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NESHAP for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR part 63, subpart N) (Final Rule)

OMB: 2060-0327

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SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR CHROMIUM EMISSIONS FROM HARD AND DECORATIVE CHROMIUM ELECTROPLATING AND CHROMIUM ANODIZING TANKS (40 CFR PART 63, SUBPART N) (FINAL RULE)


PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

“National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.” This is a new information collection request (ICR), and the EPA tracking number is 1611.10 (2060-0327).

(b) Short Characterization.

The potential respondents are owners or operators of any existing or new chromium electroplating or chromium anodizing tanks. There are an estimated 1,343 facilities subject to the Chromium Electroplating NESHAP. Of these, there are an estimated 652 hard chromium electroplating facilities, 517 decorative chromium electroplating facilities, and 174 chromium anodizing facilities. The affected source is any tank that is used for chromium electroplating or chromium anodizing.

The final amendments to subpart N require affected facilities to meet more stringent emission limits or more stringent surface tension limits, depending on the compliance method selected by the facility. Some facilities will be required to conduct performance tests and submit notifications to demonstrate compliance with the revised limits. The final amendments also prohibit the use of certain types of chemical fume suppressants in affected chromium electroplating or anodizing tanks; require additional housekeeping procedures to minimize fugitive emissions of chromium compounds; specify procedures for checking and maintaining instruments used for measuring surface tension; clarify testing procedures; and revise the reporting requirements. The following paragraph provides additional details on these requirements.

The final amendments specify more stringent emissions limits for existing sources, depending on the process. Large hard chromium electroplating sources must meet an emissions limit of 0.011 milligrams per dry standard cubic meter (mg/dscm); small hard chromium electroplating sources must meet an emissions limit of 0.015 mg/dscm; decorative chromium electroplating sources and chromium anodizing sources must meet an emissions limit of 0.007 mg/dscm. All new sources must meet an emissions limit of 0.006 mg/dscm. Many chromium electroplating and anodizing sources comply with the NESHAP through the use of chemical fume suppressants to maintain the surface tension in tank baths below certain levels. The final amendments require these sources to maintain a surface tension limit of 40 dynes per centimeter (dynes/cm) if measured using a stalagmometer, or 33 dynes/cm if measured using a tensiometer. The final amendments prohibit the use of such fume suppressants that contain perfluorooctane sulfonic acid (PFOS). The final housekeeping procedures specify requirements for storing hexavalent chromium chemicals, installing guards and trays to minimize spills of electroplating and anodizing tank solution, prompt cleanup of chromium chemical spills, installing barriers between certain types of operations and chromium electroplating and anodizing tanks, and disposing of chromium chemical wastes. The final amendments require checking stalagmometers used for measuring surface tension, and cleaning the instrument, if necessary. The final amendments allow testing by either Method 306 or Method 306A for multiple sources controlled by a common add-on air pollution control device. Finally, the final amendments correct a discrepancy between the NESHAP the General Provisions to part 63 by requiring owners or operators of affected sources to submit a semiannual report if the duration of excess emissions exceeds 1 percent of source operating time or the duration of air pollution control device malfunctions exceeds 5 percent of source operating time. For the final amendments, the requirements associated with additional reporting and recordkeeping costs are the costs associated with reading the final amendments, revising Operation and Maintenance Plans, checking and recalibrating certain types of instruments used to measure surface tension, and testing and related reporting.

The information collection requirements associated with the final amendments to the NESHAP are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a stationary source that is not a major source (i.e., an area source does not emit and does not have the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any combination of HAP). For major sources, these technology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non-air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires EPA to review these technology-based standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source categories subject to certain CAA section 112(d) standards whether the emissions limitations provide an ample margin of safety to protect public health. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a source in the category or subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA determines that the existing standards are sufficiently protective. EPA must also adopt more stringent standards, if necessary, to prevent an adverse environmental effect, but must consider cost, energy, safety, and other relevant factors in doing so.

Certain records and reports are necessary for the Administrator to confirm the compliance status of sources subject to NESHAP, identify any new or reconstructed sources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (State agency, or Regional Administrator if there is no delegated State agency) to ensure that the standards and other requirements are being achieved. Based on review of the recorded information at the site and the reported information, the delegated permitting authority can identify facilities that may not be in compliance and decide which facilities, records, or processes may need inspection.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA’s ongoing ICRs revealed no duplication of information-gathering efforts.

(b) Public Notice Required Prior to ICR Submission to OMB.

Public notice was provided via the preamble to the proposed and final rule.

(c) Consultations.

The final amendments were developed in consultation with individual companies, State agencies, and trade associations. The non-EPA persons consulted on the information collection activities are identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact

Organization

Telephone No.

Carla Takemoto

California Air Resources Board

(916) 324-8028

Russell Yanagihara

San Diego Air Pollution Control District

(858) 586-2719

Eugene Kang

South Coast Air Quality Management District

(909) 396-3524

Jeff Hannapel

The Policy Group/National Association for Surface Finishing

(202) 457-0630

Christian Richter

The Policy Group/National Association for Surface Finishing

(202) 457-0630

Douglas Lay

Coventya Inc.

(216) 351-1500

Rick Hall

KCH Engineered Systems

(828) 245-9836

Gene Barlowe

Atotech

(803) 326-3468


(d) Effects of Less Frequent Collection.

If the relevant information were collected less frequently, the delegated permitting authority (State or EPA) will not be reasonably assured that a facility is in compliance with the standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B--Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart N are owners or operators of any existing or new facility engaged in one or more of the following operations: hard chromium electroplating, decorative chromium electroplating, and chromium anodizing. Chromium electroplating and anodizing facilities are primarily classified under NAICS code 332813. However, chromium electroplating and anodizing operations are also collocated at many facilities that are classified under other NAICS codes. Examples include NAICS 33251, Hardware Manufacturing; 323111, Commercial Gravure Printing; 332116, Metal Stamping; 332722, Bolt, Nut, Screw, Rivet, and Washer Manufacturing; 332811, Metal Heat Treating; 332812, Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers; 332913, Plumbing Fixture Fitting and Trim Manufacturing; Other Metal Valve and Pipe Fitting Manufacturing; 332999, All Other Miscellaneous Fabricated Metal Product Manufacturing; and 336412, Aircraft Engine and Engine Parts Manufacturing.

There are an estimated 1,343 facilities that are subject to the NESHAP, including about 652 hard chromium electroplating plants, 517 decorative chromium electroplating plants, and 174 chromium anodizing plants. However, the additional requirements incorporated in the final amendments will not apply to all of these facilities. No new chromium electroplating or anodizing sources are expected during the 3­year period of this ICR.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the Chromium Electroplating Source Category.

(ii) Respondent Activities. The respondent activities that will be required by the final amendments to the Chromium Electroplating NESHAP are identified in Table 2 and are introduced in section 6(a).

5. The Information Collected–Agency Activities, Collection Methodology, and Information Management

(a) Agency Activities.

The Agency activities associated with the final amendments to the Chromium Electroplating NESHAP are provided in Table 3 and are introduced in section 6(c).

(b) Collection Methodology and Management.

Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority. EPA is the permitting authority until the State agency is delegated authority to implement the final amendments to the rule. Therefore, information contained in any report submitted to the Regional Administrator will be entered into the Air Facility System (AFS), which is operated and maintained by EPA’s Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated authorities can edit, store, retrieve and analyze the data.

(c) Small Entity Flexibility.

The Small Business Administration defines a small entity for the chromium electroplating and anodizing industry as a firm having no more than 500 to 1,000 employees (depending on the size definition for the affected NAICS code). The final amendments will not result in any adverse impacts on a substantial number of small entities in the Chromium Electroplating Source Category. The final amendments will not create any new requirements or burdens for existing sources other than minimal notification requirements, and for some facilities, performance testing requirements.

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is shown in Table 2 for the Chromium Electroplating Source Category.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the final amendments to the Chromium Electroplating NESHAP are shown in Table 2. These numbers were derived from estimates based on EPA’s experience with other standards. No burden estimates are provided for new sources because no new facilities are expected to become affected sources during the 3­year period of this ICR.

(b) Estimating Respondent Costs.

The information collection activities for the final amendments to the Chromium Electroplating NESHAP are presented in Table 2. Because the data are already collected by respondents as part of normal operations, no respondent development costs are associated with the information collection activities.

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2012 available at http://www.bls.gov/oes/current/naics4_332800.htm#51-0000. Wages for technical labor are based on "51-4193 Plating and Coating Machine Setters, Operators, and Tenders, Metal and Plastic," with a total compensation of $14.56/hour. Wages for management labor are taken from "51-1011 First-Line Supervisors/Managers of Production and Operating Workers," with a total compensation of $25.98/hour. Wages for clerical labor are based on "43-9061 Office Clerks, General," with a total compensation of $14.24/hour. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $30.58/hour, management at $54.56/hour, and clerical at $29.90/hour.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. The total capital costs associated with the information collection requirements of the final amendments to the Chromium Electroplating NESHAP is based on the capital costs associated with performance testing. The final amendments require an estimated 156 facilities to conduct new performance testing, which is estimated to cost an average of $792,661 per year. The O&M costs associated with the final amendments to the Chromium Electroplating NESHAP consist of new requirements to check and clean, when necessary, instruments used to measure surface tension of the electroplating and anodizing solutions. These costs are estimated to be $287,342 per year.

(iii) Annualizing Capital Costs. The annualized capital costs associated with the information collection requirements of the final amendments is based on performance testing costs. These costs are estimated to be $87,030 per year.

(c) Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal Government. Publication and distribution of the information are part of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sources that is part of EPA’s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs that the Federal government will incur are user costs associated with the analysis of the reported information, as presented in Table 3.

The Agency labor rates are from the Office of Personnel Management (OPM) 2012 General Schedule, which excludes locality rates of pay and are frozen at 2010 rate levels. These rates can be obtained from Salary Table 2012-GS available on the OPM website, http://www.opm.gov/oca/12tables/pdf/gs_h.pdf. The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for technical (GS-12, Step 1), and $38.92/hr for management (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at $25.01/hour; technical at $46.21/hour, and management at $62.27/hour.

(d) Estimating the Respondent Universe and Total Burden and Costs.

There are an estimated 1,343 existing facilities that are subject to the Chromium Electroplating NESHAP. No new sources are expected during the next 3 years.

For the final amendments to the Chromium Electroplating NESHAP, the components of the total annual burden attributable to this ICR include reading the amendments to the NESHAP for all affected facilities, revising the Operation and Maintenance Plan, and, for facilities that will be required to perform testing, submitting notifications of performance testing and compliance status. All other recordkeeping and reporting activities are already accounted for in the ICR for the NESHAP.

The number of total annual responses for subpart N is estimated as: 500 (52 annual respondents for the notification of performance test and 448 annual respondents for the notification of compliance status).

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in Table 2 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. The average annual burden for the recordkeeping and reporting requirements in the final amendments to subpart N for the 1,343 existing facilities that are affected by the amendments to the Chromium Electroplating NESHAP is 6,577 person-hours, with an annual average cost of $207,583. Capital costs for performance testing totals $792,661 ($87,030 annualized) and operation and maintenance costs totals $287,342 per year.

(ii) The Agency tally.

The average annual Federal Government cost is $21,233 for 471 hours for the final amendments to subpart N. The bottom line Agency burden hours and costs presented in Table 3 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.

(iii) Variations in the annual bottom line.

This section does not apply since no significant variation is anticipated.

(f) Reasons for Change in Burden.

This ICR covers information collection requirements in the final amendments to the Chromium Electroplating NESHAP (40 CFR part 63, subpart N).

(g) Burden Statement

The average annual respondent burden for the final amendments to the Chromium Electroplating NESHAP is estimated to be 13 hours per response.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency’s need for this information the accuracy of the provided burden estimates, and any suggestions for minimizing respondent burden, including through the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2010-0600, which is available for online viewing at http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air Docket is (202) 566-1742. An electronic version of the public docket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in one of the Docket ID Numbers identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number (EPA-HQ-OAR-2005-0084) and OMB Control Number 2060-0327 in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection associated with the final rule.

TABLE 2. ANNUAL RESPONDENT BURDEN AND COST--AMENDMENTS TO CHROMIUM ELECTROPLATING NESHAP

Burden item

(A) Person-hours per occurrence

(B) No. of occurrences per respondent

(C) Person-hours per respondent (C=A*B)

(D) Respondents per year

(E) Technical person-hours per year (E=C*D)

(F) Management person-hours per year

(E*0.05)

(G) Clerical person-hours per year (E*0.1)

(H)

Costa, $

1. Applications

N/A

 

 

 

 

 

 

 

2. Survey and Studies

N/A

 

 

 

 

 

 

 

3. Acquisition, Installation, & Utilization of Tech. & Systs

N/A

 

 

 

 

 

 

 

4. Reporting Requirements

 

 

 

 

 

 

 

 

A. Read instructions (b)

4

1

4.0

448

1,791

90

179

$64,991

B. Required activities

N/A

 

 

 

 

 

 

 

C. Create information

N/A

 

 

 

 

 

 

 

D. Gather existing information

N/A

 

 

 

 

 

 

 

E. Write report

 

 

 

 

 

 

 

 

Notification of initial performance test (c)

4

1

4.0

52

208

10

21

$7,549

Notification of compliance status (d)

4

1

4.0

448

1,791

90

179

$64,991

Revise O&M Plan (e)

4

1

4.0

448

1,791

90

179

$64,991

5. Recordkeeping Requirements (f)

 

 

 

 

 

 

 

 

A. Read instructions

See 4A








B. Plan activities

N/A

 

 

 

 

 

 

 

C. Implement activities

N/A

 

 

 

 

 

 

 

D. Develop record system

N/A

 

 

 

 

 

 

 

E. Time to enter information

N/A

 

 

 

 

 

 

 

F. Time to train personnel

N/A

 

 

 

 

 

 

 

G. Time to adjust existing ways to comply w/ prev. appl. req.

N/A

 

 

 

 

 

 

 

H. Time to transmit or disclose information

0.25

1.1

0.3

500

139

7

14

$5,060

I. Time for audits

N/A

 

 

 

 

 

 

 

TOTAL ANNUAL BURDEN AND COST (SALARY)





5,719

286

572

$207,583

TOTAL ANNUAL NUMBER OF RESPONSES








500

ANNUAL CAPITAL COSTS (g)








N/A

Performance Tests (h)








$792,661

ANNUALIZED CAPITAL COSTS (i)








$87,030

OPERATION AND MAINTENANCE COSTS (j)








$287,342

TOTAL ANNUALIZED COSTS (Annual capital+O&M costs)








$374,372


N/A = Not Applicable.

(a) Costs are based on the following hourly rates: technical $30.58, management $54.56, and clerical $29.90. Mgmt person-hours and clerical person-hours are assumed to be 5% and 10% of technical person-hours, respectively.

(b) There are an estimated 1,343 existing Cr electroplating and anodizing plants, no new facilities are expected; the average number expected to read the rule during the 3yr clearance period is 1,343/3 = 448.

(c) There are 156 facilities that will be required to complete performance tests; the average number expected to perform testing during the 3-yr clearance period is 156/3 = 52.

(d) O&M Plan must be revised to incorporate housekeeping requirements.

(e) There are 1,343 facilities that will be required to submit a Notification of Compliance Status; the average number during the 3yr clearance period is 1,343/3 = 448.

(f) Final amendments would not require additional recordkeeping.

(g) The only capital costs associated with the reporting and recordkeeping requirements of the final amendments would be the costs for performance tests.

(h) Assumes emission tests to be conducted at 152 facilities at an average annual cost of $14,518 per facility that must test; also assumes 5% of plants will fail an initial performance test for one affected source and must repeat it.

(i) Annualized testing costs (15 year life at 7 percent interest: CRF = 0.1098).

(j) O&M costs consists of labor required to check stalagmometer calibration and clean stalagmometer when needed.

3. ANNUAL BURDEN AND COST TO THE AGENCY----AMENDMENTS TO CHROMIUM ELECTROPLATING NESHAP

Burden item

(A)

Person-hours per occurrence

(B) Occurrences per respondent

(C)

EPA person-hours/year (C=A*B)

(D)

Facilities per year

(E)

Technical person-hours/year (D=A*B*C)

(F)

Management person-hours/year (E=0.05*D)

(G)

Clerical person-hours/year (F=0.1*D)

(H)

Costa, $

Attend initial performance test (b)

8

1

8.0

10

80

4

8

$4,146

Attend repeat performance test (c)

 

 

 

 

 

 

 

 

Retesting preparation

1

1

1.0

1

1

0.1

0.1

$52

Retesting

8

1

8.0

1

8

0.4

1

$415

Litigation (d)

2,080

 

0.0

 

0

0.0

0

$0

Report Review

 

 

 

 

 

 

 

 

Operation and maintenance plan (e)

2

1

2.0

67

134

6.7

13

$6,944

Plant records of fume suppressant use (f)

2

1

2.0

26

52

2.6

5

$2,695

Notification of initial performance test (g)

2

1

2.0

3

5

0.3

1

$269

Notification of compliance status (g)

4

1

4.0

22

90

4.5

9

$4,640

Repeat performance test report (c)

40

1

40.0

1

40

2.0

4

$2,073

TOTAL BURDEN AND COST (SALARY)

 

 

 

 

410

20

41

$21,233

(a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01.

Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

(b) Assumes Agency personnel will attend performance tests for 10 affected facilities per year.

(c) Assumes Agency personnel will attend repeat performance tests for 1 affected facility per year.

(d) Assumes none of the affected plants will be involved in litigation.

(e) Assumes Agency will review 5% of revised O&M Plants (1,343 x 0.05 = 67).

(f) Assumes Agency will review records of 5% of the 540 plants that use fume suppressants (540 x 0.05 = 26) to confirm that non-PFOS fume suppressants are being used.

(g) Assumes Agency will review 5% of notifications submitted.











ATTACHMENT 1. INFORMATION REQUIREMENTS----AMENDMENTS TO CHROMIUM ELECTROPLATING NESHAP

Requirement

Citation for existing sources

Citation for new sources

General Provisions citation

Monitoring

§ 63.343(c)(5)

§ 63.343(c)(5)

N/A

Performance Testing

§63.343(b)(1)

§63.343(b)(1)

§63.7,

Notifications

§63.347(d) and (e)

§63.347(d) and (e)

N/A

Plans




Operation and Maintenance Plan

§ 63.342(f)(3)

§ 63.342(f)(3)

N/A

Records




Monitoring/inspection information

§ 63.346(b)

§ 63.346(b)

40 CFR 63.10

Reports

N/A

N/A

N/A


4


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