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 Collection.

“National Emission Standards for Hazardous Air Pollutants for Area Sources: Prepared 

Feeds Manufacturing.” This is a new information collection request (ICR), and the EPA tracking 

number is 2354.01.

(b) Short Characterization.

This ICR covers information collection requirements in 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 potential 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 facility is a facility that produces feed for 

animals (other than dogs and cats). We believe there are approximately 1,800 facilities currently 

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

(NESHAP) for the Prepared Feeds Manufacturing Area Source Category. 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 practices 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 regulation 

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 already 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 impacts associated with the compliance requirements of the 

final rule (monitoring, reporting, and recordkeeping) will average approximately $980 per 

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

Feeds Manufacturing Area Source Category are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires 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 [tpy] of any single HAP and more than 

25 tpy of any combination of HAP). Requirements for area sources in CAA sections 112(c)(3)

and 112(k) direct EPA to (1) identify at least 30 air toxics that present the greatest potential 

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

categories to ensure that sources representing 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 Urban Air Toxics Strategy Area Source Category list on November 22, 

2002 (67 FR 70427). Regulation of prepared feeds manufacturing is necessary for EPA to meet 

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

HAP metals 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 

additional control is needed for sources that are already well-controlled as a result of other air 

emissions standards.

Certain records and reports are necessary for the Administrator to confirm the compliance 

status of area sources, identify any new or reconstructed sources 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 in the part 63 NESHAP General Provisions. The recordkeeping and reporting 

requirements for title 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 date 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 (state agency, or Regional 

Administrator if there is no delegated state agency) to 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 decide which facilities, 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 informationgathering 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 was 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 Wegner 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 Feeds 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 Bob.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) will not be reasonably assured that a facility 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 according 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 

17674, 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/NAICS Codes.

Potential respondents under Subpart 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 Manufacturing is 311119. We estimate that approximately 1,800 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 Requirements. Attachment 1, Information 

Requirements, summarizes the data items, including recordkeeping and reporting requirements, 

for the Prepared Feeds Manufacturing Area Source NESHAP.

Sources would be required to use 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 cooperation 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) and are introduced in section 6(a).

5. The Information 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 this 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 notifications 

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 permitting authority until the state agency is delegated authority to 

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

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

maintained 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 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.

(c) Small Entity Flexibility.

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

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

having less than 500 employees for NAICS 311119. We estimate that a significant portion of the 

facilities are small entities. However, our 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 final 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 expected 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 already 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 2007 labor rates from the Bureau of Labor 

Statistics for Animal Food Manufacturing (NAICS 311100).

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 benefits 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 $38.94. 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) Estimating 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 levels 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 $29 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 3rd 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

(iii) 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 part 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 will 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 can 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 sources 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 will 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) 2007

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

Table 2007-GS available on the OPM website, http://www.opm.gov/oca/07tables/html/gs_h.asp.

The government employee labor rates are $14.60/hour for clerical (GS-6, Step 3), $26.98 for 

technical (GS-12, Step 1), and $36.36/hr for management (GS-13, Step 5). These rates were 

increased by 60 percent to include fringe benefits and overhead. The fully-burdened 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 1,800 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 final 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 1,800 facilities that will be 

subject to the rule.

The number of total annual responses for subpart DDDDDDD is estimated at 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 year 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 Area Source NESHAP is 12 

person-hours, with an annual labor average cost of around $980, which includes annualized 

capital costs and O&M costs of around $61.

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

subpart DDDDDDD. The bottom 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 Manufacturing Area Source NESHAP 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 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 currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR 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-2008-0080, 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 Docket 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 Room is (202) 566-1744, and the telephone number for the 

Air Docket is (202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view 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 Numbers identified above. 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 relevant Docket ID Number 

(EPA-HQ-OAR-2008-0080) in any correspondence.
11

PART B

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

associated with the final rule.
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TABLE 2A. Year 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS 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 instructions

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 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 

ANNUAL 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 years proposed to comply with rule means year three for the Notification of Compliance Status and no Annual Compliance Certifications during the period. 
13

TABLE 2B. Year 3 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS 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 Requirements

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 annual 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 year one.

(c) One-time activity. Two years proposed to comply with rule means year three for the Notification of Compliance Status and no Annual 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.
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TABLE 3. ANNUAL BURDEN 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

personhourspersonhours personoccurrence 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 plants will submit an annual compliance certification during the period since they have two years to comply.

Total 

hours

 

2,070 
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ATTACHMENT 1. INFORMATION REQUIREMENTS--NESHAP FOR PREPARED FEEDS MANUFACTURING AREA 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 §63. 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