### GRAIN ELEVATOR AND PROCESSOR NSPS INDUSTRY SURVEY

INTRODUCTION AND GENERAL INSTRUCTIONS

This survey form is to be completed by a respondent for each of its wholly owned facilities as described in the

following four paragraphs (A-D), using the definitions at the end of this introductory section. Respondents must

meet the requirements of paragraphs A, B, and C.

A. This survey is limited to the following facilities: any “grain elevator” that would constitute a “grain

terminal elevator” or a “grain storage elevator” (as those terms are defined by Subpart DD (40 CFR

60.301)) if only permanent storage or both permanent and temporary storage at the grain elevator are

taken into account. A respondent need not provide data for any facility not possessing this type of

grain elevator.

B. EPA is interested in obtaining information about the following categories of grain elevators:

(1) Country grain elevators with storage capacity^ ≥ 2,500,000 bushels

(2) Other stand-alone elevators with storage capacity^ ≥ 2,500,000 bushels

(3) Wheat flour mill elevators *

(4) Wet corn mill elevators *

(5) Dry corn mill (human consumption) elevators *

(6) Rice mill elevators *

(7) Soybean oil extraction elevators *

^”Storage capacity” may include only permanent storage c apacity, or it may include both permanent and temporary

storage capacity.

*Grain elevators in categories 3-7 above must have storage capacity of ≥ 1,000,000 bushels.

For each of the above seven categories, a respondent must submit a response for at least five

facilities under its control. If a respondent has less than five facilities in a particular category, the

respondent must provide information for all of its facilities in that category.C. EPA is also interested in obtaining inform ation about the following types of facilities:

 Grain elevators located in each EPA Region.

 Five storage combinations:

- Grain elevator alone

- Grain elevator w/emergency storage

- Grain elevator w/temporary storage

- Grain elevator w/emergency and temporary storage

- Grain elevator w/barge unloading

 Facilities handling multiple grains.

 Facilities handling only one grain.

A respondent must submit a response for each of the facilities listed below to the extent it has any such

facility under its control for each of the 7 categories listed in paragraph B:

 At least one facility in each Region;

 At least one facility with each of the grain storage combinations;

 At least one facility that handles multiple grains; and

 At least one facility that handles only one grain.

For example, if a respondent has 18 facilities in t he country grain elevator category, and 10 are in EPA

Region 5 and eight are in EPA Region 6, the respondent shall provide information for a minimum of five

grain elevators. At least one elevator must be in Region 5 and one in Region 6. In addition, if

applicable, the respondent shall provide information on at least one facility with each of the five grain

storage combinations. The respondent must also provide information for at least one facility that

handles multiple grains and one that handles only one grain. In this example, assuming the respondent

owned each of the different types of grain elevators of interest to EPA, it is possible to meet the EPA

requirements with five facilities responding if the five chosen facilities can meet multiple requirements

(e.g., handling multiple grains in EPA Region 5 and using each of the 5 storage methods). However, it

may be necessary to provided additional facility respons es to meet the EPA requirements if facilities

cannot meet multiple EPA requirements.

D. The total number of facilities for a respondent may exceed 35 (five facilities in each of the seven

categories) when including the regional, combination, and grain information. However, no respondent

is required to submit information about more than 51 facilities.

Since one of the goals of this survey is to gather data on temporary storage facilities, EPA encourages

respondents to exercise any discretion afforded by paragr aphs A-D above in favor of submitting data on such

facilities. For the same reason, EPA encourages respondents to include along with their required responses to

this survey any supplemental data on such facilities that may go beyond the bounds of this survey but

nevertheless would be helpful to EPA in understanding tem porary storage facilities fully from the standpoint of

Subpart DD.

This survey is provided in paper format and by first-class mail. However, you may opt to complete this survey

either in paper format or in electronic format. To obtai n an electronic file (in Microsoft Word) to compile your

responses, please contact Bill Schrock at schrock.bill@epa.gov . Please submit complete responses to Bill

Schrock within 60 days after receipt by first-class mail. Any request for an extension of that 60-day period

must be submitted to Bill Schrock within 30 days after rece ipt by first-class mail. Extensions will not be granted

except upon a showing of undue hardship and then only for the minimum time reasonably necessary.

It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary

storage” and “emergency storage” to differentiate between those structures typically constructed of concrete

and topped with metal roofs and the pyramid shaped storage uni ts typically with low concrete walls and a vinyl

top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the currentreceipt by first-class mail. Any request for an extension of that 60-day period must be submitted

to Bill Schrock within 30 days after receipt by first-class mail. Extensions will not be granted

except upon a showing of undue hardship and then only for the minimum time reasonably

necessary.

It is important to note that, throughout this document, we have used the terms “permanent

storage,” “temporary storage” and “emergency storage” to differentiate between those structures

typically constructed of concrete and topped with metal roofs and the pyramid shaped storage

units typically with low concrete walls and a viny l top. The use of the terms “permanent storage”

and “temporary storage” is strictly to reflect the current terminologies used in industry as defined

by the U.S. Department of Agriculture (USDA) and in no way represents any EPA decision as to

how these units will be treated in any subsequent action. See definitions section for a list of

terms used in this survey.

In addition to the items listed in the survey forms that follow this introduction, we are also

requesting copies of the following information to the extent it relates to grain elevators or

portions of processing plants that consist of grain elevators:

1. Your current air quality operating permit, if you have one.

2. Copies of the most recent results from PM/PM10 emissions testing conducted at your

facility within the last 3 years, including but not limited to, opacity measurements and

stack testing. No new testing is required for this survey.

Following is a summary of the forms that comprise this survey:

Form A General Form . One should be completed for each facility.

Form B Storage Information . Please complete for storage units at each facility.

Form C Receiving and Shipping . Complete for shipping/receiving units at each facility.

Form D Temporary Storage . Please complete one form for each temporary storage area.

Form E Emergency Storage . Complete one form for each emergency storage area.

Form F Grain Dryers . Please complete one form for fuels used for grain dryers.

Form G Permitted Sources . Please complete if any part of your facility is covered under

an air quality operating permit.

Form H Work Practices . Please complete if any part of your grain elevator or processing

facility uses work practices for grain storage, shipping, and receiving operations.

Form I Add-on Particulate Controls . Please complete for each add-on particulate

control.

## Definitions (in addition to those in Subpart DD):

Storage Unit – For the purposes of this survey, a storage unit is any building, bin, silo, or pile used to

store corn, wheat, sorghum, rice, rye, oats, barley or soybeans.

Permanent Storage – A storage unit with an immovable roof; a floor made of concrete, asphalt or

similar material; and sidewalls made of steel, concrete or similar material.

Temporary Storage – A storage unit that is comprised of: asphalt, concrete, or other comparable base

material; rigid self-supporting sidewalls; a tarp , cover or the equivalent; and an aeration system.

Emergency Storage – A form of storage other than permanent storage or temporary storage.

Country Elevator – Any grain elevator where more than 50% of grain is received from farms.

Other Stand

- Alone Elevator – Any grain elevator where less than 50% of grain is received from farms

AND grain processing is not the primary activity.

Grain Processing – Equipment or processes used to alter the natural state of grain by fractioning,

grinding, blending, conditioning, etc., in order to produce a product for human or animal consumption or

the production of biofuels.

Shipping Units – All equipment associated with loading grain from a storage unit.

Receiving Units – All equipment associated with loading grain into a storage unit.

Design or Work Practice – Any technique other than the installation of air pollution control equipment

for the reduction of particulate matter emissions.

### FORM A Page 1 

# Grain Elevator Survey

FORM A – General Information

A-1 Facility Name:

A-2 (a) Facility Street Address:

(b) Suite or P.O (s pecify): (c) City:

(d) State: (e) Zip Code: (f) County:

A-3 (a) Facility Manager: (b) Phone:

A-4 (a) Technical contact (for info rmation on this survey):

(b) Title: (c ) Telephone Number:

(d) Email Address:

A-5 Number of full-time employees at this location (total for all shifts):

A-6 Number of seasonal employees at this location (total for all shifts):

A-7 (a) Parent Company/ Co-Op:

(b) Is this a co-op? (check one) Yes No

(c) Parent Company/ Co-Op Main Office Street Address:

(d) Suite or P.O. (specify) : (e) City:

(f) State: (g) Zip Code:

A-8 Number of full-time employees within all business units of the Parent Company:

(please check one): < 100 101- 249 250- 499 > 500

A-9 Number of seasonal employees within a ll business units of the Parent Company

(please check one): < 100 101- 249 250- 499 > 500 FACILITY ID:

FACID :

(First 4 letters of company name plus first

4 letters of city name. If not unique

identifier, add number at end of ID)

## FORM B - Storage Information

(B-1) FACID:

FORM B Page 1 B-2 In what year was this facility first constructed?

B-3 Total number of storage units: (a) "permanent" storage

(b) "t emporary" storage

(c) "emergency" storage

[Note : In completing the remainder of the survey, y ou will be able to group information for similar

storage units. See B-4 for example.]

B-4 Please provide an overview flow diagram (or blo ck flow diagram) of the grain elevator(s) at

your facility. Please include pe rmanent (P), temporary (T), and emergency (E) storage units,

associated receiving (R) and shipping (S ) units, and grain dryers (D).

o Permanent Storage ID: use your current designation or assign a nu merical value. If assigning

an ID, please use “P-1, P-2, etc” format. You may group multiple storage units into one

permanent storage ID; if not readily apparent, please provide ex planations on the back of this

sheet or indicate in your elevator diagram.

o Temporary Storage ID: use your current designation or assign a nu merical value. If assigning

a new ID, please use “T-1, T-2” format.

o Emergency Storage ID: use your current designation or assign a nu merical value. If assigning

a new ID, please use “E-1, E-2” format.

o Receiving Units ID: use your current designation or assign a numerical value. If assigning an

ID, please use “R-1, R-2” format.

o Shipping Units ID: use your current designati on or assign a numerical value. If assigning an

ID, please use “S-1, S-2” format.

o Grain Dryer ID: use your current designation or assign a numerica l value. If assigning an ID,

please use “D-1, D-2” format.

o Capacity: please provide capacity in bushels. Do not use a pack factor

.FORM BPage2Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM B – Storage Information(B-1) FACID:B-5.Please complete the following table for storage information. An example is provided.2005 2006 2007Storage Type(P, T, E)StorageIDYear FirstUsedStorageCapacity(Bushels)2GrainStored1Through-put(actual bushels)2Weeks peryear utilizedThrough-put(actual bushels)2Weeks per yearutilizedThrough-put(actual bushels)2Weeks peryear utilizedCorn100,0002P - exampleP-11970300,000Wheat400,00050300,00050300,00050P - exampleP-21985400,000Corn400,00052400,00050400,00048T - exampleT-12004450,000Corn200,00022250,00020150,000241 Use grain designations: corn, wheat, sorghum, rice, rye, oats, barley, soybeans, or specify a different grain.2 Storage capacity and throughput refer to the aggregated storage capacity and throughput of the units included in the storageID from B-4. Fortemporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knowledge if actualdata is notavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data is not available.FORM BPage2Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM B – Storage Information(B-1) FACID:B-5.Please complete the following table for storage information. An example is provided.2005 2006 2007Storage Type(P, T, E)StorageIDYear FirstUsedStorageCapacity(Bushels)2GrainStored1Through-put(actual bushels)2Weeks peryear utilizedThrough-put(actual bushels)2Weeks per yearutilizedThrough-put(actual bushels)2Weeks peryear utilizedCorn100,0002P - exampleP-11970300,000Wheat400,00050300,00050300,00050P - exampleP-21985400,000Corn400,00052400,00050400,00048T - exampleT-12004450,000Corn200,00022250,00020150,000241 Use grain designations: corn, wheat, sorghum, rice, rye, oats, barley, soybeans, or specify a different grain.2 Storage capacity and throughput refer to the aggregated storage capacity and throughput of the units included in the storageID from B-4. Fortemporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knowledge if actualdata is notavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data is not available.FORM CPage1Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM C – Receiving and Shipping Information(C-1) FACID:C-2Please complete the following table for receiving and shipping operationsat each storage unit (orgroup of units). Use theStorage, Shipping, and Receiving ID’s provided in B-4.An example is provided.What is the Maximum LoadingRate?Receiving/ShippingIDStorage IDassociated withreceiving/shipping unitHow is Grain Received Into orShipped (Loaded) Out ofStorage?aValue UnitsAre there any addon controls for thereceiving/shipping unit (Y/N)Any qualitativeemissionsmonitoringconducted?b(Y/N)R-1P1Fixed Conveyor BeltS-1P1Fixed Conveyor BeltR-1T1Portable AugeraLoading and unloading methods include:portable augerfixed receiving pit with leg to aeration towerenmass drag conveyor unloaderportable inclined beltfixed conveyor off main complexpneumatic unloadergravity fill spoutportable conveyor with trucksor specify a different methodfront-end loadermarine legfixed drag conveyortrack hoe/clamshell unloaderfixed conveyor beltcontinuous barge unloaderbQualitative methods include opacity measurements as well as monitoring instruments (e.g. CEMS), and monitoringof parameters toindicate whether the air pollutioncontrol device is operating properly.FORM BPage2Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM B – Storage Information(B-1) FACID:B-5.Please complete the following table for storage information. An example is provided.2005 2006 2007Storage Type(P, T, E)StorageIDYear FirstUsedStorageCapacity(Bushels)2GrainStored1Through-put(actual bushels)2Weeks peryear utilizedThrough-put(actual bushels)2Weeks per yearutilizedThrough-put(actual bushels)2Weeks peryear utilizedCorn100,0002P - exampleP-11970300,000Wheat400,00050300,00050300,00050P - exampleP-21985400,000Corn400,00052400,00050400,00048T - exampleT-12004450,000Corn200,00022250,00020150,000241 Use grain designations: corn, wheat, sorghum, rice, rye, oats, barley, soybeans, or specify a different grain.2 Storage capacity and throughput refer to the aggregated storage capacity and throughput of the units included in the storageID from B-4. Fortemporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knowledge if actualdata is notavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data is not available.

## FORM D – “Temporary” Storage

(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 1 (Please copy this sheet and comp lete a separate sheet for each

temporary storage at your facility)

D-3 Please provide a diagram of each storage unit and indicate which pieces of equipment (e.g.,

walls, cover, floor, conveyance system, generator, housing for electrical, etc) remain in place

year round and which are removed during specific time s of the year. If th is system is identical

(or nearly identical) to another temporary system at the same facility, only one diagram is

needed. Please include all applicable ID numbers on the diagram and explain any differences

below.

D-4 What are the materials of construction for this storage unit?

(a) Walls:

(b) Cover/tarp:

(c) Floor:

D-5 (a) Has the cover/tarp ever been replaced? (check one) Y N

(b) If yes, month(s)/year(s) cover/ tarp was used before being replaced:

## FORM D – “Temporary” Storage

(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 2 D-6 Describe the routine maintenance (including repai r and replacement) that is conducted on the

temporary storage units, including frequency of these activities. If you typically replace a

component of a unit (e.g., repl acement of a tarp/cover in sections, as opposed to entire

replacement), indicate frequency and typical perc ent of the entire unit that is replaced.

Walls:

Floors:

Cover/Tarp:

Aeration:

Other equipment associated with st orage (e.g., conveying equipment)

D-7 Describe methods used to reduce particulate emissions during receiving and shipping,

aeration (or other similar processes), and general storage. Indicate frequencies of any actions.

(Please complete Form I for any add-on pollution control device).

## FORM E – “Emergency” Storage

(E-1) FACID: (E -2) Emergency Storage ID:

FORM E  Page 1 E- 3 Explain any approaches taken to minimize particulate emissions from the emergency storage

pile. Indicate frequencies of any actions.

## FORM F – Grain Dryers

(F-1) FACID:

FORM F  Page 1 F-  Please complete the following tabl e for grain dryers used at your facility. Use the Dryer,

Storage, Shipping, and Receiv ing ID’s provided in B-3. An example is provided.

How much fuel was used

Grain Dryer ID Storage/Receiving/Ship

ping units associated

with Dryer Fuel Used 1 2005 2006 2007

D-1 P-1, P-2, R-1, S-1 FO2 10,000 10,000 8,000

D-2 T-1 FO2 1,000 1,000 1,000

1 

### Select fuel from list below. If other, please specify.

FO2 - #2 Fuel Oil (gallons)

FO6 - #6 Fuel Oil (gallons)

NG – Natural Gas (MM cubic feet)

Bio – Biofuel (gallons)

O – Other, please specify type of fuel and unit of measure

F-  For each column dryer at your facility that does not include a perforated column plate in its

design, please: (1) describe the design of that dryer, including whether it uses woven wire

screening; (2) indicate the grain(s) for which t he dryer is used; and (3) provide the year of

original installation.

## FORM F – Grain Dryers

(F-1) FACID:

FORM F  Page 1 F-  Please complete the following tabl e for grain dryers used at your facility. Use the Dryer,

Storage, Shipping, and Receiv ing ID’s provided in B-3. An example is provided.

How much fuel was used

Grain Dryer ID Storage/Receiving/Ship

ping units associated

with Dryer Fuel Used 1 2005 2006 2007

D-1 P-1, P-2, R-1, S-1 FO2 10,000 10,000 8,000

D-2 T-1 FO2 1,000 1,000 1,000

1 

### Select fuel from list below. If other, please specify.

FO2 - #2 Fuel Oil (gallons)

FO6 - #6 Fuel Oil (gallons)

NG – Natural Gas (MM cubic feet)

Bio – Biofuel (gallons)

O – Other, please specify type of fuel and unit of measure

F-  For each column dryer at your facility that does not include a perforated column plate in its

design, please: (1) describe the design of that dryer, including whether it uses woven wire

screening; (2) indicate the grain(s) for which t he dryer is used; and (3) provide the year of

original installation.

## FORM G –Permitted Sources

(G-1) FACID:

FORM G Page 1 G-2 Please indicate the total number of each component listed below that you have at this facility

and the number for which your operating permit specifies an applicable control requirement.

Component Total Number at Site Number for which your permit

specifies a control requirement?

Truck receiving station

Truck shipping station

Barge and ship receiving station

Barge and ship shipping station

Railcar receiving station

Railcar shipping station

Grain dryer



### G-3 Is any grain handling equipment subjected to a control requi rement in your permit?

(check one) Y N

As defined in NSPS, Subpart DD, grain handling operations includ e, as an assemblage of equi pment, bucket elevators or

legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers,

cleaners, trippers, and the headhouse and other such structures.



### For purposes of Form G, the term “control requirement” refers onl y to particulate matter (PM)

emission limits specified for the particular “component” in question and expressed in terms of

emissions per unit of time or production ( e.g., lb of PM/hr; grains/dscf), opacity ( e.g., 20%), or a

design or work practice ( e.g., use of enclosure), and not to rest rictions on operational parameters

such as hours, feedstock or throughput.

## FORM H – Work Practices

(H-1) FACID:

FORM H Page 1 H-2 Describe the design or work practices you follow to reduce emissions (e.g, choke flow, louvered grates,

mineral oil, etc.). Please describe the frequency the activity is used (e.g, during each loading operation,

all the time, etc) and the estimated time spent on the activity per usage (e.g, 20 minutes per loading

event). For “barge and ship receiving station,” pleas e provide copies of any equivalency determinations

under 40 CFR 60.302(d) and any permit conditions resulting from such determinations.



### Truck receiving station

Truck shipping station

Barge and ship receiving station

Barge and ship shipping station

Railcar receiving station

Railcar shipping station

Grain dryer

Grain handling operations a

a As defined in NSPS, Subpart DD, grain handl ing operations include, as an assemblage of equipment, bucket elevators or

legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers,

cleaners, trippers, and the headhouse and other such structures.FORM I – Add-on Pollution Control Device(I-1) FACID:FORM IPage 1If data are not available or unknown, please enter NDI-2Please complete the following table for any air pollution control devices at your facility. Please provide ID and include on processdiagram. For each unit, please provide the most recent performance data you have.An example is provided.Air Pollution ControlDevice IDType of Control [e.g., fabricfilter/baghouse; cyclone;other (specify)]Points controlledby this control(Use ID’s fromForms B, C, andD)Type of Data Available [e.g.,performance test, manufacturer’sspecs or guarantee, engineeringcalculations, other (specify)]DesignEfficiencyUnits (include whetherefficiencies are for PM,PM10PM2.5, opacity)APCD-1 exampleCycloneR-1, R-2Manufacturer’s specifications40%PMAPCD-2 exampleFabric FilterS-1Manufacturer’s specifications90%PM and PM10Make additional copies, as necessary

## FORM I – Add-on Pollution Control Device

(I-1) FACID:

FORM I   Page 2 I-3. Provide a copy of the most re cent performance test for each air pollution control device

If no performance tests are available, complete questions I-4 through I-7.

I-4. Please complete for each c ontrol device listed in I-2.

Inlet Flow Pressure Drop Inlet Temperature

APCD ID Max Units Min Max Units Min Max o C/ o F



### I-5 For each cyclone, please co mplete the following table

APCD ID Particle Density Units

## FORM I – Add-on Pollution Control Device

(I-1) FACID:

FORM I  Page 3 I-6 . For each fabric filter/baghouse, pl ease provide the following information.

APCD ID Number of bags Total Surface Area Units

I-7 For each control not listed in I-5 and I-6, please describe the te chnology and the parameters that

are relevant for operation of the controlENCLOSURE 2

EPA's Information Gathering Authority

Under Section 114 of the Clean Air Act

Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental Protection

Agency broad authority to secure information needed for the purpose of (i) developing or assisting in the

development of any implementation plan under Sect ion 110 or 111(d), any standard of performance under

Section 111, or any emission standard under Section 112; (ii) determining whether any person is in violation of

any such standard of any requirement of such a plan; or (iii) carrying out any prov ision of this Act. Among

other things, Section 114 authorizes EPA to make ins pections, conduct tests, examine records, and require

owners or operators of emission sources to submit information reasonably required for the purpose of

developing such standards. In addition, the EPA Office of General Counsel has interpreted Section 114 to

include authority to photograph or require submission of photographs of pertinent equipment, emissions, or

both.

Under Section 114, EPA is empowered to obtain info rmation described by that section even if you

consider it to be confidential. You may, however, request that EPA treat such information as confidential.

Information obtained under Section 114 and covered by such a request will ordinarily be released to the public

only if EPA determines that the information is not entitled to confidential treatment. 1 Procedures to be used for

making confidentiality determinations, substantive criteria to be used in such determinations, and special rules

governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal

Register on September 1, 1976 (40 FR 36902).

Pursuant to § 2.204(a) of EPA's Freedom of Information Act (FOIA) regulation, in the event a request is

received, or it is determined that a request is likely to be received, or EPA desires to determine whether

business information in its possession is entitled to confidential treatment even though no request for release

of the information has been received, please be advised that EPA will seek, at that time, the following

information to support your claim as required by § 2.204(e)(4) of EPA's FOIA regulations:

1. Measures taken by your company to guard against undesired disclosure of the information to others;

2. The extent to which the information has been disclosed to others, and the precautions taken in

connection therewith;

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any

such determinations, or reference to it, if available; and

4. Whether your company asserts that disclosure of the information would be likely to result in substantial

harmful effects on the business' competitive position, and if so, what those harmful effects would be,

why they should be viewed as substantial, and an explanation of the causal relationship between

disclosure and such harmful effects.

1 Section 114 requires public availability of all emission da ta and authorizes disclosure of confidential information in

certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976).