1

TECHNICAL MEMORANDUM

DATE: December 2013

TO: Docket EPA-HQ-OAR-2010-0707

FROM: Eastern Research Group

SUBJECT: Impacts of Grain Elevator NSPS Subpart DDa Requirements

1.0 Introduction

This memorandum documents the estimated cost and environmental impacts of meeting 

requirements in the proposed Subpart DDa new source performance standard (NSPS) for grain 

elevators. The impacts are expressed as incremental differences between the impacts of grain 

elevators complying with the proposed subpart DDa and the current NSPS requirements of 

subpart DD. The impacts are presented for future grain elevators that are projected to commence 

construction, reconstruction, or modification over the five years following proposal of the 

revised NSPS. The requirements in the proposed subpart DDa that differ from subpart DD that 

effect costs are:

• Annual opacity testing for affected facilities, 

• Particulate matter (PM) testing every 60 months for affected facilities, 

• Weekly visual inspection of affected facilities, 

• Inspection of fabric filters and baghouses every six months for affected facilities, 

• New recordkeeping requirements, 

• Reporting in EPA’s emissions reporting tool (ERT), 

• New opacity limit for wire mesh column dryers, and 

• New opacity limit for barge unloading stations using an en-masse conveyor system. 

• PM and opacity standards for affected facilities associated with TSFs (grain handling, 

truck loading, and truck unloading)

The proposed requirements would be incurred only by affected facilities that commence 

construction, modification, or reconstruction after the date subpart DDa is proposed (i.e., they 

would not be incurred by all affected facilities at a grain elevator). Barge unloading stations 

using an en-masse conveyor and wire mesh column dryers are not expected to incur a cost or 

emissions impact from application of add-on controls because data collected indicates that 

sources should be able to meet the standards without their use.

1 PM testing every five years for 

affected facilities would occur outside of the five-year period analyzed because most 

construction, reconstructions, and modifications for grain elevators are expected to occur after 

the first or second year following promulgation. Information provided in the responses to the

2009 survey indicate that grain elevators are already keeping records that are proposed in subpart 

DDa (but not in subpart DD), except for those associated with visual monitoring and baghouse 

inspections.

2-4 The only incremental cost estimated for subpart DDa would be for annual opacity 
2

testing at affected facilities, weekly visual inspection of affected facilities, inspection of fabric 

filters for affected facilities every six months, the recordkeeping associated with visual 

monitoring and inspections, reporting in ERT, and compliance costs to meet PM and opacity 

standards for affected facilities associated with TSFs. Recordkeeping and reporting costs are 

included in the burden estimate5 and are not presented in the memorandum.

In order to estimate the incremental impacts of the proposed subpart DDa requirements, 

the potential scenarios where grain elevators may be constructed, reconstructed, or modified and 

subject to subpart DDa were identified. The cost and environmental impacts of each scenario 

were then estimated. Section 2.0 discusses the projected units and affected facilities subject to 

each scenario. Section 3.0 discusses the impacts estimated for each scenario.

2.0 Estimation of Projected Units and Facilities 

Eleven different scenarios were identified where grain elevators may be constructed, 

reconstructed, or modified, and are summarized in Table 2-1. Of these, scenarios 6a and 6b

through 11 would incur impacts based on requirements in subpart DDa (that are not in subpart 

DD). The count of grain elevators in scenarios 7 through 10 that are projected to be subject to the 

new subpart DDa requirements were estimated by extrapolating information in previous years to 

the five years following promulgation of the standard. First, for the population of grain elevators 

where information was gathered, a ratio was calculated relating the number of grain elevators in 

previous years (that would be included in each scenario) to the total number of grain elevators in 

the population. In another memorandum6

, EPA estimated the population of grain elevators that 

are subject to subpart DD to be between 350 and 1100. The lower end of the range represents 

grain elevators identified in EPA’s Air Facility System (AFS)3 count of approximately 350 grain 

elevators subject to the NSPS to be subject to subpart DD. The upper end of the range represents 

a potential list of grain elevators developed by supplementing the AFS dataset with information 

in State and other Federal databases, and filtering grain elevators based on their grain storage 

capacity and the subpart DD storage capacity requirements. However, insufficient information is 

available on the type of grain stored, grain elevator construction date, and use of the grain to 

verify that the grain elevators in the upper range are definitively subject to subpart DD. 

Therefore for the impacts analysis, the lower range estimate of 350 grain elevators was used to 

provide a conservative estimate of the population. National projections were extrapolated by 

applying the AFS count to the calculated ratio. The resulting number was then divided by the 

number of years for which the information was obtained to develop a per year count. The per 

year count was then used to make projections over the five years following promulgation of 

subpart DDa. 

For scenarios where permanent storage capacity is added to grain elevators, the 

applicability criteria for subpart DD and proposed DDa are the same. For scenarios where 

temporary storage facility (TSF) capacity is added, the applicability criteria of the proposed 

subpart DDa was used to determine whether the applicability levels were exceeded because 

subpart DDa includes new requirements that are specific to TSFs. The basis and estimate of the 

number of projected grain elevators and affected facilities are discussed below for each scenario. 

For scenarios 6a, 6b and 11, other approaches were used, and are also explained below.
3

Scenarios 6a and 6b – New construction

The number of new grain elevators projected to be constructed was based on the number 

of elevators that had been identified to be constructed in the past five years.6 The number was

estimated to be three. Therefore, for the five years following promulgation of subpart DDa, three 

grain elevators are projected to be constructed. Based on a 2009 CAA section 114 survey 

submitted by 121 grain elevators2

, one-third of the estimated new grain elevator constructions are 

assumed to be subject to subpart DDa due to the TSF capacity, or one new grain elevator in the 

next five years. The remaining two elevators are assumed to be subject to subpart DDa due to the 

permanent storage capacity.

Scenario 7 – Add TSF capacity and meet applicability criteria

The numbers of grain elevators estimated for scenarios 7 through 10 were based on 

responses to a 2009 CAA section 114 survey submitted by 121 grain elevators2

. The earliest TSF

identified in the survey was installed in 1984. The survey responses indicated that four out of 

121 grain elevators from 1984 through 2008 (i.e., 24 years) added TSFs with capacities such that 

the applicability of subpart DDa would be met (when it had not been previously) and the grain 

elevator would be subject to the requirements of subpart DDa. The resulting estimate, 

extrapolated using the AFS count, is approximately 0.5 grain elevators per year would be subject 

to scenario 7. This number was rounded to the nearest whole number, i.e., 1.

Scenario 8 – Add permanent capacity and meet applicability criteria

Subpart DD was promulgated in 1978. The survey responses indicated that 14 out of 121 

grain elevators between 1978 and 2008 (i.e., 30 years since subpart DD was promulgated), added 

permanent storage capacity such that the applicability of subpart DD and proposed subpart DDa

would be met (when it had not been previously). Affected facilities at those grain elevators

would be subject to NSPS requirements. The resulting estimate, extrapolated using the AFS

count, is approximately 1.3 grain elevators per year would be subject to scenario 8. This number 

was rounded to the nearest whole number, i.e., 1.

Scenario 9 – Add permanent capacity to grain elevator already subject to subpart DD

The survey responses indicated that 17 out of 121 grain elevators in 30 years, that would 

already meet the applicability thresholds in subpart DD and proposed subpart DDa, added 

permanent storage capacity. The affected facilities in those grain elevators would be subject to 

NSPS requirements. The resulting estimate, extrapolated using the AFS count, is approximately 

1.51 grain elevators per year would be subject to scenario 9. This number was rounded to the 

nearest whole number, i.e., 2.

Scenario 10 – Add TSF capacity to grain elevator already subject to subpart DD

The survey responses indicated that 13 out of 121 grain elevators in 24 years, that would 

already meet the applicability thresholds in subpart DD, added TSF capacity. The affected 

facilities in those grain elevators would be subject to the requirements of subpart DDa. The 

resulting estimate, extrapolated using the AFS count, is approximately 1.56 grain elevators per

year would be subject to scenario 10. This number was rounded to the nearest whole number, 

i.e., 2.
4

Scenario 11 – Reconstruction or modification of grain elevators

Insufficient information was available to make a projection of the number of grain 

elevators that would be modified or reconstructed. For estimation purposes, it was assumed that 

at least 5 percent of the population of grain elevators would be modified or reconstructed each 

year. 

Table 2-2 summarizes the projected number of grain elevators in each scenario over the 

five years following promulgation of subpart DDa.

The numbers of affected facilities at each grain elevator in scenarios 7 through 10 were 

estimated based on the assumption that addition of TSF or permanent storage capacity would 

result in grain handling, one truck unloading station, and one truck loading station at each grain 

elevator becoming subject to subpart DDa requirements. For scenarios 6a and 6b (new 

construction), information from the 2009 survey responses was used to determine an average 

number of affected facilities that would become subject to subpart DDa requirements. For 

scenario 11, a percentage of the grain elevators in the scenario were assumed to be subject to the 

subpart DDa requirements for each affected facility. The percentages were based on reviewing 

the 2009 survey responses and sorting the number of affected facilities that were indicated to be 

subject to the NSPS from highest to lowest, information provided by industry representatives, 

and an evaluation of the likelihood that the affected facility would be modified or reconstructed 

based on potential changes at grain elevators. Table 2-3 summarizes the number of affected 

facilities per grain elevator for each scenario. Table 2-4 summarizes the total number of affected 

facilities for each scenario resulting from multiplying the number of affected facilities per grain 

elevator for each scenario by the number of grain elevators projected in each scenario.

3.0 Estimation of Cost and Environmental Impacts

Cost Impacts

The only scenarios that would require installation of equipment resulting in capital costs 

are those that added TSF capacity—Scenarios 6b, 7, and 10. The installed equipment would be 

addition of a three-sided shed for truck unloading operations, fabric filters for dust control and to 

meet the PM limits, and screens for dryers to meet limits, as applicable. Costs were estimated 

using information collected from vendors of dust collectors/fabric filters, dryer screens provided 

for dryers at facility storing rice, and shed costs calculated using EPA’s Air Compliance Advisor 

(ACA) calculation tool (see attachment C for cost information on sheds, dryer screens, and fabric 

filters/dust collectors). Costs were escalated to a 2012 basis. 

For scenario 6b, two 3-sided sheds were costed for one greenfield facility assuming two 

truck unloading stations. For scenario 7, five 3-sided sheds were costed for one additional truck 

unloading affected source for each of the five years based on calculations discussed in section 

2.0. For scenario 10, 10 3-sided sheds were costed (i.e., 2 sheds each for the five-year period)

based on calculations discussed in section 2.0.

Only scenario 6b was assumed to require the addition of screens on dryers as it is a 

completely new grain elevator that would not already have dryers or screens in place and would 

be the only scenario where the dryer would be an affected facility. The dryer is assumed to be 
5

used for any grain. Costs are based on information provided for a rice dryer and may overstate 

costs for screens used on non-rice dryers. Only scenario 6b was assumed to require additional 

fabric filters/dust collectors installed. The cost calculation assumes that the grain elevator will 

already use fabric filters/dust collectors for dust suppression, but may require an additional three

fabric filters/dust collectors to reduce dust/PM from affected facilities complying with subpart 

DDa. Existing fabric filters in the other scenarios were assumed to be able to handle any new 

affected sources that would require PM control. 

The only incremental annual cost for subpart DDa would be for initial PM testing at 

affected facilities, annual opacity testing at affected facilities, weekly visual inspection of 

affected facilities, inspection of fabric filters/dust collectors for affected facilities every six 

months, and annual direct costs (i.e., operating costs) and indirect costs associated with controls 

added due to subpart DDa requirements. PM and Method 9 opacity testing costs are based on 

previous EPA rulemakings and scaled up to 2012 dollars.7,8 The cost of visual and fabric 

filter/dust collector inspections are based on the proposed subpart DDa requirements, current 

labor rates5

, and estimated time to conduct inspection activities. Direct costs include 

maintenance, dust disposal (resulting from new dust collectors), and utility costs (e.g., electricity 

costs to operate the controls), and were calculated using procedures and defaults in the OAQPS 

Control Cost Manual (OCCM)9 and other rulemakings7,8. Indirect costs include property taxes, 

administrative charges, insurance and capital recovery. Property taxes, administrative charges, 

and insurance were calculated based on the capital costs and cost factors provided in the OCCM. 

Capital recovery costs were estimated assuming seven percent interest rate over the life of the 

equipment. Sheds were assumed to have a 20 year life, while a 15 year life was used for both 

fabric filters/dust collectors and dryer screens based on information collected. Appendix A 

presents a more detailed summary of the cost inputs and calculations for each scenario and for 

each cost element. The cost information for sheds, dryer screens, and fabric filters/dust collectors 

are provided in Attachment C. 

Table 3-1 summarizes the cumulative total capital costs, total annual costs, and PM10 

emission reductions estimated for each scenario, five years after proposal of the subpart DDa 

rule. Table 3-2 summarizes the cumulative capital cost impacts calculated for each scenario 

based on these requirements for each of the five years following proposal of the subpart DDa 

rule. Table 3-3 summarizes the cumulative total annual cost impacts calculated for each scenario 

based on the requirements for each of the five years following proposal of the subpart DDa rule. 

The total increase in nationwide capital and annual costs is estimated to be $1.09 million and 

$1.12 million for the number of affected facilities that are projected to be constructed, 

reconstructed, or modified by the fifth year, respectively, following promulgation of subpart 

DDa. 

Emission Reductions

Incremental emission reductions are estimated for complying with subpart DDa due to 

emissions being controlled with fabric filters and screens on dryers associated with TSFs at 

affected sources – scenarios 6b, 7, and 10. Fabric filters were assumed to reduce PM emissions 

by 99 percent and dryer screens were assumed to reduce emissions by 84 percent based on EPA 

studies10. Table 3-3 summarizes the PM10 emission reductions for each scenario based on model 

grain elevators and affected facilities. Appendix B presents the detailed emission reductions 

calculations. For the emissions reductions analyses, a model grain elevator with 2 million 

bushels in permanent storage and an additional 2 million bushels in temporary storage was used.
6

This model would represent the combination of maximum permanent storage and temporary 

storage capacities that exceed the applicability cut-off and would trigger control requirements. 

The percent of grain throughput used in the calculations was based on the grain elevator survey 

responses, and the uncontrolled emission factors are from previous EPA studies8

. Emission 

reductions were calculated from truck unloading and grain handling affected sources only for 

scenarios 7 and 10, and multiplied by the number of affected sources in each year. For scenario 

6b, a greenfield facility, emission reductions from applying screens on the dryers were also 

added to the truck unloading and grain handling emission reductions. No emission reductions 

were estimated for compliance with opacity limits. 

Other Impacts

No indirect or secondary incremental air quality impacts associated with subpart DDa

requirements are anticipated. No additional control technologies or operating standards are 

necessary to comply with the new proposed standards for barge unloading stations and wire 

mesh dryers. Additional solid waste impacts due to controlling PM emissions from grain sent to 

TSFs were estimated. The impacts were calculated by multiplying PM10 emission reductions by 

a factor of three. (i.e, EPA emission factor documents10 have assumed that PM10 emissions 

comprise one-third of total PM emissions). The result is total PM emissions reductions, and 

consequently solid waste of 114 tons per year. Energy impacts are estimated to be negligible 

from add-on controls.

4.0 References

1. Evaluation of the Revisions to Grain Elevator Emission Standards. Memorandum from ERG 

to Bill Schrock, U.S. Environmental Protection Agency. December 2013. Docket ID Number 

EPA-HQ-OAR-2010-0706.

2. Database of Grain Elevator Survey Responses. Docket ID Number EPA-HQ-OAR-2010-

0706.

3. Database of Grain Elevators from Airs Facility System. Docket ID Number EPA-HQ-OAR2010-0706.

4. Collection of Grain Elevator Industry White Papers and Presentations. Docket ID Number 

EPA-HQ-OAR-2010-0706.

5. Burden Estimate and Supporting Statement for Proposed Subpart DDa. Docket ID Number 

EPA-HQ-OAR-2010-0706.

6. Evaluation of the Grain Elevator Emission Standards In Response to Executive Order 13563. 

Memorandum from ERG to Bill Schrock, U.S. Environmental Protection Agency. December

2013. Docket ID Number EPA-HQ-OAR-2010-0706.

7. Revised (November 2011) Methodology for Estimating Control Costs for Industrial, 

Commercial, Institutional Boilers and Process Heaters National Emission Standards for 

Hazardous Air Pollutants – Major Source. Memorandum from Eastern Research Group to 
7

Brian Shrager, U.S. Environmental Protection Agency, OAQPS. November 2011. Docket ID 

Number EPA-HQ-OAR-2002-0058-3384.

8. Final Reconsideration Compliance Cost Analyses for CISWI Units. Memorandum from 

Eastern Research Group to U.S. Environmental Protection Agency. November 26, 2012. 

EPA-HQ-OAR-2003-0119-2692.

9. OAQPS Control Cost Manual. Fifth Edition. U.S. Environmental Protection Agency, Office 

of Air Quality Planning and Standards. EPA 453/B-96-001, Research Triangle Park, NC. 

February, 1996.

10. Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area 

Sources. U.S. Environmental Protection Agency. Fifth Edition. January 1995. 

http://www.epa.gov/ttnchie1/ap42/
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Table 2-1. Summary of Impacts Analysis Scenarios

Scenario Description

1 Greenfield grain elevator w/ capacity <DDa applicability cutoffs

2 Existing grain elevator w/ capacity <DDa applicability cutoffs, and does 

modification or reconstruction

3 Existing grain elevator w/ capacity <DDa applicability cutoffs, and adds 

capacity but is still <DD cutoffs

4 Existing grain elevator w/ capacity >DDa applicability cutoffs, but no changes 

occur

5 Existing grain elevator w/ capacity >DDa applicability cutoffs, but then adds 

permanent storage capacity or TSF capacity that does not increase hourly grain 

handling capacity

6a Greenfield grain elevator w/ capacity >DDa applicability cutoffs due only to 

permanent storage

6b Greenfield grain elevator w/ capacity >DDa applicability cutoffs due to adding 

TSF capacity

7 Existing grain elevator w/ capacity <DDa applicability cutoffs, but then adds 

TSF capacity and exceeds cutoffs

8 Existing grain elevator w/ capacity <DDa applicability cutoffs, but then adds 

permanent storage capacity and exceeds cutoffs

9 Existing grain elevator w/ capacity >DDa applicability cutoffs, but then adds 

permanent storage capacity 

10 Existing grain elevator w/ capacity >DDa applicability cutoffs, but then adds 

TSF capacity

11 Existing grain elevator w/ capacity >DDa applicability cutoffs, and does 

modification or reconstruction
9

Table 2-2. Projected Number of Grain Elevators For Each Scenario In Each Year

Scenario Description Year 1 Year 2 Year 3 Year 4 Year 5 Total

6a

Greenfield GE w/capacity 

> DDa cutoffs due only to 

permanent storage 

capacity 1 1 2

6b

Greenfield GE w/capacity 

> DDa cutoffs due to 

adding TSF capacity

1 1

72

Existing GE w/ capacity 

<DDa cutoffs, but then 

adds TSF capacity and 

exceeds cutoffs 1 1 1 1 1 5

83

Existing GE w/ capacity 

<DDa cutoffs, but then 

adds permanent storage 

capacity and exceeds

cutoffs 1 1 1 1 1 5

94

Existing GE w/ capacity 

>DDa cutoffs, but then 

adds permanent storage 

capacity 2 2 2 2 2 10

105

Existing GE w/ capacity 

>DDa cutoffs, but then 

adds TSF capacity 2 2 2 2 2 10

116

Existing GE w/ capacity

>DDa cutoffs, and does 

modification or 

reconstruction 18 18 18 18 18 90 1Based on the number of elevators that had been identified to be constructed in the past five years, i.e., 3, and apportioning one-third to TSFs and tw-thirdds due to 

permanent storage only based on 2009 survey responses.

2 Calculated from 2009 survey responses showing 4 out of 121 grain elevators over 24 years in scenario 7. Extrapolated nationally using AFS database count resulting in 

approximately 0.5 grain elevators per year. This number was rounded to the nearest whole number, i.e., 1. 3 Calculated from 2009 survey responses showing 14 out of 121 grain elevators over 30 years in scenario 8. Extrapolated nationally using AFS database count resulting in

approximately 1.3 grain elevators per year. This number was rounded to the nearest whole number, i.e., 1. 4 Calculated from 2009 survey responses showing 17 out of 121 grain elevators over 30 years in scenario 9. Extrapolated nationally using AFS database count resulting in 

approximately 1.51 grain elevators per year. This number was rounded to the nearest whole number, i.e., 2. 5 Calculated from 2009 survey responses showing 13 out of 121 grain elevators over 24 years in scenario 10. Extrapolated nationally using AFS database count resulting in 

approximately 1.56 grain elevators per year. This number was rounded to the nearest whole number, i.e., 2. 6 Assumed that at least 5 percent of the population of grain elevators would be modified or reconstructed each year. 
10

Table 2-3. Number of Affected Facilities per Grain Elevator in Each Scenario

Affected Facilty Subcategory

Scenarios 

% of GE with 

Modifications 

to Affected 

Facilities 

6a and 6b1 72 82 92 102 113

Greenfield 

GE w/

capacity > 

DDa

cutoffs

Existing GE w/

capacity <DDa

cutoffs, but

then adds TSF 

capacity and 

exceeds

cutoffs

Existing GE w/

capacity <DDa

cutoffs, but

then adds 

permanent 

storage capacity 

and exceeds

cutoffs

Existing GE 

w/ capacity 

>DDa

cutoffs, but

then adds 

permanent 

storage 

capacity 

Existing GE w/

capacity >DDa

cutoffs, but

then adds TSF 

capacity

Existing GE w/

capacity >DDa

cutoffs, and 

does 

modification or 

reconstruction

Grain Handling 4 1 1 1 1 25%

Dryer

Rice Column 0 0 0 0 0 10%

Rack 1.5 0 0 0 0 15%

Truck Unloading 2 1 1 1 1 15%

Truck Loading 1.5 1 1 1 1 10%

Barge/Ship 

Unloading

En-masse 0 0 0 0 0 2%

Marine Leg 0 0 0 0 0 5%

Barge/Ship Loading 0 0 0 0 0 5%

Railcar Unloading

1 0 0 0 0 10%

Railcar Loading

1 0 0 0 0 15%

1

Information from the 2009 survey responses was used to determine an average number of affected facilities that would become subject to 

subpart DDa requirements. 2

Estimated based on assuming that addition of TSF or permanent storage capacity would result in grain handling, one truck unloading 

station, and one truck loading station at each grain elevator becoming subject to subpart DDa requirements. 

3

Percentages are based on reviewing the 2009 survey responses and sorting the number of affected facilities that were indicated to be 

subject to the NSPS from highest to lowest, information provided by industry representatives, and an evaluation of the likelihood that the

affected facility would be modified or reconstructed based on potential changes at grain elevators. 
11

Table 2-4. Total Number of Affected Facilities Projected For Each Scenario and Year

Scenario Year 1 Year 2 Year 3 Year 4 Year 5 Total

6a 11 0 0 11 0 22

6b 0 0 11 0 0 11

7 3 3 3 3 3 15

8 3 3 3 3 3 15

9 6 6 6 6 6 30

10 6 6 6 6 6 30

11 20 20 20 20 20 100a

Total 49 38 49 49 38 223a

a Number reflects rounding.
12

Table 3-1. Summary of Cumulative Costs and Emission Reductions for Projected Grain Elevators In Each Scenario Subject to Proposed 

Subpart DDa Requirements (that are different than subpart DD requirements) In the Fifth Year Following Proposal 

Scenario Description

Capital Cost ($) Annual Costs ($/yr) PM10 

Emission 

Reduction 

(tons/year)

3-sided 

shed

Dryer Fabric 

filter

Total PM testing 

(initial/eve

ry 5 years)

Semi 

annual FF 

inspection

Annual 

Opacity Test 

(Method 5

Weekly 

Visual 

Inspection

Annualized 

3-sided shed

Annualized 

Dryer 

Screens

Annualized 

Fabric 

Filter

Total

6A Greenfield GE 

w/capacity > 

DDa cutoffs due 

only to 

permanent 

storage capacity

NA1 NA NA NA NA 414 55,879 9,867 NA NA NA 66,160 0

6B Greenfield GE 

w/capacity > 

DDa cutoffs due 

to adding TSF 

capacity

66,400 370,000 153,000 589,400 36,576 207 27,940 4,934 24,773 78,986 60,531 233,946 17

7 Existing GE w/ 

capacity <DDa 

cutoffs, but then 

adds TSF 

capacity and 

exceeds cutoffs

166,000 NA NA 166,000 60,959 345 38,100 6,728 61,931 NA NA 168,063 6.9

8 Existing GE w/

capacity <DDa 

cutoffs, but then 

adds permanent 

storage capacity 

and exceeds 

cutoffs

NA NA NA NA NA 345 38,100 6,728 NA NA NA 45,172 0

9 Existing GE w/ 

capacity >DDa 

cutoffs, but then 

adds permanent 

storage capacity 

NA NA NA NA NA 690 76,199 13,455 NA NA NA 90,344 0

10 Existing GE w/ 

capacity >DDa 

cutoffs, but then 

adds TSF 

capacity

332,000 NA NA 332,000 NA 690 76,199 13,455 123,863 NA NA 214,207 6.9

11 Existing GE w/ 

capacity >DDa 

cutoffs, and does 

modification or 

reconstruction

NA NA NA NA NA 5,253 248,917 43,953 NA NA NA 298,123 0

Total 564,400 370,000 153,000 1,087,400 97,535 7,944 561,334 99,119 210,567 78,986 60,531 1,116,015 31 1

NA = Not applicable based on cost and emission reductions assumptions.
13

Table 3-2. Total Capital Costs, Cumulative for Each Year for Projected Grain Elevators In Each 

Scenario Subject to Proposed Subpart DDa Requirements (that are different than subpart DD 

requirements)

Scenario Description

Cumulative Costs For Each Year ($/yr)1

Year 1 Year 2 Year 3 Year 4 Year 5

6a

Greenfield GE 

w/capacity > DDa 

cutoffs due only 

to permanent 

storage capacity - 

 

- 

 

- 

 

- 

 

- 

6b

Greenfield GE 

w/capacity > DDa

cutoffs due to 

adding TSF 

capacity - 

 

- 

 

589,400 

 

589,400 

 

589,400 

7

Existing GE w/

capacity <DDa

cutoffs, but then 

adds TSF capacity 

and exceeds

cutoffs

 

33,200 

 

66,400 

 

99,600 

 

132,800 

 

166,000 

8

Existing GE w/

capacity <DDa

cutoffs, but then 

adds permanent 

storage capacity 

and exceeds

cutoffs - 

 

- 

 

- 

 

- 

 

- 

9

Existing GE w/

capacity >DDa

cutoffs, but then 

adds permanent 

storage capacity - 

 

- 

 

- 

 

- 

 

- 

10

Existing GE w/

capacity >DDa

cutoffs, but then 

adds TSF capacity

 

66,400 

 

132,800 

 

199,200 

 

265,600 

 

332,000 

11

Existing GE w/

capacity >DDa

cutoffs, and does 

modification or 

reconstruction - 

 

- 

 

- 

 

- 

 

- 

Total 

99,600 

 

199,200 

 

888,200 

 

987,800 

 

1,087,400 

1 Costs were calculated for dryer screens, sheds during unloading, and fabric filters for PM control.
14

Table 3-3. Total Annual Costs, Cumulative for Each Year for Projected Grain Elevators In Each 

Scenario Subject to Proposed Subpart DDa Requirements (that are different than subpart DD 

requirements)

Scenario Description

Cumulative Costs For Each Year ($/yr)1

Year 1 Year 2 Year 3 Year 4 Year 5

6a

Greenfield GE 

w/capacity > DDa 

cutoffs due only 

to permanent 

storage capacity

 

149,351 

 

149,351 

 

298,703 

 

448,054 

 

448,054 

6b

Greenfield GE 

w/capacity > DDa

cutoffs due to 

adding TSF 

capacity

 

33,080 

 

33,080 

 

33,080 

 

66,160 

 

66,160 

7

Existing GE w/

capacity <DDa

cutoffs, but then 

adds TSF capacity 

and exceeds

cutoffs

 

- 

 

- 

 

233,946 

 

233,946 

 

233,946 

8

Existing GE w/

capacity <DDa

cutoffs, but then 

adds permanent 

storage capacity 

and exceeds

cutoffs

 

33,613 

 

67,225 

 

100,838 

 

134,450 

 

168,063 

9

Existing GE w/

capacity >DDa

cutoffs, but then 

adds permanent 

storage capacity 

 

9,034 

 

18,069 

 

27,103 

 

36,138 

 

45,172 

10

Existing GE w/

capacity >DDa

cutoffs, but then 

adds TSF capacity

 

18,069 

 

36,138 

 

54,206 

 

72,275 

 

90,344 

11

Existing GE w/

capacity >DDa

cutoffs, and does 

modification or 

reconstruction

 

42,841 

 

85,683 

 

128,524 

 

171,366 

 

214,207 

Total 

196,262 

 

359,444 

 

756,571 

 

952,833 

 

1,116,015 

1 Costs were calculated for PM testing, opacity testing, baghouse inspection, and visual monitoring, and annualized costs from 

dryer screens, sheds, and fabric filters.
A-1

Appendix A. Detailed Cost Calculations

Table A-1. Cumulative Cost For Each Year, For Each Scenario – Fabric Filer/Dust Collector

Inspection Annual Costs

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE w/capacity > DD 

cutoffs due only to permanent 

storage

 

207 

 

207 

 

207 

 

414 

 

414 

6B

Greenfield GE w/capacity > DD 

cutoffs due to adding TSF 

capacity 

- 

 

- 

 

207 

 

207 

 

207 

7

Existing GE w/ capacity <DDa 

cutoffs, but then adds TSF 

capacity and exceeds cutoffs 

69 

 

138 

 

207 

 

276 

 

345 

8

Existing GE w/ capacity <DDa 

cutoffs, but then adds 

permanent storage capacity 

and exceeds cutoffs 

69 

 

138 

 

207 

 

276 

 

345 

9

Existing GE w/ capacity >DDa 

cutoffs, but then adds 

permanent storage capacity 

138 

 

276 

 

414 

 

552 

 

690 

10

Existing GE w/ capacity >DDa 

cutoffs, but then adds TSF 

capacity

 

138 

 

276 

 

414 

 

552 

 

690 

11

Existing GE w/ capacity >DDa 

cutoffs, and does modification 

or reconstruction 

1,051 

 

2,101 

 

3,152 

 

4,202 

 

5,253 

Total 

1,672 

 

3,136 

 

4,808 

 

6,479 

 

7,944 

FF/dust collector inspection cost per affected 

facility $ 69 Based on:

Labor costs ($/hr) $34 From ICR supporting statement, technical labor

# times a year 2 From subpart DDa proposal

# hrs per affected facility 1 Based on estimated time for inspection
A-2

Table A-2. Cumulative Cost For Each Year, For Each Scenario - Method 9 Opacity Annual Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage

 

27,940 

 

27,940 

 

27,940 

 

55,879 

 

55,879 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to adding 

TSF capacity

 

- - 

 

27,940 

 

27,940 

 

27,940 

7

Existing GE w/ 

capacity <DDa 

cutoffs, but then adds 

TSF capacity and 

exceeds cutoffs

 

7,620 

 

15,240 

 

22,860 

 

30,480 

 

38,100 

8

Existing GE w/ 

capacity <DDa 

cutoffs, but then adds 

permanent storage 

capacity and exceeds 

cutoffs

 

7,620 

 

15,240 

 

22,860 

 

30,480 

 

38,100 

9

Existing GE w/ 

capacity >DDa 

cutoffs, but then adds 

permanent storage 

capacity 

 

15,240 

 

30,480 

 

45,719 

 

60,959 

 

76,199 

10

Existing GE w/ 

capacity >DDa 

cutoffs, but then adds 

TSF capacity

 

15,240 

 

30,480 

 

45,719 

 

60,959 

 

76,199 

11

Existing GE w/ 

capacity >DDa 

cutoffs, and does 

modification or 

reconstruction

 

49,783 

 

99,567 

 

149,350 

 

199,134 

 

248,917 

Total 

123,443 

 

218,946 

 

342,388 

 

465,831 

 

561,334 

Method 9 Cost $ 2,540 From CISWI 1, and escalated to 2012 $ from 2008$

2008 Method 9 Cost $2,500 From CISWI 1

Escalation Ratio 584.6/575.4 Escalated from 2008 $ to 2012 $

1

"Final Reconsideration Compliance Cost Analyses for CISWI Units", November 26, 2012. 

EPA-HQ-OAR-2003-0119-2692.
A-3

Table A-3. Cumulative Cost For Each Year, For Each Scenario -PM Testing Cost

Scenario Description Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6a

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage - - - - - 

6b

Greenfield GE 

w/capacity > DD 

cutoffs due to 

adding TSF 

capacity - - 36,576 36,576 36,576 

7

Existing GE 

w/capacity < DD 

cutoffs, but then 

adds TSF capacity 

and exceed cutoffs 12,192 24,384 36,576 48,767 60,959 

8

Existing GE 

w/capacity <DD 

cutoffs, but then 

adds permanent 

storage capacity 

and exceed cutoffs - - - - - 

9

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds permanent 

storage capacity - - - - - 

10

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds TSF capacity - - - - - 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction - - - - - 

Total 12,192 24,384 73,151 85,343 97,535 

Method 5 PM testing $ 12,192 From CISWI 1, and escalated to 2012 $ from 2008$

2008 Method 9 Cost $12,000 From CISWI 1

Escalation Ratio 584.6/575.4 Escalated from 2008 $ to 2012 $

1

"Final Reconsideration Compliance Cost Analyses for CISWI Units", November 26, 2012. 

EPA-HQ-OAR-2003-0119-2692.
A-4

Table A-4. Cumulative Cost For Each Year, For Each Scenario - Weekly Visual 

Monitoring

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6a

Greenfield GE w/capacity > DD 

cutoffs due only to permanent 

storage

 

4,934 

 

4,934 4,934 

 

9,867 

 

9,867 

6b

Greenfield GE w/capacity > DD 

cutoffs due to adding TSF 

capacity

 

- 

 

- 4,934 

 

4,934 

 

4,934 

7

Existing GE w/ capacity <DDa 

cutoffs, but then adds TSF 

capacity and exceeds cutoffs 

1,346 

 

2,691 4,037 

 

5,382 

 

6,728 

8

Existing GE w/ capacity <DDa 

cutoffs, but then adds 

permanent storage capacity 

and exceeds cutoffs 

1,346 

 

2,691 4,037 

 

5,382 

 

6,728 

9

Existing GE w/ capacity >DDa 

cutoffs, but then adds 

permanent storage capacity 

2,691 

 

5,382 8,073 

 

10,764 

 

13,455 

10

Existing GE w/ capacity >DDa 

cutoffs, but then adds TSF 

capacity 

2,691 

 

5,382 8,073 

 

10,764 

 

13,455 

11

Existing GE w/ capacity >DDa 

cutoffs, and does modification 

or reconstruction 

8,791 

 

17,581 26,372 

 

35,162 

 

43,953 

Total 

21,797 

 

38,661 60,458 

 

82,255 

 

99,119 

Visual monitoring cost per 

affected facility $ 449 

Labor costs ($/hr) 34.5 From ICR supporting statement, technical labor

# times a year 52 From subpart DDa proposal

# hrs per affected facility 0.25 Based on estimated time for inspection
A-5

Table A-5. Cumulative Cost For Each Year, For Each Scenario -3-sided Shed Capital 

Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage

 - - 

 

- 

 

- 

 

- 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to adding 

TSF capacity - - 

 

66,400 

 

66,400 

 

66,400 

7

Existing GE w/capacity 

< DD cutoffs, but then 

adds TSF capacity and 

exceed cutoffs

 33,200 

 

66,400 

 

99,600 

 

132,800 

 

166,000 

8

Existing GE w/capacity 

<DD cutoffs, but then 

adds permanent 

storage capacity and 

exceed cutoffs - - 

 

- 

 

- 

 

- 

9

Existing GE w/capacity 

>DD cutoffs, but then 

adds permanent 

storage capacity - - 

 

- 

 

- 

 

- 

10

Existing GE w/capacity 

>DD cutoffs, but then 

adds TSF capacity

 66,400 

 

132,800 

 

199,200 

 

265,600 

 

332,000 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction - - 

 

- 

 

- 

 

- 

Total 99,600 

 

199,200 

 

365,200 

 

464,800 

 

564,400 

3-sided shed Capital Cost $ 33,200 Calculatd using EPA's ACA tool, see Attachment C

Capital Cost ($/sqft) 83 From ACA, see attachment C

Shed area (sq ft) 400 See attachment C
A-6

Table A-6. Cumulative Cost For Each Year, For Each Scenario -3-sided Shed 

Annualized Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage 

- - 

 

- 

 

- 

 

- 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to adding

TSF capacity 

- - 

 

24,773 

 

24,773 

 

24,773 

7

Existing GE w/capacity 

< DD cutoffs, but then 

adds TSF capacity and 

exceed cutoffs 

12,386 24,773 

 

37,159 

 

49,545 

 

61,931 

8

Existing GE w/capacity 

<DD cutoffs, but then 

adds permanent 

storage capacity and 

exceed cutoffs

 

- - 

 

- 

 

- 

 

- 

9

Existing GE w/capacity 

>DD cutoffs, but then 

adds permanent 

storage capacity 

- - 

 

- 

 

- 

 

- 

10

Existing GE w/capacity 

>DD cutoffs, but then 

adds TSF capacity 

24,773 49,545 

 

74,318 

 

99,090 

 

123,863 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction

 

- - 

 

- 

 

- 

 

- 

Total 

37,159 74,318 

 

136,249 

 

173,408 

 

210,567 
A-7

Annual Cost = Direct + Indirect Costs

Annual Cost = $12,386.29 Per shed, calculated from

Direct costs = maintenance materials and maintenance labor

Direct costs = $ 3,398 Calculated from:

Maintenance labor = $1,699 Based on:

Performed: 12 time a year, taking

Hours: 4 hours an event, at a rate of

labor cost: 35.4 $/hr

Maintenance materials = $1,699 Based on OAQPS Cost Manual

Indirect Costs = overhead, administrative, property tax, insurance, capital recovery

Indirect Costs = $ 8,987.89 

Admin, tax, ins.= $ 3,815 From EPA's ACA tool, see attachment C

Overhead= $ 2,039.04 60% of maintenance costs, from OCCM

Capital Recovery= $ 3,133.85 Calculated by multiplying shed costs and CRF

CRF: 0.0943929 Calculated from:

Interest rate: 7%

Lifetime: 20 years
A-8

Table A-7. Cumulative Cost For Each Year, For Each Scenario -Dryer Screen Capital Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD cutoffs 

due only to permanent 

storage

 - 

 

- - - - 

6B

Greenfield GE 

w/capacity > DD cutoffs 

due to adding TSF 

capacity

 - 

 

- 370,000 370,000 370,000 

7

Existing GE w/capacity 

< DD cutoffs, but then 

adds TSF capacity and 

exceed cutoffs

 - 

 

- - - - 

8

Existing GE w/capacity 

<DD cutoffs, but then 

adds permanent 

storage capacity and 

exceed cutoffs

 - 

 

- - - - 

9

Existing GE w/capacity 

>DD cutoffs, but then 

adds permanent 

storage capacity - 

 

- - - - 

10

Existing GE w/capacity 

>DD cutoffs, but then 

adds TSF capacity - 

 

- - - - 

11

Existing GE w/capacity> 

DD cutoffs, and does 

modification or 

reconstruction

 - 

 

- - - - 

Total - 

 

- 370,000 370,000 370,000 

Capital Cost $ 370,000.00 

Response from Rice Manufacturer for rice screens, 

attachment C

Estimate assumes 1 dryer to be fitted with screens.
A-9

Table A-8. Cumulative Cost For Each Year, For Each Scenario -Dryer Screen 

Annualized Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage

 

- - 

 

- 

 

- 

 

- 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to

adding TSF capacity

 

- - 

 

78,986 

 

78,986 

 

78,986 

7

Existing GE 

w/capacity < DD 

cutoffs, but then 

adds TSF capacity 

and exceed cutoffs

 

- - 

 

- 

 

- 

 

- 

8

Existing GE 

w/capacity <DD 

cutoffs, but then 

adds permanent 

storage capacity 

and exceed cutoffs

 

- - 

 

- 

 

- 

 

- 

9

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds permanent 

storage capacity 

 

- - 

 

- 

 

- 

 

- 

10

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds TSF capacity 

- - 

 

- 

 

- 

 

- 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction

 

- - 

 

- 

 

- 

 

- 

Total 

- - 

 

78,986 

 

78,986 

 

78,986 
A-10

Annual Cost = Direct + Indirect Costs

Annual Cost = $78,986 Per shed, calculated from

Direct costs = maintenance materials and maintenance labor

Direct costs = $ 14,726 Calculated from:

Maintenance labor = $7,363 Based on:

Performed: 52 time a year, taking

Hours: 4 hours an event, at a rate of

labor cost: 35.4 $/hr

Maint. materials = $7,363 Based on OAQPS Cost Manual

Indirect Costs = overhead, administrative, property tax, insurance, capital recovery

Indirect Costs = $ 64,260 Calculated from:

Admin, tax, ins. = $ 14,800 4% of capital cost, from OCCM

Overhead = $ 8,836 60% of maintenance costs, from OCCM

Capital Recovery = $ 40,624 Calculated by multiplying screen costs and CRF

CRF: 0.109795 Calculated from:

Interest rate: 7%

Lifetime: 15 Years, based on attachment C
A-11

Table A-9. Cumulative Cost For Each Year, For Each Scenario -FF Capital Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage - 

 

- 

 

- 

 

- 

 

- 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to adding 

TSF capacity - 

 

- 

 

150,000 

 

150,000 

 

150,000 

7

Existing GE w/capacity 

< DD cutoffs, but then 

adds TSF capacity and 

exceed cutoffs

 - 

 

- 

 

- 

 

- 

 

- 

8

Existing GE w/capacity 

<DD cutoffs, but then 

adds permanent 

storage capacity and 

exceed cutoffs - 

 

- 

 

- 

 

- 

 

- 

9

Existing GE w/capacity 

>DD cutoffs, but then 

adds permanent 

storage capacity - 

 

- 

 

- 

 

- 

 

- 

10

Existing GE w/capacity 

>DD cutoffs, but then 

adds TSF capacity

 - 

 

- 

 

- 

 

- 

 

- 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction - 

 

- 

 

- 

 

- 

 

- 

Total - 

 

- 

 

150,000 

 

150,000 

 

150,000 

Capital Cost $ 51,000 Per dust collector/fabric filter from vendor quote, attachment C.

Capital cost estimated assuming 3 dust collectors that would not have been added

for dust control but would be to meet additional DDa requirements
A-12

Table A-10. Cumulative Cost For Each Year, For Each Scenario -FF Annualized 

Cost

Scenario Description

Cumulative Costs For Each Year

Year 1 Year 2 Year 3 Year 4 Year 5

6A

Greenfield GE 

w/capacity > DD 

cutoffs due only to 

permanent storage 

- 

 

- - 

 

- 

 

- 

6B

Greenfield GE 

w/capacity > DD 

cutoffs due to 

adding TSF capacity

 

- 

 

- 

 

60,531 

 

60,531 

 

60,531 

7

Existing GE 

w/capacity < DD 

cutoffs, but then 

adds TSF capacity 

and exceed cutoffs

 

- 

 

- - 

 

- 

 

- 

8

Existing GE 

w/capacity <DD 

cutoffs, but then 

adds permanent 

storage capacity 

and exceed cutoffs

 

- 

 

- - 

 

- 

 

- 

9

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds permanent 

storage capacity 

 

- 

 

- - 

 

- 

 

- 

10

Existing GE 

w/capacity >DD 

cutoffs, but then 

adds TSF capacity 

- 

 

- - 

 

- 

 

- 

11

Existing GE 

w/capacity> DD 

cutoffs, and does 

modification or 

reconstruction

 

- 

 

- - 

 

- 

 

- 

Total 

- 

 

- 

 

60,531 

 

60,531 

 

60,531 
A-13

Annual Cost = Direct + Indirect Costs

Annual Cost = $20,177 Per FF/dust collector, calculated from

Direct costs = maintenance materials and maintenance labor, electricity, dust disposal

Direct costs = $ 10,498 Calculated from:

Maintenance labor = $1,699 Based on:

Performed: 12 time a year, taking

Hours: 4 hours an event, at a rate of

labor cost: 35.4 $/hr

Maintenance materials = $1,699 Based on OAQPS Cost Manual

 Electricity for fan = $5,000 Based on OAQPS Cost Manual

 Dust Disposal = $2,100 Based on $42.14/ton from Boiler NESHAP

 and ratio of 3:1 Total PM to PM10

Indirect Costs = overhead, administrative, property tax, insurance, capital recovery

Indirect Costs = $ 9,679

Admin, tax, ins. = $ 2,040 4% of capital cost, from OCCM

Overhead = $ 2,039 60% of maintenance costs, from OCCM

Capital Recovery = $ 5,600 Calculated by multiplying screen costs and CRF

CRF: 0.109795 Calculated from:

Interest rate: 7%

Lifetime: 15 Years, based on attachment C
B-1

Table B-1. Calculation of Emission Reductions for a Model Grain Elevator

Permanent Capacity 2,000,000 Grain density: 54 lb/bushel

Temporary Capacity 2,000,000

Permanent Turnovers: 3.61

Throughput based on turnovers: 7,220,000 

% of 114 pop with turnovers: 72%

Equivalency Ratio: 0.34

Temporary storage equivalents 680,000 

Total permanent storage capacity 2,680,000 

Temporary storage turnovers: 1

Uncontrolled Emissions:

Permanent Storage Temporary Storage

Affected Facility Type

% grain 

throughput

emission factor 

(lbPM10/ton grain) 

Uncontrolled 

emissions (ton 

PM10/year)

% grain 

throughput

emission factor 

(lbPM10/ton grain) 

Uncontrolled 

emissions (ton 

PM10/year)

Unloading Truck Straight 25% 0.059 1.4 25% 0.059 0.4

Hopper 25% 0.0078 0.2 75% 0.0078 0.2

Railcar 50% 0.0078 0.4 0% 0.0078 0.0

Loading Truck 50% 0.029 1.4 50% 0.029 0.4

Railcar 50% 0.0022 0.1 50% 0.0022 0.0

Grain handling 100% 0.034 3.3 100% 0.034 0.9

Dryer Rack 20% 0.75 14.6 20% 0.75 4.1

Dryer Rack 10% 0.75 7.3 10% 0.75 2.0

Dryer Rack 5% 0.75 3.7 5% 0.75 1.0

NSPS Controlled

Permanent Storage Temporary Storage

Affected Facility Type % capture % control

Controlled Emissions 

(tonsPM10/yr)

Emission 

Reductions (tons 

PM10/yr) % capture % control

Controlled 

Emissions 

(tonsPM10/yr)

Emission 

Reductions (tons 

PM10/yr)

Unloading Truck Straight 95% 99% 0.09 1.4 95% 99% 0.02 0.4

Hopper 95% 99% 0.01 0.2 95% 99% 0.01 0.1

Railcar 95% 99% 0.02 0.4 95% 99% 0.00 0.0

Loading Truck 95% 99% 0.08 1.3 95% 99% 0.02 0.4

Railcar 95% 99% 0.01 0.1 95% 99% 0.00 0.0

Grain handling 95% 99% 0.20 3.1 95% 99% 0.05 0.9

Dryer Rack 20% 100% 84% 2.34 12.3 100% 84% 0.65 3.4

Dryer Rack 10% 100% 84% 1.17 6.1 100% 84% 0.32 1.7

Dryer Rack 5% 100% 84% 0.58 3.1 100% 84% 0.16 0.9
Appendix C

Cost Input Information
C-1

From: Brown, Kerry" <K.Brown@schenckprocess.com

To: Gibson, Graham, Eastern Research Group

Date: 8/6/2013 3:57 PM

Subject: Dust Collection System

Graham,

I understand you are looking for some basic information on dust collection systems. A typical system includes a dust collector, fan, 

and airlock. I have attached GD drawings of each of these items. Budgetary numbers for a 10,000 CFM system are below, all 

carbon steel construction, NEMA 4 environment. 

HD12x10 airlock, $4,000

120LST144 dust collector, $34,000

Fan, $13,000

Thank you.

Kerry Brown

Aftermarket Sales Manager

Mac Process LLC

Phone: 800-821-2476 x 3441

Cell: 816-510-6975

Fax: 816-891-8336
C-2

Riceland – Request for Additional Information and Clarification 

08/28/2012 

Riceland Response

Cost Data 

For each type of control (enclosure, mesh control screen, Screen Airs, other?) can you provide: 

1. Capital cost of control equipment: All cost items necessary to design, purchase, and install the control 

system: 

a. Purchased cost of enclosure, screen and auxiliaries (e.g., hoods, fans, and any instrumentation); 

b. Equipment installation cost (e.g., foundations, piping, electrical, wiring, retrofitting, installation) 

c. Engineering, construction overhead, and contingencies. 

d. Year of cost data. 

2. Annualized cost to operate and maintain control equipment 

a. Life of equipment 

Cost Data - answers 

1. Capital cost of control equipment 

Enclosure costs: From 2012 Cost estimates 

It has been estimated that the cost of the enclosure adds about 33% to the cost of the dryer. Riceland 

plans to begin construction of a 10,000 bu/hr dryer this winter. The cost of the dryer is $1,130,000. The 

cost of the enclosure, screens, dust system and associated equipment is estimated at about $370,000. 

Bringing the total project costs to $1,500,000. 

Hull Chamber costs: From 2012 cost estimates 

Each hull chamber is made to fit the particular headhouse and dryer it serves. 

Riceland estimates that a typical hull chamber retrofit consisting of a headhouse having two grain dryers 

rated at 5,000 bu/hr each would cost around $440,000. 

Tech Air Screen Air costs: From 2007 

Riceland completed a Screen Air retrofit on one (1) dryer. The approximate cost for this retrofit in 2007 

dollars was $515,000. 

2. Annualized cost to operate and maintain control equipment 

Riceland has no detailed information regarding operating and maintenance costs for the grain dryer dust 

control systems it employs. However, each enclosure is made of 3’ x 10’ louvered panels with 24 mesh 

stainless steel screen on the inside of the panel. The approximate life of the 24 mesh screen is 15 years. 

Riceland rescreened a hull chamber enclosure comprised of 203 panels prior to the 2012 harvest. The 

installed cost of the rescreen was $200 per panel. 
C-3

Air Compliance Advisor (ACA)1 3-sided Shed Costing

Inputs for ACA:

size ft

width 8

length 45 Will hold an 18-wheeler, a 15-foot diameter tank, and 5 feet for a conveyor

height 20

sq ft 360

cubic 

feet 7,200

Outputs from ACA:

3-wall; concrete 

masonry units

Purchased Equipment Cost 3,123

Ratio; equip vs. direct installation 2

Total Capital Investment 2008$ 29,137

Total Annual Costs 3,815 Includes taxes, insurance, G&A

Adjusted Cost:

Total Capital Investment 2012$ 29,603

$ per square foot: 83

1 Program is found at: http://www.epa.gov/ttnecas1/ACA.htm