DDa NSPS_Supporting Statement_051314

DDa NSPS_Supporting Statement_051314.pdf

NSPS for Grain Elevators (40 part 60, supbart DDa) (Proposed Rule)

OMB: 2060-0699

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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 maintain 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 NSPS. 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 measurements,
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) regional 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
1

performance for new grain elevators. Respondents are owners 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 requirements, 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 71 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 73 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 federal 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 environmental 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 Administrator 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
2

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 be 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 control 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) Nonduplication
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

During development of the proposed revisions, EPA held meetings and conference calls
with a coalition representing grain elevator owners and operators. We estimate that
approximately 73 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 initial and periodic 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 decrease 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
information submitted to the Agency for which a claim of confidentiality is made will be
safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B
- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1,
1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR
17674, March 23, 1979).
3(g) Sensitive Questions
The reporting or recordkeeping requirements in the standard do not include sensitive
questions.
4.

THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents/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).
4

Based on the assumed distribution of new or modified facilities, there are 73 grain
elevators which will be affected. Of these, 100 percent are assumed 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
Notification of construction/reconstruction
Initial notifications
Notification of actual startup
Physical or operational change
Notification of demonstration of continuous monitoring system
PM and opacity test results
Compliance status
Malfunction report

60.6(a)
60.7(a)(1)
60.7(a)(3)
60.7(a)(3)
60.7(a)(4)
60.7(a)(5)
60.8(a), 60.306a(a),
60.306a(b)
60.7(a)(7)
60.7(b), 60.306a(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
Records of ongoing monitoring
Records of grain storage capacity and annual throughput
Physical or operational change
Notification of demonstration of continuous monitoring system
Initial performance test results
Records of visual inspections
Records of baghouse and fabric filter inspections
Records of opacity tests
Records when an affected source failed to meet the standard

60.7(f)
60.7(f)
60.305a(a) and (b)
60.7(a)(4)
60.7(a)(5)
60.8(a)
60.305a(e)
60.305a(d)
60.305a(f)
60.305a(c)

(ii) Respondent Activities
The respondent activities required by subpart DDa are listed in the following table.
Respondent Activities
5

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 to 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 tests.
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 capability 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 operation 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, maintenance, 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 regional
offices, and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve, and
analyze the data.

The records required by this regulation must be retained by the owner 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 monitoring equipment
that would result in capital and operating costs, but instead proposes visual inspection of
equipment 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 Elevators (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 Elevators (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 detailed 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 identified; responses to this information
collection are mandatory.
The Agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB Control Number.
6(a) Estimating Respondent Burden
The baseline population of 73 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 3,300 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

The information collection activities 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
Technical
Clerical

$78.06 ($37.17 + 110%)
$30.28 ($14.42 + 110%)
$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 increased 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 activities 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 the 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
(D)
(B)
(C)
(E)
Total Annualized
Number of
Total
Average Annual
Capital/Start-up
Respondents
Capital/Startup
Capital/Startup
and O&M over 3
(facilities)
Costs
and O&M Costs
years
Grain Elevators

$13,000

$795,000

$265,000

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.

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 inspection of sources of
emissions, and the publication and distribution of collected information.
The average annual agency cost during the three years of the ICR is estimated to be
$54,000.
This cost is based on the average hourly labor rates as follows:
Managerial
Technical
Clerical

$62.27 (GS-13, Step 5, $38.92+ 60%)
$46.21 (GS-12, Step 1, $28.88+ 60%)
$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 used 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
proposed NSPS.
Additional estimates regarding the respondent universe are included in the industry
burden determination. The EPA estimates that 73 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
Grain Elevators

(B)
Number of
Respondents
(facilities)

(D)
Average Annual
Number of Responses

279

The number of average annual responses is 93.
6(e) Bottom Line Burden Hours and Cost Tables

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 36 hours per response.
(i) The Respondent Tally
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 subpart DDa, it is estimated that industry would expend 3,300 hours
annually at a cost of $110,000 per year to meet the monitoring, recordkeeping, and reporting
requirements. The annual non-labor costs 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 Designated Administrator would be 810 hours at a cost of $54,000
per year.
(iii) Variations in the annual bottom line
The total respondent 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, 3200, and 4900 (see
Tables 1 through 4 of Attachment 1). Activities include reading and understanding the rule,
annual 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, and reviewing test reports. In years 1, 2, and 3, the Designated
Administrators will expend 1000, 560, and 870 total hours in labor, respectively. The
corresponding costs for each year are $54,000, $42,000, and $65,000 (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
10

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 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 are listed in 40 CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID Number EPA-HQ-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 comments, access the index listing of the
contents of the docket, and to access those documents in the public docket that are available
electronically. When in the system, select “search,” then key in the docket ID number identified
in this document. The documents are also available for public viewing at the Enforcement and
Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), 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
Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID
Number EPA-HQ-OAR-2010-0706 in any correspondence.

PART B OF THE SUPPORTING STATEMENT
This section is not applicable because statistical methods are not used in data
collection associated with this regulation.

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

1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read and Understand Rule
Requirements
B. Required Activities
1. Opacity Test
2. Visual Inspection
3. Fabric Filter Inspections
4. PM Test
C. Create Information
D. Gather Information
E. Report Preparation
1. Opacity Test Results
2. PM Test Results
Reporting Subtotal
4. Recordkeeping Requirements
A. Read Instructions
B. Implement Activities
C. Develop Record System
D. Record Information
1. Records of Opacity Testing
2. Records of Visual Inspection
3. Records of Fabric Filter Inspections
4. Records of PM Testing
E. Personnel Training
F. Time for Audits
Recordkeeping Subtotal
TOTAL

(A)
Respondent
Hours Per
Occurrence
(Technical
hours)

(B)
NonLabor
Costs
Per
Occurre
nce

(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
NonLabor
Capital
Costs Per
Year
[(B+C)xD
xF]

(K)
Total
Number
of
Respon
ses Per
Year
(D x F)

123

$4,515

0
0.25
1
1
n/a
n/a

$2,540
$0
$0
$12,192

1
52
2
1

0
13
2
0

49
49
24
1

0
632
48
0

0
63
5
0

0
32
2
0

$0
$23,288
$1,769
$0

$123,443
$0
$0
$12,192

0
0
0
0

b
b
b
c

5
5

$0
$0

1
1

5
5

49
1

243
5
1,050

24
1
105

12
0
53

$8,957
$184
$38,714

$0
$0
$135,635

49
1
50

b
c

$0
$0
$0
$0

1
52
2
2

2
9
1
4

49
49
24
1

97
430
24
4

10
43
2
0

5
21
1
0

$3,583
$15,836
$885
$147

$0
$0
$0
$0

0
0
0
0

b
b
b
c

555
1,605

55
161

28
80

$20,451
$59,165

$0
$135,635

0
50

Footnotes

Burden Item

n/a
n/a

Inc. in 3.A
n/a
n/a
2
0.17
0.5
2
n/a
n/a

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

(A)
Respondent
Hours Per
Occurrence
(Technical
hours)

(B)
NonLabor
Costs
Per
Occurre
nce

(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
NonLabor
Capital
Costs Per
Year
[(B+C)xD
xF]

(K)
Total
Number
of
Respon
ses Per
Year
(D x F)

118

$4,331

0
0.25
1
1
n/a
n/a

$2,540
$0
$0
$12,192

1
52
2
1

0
13
2
0

86
86
45
2

0
1,121
90
0

0
112
9
0

0
56
5
0

$0
$41,306
$3,317
$0

$218,946
$0
$0
$24,384

0
0
0
0

b
b
b
c

5
5

$0
$0

1
1

5
5

86
2

431
10
1,769

43
1
177

22
1
88

$15,887
$369
$65,209

$0
$0
$243,329

86
2
88

b
c

$0
$0
$0
$0

1
52
2
2

2
9
1
4

86
86
45
2

172
762
45
8

17
76
5
1

9
38
2
0

$6,355
$28,088
$1,659
$295

$0
$0
$0
$0

0
0
0
0

b
b
b
c

987
2,757

99
276

49
138

$36,396
$101,606

$0
$243,329

0
88

Footnotes

Burden Item

n/a
n/a

Inc. in 3.A
n/a
n/a
2
0.17
0.5
2
n/a
n/a

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

(A)
Respondent
Hours Per
Occurrence
(Technical
hours)

(B)
NonLabor
Costs
Per
Occurre
nce

(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
NonLabor
Capital
Costs Per
Year
[(B+C)xD
xF]

(K)
Total
Number
of
Respon
ses Per
Year
(D x F)

123

$4,515

0
0.25
1
1
n/a
n/a

$2,540
$0
$0
$12,192

1
52
2
1

0
13
2
0

135
135
70
6

0
1,752
140
0

0
175
14
0

0
88
7
0

$0
$64,594
$5,160
$0

$342,388
$0
$0
$73,151

0
0
0
0

b
b
b
c

5
5

$0
$0

1
1

5
5

135
6

674
30
2,719

67
3
272

34
2
136

$24,844
$1,106
$100,219

$0
$0
$415,539

135
6
141

b
c

$0
$0
$0
$0

1
52
2
2

2
9
1
4

135
135
70
6

270
1,192
70
24

27
119
7
2

13
60
4
1

$9,938
$43,924
$2,580
$885

$0
$0
$0
$0

0
0
0
0

b
b
b
c

1,555
4,274

156
427

78
214

$57,326
$157,546

$0
$415,539

0
141

Footnotes

Burden Item

n/a
n/a

Inc. in 3.A
n/a
n/a
2
0.17
0.5
2
n/a
n/a

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

Total Costs

$59,165
$101,606
$157,546

Non-Labor
(Annualized
Capital/Startup and
O&M) Costs
$135,635
$243,329
$415,539

1
2
3

1,605
2,757
4,274

161
276
427

80
138
214

1,846
3,170
4,915

Total
Average

8,636
2,879

864
288

432
144

9,931
3,310

$318,316
$106,105

$794,503
$264,834

$1,112,820
$370,940

$194,800
$344,935
$573,085

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 - Years 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
(A)
EPA hours per
occurrence

(B)
Number of
occurrence
s per year

1. Read and Understand Rule Requirements
10
60
600
2. Enter and Update Information Into Agency Recordkeeping System
2
0
0
3. Required Activities
A. Observe Performance Test
5
10
50
B. Excess Emissions Enforcement Activities
24
5
120
4. Reporting Requirements
A. Review Opacity Test Reports
2
49
97.2
B. Review PM Test Reports
2
1
2
5. Travel Expenses for Tests Attended:
2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip
Total
869.2

(D)
Management
Hours Per
Year
(Cx0.05)

(E)
Clerical
Hours Per
Year
(Cx0.1)

EPA
Cost Per
Year

30
0

60
0

$31,095
$0

a
b

3
6

5
12

$2,591
$6,219

c
d

5
0

10
0

e
f

$5,037
$104
$9,360
$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 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.

Footnotes

Burden Item

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for
Grain Elevators - Subpart DDa - Year 2
(A)
EPA hours per
occurrence

(B)
Number of
occurrence
s per year

1. Read and Understand Rule Requirements
10
0
0
2. Enter and Update Information Into Agency Recordkeeping System
2
0
0
3. Required Activities
A. Observe Performance Test
5
18
90
B. Excess Emissions Enforcement Activities
24
9
216
4. Reporting Requirements
A. Review Opacity Test Reports
2
86
172.4
B. Review PM Test Reports
2
2
4
5. Travel Expenses for Tests Attended:
2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip
Total
482.4

(D)
Management
Hours Per
Year
(Cx0.05)

(E)
Clerical
Hours Per
Year
(Cx0.1)

EPA
Cost Per
Year

0
0

$0
$0

a
b

5
11

9
22

$4,664
$11,194

c
d

9
0

17
0

e
f

$8,935
$207
$16,848
$41,848

Footnotes

Burden Item

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS for
Grain Elevators - Subpart DDa - Year 3
(A)
EPA hours per
occurrence

(B)
Number of
occurrence
s per year

1. Read and Understand Rule Requirements
10
0
0
2. Enter and Update Information Into Agency Recordkeeping System
2
0
0
3. Required Activities
A. Observe Performance Test
5
28
140
B. Excess Emissions Enforcement Activities
24
14
336
4. Reporting Requirements
A. Review Opacity Test Reports
2
135
269.6
B. Review PM Test Reports
2
6
12
5. Travel Expenses for Tests Attended:
2 days * ($110 hotel + $58 meals/incidentals) + ($600 round trip) = $936 per trip
Total
757.6

(D)
Management
Hours Per
Year
(Cx0.05)

(E)
Clerical
Hours Per
Year
(Cx0.1)

EPA
Cost Per
Year

0
0

$0
$0

a
b

7
17

14
34

$7,255
$17,413

c
d

13
1

27
1

e
f

$13,972
$622
$26,208
$65,470

Footnotes

Burden Item

Table 8 - Summary of Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements for the NSPS for Grain Elevators - Subpart DDa
Year
1
2
3
Total
Average

Technical
Hours

Managemen
t Hours

Clerical
Hours

Total
Hours

Labor Costs

Non-Labor
Costs

Total Costs

869
482
758

43
24
38

87
48
76

1,000
555
871

$54,406
$41,848
$65,470

$0
$0
$0

$54,406
$41,848
$65,470

2,109
703

105
35

211
70

2,426
809

$161,724
$53,908

$0
$0

$161,724
$53,908

File Type	application/pdf
File Title	STANDARD FORM 83 SUPPORTING STATEMENT ICR No
Author	JHuckaby
File Modified	2014-06-19
File Created	2014-05-13