SUPPORTING
STATEMENT
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
THE
PLATING
AND
POLISHING
AREA
SOURCE
CATEGORY
PART
A
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Information
Collection
Request
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
Plating
and
Polishing
Area
Source
Category."
This
is
a
new
information
collection
request
(
ICR);
the
EPA
ICR
number
is
2186.01.

(
b)
Short
Characterization/
Abstract.

The
Environmental
Protection
Agency
(
EPA)
plans
to
collect
information
and
data
from
1,208
existing
plating
and
polishing
facilities.
These
establishments
are
primarily
engaged
in
electroplating,
electroless
plating,
metal
and
thermal
spraying,
anodizing,
coloring,
and
finishing
of
metals
and
formed
products
for
the
trade.
Plants
will
be
requested
to
complete
a
simple
paper
questionnaire
on
general
facility
information
(
location,
description,
types
of
processes
performed,

operating
hours,
technical
contact),
HAP
emissions
and
permit
data,
permit
conditions,
emission
tests
data,
process
design
and
operating
data,
HAP­
containing
material
data,
finished
product
types,
local
ventilation
system
information,
HAP
emission
control
measures,
and
pollution
prevention
practices.
The
questionnaire
may
be
completed
from
existing
information;
no
additional
monitoring
or
testing
is
required.
The
information
collected
will
be
quality­
assured
and
entered
into
a
computerized
database
for
use
in
the
development
of
area
source
standards
for
emissions
of
HAP.
2
2.
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

Section
112(
d)
of
the
Clean
Air
Act
(
CAA)
requires
EPA
to
promulgate
national
emission
standards
for
HAP
emissions
from
new
and
existing
major
and
area
sources
that
are
listed
for
regulation
under
section
112(
c).
Area
sources
are
small
emitters
(
less
than
10
tons/
yr
of
any
individual
HAP
and
less
than
25
tons/
yr
from
a
combination
of
HAP),
but
contribute
about
half
of
the
nationwide
HAP
emissions
from
stationary
sources.
The
purpose
of
the
Area
Source
Program,
described
in
section
112(
k)
of
the
CAA,
is
to
reduce
HAP
emissions
to
a
level
that
achieves
a
substantial
reduction
in
risk
to
the
public
health.
The
area
source
standards
may
be
based
on
the
maximum
achievable
control
technology
(
MACT)
under
section
112(
d)(
2)
or
on
generally
available
control
technology
(
GACT)
or
management
practices
under
section
112(
d)(
5)

of
the
CAA.

Plating
and
polishing
is
one
of
the
70
area
source
categories
listed
for
regulation
under
EPA's
Integrated
Urban
Air
Toxics
Strategy
(
67
FR
43112,
June
26,
2002).
Current
information
and
data
are
needed
to
support
the
development
of
area
source
standards
for
this
source
category.

This
information
collection
is
authorized
under
section
114
of
the
CAA.

(
b)
Practical
Utility/
Users
of
the
Data.

The
proposed
ICR
focuses
on
the
basic
information
and
data
needed
for
developing
technology­
based
standards
or
requirements,
such
as
the
types
of
electroplating
and
other
plating
and
polishing
operations
performed,
annual
operating
hours
and
production
rates,
types
of
equipment
used,
and
air
pollution
control
systems
(
or
management
practices).
The
proposed
ICR
also
requests
basic
information
needed
to
perform
economic
impact
analyses.
The
database
that
3
will
be
developed
from
the
completed
questionnaires
will
be
used
by
the
Emission
Standards
Division
(
ESD)
in
EPA's
Office
of
Air
Quality
Planning
and
Standards
to
identify
HAP
emission
sources
(
including
any
subcategories)
and
applicable
control
technologies
or
methods;
to
determine
the
appropriate
scope
and
level
of
control;
and
to
estimate
HAP
emissions,
as
well
as
environmental,
cost,
and
economic
impacts.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
search
of
EPA's
ongoing
ICRs
revealed
no
duplication
of
information­
gathering
efforts,

and
the
information
requested
is
not
available
through
other
sources.

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

The
EPA
published
a
pre­
ICR
Federal
Register
notice
on
July
29,
2005
(
70
FR
43865),

which
announced
our
intent
to
submit
this
ICR
to
OMB
and
requested
public
comments.
EPA
received
no
comments.

(
c)
Consultations.

The
questionnaire
was
developed
in
consultation
with
individual
facilities
and
an
industry
trade
association.
The
draft
questionnaire
was
field­
tested
by
nine
facilities
representing
a
crosssection
of
the
industry
to
obtain
labor
hour
estimates
and
suggestions
for
improvements.
Seven
of
the
nine
facilities
provided
labor
hour
estimates
with
their
responses.
Comments
also
were
invited
on
a
voluntary
basis
from
an
industry
trade
association.
In
general,
the
trade
association
and
plants
found
the
questionnaire
to
be
clearly
presented
and
easy
to
complete.
As
a
result
of
these
consultations,
ESD
made
minor
revisions
to
the
survey
instrument
to
clarify
questions
and
simplify
responses.
Table
1
identifies
the
non­
EPA
persons
consulted
during
development
of
the
4
proposed
ICR.

TABLE
1.
PERSONS
CONSULTED
ON
THE
PROPOSED
INFORMATION
COLLECTION
ACTIVITIES
Contact
Organization
Telephone
no.

1.
Field
testing
participants
John
Lindstedt
Artistic
Plating
Company
414­
271­
8138
Michael
G.
Green
Hadronics,
Inc.
513­
321­
9350
Clifton
R.
Game
Naval
Air
Depot
­
Cherry
Point
252­
464­
7690
Wyatt
Harding
Nobert
Plating
Company
(
2
locations)
312­
421­
4040
Don
Church
Baycote
Metal
Finishing
574­
256­
5673
Rajesh
M.
Shah
Providence
Metallizing
401­
722­
5300
John
Carpenter
U.
S.
Chrome
Corporation
of
Connecticut
203­
378­
9622
Joseph
Leonhardt
Leonhardt
Plating
Company
513­
242­
1410
2.
General
Comments
Christian
Richter
National
Association
of
Metal
Finishers
407­
281­
6445
Jeff
Hannapel
National
Association
of
Metal
Finishers
407­
281­
6445
J.
Kelly
Mowry
Gull
Industries,
Inc.
713­
224­
2430
Joelie
Zak
Scientific
Control
Laboratories,
Inc.
773­
254­
2406
(
d)
Effects
of
Less
Frequent
Collection.

Not
applicable
because
this
is
a
one­
time
request.

(
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
40
CFR
part
2,
subpart
B
 
Confidentiality
of
Business
Information
(
See
41
FR
36902,
September
1,
1976;
amended
by
5
43
FR
39999,
September
8,
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/
SIC
and
NAICS
Codes.

Potential
respondents
are
owners
and
operators
of
establishments
primarily
engaged
in
all
types
of
electroplating,
electroless
plating,
metal
and
thermal
spraying,
anodizing,
coloring,
and
finishing
of
metals
and
formed
products
for
the
trade.
The
primary
standard
industrial
classification
(
SIC)
code
for
the
respondents
is
3471,
Electroplating,
Plating,
Polishing,

Anodizing,
and
Coloring;
the
North
American
Industry
Classification
System
(
NAICS)
code
is
332813,
Electroplating,
Plating,
Polishing,
Anodizing,
and
Coloring.

(
b)
Information
Requested.

(
i)
Data
Items,
Including
Recordkeeping
Requirements.
A
copy
of
the
questionnaire
is
provided
as
an
attachment.
There
are
no
recordkeeping
requirements
associated
with
this
request.

°
Background
and
Instructions
provides
the
statutory
basis
for
the
information
collection,
describes
how
the
data
will
be
used,
gives
other
guidance
to
the
respondent,
and
highlights
that
no
additional
monitoring
or
testing
is
required
to
respond
to
the
questionnaire.

The
instructions
also
list
an
EPA
contact
for
questions
(
or
for
requests
to
submit
the
information
collected
in
a
different
format
such
as
computer
microdisk)
and
provide
the
return
name
and
address
for
completed
surveys.
6
°
Part
I
(
General
Information)
requests
the
company
name,
address,
contact
person,

and
geographical
location
(
UTM
coordinates,
if
available)
and
basic
economic
characteristics
(
annual
sales,
Dunn
&
Bradstreet
facility
identification
number,
applicable
NAICS
or
SIC
code,

number
of
employees,
and
parent
company).
Information
is
also
requested
on
the
types
of
plating
and
polishing
operations
performed,
annual
operating
hours,
any
Federal
emission
standards
to
which
the
plant
is
subject,
and
source
classification
(
major,
area,
minor)
with
respect
to
HAP
emissions.

°
Part
II
(
HAP
Emission
Points
and
Permit
Data)
directs
the
respondent
to
fill
out
tables
to
indicate
estimated
annual
emissions
of
HAP,
requests
a
copy
of
the
facility's
operating
permit,
and
requests
copies
of
emission
test
reports.

°
Part
III
(
Plating
and
Polishing
Process
Information)
directs
the
respondent
to
fill
out
tables
for
information
on
electroplating
tank
size
and
operation,
and
information
on
electroless
plating,
anodizing,
thermal
spraying,
other
finishing
operations,
and
types
of
finished
products.

°
Part
IV
(
HAP­
Containing
Plating
and
Polishing
Material
Data)
requests
information
on
materials
that
contain
HAP
and
are
used
for
plating
and
polishing
operations
°
Part
V
(
Ventilation
System
and
Emission
Control
System
Information)
requests
information
on
plating
and
polishing
tank
ventilation
system
design
and
operation.
This
section
also
requests
information
on
emission
control
devices
and
other
methods
used
(
e.
g.,
wetting
agents
and
surfactants)
to
control
or
reduce
HAP
emissions
°
Part
VI
(
Pollution
Prevention)
requests
the
respondent
to
provide
information
on
pollution
prevention
practices.

(
ii)
Respondent
Activities.
Respondent
activities
include
reading
the
instructions;
7
searching
data
sources
to
collect
available
data
from
files;
completing
the
written
survey;
and
transmitting
the
survey
to
EPA.
The
request
does
not
require
respondents
to
make
measurements
of
emissions
or
otherwise
create
information,
and
it
relies
on
information
that
should
be
readily
available
from
existing
records
and
reports.
There
is
no
need
for
respondents
to
develop
or
acquire
technology
or
systems
to
collect,
process,
or
disclose
the
information;
to
adjust
existing
ways
to
comply
with
previous
instructions;
or
to
train
personnel.

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

Agency
activities
associated
with
this
information
collection
include
preparing
and
transmitting
the
questionnaire,
answering
respondent
questions
about
the
questionnaire,
reviewing
and
assuring
the
quality
of
data
submissions,
addressing
any
requests
for
confidentiality,
and
entering
the
data
into
a
computerized
database.

(
b)
Collection
Methodology
and
Information
Management.

The
EPA
has
identified
a
total
of
1,208
plants
as
plating
and
polishing
area
sources.
The
ESD
will
mail
each
facility
a
paper
copy
of
the
survey.
An
electronic
version
of
the
ICR
form
is
also
available
in
the
public
docket
through
the
EPA's
Electronic
Docket
(
EDOCKET)
at:

http://
www.
epa.
gov/
edocket.
Respondents
can
use
EDOCKET
to
download
a
word
processing
electronic
copy
of
the
form
by
selecting
"
search"
and
keying
in
the
Docket
ID
number:

OAR­
2005­
0084.
A
facility
may
return
the
completed
survey
in
paper
or
electronic
format
except
when
the
survey
contains
CBI,
in
which
case
it
cannot
be
emailed
or
sent
by
fax.
The
survey
responses
will
be
reviewed
for
completeness
and
quality­
assured
prior
to
being
entered
in
a
8
computerized
database.
Followup
calls
will
be
made
to
maximize
the
response
rate
and
clarify
any
questions
on
the
responses.
Any
CBI
will
be
maintained
in
a
secure
location
as
required
by
EPA
CBI
procedures.
The
CBI
will
not
be
entered
into
the
database
unless
a
substantial
number
of
responses
contain
CBI.
In
that
case,
the
data
will
be
entered
into
the
database,
and
the
database
will
be
treated
as
CBI
in
its
entirety.
Public
access
to
non­
CBI
information
will
be
provided
through
the
rulemaking
docket.

(
c)
Small
Entity
Flexibility.

The
Small
Business
Administration
defines
a
small
entity
in
this
industry
as
a
company
with
fewer
than
500
employees
at
all
facilities.
The
information
collected
from
small
entities
is
needed
to
perform
analyses
required
by
the
Regulatory
Flexibility
Act
and
the
Small
Business
Regulatory
Enforcement
Fairness
Act.
Information
on
emissions
and
the
level
of
control
performance
is
needed
from
all
plants
(
large
and
small)
to
determine
the
appropriate
regulatory
approach
and
level
of
control.
Information
on
small
facilities
will
also
provide
insight
into
pollution
prevention
measures
that
may
be
applicable.

Most
of
the
plants
in
this
area
source
category
are
likely
to
meet
the
definition
of
small
entity,
and
this
survey
has
been
designed
to
ensure
that
the
burden
of
responding
is
not
high.
The
information
requested
should
be
readily
available,
and
the
questionnaire
highlights
that
facilities
are
not
required
to
perform
additional
monitoring
or
testing
or
create
information.

(
d)
Collection
Schedule.

The
proposed
mailing
date
for
the
questionnaire
is
within
4
weeks
of
ICR
approval
by
OMB.
Respondents
generally
are
required
to
respond
within
8
weeks
of
receiving
the
survey.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
9
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
collecting
and
reporting
information
were
derived
from
labor
hour
estimates
provided
by
seven
of
the
nine
plants
that
field­
tested
the
draft
questionnaire.

The
labor
estimates
ranged
from
3.5
hours
for
a
small
plant
to
104
hours
for
a
very
large
facility.

Some
responses
were
completed
by
plant
personnel,
and
other
responses
were
completed
by
consultants.
When
the
responses
were
completed
by
plant
personnel,
the
average
burden
was
estimated
to
be
10
hours;
when
the
responses
were
completed
by
consultants,
the
average
burden
was
estimated
to
be
36
hours.
One
of
the
respondents,
a
military
installation
that
operates
dozens
of
plating
tanks,
estimated
the
burden
to
be
104
hours.
These
three
average
burden
estimates
(
10
hours,
36
hours,
and
104
hours)
were
used
to
estimate
the
overall
burden
for
this
information
collection.
It
was
assumed
that
a
total
of
10
military
installations
or
comparably
sized
facilities
would
respond
to
the
ICR,
and
that,
of
the
remaining
facilities,
95
percent
of
the
responses
would
be
completed
by
plant
personnel,
and
5
percent
of
the
responses
would
be
completed
by
consultants.
This
results
in
an
overall
average
burden
of
12.1
hours
per
facility.

(
b)
Estimating
Respondent
Costs.

(
i)
Estimating
Labor
Costs.
Technical,
management,
and
clerical
average
hourly
rates
are
from
recent
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t11.
htm)
published
by
the
Bureau
of
Labor
Statistics
(
BLS).
Wages
for
civilian
workers
(
white
collar
occupations)

are
used
as
the
basis
of
the
labor
rates
with
a
total
compensation
of
$
40.47
for
technical
(
i.
e.,

engineer),
$
48.19
for
managerial,
and
$
21.37
for
clerical.
These
rates
represent
salaries
plus
fringe
benefits
but
do
not
include
the
cost
of
overhead.
The
base
labor
rates
were
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
Using
this
adjustment,
the
fully­
burdened
wage
rates
10
used
to
represent
respondent
labor
costs
are:
technical
at
$
67.58,
management
at
$
80.48,
and
clerical
at
$
35.69.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs;
Capital/
Startup
v.
O&
M
Costs;
and
Annualizing
Capital
Costs.
There
are
no
capital
or
O&
M
costs.

(
c)
Estimating
Agency
Burden
and
Cost.

The
Agency
burden
estimates
are
based
on
labor
hours
for
preparing
and
transmitting
the
questionnaire;
answering
respondent
questions
about
the
questionnaire;
reviewing
data
submissions
(
including
followup
calls
if
needed
to
clarify
responses);
addressing
requests
for
confidentiality;
and
entering
data
in
the
computerized
database
(
including
quality
assurance
procedures).
These
burden
items
are
based
on
Agency
experience
with
previous
industry
surveys
conducted
to
meet
standards
development
needs.

The
Agency
labor
rates
are
based
on
Office
of
Personnel
Management
(
OPM)
2004
General
Schedule
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
Salary
Table
2005­
GS
available
on
the
OPM
website
at
http://
www.
opm.
gov/
oca/
05tables/
pdf/
gs_
h.
pdf.

The
government
employee
labor
rates
are
$
30.90
for
technical
(
GS­
13,
Step
1),
$
42.94
for
managerial
(
GS­
15,
Step
1),
and
$
14.65
for
clerical
(
GS­
7,
Step
1).
These
rates
represent
salaries
plus
fringe
benefits
but
do
not
include
the
cost
of
overhead.
The
base
labor
rates
were
adjusted
by
an
overhead
rate
of
167
percent.
Using
this
adjustment,
the
fully­
burdened
wage
rates
used
to
represent
Agency
labor
costs
are:
technical
at
$
51.60,
management
at
$
71.71,
and
clerical
at
$
24.47.

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

The
EPA
has
identified
a
total
of
1,280
potential
respondents
from
existing
Agency
11
databases
and
reference
sources.
Burden
hours
and
costs
are
annualized
over
the
3­
year
clearance
period
for
the
ICR.
Therefore,
the
average
annual
number
of
respondents
is
403.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
Tally.
Respondent
burden
hours
are
shown
in
Table
2.
The
average
annual
burden
is
estimated
at
5,608
person­
hours
per
year
with
an
average
annual
cost
of
$
366,566.
No
annual
capital
or
O&
M
costs
are
applicable.

(
ii)
The
Agency
tally.
The
average
annual
Agency
burden
is
given
in
Table
3.
The
average
annual
burden
is
estimated
at
1,537
person­
hours
with
an
average
annual
cost
of
$
77,004.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
is
not
applicable
because
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
since
this
is
a
new
collection.

(
g)
Burden
Statement.

The
average
annual
respondent
burden
per
facility
is
estimated
at
12.1
hours
at
a
cost
of
$
925.
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
12
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.
OAR­
2005­
0084,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center,
EPA
West,
Room
B­
102,
1301
Constitution
Avenue,
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
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.

Use
EDOCKET
to
submit
or
view
public
comments,
and
to
access
the
index
listing
of
the
contents
of
the
public
docket
that
are
available
electronically.
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
EPA
Docket
ID
No.
OAR­
2005­
0084
in
any
correspondence.
13
PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
proposed
data
collection.
14
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
Burden
item
(
A)

Personhours
per
respondenta
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
per
yearb
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
F=
Ex0.05)
(
G)
Clerical
personhours
per
year
(
G=
Ex0.1)
(
H)
Cost,$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
A.
Read
Instructions
1
1
1
403
403.0
20.2
40.3
$
30,295
B.
Gather
Existing
Information
8.7
1
8.7
403
3,506.1
175.3
350.6
$
263,564
C.
Complete
and
Review
Survey
Form
1.4
1
1.4
403
564.2
28.2
56.4
$
42,413
D.
Transmit
Information
1.0
1
1
403
403.0
20.2
40.3
$
30,295
3.
Acquisition,
Installation,

and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
N/
A
5.
Recordkeeping
Requirements
N/
A
TOTAL
LABOR
BURDEN
AND
COST
4,876
244
488
$
366,566
Annualized
cost
of
capital
$
0
Operation
and
maintenance
$
0
a
Based
on
pretest
responses
from
seven
of
nine
facilities
that
field­
tested
the
draft
questionnaire.

b
One
time
event
over
the
3­
year
term
of
the
ICR
(
1,208/
3
=
403
respondents/
yr).

c
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
67.58,
management
at
$
80.48,
and
clerical
at
$
35.69.
15
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
Activity
(
A)

Hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
year
(
C=
AxB)
(
D)
Management
person­
hours
per
year
(
D=
Cx0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
Cx0.1)
(
F)

Cost,
$
a
Surveys
and
Studies
1.
Develop
survey
(
b)
160
0.33
53.3
2.67
5.33
$
3,074
2.
Distribute
survey
(
b)
40
0.33
13.3
0.67
1.33
$
768
3.
Answer
questions
(
c)
0.5
40.3
20.2
1.01
2.02
$
1,161
4.
Log
in
and
acknowledge
receipt
of
responses
1
403
403.0
20.2
40.3
$
23,226
5.
Enter
into
database,
QA
check,
analyze
and
summarize
results
2
403
806.0
40.3
80.6
$
46,452
6.
Respond
to
requests
for
confidentiality
(
d)
1
40.3
40.3
2.02
4.03
$
2,323
Travel
N/
Ae
$
0
Litigation
N/
Ae
$
0
Enforcement
Activities
N/
Ae
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
1,336
67
134
$
77,004
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
51.60,
management
at
$
71.71,
and
clerical
at
$
24.47.

b
One
time
event
over
the
3­
year
term
of
the
ICR
(
1/
3=
0.33
occurrences/
yr)

c
Of
the
403
respondents/
yr
(
1,208/
3),
assume
10
percent
(
403*
0.1=
40.3)
will
require
assistance.

d
Of
the
403
respondents/
yr
(
1,208/
3),
assume
10
percent
(
403*
0.1=
40.3)
will
request
information
to
be
treated
as
CBI.

e
Travel,
litigation,
and
enforcement
activities
are
not
applicable.
OMB
Control
No.
20XX­
XXXX
Approval
expires
XX/
XX/
XX
BACKGROUND
AND
INSTRUCTIONS
FOR
PLATING
AND
POLISHING
INFORMATION
REQUEST
Background
and
Instructions
Section
112
of
the
Clean
Air
Act
outlines
the
statutory
requirements
for
the
EPA's
stationary
source
air
toxics
program.
Section
112(
k)
requires
the
development
of
standards
for
area
sources
which
account
for
90
percent
of
the
emissions
in
urban
areas
of
the
33
urban
hazardous
air
pollutants
(
HAP)
listed
in
the
Integrated
Urban
Air
Toxics
Strategy.
The
Integrated
Urban
Air
Toxics
Strategy
lists
plating
and
polishing
as
an
area
source
category.
The
plating
and
polishing
source
category
is
defined
to
include
establishments
primarily
engaged
in
all
types
of
electroplating,
plating,
polishing
(
using
physical,
chemical,
or
electrochemical
processes),
thermal
or
metal
spraying,
anodizing,
coloring,
and
finishing
of
metals
and
formed
products
for
the
trade.
Please
note
that
chromium
emissions
from
chromium
electroplating
and
anodizing
tanks
are
regulated
under
40
CFR
63,
subpart
N
and
will
not
be
addressed
under
the
plating
and
polishing
source
category.
We
are
requesting
in
question
I.
G
that
you
identify
electroplating
finishes,
including
chromium,
applied
in
your
facility
and
we
are
requesting
facility
chromium
emissions
in
Table
1
but
we
are
not
requesting
any
further
information
on
chromium
electroplating
operations.
Also
note
that
the
electroplating,
electroless
plating,
polishing,
anodizing,
thermal
or
metal
spraying,
coloring,
and
finishing
processes
covered
by
this
questionnaire
will
be
referred
to
generically
as
plating
and
polishing.

The
EPA
will
use
the
information
collected
from
a
full
industry
mail
out
of
this
questionnaire
to
evaluate
the
need
for
area
source
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
plating
and
polishing
area
source
category.
If
an
area
source
NESHAP
is
developed,
the
collected
information
will
be
used
to
evaluate
the
types
of
provisions
needed
to
limit
HAP
emissions
from
plating
and
polishing
operations
and
to
estimate
the
impacts
of
regulatory
options.

Please
answer
all
questions
unless
not
applicable
to
your
facility
or
operations,
in
which
case
note
that
the
question
is
not
applicable.
All
information
should
be
for
the
reporting
year.
Readily
available
information
should
be
used;
no
additional
emission
testing
or
monitoring
is
required
to
respond
to
this
questionnaire.

An
electronic
version
of
the
Information
Request
form
is
available
in
the
public
docket
through
the
EPA's
Electronic
Docket
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.
Use
EDOCKET
to
download
a
word
processing
electronic
copy
of
the
form.
Once
in
the
EPA
docket
system,
select
"
search,"
then
key
in
the
Docket
ID
number:
OAR­
2005­
0084.
17
Please
note
that
you
are
to
provide
a
separate
response
package
for
each
facility
in
your
company
with
plating
and
polishing
operations.
Copies
of
this
questionnaire
should
be
made
for
additional
facilities.
Return
this
request
along
with
any
additional
information
to:

Donna
Lee
Jones
USEPA
Mailroom
(
C439­
02)
Research
Triangle
Park,
NC
27711
If
you
have
any
questions
regarding
this
request,
please
contact
Donna
Lee
Jones
at
919­
541­
5251
(
e­
mail
Jones.
DonnaLee@
epa.
gov).

The
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
12.1
hours
per
response.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
in
any
correspondence.
Do
not
send
the
completed
form
to
this
address.
18
ENCLOSURE
1
INFORMATION
REQUEST
FOR
PLATING
AND
POLISHING
OPERATIONS
I.
General
Information
A.
Facility
Name:

B.
Facility
Street
Address:
1)
Street:
2)
City:
3)
State:
4)
ZIP
Code:
5)
County:

C.
Mailing
Address
(
If
different
from
Facility
Street
Address):
1)
Street
or
P.
O.
Box
2)
City:
3)
State:
4)
ZIP
Code:

D.
Corporate
Owner:
1)
Name
of
Corporate
Owner:
2)
Street:
3)
City:
4)
State:
5)
ZIP
Code:
6)
Corporate
Sales:
$

E.
Facility
Description
1)
Provide
a
brief
description
of
the
facility
(
e.
g.,
plating
and
polishing
job
shop)

2)
Dun
&
Bradstreet
No:
3)
SARA
TRI
Facility
ID:
4)
Number
of
facility
employees
5)
SIC(
s)
6)
NAIC(
s)
7)
Operating
hours:
Hours/
day:________
Days/
week:_______
Weeks/
year:________
F.
Plating
and
Polishing
Processes
Conducted
(
Check
all
that
apply)


Electroplating

Polishing
(
Please
Identify,
e.
g.,
mechanical,
chemical,
or
electrochemical,
and
briefly
describe)


Electroless
Plating
(
Please
identify
processes,
e.
g.,
electroless
nickel)


Anodizing
(
Please
identify
and
briefly
describe)


Thermal
or
Metal
Spraying
(
Please
identify
and
briefly
describe)
19

Other
(
Please
identify
and
briefly
describe)

G
Electroplating
Finishes
Applied
(
Check
all
that
apply)


Brass

Bronze

Cadmium

Chromium,
Black

Chromium,
Decorative

Chromium,
Hard

Copper

Gold

Lead

Nickel,
Black

Nickel,
Decorative

Nickel,
Industrial

Platinum

Silver

Tin

Tin­
Lead

Tin­
Nickel

Tin­
Zinc

Zinc

Zinc­
Iron

Zinc­
Nickel

Other
(
Please
identify)

H.
Technical
Contact
(
able
to
answer
technical
questions
about
this
survey)
1)
Name
and
Title:
2)
Telephone:
3)
Facsimile:
4)
Email:

I.
Geographic
Coordinates;
either
latitude
and
longitude
(
in
degrees
and
minutes)
or
UTM
coordinates
of
the
center
of
the
plant:

J.
Regulatory
Requirements
(
Please
indicate
any
Federal
emission
standards,
such
as
NSPS
or
NESHAP,
which
are
applicable
to
your
facility):


40
CFR
part
63,
subpart
N
Chromium
Electroplating
NESHAP

40
CFR
part
63,
subpart
T
Halogenated
Solvent
Cleaning

Other
(
Please
Identify)

K.
Facility
Classification
for
HAP
(
If
you
have
an
air
operating
permit
issued
under
Title
V
of
the
Clean
Air
Act,
please
indicate
the
classification
of
your
facility):


Major
Source

Synthetic
Minor
Source

Minor/
Area
Source
What
co­
located
activities
influence
facility
classification:
20
II.
HAP
Emissions
and
Permit
Data
Attachment
1
is
a
list
of
the
most
common
HAP
reported
as
being
emitted
by
electroplating
facilities.
The
complete
list
of
HAP
is
provided
in
Attachment
2.
Please
provide
readily
available
emissions
information
for
these
HAP
in
Table
1
for
the
most
recent
year
for
which
data
are
available.
Indicate
the
reporting
year
below.
Also
provide
readily
available
emissions
information
for
any
other
HAP
(
e.
g.,
chromium
compounds
from
chromic
acid
etching)
known
to
be
used
in
your
facility.
If
you
are
required
to
prepare
annual
emissions
inventory
reports,
you
may
attach
a
copy
of
the
most
recent
annual
emissions
inventory
instead
of
completing
this
table.
No
additional
emissions
testing
or
monitoring
is
required
to
respond
to
this
questionnaire.
Reporting
Year:
________

1.
Table
1.
HAP
Emissions
HAP
CAS
Number
Facility
HAP
Emissions
(
pounds/
year)
Plating
and
Polishing
HAP
Emissions
(
pounds/
year)
Basis
for
Estimate
2
Reporting
Year
Actual
Reporting
Year
Actual
Chlorine
7782505
Formaldehyde
50000
Hydrochloric
Acid
7647010
Hydrogen
Fluoride
7664393
Cadmium
Compounds
Chromium
Compounds
1
Cyanide
Compounds
Glycol
Ethers
Lead
Compounds
Manganese
Compounds
Nickel
Compounds
Other
(
Specify
)__________

Other
(
Specify
)__________

Total
HAP
­­­­­

1
For
facility
emissions,
include
all
chromium
emissions;
for
plating
and
polishing
emissions,
do
not
include
chromium
emissions
from
electroplating
or
anodizing
tanks
subject
to
the
NESHAP
(
40
CFR
63,
subpart
N).
2
Indicate
basis
for
emission
estimates:
TD
=
test
data;
MB
=
mass
balance;
EJ
=
engineering
judgement;
Other
(
please
specify).

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
21
B.
Permit
Conditions
If
any
of
the
plating
and
polishing
operations
at
your
facility
are
subject
to
permit
limits,,
please
provide
a
copy
of
your
air
operating
permit.

C.
Emission
tests
Enclose
complete
test
reports
from
any
emission
tests
conducted
on
plating
and
polishing
processes
and
air
pollution
control
devices
(
APCDs).
No
additional
emissions
testing
or
monitoring
is
required
to
respond
to
this
questionnaire.
Include:

(
1)
pollutants
and
emission
rates
measured,
(
2)
the
test
method
or
procedure
used,
(
3)
information
on
actual
plating
or
polishing
process
conditions
at
the
time
the
measurements
were
made,
(
4)
if
the
tests
were
conducted
on
outlet
streams
of
APCDs,
the
APCD
operating
conditions,
and
(
5)
all
appendices,
including
field
data
sheets,
laboratory
reports,
example
calculations,
process
data
recorded
during
the
test,
and
other
supporting
data.
22
III
Plating
and
Polishing
Process
Information
A.
Table
2.
Summary
of
Electroplating
Tank
Information
(
Provide
the
following
information
for
each
tank
in
which
an
electroplating
finish
containing
HAP
listed
in
Attachment
1
is
applied
[
plating
tank].)

Tank
ID
1
Finish
type
applied
2
Tank
volume
(
gal)
Tank
surface
dimensions
(
ft
x
ft)
Maximum
operating
amperage
(
amps)
Rectifier
operating
hours
(
hr/
year)
Type
of
bath
agitation3
Tank
emission
control
method
4
1
For
example,
if
you
operate
three
industrial
nickel
plating
tanks,
you
can
number
them
InNi1,
InNi2,
and
InNi3.
2
For
Example,
Black
nickel
=
BlNi;
Brass
=
Bs;
Cadmium
=
Cd;
Copper
=
Cu;
Gold
=
Au;
Lead
=
Pb;
Nickel,
Decorative
=
NiD;
Nickel,
Industrial
=
NiI;
Silver
=
Ag;
Tin/
Lead
=
SnPb;
Tin­
Nickel
=
SnNi;
Zinc
=
Zn;
Zinc/
Nickel
=
ZnNi.
3
Please
fill
in
Air
agitation
=
AA;
Eductor
(
pump
mixing)
=
Ed;
Mechanical
mixing
=
MM;
No
agitation
=
None;
or
Other
(
Specify)
=
Other.
4
Indicate
only
controls
applied
to
each
specific
tank,
such
as
polypropylene
balls
=
PB;
wetting
agent
fume
suppressant
=
WAFS;
foam
blanket
=
FB;
Merlin
cover
=
MC;
tank
enclosure
=
TE.
Do
not
include
control
devices
installed
on
the
ventilation
or
exhaust
system.

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
23
B.
Table
3.
Summary
of
Electroless
Plating,
Anodizing,
and
Other
Finishing
Tank
Information
(
Provide
the
following
information
for
each
tank
in
which
an
electroless
plating,
anodizing
or
other
finish
containing
HAP
listed
in
Attachment
1
is
applied.)

Tank
ID
1
Finish
type
applied
2
Tank
volume
(
gal)
Tank
surface
dimensions
(
ft
x
ft)
Type
of
bath
agitation
3
Tank
emission
control
method
4
1
For
example,
if
you
operate
three
electroless
nickel
plating
tanks,
they
could
be
numbered
ENi1,
ENi2,
and
ENi3.
2
For
example;
Alodine
Treatment
=
Ad,
Blackening/
Antiquing
=
BlA,
Black
Dye
=
BlDy,
Black
Oxide
=
BlOx,
Boric­
Sulfuric
Acid
Anodize
=
Bo­
SuAn,
Bright
Dip
=
BrD,
Cadmium
Strip
=
CdStr,
Chromate
Conversion
=
ChCv;
Electroless
Nickel
=
ENi;
Electrophoretic
Coating
Process
=
EPC,
Galvanic
Anodize
=
GaAn,
Lacquering
=
Lq,
Magnesium
Treatment
=
Mg,
Nitric
Acid
Passivation
=
NitPa,
Passivation
=
Pa,
Phosphating
=
Ph,
Phosphoric
Acid
Anodize
=
PhAn,
Sodium
Dichromate
Treat
=
NaDiCr,
Sulfuric
Acid
Aluminum
Anodize
=
SuAn,
Sulfuric
Acid
Strip
Anodize
=
SuStrAn,
Titanium
Anodize
=
TiAn.
3
Please
fill
in
Air
Agitation
=
AA,
Eductor
(
pump
mixing)
=
Ed,
Mechanical
Mixing
=
MM,
or
No
Agitation
=
None.
4
Indicate
only
controls
applied
to
each
specific
tank,
such
as:
polypropylene
balls
=
PB;
wetting
agent
fume
suppressant
=
WAFS;
foam
blanket
=
FB;
Merlin
cover
=
MC;
tank
enclosure
=
TE.
Do
not
include
control
devices
installed
on
exhaust
system.

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
24
C.
Table
4.
Summary
of
Information
on
Thermal
Spraying
(
Provide
the
following
information
for
each
thermal
or
metal
spraying
operation
in
which
any
material
containing
HAP
listed
in
Attachment
1
is
applied.)

Thermal
spraying
line
ID
1
Thermal
spraying
process
type
2
Is
line
operated
in
booth
or
enclosure?
(
yes/
no)
Type
of
booth
or
enclosure3
Is
operation
ventilated?
(
yes/
no)

1
For
each
thermal
spraying
process
line,
indicate
the
name
or
ID
number.
2
For
example,
flame
spraying
=
FlS;
electric
arc
spraying
=
EAS;
plasma
arc
spraying
=
PAS;
highvelocity
oxy­
fuel
=
HVOF;
detonation
gun
=
DG;
Other
=
(
specify).
3
Indicate
if
booth
or
enclosure
is
partial
(
i.
e.,
open
on
one
or
more
sides)
or
if
enclosure
is
complete
(
enclosed
on
all
sides).

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
25
D.
Table
5.
Summary
of
Information
on
Finished
Materials,
Substrates,
and
Products
(
Provide
the
following
information
for
products
or
materials
that
are
plated,
polished,
or
finished
at
your
facility.
For
each
product,
also
indicate
the
base
metal
or
base
material
that
is
finished
and
the
ID
number
corresponding
to
the
tanks
from
Tables
2
or
3,
or
thermal
spraying
operation
from
Table
4,
that
are
used
to
finish
the
product.)

Type
of
product
or
substrate
finished
Base
metal
or
material
ID
Nos
for
tanks
and/
or
thermal
spraying
lines
Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
26
IV.
HAP­
Containing
Plating
and
Polishing
Material
Data
Table
6.
HAP­
Containing
Material
Data
(
Please
provide
the
following
information
for
each
HAPcontaining
plating
or
polishing
material
used
in
the
Reporting
Year
that
is
a
source
of
HAP
emissions
reported
in
Table
1.
If
records
for
the
full
Reporting
Year
are
not
readily
available,
provide
HAPcontaining
material
information
for
a
typical
quarter
in
the
Reporting
Year
and
check

that
data
are
for
one
quarter
of
the
Reporting
Year.
For
each
material,
either
submit
speciated
HAP
content
data
from
the
Material
Safety
Data
Sheet
[
MSDS]
or
provide
the
speciated
HAP
content
in
Columns
4
and
5
of
this
table.)

Data
are
for
Full
Reporting
Year

Data
are
for
One
Quarter

Material
name
or
ID1
Manufacturer
or
supplier
name
Amount
used2
Units3
HAP
Species4
Tank
or
thermal
spray
line
ID
Nos.
5
1
Indicate
the
generic
name,
trade
name,
or
product
name
for
any
material
that
contains
one
or
more
HAP.
2
Indicate
the
total
amount
used
during
the
reporting
year.
3
For
example,
gallons,
pounds.
4
List
all
HAP
present
in
the
material;
refer
to
the
attachment
for
a
list
of
HAP
commonly
used
in
plating
and
polishing
operations.
5
Use
the
same
ID
Nos
for
all
plating
and
polishing
tanks
listed
in
Tables
2
and
3
and
for
all
thermal
spraying
lines
listed
in
Table
4.

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
27
V.
Ventilation
System
and
Emission
Control
System
Information
A.
Table
7.
Local
Ventilation
System
Design
and
Operating
Data
(
For
each
ventilation
system
that
exhausts
one
or
more
of
the
tanks
listed
in
Tables
2
or
3,
or
thermal
spraying
operation
listed
in
Table
4,
please
provide
the
following
information,
if
available.

Ventilation
system
ID1
Tank
and
thermal
spray
line
ID
Nos.
2
Exhaust
flow
rate
(
acfm)
3
Exhaust
duct
diameter
(
in)
4
Hood
location5
Type
of
emission
control6
1
Indicate
the
name
or
identification
number
for
each
independent
ventilation
system.
2
List
the
ID
Nos.
from
Tables
2
and
3
for
all
tanks
or
the
thermal
spray
line
ID
Nos
from
Table
4
for
all
tanks
and
thermal
spraying
operations
that
are
exhausted
by
the
ventilation
system.
3
Indicate
the
exhaust
flow
rate
through
the
entire
system
in
units
of
actual
cubic
feet
per
minute.
4
Provide
the
diameter
of
the
duct
in
inches
at
the
inlet
to
the
control
device
or
at
the
exhaust
point.
5
For
ventilation
systems
that
exhaust
tanks,
indicate
if
the
tank
exhaust
hood
is
located
on
the
centerlines
or
sides
of
the
tanks.
6
Identify
the
type
of
emission
control
system
installed
on
the
ventilation
system.
For
example,
composite
mesh
pad
=
CMP;
mesh
pad
mist
eliminator
=
MPME;
packed
bed
scrubber
=
PBS;
high
efficiency
particulate
air
filter
=
HEPA;
wet
scrubber
(
other
than
packed
bed)
=
WS;
chevron­
blade
mist
eliminator
=
CBME.

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
28
B.
Table
8.
Surfactant
or
Wetting
Agent
Fume
Suppressant
Information
(
For
each
tank
listed
in
Tables
2
or
3
in
which
a
foam
blanket,
surfactant
or
wetting
agent
fume
suppressant,
or
combination
foam
blanket/
surfactant
or
wetting
agent
is
used,
please
provide
the
following
information
and
submit
the
MSDS
for
each
surfactant
or
wetting
agent
used.)

Tank
ID1
Surfactant
or
wetting
agent
name
Manufacturer/
supplier
Amount
used
in
reporting
year2
Annual
cost
of
surfactant
or
wetting
agent
($)
Bath
surface
tension3
1
List
the
ID
Nos.
from
Tables
2
and
3
for
all
tanks
in
which
the
surfactant
or
wetting
agent
is
used.
2
Indicate
the
amount
used
during
the
reporting
year
and
units
(
e.
g.,
gallons,
pounds).
3
If
you
monitor
or
periodically
measure
the
bath
surface
tension,
indicate
the
surface
tension
in
units
of
dynes
per
centimeter.

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
29
C.
Table
9.
Air
Pollution
Control
Device
(
APCD)
Information
(
For
each
ventilation
system
listed
in
Table
7
that
is
exhausted
to
an
emission
or
air
pollution
control
device,
please
provide
the
following
information
Ventilation
system
ID
1
APCD
Type
2
Control
efficiency
(%)
3
Basis
for
control
efficiency
4
1
Indicate
the
ventilation
system
ID
No
or
name
from
Table
7.
2
List
the
type
of
air
pollution
control
device.
For
example,
composite
mesh
pad
=
CMP;
mesh
pad
mist
eliminator
=
MPME;
packed
bed
scrubber
=
PBS;
high
efficiency
particulate
air
filter
=
HEPA;
wet
scrubber
(
other
than
packed
bed)
=
WS;
chevron­
blade
mist
eliminator
=
CBME.
3
Indicate
the
control
efficiency
or
percent
reduction
in
percent.
4
Identify
the
basis
for
the
control
efficiency.
For
example,
manufacturer's
guarantee,
performance
test,
other
(
please
specify).

Please
make
blank
copies
of
this
table
for
use
as
work
sheets
and/
or
for
additional
room.
1
Pollution
prevention
means
any
practice
that
reduces
or
eliminates
the
creation
of
pollutants
through
increased
efficiency
in
the
use
of
raw
materials,
energy,
water,
or
other
resources.
Examples
include
substituting
a
hazardous
material
with
a
nonhazardous
material
and
process
changes
that
eliminate
the
use
of
a
hazardous
material.

2
Dragout
refers
to
residual
plating
or
finishing
bath
solution
that
remains
on
parts
or
workpieces
after
they
are
removed
from
the
tank.

30
VI.
Pollution
Prevention1
A.
Steps
used
to
minimize
drag­
out2:


Surfactants

Drip
time

Air
blow
down

Other:

B.
Describe
any
other
pollution
prevention
measures
(
e.
g.,
drain
board
between
tanks
angled
to
drain
dragout
back
to
the
previous
bath):

C.
Provide
costs
and
cost
basis
(
e.
g.,
cost
of
developing
and
implementing
work
practices
or
cost
of
substituting
a
non­
HAP
plating
finish
for
a
HAP­
containing
plating
finish)
of
work
practices
or
pollution
prevention
(
P2)
measures
currently
being
used:

D.
Provide
costs
and
cost
basis
for
P2
measures
evaluated
but
not
implemented
and
reason(
s)
why
they
were
not
implemented:
31
Attachment
1
List
of
Most
Common
Hazardous
Air
Pollutants
(
HAPs)
Reported
Emitted
from
Electroplating
Facilities
in
SIC
Code
3471
CAS
Number
Chemical
Name
7782505
Chlorine
50000
Formaldehyde
7647010
Hydrochloric
acid
7664393
Hydrogen
Fluoride
67561
Methanol
7723140
Phosphorus
108883
Toluene
1330207
Xylenes
Cadmium
Compounds
Cobalt
Compounds
Chromium
Compounds
Cyanide
Compounds
Glycol
Ethers
Lead
Compounds
Manganese
Compounds
Nickel
Compounds
