### 1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR

AREA SOURCES: PREPARED FEEDS MANUFACTURING

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collec tion.

“ N a tional Emission Standards for Hazardous Air Pollutants for Area Source s : Prepared

Feeds Manufacturing .” This is a new information collection request (ICR)

, and the EPA tracking

number i s 2354.01.

(b) Short Characterization.

This ICR covers i nformation collection requirements i n the final area source rule for

Prepared Feeds Manufacturing ( 40 CFR part 63, subpart DDDDDDD )

. The information

collected will be used by EPA and delegated state and local agencies to determine the

compliance status of sources subject to the rule.

The p otential respondents are owners or operators of any existing or new area source

prepared feed manufacturing facility that adds chromium compounds or manganese compounds

to their products

. A prepared feed manufacturing f acility is a facility that produces feed for

animals (other than dogs and cats). We believe there are approximately 1 ,80 0 facilities currently

operating that would be subject to National Emissions Standards for Hazardous Air Pollutants

( NESHAP ) for the Pr epared Feeds Manufacturing A rea S ource C ategory. The affected source

category is prepared feeds manufacturers (except for cat and dog food) who add chromium

compounds or manganese compounds to their product. The final standards include both

management p ractices and equipment requirements. The final management practices include

general requirements to perform housekeeping measures to minimize excess dust and to maintain

and operate all process equipment in a manner to minimize dust creation. The final r egulation

would require that all facilities with daily production rates greater than 50 tons per day install,

operate

, and maintain a capture system that collects the emissions from the pelleting operations

### 2

and conveys the collected emissions to a cyclone. This cyclone must be designed to achieve at

least 95 percent efficiency in the removal of PM. Existing area source prepared feed

manufacturers currently control particulate emissions as a result of permitting requirements,

and/or management practices al ready used by the industry to reduce particulate matter

. These

controls and management practices also result in the reduction of chromium and manganese

emissions

. We estimate that the impact s associated with the compliance requirements of the

final rule (monitoring, reporting, and recordkeeping) will average approximately $ 9 80 per

facility. The information collection requirements for existing and new sources in the Prepared

Feeds Manufacturing Area S ource C ategor y are listed in Attachment 1

.

2. Need Fo r and Use of the Collection

(a) Need/Authority for the Collection

.

Section 112 of the C lean Air Act (C AA ) require s EPA to establish NESHAP for both

major and area sources of HAP that are listed for regulation under CAA section 112(c). An area

source is a stationary source that is not a major source (i.e., an area source does not emit and does

not have the potential to emit more than 10 tons per year [ t py ] of any single HAP and more than

25 t py of any combination of HAP )

. R equirements for area sources in CAA sections 112(c) (3)

and 112(k) direct EPA to (1) identify at least 30 a ir toxics that p resent the greatest potential

health threat in the largest number of urban areas and (2) to identify sufficient area source

categories to ensure that sources represen t ing 90 percent or more of the emissions of the 30

“listed” HAP are subject to regulation . EPA implements these requirements through the

Integrated Urban Air Toxics Strategy (64 FR 38715, July 19, 1999). We added the source

category to the Integrated Urb an Air Toxics Strategy A rea S ource C ategory list on November 22,

2002 (67 FR 70427)

. Regulation of p repared feeds manufacturing is necessary for EPA to meet

the 90 percent requirement for chromium compounds and manganese compounds. Both of these

HAP meta ls are on the list of 30 HAP identified in the 1999 strategy.

Under CAA section 112(d)(5), EPA may elect to promulgate HAP standards for area

sources based on the use of generally available control technology or management practices (i.e.,

“GACT”) used by the sources

. EPA can consider costs and economic impacts in determining

GACT, which is particularly important when developing regulations for source categories that

### 3

may have few establishments and many small businesses, or when determining whether

additi onal control is needed for sources that are already well

- controlled as a result of other air

emissions standards.

Certain records and reports are nec essary for the Administrator to confir m the compliance

status of area sources

, identify any new or reconst ructed s ources subject to the standards, and

confirm that the standards are being achieved on a continuous basis. These recordkeeping and

reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C.

7414) and set out i n the part 63 NESHAP General Provisions

. The recordkeeping and reporting

requirements for t itle V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63

and 70 or 71, the owner or operator must keep each record for 5 years following the dat e of each

occurrence, measurement, maintenance, corrective action, report, or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority ( s tate agency

, or Regional

Administrator if there is no delegated s tate agency) t o ensure that the standards and other

requirements are being achieved. Based on review of the recorded information at the site and the

reported information, the delegated permitting authority can identify facilities that may not be in

compliance and decid e which facilitie s, records, or processes may need inspection

.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA ’ s ongoing ICRs revealed no duplication of information

gathering efforts

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

This section is not applicable because this is a rule

- related ICR.

(c) Consultations.

The final rule w as developed in consultation with individual companies and trade

organizations . The key non

- EPA persons consulted on the information collection activities are

identified in Table 1.

### 4

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Email address /Phone Number

Lauren Barker ADM Alliance Nutrition Lauren_Barker@admworld.com

John Jones Cargill Animal Nutrition john_d_jones@cargill.com

Keith Epperson American Feed Industry Assoc. (AFIA) 703

- 558

- 3568

Rebecca Ranck W egner Feeds 717

- 361

- 4269

Gary Brown Flint River Mills, Inc. brownge@f

- r

- m.com

Mark Willhite DeKalb Feeds Inc. markwillhite@dekalbfeeds.com

Mike Murphy DeKalb Fe eds Inc. mikemurphy@dekalbfeeds.com

James D. Seley Feed Commodities, L.L.C. jseley@feedcomm.com

Gary Zurinski Quality Liquid Feeds gary@qlf.com

David Parker Koch Foods davpar@kochfoods.com

Ron Krebs Airlance rkrebs@airlance.com

Bob Orr Bateman B ob.orr@bateman

- bet.com

Don Lear Kice Industries dlear@kice.com

Bruce Dokurno Differential Pressure Plus 203

- 481

- 2545

Omega Engineering Inc. www.Omega.com

Dwyer Instruments www.dwyer

- inst.com



### (d) Effects of Less Frequent Collection.

If the relevant information were collected less frequently, the delegated permitting

authority (State or EPA) w ill not be reasonably assured that a facil ity is in compliance with the

standards.

(e) General Guidelines

.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is made will

be safeguarded acc ording to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart

B

-- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976;

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR

176 74, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive

nature.

### 5

4. The Respondents and the Information Requested

(a) Respondents/NAIC S Codes

.

Potential respondents under Su bpart DDDDDDD are owners or operators of any existing

or new area source prepared feed manufacturing facility that adds chromium or manganese to

their products . The North American Industry Classification System (NAICS) code for Prepared

Feeds Manufacturin g is 31 111 9 . We estimate that approximately 1 ,80 0 area source facilities will

be subject to the NESHAP; no new area sources are projected during the 3 year period of this

ICR.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirem ents. Attachment 1

, Information

Requirements, summarize s the data items, including recordkeeping and reporting requirements

,

for the Prepared Feeds Manufacturing Area Source NESHAP

.

S ources would be required to us e 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.

Also, regulatory agencies in cooperati on with the respondents continue to create reporting

systems to transmit data electronically. However, electronic reporting systems are still not

widely used and we estimate that only a small percentage currently use electronic reporting

systems.

(ii) Respondent Activities. The respondent activities that will be required by the final

Prepared Feeds Manufacturing Area Source NESHAP are identified in Table 2 (located at the

end of this supporting statement) an d are introduced in section 6(a).

5. The Info rmation Collected

– Agency Activities, Collection Methodology, and

Information Management

(a) Agency Activities.

The Agency activities associated with the final Prepared Feeds Manufacturing Area

Source NESHAP are provided in Table 3 (located at the end of t his supporting statement) and are

introduced in section 6(c).

### 6

(b) Collection Methodology and Management

.

Data and records maintained by the respondents are tabulated and published for use in

compliance and enforcement programs of the delegated permitting authority . The notific ations

of compliance status and annual compliance certifications required under the final rule are used

for problem identification, as a check on source operation and maintenance, and for compliance

determinations. EPA is the permi tting authority until the s tate agency is delegated authority to

implement the final rule. Therefore, i nformation contained in the reports submitted to the

Regional Administrator will be entered into the Air Facility System (AFS), which is operated and

ma intained by EPA ’ s Office of Compliance. AFS is EPA’s database for the collection,

maintenance, and retrieval of compliance data for approximately 125,000 industrial and

government

- owned facilities. EPA uses the AFS for tracking air pollution compliance a nd

enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters.

EPA and its delegated a uthorities can edit, store, retrieve and analyze the data.

(c) Small Entity Flexibility.

The Small Business Administration defines a small entity as one that meets the Small

Business Administration size standards for small busi nesses found at 13 CFR 121.201 as one

having less than 5 0 0 employees for NAICS 3 1 111 9

. We estimate that a significant portion of the

facilities are small entit ies. However, o ur analysis indicates that the final rule would not impose

a significant adverse impact on any facilities, large or small

, since these costs are less than 0.1

percent of revenues.

(d) Collection Schedule

.

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

shown in Table 3 for Prepared Feeds Manufacturing Area Source Category

.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the f inal Prepared Feeds Manufacturing Area Source

NESHAP are shown in Table 2

. These numbers were derived from estimates based on EPA’s

experience with other standards. No burden estimates are provided for new area sources because

no new facilities are expec ted to become affected sources during the 3

- year period of this ICR.

### 7

(b) Estimating Respondent Costs.

The information collection activities for the final Prepared Feeds Manufacturing Area

Source NESHAP are presented in Table 2

. Because the data are al ready collected by respondents

as part of normal operations

, no respondent development costs are associated with the

information collection activities.

(i) Estimating Labor Costs

. We used May 200 7 labor rates from the Bureau of Labor

Statistics for Anima l Food Manufacturing (NAICS 311 1 00)

. 1 

### Wages for occupational groups are

used as the basis for the labor rates with hourly rates of $32.10/hour for technical, $35.64/hour

for managerial, and $14.65/hour for clerical. To these rates we added fringe benefit s calculated

at 29 percent of hourly earnings and an overhead rate of 110 percent. The fully

- burdened hourly

wage rates used to represent respondent labor costs are: technical at $82.65, management at

$96.55, and clerical at $38.9 4. Loading factors (i. e., fringe benefits and overhead rates) were

calculated using methodologies referenced in promulgated regulations and their accompanying

Information Collection Requests (ICRs), particularly those used in New Source Review (NSR)

regulations.

(ii) Estima ting Capital and Operations and Maintenance (O&M) Costs

. The final

Prepared Feeds Manufacturing Area Source NESHAP would require that every existing and new

facility 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 to monitor inlet flow rate, inlet velocity, pressure drop, or amperage. We estimate

that none of the 1,284 facilities with daily production le vels greater than 50 tons per day already

have the required monitoring equipment. Therefore, all would be required to purchase and

operate monitoring equipment. We estimate that a monitoring device could be purchased for

$ 295 (based on the average of the costs obtained from Dwyer, Differential Pressure Plus, and

Omega)

. We assumed an annual operation and maintenance of 10 percent of the initial capital

cost, or $ 2 9 per year. Therefore, the annual operation and maintenance costs would be $ 37, 236

per year for the 1,284 facilities. These costs would only be incurred in the 3 rd 

### year of the period.

1 May 2006 National Industry

- Specific Occupational Employment and Wage Estimates. Located

http://www.bls.gov/oes/current/naics4_331100.htm

### 8

(i ii ) Annualizing Capital Costs

. These capital costs were annualized assuming an

interest rate of 7 percent and a life of 15 years, resulting in an annualized capital cost of $ 32 per

year per facility . The total annualized capital cost for all 1,284 facilities would be $ 41,088 per

year

.

(c) Estimating Agency Burden and Cost

.

Because the information collection requirements were developed as an incidental par t of

standards development, no costs can be attributed to the development of the information

collection requirements. Because reporting and recordkeeping requirements on the part of the

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the

part 63 NESHAP General Provisions, no operational costs w ill be incurred by the Federal

Government. Publication and distribution of the information are part of the Compliance Data

System, with the result that no Federal costs ca n be directly attributed to the ICR. Examination

of records to be maintained by the respondents will occur incidentally as part of the periodic

inspection of sour ces that is part of EPA’ s overall compliance and enforcement program, and,

therefore, is not attributable to the ICR. The only costs that the Federal government w ill incur

are user costs associated with the analysis of the reported information, as presented in Table 3

.

The Agency labor rates are from the Office of Personnel Management (OPM) 200 7

General Schedule which excludes locality rates of pay. These rates can be obtained from Salary

Table 200 7

- GS available on the OPM website, http://www.opm.gov/oca/07tables/html/gs_h.asp

.

The go vernment employee labor rates are $14. 60 /hour for clerical (GS

- 6, Step 3), $2 6

. 98 for

technical (GS

- 12, Step 1), and $3 6

. 36 /hr for management (GS

- 13, Step 5). These rates were

increased by 60 percent to include fringe benefits and overhead. The fully

- bur dened wage rates

used to represent Agency labor costs are: clerical at $ 23.36 ; technical at $ 43.17 , and

management at $ 58.18

.

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

.

There are an estimated 1 ,80 0 existing facilities that will be subject to the Prepared Feeds

Manufacturing Area Source NESHAP

. No new sources are expected during the next 3 years.

Consequently, the average annual number of prepared feed facilities estimated during the 3

- year

period of this ICR is 1,800.

### 9

For the fin al Prepared Feeds Manufacturing Area Source NESHAP , the components of

the total annual responses attributable to this ICR in the first three years are one

- time initial

notifications and one

- time notifications of compliance status for the 1 ,80 0 facilities t hat will be

subject to the rule.

T he number of total annual responses for subpart DDDDDDD is estimated a t 1,200. This

is the number of initial notifications and notifications of compliance for each of the 1,800

facilities (3,600) divided by the three ye ar period of the ICR.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in

Table 2 are calculated by adding person

- hours per year down each column for technical,

managerial, and clerical staff, and by adding down the cost column

. The average annual burden

for the recordkeeping and reporting requirements in subpart DDDDDDD for the 1,800 existing

facilities that are subject to the Prepared Feeds Manufacturing A rea S ource NESHAP is 12

person

- hours

, with an annual labor average cost of around $ 98 0 , which includes annualized

capital costs and O&M costs of around $ 61

.

(ii) The Agency tally. The average annual Federal Go vernment cost is $ 48 for 1 hour for

subpart DDDDDDD

. The bot tom line Agency burden hours and costs presented in Table 3

(located at the end of this supporting statement) are calculated by adding person

- hours per year

down each column for technical, managerial, and clerical staff, and by adding down the cost

column.

(iii) Variations in the annual bottom line. This section does not apply since no

significant variation is anticipated.

(f) Reasons for Change in Burden.

We are requesting an increase in burden of 387 hours due to implementation of this new

regulation

.

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 1 hour per response. The average annual respondent burden for the final

Prepared Feeds Manufactu ring Area Source NES HAP is estimated at 15 hours per year

.

### 10

Burden means the total time, effort, or financial resources expended by persons to

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This

includes the time needed to review in structions; 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

c omply 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 informa tion.

An 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. The OMB

control numbers for EPA ’ s regulations in 40 CFR part 63 are listed in 40 C FR part 9.

To comment on the Agency’s need for this information

, the accuracy of the provided

burden estimates, and any suggestions for minimizing respondent burden, including the use of

automated collection techniques, EPA has established a public docket for this ICR under Docket

ID No. EPA

- HQ

- OAR

- 200 8

- 0 0 80

, which is available for online viewing at

http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and

Information Center in the EPA D ocket Center (EPA/DC), EPA 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 R oom is (202) 566

- 1744, and the telephone number for the

Air Docket is (202) 566

- 1 742

. An e lectronic version of the public do cket is available at

http://www.regulations.gov. This site can be used to submit or v iew public comments, access the

index listing of the contents of the public 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 s identified abo ve. Also, you can send comments to the Office of Information

and Regulatory Affairs, Office of Management and Budget, 725 17 th 

### Street, NW, Washington,

DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number

( EPA

- HQ

- OAR

- 200 8

- 0 080 ) in any c orrespondence.

### 11

PART B

This section is not applicable because statistical methods are not used in data collection

associated with the final rule

.

### 12

TABLE 2A. Year 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREM ENTS OF THE PROPOSED STANDARD

(A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Respondents Technical Management Clerical Cost,$ (a)

hours per occurrences per respondent per year person

- hours person

- hours person

- hours

occurrence per respondent per year per year per year per year

per year (C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications

2. Survey and Studies

3. Acquisition, Installation, & Utilization of

Tech. & Systems

4. Reporting Requirements

A. Read instructions (b) 1.00 1.0 1.0 1800.0 1800.0 90.0 180.0 $ 164,471

B. Required activities

i. Quarterly control equipment inspection 1.00 4 4.0 0 0 0 $

-

ii. Daily cyclone performance measures 0.10 365 36.5 0 0 0 $

-

C. Create information

D. Gather existing information

E. Write report

Initial Notification (b) 0.50 1.0 0.5 1800.0 900.0 45.0 90.0 $ 82,236

Notification of Compliance Status (c) 1.00 1.0 1.0 0.0 0.0 0.0 0.0 $

-

Annual Compliance Certification (c) 1.00 1.0 1.0 0.0 0.0 0.0 0.0 $

-

5. Recordkeeping Requirements

A. Read i nstructions

B. Plan activities

C. Implement activities

D. Develop record system

E. Time to enter information

F. Time to train personnel

G . Time to tr ansmit or disclose information 0.10 1.0 0.1 0.0 0.0 0.0 0.0 $

-

I. Time for audits

TOTAL ANNUAL BURDEN AND COST (SALARY) 2700.0 135.0 270.0 $ 246,707

TOTAL ANNUAL NUMBER OF RESPONSES (i) 1,800

A NNUAL CAPITAL COSTS: 0.00 $

-

ANNUALIZED CAPITAL COSTS:

Total annualized capital 0.00 $

-

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $

-

(a) Costs are based on the following hourly rates: technical at $82.65, management at $96.55, and clerical at $38.94.

(b) One

- time activity. There are an estimated 1,800 existing facilities and no new facilities are expected.

(c) Two ye ars proposed to comply with rule means year three for the Notification of Compliance Status and no Annual Compliance Certific ations during the period.

### 13

TABLE 2B. Year 3 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQ UIREMENTS OF THE PROPOSED STANDARD

1 There are no requirements for year 2 so the burden is zero.

(A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Respondents Technical Management Clerical Cost,$ (a)

hours per occurrences per respondent per year person

- hours person

- hours person

- hours

occurrence per respondent per year per year per year per year

per year (C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications

2. Survey and Studies

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

. 4. Reporting Requirements

A. Read instructions (b) 1.00 1.0 1.0 0.0 0.0 0.0 0.0 $

-

B. Required activities

i. Monthly control equipment inspection 1.00 4 4.0 1,284 5136.0 257 514 $469,292

ii. Daily cyclone performance measures 0.10 365 36.5 1,284 46866.0 2,343 4,687 $4,282,288

C. Create information

D. Gather existing information

E. Write report

Initial Notification (b) 1.00 1.0 1.0 0.0 0.0 0.0 0.0 $

-

Notification of Compliance Status (c) 1.00 1.0 1.0 1800.0 1800.0 90 180 $ 164,471

Annual Compliance Certification (c) 1.00 1.0 1.0 0.0 0.0 0.0 0.0 $

-

5. Recordkeeping Re quirements

A. Read instructions 0.50 1.0 0.5 516.0 258.0 13 26 $23,574

B. Plan activities

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)

I. Time for audits 0.10 1.0 0.1 1800.0 180.0 9.0 18.0 $ 16,447

TOTAL ANNUAL BURDEN AND COST (SALARY) 54240.0 2712.0 5424.0 $ 4,956 ,073

TOTAL ANNUAL NUMBER OF RESPONSES 1,800

ANNUAL CAPITAL COSTS:

ANNUALIZED CAPITAL COSTS: (e)

Total annualized capital (f) 0.00 $ 41, 529

Total annua l O&M (f) $37,825

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) (e) $79,354

(a) Costs are based on the following hourly rates: technical at $82.65, management at $96.55, and clerical at $38.94.

(b) One

- time activity completed during ye ar one.

(c) One

- time activity. Two years proposed to comply with rule means year three for the Notification of Compliance Status and no Annu al Compliance Certifications during the period.

(d) Information related to requirements under 4B.

(e) monitoring device

- $ 295 each capital, # = 1,284

- to monitor cyclone performance

. (f) Annualized cost of monitoring device

- $32/year, # = 1,284 (7%. 15 years). O&M

– 10% of capital cost/year

- $29, #

- 1,284.

### 14

TABLE 3. ANNUAL BURD EN AND COST TO THE FEDERAL GOVERNMENT OF THE PROPOSED STANDARDS

(A) (B) (C) (D) (E) (F) (G) (H)

EPA

person

- No. of EPA

person

- Plants Technical Management Clerical Cost,$ (a)

hours per occurrences hours per per person

hours person

hours person

occurrence per plant plant per year per year per year hours

per

per year year (E=CxD) (Ex0.05) year

Activity (C=AxB) (Ex0.1)

Report Review

Initial Notification (b) 1.0 1.0 1.0 600.0 600.0 30.0 60.0 $29,048

Notification of Compliance Status (c) 2.0 1.0 2.0 600.0 1200.0 60.0 120.0 $58,095

Annual Compliance Certification (d) 2.0 1.0 2.0 0.0 0.0 0.0 0.0 $0

$0

TOTAL BURDEN AND COST (SALARY) 1800.0 90.0 180.0 $87,143

(a ) Costs are based on the following hourly rates: technical at $43.17, management at $58.18, and clerical at $23.36.

Management person

- hours and clerical person

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

- hours,

respectively.

(b) All 1,800 plants will submit the initial notification, leading to an average annual burden of 3 plants/yr.

(c) All 1,800 plants will submit the notification of compliance status, leading to an average annual burden of 3 plants/yr.

(d) All no p lants will submit an annual compliance certification during the period since they have two years to comply.

Total

hours 2,070

### 15

ATTACHMENT 1. INFORMATION REQUIREMENTS

-- NESHAP FOR PREPARED FEEDS MANUFACTURING AR EA SOURCES

Requirement Citation for existing sources Citation for new sources General Provisions citation

Monitoring §63.11622 §63.11622 N/A

Notifications

Notification of applicability §63.1164(a)(1) §63.1164(a)(1) 40 CFR 63.9( b )(2)

Notification of construction/reconstruction N/A N/A 40 CFR 63.9(b)(5)

Notification of special compliance requirements N/A N/A 40 CFR 63.9(d)

Notification of compliance status §63. 11624(a)(2) §63. 11624(a)(2) 40 CFR 63.9(h)

Notification of changes in information N/A N/A 40 CFR 63.9(j)

Plans N/A N/A N/A

Records

Records of notifications §63. 11624(c)(1) §63. 11624(c)(1) 40 CFR 63.10

Records that demonstrate continuous compliance §63. 11624(c)(2)

– (5) §63. 11624(c)(2)

– (5) 40 CFR 63.10

Monitoring information §6 3. 11624(c)(5) §63. 11624(c)(5) 40 CFR 63.10

Reports

CMS performance evaluation/report N/A N/A 40 CFR 63.8(e)(5)

SSM reports N/A N/A 40 CFR 63.6(e)(3)

Excess emissions reports N/A N/A 40 CFR 63.10(e)(3)

Annual compliance certifications §63. 11624(b ) §63. 11624(b) N/A