 0.015 0.018

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.00034 0.015 0.023

NEO Industries 10 Technology Place Beaver Dam KY CMP 0.0006 0.015 0.04

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.00062 0.015 0.041

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.00074 0.015 0.049

Delphi Chassis Systems –

Needmore

1435 Cincinnati Street Dayton OH CMP 0.00085 0.015 0.057

Quality Plating Company 420 S 500 W Salt Lake City UT MPME/HEPA 0.0011 0.015 0.071

McDowell Enterprises-North 2010 Superior Street Elkhart IN CMP 0.0011 0.015 0.073

Teikuro Corporation 4500 Gateway Boulevard Springfield OH WAFS 0.0011 0.015 0.076

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0012 0.015 0.080

Tinker AFB Logistics Center 7701 Arnold Street Midwest City OK PBS/CMP 0.0012 0.015 0.08

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0012 0.015 0.081

Kyb Manufacturing North 

America, Inc.

2625 North Morton Franklin IN CMP 0.0013 0.015 0.084

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0014 0.015 0.093

Garrod Hydraulics, Inc. 1050 Locust Point Road York PA CMP 0.0015 0.015 0.10
11

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Whyco Finishing 

Technologies, Inc

670 Waterbury Road Thomaston CT WAFS/MPME 0.0016 0.015 0.10

Lasalle Steel 1045 East Main Street Griffith IN CMP 0.0016 0.015 0.10

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0017 0.015 0.11

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0019 0.015 0.13

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0021 0.015 0.14

Quebecor World – Franklin 300 Brown Road Franklin KY CMP 0.0025 0.015 0.17

Ultra Plating 345 S. Pearl Street Green Bay WI CMP 0.0026 0.015 0.17

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0027 0.015 0.18

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0028 0.015 0.19

Grove US L.L.C. 7677 Anthony Highway Quincy PA CMP 0.0030 0.015 0.20

Perfection Industries, Inc. 18571 Weaver Street Detroit MI CMP 0.0030 0.015 0.20

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0031 0.015 0.20

National Chromium Co. Inc. 10 Senexet Road Putnam CT CMP 0.0031 0.015 0.20

Hard Chrome 510 Dresden Evansville IN PBS/ CMP 0.0031 0.015 0.21

Chrome Deposit Corp 6640 Melton Road Portage IN CMP 0.0035 0.015 0.23

Delphi Chassis Systems, 

Kettering Operations

2000 Forrer Boulevard Kettering OH CMP 0.0036 0.015 0.24

Tinker AFB Logistics Center 7701 Arnold Street Midwest City OK PBS/CMP 0.0039 0.015 0.26

National Chromium Co. Inc. 10 Senexet Road Putnam CT CMP 0.0040 0.015 0.26

Moyno, Inc. 1895 West Jefferson Street Springfield OH CMP 0.0040 0.015 0.27

McDowell Enterprises-South 2010 Superior Street Elkhart IN CMP 0.0040 AMR 

limit

N/A

KSI, Inc.-West Line 1500 Genesis Drive LaPorte IN CMP 0.0048 0.015 0.32

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.0053 0.015 0.35
12

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Garrod Hydraulics, Inc. 1050 Locust Point Road York PA CMP 0.0053 0.015 0.36

Quebecor World – Franklin 300 Brown Road Franklin KY CMP 0.0055 0.015 0.37

Huntington Plating Inc. 625 Monroe Avenue Huntington WV CMP 0.0058 0.015 0.39

NEO Industries 3025 Branch Drive Weirton WV "Scrubber" 0.0059 0.015 0.39

En-Chro Plating, Ltd. 2755 W. Lake Street Melrose Park IL CMP 0.0060 0.015 0.40

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.0060 0.015 0.40

KSI, Inc.-East Line 1500 Genesis Drive LaPorte IN CMP 0.0063 0.015 0.42

KBY Manufacturing North 

America, Inc.

2625 North Morton Franklin IN PBS/CMP 0.0066 0.015 0.44

NEO Industries 1465 North Park Drive Decatur AL CMP 0.0070 0.015 0.47

Universal Plating 478 Morgan Avenue Akron OH CMP 0.0070 0.015 0.47

Parker Hannifin-Horizontal One Parker Drive Ashley IN PBS/CMP 0.0071 0.015 0.47

Grove US L.L.C. 7677 Anthony Highway Quincy PA CMP 0.0080 0.015 0.53

KBY Manufacturing North 

America, Inc.

2625 North Morton Franklin IN WS/CMP 0.0080 0.015 0.53

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.0080 0.015 0.53

Ultra Plating 345 S. Pearl Street Green Bay WI CMP? 0.0080 0.015 0.54

Harrision Engine 301 Detroit Street LaPorte IN PBS/CMP 0.0087 0.015 0.58

NEO Industries 1775 Willow Creek Road Portage IN PBS/CMP 0.0091 0.015 0.61

CCR, Inc. 1011 South Perkins Avenue Muncie IN CMP 0.0092 0.015 0.61

Delta Airlines 1775 Aviation Boulevard Atlanta GA CMP 0.0092 0.015 0.61

National Chromium Co., Inc. 10 Senexet Road Putnam CT CMP 0.0096 0.015 0.64

Parker Hannifin-New 

Horizontal

One Parker Drive Ashley IN PBS/CMP 0.0098 0.015 0.65

H&L Plating 410 E. Willard Street Muncie IN CMP 0.0099 0.015 0.66

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.010 0.015 0.67
13

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Hohman Plating & Mfg, Inc. 814 Hillrose Avenue Dayton OH WAFS 0.012 0.015 0.77

Chromium Plating Co. 412 N. Cheyenne Tulsa OK CMP 0.012 0.015 0.78

Parker Hannifin-Vertical One Parker Drive Ashley IN PBS/CMP 0.012 0.015 0.80

Chromium Plating Co. 412 N. Cheyenne Tulsa OK CMP 0.013 0.015 0.84

Delta Airlines 1775 Aviation Boulevard Atlanta GA CMP 0.013 0.015 0.87

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.013 0.015 0.87

Empire Hard Chrome 1537 S. Wood Street Chicago IL PBS 0.013 0.015 0.87

U.S. Chrome Corporation of 

Ohio

107 Westboro Street Dayton OH CMP 0.013 0.015 0.87

Hausner Hard-Chrome, Inc. 670 Greenleaf Avenue Elk Grove Village IL CMP 0.015 0.015 0.99 1 This table summarizes the available data on emissions concentrations and was used to estimate the percentage of facilities that could meet the final limits. Some of the facilities in this table 

may be closed and it should be noted that this data set is different than the data set for annual emissions that was used to simulate and estimate actual emissions for the residual risk 

assessment.
14

Table 3. Summary of Actual Emission Concentration Data -- New Small Hard Chromium Electroplating1

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

PPI Aerospace Acquisition,

L.L.C.

23514 Groesbeck Hwy Warren MI PBS/CMP 0.00022 AMR limit N/A

D & B Metal Finishing 22803 Patmore Clinton Township MI WAFS/Cover 0.00060 0.015 0.040

Modern Hard Chrome Service 12880 East Nine Mile Road Warren MI CMP/HEPA 0.00067 0.015 0.044

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL MPME 0.00090 0.015 0.060

Diamond Hard Chrome 6110 Grand Avenue Cleveland IL CMP-PBS 0.0009 0.015 0.061

Bales Mold Service, Inc. 2824 Hitchcock Avenue Downers Grove IL CMP 0.0010 0.015 0.067

RR Donnelley 2801 West Old Route 30 Warsaw IN CMP/HEPA 0.0012 0.015 0.080

Hydra-Lock Corporation 25000 Joy Boulevard Mt. Clemens MI CMP 0.0014 0.015 0.093

H.V. Roll Center 1079 W. State Road 149 Chesterton IN CMP 0.0015 0.015 0.10

K&I Hard Chrome-System #1 

East Stack

1900 E. Main Street New Albany IN CMP 0.0017 0.015 0.11

Milac Manufacturing 165 S. Balfour Avenue Moultrie GA CMP 0.0017 0.015 0.11

D & B Metal Finishing 22803 Patmore Clinton Township MI WAFS/Cover 0.0020 0.015 0.13

Kings’ Mountain International 1755 South Battleground 

Avenue

King's Mountain NC PBS 0.0023 0.015 0.15

RR Donnelley and Sons 216 Greenfield Road Lancaster City PA CMP/HEPA 0.0023 0.015 0.15

AK Steel 6500 N US Hwy 21 Rockport IN CMP 0.0034 0.015 0.22

Southern Cylinder 1000 Bales Lane Clarksville IN CMP 0.0040 0.015 0.27

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL CMP 0.0042 0.015 0.28

Baycote 1302 Industrial Drive Mishawaka IN WAFS/CMP 0.0045 0.015 0.30

Armoloy of Illinois, Inc. 118 Simonds Avenue De Kalb IL CMP 0.0047 0.015 0.31

SMS Millcraft 671 Colbert Avenue Oil City PA CMP 0.0050 0.015 0.33

K&I Hard Chrome-System #2 

West Stack

1900 E. Main Street New Albany IN CMP 0.0056 0.015 0.37

Roembke 1580 Baker Drive Ossian IN CMP 0.0057 0.015 0.38
15

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Elkhart Products 700 Rainbow Road Elkhart IN CMP 0.0057 0.015 0.38

Electro-Tech, Inc. 100 West Poplar Street Meadville PA WAFS/CMP 0.0063 0.015 0.42

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0063 0.015 0.42

Electro Plating Service, Inc. 945 E. Ten Mile Road Madison Heights MI CMP 0.0063 0.015 0.42

Diamond Hard Chrome 6110 Grand Avenue Cleveland IL CMP-PBS 0.0066 0.015 0.44

Xaloy, Inc., Tanner Plating 

Division

1399 Countyline Road New Castle PA CMP 0.0070 0.015 0.47

Allied Signal 717 North Bendix South Bend IN WAFS 0.0074 0.015 0.49

PPI Aerospace Acquisition,

L.L.C.

23514 Groesbeck Hwy Warren MI PBS/CMP 0.0076 0.015 0.51

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0077 0.015 0.51

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0082 0.015 0.55

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.0097 0.015 0.64

Innovative Packaging 

Solutions

1405 West Missouri Street Evansville IN CMP 0.0099 0.015 0.66

Cope Brothers 5301 E SR 231 Leroy IN CMP 0.010 0.015 0.70

Chrome Crankshaft Co of III 6010 S New England Avenue Chicago IL CMP 0.011 0.015 0.71

Xaloy, Inc., Tanner Plating 

Division

1399 Countyline Road New Castle PA CMP 0.012 0.015 0.80

Biddle Precision 701 South Main Street Sheridan IN PBS/CMP 0.013 0.015 0.87 1 This table summarizes the available data on emissions concentrations and was used to estimate the percentage of facilities that could meet the final limits. Some of the facilities in this table 

may be closed and it should be noted that this data set is different than the data set for annual emissions that was used to simulate and estimate actual emissions for the residual risk 

assessment.
16

Table 4. Chromium Electroplating -- Summary of Actual Emission Concentration Data -- Existing Small Hard Chromium 

Electroplating1

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

Allison Transmission 4700 West 10th Street Indianapolis IN CMP 0.00062 0.030 0.021

Integrity Hard Chrome, L.L.C. 1300 National Avenue Addison IL Scrubber 0.00075 0.030 0.025

Richards Industries, Inc. 3170 Wasson Road Cincinnati OH CMP 0.0015 0.030 0.050

Harsh International, Inc. 600 Oak Avenue Eaton CO WAFS/PBS 0.0016 0.030 0.053

Microprecision Textron 525 Berne Street Berne IN WAFS 0.0021 0.030 0.070

Plating Perceptions, Inc. 8815 Herrick Road Twinsburg OH CMP 0.002 0.030 0.07

Hartzell Propeller, Inc. One Propeller Place Piqua OH PBS 0.0021 0.030 0.071

R&S Plating 2302 Bloyd Avenue Indianapolis IN PBS/CMP 0.0024 0.030 0.080

Plating Perceptions, Inc. 8815 Herrick Road Twinsburg OH CMP 0.003 0.030 0.08

Crown Plating 4221 N.E. St. Johns 

Boulevard, Unit G

Vancouver WA WAFS/Cover 0.0027 0.030 0.090

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0030 0.030 0.10

Hard Chrome Enterprises, Inc. 220 10th Street Lake Park FL CMP 0.003 0.030 0.11

Franke Plating Works, Inc. 2109 E. Washington Blvd Fort Wayne IN CMP 0.0037 0.030 0.12

Hi-Tech Plating Co, Inc. 1015 West 18th Street Erie PA WAFS/PBS 0.0039 0.030 0.13

Amcast, Geneva 700 Rainbow Road Geneva IN CMP 0.0043 0.030 0.14

Corning, Inc. 1025 Martin Street Greenville OH FB 0.0049 0.030 0.16

Gravure Process Company 4179 W Belmont Avenue Chicago IL CMP 0.0049 0.030 0.16

Precision Plating 407 Summit View Drive New Castle PA CMP 0.0050 0.030 0.17

Freudenberg NOK (Tobin 

Tool)

1004 W. Washington Street Shelbyville IN CMP 0.0063 0.030 0.21

Denver Metal Finishing 3100 East 43rd Avenue Denver CO WAFS 0.0076 0.030 0.25

Tools for Bending, 

Incorporated

194 W Dakota Avenue Denver CO WAFS/PBS 0.0080 0.030 0.27

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.0083 0.030 0.28
17

Company/Plant Name Street City State Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dscm 

Limit

Actual to 

MACT

CM Grinding 23550 Ardmore Trail South Bend IN WAFS 0.0087 0.030 0.29

Amcast, Elkhart 1255 Oak Street, P.O. Box 

1008

Elkhart IN CMP 0.0096 0.030 0.32

Muncie Precision 1001 East 18TH Street Muncie IN WAFS/FB 0.0098 0.030 0.33

Toppan Interamerica, Inc. 1131 Hwy 155 South McDonough GA CMP 0.0099 0.030 0.33

CM Grinding 23550 Ardmore Trail South Bend IN WAFS 0.010 0.030 0.33

NOVA Chrome, Inc. 3200 N Wolf Rd Franklin Park IL PBS/CMP 0.010 0.030 0.34

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.010 0.030 0.34

Rolls Royce/Allison Engine 2100-2355 So. Tibbs Avenue Indianapolis IN CMP 0.011 0.030 0.36

Economy Plating, Inc. 2350 N Elston Avenue Chicago IL CMP 0.014 0.030 0.46

West Falls Machine, Co. 11692 East Main Street East Aurora NY WAFS 0.015 0.030 0.50

Dover Industrial 2929 North Campbell Avenue Chicago IL WAFS 0.015 0.030 0.50

Dover Industrial 2929 North Campbell Avenue Chicago IL WAFS 0.016 0.030 0.54

Nussmier Engraving 933 Main Street, Evansville Evansville IN PBS/CMP 0.023 0.030 0.77 1 This table summarizes the available data on emissions concentrations and was used to estimate the percentage of facilities that could meet the final limits. Some of the facilities in this table 

may be closed and it should be noted that this data set is different than the data set for annual emissions that was used to simulate and estimate actual emissions for the residual risk 

assessment.
18

Table 5. Chromium Electroplating -- Summary of Actual Emission Concentration Data -- Decorative Cr Electroplating and 

Chromium Anodizing1

Company/Plant Name Street City State Process Control

Conc. 

mg/dscm 

Actual

Conc.

mg/dsc

m Limit

Actual to 

MACT

Century Plating Co. Inc. 2939 N. Oakley Avenue Chicago IL Decorative Cr MPME 0.000052 0.010 0.0052

American Plating 504 NE 2nd Street Winlock WA Decorative Cr WAFS 0.00020 0.010 0.020

Whyco Finishing Technologies, Inc 670 Waterbury Road Thomaston CT Decorative Cr WAFS/MPME 0.00025 0.010 0.025

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00038 0.010 0.038

Lacks Enterprises Inc. - Barden 4375 52nd Street Kentwood MI Decorative Cr WAFS/CMP 0.00043 0.010 0.043

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00053 0.010 0.053

Lacks Enterprises Inc. - Barden 4375 52nd Street Kentwood MI Decorative Cr WAFS/CMP 0.00060 0.010 0.060

Lacks Enterprises Inc. - Airlane 4260 Airlane Drive SE Kentwood MI Decorative Cr CMP 0.00068 0.010 0.068

Deco Plate Manufacturing 

Company

395 Demille Road Lapeer MI Decorative Cr MPME 0.0030 0.010 0.30

Chem Processing Inc. - Linden 

Oaks

3910 Linden Oaks Drive Rockford IL Decorative Cr MPME 0.0038 0.010 0.38

Hohman Plating & Mfg Inc. 814 Hillrose Avenue Dayton OH Decorative Cr WAFS 0.0044 0.015 0.29

Component Repair Technologies, 

Inc.

8507 Tyler Blvd Mentor Ohio Decorative Cr CMP 0.0048 0.010 0.48

American Nickeloid Company 131 Cherry Walnutport PA Decorative Cr PBS 0.0065 0.010 0.65

Component Repair Technologies, 

Inc.

8507 Tyler Blvd Mentor Ohio Decorative Cr CMP 0.0066 0.010 0.66

Kaman Aerospace Corp Helicopters 

Division

Old Winsor Road Bloomfield CT Cr Anodizing ME 0.0007 0.010 0.07

Poly-metals Finishing, Inc 1 Allen Street Springfield MA Cr Anodizing ME 0.001 0.01 0.1

LMI (Leonard Metals, Inc.) 2104 N 170th E Avenue Tulsa OK Cr Anodizing WS 0.0016 0.010 0.16 1 This table summarizes the available data on emissions concentrations and was used to estimate the percentage of facilities that could meet the final limits. Some of the facilities in this table 

may be closed and it should be noted that this data set is different than the data set for annual emissions that was used to simulate and estimate actual emissions for the residual risk 

assessment.
19

Table 6. Summary of Affected Plants for Proposed Emission Limits

Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing 

No. of affected plants nationwide 57 91 313 74 

No. of plants currently using WAFS 4 29 374 67

No. of plants currently using WAFS and can already 

meet proposed limits (i.e., do not need to add 

additional WAFS) – 20% of plant currently using 

WAFS

1 6 75 13

No. of plants that currently use WAFS and do not 

currently meet limit (i.e., plants that will need to add 

additional WAFS to meet proposed limits) – 80% of 

plant currently using WAFS

3 23 299 54

No. of plants that will begin using WAFS to meet 

the proposed limits 3 26 7 10

No. plants that will retrofit a CMP to meet the 

proposed limits 23 6 - -

No. plants that will retrofit a HEPA filter to meet the 

proposed limits 6 1 - -

No. of plants that will be required to complete 

performance test and have not previously performed 

testing that shows compliance with new limits

22 35 7 10
20

Table 7. Summary of Control Costs for Typical Chromium Electroplating Plants

Plant Type

Flow 

rate, 

ACFM

Total Tank

Volume, 

gal

Energy Input, 

Amp-hr/yr

HEPA Filter Retrofit CMP Retrofit WAFS WAFS

Annualized 

Cost, $/yr

Capital 

Cost, $

Annualized 

Cost, $/yr

Capital 

Cost, $

Annualized 

Cost, $/yra

Capital 

Cost, $

Large, hard 

chromium

35,247 15,852 107,061,750 $64,319 $164,939 $43,613 $193,106 $55,513 $0

Small, hard 

chromium

10,618 2,938 14,560,000 $22,647 $65,956 $19,403 $72,918 $7,983 $0

Decorative 

chromium

15,817 1,021 5,250,000 $31,443 $86,848 $24,513 $98,286 $2,857 $0

Chromium 

anodizing

14,998 1,381 1,400,000 $30,058 $83,560 $23,708 $94,293 $1,377 $0

a Includes additional 15 percent to account for the use of non-PFOS WAFS.
21

 Table 8. Estimated Cost of Emission Test -- 2 Electroplating Systems/Stacks - 2 hr test runs

Hours of testing 12 Assumes M 306, 3 runs, 2 hours each

No. of tests

Method 5 - PM 1 kiln stack

Method 202 - Condensable PM 1 kiln stack

Method 26A - HF/HCl 1 kiln stack

Method 306 2 1 kiln stack

Method 23 - Dioxins/furans 1 kiln stack, 2 dryer stacks

Total No. of tests 2

Days 3 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 2

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

 volumetric flow sampler 150

 CO2/O2 analyzer 600

 Sample lines 225

 Trailer to haul equipment 600

 Rental truck 300

 Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

 labor 1,160

 lodging 450

 per diem 120

 vehicle rental 180 One car

Total travel cost 1,910

Testing cost

 Mobilization 460 4 hours for site manager and Technical II
22

 Setup equipment 580 Assume 4 hours for 3-man crew

 Perform test 2,314 Includes downtime, assumed to be 33% of testing time

 Take down equipment 290 Assume 2 hours for 3-man crew

 Onsite contingency 182 Approximately 5% of testing cost for short-term delays

Total testing cost 3,826

Standby/overtime fees Not applicable

Laboratory Analysis

Method 5 - PM 0

Method 202 - Condensable PM 0

Method 26A - HF/HCl 0

Method 29 - Metals 5,300

Method 23 - Dioxins/furans 0

Total 5,300

Test report

 Data reduction and review 240 2 hr + 2 hr/test

 Report preparation 340 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

 Report review 240 1 hr + 0.5 hr/test for project manager

 Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 920

SUMMARY

Total equipment rental cost 2,775

Total travel cost 1,910

Total testing cost 3,826

Standby/overtime fees 0

Laboratory analysis cost 5,300

Total test report cost 920

TOTAL 14,730
Table 9. Summary of Nationwide Testing Costs

Plant Type

Estimate 

No. of 

Facilities 

Breakdown of Plants by 

No. of Stacksa Cost Per No. of Stacks

Total

Annualized 

1 2 3 1 2 3 Cost

Hard Cr electroplating, large 54 50% 50% $0 $401,127 $544,640 $945,767 $103,840

Hard Cr electroplating, small 68 30% 70% $251,911 $810,692 $0 $920,923 $101,112

Deco Cr electroplating 14 70% 30% $102,571 $60,629 $0 $163,199 $17,918

Cr anodizing 20 80% 20% $174,639 $60,216 $0 $234,856 $25,786

a For example, it is assumed that 50% of large hard chromium electroplating plants have two stacks, and 50% have three stacks.
24

Table 10. Summary of Baseline Emissions for Non-California Plants

Process

Simulated Emissions Actual Emissions Total

Average, 

lbs/yr

No. of 

plants

Total emissions, 

lbs/yr No. of 

plants

Total emissions, 

lbs/yr No. of 

plants

Total emissions, 

lbs/yr

lbs/yr tons/yr lbs/yr tons/yr lbs/yr tons/yr

Hard Cr electroplating, large 153 

 

389 

 

0.19 

 

35 

 

64.5 

 

0.03 

 

188 

 

454 

 

0.23 2.41

Hard Cr electroplating, small 328 

 

191 

 

0.10 

 

66 

 

32.4 

 

0.02 

 

394 

 

223 

 

0.11 0.57

Decorative Cr electroplating 389 

 

199 

 

0.10 

 

34 

 

22.8 

 

0.01 

 

423 

 

222 

 

0.11 0.52

Cr anodizing 133 

 

54 

 

0.03 

 

7 

 

2.5 

 

0.001 

 

140 

 

57 

 

0.03 0.40

Total 1,003 

 

833 

 

0.42 

 

142 

 

122.3 

 

0.061 

 

1,145 

 

955 

 

0.477 0.83
25

Table 11. Summary of Cost Effectiveness for Promulgated Requirements

Process

No. of affected 

facilities Capital Cost, $

Annualized Cost, 

$/yr

Emissions 

reductions, 

lbs/yr

Cost 

Effectiveness, $/lb

Large, hard chromium electroplating 57 $6,376,848 $1,686,035 148 $11,379

Small, hard chromium electroplating 91 $1,424,387 $475,526 33 $14,600

Decorative chromium electroplating 313 $163,199 $166,151 35 $4,773

Chromium anodizing 74 $234,856 $50,624 8 $6,575

Total 535 $8,199,290 $2,378,336 224 $10,618
26

Table 12. Summary of Costs and Emissions Reductions for Promulgated Requirements

Parameter Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing Total

Emission Limit

Current Emission Limit 0.015 0.015/0.030 0.010 0.010

Proposed Emission Limit, existing sources 0.011 0.015 0.0070 0.0070

Proposed Emission Limit, new sources 0.0060 0.0060 0.0060 0.0060

No. of Plants

No. of Existing Plants 188 263 423 140 1,014 

No. of Affected Plants Subject to New Limits

Total 36 62 381 77 556 

WAFS only (15%) 4 29 374 67 474 

% of Facilities that use WAFS and can already 

meet limit (do not need additional WAFS) 20% 20% 20% 20%

New WAFS (100%) 3 26 7 10 46 

CMP Retrofit 23 6 - - 29 

HEPA Retrofit 6 1 - - 7 

% of facilities whose compliance test met 

revised limit 88% 89% 90% 90%

Assumed % of facilities that still operate as 

during test 80% 80% 80% 80%

Testing 54 68 14 20 167 

Capital Cost

CMP Control Equipment $4,441,448 $437,508 $0 $0 4,878,956 

HEPA Control Equipment $989,632 $65,956 $0 $0 1,055,588 

Testing $945,767 $920,923 $163,199 $234,856 2,406,426 

Total $6,376,848 $1,424,387 $163,199 $234,856 8,340,970 

Capital Cost Per Plant $118,090 $20,947 $11,657 $11,743

Annualized Cost

CMP Control Equipment $1,003,095 $116,416 $0 $0 1,119,511 
27

Parameter Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing Total

HEPA Control Equipment $385,914 $22,647 $0 $0 408,561 

Revised WAFS* $193,186 $235,350 $148,233 $24,838 601,607 

Testing $103,840 $101,112 $17,918 $25,786 264,213 

Total $1,686,035 $475,526 $166,151 $50,624 2,393,892 

Annualized Cost Per Plant $31,223 $6,993 $11,868 $2,531

Emissions

Total (Non CA) Baseline Emissions, lbs/yr 453.7 223.0 221.6 56.6 955 

Emissions Reductions, lbs/yr 148.2 32.6 34.8 7.7 223 

Cost Effectiveness, $/lb $11,379 $14,600 $4,773 $6,575 $10,723

No. of plants that use only WAFS 3 23 299 54 379 

Cost per plant $8,327 $1,198 $429 $207 

No. of plants that only must test 22 35 7 10 85 

Cost per plant $1,907 $1,484 $1,306 $1,262

No. of plants that must use WAFS & test 3 26 7 10 46 

WAFS cost per plant $55,513 $7,983 $2,857 $1,377

Testing cost per plant $1,907 $1,484 $1,306 $1,262

Total cost per plant $57,420 $9,467 $4,163 $2,638

No. of plants that must retrofit APCD & test 29 7 - - 36 

No. of plants that must retrofit CMP & test 23 6 - - 29 

 CMP Cost 43,613 19,403 - - 

No. of plants that must retrofit HEPA & test

 

6 

 

1 

- - 7 

 HEPA Cost $64,319 $22,647 - - 

Testing cost $1,907 $1,484 - - 
28

Parameter Large Hard Cr Small Hard Cr Decorative Cr Cr Anodizing Total

Average cost per plant CMP $45,519 $20,887 - - 

Average cost per plant HEPA $66,226 $24,131 - - 

No. of plants not required to do anything 131 172 110 66 468 

* Assume 20% of existing already meet 40/33 and the remaining plants have to add 15% more WAFS.

** Includes plants that would not have to install or use any additional add-on controls or add any additional WAFS to meet surface tension limits 

and would not be required to test (i.e., sum of values obtained from row immediately above in this table plus the values from row 4 of Table 6 

above) .
29

Table 13. Summary of Cost Effectiveness for Other Regulatory Options Considered at Supplemental Proposal1,9

Option Process

No. of 

affected 

facilities8 Capital Cost, $

Annualized Cost, 

$/yr

Emissions 

reductions, 

lbs/yr

Cost 

Effectiveness, 

$/lb

Option A2 New small hard Cr 34 $571,000 $243,000 7 $36,000 

Option B3 Large hard Cr 76 $2,847,000 $4,182,000 169 $24,700

Option C4 Existing small hard Cr 140 $2,447,000 $1,225,000 64 $19,200

Option D5 Large hard Cr 97 $3,414,000 $5,368,000 180 $29,900

Option E6 Existing small hard Cr 171 $3,161,000 $1,585,000 81 $19,700

Option F7 New small hard Cr 80 $1,268,000 $653,000 35 $18,800

1

All options assume that, of the plants that would need to reduce emissions, 10 percent would have to install add-on controls. Costs calculations account do 

not include testing costs for facilities that would be exempt from testing and assume that no facilities currently meet the new emissions limit. 

2 Option A reduces the emission limit to 67% of the current limit. 

3 Option B reduces the emission limit to 50% of the current limit. 

4 Option C reduces the emission limit to 33% of the current limit. 

5 Option D reduces the emission limit to 0.006 mg/dscm.

6 Option E reduces the emission limit to 0.006 mg/dscm.

7 Option F reduces the emission limit to 0.006 mg/dscm.

8 Number of plants that would have to install additional controls. 

9 Table 13 represents the regulatory options that were considered during the supplemental proposal and does not reflect the changes in cost methodologies 

and affected plants that have occurred since the supplemental proposal. 

Table 14. Summary of Cost Effectiveness for Retrofitting HEPA Filters on Existing Hard Sources - Considered at October 2010

Proposal

Process

No. of 

plants

Capital 

Cost, $

Annualized 

Cost, $/yr

Emissions 

reductions,

lbs/yr

Cost 

Effectiveness, 

$/lb

Large, hard chromium 188 $31,008,484 $12,450,399 453.6 $27,448

Small hard chromium 394 $25,986,568 $9,507,597 222.9 $42,655
Figure 1. Cumulative Distribution Curve for Large Hard Chromium Electroplating

Figure 2. Cumulative Distribution Curve for Small Hard Chromium Electroplating

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Cumlative Distribution of PLants

Percentage of Total Emissions

Cumulative Emissions Distribution 

Large Hard Cr Electroplating

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

100.0%

0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0%

Cumulative Distribution of Plants

Percentage of Total Emissions

Cumulative Emissions Distribution 

Small Hard Chromium Electroplating
31

Figure 3. Cumulative Distribution Curve for Decorative Chromium Electroplating

Figure 4. Cumulative Distribution Curve for Chromium Anodizing

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Cumulative Distribution of Plants

Percentage of Total Emissions

Cumulative Emissions Distribution 

Decorative Chromium Electroplating

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Cumulative Distribution of Plants

Percentage of Total Emissions

Cumulative Emissions Distribution 

Chromium Anodizing
Appendix A 

Methodology Used to Determine Number of Plants Subject to

the Requirements of the Proposed Amendments for Chromium Electroplating

No. Description Basis/Methodology

1 Number of Existing 

Plants

• For the October 2010 proposal, the relative percentages of each type of chromium electroplating plant were 

determined. (See Estimated Number of Chromium Electroplating Plants, May 25, 2010, which is available in the 

docket for the proposed rulemaking.)

• At that time, it was estimated there were about 1,770 plants nationwide.

• Between February 2011 and April 2011, extensive data gathering was conducted and additional data was 

provided in comments to the supplemental proposal. The results of these efforts indicated that many of the 

plants were no longer in operation, and the resulting data set showed a total of 1,343plants still in operation.

• The resulting number of Non California plants were:

o 188 large hard chromium plants

o 394 small hard chromium plants (263 small hard existing)

o 423 decorative hard chromium plants

o 140 chromium anodizing plants

• The resulting number of California plants were:

o 70 hard chromium plants

o 94 decorative hard chromium plants

o 34 chromium anodizing plants 

2 Number of Affected 

Plants

• For reasons explained elsewhere, the plants in California were separated from the list of plants in other States. 

• This resulted in the following numbers of non-California plants:

o 188 large hard chromium plants

o 394 small hard chromium plants (263 small hard existing)

o 423 decorative hard chromium plants

o 140 chromium anodizing plants

o 1,145 total plants
33

No. Description Basis/Methodology

3

Plants that only use 

WAFS for emission 

control

• To determine control costs, it was necessary to determine the estimated number of plants in each category 

that use WAFS and that use add-on controls. Data from hundreds of permits and other documents were 

compiled on control methods and the percentages of each were calculated. These percentages are provided in 

Table 12 of the Profile of Chromium Electroplating Processes and Emissions, Emission Standards Technical 

Support and Post Promulgation Activities, January 6, 2012 (hereafter referred to as the Industry Profile).

• These percentages were applied to the number of affected plants to determine the number of plants that 

currently use WAFS for emission control, resulting in the following: 

o 4 large hard chromium plants

o 29 small hard chromium plants

o 374 decorative hard chromium plants

o 67 chromium anodizing plants

o 474 total plants

• It was assumed that these plants would continue to use WAFS to meet the proposed surface tension limits, and 

would not switch to add-on control devices. Plants that meet the surface tension limits are not subject to, and 

do not have to comply with, the emissions limits.

• Of these plants, we assume that 80% would need to add additional WAFS to meet the proposed lower surface 

tension limits. The data compiled for the surface tension analysis indicated that many plants already operate 

below the proposed surface tension limits. Therefore the assumption of 80% seemed reasonable. 

o 3 large hard chromium plants

o 23 small hard chromium plants

o 299 decorative chromium plants

o 54 chromium anodizing plants

• Of these plants, we assume that 20% would not need any additional WAFS to meet the proposed lower surface 

tension limits, thus would have no additional costs. 

o 1 large hard chromium plants

o 6 small hard chromium plants

o 75 decorative chromium plants

o 13 chromium anodizing plants
34

No. Description Basis/Methodology

4

Number of hard 

chromium 

electroplating plants 

that must use 

additional control to 

meet the proposed 

limits

• To determine the number of facilities that would be subject to the proposed emission limits and would need 

additional controls to meet those limits, the available emissions data for each process type were first ranked. 

These data are provided in Tables 1 through 4 of the Industry Profile. The data are also provided in Tables 2 

through 5 of Procedures for Determining Control Costs and Cost Effectiveness for Chromium Electroplating 

Supplemental Proposal, January 19, 2012 (hereafter referred to as the Cost Memo). 

• Next, the percentage of plants in the rankings that would not meet the proposed emission limit was 

determined by multiplying the proposed limit by 85% to allow for a compliance margin, and this value was used 

to determine the percentage of plants that would need additional control. For example, for large hard 

chromium, the proposed limit is 0.011 mg/dscm, and 85% of 0.011 is 0.0094. 

• The percentage of plants with emissions greater than this value was determined from the table of ranked 

sources. For hard chromium electroplating, these percentages were:

o 17% for large hard chromium

o 14% for existing small hard chromium

• After subtracting the number of plants that use WAFS from the total, these percentages were applied to the 

remainder, resulting in the following plants that would need additional control: 

o 32 large hard chromium plants

o 33 existing small hard chromium plants

o New small hard chromium plants would not be required to meet a more stringent emission limit, but if they 

had, the same methodology would have been used.

5

Number of decorative 

chromium and 

chromium anodizing 

plants that must use 

additional control to 

meet the proposed 

limits

o The same methodology described above for hard chromium was used to determine the number of decorative 

chromium electroplating and chromium anodizing plants that would need additional control. 

• However, because the ranked emission data showed that all plants would meet the proposed limits, it was 

conservatively assumed the 14 percent of plants that use WAFS would need to reduce emissions. This resulted 

in the following number of plants that would need additional control: 

o 7 decorative chromium plants

o 10 chromium anodizing plants
35

No. Description Basis/Methodology

6

Number of plants that 

would use WAFS as the 

additional control to 

meet the proposed 

emission limits

• It was assumed that 10% of large hard chromium plants and 80% percent of small hard chromium plants that 

needed additional control to meet the proposed limits could use WAFS to reduce emissions enough to meet 

those limits. The data indicate that many plants use WAFS to supplement the emissions reductions achieved 

using an add-on control device. This resulted in the following numbers of plants: 

o 3 large hard chromium plants

o 26 small hard chromium plants

o 7 decorative hard chromium plants

o 10 chromium anodizing plants

7

Number of plants that 

would retrofit add-on 

controls to meet the 

proposed emission 

limits

• The number of plants that would retrofit add-on controls was determined as the difference between the 

number needing additional controls (see Items 4 and 5 above) and the number of plants that would use WAFS 

as the additional control (see Item 6 above). This resulted in the following number of plants: 

o 29 large hard chromium plants

o 7 small hard chromium plants

o 0 (zero) decorative hard chromium plants

o 0 (zero) chromium anodizing plants

8

Number of plants that 

would retrofit CMPs 

and HEPA filters

• It was assumed that half of the plants listed in Item 7 above would retrofit CMPs and the remainder would 

retrofit HEPA filters (with rounding as needed). The available data show that most plants could meet the 

proposed limits using a CMP and would not need to retrofit a HEPA filter. However, it was conservatively 

assumed that half of these plants would retrofit a HEPA filter. This resulted in the following:

o 23 large hard chromium plants would retrofit CMPs

o 6 large hard chromium plants would retrofit HEPA filters

o 6 small hard chromium plants would retrofit CMPs

o 1 small hard chromium plants would retrofit HEPA filters
36

No. Description Basis/Methodology

9

Number of plants that 

would be required to 

conduct emission tests

• The proposed amendments would grant an exemption from testing for plants that previously demonstrated 

that their sources met the proposed emission limits. To determine the number of plants that satisfied this 

condition, the ranked data discussed in Item 4 were used.

• It was assumed that 20% of those that had previously met the proposed limit would have undergone changes 

that would have negated their exemption. Assuming 20% is a conservative estimate to help ensure that the 

additional testing costs would not be underestimated.

• The number of plants that would have to test was determined as the number of plants that had not met the 

proposed limits previously, plus the 20% with negated exemptions.

• For example, for large hard chromium, 12% had not met the revised emission limit. Once you include the 20% 

lost their exemption you get 54 large hard chromium plants which equates to 184 x (1- 0.88*0.80). For small 

hard chromium, decorative, and anodizing the percentages that had not met the proposed limit were 17%, 

10%, and 10%, respectively. Applying this methodology to the source categories results in the following 

numbers of plants that must test:

o 54 large hard chromium plants

o 68 small hard chromium plants

o 14 decorative hard chromium plants

o 20 chromium anodizing plants

10

Number of plants that 

are required only to 

conduct emission tests

• Some plants would be subject to the emission limits and would be required to test, but would not be required 

to add additional controls. These numbers were determined by subtracting from the number of plants 

required to test (see Item 9 above), the number of plants required to install or use additional controls.

• For example, for large hard chromium, the calculation is: 

54 total - 3 (use WAFS) - 23 (retrofit CMP) - 6 (retrofit HEPA) = 22 plants

• Applying these assumptions to the source categories results in the following numbers of plants that are 

required only to test:

o 22 large hard chromium plants

o 35 small hard chromium plants

o 7 decorative hard chromium plants

o 10 chromium anodizing plants
37

No. Description Basis/Methodology

11 Number of plants with 

no requirements

• The number of plants with no requirements is simply the total number of plants in the category, minus the 

number of plants that already use WAFS as the control method and will need to add additional WAFS to meet 

the proposed limits (see Item 3 above), minus the number required to test. (Note that the numbers of plants 

that must use additional control are included among those that must test.) This results in the following 

numbers of plants:

o 131large hard chromium plants (i.e., 188 - 3 - 54 = 131) 

o 172 small hard chromium plants (i.e., 263 - 23 - 68 = 172) 

o 110decorative hard chromium plants (i.e., 423 - 299 - 14 = 110)

o 66 chromium anodizing plants (i.e., 140 - 54 - 20 = 66)
38

Appendix B

Cumulative Distribution Curve Data
39

Large Hard Chromium Electroplating Cumulative Distribution Data

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1093 0.0038 100.0% 100.0%

949 0.0060 99.5% 100.0%

521 0.032 98.9% 100.0%

656 0.040 98.4% 100.0%

947 0.088 97.9% 100.0%

747 0.100 97.3% 100.0%

1418 0.100 96.8% 99.9%

54 0.114 96.3% 99.9%

641 0.124 95.7% 99.9%

32 0.125 95.2% 99.9%

129 0.128 94.7% 99.8%

1145 0.131 94.1% 99.8%

304 0.141 93.6% 99.8%

333 0.156 93.1% 99.7%

407 0.170 92.6% 99.7%

416 0.182 92.0% 99.7%

473 0.184 91.5% 99.6%

303 0.186 91.0% 99.6%

577 0.199 90.4% 99.5%

668 0.213 89.9% 99.5%

675 0.224 89.4% 99.4%

759 0.228 88.8% 99.4%

825 0.243 88.3% 99.3%

927 0.258 87.8% 99.3%

962 0.273 87.2% 99.2%

752 0.273 86.7% 99.1%

1154 0.288 86.2% 99.1%

1285 0.295 85.6% 99.0%

651 0.300 85.1% 98.9%

1187 0.303 84.6% 98.9%

1311 0.318 84.0% 98.8%

604 0.320 83.5% 98.7%

1370 0.334 83.0% 98.7%

634 0.348 82.4% 98.6%

10 0.349 81.9% 98.5%

799 0.353 81.4% 98.4%

14 0.365 80.9% 98.3%

15 0.380 80.3% 98.2%

18 0.397 79.8% 98.2%

24 0.413 79.3% 98.1%

30 0.429 78.7% 98.0%

122 0.445 78.2% 97.9%

1015 0.452 77.7% 97.8%

128 0.461 77.1% 97.7%

143 0.478 76.6% 97.5%
40

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

288 0.492 76.1% 97.4%

149 0.494 75.5% 97.3%

157 0.511 75.0% 97.2%

801 0.525 74.5% 97.1%

164 0.528 73.9% 97.0%

196 0.545 73.4% 96.8%

557 0.559 72.9% 96.7%

206 0.562 72.3% 96.6%

299 0.579 71.8% 96.4%

326 0.596 71.3% 96.3%

39 0.600 70.7% 96.2%

382 0.613 70.2% 96.0%

386 0.631 69.7% 95.9%

1375 0.648 69.1% 95.7%

391 0.649 68.6% 95.6%

418 0.667 68.1% 95.4%

434 0.703 67.6% 95.3%

449 0.721 67.0% 95.1%

523 0.758 66.5% 94.9%

553 0.795 66.0% 94.8%

555 0.815 65.4% 94.6%

862 0.828 64.9% 94.4%

593 0.834 64.4% 94.2%

935 0.846 63.8% 94.0%

665 0.847 63.3% 93.8%

624 0.853 62.8% 93.6%

697 0.873 62.2% 93.4%

706 0.892 61.7% 93.2%

709 0.912 61.2% 93.0%

1326 0.926 60.6% 92.8%

713 0.931 60.1% 92.6%

1102 0.946 59.6% 92.3%

763 0.951 59.0% 92.1%

783 0.971 58.5% 91.9%

945 0.973 58.0% 91.7%

800 0.991 57.4% 91.4%

694 1.00 56.9% 91.2%

806 1.01 56.4% 91.0%

821 1.03 55.9% 90.7%

810 1.03 55.3% 90.5%

812 1.05 54.8% 90.2%

817 1.07 54.3% 90.0%

843 1.09 53.7% 89.8%

859 1.11 53.2% 89.5%

888 1.16 52.7% 89.2%

910 1.18 52.1% 89.0%
41

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

998 1.25 51.6% 88.7%

1069 1.27 51.1% 88.4%

1081 1.29 50.5% 88.1%

1104 1.31 50.0% 87.8%

1115 1.34 49.5% 87.5%

1116 1.36 48.9% 87.2%

990 1.37 48.4% 86.9%

1118 1.38 47.9% 86.5%

632 1.42 47.3% 86.2%

1203 1.43 46.8% 85.9%

1232 1.46 46.3% 85.5%

1251 1.48 45.7% 85.2%

1264 1.53 45.2% 84.8%

1291 1.58 44.7% 84.5%

1321 1.63 44.1% 84.1%

1346 1.66 43.6% 83.7%

1358 1.69 43.1% 83.3%

1363 1.71 42.6% 83.0%

1377 1.74 42.0% 82.6%

1426 1.80 41.5% 82.1%

83 1.91 41.0% 81.7%

102 1.94 40.4% 81.3%

198 2.03 39.9% 80.8%

212 2.10 39.4% 80.3%

231 2.13 38.8% 79.9%

265 2.19 38.3% 79.4%

273 2.22 37.8% 78.8%

274 2.26 37.2% 78.3%

284 2.29 36.7% 77.8%

317 2.33 36.2% 77.2%

323 2.36 35.6% 76.7%

1185 2.38 35.1% 76.1%

390 2.43 34.6% 75.6%

946 2.44 34.0% 75.0%

406 2.47 33.5% 74.5%

428 2.51 33.0% 73.9%

438 2.54 32.4% 73.3%

448 2.58 31.9% 72.7%

464 2.62 31.4% 72.1%

502 2.63 30.9% 71.5%

480 2.66 30.3% 70.9%

512 2.74 29.8% 70.2%

551 2.78 29.3% 69.6%

559 2.82 28.7% 68.9%

562 2.87 28.2% 68.3%

612 3.04 27.7% 67.6%
42

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

617 3.09 27.1% 66.9%

623 3.13 26.6% 66.2%

203 3.22 26.1% 65.4%

639 3.23 25.5% 64.7%

648 3.28 25.0% 63.9%

652 3.38 24.5% 63.1%

661 3.43 23.9% 62.4%

1003 3.45 23.4% 61.6%

667 3.48 22.9% 60.7%

678 3.54 22.3% 59.9%

679 3.59 21.8% 59.1%

689 3.65 21.3% 58.3%

690 3.71 20.7% 57.4%

751 3.77 20.2% 56.5%

754 3.83 19.7% 55.6%

785 3.89 19.1% 54.7%

798 3.95 18.6% 53.8%

627 3.99 18.1% 52.9%

868 4.29 17.6% 52.0%

875 4.37 17.0% 51.0%

877 4.44 16.5% 49.9%

940 4.52 16.0% 48.9%

953 4.60 15.4% 47.8%

972 4.68 14.9% 46.8%

1443 4.69 14.4% 45.7%

437 4.76 13.8% 44.6%

994 4.77 13.3% 43.5%

996 4.86 12.8% 42.3%

1004 4.95 12.2% 41.2%

1012 5.04 11.7% 40.0%

590 5.05 11.2% 38.9%

1053 5.35 10.6% 37.7%

1067 5.46 10.1% 36.4%

1091 5.70 9.6% 35.1%

1094 5.83 9.0% 33.8%

499 6.06 8.5% 32.4%

1148 6.10 8.0% 31.0%

1157 6.25 7.4% 29.6%

782 6.53 6.9% 28.1%

1200 6.57 6.4% 26.6%

1209 6.75 5.9% 25.0%

1238 7.38 5.3% 23.5%

1244 7.62 4.8% 21.7%

1292 8.51 4.3% 19.9%

1301 8.88 3.7% 17.9%

1312 9.32 3.2% 15.9%
43

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1353 9.85 2.7% 13.7%

1382 10.52 2.1% 11.4%

498 10.75 1.6% 8.9%

1420 12.57 1.1% 6.4%

1464 14.65 0.5% 3.4%
44

Small Hard Chromium Electroplating Cumulative Distribution Data

Plant ID Emissions, 

lbs/yr

Cumulative 

Plant 

Distribution

Percentage of 

Total 

Emissions

A 0.013 100.0% 100.0%

B 0.029 96.0% 99.9%

C 0.049 92.0% 99.7%

D 0.071 88.0% 99.4%

E 0.095 84.0% 99.0%

F 0.121 80.0% 98.4%

G 0.150 76.0% 97.6%

H 0.181 72.0% 96.7%

I 0.216 68.0% 95.6%

J 0.252 64.0% 94.2%

K 0.293 60.0% 92.6%

L 0.337 56.0% 90.8%

M 0.386 52.0% 88.7%

N 0.440 48.0% 86.2%

O 0.502 44.0% 83.5%

P 0.570 40.0% 80.3%

Q 0.648 36.0% 76.8%

R 0.740 32.0% 72.7%

S 0.845 28.0% 68.0%

T 0.971 24.0% 62.7%

U 1.128 20.0% 56.6%

V 1.326 16.0% 49.6%

W 1.603 12.0% 41.2%

X 2.030 8.0% 31.2%

Y 2.940 4.0% 18.4%
45

Decorative Chromium Electroplating Cumulative Distribution Data

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1173 0.00023 100.0% 100.0%

3 0.00028 99.8% 100.0%

9 0.00034 99.6% 100.0%

17 0.00040 99.3% 100.0%

20 0.00046 99.1% 100.0%

26 0.00053 98.9% 100.0%

27 0.00060 98.7% 100.0%

31 0.00068 98.5% 100.0%

35 0.00076 98.3% 100.0%

37 0.00084 98.0% 100.0%

51 0.00093 97.8% 100.0%

60 0.00102 97.6% 100.0%

66 0.00112 97.4% 100.0%

86 0.00122 97.2% 100.0%

88 0.00133 96.9% 100.0%

105 0.00144 96.7% 100.0%

108 0.00155 96.5% 100.0%

126 0.00167 96.3% 100.0%

127 0.00179 96.1% 100.0%

132 0.00192 95.9% 100.0%

133 0.00205 95.6% 100.0%

734 0.00212 95.4% 100.0%

134 0.00219 95.2% 100.0%

135 0.00233 95.0% 100.0%

137 0.00248 94.8% 100.0%

146 0.00264 94.6% 100.0%

150 0.00279 94.3% 100.0%

153 0.00294 94.1% 100.0%

600 0.00300 93.9% 100.0%

101 0.00306 93.7% 100.0%

163 0.00310 93.5% 100.0%

174 0.00327 93.2% 100.0%

179 0.00344 93.0% 100.0%

186 0.00362 92.8% 100.0%

201 0.00380 92.6% 100.0%

210 0.00399 92.4% 100.0%

213 0.00418 92.2% 100.0%

214 0.00437 91.9% 100.0%

1361 0.00456 91.7% 100.0%

218 0.00458 91.5% 100.0%

226 0.00479 91.3% 100.0%

253 0.00499 91.1% 100.0%

267 0.00521 90.8% 100.0%

280 0.00544 90.6% 100.0%
46

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

291 0.00566 90.4% 100.0%

292 0.00589 90.2% 100.0%

294 0.00612 90.0% 99.9%

296 0.00637 89.8% 99.9%

305 0.00661 89.5% 99.9%

308 0.00686 89.3% 99.9%

309 0.00711 89.1% 99.9%

312 0.00736 88.9% 99.9%

332 0.00763 88.7% 99.9%

334 0.00789 88.5% 99.9%

342 0.00815 88.2% 99.9%

350 0.00842 88.0% 99.9%

352 0.00870 87.8% 99.9%

896 0.00882 87.6% 99.9%

362 0.00899 87.4% 99.9%

364 0.00929 87.1% 99.9%

366 0.00959 86.9% 99.9%

372 0.00989 86.7% 99.9%

373 0.0102 86.5% 99.9%

375 0.0105 86.3% 99.9%

381 0.0108 86.1% 99.9%

384 0.0112 85.8% 99.9%

396 0.0115 85.6% 99.9%

402 0.0118 85.4% 99.9%

412 0.0122 85.2% 99.9%

420 0.0125 85.0% 99.9%

421 0.0129 84.7% 99.9%

432 0.0132 84.5% 99.8%

435 0.0136 84.3% 99.8%

452 0.0140 84.1% 99.8%

455 0.0144 83.9% 99.8%

457 0.0147 83.7% 99.8%

458 0.0151 83.4% 99.8%

462 0.0155 83.2% 99.8%

463 0.0159 83.0% 99.8%

1237 0.0160 82.8% 99.8%

467 0.0163 82.6% 99.8%

471 0.0167 82.4% 99.8%

472 0.0172 82.1% 99.8%

475 0.0176 81.9% 99.8%

510 0.0180 81.7% 99.8%

511 0.0184 81.5% 99.8%

522 0.0189 81.3% 99.7%

531 0.0193 81.0% 99.7%

535 0.0198 80.8% 99.7%
47

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

545 0.0202 80.6% 99.7%

554 0.0207 80.4% 99.7%

565 0.0211 80.2% 99.7%

568 0.0216 80.0% 99.7%

569 0.0221 79.7% 99.7%

574 0.0226 79.5% 99.7%

575 0.0231 79.3% 99.7%

583 0.0236 79.1% 99.7%

585 0.0241 78.9% 99.6%

589 0.0246 78.6% 99.6%

591 0.0251 78.4% 99.6%

592 0.0256 78.2% 99.6%

595 0.0262 78.0% 99.6%

599 0.0267 77.8% 99.6%

603 0.0278 77.6% 99.6%

608 0.0283 77.3% 99.6%

609 0.0289 77.1% 99.6%

613 0.0294 76.9% 99.5%

636 0.0300 76.7% 99.5%

638 0.0306 76.5% 99.5%

646 0.0312 76.3% 99.5%

660 0.0318 76.0% 99.5%

662 0.0324 75.8% 99.5%

824 0.0327 75.6% 99.5%

663 0.0330 75.4% 99.4%

673 0.0337 75.2% 99.4%

682 0.0343 74.9% 99.4%

683 0.0349 74.7% 99.4%

711 0.0356 74.5% 99.4%

728 0.0362 74.3% 99.4%

732 0.0369 74.1% 99.4%

737 0.0376 73.9% 99.3%

749 0.0382 73.6% 99.3%

757 0.0389 73.4% 99.3%

762 0.0396 73.2% 99.3%

773 0.0403 73.0% 99.3%

786 0.0410 72.8% 99.3%

787 0.0417 72.5% 99.2%

809 0.0424 72.3% 99.2%

813 0.0432 72.1% 99.2%

827 0.0439 71.9% 99.2%

828 0.0447 71.7% 99.2%

839 0.0454 71.5% 99.1%

840 0.0462 71.2% 99.1%

846 0.0470 71.0% 99.1%
48

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

849 0.0477 70.8% 99.1%

851 0.0485 70.6% 99.1%

852 0.0493 70.4% 99.0%

853 0.0502 70.2% 99.0%

854 0.0510 69.9% 99.0%

869 0.0518 69.7% 99.0%

185 0.0519 69.5% 98.9%

873 0.0526 69.3% 98.9%

874 0.0535 69.1% 98.9%

876 0.0543 68.8% 98.9%

879 0.0552 68.6% 98.9%

880 0.0561 68.4% 98.8%

883 0.0569 68.2% 98.8%

886 0.0578 68.0% 98.8%

903 0.0587 67.8% 98.8%

906 0.0596 67.5% 98.7%

907 0.0605 67.3% 98.7%

912 0.0614 67.1% 98.7%

913 0.0623 66.9% 98.7%

923 0.0633 66.7% 98.6%

933 0.0642 66.4% 98.6%

937 0.0652 66.2% 98.6%

954 0.0662 66.0% 98.5%

955 0.0671 65.8% 98.5%

957 0.0681 65.6% 98.5%

976 0.0691 65.4% 98.5%

977 0.0701 65.1% 98.4%

985 0.0711 64.9% 98.4%

987 0.0721 64.7% 98.4%

1007 0.0732 64.5% 98.3%

1009 0.0742 64.3% 98.3%

1010 0.0753 64.1% 98.3%

1017 0.0764 63.8% 98.2%

1020 0.0775 63.6% 98.2%

1083 0.0784 63.4% 98.2%

1023 0.0786 63.2% 98.1%

99 0.0793 63.0% 98.1%

1027 0.0797 62.7% 98.1%

1041 0.0808 62.5% 98.0%

1063 0.0819 62.3% 98.0%

1073 0.0831 62.1% 98.0%

1078 0.0843 61.9% 97.9%

1079 0.0854 61.7% 97.9%

1086 0.0866 61.4% 97.8%

1087 0.0878 61.2% 97.8%
49

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1088 0.0890 61.0% 97.8%

1097 0.0902 60.8% 97.7%

1117 0.0914 60.6% 97.7%

1123 0.0927 60.3% 97.7%

1132 0.0939 60.1% 97.6%

1136 0.0951 59.9% 97.6%

1138 0.0963 59.7% 97.5%

1139 0.0976 59.5% 97.5%

1140 0.0989 59.3% 97.4%

1162 0.100 59.0% 97.4%

1166 0.101 58.8% 97.4%

1175 0.103 58.6% 97.3%

1181 0.104 58.4% 97.3%

1184 0.106 58.2% 97.2%

1188 0.107 58.0% 97.2%

1196 0.108 57.7% 97.1%

1197 0.110 57.5% 97.1%

1198 0.111 57.3% 97.0%

1205 0.112 57.1% 97.0%

1444 0.114 56.9% 96.9%

1208 0.114 56.6% 96.9%

795 0.115 56.4% 96.8%

1211 0.115 56.2% 96.8%

1233 0.117 56.0% 96.7%

1235 0.118 55.8% 96.7%

1236 0.120 55.6% 96.6%

1016 0.120 55.3% 96.6%

1242 0.121 55.1% 96.5%

1245 0.123 54.9% 96.5%

1252 0.124 54.7% 96.4%

1254 0.126 54.5% 96.4%

1259 0.128 54.2% 96.3%

1267 0.129 54.0% 96.3%

1271 0.131 53.8% 96.2%

1275 0.133 53.6% 96.1%

1277 0.134 53.4% 96.1%

1278 0.136 53.2% 96.0%

1293 0.138 52.9% 96.0%

1295 0.139 52.7% 95.9%

1296 0.141 52.5% 95.8%

1297 0.143 52.3% 95.8%

1303 0.144 52.1% 95.7%

1307 0.146 51.9% 95.7%

1324 0.148 51.6% 95.6%

1325 0.150 51.4% 95.5%
50

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1327 0.151 51.2% 95.5%

1329 0.153 51.0% 95.4%

344 0.154 50.8% 95.3%

1330 0.155 50.5% 95.3%

1090 0.157 50.3% 95.2%

1333 0.157 50.1% 95.1%

1224 0.157 49.9% 95.1%

1265 0.157 49.7% 95.0%

1341 0.159 49.5% 94.9%

1342 0.161 49.2% 94.9%

794 0.161 49.0% 94.8%

1349 0.163 48.8% 94.7%

1350 0.165 48.6% 94.6%

1364 0.167 48.4% 94.6%

1260 0.168 48.1% 94.5%

1373 0.169 47.9% 94.4%

1379 0.171 47.7% 94.4%

1380 0.173 47.5% 94.3%

404 0.174 47.3% 94.2%

1394 0.175 47.1% 94.1%

1395 0.177 46.8% 94.1%

1401 0.179 46.6% 94.0%

1408 0.181 46.4% 93.9%

1410 0.183 46.2% 93.8%

1412 0.185 46.0% 93.7%

1413 0.187 45.8% 93.7%

984 0.188 45.5% 93.6%

1416 0.190 45.3% 93.5%

1419 0.192 45.1% 93.4%

1422 0.194 44.9% 93.3%

1429 0.197 44.7% 93.2%

1431 0.199 44.4% 93.2%

1437 0.201 44.2% 93.1%

1445 0.203 44.0% 93.0%

1448 0.206 43.8% 92.9%

1451 0.208 43.6% 92.8%

1454 0.211 43.4% 92.7%

1461 0.213 43.1% 92.6%

22 0.215 42.9% 92.5%

28 0.218 42.7% 92.4%

33 0.220 42.5% 92.3%

34 0.223 42.3% 92.2%

40 0.226 42.0% 92.1%

42 0.228 41.8% 92.0%

45 0.231 41.6% 91.9%
51

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

46 0.233 41.4% 91.8%

47 0.236 41.2% 91.7%

53 0.239 41.0% 91.6%

57 0.241 40.7% 91.5%

61 0.244 40.5% 91.4%

67 0.247 40.3% 91.3%

71 0.250 40.1% 91.2%

80 0.253 39.9% 91.1%

85 0.255 39.7% 91.0%

720 0.257 39.4% 90.9%

89 0.258 39.2% 90.8%

92 0.261 39.0% 90.7%

93 0.264 38.8% 90.5%

97 0.267 38.6% 90.4%

103 0.270 38.3% 90.3%

136 0.277 38.1% 90.2%

142 0.280 37.9% 90.1%

147 0.283 37.7% 90.0%

148 0.286 37.5% 89.8%

158 0.289 37.3% 89.7%

159 0.293 37.0% 89.6%

161 0.296 36.8% 89.5%

165 0.299 36.6% 89.3%

182 0.303 36.4% 89.2%

184 0.306 36.2% 89.1%

191 0.309 35.9% 88.9%

202 0.313 35.7% 88.8%

205 0.316 35.5% 88.7%

219 0.320 35.3% 88.5%

222 0.324 35.1% 88.4%

223 0.327 34.9% 88.2%

227 0.331 34.6% 88.1%

230 0.334 34.4% 87.9%

237 0.338 34.2% 87.8%

248 0.342 34.0% 87.7%

249 0.346 33.8% 87.5%

260 0.350 33.6% 87.4%

279 0.354 33.3% 87.2%

311 0.358 33.1% 87.0%

318 0.362 32.9% 86.9%

340 0.366 32.7% 86.7%

346 0.370 32.5% 86.6%

354 0.374 32.2% 86.4%

355 0.378 32.0% 86.2%

359 0.383 31.8% 86.1%
52

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

365 0.387 31.6% 85.9%

369 0.391 31.4% 85.7%

348 0.392 31.2% 85.6%

387 0.396 30.9% 85.4%

389 0.400 30.7% 85.2%

392 0.405 30.5% 85.1%

400 0.409 30.3% 84.9%

408 0.414 30.1% 84.7%

410 0.419 29.8% 84.5%

413 0.424 29.6% 84.3%

414 0.428 29.4% 84.2%

419 0.433 29.2% 84.0%

423 0.438 29.0% 83.8%

424 0.443 28.8% 83.6%

439 0.448 28.5% 83.4%

443 0.454 28.3% 83.2%

446 0.459 28.1% 83.0%

450 0.464 27.9% 82.8%

454 0.470 27.7% 82.6%

469 0.475 27.5% 82.4%

477 0.480 27.2% 82.2%

483 0.486 27.0% 82.0%

485 0.492 26.8% 81.8%

488 0.497 26.6% 81.5%

492 0.503 26.4% 81.3%

494 0.509 26.1% 81.1%

504 0.515 25.9% 80.9%

517 0.521 25.7% 80.7%

518 0.527 25.5% 80.4%

525 0.534 25.3% 80.2%

526 0.540 25.1% 80.0%

546 0.553 24.8% 79.7%

549 0.559 24.6% 79.5%

564 0.566 24.4% 79.2%

579 0.572 24.2% 79.0%

598 0.579 24.0% 78.8%

602 0.586 23.7% 78.5%

610 0.593 23.5% 78.2%

616 0.600 23.3% 78.0%

640 0.607 23.1% 77.7%

650 0.615 22.9% 77.5%

654 0.622 22.7% 77.2%

670 0.630 22.4% 76.9%

671 0.637 22.2% 76.6%

672 0.645 22.0% 76.4%
53

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

674 0.653 21.8% 76.1%

684 0.661 21.6% 75.8%

688 0.669 21.4% 75.5%

692 0.677 21.1% 75.2%

700 0.686 20.9% 74.9%

705 0.694 20.7% 74.6%

715 0.703 20.5% 74.3%

722 0.711 20.3% 74.0%

723 0.720 20.0% 73.7%

735 0.730 19.8% 73.4%

741 0.739 19.6% 73.1%

743 0.748 19.4% 72.7%

745 0.758 19.2% 72.4%

761 0.761 19.0% 72.1%

760 0.767 18.7% 71.8%

767 0.777 18.5% 71.4%

777 0.797 18.3% 71.1%

1106 0.800 18.1% 70.7%

784 0.807 17.9% 70.4%

788 0.818 17.6% 70.0%

793 0.828 17.4% 69.7%

796 0.839 17.2% 69.3%

816 0.862 17.0% 68.9%

833 0.874 16.8% 68.6%

837 0.885 16.6% 68.2%

848 0.897 16.3% 67.8%

867 0.909 16.1% 67.4%

881 0.934 15.9% 67.0%

890 0.960 15.7% 66.6%

576 0.960 15.5% 66.2%

894 0.974 15.3% 65.8%

847 0.980 15.0% 65.3%

899 0.987 14.8% 64.9%

1068 0.988 14.6% 64.5%

125 1.000 14.4% 64.1%

911 1.015 14.2% 63.6%

919 1.030 13.9% 63.2%

931 1.044 13.7% 62.7%

952 1.059 13.5% 62.3%

961 1.060 13.3% 61.8%

959 1.075 13.1% 61.3%

967 1.091 12.9% 60.9%

969 1.107 12.6% 60.4%

988 1.123 12.4% 59.9%

1001 1.139 12.2% 59.4%
54

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1006 1.156 12.0% 58.9%

1008 1.174 11.8% 58.4%

1013 1.192 11.5% 57.9%

49 1.223 11.3% 57.4%

1028 1.230 11.1% 56.9%

1029 1.249 10.9% 56.3%

1031 1.269 10.7% 55.8%

1034 1.290 10.5% 55.2%

1036 1.310 10.2% 54.7%

1037 1.331 10.0% 54.1%

1042 1.354 9.8% 53.5%

1050 1.400 9.6% 52.9%

1060 1.448 9.4% 52.3%

1074 1.473 9.2% 51.7%

1080 1.498 8.9% 51.0%

1100 1.525 8.7% 50.4%

1111 1.552 8.5% 49.7%

842 1.558 8.3% 49.0%

1112 1.580 8.1% 48.4%

1121 1.608 7.8% 47.7%

1126 1.639 7.6% 47.0%

1127 1.669 7.4% 46.2%

1239 1.695 7.2% 45.5%

1134 1.702 7.0% 44.8%

156 1.725 6.8% 44.0%

1160 1.735 6.5% 43.3%

1176 1.770 6.3% 42.5%

1183 1.805 6.1% 41.7%

1191 1.843 5.9% 41.0%

1192 1.883 5.7% 40.2%

1195 1.923 5.4% 39.3%

1217 1.965 5.2% 38.5%

536 2.025 5.0% 37.6%

1249 2.154 4.8% 36.8%

1262 2.259 4.6% 35.8%

1269 2.374 4.4% 34.8%

1319 2.574 4.1% 33.8%

1335 2.649 3.9% 32.7%

1340 2.727 3.7% 31.5%

1343 2.810 3.5% 30.3%

1355 2.901 3.3% 29.1%

721 2.940 3.1% 27.8%

1386 2.996 2.8% 26.5%

1405 3.208 2.6% 25.2%

1415 3.329 2.4% 23.8%
55

Plant 

ID

Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1417 3.462 2.2% 22.4%

1423 3.606 2.0% 20.9%

1424 3.765 1.7% 19.3%

1428 4.378 1.5% 17.6%

1430 4.641 1.3% 15.7%

1440 4.949 1.1% 13.7%

1446 5.313 0.9% 11.6%

1447 5.763 0.7% 9.2%

1453 7.132 0.4% 6.7%

1460 8.253 0.2% 3.6%
56

Chromium Anodizing Cumulative Distribution Data

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

1180 0.0056 100.0% 100.0%

38 0.0074 99.3% 100.0%

44 0.0092 98.6% 100.0%

52 0.0110 97.9% 100.0%

55 0.0129 97.1% 99.9%

58 0.0149 96.4% 99.9%

70 0.0170 95.7% 99.9%

87 0.0191 95.0% 99.9%

104 0.0212 94.3% 99.8%

111 0.0235 93.6% 99.8%

116 0.0257 92.9% 99.7%

121 0.0280 92.1% 99.7%

123 0.0303 91.4% 99.7%

176 0.0327 90.7% 99.6%

824 0.0327 90.0% 99.5%

177 0.0351 89.3% 99.5%

188 0.0375 88.6% 99.4%

242 0.0400 87.9% 99.4%

270 0.0426 87.1% 99.3%

330 0.0452 86.4% 99.2%

336 0.0480 85.7% 99.1%

337 0.0507 85.0% 99.0%

349 0.0534 84.3% 99.0%

371 0.0563 83.6% 98.9%

393 0.0591 82.9% 98.8%

394 0.0621 82.1% 98.7%

395 0.0652 81.4% 98.5%

422 0.0682 80.7% 98.4%

425 0.0713 80.0% 98.3%

436 0.0744 79.3% 98.2%

451 0.0776 78.6% 98.1%

460 0.0809 77.9% 97.9%

461 0.0842 77.1% 97.8%

482 0.0876 76.4% 97.6%

513 0.0910 75.7% 97.5%

520 0.0944 75.0% 97.3%

686 0.0970 74.3% 97.1%

570 0.0980 73.6% 97.0%
57

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

615 0.102 72.9% 96.8%

618 0.105 72.1% 96.6%

649 0.109 71.4% 96.4%

659 0.112 70.7% 96.2%

685 0.116 70.0% 96.0%

696 0.120 69.3% 95.8%

733 0.124 68.6% 95.6%

755 0.128 67.9% 95.4%

769 0.132 67.1% 95.2%

789 0.136 66.4% 94.9%

803 0.140 65.7% 94.7%

819 0.145 65.0% 94.5%

820 0.149 64.3% 94.2%

901 0.153 63.6% 93.9%

921 0.158 62.9% 93.7%

943 0.163 62.1% 93.4%

960 0.167 61.4% 93.1%

965 0.172 60.7% 92.8%

404 0.174 60.0% 92.5%

1213 0.174 59.3% 92.2%

973 0.177 58.6% 91.9%

982 0.182 57.9% 91.6%

992 0.187 57.1% 91.3%

999 0.192 56.4% 90.9%

1000 0.197 55.7% 90.6%

1019 0.202 55.0% 90.2%

1065 0.208 54.3% 89.9%

1089 0.213 53.6% 89.5%

1125 0.219 52.9% 89.1%

1129 0.224 52.1% 88.8%

1172 0.230 51.4% 88.4%

1193 0.236 50.7% 88.0%

1206 0.242 50.0% 87.5%

1216 0.248 49.3% 87.1%

1274 0.254 48.6% 86.7%

1289 0.260 47.9% 86.2%

1318 0.267 47.1% 85.8%

1367 0.274 46.4% 85.3%

1393 0.280 45.7% 84.8%

1402 0.287 45.0% 84.3%
58

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

7 0.294 44.3% 83.8%

21 0.301 43.6% 83.3%

63 0.308 42.9% 82.8%

76 0.316 42.1% 82.2%

157 0.323 41.4% 81.7%

162 0.331 40.7% 81.1%

178 0.339 40.0% 80.5%

182 0.347 39.3% 79.9%

199 0.355 38.6% 79.3%

205 0.364 37.9% 78.7%

219 0.373 37.1% 78.0%

230 0.381 36.4% 77.4%

248 0.390 35.7% 76.7%

250 0.400 35.0% 76.0%

256 0.410 34.3% 75.3%

259 0.419 33.6% 74.6%

268 0.430 32.9% 73.8%

295 0.440 32.1% 73.1%

315 0.451 31.4% 72.3%

325 0.462 30.7% 71.5%

329 0.473 30.0% 70.7%

399 0.485 29.3% 69.8%

449 0.496 28.6% 69.0%

492 0.509 27.9% 68.1%

501 0.522 27.1% 67.2%

533 0.535 26.4% 66.3%

580 0.549 25.7% 65.3%

670 0.563 25.0% 64.4%

677 0.577 24.3% 63.4%

699 0.592 23.6% 62.4%

700 0.608 22.9% 61.3%

722 0.624 22.1% 60.2%

745 0.641 21.4% 59.1%

776 0.659 20.7% 58.0%

788 0.678 20.0% 56.8%

812 0.697 19.3% 55.6%

816 0.718 18.6% 54.4%

118 0.720 17.9% 53.1%

818 0.739 17.1% 51.9%

826 0.761 16.4% 50.6%
59

Plant ID Emissions, 

lbs/yr

Cumulative Plant 

Distribution

Percentage of 

Total Emissions

859 0.784 15.7% 49.2%

865 0.809 15.0% 47.8%

898 0.836 14.3% 46.4%

904 0.863 13.6% 44.9%

959 0.893 12.9% 43.4%

1006 0.924 12.1% 41.8%

1029 0.958 11.4% 40.2%

1069 0.995 10.7% 38.5%

1099 1.033 10.0% 36.7%

1100 1.076 9.3% 34.9%

1104 1.123 8.6% 33.0%

1119 1.175 7.9% 31.0%

1262 1.234 7.1% 29.0%

1298 1.298 6.4% 26.8%

1383 1.300 5.7% 24.5%

1309 1.373 5.0% 22.2%

1314 1.458 4.3% 19.8%

1343 1.562 3.6% 17.2%

1347 1.690 2.9% 14.4%

1411 1.863 2.1% 11.5%

1430 2.106 1.4% 8.2%

1452 2.516 0.7% 4.4%