2354ss05v2

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal), EPA ICR Number 2354.05, OMB Control Number 2060-0635.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Prepared Feeds Manufacturing were proposed on July 27, 2009, promulgated on January 5, 2010, and amended on both July 20, 2010, and December 23, 2011. A prepared feed manufacturing facility is a facility where animal feed (other than feed products for dogs and cats) makes up at least half (by mass) of the facility’s annual production of all products. These regulations apply to new and existing area source prepared feeds manufacturing facilities that use one or more materials (additives/premixes) that contain 0.1 percent or greater by weight of chromium (Cr) or 1.0 percent or greater by weight of manganese (Mn). New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart DDDDDDD.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents and retain the file for at least five years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The respondents are prepared feeds manufacturing facilities that are an area source of hazardous air pollutants (HAPs), and State and local governments that submit data to EPA. These facilities are privately-owned, for-profit businesses. The respondent’s estimated burden is found in Table : Annual Respondent Estimated Burdens and Costs – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal). The burden to the Federal Government is attributed entirely to work performed by either Federal employees and can be found below in Table : Average Annual EPA Estimated Burdens and Costs – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal). There are approximately 1,800 prepared feeds manufacturing facilities, which are owned and operated by the prepared feeds manufacturing industry, which are are all owned and operated by privately-owned, for-profit businesses..

Based on our consultations with internal industry experts and industry representatives, as discussed in Section 3(c), there is an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 1,800 respondents per year will be subject to these standards, and EPA assumes that there will be no additional respondents in the next three years that will become subject to these standards.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, chromium and manganese emissions from prepared feed manufacturing either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart DDDDDDD.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standards. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance.

The notifications required in these standards are used to either inform the Agency or its delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and that these standards are being met. The performance test may also be observed.

The required annual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart DDDDDDD.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. Delegated authorities may be determined in 40 CFR 63.99. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.

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

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (FR citation, e.g., 83 FR 24785) on May 30, 2018. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 1,800 respondents will be subject to these standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the National Grain and Feed Association (NGFA), at (202) 289-0873, and the American Feed Industry Association, at (703) 524-0810.¹

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and that emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and operators of area source prepared feed manufacturing facilities that add chromium or manganese to their products. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 0723 and 2048, which correspond to the North American Industry Classification System (NAICS) code 311119 for Other Animal Food Manufacturing. Not all businesses that are classified according to the NAICS or SIC codes are necessarily subject to the requirements of Subpart PPPP; only those that meet the applicability criteria in 40 CFR 63.11619.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD).

A respondent must adhere to the following requirements listed in Tables 1-3::

Table 1: Notifications
Notification Requirements	40 CFR Part Section
Notification of applicability	§63.9(b)(2)
Notification of construction/reconstruction	§63.9(b)(5)
Notification of special compliance requirements	§63.9(d)
Notification of compliance status	§§63.9(h), 63.11624(a)(2)
Notification of changes in information	§63.9(j)
Initial notification	§63.11624(a)(1)

Table 2: Reports
Reporting Requirements	40 CFR Part Section
CMS performance evaluation	§63.8(e)(5)
Excess emissions reports	§63.10(e)(3)
Annual compliance certifications	§63.11624(b)

Table 3: Recordkeeping
Recordkeeping Requirements	40 CFR Part Section
Records of notifications	§§63.10, 63.11624(c)(1)
Records of annual compliance certifications	§63.11624(c)(2)
Records of device inspection	§63.11624(c)(3)
Records that demonstrate continuous compliance	§63.10
Monitoring information	§63.10
Records of quarterly inspection, including information on the cyclone	§§63.11624(c)(4)-(5)
Records of feed production	§63.11624(c)(6)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. This rule has no electronic reporting requirements.

(ii) Respondent Activities

The activities described in the Respondent Activities table are typical actions that an existing or new source subject to the requirements of NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) might complete in order to comply with the rule.

Table 4: Respondent Activities	Applicable Rules
Familiarization with the regulatory requirements.	§§63.1-15, §§63.11619-11638
Install, calibrate, maintain, and operate CMS for opacity, or for inlet flow rate, inlet velocity, pressure drop, or fan amperage for the cyclone.	§63.8, §63.11622
Perform initial performance test, Reference Method 5 test, and repeat performance tests if necessary.	§63.7, §63.11623
Write the notifications and reports listed above.	§§63.9-10, §63.11624
Enter information required to be recorded above.	§63.10, §63.4530
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for collecting, validating, and verifying information.	§§63.9-10, §63.11624
Develop, acquire, install, and utilize technology and systems for processing and maintaining information.	§63.10, §63.11624
Develop, acquire, install, and utilize technology and systems for disclosing and providing information.	§63.10, §63.11624
Train personnel to be able to respond to a collection of information.	§63.10, §63.11624
Transmit, or otherwise disclose the information.	§§63.9-10, §63.11624

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:

Table 5. Agency Activities	Applicable Rules
Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.	§§63.9-10, §63.11624
Audit facility records.	§63.10, §63.11624
Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.	§63.11624, 42 U.S.C. §7414(a)(1)

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standards. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The annual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The burden for these activities is covered under OMB Control No. 2060-0096, Air Stationary Source Compliance and Enforcement Information Reporting.

This burden is covered under “Air Stationary Source Compliance and Enforcement Information Reporting” (EPA ICR No. 0107.12, OMB Control No. 2060-0096).

The records required by this regulation must be retained by the owner/operator for five years.

5(c) Small Entity Flexibility

The majority of the respondents are small entities (i.e., smaller businesses). Our analysis indicates that the regulation does not impose a significant adverse impact on any facilities, large or small, since these costs are less than 0.1 percent of revenues. Due to technical considerations involving the process operations and the types of control equipment employed, the record-keeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below at the end of this document in Table 9: Annual Estimated Respondent Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 9 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of ‘Burden’ under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these record-keeping and reporting requirements is estimated to be 64,100 hours (Total Labor Hours from Table 9 at the end of this document). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $147.40 ($70.19+ 110%)

Technical $117.92 ($56.15 + 110%)

Clerical $57.02 ($27.15 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standard(s) are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

Table 6. Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Cyclone monitor	$295	0	$0	$291	1,2842	$37,236
Total 3			$0			$37,200

¹ We assume that annual O&M costs would be 10 percent of the initial capital cost.

² The NESHAP requires that existing and new facilities with a daily production level greater than 50 tons per day install and operate a cyclone to reduce emissions from pelleting operations. These facilities are required to install a device on the cyclone to monitor inlet flow rate, inlet velocity, pressure drop, or amperage. We estimate 1,284 of the 1,800 facilities have production greater than 50 tons per day.

³ Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $37,200. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $37,200. These are the O&M recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $197,000.

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

Managerial $65.71 (GS-13, Step 5, $41.07 + 60%)

Technical $48.75 (GS-12, Step 1, $30.47 + 60%)

Clerical $26.38 (GS-6, Step 3, $16.49 + 60%)

These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 1,800 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The estimated number of respondents is 1,800 per year. This represents no change from the previous ICR. The reasons for this estimate are explained in Section 3(c) above.

The total number of annual responses per year is calculated using the following table:

Table 7: Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notification a	0	1	0	0
Notification of compliance status a	0	1	0	0
Annual compliance certification a	1,800	1	0	1,800
			Total	1,800

^a new sources are required to submit initial notification and notification of compliance status. No new sources are expected to construct in the three-year period of this ICR. Only

^b existing source is required to submit an annual compliance certification. Each

The number of Total Annual Responses is 1,800.

The total estimated annual labor costs are $7,310,000 (rounded). Details regarding these estimates may be found below at the end of this document in Table : Annual Estimated Respondent Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 9 and 10 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 64,100 hours (rounded). Details regarding these estimates may be found at the end of this document in Table 9: Annual Estimated Respondent Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 36 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $37,200. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) Agency Estimated Labor Hours and Costs

The average annual Agency burden and cost over next three years is estimated to be 4,140 labor hours at a cost of $197,000; see at the end of this document in Table 10: Average Annual EPA Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is no change in the burden in this ICR compared to the previous ICR. This is due to two considerations. First, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, we have no updated information on the growth rate for the industry, which has typically been very low, negative or non-existent. We have assumed that the population of respondents is static, so there is no significant change in the overall burden. There is an adjustment increase in costs from the most recently-approved ICR. The adjustment is due to an increase in the labor rates used in calculating the labor costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 36 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Responses to this information collection are mandatory.

An agency may neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2012-0703. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2012-0703 and OMB Control Number 2060-0635 in any correspondence.

Table 9: Annual Respondent Estimated Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal)

Activity	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year	(E) Technical person hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $a
1. Applications
2. Survey and Studies
3. Acquisition, Installation, & Utilization of Tech. & Systems
4. Reporting Requirements
A. Familiarize with rule requirements b	1	1	1	1,800	1,800	90	180	$235,785.60
B. Required Activities:
i. Quarterly control equipment inspection c	1	4	4	1,284	5,136	256.8	513.6	$672,774.91
ii. Daily cyclone performance measures	0.1	365	36.5	1,284	46,866	2343.3	4686.6	$6,139,071.07
C. Create information
D. Gather existing information
E. Write report
Initial Notification b	0.5	1	0.5	0	0	0	0	$0
Notification of Compliance Status b	1	1	1	0	0	0	0	$0
Annual Compliance Certification	1	1	1	1,800	1,800	90	180	$235,785.60
Subtotal for Reporting Requirements					63,942			$7,283,417.18
5. Recordkeeping Requirements
A. Familiarize with rule requirements b	See 4A
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	0.1	1	0.1	1,800	180	9	18	$23,578.56
I. Time for audits	0.1	1	0.1	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					207			$23,578.56
TOTAL LABOR BURDEN AND COSTS (rounded)e					64,100			$7,310,000
TOTAL CAPITAL AND O&M COST (rounded)e								$37,200
GRAND TOTAL(rounded)e								$7,350,000

Assumptions:

^a This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^b We have assumed that it will take one hour for each respondent to familiarize with regulatory requirements, one hour to complete the initial notification, and one hour to complete the Notification of Compliance Status.

^c The NESHAP requires that existing and new facilities with a daily production level greater than 50 tons per day install and operate a cyclone to reduce emissions from pelleting operations. These facilities are required to install a device on the cyclone to monitor inlet flow rate, inlet velocity, pressure drop, or amperage. We estimate 1,284 of the 1,800 facilities have production greater than 50 tons per day.

^d We have assumed that it will take one hour for each respondent to transmit or disclose information.

^e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 10: Annual Estimated EPA Burden and Cost – NESHAP for Prepared Feeds Manufacturing (40 CFR Part 63, Subpart DDDDDDD) (Renewal)

Activity	(A)	(B)	(C)	(D) Plants per year	(E) Technical person hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H)
	EPA person hours per occurrence	No. of occurrences per plant per year	EPA person hours per plant per year (AxB)					Cost, $ a
Report Review
Initial Notification b	1	1	1	0	0	0	0	$0
Notification of Compliance Status c	2	1	2	0	0	0	0	$0
Annual Compliance Certification	2	1	2	1,800	3,600	180	360	$196,824.60
TOTAL BURDEN AND COST d					4,140			$197,000

Assumptions:

^a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay.

^b We have assumed that it will take 1 hour to review the initial notification of applicability report.

^c We have assumed that it will take 2 hours to review the initial notification of compliance status report.

^d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

1 Neither of these trade associations responded to EPA inquiries.