## 1 

# SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Standards of Performance for Grain Elevators

(40 CFR part 60, Subpart DDa )

January 2014

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1 (a) Title of the Information Collection

“ Recordkeeping and Reporting Requirements for Grain Elevators (40 CFR Part 60,

Subpart DDa).” The EPA ICR tracking number is 2497.01

.

1 (b) Characterization of Information Collection

The New Source Performance Standards (NSPS) for grain elevators (40 CFR part 60,

subpart DD) were promulgated on August 3, 1978. This information collection request is for a

new subpart DDa, which will apply to grain elevators which commence construction,

modification, or reconstruction after the date of proposal. Particulate matter (PM) is the pollutant

regulated under this subpart. The grain elevators NSPS regulates affected facilities at grain

storage elevators and grain terminal elevators storing corn, wheat, sorghum, rice, rye, oats,

barley, and soybeans constructed or modified after August 3, 1978. Affected facilities at grain

elevators include grain handling equipment, grain dryers, and grain loading and unloading

facilities (for trucks, railcars, and barges/ships). This information is being collected to assure

compliance with 40 CFR part 60, subpart DDa.

In general, all NSPS standards require initial notifications, performance tests, and

periodic reports. Owners or operators are also required to ma intain records of the occurrence and

duration of any startup, shutdown, or malfunction in the operation of an affected facility. These

notifications, reports, and records are essential in determining compliance, and are required of all

sources subject to N SPS. This information collection request documents the additional

recordkeeping and reporting burden due to the proposed subpart DDa only, burden which

facilities already incur due to subpart DD is not included. The additional requirements include

opacity testing

, PM testing, weekly visual inspections, and fabric filter inspections

.

Any owner or operator subject to the provisions of this part shall maintain a file of these

measurements, and retain the file for at least 2 years following the date of such me asurements,

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 United

States Environmental Protection Agency (EPA) r egional office.

This ICR presents the burden to respondents and the Designated Administrator (State or

Federal Government) that will be imposed by the plans developed to implement the standards of

## 2

performance for new grain elevators . Respondents are owner s or operators of new or modified

grain elevators

.

The requirements described below are the minimum requirements established by the

standards of performance for grain elevators . Although the Designated Administrator may

choose to impose more stringent req uirements, it is assumed for this burden estimate that the

implemented plans mirror the NSPS.

Potential respondents are owners or operators of new, reconstructed, or modified grain

elevators. It is estimated that an additional 2 newly constructed grain elevators with 22 affected

facilities and 7 1 modified or reconstructed grain elevators with 113 affected facilities will

become subject to the regulation in the next three years. The cost of this Information Collection

Request (ICR) , based on these 7 3 grain elevators , will be $1. 1 million

.

The burden to the “Affected Public” for each grain elevator may be found in Tables 1

- 4

in Attachment 1 . The burden to the “ Designated Administrator ” is attributed entirely to work

performed by f

ederal employees or government contractors; this burden may be found in Tables

5

- 8 of Attachment 2

.

2. NEED FOR AND USE OF THE COLLECTION

2 (a) Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to

establish standards of performance for new stationary sources that reflect :

. . . application of the best system of emission reduction which

(taking into account the cost of achieving such reduction and any

non

- air quality health and environme ntal impact and energy

requirements) the Administrator determines has been adequately

demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best system of emission reduction (BSER).

Section 111 also requires that the Administr ator review and, if appropriate, revise such standards

every eight years.

In addition, section 114(a) states that the Administrator may require any owner or

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

## 3 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, PM emissions from grain elevators cause or contribute

to air pollution that may reasonably be anticipated to endanger public health or welfare.

Therefore, the NSPS will be proposed for this source category at 40 CFR part 60, subpart DDa.

2 (b) Use / Users of the Data

The information will be used by Designated Administrators' enforcement personnel to

ensure that the requirements of the State (or Federal) plan are being implemented and are

complied with on a continuous basis. Specifically, the information will be used by the

Designated Administrator to: (1) identify new, modified, and reconstructed sources subject to the

NSPS; (2) ensure that the NSPS is being properly applied; and (3) ensure that the emission limits

are being complied with.

In addition, records and reports are necessary to enable the Designated Administrator to

identify grain elevators that may not be in compliance with the NSPS. Based on reported

information, the Designated Administrator will decide which facilities should b e inspected and

what records or units should be inspected at the facilities. The records that grain elevators

maintain will indicate to the Designated Administrator whether facility personnel are properly

operating and maintaining the incinerator and contr ol equipment and whether facility personnel

have met the qualification requirements.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

The requested recordkeeping and reporting will be required under (40 CFR part 60,

subpart DDa ).

3 (a) N onduplication

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 their 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 prior to ICR submission to OMB

This section is not applicable because this is a rule related ICR.

3 (c) Consultations

## 4

During development of the proposed revisions, EPA held meetings and conference calls

with a coalition representing grain elevator owners and operato r s. We estimate that

approximately 7 3 grain elevators will be constructed, modified, or reconstructed, or expanded

over the next 3 years.

3 (d) Effects of Less Frequent Data Collection

The NSPS require initi al and peri odic performance tests and weekly visual monitoring

. The frequency of these activities was chosen by EPA as the period that will provide an adequate

margin of assurance that affected facilities will not operate for extended periods in violation of

the NSPS.

Less frequent information collection would dec rease the margin of assurance that plants

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 likelihood of detecting poor 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.

3 (f) Confidentiality

Some respondents may consider grain throughput data to be confidential. Any such

infor mation 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/NAICS Codes

The respondents to the recordkeeping and reporting requirements are grain elevators. The

North American Industry Classification System (NAICS) code for respondents affected by the

standards are 49313 (grain elevators, storage), and 424510 (grain elevators, merchants and

wholesalers).

## 5

Based on the assumed distribution of new or modified facilities

, there are 7 3 grain

elevators which will be affected. Of these, 100 percent are assum ed to be located in the private

sector.

4 (b) Information Requested

(i) Data Items , Including Recordkeeping Requirements.

All data in this ICR that is recorded and/or reported is required by the NSPS for Grain

Elevators (40 CFR part 60, subpart DDa).

A source must make the following reports:

Reports for 40 CFR part 60, subpart DDa

Notification of construction or modification application 60.6(a)

Notification of construction/reconstruction 60.7(a)(1)

Initial notifications 60.7(a)(3)

Notification of actual startup 60.7(a)(3)

Physical or operational change 60.7(a)(4)

Notification of demonstration of continuous monitoring system 60.7(a)(5)

PM and opacity test results 60.8(a) , 60.30 6 a(a)

, 60.30 6 a(b)

Compliance status 60.7(a)(7)

Malfunction report 60.7(b)

, 60.30 6 a(d)

A source must maintain the following records:

Records for 40 CFR part 60, subpart DDa

Records are required to be retained for two (2) years 60.7(f)

Records of ongoing monitoring 60.7(f)

Records of grain storage capacity and annual throughput 60.30 5 a(a) and (b)

Physical or operational change 60.7(a)(4)

Notification of demonstration of continuous monitoring system 60.7(a)(5)

Initial performance test results 60.8(a)

Records of visual inspections 60.30 5 a( e )

Records of baghouse and fabric filter inspections 60.30 5 a(d)

Records of opacity tests 60.30 5 a(f)

Records when an affected source failed to meet the standard 60.30 5 a(c)

(ii) Respondent Activities

The respondent activities required by subpart DD a are listed in the following table.

Respondent Activities

## 6

Read instructions

Write the notifications and reports listed above

Enter information required to be recorded above

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

Transmit or otherwise disclose the information

This ICR captures the additional costs due to the proposed NSPS subpart DDa, as

compared to the requirements of NSPS subpart DD. The additional activities include conducting

opacity tests, PM tests, weekly visual inspections, and fabric filter inspections. Opacity tests

must be conducted for affected dryers, grain loading stations, grain unloading stations, and grain

handling operations, PM and opacity tests must be conducted for facilities that exceed the

storage capacity threshold due t o the use of temporary storage facilities.

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

Observe opacity and PM test s

. Review notifications and reports, including performance test reports, and excess emissions

reports, required to be submitted by industry.

5 (b) Collection Methodology and Management.

Following notification of startup, the reviewing authority might inspect the source to

determine whether the pollution control devices are properly installed and operated. Performance

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

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

for use in compliance and enforcement programs. The reports of noncompliance are used for

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

determinations.

Information contained in the reports is entered into the AIRS Facility Subsystem (AFS)

which is operated and maintained by EPA’s Office of Compliance. AFS is EPA’s database for

the collection, ma intenance, and retrieval of compliance and annual emission inventory data for

over 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 region al

offices, and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve, and

analyze the data.

## 7

The records required by this regulation must be retained by the owner or operator for two

years.

5(c) Small Entity Flexibility

In the proposed rule, we have provided flexibility to all grain elevators, including small

entities, by requiring only the minimum frequency of testing, and recordkeeping and reporting

that will also ensure compliance with the rules. The rule does not require mon itoring equipment

that would result in capital and operating costs, but instead proposes visual inspection of

equ ipment at the minimum frequencies needed to ensure compliance.

5 (d) Collection Schedule

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

shown in Tables 1 through 3 : Annual Respondent Burden and Cost of Recordkeeping and

Reporting Requirements for the NSPS for Grain Elevator s (40 CFR Part 60, Subpart DDa) for

the first three years of the information collection

.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 through 3 : Annual Respondent Burden and Cost of Recordkeeping and

Reporting Requirements for the NSPS for Grain Elevator s (40 CFR Part 60, Subpart DDa)

document the computation of individual burdens for the recordkeeping and reporting

requirements applicable to the industry for each of the first 3 years. Table 4 contains a summary

of the respondent burden costs and hours de tailed in Tables 1 through 3

.

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 ident ified; 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.

6 (a) Estimating Respond ent Burden

The baseline population of 7 3 new or modified grain elevators is based upon past growth

in consideration with the requirements of the NSPS rule

.

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

and reporting requirements is estimated to be 3, 3 00 hours. These hours are based on Agency

studies and background documents from the development of the regulation, Agency knowledge,

and experience with the NSPS program, and any comments received.

6 (b) Estimating Respondent Costs

## 8

The information collection activitie s for sources subject to these requirements are

presented in Tables 1 through 3 of Attachment 1

. The total cost for each respondent activity

includes labor costs, capital/startup costs, and operating and maintenance (O&M) costs.

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $ 78.06 ($ 37.17 + 110%)

Technical $ 30.28 ($ 14.42 + 110%)

Clerical $ 26.75 ($ 12.74 + 110%)

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

May 2011, “National Industry

- Specific Occupational Employment and Wage Estimates, NAICS

424500 .” The rates are from column 8, mean hourly wage. The rates have been incr eased by 110

percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Start

- up and Operation and Maintenance Costs

The type of industry costs associated with the information collection activitie s in the

grain elevator NSPS are both labor costs

, which are addressed elsewhere in this ICR

, and the

costs associated with opacity testing , PM testing, and reading the rule . The capital/startup costs

are onetime costs when a facility becomes subject to th e regulation (i.e., reading the rule) . The

annual operation and maintenance costs are the ongoing costs to perform testing and other costs

such as photocopying and postage

.

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

Below are the estimated capital and startup costs and O&M costs for the affected grain

elevators for the first 3 years after proposal

.

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

(B)

Number of

Respondents

(facilities) (C)

Total

Capital/Startup

Costs (D)

Total Annualized

Capital/Start

- up

and O&M over 3

years (E)

Average Annual

Capital/Startup

and O&M Costs

Grain Elevators 73 $13,000 $ 79 5 ,000 $ 26 5 ,000



## The total capital/startup costs for this ICR are $13,000.

The total annualized capital/startup and O&M costs for this ICR are $ 794 ,000, or an

average of $ 264 ,000 per year. These are recordkeeping costs.

## 9

6 (c) Estimating Agency Burden and Cost

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

information. The EPA's overall compliance and enforcement program includes activities such as

the examination of records maintained by the respondents, periodic inspectio n of sources of

emissions, and the publication and distribution of collected information.

The average annual agency cost during the three years o f the ICR is estimated to be

$ 5 4 ,000.

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

Man agerial $62.27 (GS

- 13, Step 5, $38.92+ 60%)

Technical $46.21 (GS

- 12, Step 1, $28.88+ 60%)

Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for

overhead and fringe benefit costs. Details on the line item estimates use d to calculate these

burdens are presented in Tables 5 through 8 of Attachment 2

.

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

The total number of respondents is also referred to as the respondent universe. The

respondent universe for this ICR is based upon past growth in consideration with the

requirements of the NSPS rule . Industry burden is calculated based on the number of units and

the anticipated controls and monitoring that each unit will most likely utilize to comply with the

p roposed NSPS

.

Additional estimates regarding the respondent universe are included in the industry

burden determination. The EPA estimates that 7 3 respondents ( grain elevators ) will read the rule

over the course of three years

, perform initial and annual opacity tests with a report

, conduct

weekly visual monitoring , and conduct fabric filter inspections

.

Total Annual Responses

(A)

Unit Type (B)

Number of

Respondents

(facilities) (C)

Total Number

Responses for 3

- year

Period (D)

Average Annual

Number of Responses

Grain Elevators 73 2 79 9 3



## The number of average annual responses is 9 3

.

6 (e) Bottom Line Burden Hours and Cost Tables

## 10

The bottom line burden hours and cost tables for both the Agency and the respondents are

attached. The annual public reporting and recordkeeping burden for this collection of

information is estimated to average 3 6 hours per response.

(i ) The Respondent Ta lly

A breakdown for each of the collection, reporting, and recordkeeping activities required

by the NSPS is presented in Tables 1 through 4 of Attachment 1

. Tables 1 , 2 , and 3 show the

costs for grain elevators in years 1, 2, and 3. Table 4 summarizes the costs for the three year

period. The estimate of total annual hours requested from the respondents was based on the

assumptions outlined in section 6(d) of this ICR. The respondent burden is estimated for the first

3 years after adoption of the NSPS by totaling the hours per year for technical, managerial, and

clerical staff at the plant. This total was then divided by 3 to arrive at the annualized burden (see

Table 4 ). A similar approach was taken for estimating annual labor costs. For the first three years

after the adoption of su bp art DDa

, it is estimated that industry would expend 3, 3 00 hours

annually at a cost of $ 1 10,000 per year to meet the monitoring, recordkeeping, and reporting

requirements. The annual non

- labor cost s are estimated at $ 260 ,000 , which include the annual

costs associated with initial and annual opacity and PM testing

.

(ii) The Designated Administrator

The bottom line Designated Administrator burden hours and costs, presented in Tables 5

through 7 of Attachment 2, were calculated by totaling the hours per year for technical,

managerial, and clerical staff, and by totaling the cost column. Table 8 of Attachment 2

summarizes the annual agency burden for each of the first three years and calculates the average

annual burden by dividing the three year total by three. The estimated average annual burden

over the first 3 years for the Design ated Administrator would be 810 hours at a cost of $ 5 4 ,000

per year.

(iii) Variations in the annual bottom line

The total responde nt costs for years 1, 2, and 3 are $ 195 ,000 , $ 345 ,000, and $ 573 ,000

. The corresponding total respondent hours over these periods are 1800

, 32 00 , and 4900 (see

Tables 1 through 4 of Attachment 1 ). Activities include reading and understanding the rule,

annu al opacity and PM testing and writing a corresponding report

, weekly visual monitoring,

fabric filter inspections, and all recordkeeping

.

During the first 3 years, the Designated Administrators will be reviewing the regulation,

observing opacity tests, an d reviewing test reports. In years 1, 2, and 3, the Designated

Administrators will expend 1 0 00

, 560 , and 870 total hours in labor, respectively. The

corresponding costs for each year are $ 54 ,000 , $ 4 2 ,000 , and $ 6 5 ,000 (see Tables 5 through 8 of

Attachment 2 ).

6 (f) Reasons for change in burden

There is no change in burden because this is a new Information Collection for subpart

## 11

DDa

.

6 (g) Burden Statement

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

is estimated to be 36 hours per response. Burden means 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 inst ructions; 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 com ply 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 informati on.

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 are listed in 40 CFR part 9 and 48 CF R 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 publ ic docket for this ICR under

Docket ID Number EPA

- HQ

- OAR

- 2010

- 0706

. 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 comm ents, 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 docum ents are also available for public viewing at the Enforcement and

Compliance 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 docket center is (202) 566

- 1927. Also, you can send comments to the Office of

Infor mation 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

- OAR

- 2010

- 0706 in any correspondence.

## 12 PART B OF THE SUPPORTING STATEMENT

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

collection associated with this regulation.

## 13 ATTACHMENT 1

TABLES 1, 2, 3, and 4

Tables 1

- 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting

Requirements for the NSPS for Grain Elevators, Subpart DDa

– Years 1

- 3

Table 4: Summary of Annual Respondent Burden and Cost of Recordkeeping and

Reporting Requirements for the NSPS for Grain Elevators, Subpart DDa

### Table 1

- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for Grain Elevators

- Subpart DDa

- Year 1

Burden Item (A)

Respondent

Hours Per

Occurrence

(Technical

hours) (B)

Non

Labor

Costs

Per

Occurre

nce (C)

Number

of

Occurren

ces Per

Responde

nt Per

Year (D)

Technic

al Hours

Per

Respon

dent Per

Year

(A x D) (E)

Number

of

Respond

ents Pe r

Year (F)

Technica

l Hours

Per Year

(D x E) (G)

Clerical

Hours

Per

Year

(F x 0.1) (H)

Managem

ent Hours

Per Year

(F x .05) (I)

Total

Labor

Costs Per

Year (J)

Total

Non

Labor

Capital

Costs Per

Year

[(B+C)xD

xF] (K)

Total

Number

of

Respon

ses Per

Year

(D x F) Footnotes

1. Applications n/a

2. Surveys and Studies n/a

3. Reporting Requirements

A. Read and Understand Rule

Requirements 5 $0 1 5 25 123 12 6 $4,515 $0 0 a

B. Required Activities

1. Opacity Test 0 $2,540 1 0 49 0 0 0 $0 $123,443 0 b

2. Visual Inspection 0.25 $0 52 13 49 632 63 32 $23,288 $0 0 b

3. Fabric Filter Inspections 1 $0 2 2 24 48 5 2 $1,769 $0 0 b

4. PM Test 1 $12,192 1 0 1 0 0 0 $0 $12,192 0 c

C. Create Information n/a

D. Gather Information n/a

E. Report Preparation

1. Opacity Test Results 5 $0 1 5 49 243 24 12 $8,957 $0 49 b

2. PM Test Results 5 $0 1 5 1 5 1 0 $184 $0 1 c

Reporting Subtotal 1,050 105 53 $38,714 $135,635 50

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3.A

B. Implement Activities n/a

C. Develop Record System n/a

D. Record Information

1. Records of Opacity Testing 2 $0 1 2 49 97 10 5 $3,583 $0 0 b

2. Records of Visual Inspection 0.17 $0 52 9 49 430 43 21 $15,836 $0 0 b

3. Records of Fabric Filter Inspections 0.5 $0 2 1 24 24 2 1 $885 $0 0 b

4. Records of PM Testing 2 $0 2 4 1 4 0 0 $147 $0 0 c

E. Personnel Training n/a

F. Time for Audits n/a

Recordkeeping Subtotal 555 55 28 $20,451 $0 0

TOTAL 1,605 161 80 $59,165 $135,635 50

a. One

- time cost for each grain elevator or affected facility, occurs in year facility is applicable.

b. Based on number of affected facilities which start compliance in year 1.

c. Based on number of facilities that exceed capacity thresholds due to use of TSF.

### Table 2

- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for Grain Elevators

- Subpart DDa

- Year 2

Burden Item (A)

Respondent

Hours Per

Occurrence

(Technical

hours) (B)

Non

Labor

Costs

Per

Occurre

nce (C)

Number

of

Occurren

ces Per

Responde

nt Per

Year (D)

Technic

al Hours

Per

Respon

dent Per

Year

(A x D) (E)

Number

of

Respond

ents Per

Year (F)

Technica

l Hours

Per Year

(D x E) (G)

Clerical

Hours

Per

Year

(F x 0.1) (H)

Managem

ent Hours

Per Year

(F x .05) (I)

Total

Labor

Costs Per

Year (J)

Total

Non

Labor

Capital

Costs Per

Year

[(B+C)xD

xF] (K)

Total

Number

of

Respon

ses Per

Year

(D x F) Footnotes

1. Applications n/a

2. Surveys and Studies n/a

3. Reporting Requirements

A. Read and Understand Rule

Requirements 5 $0 1 5 24 118 12 6 $4,331 $0 0 a

B. Required Activities

1. Opacity Test 0 $2,540 1 0 86 0 0 0 $0 $218,946 0 b

2. Visual Inspection 0.25 $0 52 13 86 1,121 112 56 $41,306 $0 0 b

3. Fabric Filter Inspections 1 $0 2 2 45 90 9 5 $3,317 $0 0 b

4. PM Test 1 $12,192 1 0 2 0 0 0 $0 $24,384 0 c

C. Create Information n/a

D. Gather Information n/a

E. Report Preparation

1. Opacity Test Results 5 $0 1 5 86 431 43 22 $15,887 $0 86 b

2. PM Test Results 5 $0 1 5 2 10 1 1 $369 $0 2 c

Reporting Subtotal 1,769 177 88 $65,209 $243,329 88

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3.A

B. Implement Activities n/a

C. Develop Record System n/a

D. Record Information

1. Records of Opacity Testing 2 $0 1 2 86 172 17 9 $6,355 $0 0 b

2. Records of Visual Inspection 0.17 $0 52 9 86 762 76 38 $28,088 $0 0 b

3. Records of Fabric Filter Inspections 0.5 $0 2 1 45 45 5 2 $1,659 $0 0 b

4. Records of PM Testing 2 $0 2 4 2 8 1 0 $295 $0 0 c

E. Personnel Training n/a

F. Time for Audits n/a

Recordkeeping Subtotal 987 99 49 $36,396 $0 0

TOTAL 2,757 276 138 $101,606 $243,329 88

a. One

- time cost for each grain elevator or affected facility, occurs in year facility is applicable.

b. Based on number of affected facilities which start compliance in year 2 plus year 1.

c. Based on number of facilities that exceed capacity thresholds due to use of TSF.

### Table 3

- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for Grain Elevators

- Subpart DDa

- Year 3

Burden Item (A)

Respondent

Hours Per

Occurrence

(Technical

hours) (B)

Non

Labor

Costs

Per

Occurre

nce (C)

Number

of

Occurren

ces Per

Responde

nt Per

Year (D)

Technic

al Hours

Per

Respon

dent Per

Year

(A x D) (E)

Number

of

Respond

ents Per

Year (F)

Technica

l Hours

Per Year

(D x E) (G)

Clerical

Hours

Per

Year

(F x 0.1) (H)

Managem

ent Hours

Per Year

(F x .05) (I)

Total

Labor

Costs Per

Year (J)

Total

Non

Labor

Capital

Costs Per

Year

[(B+C)xD

xF] (K)

Total

Number

of

Respon

ses Per

Year

(D x F) Footnotes

1. Applications n/a

2. Surveys and Studies n/a

3. Reporting Requirements

A. Read and Understand Rule

Requirements 5 $0 1 5 25 123 12 6 $4,515 $0 0 a

B. Required Activities

1. Opacity Test 0 $2,540 1 0 135 0 0 0 $0 $342,388 0 b

2. Visual Inspection 0.25 $0 52 13 135 1,752 175 88 $64,594 $0 0 b

3. Fabric Filter Inspections 1 $0 2 2 70 140 14 7 $5,160 $0 0 b

4. PM Test 1 $12,192 1 0 6 0 0 0 $0 $73,151 0 c

C. Create Information n/a

D. Gather Information n/a

E. Report Preparation

1. Opacity Test Results 5 $0 1 5 135 674 67 34 $24,844 $0 135 b

2. PM Test Results 5 $0 1 5 6 30 3 2 $1,106 $0 6 c

Reporting Subtotal 2,719 272 136 $100,219 $415,539 141

4. Recordkeeping Requirements

A. Read Instructions Inc. in 3.A

B. Implement Activities n/a

C. Develop Record System n/a

D. Record Information

1. Records of Opacity Testing 2 $0 1 2 135 270 27 13 $9,938 $0 0 b

2. Records of Visual Inspection 0.17 $0 52 9 135 1,192 119 60 $43,924 $0 0 b

3. Records of Fabric Filter Inspections 0.5 $0 2 1 70 70 7 4 $2,580 $0 0 b

4. Records of PM Testing 2 $0 2 4 6 24 2 1 $885 $0 0 c

E. Personnel Training n/a

F. Time for Audits n/a

Recordkeeping Subtotal 1,555 156 78 $57,326 $0 0

TOTAL 4,274 427 214 $157,546 $415,539 141

a. One

- time cost for each grain elevator or affected facility, occurs in year facility is applicable.

b. Based on number of affected facilities which start compliance in year 3 plus years 1 and 2.

c. Based on number of facilities that exceed capacity thresholds due to use of TSF.

### Table 4

- Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS

for Grain Elevators

- Subpart DDa

Year Technical Hours Clerical Hours Management

Hours Total

Hours Labor Costs Non

- Labor

(Annualized

Capital/Startup and

O&M) Costs Total Costs

1 1,605 161 80 1,846 $59,165 $135,635 $194,800

2 2,757 276 138 3,170 $101,606 $243,329 $344,935

3 4,274 427 214 4,915 $157,546 $415,539 $573,085

Total 8,636 864 432 9,931 $318,316 $794,503 $1,112,820

Average 2,879 288 144 3,310 $106,105 $264,834 $370,940

## ATTACHMENT 2

TABLES 5, 6, 7, and 8

Tables 5

- 7: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for

Grain Elevators, Subpart DDa

- Year s 1

- 3

Table 8: Summary of Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the

NSPS for Grain Elevators, Subpart DDa

### Table 5

- Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for

Grain Elevators

- Subpart DDa

- Year 1

Burden Item (A)

EPA hours per

occurrence (B)

Number of

occurrence

s per year (C)

Technical

Hours Per

Year

(AxB) (D)

Management

Hours Per

Year

(Cx0. 05) (E)

Clerical

Hours Per

Year

(Cx0.1) EPA

Cost Per

Year Footnotes

1. Read and Understand Rule Requirements 10 60 600 30 60 $31,095 a

2. Enter and Update Information Into Agency Recordkeeping System 2 0 0 0 0 $0 b

3. Required Activities

A. Observe Performance Test 5 10 50 3 5 $2,591 c

B. Excess Emissions Enforcement Activities 24 5 120 6 12 $6,219 d

4. Reporting Requirements

A. Review Opacity Test Reports 2 49 97.2 5 10 $5,037 e

B. Review PM Test Reports 2 1 2 0 0 $104 f

5. Travel Expenses for Tests Attended: 2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip $9,360

Total 869.2 43 87 $54,406

a. Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents).

b. Information will not need to be updated as a result of subpart DDa.

c. Assumes EPA personnel attend 20 percent of the opacity and PM tests.

d. Number of occurences is based on the assumption that of the units that test, 10% of them will have exceedances and need enfor cement.

e. Number of occurences is the number of units which must perform opacity tests.

f. Number of occurences is the number of units which perform PM tests.

### Table 6

- Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for

Grain Elevators

- Subpart DDa

- Year 2

Burden Item (A)

EPA hours per

occurrence (B)

Number of

occurrence

s per year (C)

Technical

Hours Per

Year

(AxB) (D)

Management

Hours Per

Year

(Cx0.05) (E)

Clerical

Hours Per

Year

(Cx0.1) EPA

Cost Per

Year Footnotes

1. Read and Understand Rule Requirements 10 0 0 0 0 $0 a

2. Enter and Update Information Into Agency Recordkeeping System 2 0 0 0 0 $0 b

3. Required Activities

A. Observe Performance Test 5 18 90 5 9 $4,664 c

B. Excess Emissions Enforcement Activities 24 9 216 11 22 $11,194 d

4. Reporting Requirements

A. Review Opacity Test Reports 2 86 172.4 9 17 $8,935 e

B. Review PM Test Reports 2 2 4 0 0 $207 f

5. Travel Expenses for Tests Attended: 2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip $16,848

Total 482.4 24 48 $41,848

a. Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA re gions = 60 respondents).

b. Information will not need to be updated as a result of subpart DDa.

c. Assumes EPA personnel attend 20 percent of the opacity and PM tests.

d. Number of occurences is based on the assumption that of the units that test, 10% of them will have exceedances and need e nforcement.

e. Number of occurences is the number of units which must perform opacity tests.

f. Number of occurences is the number of units which perform PM tests.

### Table 7

- Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for

Grain Elevators

- Subpart DDa

- Year 3

Burden Item (A)

EPA hours per

occurrence (B)

Number of

occurrence

s per year (C)

Technical

Hours Per

Year

(AxB) (D)

Management

Hours Per

Year

(Cx0.05) (E)

Clerical

Hours Per

Year

(Cx0.1) EPA

Cost Per

Year Footnotes

1. Read and Understand Rule Requirements 10 0 0 0 0 $0 a

2. Enter and Update Information Into Agency Recordkeeping System 2 0 0 0 0 $0 b

3. Required Activities

A. Observe Performance Test 5 28 140 7 14 $7,255 c

B. Excess Emissions Enforcement Activities 24 14 336 17 34 $17,413 d

4. Reporting Requirements

A. Review Opacity Test Reports 2 135 269.6 13 27 $13,972 e

B. Review PM Test Reports 2 6 12 1 1 $622 f

5. Travel Expenses for Tests Attended: 2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip $26,208

Total 757.6 38 76 $65,470

a. Number of occurences is the number of states where affected sources will exist and each EPA Region (50 states + 10 EPA regions = 60 respondents).

b. Information will not need to be updated as a result of subpart DDa.

c. Assumes EPA personnel attend 20 percent of the opacity and PM tests.

d. Number of occurences is based on the assumption that of the units that test, 10% of them will have exceedances and need enforcement.

e. Number of occurences is the number of units which must perform opacity tests.

f. Number of occurences is the number of units which perform PM tests.

### Table 8

- Summary of Designated Administrator Burden and Cost of Recordkeeping and

Reporting Requirements for the NSPS for Grain Elevators

- Subpart DDa

Year Technical

Hours Managemen

t Hours Clerical

Hours Total

Hours Labor Costs Non

- Labor

Costs Total Costs

1 869 43 87 1,000 $54,406 $0 $54,406

2 482 24 48 555 $41,848 $0 $41,848

3 758 38 76 871 $65,470 $0 $65,470

Total 2,109 105 211 2,426 $161,724 $0 $161,724

Average 703 35 70 809 $53,908 $0 $53,908