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) for 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 

those that commenced construction or reconstruction after the date of proposal. This information 

is being collected to assure compliance with 40 CFR Part 63, Subpart DDDDDDD.

In general, all NESHAP standards require initial notification reports, performance 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 during 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 shall 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.

The “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). The “burden” to the Federal Government is attributed entirely to work performed by 

either Federal employees or government contractors, and can be found below in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR 
2

Part 63, 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).

Over the next three years, approximately 1,800 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to these same 

standards. 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 

Administrator 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) provide such other information as the Administrator 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 Data

The recordkeeping and reporting requirements in these standards 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 evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards Continuous emission monitors are used to 

ensure compliance with these standards at all times. 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 notifications required in these standards 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, leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

The required annual reports are used to determine periods of excess emissions, identify 

problems at the facility, verify operation/maintenance procedures, and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR 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 similar 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, 2015. No comments were received on the 

burden published in the Federal Register. 
4

3(c) Consultations

The Agency has consulted industry 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 retrieval 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. 

Industry 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 first Federal Register notice. NGFA 

representative(s) reviewed the ICR supporting statement 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. Requirements 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

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 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. The retention of records for five years allows 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 violators due to the destruction or 
5

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, chapter 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

The 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 correspond to the North 

American Industry Classification System (NAICS) code 311119 for Other Animal Food 

Manufacturing. 

4(b) Information Requested

(i) Data Items

In 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:

Notifications

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

Notifications

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 respondents 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 information.

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 properly installed and operated. Performance 
8

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

emission standards. Data and records maintained by the respondents are tabulated and published 

for use in compliance and enforcement 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. ICIS 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 compliance 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 owner/operator for five

years.

5(c) Small Entity Flexibility

A majority of the respondents are small entities (i.e., smaller businesses). Our 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 information 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.
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6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 64,100 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development 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 $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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 activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup 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 such as photocopying and postage.

(iii) Capital/Startup vs. Operation 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 cyclone 
10

to monitor 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 of 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/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $37,200. These are the recordkeeping 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 includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution 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 $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 these standards. It is estimated that no additional 

respondents per year will become subject to these same standards. The overall average number 

of respondents, as shown in the table below, is 1,800 per year.

The number of respondents is calculated using the following table that addresses the three 
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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.

Column 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).
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6(e) Bottom Line 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 labor 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 copies 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 $36 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 assumption used to calculate O&M cost. 
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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 

resources 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 purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to 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 this ICR under 

Docket ID Number EPA-HQ-OECA-2012-0703. 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 information, 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 identified 

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 Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. 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-2012-0703 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.
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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 activities
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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 $103.97, management at $129.93, and clerical at $51.79. 

(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 requirements 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.