1611

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Overview

TABLE 1
TABLE 2

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Sheet 1: TABLE 1

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)
				0.869565				$30.60	$55.67	$27.97
REPORTING/RECORDKEEPING REQUIREMENT				(A) Respondent Hours per Occurrence (Technical hours)	(B) Number of Occurences per Respondent per Year	(C) Hours per Respondent per Year (C=A x B)	(D) Number of Respondents per Yeara	(E) Technical Hours per Year @ $30.60 (E=C x D)	(F) Management Hours per Year @ $55.67 (F= E x 0.05)	(G) Clerical Hours per Year @ $27.97 (G= E x 0.1)	Total Labor Costs per Year b
1. APPLICATIONS				N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
2. SURVEY AND STUDIES				N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS				N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
4. REPORTING REQUIREMENTS
	A. Read Instructions			1.00	1.00	1.00	0.00	0.00	0.00	0.00	$0.00
	B. Required Activities
		Performance testc		------------------------Included in 4E---------------------------
		Monitoring of operations equipment d		------------------------Included in 5E---------------------------
	C. Create Information			------------------------Included in 4B and 5E----------------------------
	D. Gather Existing Information			------------------------Included in 4B and 5E----------------------------							N/A
	E. Write Report a,e
		Notification of compliance status		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
		Notification of actual startup		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
		Notification of construction / reconstruction		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
		Notification of performance test		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
		Performance test report		4.00	1.00	4.00	0.00	0.00	0.00	0.00	$0.00
		Operation and maintenance plan		10.00	1.00	10.00	0.00	0.00	0.00	0.00	$0.00
		Annual compliance status reports for area sources f		4.00	1.00	4.00	1,357.00	5,428.00	271.40	542.80	$196,387.75
		Semiannual reports of exceedances for area sources f, g		8.00	2.00	16.00	339.00	5,424.00	271.20	542.40	$196,243.03
		Semiannual compliance status reports for major sources h		8.00	2.00	16.00	0.00	0.00	0.00	0.00	$0.00
		Quarterly compliance status reports for major sources g,h		8.00	2.00	16.00	0.00	0.00	0.00	0.00	$0.00
		Request to reduce report frequency g		2.00	1.00	2.00	170.00	340.00	17.00	34.00	$12,301.37
				Total Reporting Hours by Labor Category				11192.00	559.60	1,119.20	$404,932.16
	TOTAL REPORTING BURDEN								12,870.8	Hours	$404,932
5. RECORDKEEPING REQUIREMENTS
	A. Read Instructions			------------------------Included in 4A----------------------------
	B.  Plan Activities			------------------------Included in 4B----------------------------
	C. Implement Activities			------------------------Included in 4B----------------------------
	D.  Develop Record System			40	1	40.00	0.00	0.00	0.00	0.00	$0.00
	E.  Time to Enter and Transmit Information
		Records of monitoring:
		- Composite mesh pad/packed scrubber i		0.50	250.00	125.00	793.00	99,125.00	4,956.25	9,912.50	$3,586,392.06
		- Wetting agents (normal schedule) j,k		0.25	1,000.00	250.00	73.40	18,350.00	917.50	1,835.00	$663,912.18
		- Wetting agents (reduced frequency schedule) j,k		0.25	100.00	25.00	660.60	16,515.00	825.75	1,651.50	$597,520.96
		- Foam Blankets (normal schedule) l		0.25	4,000.00	1,000.00	0.00	0.00	0.00	0.00	$0.00
		- Foam Blankets (reduced frequency schedule) l		0.25	500.00	125.00	0.00	0.00	0.00	0.00	$0.00
		- Excess emissions		------------------------Included in 4E----------------------------
		Records of operations: m
		- Operation and maintenance		1.00	4.00	4.00	793.00	3172.00	158.60	317.20	$114,764.55
		- Cumulative rectifier capacity		------------------------Included in 4E----------------------------
		- Records of trivalent chromium bath purchases n		0.50	12.00	6.00	74.00	444.00	22.20	44.40	$16,064.14
	F. Time to train personnel			N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
	G. Time for Audits			N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
				Total Reporting Hours by Labor Category				137,606	6,880	13,761
	TOTAL RECORDKEEPING BURDEN								158,246.9	Hours	$4,978,654
	TOTAL ANNUAL BURDEN								171,118	Hours	$5,383,586
Assumptions:
	a There are an estimated total of 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 capacity. The ongoing monitoring, reporting, and recordkeeping for new tanks is the same as that for existing tanks.
	b This ICR uses the following labor rates: $55.67 per hour for Executive, Administrative, and Managerial labor; $30.60 per hour for Technical labor, and $48.53 per hour for Clerical labor. These rates are the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rate has been increased by 110 percent to account for the benefit packages available to those employed by private industry.
	c Sources are required to conduct performance tests using Methods 306 or 306A of Appendix A, or the California Air Resources Board (CARB) Method 425, as an alternative, Method 306B, and alternate methods if the method has been validated using Method 301 of Appendix A.
	d Sources are required to follow work practice standards at composite-mesh-pad (CMP) systems, packed-bed scrubbers (PBS), PBS/CMP systems, fiber-bed mist eliminators, and other air pollution control devices not listed in the rule, as well as monitoring operational parameters (i.e., pressure drop for composite mesh pad systems and fiber 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) and monitoring equipment.
	e We have assumed that all existing sources are in compliance with the initial rule requirements.
	f All sources, except decorative chromium electroplating plants using trivalent chromium bath (1,770 - 74 = 1,696), are required to submit compliance status reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report. However, we have assumed that 80 percent of the sources (0.80 x 1,696 = 1,357) will have no excess emissions and 20 percent of the sources (0.20 x 1,696 = 339) will have excess emissions.
	g If excess emissions occur at the plant, sources are required to submit these reports on a more frequent basis (i.e., semiannually for area sources and quarterly for major sources) until the regulatory agency has approved the source request to reduce frequency of ongoing compliance status reports. We have further assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 339 = 170) will request the regulatory agency to approve a reduction in frequency for ongoing compliance status reports (i.e., annual reporting).
	h We have assumed that all sources are area sources.
	i We have assumed that the monitoring required for composite mesh pad/packed bed scrubbers occurs once per day, 5 five days a week, 50 weeks per year for all plants with add-on control devices. The number of facilities with add-on control devices is estimated to be 793 based on the assumption that 84 percent of hard chromium electroplating facilities (84% of 790 = 663.6), 13 percent of the decorative chromium electroplating that use hexavalent chromium bath (13% of 666 = 86.6) and 18 percent of chromium anodizing facilities (18% of 240 = 43.2) will use add-on control devices.
	j We have assumed that 85 percent of decorative chromium electroplating plants that use hexavalent chromium bath (85% of 666 = 566) and 70 percent of chromium anodizing plants (70% of 240 = 168) will use wetting agents for a total of 734 sources.
	k We have assumed that area sources using wetting agents will be required to monitor once every four hours and at least twice per shift, five days a week, 50 weeks per year per operating schedule if the source is on a regular monitoring schedule. If the source is on a reduced monitoring schedule, it will be required to monitor once every 40 hours for 16-hour day, five days a week, 50 weeks per year per operating schedule. We have assumed that 90 percent of the sources (90% of 734 = 660.6) will be on a normal schedule and 10 percent of the sources (10% of 734 = 73.4) are on a reduced schedule.
	l We have assumed that sources will not elect to use foam blankets because the rule requires them to do compliance testing. If sources elect to use foam blankets, the reduced monitoring schedule will required them to monitor once every 8 hours, per 16-hour day, five days a week, 50 weeks per year per operating schedule. If the source is on a normal monitoring schedule it will be required to monitor once every hour, per 16-hour day, five days a week, 50 weeks per year per operating schedule.
	m We have assumed that all facilities with add-on control devices (793) would be required to have an approved Operation and Maintenance Plan for their operations.
	n We have assumed that 10 percent of the decorative chromium electroplating plants (10% of 740 = 74) use trivalent chromium baths.

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Sheet 2: TABLE 2

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)
			0.869565				$46.22	$62.27	$25.01
REPORTING/RECORDKEEPING REQUIREMENT			(A) EPA Hours per Occurence (Technical hours)	(B) Number of Occurences per Plant per Year	(C) EPA Hours per Year (C=A x B)	(D) Plants per Year a	(E) Technical Hours per Year @ $46.22 (E=C x D)	(F) Management Hours per Year @ $62.27 (F= E x 0.05)	(G) Clerical Hours per Year @ $25.01 (G= E x 0.1)	Costs per Year b
	Notification of Compliance Status c		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Notification of Actual Startup		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Notification of construction/ reconstruction		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Operation and maintenance plan d		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Notification of Performance Test a		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Reports of Performance Test results a		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Annual compliance status reports for area sources e		2.00	1.00	2.00	1,357.00	2,714.00	135.70	271.40	$140,676.12
	Semiannual reports of exceedances for area sources e, f		2.00	2.00	4.00	339.00	1,356.00	67.80	135.60	$70,286.23
	Semiannual compliance status reports for major sources g		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Quarterly compliance status reports for major sources		2.00	1.00	2.00	0.00	0.00	0.00	0.00	$0.00
	Request to reduce report frequency f		2.00	1.00	2.00	170.00	340.00	17.00	34.00	$17,623.39
TOTAL ANNUAL HOURS							4,410.00	220.50	441.00
TOTAL ANNUAL BURDEN								5,072	Hours	$228,586
Assumptions:
	a There are an estimated total of 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 capacity. The ongoing monitoring, reporting, and recordkeeping for new tanks is the same as that for existing tanks.
	b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.22 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) "2009 General Schedule" which excludes locality rates of pay.
	c Assumes that all existing sources are in compliance with the initial rule requirements.
	d There will be no periodic burden for the regulatory agency associated with this requirement although we have assumed that all facilities with add-on control devices (793) would be required to have an approved Operation and Maintenance Plan for its operations.
	e All sources, except decorative chromium electroplating plants using trivalent chromium bath (1,770 - 74 = 1,696), are required to submit compliance status reports. Area sources are required to submit an annual compliance status report and major sources a semiannual compliance status report. However, we have assumed that 80 percent of the sources (0.80 x 1,696 = 1,357) will have no excess emissions and 20 percent of the sources (0.20 x 1,696 = 339) will have excess emissions.
	f If excess emissions occur at the plant, sources are required to submit these reports on a more frequent basis (i.e., semiannually for area sources and quarterly for major sources) until the regulatory agency has approves the source request to reduce frequency of ongoing compliance status reports. We have further assumed that half of the area sources submitting semiannual reports due to excess emissions (0.5 x 339 = 170) will request the regulatory agency to approve a reduction in frequency for ongoing compliance status reports (i.e., annual reporting).
	g We have assumed that all sources are area sources.