OMB Control # 2060 0482 SECTOR _________________________

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 Under the Clean Air Act and the international treaty to protect the ozone layer ( the Montreal Protocol on Substances that Deplete the Ozone Layer), the production and import of methyl bromide will be phased out in the United States on January 1, 2005. This application seeks information to support a U. S. request to produce and import methyl bromide for certain critical uses and circumstances beyond this 2005 phaseout date.

The information in this application will be used to review whether your use of methyl bromide is " critical" because no technically and economically feasible alternatives are available. In order to estimate the loss as a result of not having methyl bromide available, EPA needs to compare data ( commodity prices, revenues, and costs) for your use of methyl bromide with uses of alternative pest control regimens.

If you submit a well documented application with sound reasons why alternatives are not technically and economically feasible, the U. S. government can be a better advocate for your exemption request internationally.

EPA Form # 7620 18b Post Harvest Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. For EPA Use Only ID # ______________

2003 Application for Critical Use Exemption of Methyl Bromide for Post Harvest Use in 2005 and beyond in the United States WHY IS THIS INFORMATION NEEDED?

Click on the Instructions tab located at the bottom of the screen for additional information.

The information contained in this application is critical to process and assess the need for methyl bromide. Filling out this application in its entirety will bolster the U. S. government's ability to strengthen the nomination package for the international review boards. WHO APPLIES?

STATE CONTACTS HOW DO I APPLY?

IS MY INFORMATION CONFIDENTIAL?

WHEN IS THE INFORMATION NEEDED?

Mailing Address for applications being submitted by mail directly to the EPA: Address for applications being sent by courier or non U. S. Postal overnight express delivery to the EPA:

US Environmental Protection Agency US Environmental Protection Agency Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption Office of Pesticide Programs Office of Pesticide Programs Mail Code 7503C 911 Bay, BEAD 1200 Pennsylvania Ave, NW 1921 Jefferson Davis Highway Washington, DC 20460 Arlington, VA 22202 Telephone: ( 703) 308 8200 OMB Control # 2060 0482 HOW CAN I RECEIVE ADDITIONAL INFORMATION? If you have general questions about this application call:

Stratospheric Ozone Hotline 1 800 296 1996 The applicant may assert a business confidentiality claim covering part or all of the information in the application by placing on ( or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice employing language such as trade secret, proprietary, or company confidential. Allegedly confidential portions of otherwise non confidential documents should be clearly identified by the applicant, and may be submitted separately to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a certain date or until the occurrence of a certain event, the notice should so state. Information covered by a claim of confidentiality will be disclosed by EPA only to the extent, and by means of the procedures set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant.

Applicants submitting their application via e mail assume responsibility for the confidentiality of the electronic message transmission.

This application must be postmarked to the EPA address below no later than 120 days after the Notice was published in the Federal Register requesting critical use exemption applications.

WHERE DO I SUBMIT THE APPLICATION? Electronic Address for applications: methyl. bromide@ epa. gov When submitting an application electronically, you should also print a hard copy, sign it, and submit it by mail If a consortium is applying for multiple methyl bromide users, the economic data should be for a representative or typical user within the consortium unless otherwise noted. If economic or technical factors ( such as types of commodities) affecting the ability of this " representative user" to use alternatives are significantly different than other users in the consortium, more than one application should be submitted to reflect these differences.

Please contact your local, state, regional or national commodity association and/ or state representative agency to find out if they plan on submitting an application on behalf of your commodity group.

States that have agreed to participate in the exemption process are listed on EPA's website at www. epa. gov/ ozone/ mbr/ cueqa. html You may either complete an electronic ( Microsoft Excel) or a printed version of the application. Please fill out each form or worksheet in the application as completely as possible. If you are completing the printed version and need extra space you may attach additional sheets as needed. Additional information may be available from your local state department of agriculture or at the sites listed below or by calling 1 800 296 1996. INSTRUCTIONS The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U. S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: " a use of methyl bromide should qualify as " critical" only if the nominating Party determines that:

( i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and ( ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and health and are suitable to the crops and circumstances of the nomination  "

If you anticipate that you will need methyl bromide in 2005 because you believe there are no technically and economically feasible alternatives, then you should apply for the critical use exemption. This application may be submitted either by a consortium representing multiple users or by individual users. We encourage users with similar circumstances of use to submit a single application ( for example, any number of post harvest users with similar commodity, pest, and structural conditions can submit a single application.) EPA Form # 7620 18b Post Harvest SECTIONS OF WORKBOOK OMB Control # 2060 0482 The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the left. This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet.

Printing worksheets 6. Go to the menu line at the top of the worksheet and select " Edit" then " Paste"

7. Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab.

Note: This is the only way you can copy a worksheet and not lose portions of the text instructions.

Viewing worksheets 2. Select the top left corner of the worksheet ( this is the space to the left of column A and above row 1. You will know that the entire worksheet has been selected because the row and column marks as well as the worksheet itself will 3. Go to the menu line at the top of the worksheet and select " Edit" then " Copy".

Worksheets are best viewed in " Page Break Preview." To select the view of the worksheet, go to the menu bar and select " View" and then " Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue lines that surround the screen indicating the edges of each page.

To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select " View" and then " Zoom".

Navigating between worksheets The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move the worksheet tabs to the right or to the left incrementally. 4. Go to the blank worksheet where you want the copied information to be pasted.

5. Again, select the top left corner of the worksheet ( left of column A and above row 1) to select the entire worksheet. EXCEL USER TIPS Inserting a blank worksheet:

1. To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select " Insert" then " worksheet" 2. A tab with the name " Sheet 1" will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and double click the " new tab" 3. By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation ( e. g., 3 A( 1), 3 A( 1)( a), etc.)

4. To move a newly inserted worksheet, simply drag the worksheet with your mouse to the desired location.

5. Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, etc  Follow the instructions above to rename the new blank worksheets as appropriate.

Copying and pasting an entire worksheet's contents into a blank worksheet:

1. Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in color when it has been selected. Worksheet 4. Future Research Plans Worksheet 5. Application Summary Definitions Climate Zone Map Worksheet 2 D. Methyl Bromide  Operating Costs for 2002 Worksheet 3. Alternatives Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Worksheet 3 B. Alternatives  Changes in Operating Costs INSTRUCTIONS Each worksheet number corresponds to the tab number in the electronic version of the application. Instructions specific to each worksheet are provided at the top of each sheet. A header row is included on each worksheet to include an application ID number that EPA will assign.

Instructions Worksheet 1. Contact and Methyl Bromide Request Information Worksheet 2. Methyl Bromide Worksheet 2 A. Methyl Bromide  Pest and Processing Information Worksheet 2 B. Methyl Bromide  Historical Use for 1997  2002 Worksheet 2 C. Methyl Bromide  Commodity Treated & Gross Profit for 2000  2002 If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and select " File" and then " Print." Then in the section of the menu that appears called " Print what," select " Entire Workbook."

EPA Form # 7620 18b Post Harvest Is this information Confidential Business Information ( CBI)? Yes No Applicant Name Primary Contact Contact Name Specialty Address Agronomic X Economic Daytime Phone Cell Phone E mail Address Fax Alternate Contact Contact Name Specialty Address Agronomic X Economic Daytime Phone Cell Phone E mail Address Fax OMB Control # 2060 0482 Ben Noble ( Check One) Steve Hensley ( Check One)

4301 North Fairfax Dr., Ste. 425 Arlington, VA 22203 1616 Rice Millers' Association Worksheet 1. Contact and Methyl Bromide Request Information The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know whom to contact in case we need additional information during the review of the application.

703 236 1445 540 222 7082 shensley@ usarice. com 703 236 2301 If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

I certify that all information contained in this document is factual to the best of my knowledge. 4301 North Fairfax Dr., Ste. 425 Arlington, VA 22203 1616 703 236 1471 703 732 2336 bnoble@ usarice. com 703 236 2301 Signature Date Title Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered " critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree now to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application. Print Name Steve Hensley Signature Date Print Name Steve Hensley Title Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 324 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number.

EPA Form # 7620 18b Post Harvest 1.

2.

3.

4. Climate ( Average Minimum Temperature)

Zones: ( check all that apply)

5. Yes Amount No 6. Yes X CUE # 02 0023 No 7.

Year 2005 2006 2007 8.

9.

10. Yes Lbs No x 11. Yes x Lbs No OMB Control # 2060 0482 Total Volume ( 1,000 cu ft) to be Treated lbs.

lbs. 447,000 447,000 Total Pounds Active Ingredient ( a. i.) of Methyl Bromide What is the amount of methyl bromide being requested by this application? ( Do NOT include QPS amounts) If a consortium is submitting this application, the data should be the total for the consortium. Have you previously applied for Critical Use Exemption of Methyl Bromide? ( Individual users should enter their climate zone designation by reviewing the U. S. climate zone map located at the end of this workbook or it can be reviewed online at http:// www. usna. usda. gov/ Hardzone/ ushzmap. html. If a consortium is submitting this application, please indicate the estimated percentage of consortium users in each climate zone.)

1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b__ 6%__ 7a__ 25%__ 7b__ 34%__ 8a____ 8b____ 9a__ 16%__ 9b____ 10a__ 19%__ 10b____ 11____ 5% 5,000 to 10,000 ( 1,000 cu ft) 90% 50,000 to 100,000 ( 1,000 cu ft)

lbs. 447,000 ( 1,000 cu ft) 218,000 Is this applicant eligible for Quarantine and Preshipment ( QPS) uses of methyl bromide?

( 1,000 cu ft) 218,000 ( 1,000 cu ft) 218,000 Please explain why there may be variations in the pounds or volume ( 1,000 cu ft) treated from year to year.

N/ A Please explain why methyl bromide is being requested. To date, there is no comparable and cost effective alternative to methyl bromide for structural or storage fumigation of rice mills. Private industry is testing alternaives but has not been successful in replacing methyl bromide for facility fumigation.

Do you anticipate that you will have any methyl bromide in storage after January 1, 2005? 2000 ( Enter the state, region, or county. Provide more details about the location if relevant to the feasibility of alternatives to methyl bromide.) Location If yes, please specify amount ( in pounds). Do you have access to recycled methyl bromide?

If yes, please specify amount ( in pounds). Range of structure/ facility size by processors included in this application? Worksheet 1. Contact and Methyl Bromide Request Information Arkansas, California, Louisiana, Florida, Missouri, and Mississippi.

( Include all commodities that benefit from the application of methyl bromide in a fumigation cycle. See the Worksheet entitled " Fumigation Cycle" for definitions.) Commodity Rice ( Insert number or percentage of users in each category)

0 to 1,000 ( 1,000 cu ft) 1,000 to 5,000 ( 1,000 cu ft) over 100,000 ( 1,000 cu ft) 10,000 to 50,000 ( 1,000 cu ft) EPA Form # 7620 18b Post Harvest 482 482 Worksheet Title 2 A Methyl Bromide  Pest and Commodity Information If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

The purpose of this worksheet is to determine pest infestation and commodity information where methyl bromide is used. This forms the baseline for evaluating the impacts of using an alternative to replace methyl bromide.

2 B Methyl Bromide  Historical Use 1997  2002 If a consortium is submitting this application, all data should reflect the actual data for the consortium.

This worksheet provides data in actual usage for 1997 2002.

2 C Methyl Bromide  Commodity Treated and Gross Profits for 2000 2002 If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This worksheet provides commodity treated and gross profits for 2000 through 2002.

The purpose of this worksheet is to determine past gross profits when methyl bromide is used. This forms the baseline for evaluating the revenue impacts of using an alternative to replace methyl bromide.

2 D Baseline  Operating Costs for 2002 If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the impact on operating profit and short run economic viability as a result of not using methyl bromide.

The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable, which will be shown in Worksheet 3 B. OMB Control # 2060 0482 Worksheet 2. Methyl Bromide Purpose of Data: To establish a baseline estimate of commodity treated, gross profits, and costs using methyl bromide.

Instructions specific to each worksheet are located at the top of each sheet. EPA Form # 7620 18b Post Harvest 1. Commodity or Consortium 2. Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec x 3. Fumigation Timeline Beginning Fumigation Cycle ( please define time periods) Hours Facility Preparation 24 Sealing 5 Cleaning 5 Fumigation Timeline Reception of Raw Materials x x x x x x x x x x x x Processing x x x x x x x x x x x x Storage x x x x x x x x x x x Raw Materials x x x x x x x x x x x x Finished Product x x x x x x x x x x x x Packing x x x x x x x x x x x x Shipping x x x x x x x x x x x Retail Market Window x x x x x x x x peak peak peak x Other Pest Treatments x x x x x x x x x x x x Other 4.

4a. OMB Control # 2060 0482 EPA Form # 7620 18b Post Harvest and clean up. Future market availability will be negatively impacted by a reduction/ loss of methyl bromide, by impacting our containers under local and state regulations. Current market availability is affected by the time necessary to fumigate, aerate fumigating a packaged commodity is used in a preventive manner, at the customer's request, and is done in isolated ability to service and retain a good portion of our existing customers and prevent us from acquiring new customers. Rough rice and milled rice is fumigated, but not usually with Methyl Bromide. Virtually all of the methyl bromide used for Provide a narrative of market channel for each commodity, where it is fumigated, and how the fumigation effects market availability and commodity sale. Worksheet 2 A. Methyl Bromide  Pest & Processing Information Rice Millers Association ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.) What month does your fumigation cycle start? ( check only one)

Time Interval: Normally months or weeks ( e. g. WEEKS/ MONTH/ YEAR/ SEASON)

Please provide a simplified schematic diagram which illustrates the basic steps of the commodity moving through the process from raw material to finished product.

Receive raw material  Sotrage  Cleaning Dehulling  Whitening  Polishing  Grading  Color sorting  Weighing  Cleaning  Packing  Weighing  Finished product  Storing  Shipping 5. Target Pest( s) or Pest Problem( s):

Pest 1 Pest 2 Pest 3 6. Pest Economic Threshold Pest 1 Pest 2 Pest 3 7. Target Pest Infestation Pest 1 % Pest 2 % Pest 3 %

8.

X X feet 9.

Structure / Facility x Commodity x Storage x All x Other 10.

11. Worksheet 2 A. Methyl Bromide  Pest & Processing Information OMB Control # 2060 0482 Mill Other 3 3.5 Phosphine ( Alone) ( Please identify the top 3 target pests or pest problems. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment.)

Common Name Genus Red and Confused Flour Beetles Tribolium Rice Weevil Sitophilus oryzae Indian Meal Moth Plodia interpunctella ( If available, please provide the economic threshold information for each pest, units, and source of information.) Economic Threshold Units ( e. g. pests/ cu ft) Source 1 pests/ cu ft Facility Inspection/ Pest Survey/ IPM system 1 pests/ cu ft Facility Inspection/ Pest Survey/ IPM system 1 pests/ cu ft Facility Inspection/ Pest Survey/ IPM system ( Please estimate the percentage of this user's total structural/ facility volume with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.)

Percentage of Total Structure/ Facility Source 100 75 50 sorting and metal detection. These machines contain sensitive electronics that cannot withstand high heat or phosphine gas. Representative User : ( Please provide descriptive factors appropriate for your operation.)

0.84 900 Volume of Facility/ Structure Treated with Methyl Bromide: Volume of Commodity Treated with Methyl Bromide: 1,000 cu ft Rate of Application per Fumigation:

Structural fumigation includes all equipment  best described as basic conveying and high tech processing equipment including machines for milling In what part and phase of the operation does the methyl bromide fumigation take place? ( check all that apply) Commodity Treated per Fumigation:

Please provide a brief description of any equipment fumigated in this operation. Details Alternative % Replaced 1,000 cu ft pounds / _________ Dimension of Structure/ Facility: Total Commodity Treated per Year: 14,400 Tons ( short) 21 Tons ( short) 1 Fumigation Chamber Prior to Storage Prior to Shipping What percentage of the operation have alternative( s) replaced methyl bromide in processing this commodity and if so, during what phase of the process?

Phosphine in Combination Heat Treatment Phase of Process Empty Bins EPA Form # 7620 18b Post Harvest 482 482 B C D E Total Actual Volume ( 1,000 cu ft) Treated Average Pounds ai Applied per Volume ( 1,000 cu ft) Total Weight of Commodity Treated ( in Tons ( short)) Average Pounds ai Applied per Ton ( short)

1997 201,000 0.00204975 1998 160,000 0.00209375 1999 181,000 0.00205525 2000 184,650 0.00205253 2001 162,000 0.00194444 2002 165,000 0.002 OMB Control # 2060 0482 Column A:

Column B:

Enter the total actual volume ( 1,000 cu ft) treated. Note: This number should be the total actual volume ( 1,000 cu ft) treated by the individual user or total actual volume ( 1,000 cu ft) treated for the entire consortium, for the year indicated.

315,000 330,000 Comments: 412,000 335,000 372,000 379,000 Volume treated and quantity ai could vary due to acquisitions, fumigation failures and/ or special pest problems that cannot be treated by other alternatives. Also, bins are fumigated on an as needed basis. If there is a variation ( greater than 10%) in the quantity a. i., the volume ( 1,000 cu ft) treated or average application rate from year to year, please explain the reasons for the variation. Should your operation only measure fumigation in one type of unit ( e. g. only the facility is treated or only the commodity is treated), please use appropriate column for volume or weight.

Year A Total Actual Pounds ai of Methyl Bromide Applied The average application rates in pounds ai of methyl bromide per volume ( 1,000 cu ft) may be calculated by dividing Column A by Column B.

Column D:

The average application rates in pounds ai of methyl bromide per ton ( short) may be calculated by dividing Column C by Column D. Column E:

_ 5________ times per _____ year_______ What is the frequency of methyl bromide applied per volume ( 1,000 cu ft)? ( 1x / year, 2x / year, 1x / 3 years, etc.) Average Pounds ai Applied per Volume ( 1,000 cu ft) Worksheet 2 B. Methyl Bromide  Historical Use 1997 2002 Total Actual Pounds ai of Methyl Bromide Applied Enter the total actual pounds active ingredient ( ai) of methyl bromide applied. Note: This number should be the total pounds ai applied by the individual user or the entire consortium, for the year indicated. Include only the pounds active ingredient of methyl bromide.

Total Weight of Commodity Treated ( in Tons ( short))

Enter the total actual weight ( tons ( short)) treated. Note: This number should be the total actual weight ( tons ( short)) treated by the individual user or total actual weight ( tons ( short)) treated for the entire consortium, for the year indicated. Total Actual Volume ( 1,000 cu ft) Treated Column C: Average Pounds ai Applied per Volume ( 1,000 cu ft) EPA Form # 7620 18b Post Harvest A C D E F G H Year Market Category ( grade, time, end use) Unit of Commodity ( e. g., pounds, tons) Total Commodity Treated ( per unit of commodity) Price ( per unit of commodity) Cost of Goods Sold ( per unit of commodity) Gross Profit ( per unit of commodity)

$ 0.00 OMB Control # 2060 0482 Comments: Commodity Gross profit may be calculated using the data you entered as the Total Commodity Treated times Price minus the Cost of Goods Sold. If gross profit is not equal to total commodity sold times price subtracted by cost of goods sold (( Column E * Column F)  Column G), you may override the formula and enter a different revenue amount. Please explain why this gross profit amount is different in the comment section below. Gross Profit Column H:

B Column F: Price Enter average prices received by the users for that commodity and category. For the total line, you do not have to enter a price. Average price over all categories can be calculated separately, if needed. If a commodity treated is never owned by the facility, indicate the fees charged for all services.

Enter the total cost of goods sold ( raw materials purchased) during the period. If this expense is not relevant to your postharvesting operation, please skip this column. Column G: Cost of Goods Sold Enter marketing categories that determine prices received, for example, grade ( quality, taste, color) or timeliness ( holiday market season, early season, late season). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would effect the price in each category. Market Categories Column C: Enter all commodities that benefit from methyl bromide in the fumigation cycle ( interval between fumigations). See the Fumigation Cycle Worksheet for a comprehensive definition of the fumigation cycle.

If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the commodity treated in the same facility/ structure, please indicate so in the comments section below. Column B: Commodity Worksheet 2 C. Baseline  Methyl Bromide  Commodity Treated & Gross Profit for 2000  2002 Column A:

Be sure to enter the year. Use as many rows as needed for each year for all the commodities in the fumigation cycles from 2000 to 2002. If a fumigation cycle overlaps more than one calendar year, then the year of the fumigation cycle is the year methyl bromide was applied. Year Enter the total units of commodity treated with methyl bromide and processed/ sold per area Enter the unit of measurement for each commodity ( lbs, tons, cwt). If not by weight, specify in the comments section the average weight of the measure. For the international review board, all measures will be converted to metric. Column D: Unit of Commodity Total Commodity Treated Column E: EPA Form # 7620 18b Post Harvest Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

2.19 lbs/ cu ft 4.4 $ 9.64 0.73 hours 8 $ 5.84 $ 15.48 OMB Control # 2060 0482 TOTAL OPERATING COSTS 3. Interest 5. Other Operating Expenses Operating Expense Items 4. Depreciation for Plant Assets 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Methyl Bromide Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement Worksheet 2 D. Methyl Bromide  Operating Costs for 2002 The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable, which will be shown in Worksheet 3 B.

A Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. Other operating expenses include, but are not limited to, wage/ salary, advertising and selling, utilities, rent and lease, insurance, and supplies. Be as precise as necessary to explain how lack of methyl bromide would affect your operation, otherwise you may aggregate operating expenses. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary. Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short)) Please fill in the unshaded areas. The shaded areas can be used if the information is known.

This field is required only for methyl bromide. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units. For all inputs and operations detailed in Column B, please specify the units of measurement. Units ( lbs. hours, etc.)

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying methyl bromide, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E. EPA Form # 7620 18b Post Harvest Worksheet 3 A 3 B OMB Control # 2060 0482 Worksheet 3. Alternatives  Feasibility of Alternative Pest Control Regimens Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to compare data ( commodity prices, gross profit, operating expenses, etc.) on the use of methyl bromide and alternative pest control regimens.

Complete worksheet 3 A for each alternative pest control regimen listed in the " U. S. Matrix" for chemical controls ( www. epa. gov/ ozone/ mbr/ cueqa. html) and the " International Matrix" for nonchemical pest controls ( www. epa. gov/ ozone/ mbr/ cue). Each worksheet contains a place holder in the title for you to insert the name of the specific alternative pest control regimen addressed. You should add additional worksheets as required.

Enter all alternative pesticides and pest control methods ( and associated profit and production practices) that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition worksheet for a comprehensive definition on fumigation cycles.

Title Alternatives  Technical Feasibility of Alternatives to Methyl Bromide You must complete one worksheet for each alternative. Please insert the name of the alternative in the area on top of the page. If you prefer, you may provide the information requested in this worksheet in a narrative review. However, you must fill in the information in Question # 1 or we will assume no production or quality loss.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable.

EPA Form # 7620 18b Post Harvest Alternatives  Changes in Operating Costs If a consortium is submitting this application, the data for this table should reflect the representative user for the consortium.

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the impact on operating profit and short run economic viability as a result of not using methyl bromide and to provide required information to the international review board.

Please fill out this worksheet for each alternative specified in the U. S. Matrix and for other alternatives for which the economic evaluation would bolster the case that methyl bromide is needed. 1.

Study # % Pest Control 1 2 2 60 3 unk 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes x No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 048 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.) Alternative: Phosphine alone and in combination RC  industry alternative use data FR  industry alternative use data Study Information % of Structure/ Facility/ Volume Details Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

Climate Restriction Regulatory Restriction  Label Restriction Pest Resistant To Alternative Structural Limitations Too corrosive for use as a structural fumigant. Cannot be used in entire area. What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  This will not meet consumer quality standards because phosphine doesn't kill weevil eggs, which methyl bromide does.

products fumigated with phosphine. Therefore, there is high probability of another weevil outbreak in the product from the eggs. Also, some customers will not Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Longer exposure times required. Deactivation and disposal of spent product increases downtime and labor costs. 95 Not compatible with electronics. Damage can be acute and chronic Other Restrictions/ Limitations ( Describe) Facility Limitations Are there any production delays ( downtime) associated with this alternative?

days/ year 54 Please specify the number of days per year of downtime:

per fumigaton per mill per year. Required 2 fumigations some years. Once the facility is fumigated with phosphine it must be cosed for 72 hours to get the full effect. Requires Please explain the details of going into downtime and why it is necessary with this alternative. What is the cost of production delays or downtime per year? 2,163,000 per year longer shut down time than MB. Requires whole facility to be shut down. Study # 3 had over $ 2 Million cost For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify) Pest Being Tested pilot stored product insects Damaged phones, computers and scales RF  industry alternative use data. pilot Unknown pilot Rice Weevil 6 days downtime beyond bromide required downtime 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x Raw Materials OMB Control # 2060 048 EPA Form # 7620 18b Post Harvest Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Phosphine alone and in combination Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Magnesium Phosphide Degesch FUMI CEL and Magtoxin 1 fumicel plate Phosphine Phostoxin 990 2 550 8 Jul Fumigation Timeline Fumigation Timeline Non Chemical Pest Control ( please describe)

Finished Product ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Reception of Raw Materials Fumigation Cycle Facility Preparation Retail Market Window Other Pest Treatments Other Processing Storage Packing Shipping Sealing Cleaning Time Interval  MONTHS Fumigations vary by facility depending upon many factors: climate, pest resurgence, financial resources, harvest schedules, etc. Some structural fumigation occurs in May or earlier, pre harvest. Some fumigation occurs monthly for product shipping.

Other = IPM, Pyrethrins, Electrocuters Comments: EPA Form # 7620 18b Post Harvest 482 s 482 1.

Study # % Pest Control 1 3 2 3 unk 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes x No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6.

OMB Control # 2060 0482 Reduced insect control and virtually no rodent control in some structures compared to MB.

EPA Form # 7620 18b Post Harvest Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Cannot treat commodity with heat. Destructive to structures of mixed construction. In southern states, heat treatments are costly since most facilities do not have heating available, therefore heat and fuel must be contracted. Facility Limitations Other Restrictions/ Limitations ( Describe) Pest Resistant To Alternative Structural Limitations Can cause expansion/ contraction damage  Label Restriction Climate Restriction Southern rice states have no built in heat sources/ fuels % of Structure/ Facility/ Volume Details Regulatory Restriction Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed. What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  ineffective treatment in dense product, and damage to the product from excessive heat. Please explain the details of going into downtime and why it is necessary with this alternative.

Time shown is days beyond what is required for MB. Cost is one fumigation per mill per year. Two fumigations are required some years. Process must be done slowly to prevent structural damage. What is the cost of production delays or downtime per year? 700,000 per year Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: 13 days/ year FR  industry alternative use data Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details RF  Industry alternative use data Unknown unk unk Stored product insects pilot Roof damage, sprinkler damage, flooring damage, scale and equipment damage. Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify) OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Heat Treatment 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 x x x x x x EPA Form # 7620 18b Post Harvest Unable to use if facility cannot generate steam to provide heat for treatment of buildings. Heat Treatment still required fumigation using MB to for complete pest eradication. Other Comments: Structural fumigation in May before harvest. Cannot use heat for pre shipment fumigation of bagged product. Packing Shipping Retail Market Window Other Pest Treatments Processing Storage Raw Materials Finished Product Sealing Cleaning Fumigation Timeline Reception of Raw Materials Fumigation Cycle Time Interval ( e. g.  MONTHS Facility Preparation Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.) Non Chemical Pest Control ( please describe) Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Heat Treatment 1.

Study # % Pest Control 1 3 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes x No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6.

EPA Form # 7620 18b Post Harvest Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Fogging materials are contact insecticides and cannot penetrate into crevices and equipment. Cannot use in and around finished product or processing area. Facility Limitations Cannot be used in processing area or in finished product. Other Restrictions/ Limitations ( Describe) Pest Resistant To Alternative Structural Limitations  Label Restriction Climate Restriction % of Structure/ Facility/ Volume Details Regulatory Restriction Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed. What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  would not meet FGIS quality standards. Please explain the details of going into downtime and why it is necessary with this alternative.

Fogging prep, and 24 hour reentry prohibition. What is the cost of production delays or downtime per year? $ per year Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: 2.5 days/ year Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details RF industry alternative use data Stored product insects pilot Did not achieve complete insect control Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify) OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Pesticides of low volatility 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 EPA Form # 7620 18b Post Harvest Other Comments: Cannot be used for compelete structural fumigation Packing Shipping Retail Market Window Other Pest Treatments Processing Storage Raw Materials Finished Product Sealing Cleaning Fumigation Timeline Reception of Raw Materials Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.) Non Chemical Pest Control ( please describe) 1124 2 Vapona Vap20 18.6% 0.02 lbs Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Pesticides of low volatility 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6.

EPA Form # 7620 18b Post Harvest Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Cannot be used for structural fumigation. Requires large quantities and longer times. Does not kill eggs. Facility Limitations Other Restrictions/ Limitations ( Describe) Pest Resistant To Alternative Structural Limitations Cannot perform structural fumigation.  Label Restriction Climate Restriction % of Structure/ Facility/ Volume Details Regulatory Restriction Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed. What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  Cannot be used for structural fumigation and not as effective as MB. Please explain the details of going into downtime and why it is necessary with this alternative. What is the cost of production delays or downtime per year? $ per year Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: days/ year Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Adult rice weevils adult grain borers Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify) OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Carbon dioxide ( high pressure) 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 EPA Form # 7620 18b Post Harvest Other Comments: Sometimes used for organic rice in 2000 lbs. lots. Packing Shipping Retail Market Window Other Pest Treatments Processing Storage Raw Materials Finished Product Sealing Cleaning Fumigation Timeline Reception of Raw Materials Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.) Non Chemical Pest Control ( please describe) Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Carbon dioxide ( high pressure) 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes x No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Controlled and modified atmospheres ( carbon dioxide, nitrogen, argon)

Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: 8 days/ year What is the cost of production delays or downtime per year? 1,400,000 per year Please explain the details of going into downtime and why it is necessary with this alternative. Longer fumigation time required What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  not as effective as MB.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Sealing and maintaining pressure integrity Facility Limitations Air circulating system required for dispersion Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Cannot use this method for preshipment fumigation of bagged product.

EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Controlled and modified atmospheres ( carbon dioxide, nitrogen, argon)

Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

EPA Form # 7620 18b Post Harvest 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Contact insecticides alone or with pest free certification Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: days/ year What is the cost of production delays or downtime per year? $ per year Please explain the details of going into downtime and why it is necessary with this alternative. No additional downtime than from using MB, but it is used in conjunction with MB.

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  Not as effective, must come into physical contact with insects, cannot penetrate.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Cannot be used alone for structural fumigations Facility Limitations Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Cannot be used for pre shipment of bagged product. Cannot be used for structural fumigation EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Contact insecticides alone or with pest free certification Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

EPA Form # 7620 18b Post Harvest 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Inert dust/ diatomaceous earth Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Rice Weevil Lesser and greater Borer All moths Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: days/ year What is the cost of production delays or downtime per year? $ per year Please explain the details of going into downtime and why it is necessary with this alternative.

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  On appropriate for crack and crevice treatment in a processing area.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Cannot treat all areas of the structure Facility Limitations Cannot use in and around electical or processing equipment.

Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Effective only on contact. Cannot treat bagged commodity or in food processing facility or for finished product. Requires too much exposure time and requires aspiration after fumigation.

EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Inert dust/ diatomaceous earth Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

Sometimes used on rough rice, but most rough rice storage is turned over very quickly.

EPA Form # 7620 18b Post Harvest 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Irradiation Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: days/ year What is the cost of production delays or downtime per year? $ per year Please explain the details of going into downtime and why it is necessary with this alternative.

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  Cannot be used for structural fumigation. Some customers refuse irradiated products.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Cannot be used.

Facility Limitations Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Can be used on packaged products only but is slow and costly, and unavailable in some areas.

EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Irradiation Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

EPA Form # 7620 18b Post Harvest 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Steam treatments, alone or with pressure Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: 4 days/ year What is the cost of production delays or downtime per year? 700,000 per year Please explain the details of going into downtime and why it is necessary with this alternative. Longer fumigation time required and heat up/ cool down periods must be performed slowly.

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  Ineffective in dense product and product damage due to heat.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Expansion and contraction can cause damage.

Facility Limitations Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Cannot use on the commodity.

EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Steam treatments, alone or with pressure Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Heat entire structure and equipment with steam to a pre determined temperature and hold for a given period of time for kill.

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

Cannot use on bagged product. Many facilities cannot generate steam.

EPA Form # 7620 18b Post Harvest 1.

Study # % Pest Control 1 2 3 4 5 2.

Study # Copy? EPA? 1 2 3 4 5 3. Yes No If yes, please continue with 3a, 3b, 3c.

3a.

3b.

3c.

4.

5.

6. OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Vacuum treatment/ hermetic storage Pest Control When Comparing This Alternative to Methyl Bromide ( Provide numerical estimates where possible.)

Pest Being Tested Scale of Study ( e. g. pilot, plot) Resulting Damages ( please specify)

Study Information For the cited studies above, please list: study name, authors, publication, date, and indicate with a checkmark if a copy is attached and if it is on the EPA website.

Details Are there any production delays ( downtime) associated with this alternative?

Please specify the number of days per year of downtime: days/ year What is the cost of production delays or downtime per year? $ per year Please explain the details of going into downtime and why it is necessary with this alternative. Good only for packaged products. Downtime not a problem IF you purchase and install several chambers.

What is the estimated probability of the commodity not meeting consumer quality standards with and without methyl bromide or alternative treatments? ( please explain.)

High  not as effective as MB.

Restrictions/ Limitations on Alternative Use This information will be used to determine the amount of methyl bromide needed.

% of Structure/ Facility/ Volume Details Regulatory Restriction  Label Restriction Climate Restriction Pest Resistant To Alternative Structural Limitations Cannot be used for structural fumigation.

Facility Limitations Other Restrictions/ Limitations ( Describe)

Why is this alternative not suitable to replace 100% of methyl bromide use in processing this commodity? Can only be used in specially constructed chambers, with specific fumigants, one of them being MB.

EPA Form # 7620 18b Post Harvest 7.

8.

2.

1 2 3 4 5 6 7 8 9 10 11 12 OMB Control # 2060 0482 Worksheet 3 A. Alternatives  Technical Feasibility of Alternatives to Methyl Bromide Alternative: Vacuum treatment/ hermetic storage Use Rate of Chemical Alternative Active Ingredient ( a. i.) Name of Product and Formulation Quantity per Volume ( 1,000 cu ft) Units ( gals, lbs. Etc.) Volume ( 1,000 cu ft) Treated # of Applications per Year Non Chemical Pest Control ( please describe)

Small quantities of product are placed into a chamber and placed under vacuum, killing insects in the product.

Fumigation Timeline ( Indicate when fumigation, major commodity and pest management practices typically occur. If the fumigation cycle is longer than one year change the months to an appropriate interval.)

Fumigation Cycle Time Interval ( e. g. WEEKS/ MONTH/ YEAR)

Facility Preparation Sealing Cleaning Fumigation Timeline Reception of Raw Materials Processing Storage Raw Materials Finished Product Packing Shipping Retail Market Window Other Pest Treatments Other Comments:

EPA Form # 7620 18b Post Harvest Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

0.8 hours 27 21.6 21.6 Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

300,000 25 0 6 125,000 12 0 6 OMB Control # 2060 0482 1. Pest Management Costs ( a+ b+ c+ d) If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment. 5. Other Operating Expenses 2. Repairs / Maintenance / Replacement 3. Interest Worksheet 3 B. Alternative  Changes in Operating Expenses Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Comments: TOTAL OPERATING COST CO2 generation and delivery system What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Type of Investment Building w/ pressure chambers a) Sanitation 4. Depreciation for Plant Assets b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs Operating Expense Items Units ( lbs. hours, etc.) Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

This is not a practical solution because it cannot be used for structural fumigation, which is where the majority of MB is used. Suitable for packaged product treatment only. Operating cost is for loading and unloading the pressure chamber with product prior to shipping. Alternative: Carbon dioxide ( high pressure)

A Operating Expense Items For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary. EPA Form # 7620 18b Post Harvest prior to shipping. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%) OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Phosphene alone and in combination Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Comments:

EPA Form # 7620 18b Post Harvest High corrosion factor eliminates it as a candidate for structural fumigation. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

77 lbs. 0.58 44.66 0.73 hours 8 5.84 50.5 Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

300,000 12 0 6 150,000 12 0 6 125,000 12 0 6 OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Controlled and modified atmospheres ( CO2, nitrogen, argon)

Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative? Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Gas generation and delivery system Air ciruclation system Electrical modifications Comments:

EPA Form # 7620 18b Post Harvest Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Custom Heat Treatments Contract Heat and rental 17.9 Fuel 3.2 Labor 3.5 24.6 Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

1,000,000 12 0 6 150,000 12 0 6 150,000 12 0 6 250,000 12 0 6 3 B( 3)

Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Heat Treatment Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Steam heating system Air circulation system Electrical Modification Equipment retrofit Comments:

EPA Form # 7620 18b Post Harvest Investment costs are for installation and maintenance of steam system, and unsure of application cost per 1,000 cu. ft. Cannot treat product. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

N/ A Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%) 3 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Inert dust/ diatomaceous earth Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Comments:

EPA Form # 7620 18b Post Harvest This method of pest control is used primarily for pre processed bulk stored product, not for structural or packaged product fumigation. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

N/ A Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

4,500,000 12 0 6 OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Irradiation Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Irradiation equip for packaged product.

Comments:

EPA Form # 7620 18b Post Harvest This is not a practical solution because it cannot be used for structural fumigation which is where the majority of MB is used. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

N/ A Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%) OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Pesticides of low volitility Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Comments:

EPA Form # 7620 18b Post Harvest This alternative cannot be used for, or around finished product. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

1,000,000 12 0 6 150,000 12 0 6 150,000 12 0 6 250,000 12 0 6 OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Steam treatment, alone or with pressure Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Steam heating system Air circulation system Electrical modification Equipment retrofit Comments:

EPA Form # 7620 18b Post Harvest Not sure of application per 1,000 cu. ft. Column A:

Column B:

Column C:

Column D:

Column E:

B C D E Quantity Used per Volume ( 1,000 cu ft) or Weight ( Tons ( short)) Units ( lbs, hours, etc.) Unit Cost ($) Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

0.8 hours 27 21.6 21.6 Total Investment ($) Life of Investment (# of years) Salvage Value ($) Interest Rate (%)

300,000 25 0 6 50,000 12 0 6 OMB Control # 2060 0482 Worksheet 3 B. Alternative  Changes in Operating Expenses Alternative: Vacuum treatment/ hermetic storage Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operating Expense Items Identify the operations to which the costs apply. You may add or delete lines as necessary. The operating expense items listed here are not meant to be exhaustive or be representative of your specific operating system. These are meant to provide suggestions and to help you identify how your operation would change if methyl bromide were unavailable.

Quantity Used per Volume ( 1,000 cu ft) or Weight ( tons ( short))

This field is required only for alternatives. However you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant.

Units ( lbs. hours, etc.)

For all inputs and operations detailed in Column B, please specify the units of measurement.

Unit Cost ($)

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying alternatives, including any material costs ( e. g. tarps). If custom applied and separate costs are unavailable, write ' custom' and enter total cost in Column E.

Cost ($) per Volume ( 1,000 cu ft) or Cost ($) per Weight ( tons ( short))

Enter all appropriate costs of operations per volume ( 1,000 cu ft) or weight ( tons ( short)). You may add or delete lines as necessary.

If operation is defined in either cost per volume or cost per weight, please keep the continuity of units.

A Operating Expense Items 1. Pest Management Costs ( a+ b+ c+ d)

a) Sanitation b) Pest Control c) Fumigation ( c1+ c2)

c1) Product c2) Application d) Other Pest Management Costs 2. Repairs / Maintenance / Replacement 3. Interest 4. Depreciation for Plant Assets 5. Other Operating Expenses TOTAL OPERATING COST What are the additional new investments ( structures, facilities, equipment, fumigation chambers, etc.) needed to utilize this alternative?

Establish necessary capital expenditures required for the uses of alternatives. For example, the incremental costs to convert to heat treatment might include installing a steam heating system, purchasing generators, installing necessary ductwork, and retrofitting other components to make them amenable to heat treatment.

Type of Investment Building w/ vacuum chambers Vacuum system Comments:

EPA Form # 7620 18b Post Harvest Not for structural fumigation. Operating cost is for loading and unloading the vacuum chamber with product prior to shipping. 1. 1 4 2 5 3 2. 1 4 2 5 3 3. 1 4 2 5 3 4.

5.

6.

7.

From: To:

x x x x x 8.

Year Amount ($)

9. $

Cost 10. OMB Control # 2060 0482 Worksheet 4. Future Research Plans Please describe future plans to test alternatives to methyl bromide. You may use this worksheet to describe all future plans.

Identify the top 3 to 5 target pests for your research. Rusty Grain Beetle Red Flour Beetle Indian Meal Moth Provide a list of alternative chemicals or cultural practices that have been tested. IPM Ozone Insect Electrocuters Heat Prioritize the alternative chemicals or cultural practices to be tested. Crack/ crevice treatment What would be the best currently available alternative if methyl bromide were not available?

yes Will you collect data on the probability of failure to meet quality standards? Please provide an overview/ timeline of the plan to transition away from using methyl bromide. 10 years plus How will you minimize your use and/ or emissions of methyl bromide?

( check all that apply) Formulation Changes ( please specify) Formulation Changes Tarpaulin ( High Density Polyethylene) _____% methyl bromide, _____% chloropicrin Virtually Impermeable Film ( VIF) _____% methyl bromide, _____% chloropicrin Reclamation Other Pesticides ( please specify) Sealing Buildings Buildings are sealed and taped prior to application Cultural Practices ( please specify) Training for employees is in effect None known at this time Grant requests made to USDA, EPA, state, or other funding group. ( Describe each investment and its associated costs. e. g. specialized machinery, new facilities, etc.)

Investment Investments are by invidual companies. Other total investments, if any, made to reduce your reliance on methyl bromide? Individual companines and researchers attempting to find what suits best to particular geography, climate, and pest populations.

EPA Form # 7620 18b Post Harvest What is the cumulative amount spent and the types of contributions this consortium has made to fund research to develop alternatives to methyl bromide since 1992? ( e. g. consortium dues, direct research funding, etc.)

Name of Organization / Research Institution Integrated Pest Management ( IPM) In effect electrocuters Non Chemical Methods ( please specify) Other 1.

2.

3.

4. 2005 5. 2005 6.

2006 447,000 lbs. 218,000 2007 447,000 lbs. 218,000 Not Technically Feasible Not Economically Feasible X X X X X x x x x x x x x x x x For EPA Use Only ID # _______________

SECTOR ___________________________

This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phase out for methyl bromide. Therefore, this worksheet cannot be claimed as CBI.

Rice Millers Association 4301 N. Fairfax Drive, Ste. 425, Arlington, VA 22203 Worksheet 5. Application Summary Consortium Name:

Location:

447,000 218,000 ( 1,000 cu ft) of rice mills. Private industry is testing alternatives but has not been successful in replacing methyl bromide for facility fumigation.

Volume Treated Volume Treated $ 8,000 more expensive per treatment, damaging to equipment ($ 2.5 million), finished goods/ packaging areas cannot be heat treated, Huge capital improvement costs to Has negative metallurgical effects w/ electrical systems and microprocessors causing severe corrosion costing approximately $ 250,000 per year in repairs, takes 4 to 7 days ( 1,000 cu ft)

Not for food processing areas, crack and crevice treatment onl Not for commodity, expensive to install and maintain equipmen CO2 Not for structures, unacceptable to customers, unavailable. Not for structures, requires clean up, not for food processing ar Cannot be use for structural fumigation. Works best with MB. Controlled atmospheres Contact insecticides Costly and cannot be used in all instances. Cannot be use for structural fumigation. Heat Treatments Phosphine Place an " X" in the column( s) labeled " Not Technically Feasible" and/ or " Not Economically Feasible" where appropriate. Use the " Reasons" column to describe why the potential alternative is not feasible.

Reasons Potential Alternatives Vacuum treatment Not for structure. Requires expensive equipment Inert dust Irradiation Pesticides of low volitility Steam treatment OMB Control # 2060 0482 Rice Millers Association lbs.

( 1,000 cu ft)

To date there is no comparable and cost efficient alternative to methyl bromide for structural or storage fumigation Pounds of Methyl Bromide Requested Volume Treated with Methyl Bromide If methyl bromide is requested for additional years, reason for request: Crop: EPA Form # 7620 18b Post Harvest 82 Fumigation cycle:

Year:

Comparable data:

2 year example:

Other beneficiary example Crop cycle change example:

Crop Grouping EPA Form # 7620 18b The period of time between methyl bromide fumigations.

If a fumigation cycle overlaps more than one calendar year, " year" refers to the calendar year when methyl bromide is applied ( or the beginning of the cycle).

In order to compare revenues and costs with and without methyl bromide, data on alternatives for pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle, then to be comparable, the quantitative data for the alternatives should cover the same portion of the fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be discussed in the comments sections.

If a methyl bromide fumigation is made every 2 years, then the 2001 fumigation cycle began in 2001 and would end in 2003. The data should cover the methyl bromide costs and usage for the methyl bromide fumigation made in 2001, and all yields and revenues received and other costs incurred during the 2 year period. To be comparable, the data on alternatives should cover a similar 2 year period beginning in 2005 beginning at the same time of year when a methyl bromide fumigation would be made. The data should cover all methyl bromide alternatives used, and all yields and revenues received during that 2 year interval. Other pest control and other costs would only need to be provided for that interval if they would change from what they were with methyl bromide.

If someone other than the applicant benefits from a methyl bromide fumigation, you should comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year earlier, but there is quantitative data only on the first crop, then the data on the alternatives should cover only the first crop, and the benefits of methyl bromide and the additional pesticides that would have to be used on the rotational crop should be discussed in the comments sections.

If in a one year interval, methyl bromide is applied, tomatoes are grown and harvested followed by peppers, then the fumigation cycle would be one year including the tomatoes and peppers. If, however, without methyl bromide, it is not possible to follow tomatoes with peppers in the same one year interval, then the alternative data on pesticides, costs, yields, and revenues should just cover tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be part of the loss from not having methyl bromide.

The applicant can group simliar crops together if: ( i) Crops would experience similar yield and quality losses in the absence of methyl bromide; and ( ii) Crops are grown on the same fumigation and cultivation cycle with similar operating costs. For example, nursery crops including various flower or tree species can be aggregated, with average yields per acre and prices. However, if crops are distinctly different in revenues and operating costs, or the cycles, the applicant may want to present yield, price and operating costs for each crop separately and also indicate the proportion of land area allocated to each crop. Definitions: OMB Control # 2060 0482 Post Harvest