### 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 pr oposed 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 :

**•** A nnual opacity testing for affected facilities,

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

**•** W eekly visual inspection of affect ed facilities,

**•** I nspection of fabric filters and baghouses every six months for affected facilities

,

**•** N ew recordkeeping requirements,

**•** R eporting in EPA ’ s emissions reporting tool ( ERT )

,

**•** N ew opacity limit for wire mesh column dryers, and

**•** N ew 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 facil ities that commence

construction, modification, or reconstruction after the date s ubpart 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 co lumn 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. I nformation provided in the responses to the

2009 survey indicate that grain elevators are already keeping records that are propos e d 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 associate d 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 estimate 5 

### and are not presented in the memorandum.

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

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

subject to subpart DDa were identified

. T he cost and env ironmental 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 Faci lities

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

reconstructed, or modified, and are summarized in Table 2

- 1. Of these, scenarios 6 a and 6b

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

DD)

. The count of grain elevators in scenarios 7 through 1 0 that are projected to be subject to the

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

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 memorandum 6 

### , 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 informat ion

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

capacity and the subpart DD st or age capacity requirements. However, insufficient information is

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

verify that the grain elevators in the upper range are defini tively 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 coun t 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 scenari os 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 6 a, 6b and 11, other approaches were used, and are also explained below.

### 3 Scenario s 6 a and 6b

– New constructio n

T he 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 promulgat ion of subpart DDa, three

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

submitted by 121 grain elevators 2



### , 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 number s of grain elevators estimated for scenarios 7 through 1 0 were based on

responses to a 2009 CAA section 114 survey submitted by 121 grain elevators 2



### . 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 t he grain

elevator would be subject to the requirements of sub part 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 a pplicability 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 elevator s

would be subject to NSPS requirements

. The resulting estimate , extrapolated using the AFS

count, is approximat ely 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 o f 121 grain elevators in 30 years

, that would

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

, added

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

NSPS requirements . The re sulting 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 subje ct 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 1.5 6 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 w as available to make a projection of the number of grain

elevators that would be modified or reconstructed . For estimat ion 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 promulgati on of subpart DDa.

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

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

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

elevator becom ing subject to subpart DDa requirements. For scenario s 6 a and 6b (new

construction) , information from the 2009 survey responses w as 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 w ere assumed to be subject to the

subpart DDa requirements for each affe cted 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 ev aluation 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 to tal 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 Im pacts

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 operat i ons , 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 e ach of the five years based on calculations discussed in section

2.0

. F or 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 a ddition 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. O nly scenario 6b was assumed to require additional

fabric filters/dust collectors installed. The cost calculation assumes that the grain elevato r 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.

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

affected facilities, annual opacity testing at affected facilities, weekly visua l 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 rates 5 

### , and esti mated 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 rulemakings 7,8



### . 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 sce nario 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 es ti mated 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 e stimated 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

I ncremental e mission 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 emissi ons

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

studies 10



### . 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 combinati on 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 t he uncontrolled emission factors are from previous EPA studies 8



### . 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 sc enario

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 Impact s

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 stati ons and wire

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

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

a factor of three. (i.e, EPA emission factor documents 10 

### 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 Reference s

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

- OAR

2010

- 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

201 3

. 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 Ai r Pollutants

– Major Source. Memorandum from Eastern Research Group to

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

Number E PA

- HQ

- OAR

- 2002

- 0058

- 3384

.

8

. Final Reconsideration Complianc e Cost Analyses for CISWI Unit s. 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/

### 8 Table 2

- 1. Summary of Impacts Analysis Scenarios

Scenario Description

1 Greenfield grain elevator w/ capacity <DD a applicability cutoffs

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

modification or reconstruction

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

capacity but is still <DD cutoffs

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

occur

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

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

handling capacity

6 a Greenfield grain elevator w/ capacity >DD a a pplicability cutoffs due only to

permanent storage

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

TSF capacity

7 Existing grain elevator w/ capacity <DD a a pplicability cutoffs, but then adds

TSF capacity and exceed s cutoffs

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

permanent storage capacity and exceed s cutoffs

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

permanent storage capacity

10 Existi ng grain elevator w/ capacity >DD a applicability cutoffs, but then adds

TSF capacity

11 Existing grain elevator w/ capacity >DD a 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

6 a Greenfield GE w/capacity

> DD a cutoffs due only to

permanent storage

capacity 1 1 2

6b Greenfield GE w/capacity

> DD a cutoffs due to

adding TSF capacity

1 1

7 2 Existing GE w/ capacity

<DD a cutoffs, but then

adds TSF capacity and

exceed s cutoffs 1 1 1 1 1 5

8 3 Existing GE w/ capacity

<DD a cutoffs, but then

adds permanent storage

capacity and exceed s

cutoffs 1 1 1 1 1 5

9 4 Existing GE w/ capacity

>DD a cutoffs, but then

adds permanent storage

capacity 2 2 2 2 2 10

10 5 Existing GE w/ capacity

>DD a cutoffs, but then

adds TSF capacity 2 2 2 2 2 10

11 6 Existing GE w/ capacity

>DD a cutoffs, and does

modification or

reconstruction 18 18 18 18 18 90

1 Based on the number of elevators that had been identified to be constructed in the past five years, i.e., 3 , and apportioning one

- t hird 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 datab ase 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 nationa lly 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 modifi ed or reconstructed each year.

### 10 Table 2

- 3. Number of Affected Facilit i es per Grain Elevator in Each Scenario

Affected Facilty Subcategory Scenarios % of GE with

Modifications

to Affected

Facilit i es

6 a and 6b 1 7 2 8 2 9 2 10 2 11 3

Greenfield

GE w/

capacity >

DD a

cutoffs Existing GE w/

capacity <DD a

cutoffs, but

then adds TSF

capacity and

exceed s

cutoffs Existing GE w/

capacity <DD a

cutoffs, but

then adds

permanent

storage capacity

and exceed s

cutoffs Existing GE

w/ capacity

>DD a

cutoffs, but

then adds

permanent

storage

capacity Existing GE w/

capacity >DD a

cutoffs, but

then adds TSF

capacity Existing GE w/

capacity >DD a

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 I nformation from the 2009 survey responses w as 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 unlo ading

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

3 P ercentages 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 likeli hood 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

6 a 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 20 100 a

Total 49 38 49 49 38 22 3 a

a 

### Number reflects rounding.

### 12 Table 3

- 1

. Summary of Cumulative Costs and Emission Reduc t i ons f or 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 NA 1 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

6 a Greenfield GE

w/capacity > DDa

cutoffs due only

to permanent

storage capacity

- - - - -

6b Greenfield GE

w/capacity > DDa

cutoffs due to

adding TSF

capacity

- - 5 89

, 4 00 5 89

, 4 00 5 89

, 4 00

7 Existing GE w/

capacity <DD a

cutoffs, but then

adds TSF capacity

and exceed s

cutoffs 33,200 66,400 99,600 132,800 166,000

8 Existing GE w/

capacity <DD a

cutoffs, but then

adds permanent

storage capacity

and exceed s

cutoffs

- - - - -

9 Existing GE w/

capacity >DD a

cutoffs, but then

adds permanent

storage capacity

- - - - -

10 Existing GE w/

capacity >DD a

cutoffs, but then

adds TSF capacity 66,400 132,800 199,200 265,600 332,000

11 Existing GE w/

capacity >DD a

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

6 a 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 <DD a

cutoffs, but then

adds TSF capacity

and exceed s

cutoffs

- - 233,946 233,946 233,946

8 Existing GE w/

capacity <DD a

cutoffs, but then

adds permanent

storage capacity

and exceed s

cutoffs 33,613 67,225 100,838 134,450 168,063

9 Existing GE w/

capacity >DD a

cutoffs, but then

adds permanent

storage capacity 9,034 18,069 27,103 36,138 45,172

10 Existing GE w/

capacity >DD a

cutoffs, but then

adds TSF capacity 18,069 36,138 54,206 72,275 90,344

11 Existing GE w/

capacity >DD a

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. Cum u lative 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 inspect i on

### A

- 2 Table A

- 2. Cum u lative 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 Existi ng 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

capaci ty 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 Exist ing 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 . Cum u lative Cost For Each Year, For Each Scenario

- W eekly 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

M aintenance materials

= $ 1,699 Based on OAQPS Cost Manual

Indirect Costs = overhead, admin i strative, 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 . Cumu lative 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, admin i strative, 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. Cumu lative 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 v endor quote, attachment C.

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

for dust control bu t would be to meet additional DD a 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

M aintenance materials

= $1,699 Based on OAQPS Cost Manual

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

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

and ratio of 3:1 Total PM to PM10

Indirect Costs = overhead, admin i strative, 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

Pe rmanent 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 collect or, fan,

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

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 Cost ing

Inputs for ACA:

size ft

width 8

length 45 Will hold an 18

- wheeler, a 15

- foot diame ter 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