SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD )

( Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD )

( Renewal), EPA ICR Number 2354 .04 , OMB Control Number 2060

- 0635

.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) f or Prepared
Feeds Manufacturing were proposed on July 27, 2009, promulgated on January 5, 2010, and

amended on both July 20, 2010 and December 23, 2011

. The most

- recent amendment clarified
regulatory requirements but did not result in changes in emissions or costs associated with the

final rule. A prepared feed manufacturing facility is a facility where animal feed (other than dogs

and cats) makes up at least half (by mass) of the facility’s annual production of all products

. These regulations apply to new and existing area source prepared feeds manufacturing facilities

that use one or more materials (additives/premixes) that contain 0.1 percent or greater by weight
of chromium (Cr) or 1.0 percent or greater by weight of manganese (Mn)

. New facilities include

th ose that commenced construction or reconstruction after the date of proposal. This information
is being collected to assure compliance with 40 CFR Par t 63, Subpart DDDDDDD

.

In general, all NESHAP standards require initial notification report s, performan ce tests, and periodic reports by the owners/operators of the affected facilities. They are also required to
maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period du ring which the monitoring system is
inoperative. These notifications, reports, and records are essential in determining compliance,
and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part s hall maintain a file containing

these documents , and retain the file for at least five years following the generation date of such
maintenance reports and records. All reports are sent to the delegated state or local authority.

In the event that there is no such delegated authority, the reports are sent directly to the U

. S

. Environmental Protection Agency (EPA) regional office.

T he “Affected Public” are prepared feeds manufacturing facilities that are an area source
of hazardous air pollutants (HAPs). These facilities are privately

- owned, for

- profit businesses.

The “ burden ” to the Affected Public may be found below in Table 1: Annual Respondent Burden

and Cost

– NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD)

( Renewal)

. T he “ burden ” to the Federal Government is attributed entirely to work performed by

either F ederal employees or government contractors

, and can be found below in Table 2:
Average Annual EPA Burden and Cost

– NESHAP for Prepared Feeds Manufacturing (40 CFR2

Part 6 3, Subpart DDDDDDD ) (Renewal)

.

Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the
owner/operator of the plant site).

Ov er the next three ye ars, approximately 1,800 respondents per year will be subject to

the se standard s , and no additional respondents per year will become subject to the se same

standard s

. This estimate is based on information obtained from a previous ICR renewal

.

The Office of Management and Budget ( OMB ) approved the currently active ICR
without any “ Terms of Clearance ”

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish
standards of performance for each category or subcategory of major sources and area sources of
hazardous air pollutants. These standards are applicable to new or existing sources of hazardous
air pollutants and shall require the maximum degree of emission reduction. In addition, section
114(a) states that the Administrator may require any owner/operator subject to any requirement

of this Act to:

(A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use
such audit procedures, or methods; (D) sample such emissions (in
accordance with such procedures or methods, at such locations, at
such intervals, during such periods, and in such manner as the

Administr ator shall prescribe); (E) keep records on control
equipment parameters, production variables or other indirect data
when direct monitoring of emissions is impractical; (F) submit
compliance certifications in accordance with Section 114(a)(3);
and (G) prov ide such other information as the Admini strator may reasonably require.

In the Administrator's judgment, chromium and manganese emissions from prepared feed
manufacturing facilities either cause or contribute to air pollution that may reasonably be
anticipated to endanger public health and/ or welfare. Therefore, the NESHAP were promulgated
for this source category at 40 CFR Part 63, Subpart DDDDDDD

.3

2(b) Practical Utility/Users of the Dat a

The recordkeeping and reporting requirements in the se standard s ensure compliance with
the applicable regulations which were promulgated in accordance with the Clean Air Act. The
collected information is also used for targeting inspections and as eviden ce in legal proceedings.

Performance tests are required in order to determine an affected facility ’ s initial
capability to comp ly with the emission standard s Continuous emission monitors are used to

ensure compliance with the se standard s at all tim es. During the performance test a record of the
operating parameters under which compliance was achieved may be recorded and used to
determine compliance in place of a continuous emission monitor.

The notificat ions required in the se standard s are used to inform the Agency or delegated
authority when a source becomes subject to the requirements of the regulations. The reviewing
authority may then inspect the source to check if the pollution control devices are properly
installed and operated

, l eaks are being detected and repaired

, and the standard is being met.
The performance test may also be observed.

The requi red annual reports are used to determine periods of excess emissions, identify
problems at the facility, verify operation/maintenan ce procedures

, and for compliance

determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping an d reporting are required under 40 CF R Part 63, Subpart

DDDDDDD

.

3(a) Non

- duplication

If the subject standards have not been delegated, the information is sent directly to the
appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state
or local agency. If a state or local agency has adopted its own s imilar standards to implement the
Federal standards, a copy of the report submitted to the state or local agency can be sent to the
Administrator in lieu of the report required by the Federal standards. Therefore, no duplication

exists.

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

An announcement of a public comment period for the renewal of this ICR was published

in the Federal Register ( 80 FR 32116 ) on June 5, 20 15

. No comments were received on the
burden published in the Federal Register

.4

3(c) Consultations

The Agency has consulted i ndustry experts and internal data sources to project the

number of affected facilities and industry growth over the next three years. The primary source
of information as reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is

EPA’s database for the collection, maintenance, and re trieval of compliance data for industrial
and government

- owned facilities. The growth rate for the industry is based on our consultations
with the Agency’s internal industry experts.

I ndustry trade associations and other interested parties were provided an opportunity to
comment on the burden associated with the standard as it was being developed and the standard
has been previously reviewed to determine the minimum information needed for compliance

purposes. In developing this ICR, we contacted both the National Grain and Feed Association

(NGFA)

, at jmccluer@ngfa.org

, and the American Feed Industry Association (AFIA)

, at pkeppy@afia.org

.

It is our policy to respond after a thorough review of comments received since the last
ICR renewal as well as those submitted in response to the f irst Federal Register n otice. NGFA
representative(s) reviewed the ICR supporting statemen t and stated that it has no comments on
the burden presented in the ICR.

3(d) Effects of Less

- Frequent Collection

Less

- frequent information collection would decrease the margin of assurance that
facilities are continuing to meet the standards. Requireme nts for information gathering and
recordkeeping are useful techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met. If the information required by these standards was

collected less

- frequently, the proper operation and maintenance of control equipment and the
possibility of detecting violations would be less likely.

3(e) General Guidelines

T hese reporting or recordkeeping requirements do not violate any of the regulations
promulgated by OMB und er 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and
notifications for at least five years. This is consistent with the General Provisions as applied to

the standards. EPA believes that the five

- year records retention requirement is consistent with the
Part 70 permit program and the five

- year statute of limitations on which the permit program is

based. T he retention of records for five years allow s EPA to establish the compliance history of a

source

, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has found that the most flagrant violators have violations extending beyond five

years. In addition, EPA would be prevented from pursuing the viol ators due to the destruction or5

nonexistence of essential records

.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made
will be safeguarded according to the Agency policies set forth in Title 40, chap ter 1, part 2,
subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

T he reporting or recordkeeping requirements in the standard do not include sensitive
questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and
operators of area source prepared feed manufacturing facilities that add chromium or manganese
to their products

. The United States Standard Industrial Classification ( SIC ) code for the
respondents affected by the standards is SIC 0723 and 2048, which corr espond to the North
American Industry Classification System (NAICS ) code 311119 for Other Animal Food
Manufacturing.

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required by the NESHAP for
Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD)

.

A source must make the following reports:

Notification s

Notification of applicability 63.9(b)(2)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of compliance status 63.9(h)

, 63.11624(a)(2)6

Notification s

Notification of changes in information 63.9(j)

Initial notification 63.11624(a)(1)

Reports

CMS performance evaluation 63.8(e)(5)

Excess emissions reports 63.10(e)(3)

Annual compliance certifications 63. 11624(b)

A source must keep the following records:

Recordkeeping

Records of notifications 63.10

, 63.11624(c)(1)

Records of annual compliance certifications 63.11624(c)(2)

Records of device inspection 63.11624(c)(3)

Records that demonstrate continuous compliance 63.10

Monitoring information 63.10

Records of quarterly inspection, including information on the cyclone 63.11624(c)(4)

- (5)

Records of feed production 63.11624(c)(6)

Electronic Reporting

Some of the r espondents are using monitoring equipment that automatically records
parameter data. Although personnel at the affected facility must still evaluate the data, internal
automation has significantly reduced the burden associated with monitoring and recordkeeping at

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid
supply pressure for the cyclone.7

Respondent Activities

Perform initial performance test, Reference Method 5 test, and repeat performance tests if

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and
systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and
maintaining info rmation.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and
providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis,
storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions
reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO)

and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to
determine whether the pollution control devices are p roperly installed and operated. Performance8

test reports are used by the Agency to discern a source ’ s initial capability to com ply with the

emission standard s

. Data and records maintained by the respondents are tabulated and published
for use in compliance and enf orc ement programs. The annual reports are used for problem
identification, as a check on source operation and maintenance, and for compliance

determinations.

Information contained in the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial
and government

- owned facilities. EPA uses ICIS for tracking air pollution comp liance and
enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.
EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the ow ner/operator for five

years.

5(c) Small Entity Flexibility

A majority of the respondents are small entities (i.e., smaller businesses). O ur analysis

indicates that the regulation would not impose a significant adverse impact on any facilities,
large or small

, since these costs are less than 0.1 percent of revenues. Due to technical
considerations involving the process operations and the types of control equipment employed,
the recordkeeping and reporting requirements are the same for both small and large entities.
The Agency considers these to be the minimum requirements needed to ensure compliance
and, therefore, cannot reduce them further for small entities. To the extent that larger businesses

can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Prepared Feeds
Manufacturing (40 CFR Part 63, Subpart DDDDDDD) ( Renewal)

.

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and
reporting requirements applicable to the industry for the subpart included in this ICR. The
individual burdens are expressed under standardized headings believed to be consistent with the
concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and
major assumptions have been identified. Responses to this in formation collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to,
a collection of information unless it displays a currently valid OMB Control Number.9

6(a) Estimating Respondent Burden

The aver age annual burden to industry over the next three years from these recordkeeping
and reporting requirement s is estimated to be 64,100 hours ( Total Labor Hours from Table 1

below ). T hese hours are based on Agency studies and background documen ts from the

de velopment of the regulation, Agency knowledge and experience with the NESHAP program, the previously

- approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June

2014

, “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from

column 1, “ Total compensation. ” The rates have been increased by 110 percent to account for
the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activ ities in the
subject standard are both labor costs which are addressed elsewhere in this ICR and the costs
associated with continuous monitoring. Th e capital/star tup costs are one

- time costs when a
facility becomes subject to the regulation. The annual operation and maintenance costs are the
ongoing costs to maintain the monitor(s) and other costs su ch as photocopying and postage.

(iii) Capital/Startup vs. Operati on and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous
Monitoring

Device (B)
Capital/Startup

Cost for One
Respondent (C)

Number of

New
Respondents (D)

Total
Capital/Startup

Cost, (B X C) (E)

Annual O &M

Costs for One
Respondent 1 (F)

Number of
Respondents

with O&M 2 (G)

Total O&M,

(E X F)

Cyclone

monitor $295 0 $0 $29 1,284 $37,236

Total 3 $37,200

1 We assume that annual O&M costs would be 10 percent of the initial capital cost.

2 The NESHAP requires that existing and new facilities with a daily production level greater than 50 tons per day install and

operate a cyclone to reduce emissions from pelleting operations. These facilities are required to install a device on the cyc lone10

to mo nitor inlet flow rate, inlet velocity, pressure drop, or amperage. We estimate 1,284 of the 1,800 facilities have production
greater than 50 tons per day.

3 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are zero

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 37,200

. This is the

total of column G.

The average annual cost for capital/startu p and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $ 37,200

. These are the record

keeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported

information. EPA's overall compliance and enforcement program i ncludes activities such as

the examination of records maint ained by the respondents, periodic inspection of sources of
emissions, and the publication and distributi on of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be

$ 188,000

.

This cost is based on the average hourly labor rate as follows:

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

These rates are from the Office of Personnel Management (OPM)

, 20 1 4 General Schedule

, which excludes locality rates of pay. The rates have been increased by 60 percent to account for
the benefit packages available to government employees

. Details upon which this estimate is
based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Prepared
Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) ( Renewal)

.

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

Based on our research for this ICR, on average over the next three years, approximately

1,800 existing respondents will be subject to the se standard s

. It is estimated that no a dditional
respondents per year will become subject to these same standards

. The overall average number
of responden ts, as shown in the table below, is 1,800 per year.

The number of respondents is calculated using the following table that addresses the th ree11

years covered by this ICR.

Number of Respondents

Respondents That Submit Reports Respondents That Do
Not Submit Any Reports

Year (A)

Number of New
Respondents 1 (B)

Number of
Existing
Respondents (C)
Number of Existing
Respondents that keep

records but do not
submit reports (D)

Number of
Existing
Respondents That

Are Also New
Respondents (E)

Number of
Respondents

(E=A+B+C

- D)

1 0 1,800 0 0 1,800

2 0 1,800 0 0 1,800

3 0 1,800 0 0 1,800

Average 0 1,800 0 0 1,800

1 New respondents include sources with constructed, reconstructed and modified affected facilities.

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the
average Number of Respondents over the three year period of this ICR is 1,800

.

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity (B)

Number of
Respondents (C)

Number of

Responses (D)
Number of Existing
Respondents That

Keep Records But Do
Not Submit Reports (E)

Total Annual Responses

E=(BxC)+D

Initial notification 0 1 0 0

Notification of compliance status 0 1 0 0

Annual compliance certification 1,800 1 0 1,800

Total 1,800

The number of Total Annual Responses is 1,800.

The total annual labor costs are $6,450,000

. Details regarding these estimates may be

found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Prepared Feeds
Manufacturing (40 CFR Part 63, Subpart DDDDDDD) ( Renewal)

.12

6(e) Bottom L ine Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the
Agency are shown below in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 64,100 hours

. Details regarding these estimates may be

found in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Prepared Feeds
Manufacturing (40 CFR Part 63, Subpart DDDDDDD) ( Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical
tasks because the typical tasks for managers are to review and approve reports. Clerical burdens
are assumed to take 10% of the time required for technical tasks because the typical duties of
clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of
information is estimated to average 36 hours per response

.

The total annual capital/startup and O&M costs to the regulated entity are $37,200

. The
cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be

4,140 la bor hours at a cost of $188,000

. See below in Table 2: Average Annual EPA Burden and

Cost

– NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD)

(Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical
tasks because the typical tasks for managers are to review and approve reports. Clerical burdens
are assumed to take 10% of the time required for technical tasks because the typical duties of
clerical staff are to proofread the reports, make copi es and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent labor hours and cost in this ICR
compared to the previous ICR. This is not due to program changes. The increase occurred
because this ICR assumes all existing respondents will take some time each year to re

- familiarize
with the regulatory requirements. Additionally, there is a small decrease of $3 6 in the estimated
O&M cost due to rounding. This ICR rounds all calculated burden and costs to three significant
digits. There is no change in the methodology or a ssumption used to calculate O&M cost.13

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 36 hours per response. “ Burden ” means the total time, effort, or financial

resour ces expended by persons to generate, maintain, retain, or disclose or provide information

either to or for a Federal agency. This includes the time needed to review instructions; develop,
acquire, install, and utilize technology and systems for the purpose s of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of information; search data
sources; complete and review the collection of information; and transmit or otherwise disclose

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for t his ICR under

Docket ID Number EPA

- HQ

- OECA

- 201 2

- 0703

. An electronic version of the public docket is

available at http://www.regulations.gov/

, which may be used to obtain a copy of the draft

collection of informat ion, submit or view public comments, access the index listing of the
contents of the docket, and to access those documents in the public docket that are available
electronically. When in the system , select “search,” then key in the docket ID number identif ied

in this document. The documents are also available for public viewing at the Enforcement and
Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West,

Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Cen ter Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OECA

- 20 12

- 0703 and OMB Control Number 2060

- 0635 in any
correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this

information.14

Table 1: Annual Respondent Burden and Cost

– NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart

DDDDDDD) (Renewal)

Activity (A)

Person
hours per

occurrence (B)

No. of

occurrence

per respondent

per year (C)

Person

hours per respondent

per year

(AxB) (D)

Respondent

per year (E)

Technical

person hours per

year (CxD) (F)

Management
person hours

per year (Ex0.05) (G)

Clerical

person hours per

year (Ex0.1) (H) Cost, $ (a)

1. Applications

2. Survey and Studies

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

4. Reporting Requirements

A. Familiarize with regulatory requirements (b) 1 1 1 1,800 1,800 90 180 $208,161.90

B. Assumptions:

i. Quarterly control equipment inspection 1 4 4 1,284 5,136 256.8 513.6 $593,955.29

ii. Daily cyclone performance measures 0.1 365 36.5 1,284 46,866 2343.3 4686.6 $5,419,842.00

C. Create information

D. Gather existing information

E. Write report

Initial Notification (b) 0.5 1 0.5 0 0 0 0 $0

Notification of Compliance Status (b) 1 1 1 0 0 0 0 $0

Annual Compliance Certification 1 1 1 1,800 1,800 90 180 $208,161.90

Subtotal for Reporting Requirements 63,942 $6,430,121

5. Recordkeeping Requirements

A. Familiarize with regulatory requirements (b) See 4A

B. Plan activities15

C. Implement activities

D. Develop record system

E. Time to enter information

F. Time to train personnel

G. Time to transmit or disclose information (d) 0.1 1 0.1 1,800 180 9 18 $20,816.19

I. Time for audits 0.1 1 0.1 0 0 0 0 $0

Subtotal for Recordkeeping Requirements 207 $20,816

TOTAL ANNUAL BURDEN AND COST
(rounded) (e) 64,100 $6,450,000

Capital and O&M Cost (see Section 6(b)(iii))

(e) $37,200

GRAND TOTAL (rounded) (e) $6,490,000

Assumptions:

(a) Costs are based on the following hourly rates: technical at $10 3

. 97 , management at $12 9

. 93 , and clerical at $5 1

. 79

. (b) For new sources, we assume they will take 1.0 hr to read reporting requirements and 0.5 hr to read recordkeeping requirements

. For existing sources, we assume they will take 1.0 hour to re

- familiarize themselves with the regulatory requirements.

(c) Estimated 1,284 facilities (with daily production levels greater than 50 tons per day) have required monitoring equipment

.
(d) Information related to re quirements under 4B.

(e) Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.16

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart

DDDDDDD) (Renewal)

Activity (A)
EPA person

hours per

occurrence (B)

No. of

occurrences

per plant

per year (C)
EPA person

hours per
plant per
year (AxB) (D)

Plants

per year (E)

Technical

person hours per

year (CxD) (F)

Management
person hours

per year (Ex0.05) (G)

Clerical

person

hours

per

year (Ex0.1) (H) Cost, $ (a)

Report Review

Initial Notification (b) 1 1 1 0 0 0 0 $0

Notification of Compliance Status (b) 2 1 2 0 0 0 0 $0

Annual Compliance Certification 2 1 2 1,800 3,600 180 360 $188,424

TOTAL BURDEN AND COST (rounded) (c) 4,140 $188,000

Assumptions:

(a) Costs are based on the following hourly rates: technical at $46 .67 , management at $62. 90 , and clerical at $25. 25

.
Management person

- hours and clerical person

- hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively.

(b) One

- time only activity.

(c) Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.