SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS Review for Kraft Pulp Mills

(40 CFR Part 60, Subpart BBa)

May 2013

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection

“NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa).” This is a new ICR. 

The EPA information collection request (ICR) tracking number is 2485.01. The OMB control 

number is 2060-NEW.

(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Kraft Pulp Mills (40 CFR part 60, 

subpart BB) were proposed on September 24, 1976, and promulgated on February 23, 1978. 

Revisions to the standards were promulgated on May 20, 1986 as a result of the NSPS review 

required under the Clean Air Act (CAA). This information collection is for a new subpart BBa, 

which will apply to emission units which commence construction, modification, or reconstruction 

after the proposal date for subpart BBa. These standards limit emissions of particulate matter (PM) 

(where applicable) and total reduced sulfur (TRS) from the following sources at kraft pulp mills: 

recovery furnaces, smelt dissolving tanks (SDTs), lime kilns, digester systems, brown stock 

washer systems, multiple effect evaporator systems, and condensate stripper systems. At pulp 

mills where kraft pulping is combined with neutral sulfite semi-chemical pulping, the provisions 

of this subpart are applicable when any portion of the material charged to an affected source is 

produced by the kraft pulping operation. Facilities may be exempt from the TRS standard in the 

NSPS if the facility can demonstrate that TRS emissions from a brown stock washer cannot 

feasibly be controlled either technically or economically. This information is being collected to 

assure compliance with 40 CFR part 60, subpart BBa.

In general, all NSPS require initial notifications, performance tests, and periodic reports by 

the owners/operators of the affected sources. The owners/operators are also required to maintain 

records of the occurrence and duration of any malfunction in the operation of an affected source, or 

any period during which the monitoring system is inoperative. These notifications, reports, and 

records are essential in determining compliance, and are required of all affected sources subject to 

NSPS. A semiannual summary report, or an excess emissions report in the event there are periods 

of excess emissions, is also required.

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

measurements, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 
2

the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

Compared to a related NSPS (Subpart BB), Subpart BBa eliminates the startup, shutdown, 

and malfunction (SSM) exemption, adds provisions to provide an affirmative defense against civil 

penalties for exceedances of emission standards caused by malfunctions, adds ESP parameter 

monitoring, and adds a requirement for electronic submittal of performance test data.

Potential respondents are owners and operators of new, modified, or reconstructed sources

(emission units) at kraft pulp mills. It is estimated that two kraft pulp mills per year (for a total of 

six mills) will have new, modified, or reconstructed emission units that become subject to subpart 

BBa in the next three years. Mills can have more than one emission unit (e.g., digester, recovery 

furnace, SDT, lime kiln) onsite.

All of the kraft pulp mills in the United States are owned and operated by the kraft pulp mill 

industry (the “Affected Public”). None of the facilities in the United States are owned by state, 

local, or tribal governments or by the Federal government; all these facilities are privately-owned,

for-profit businesses. The burden to the “Affected Public” may be found below in Table 1: Annual 

Respondent Burden and Cost – NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa). 

The burden to the “Federal Government” is attributed to work performed by either federal 

employees or government contractors. This burden may be found below in Table 2: Average 

Annual EPA Burden and Cost – NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart 

BBa).

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

The EPA is charged under section 111 of the CAA, as amended, to establish standards of 

performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated.

Section 111(a)(l).

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

formerly referred to as best demonstrated technology (BDT). Section 111 also requires that the 

Administrator review and, if appropriate, revise such standards every eight years. 

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

subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports;
3

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); and 

(G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, PM and TRS emissions from kraft pulp mills cause or 

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

Therefore, NSPS were promulgated for this source category at 40 CFR part 60, subpart BB. 

Subpart BBa was developed following the second review of subpart BB. 

(b) Use/Users of the Data

The control of PM and TRS from kraft pulp mills not only requires the installation of 

properly designed equipment, but also the operation and maintenance of that equipment. 

Emissions of PM and TRS from kraft pulp mills are the result of operation of the affected sources.

The standards are achieved by the reduction of pollutant emissions using process changes 

and control technology. The notifications required in the applicable regulations are used to inform 

the Agency or delegated authority when a source becomes subject to the requirements of the 

regulations. The reviewing authority may then inspect the source to ensure that the pollution 

control devices are properly installed and operated and the regulations are being met.

Performance test reports are needed as these are the Agency’s record of a source’s initial 

and ongoing capability to comply with the emission standard and note the operating conditions 

under which compliance was achieved. The periodic reports are used for problem identification, as 

a check on source operation and maintenance, and for compliance determinations. The 

information generated by the monitoring, recordkeeping, and reporting requirements described in 

this ICR is used by the Agency to ensure that mills affected by the NSPS continue to operate their 

processes and control equipment used to achieve compliance with the NSPS. Adequate monitoring, 

recordkeeping, and reporting are necessary to ensure compliance with these standards, as required 

by the CAA. The information collected from recordkeeping and reporting requirements is also 

used for targeting inspections, and is of sufficient quality to be used as evidence in court.

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

(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted their own similar standards to implement the 
4

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

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

This section is not applicable because this is a rule-related ICR. Nevertheless, the ICR will 

be available for public review during the public comment period following publication of the 

proposed NSPS review in the Federal Register. 

(c) Consultations

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

with representatives of the kraft pulp mill industry including the American Forest and Paper 

Association (AF&PA) and National Council for Air and Stream Improvement (NCASI). 

Projections of the number of new, modified, and reconstructed affected sources expected to be 

subject to the new Subpart BBa were discussed with the industry representatives prior to 

development of this ICR. 

(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities 

are continuing to meet the standards. Requirements for information gathering and recordkeeping 

are useful techniques to ensure that good operation and maintenance practices are applied and 

emission limitations are met. If the information required by these standards was collected less 

frequently, the likelihood of detecting poor operation and maintenance of control equipment and 

noncompliance would decrease.

(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations 

established by the Office of Management and Budget (OMB) at 5 CFR 1320.5.

(f) Confidentiality

Some respondents may consider process data to be confidential. Any such information 

submitted to the Agency for which a claim of confidentiality is made will be safeguarded 

according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality 

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 

FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.
5

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are kraft pulp mills. The 

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

standards is 3221—Pulp, Paper, and Paperboard Mills.

(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements. All data in this ICR that are

recorded and/or reported are required by the NSPS Review for Kraft Pulp Mills (40 CFR part 60, 

subpart BBa).

A source must make the following reports:

Notifications and Reports for 40 CFR part 60, subpart BBa

Notification of construction or reconstruction 60.7(a)(1), 60.15

Notification of initial performance test 60.8(d)

Notification of actual startup 60.7(a)(3)

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

Notification of physical or operational changes 60.7(a)(4)

Notification of opacity or visible emissions observations 60.7(a)(6)

Report of performance test results 60.8(a), 60.287a(a), 

60.287a(e)

Semiannual report 60.7(c), 60.284a(d)

Excess emissions/monitoring systems report 60.7(c), 60.284a(d)

Malfunction report 60.287a(f)

A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart BBa

Records of operating parameters 60.7(f), 60.284a(a)-(c)

Records of malfunctions and periods where the continuous 

monitoring system is inoperative 60.7(b), 60.286a(f)

Maintain and retain files for at least two years 60.7(f)

Electronic Reporting

Currently, sources are using monitoring equipment that provides automated parameter 

data, e.g., continuous emissions monitoring. Although personnel at the sources still need to 

evaluate the data, this type of monitoring equipment has significantly reduced the burden 
6

associated with monitoring and recordkeeping. Modern pulp and paper facilities employ 

distributive controls on their manufacturing process and have integrated many of the compliance 

recordkeeping and reporting requirements into their systems. In addition, some regulatory 

agencies are setting up electronic reporting systems to allow sources to report electronically which 

is reducing the reporting burden. However, electronic reporting systems are still not widely used 

by the regulatory agencies. It is estimated that approximately 10 percent of the respondents 

currently use electronic reporting. As part of the NSPS revisions for subpart BBa, respondents 

would be required to report test results using EPA’s Electronic Reporting Tool (ERT) for test 

methods supported by the ERT.1

(ii) Respondent Activities. The respondent activities required by subpart BBa are listed in 

the following table.

Respondent Activities

Read and understand the rule requirements.

Install, calibrate, maintain, and operate continuous monitoring systems (CMS).

Conduct performance tests using EPA Reference Methods 5, 9, 16 (or 16A, 16B, 16C), and 202.

Write the notifications and reports listed above.

Develop a record system (e.g., develop, acquire, install, and utilize technology and systems for 

the purpose of processing information; adjust the existing ways to comply with any previously 

applicable instructions and requirements).

Enter information required to be recorded above.

Transmit, or otherwise disclose the information.

In addition to the respondent activities listed above, EPA is including an estimate of the 

burden associated with performing an affirmative defense. The EPA is providing this as an 

illustrative example of the potential additional administrative burden a source may incur to assert 

in an affirmative defense in response to an action to enforce the standards set forth in the 

applicable subpart. See section 6(b)(iv) of this ICR for details.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

(a) Agency Activities

The EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

 1

As of January 2013, Methods 5, 17 and 202 are the test methods referenced in subpart BBa that are included in ERT. 

Method 16 (and variants) for TRS measurement are not yet supported by ERT. 
7

Agency Activities

Observe initial and repeat performance tests.

Review reports, including performance test reports and excess emissions reports, required to be 

submitted by industry.

Review notifications, including notifications of construction/reconstruction, performance test, 

and actual startup.

(b) Collection Methodology and Management

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

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

test reports are used by the Agency to discern a source’s initial and ongoing capability to comply 

with the emission standard, and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and published for use in compliance 

and enforcement programs. The semiannual reports are used for problem identification, as a check 

on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the Air Facility System (AFS), which is 

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

collection, maintenance, and retrieval of air compliance data for over 125,000 industrial and 

government-owned facilities. The EPA uses AFS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters.

The EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

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

years.

(c) Small Entity Flexibility

Most of the respondents are large entities (i.e., large businesses). However, the impact on 

small entities (i.e., small businesses) was taken into consideration during the development of the 

regulation. Due to technical considerations involving the process operations and the types of 

control equipment employed, the recordkeeping and reporting requirements are the same for both 

small and large entities. The Agency considers these requirements to be the minimum needed to 

ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that 

larger businesses can use economies of scale to reduce their burden, the overall burden will be 

reduced.

(d) Collection Schedule

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

below in Table 1: Annual Respondent Burden and Cost - NSPS Review for Kraft Pulp Mills (40 

CFR Part 60, Subpart BBa).
8

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 1,905 hours per year (Total Labor Hours from Table 

1). These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NSPS program, the previously 

approved ICR for subpart BB, and any comments received.

(b) Estimating Respondent Costs

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of Labor 

Statistics (BLS) data. Technical, management, and clerical average hourly rates for private 

industry workers were taken from the United States Department of Labor, Bureau of Labor of 

Statistics, September, 2012, “Table 2. Civilian Workers, by Occupational and Industry group.” 

http://www.bls.gov/news.release/ecec.t02.htm. Wages for occupational groups are used as the 

basis for the labor rates, with a total compensation of $48.23 per hour for technical, $58.33 per 

hour for managerial, and $24.19 per hour for clerical. These rates represent salaries plus fringe 

benefits and do not include the cost of overhead. An overhead rate of 110 percent was used to 

account for these costs. The fully-burdened hourly wage rates used to represent respondent labor 

costs are: technical at $101.28, management at $122.49, and clerical at $50.80.

(ii) Estimating Capital/Startup and Operation and Maintenance (O&M) Costs. The type of 

industry costs associated with the information collection activities in the subject standard include 

labor costs (which are addressed elsewhere in this ICR) and the costs associated with continuous 

monitoring and performance testing. The capital/startup costs are one-time costs when a facility 

becomes subject to the regulation and include startup costs for continuous monitoring systems 

(CMS) and the purchase of stack testing services. The annual O&M costs are the ongoing costs to 

operate and maintain the monitor and the cost for 5-year repeat stack tests (which are not incurred 

during the initial 3-year ICR period but would be incurred in future ICR renewal years).

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

summarizes the capital/startup and O&M costs associated with CMS and performance tests.
9

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

(A)

Continuous Monitoring Device

(B)

Capital/

Startup 

Cost for 

One 

Respondent

(C)

Number of 

New 

Respondents 

(D)

Total 

Capital/

Startup 

Cost 

(B X C) 

(E)

Annual 

O&M Costs 

for One 

Respondent

(F)

Number of 

Respondents 

with O&M 

(G)

Total 

O&M,

(E X F)

Opacity monitor $40,000 2 $80,000 $8,600 4 $34,400

TRS monitor $108,000 2 $216,000 $23,000 4 $92,000

ESP voltage and current monitors $31,000 2 $62,000 $4,200 4 $16,800

Scrubber pressure drop monitor a $350 2 $700 $70 4 $280

Scrubber liquid flow rate monitor a $15,500 2 $31,000 $3,100 4 $12,400

Performance tests:

 Initial Method 9 for opacity $1,000 2 $2,000

 Initial Method 5 and 202 for PM 

and CPM $6,800 2 $13,600

 Initial Method 16, 16A, 16B or 

16C for TRS $3,000 2 $6,000

 Repeat Method 5 and 202 for PM 

and CPM (every 5 yrs) b $6,800 0 $0

 Repeat Method 16, 16A, 16B or 

16C for TRS (every 5 yrs) b $3,000 0 $0

Total $411,300 $155,880

Total capital + O&M cost $567,180

a Scrubber monitor O&M costs were estimated as 20 percent of the initial monitor cost.

b Repeat tests are required in 5-year intervals. No respondents would conduct repeat tests during the initial 3-year ICR period.

The total capital/startup costs per year for this ICR are $411,300. This is the total of column 

D in the above table. The total operation and maintenance (O&M) costs are $155,880. This is the 

total of column G. The average annual cost for capital/startup and operation and maintenance costs 

to industry over the next three years of the ICR is estimated to be $567,180. These are 

recordkeeping costs.

(iv) Affirmative Defense, Root Cause Analysis, and Malfunction Costs. The EPA’s 

estimate for a affirmative defense and root cause analysis is based on general experience to 

calculate the time and effort required of a source to review relevant data, interview 12 plant 

employees, and reconstruct the events prior to a malfunction in order to determine primary and 

contributing causes. The level of effort also includes time to produce and retain the report in

document form so that the source will have it available should EPA or state enforcement agencies 

ever request to review it. To provide the public with an estimate of the relative magnitude of the 

burden associated with an assertion of the affirmative defense position adopted by a source, EPA 

provides an administrative adjustment to this ICR that estimates the costs of the notification, 

recordkeeping and reporting requirements associated with the assertion of the affirmative defense. 

EPA’s estimate for the required notification, reports and records, including the root cause analysis,

associated with a single incident totals approximately $3,375 and is based on the time and effort

required of a source to review relevant data, interview plant employees, and document the events

surrounding a malfunction that has caused an exceedance of an emission limit. The estimate also

includes time to produce and retain the records and reports for submission to EPA. The EPA

provides this illustrative estimate of this burden because these costs are only incurred if there has

been a violation and a source chooses to take advantage of the affirmative defense. Of the number 
10

of excess emission events reported by source operators, only a small number would be expected to 

result from a malfunction, and only a subset of excess emissions caused by malfunctions would 

result in the source choosing to assert the affirmative defense. Thus, we believe the number of 

instances in which source operators might be expected to avail themselves of the affirmative 

defense will be extremely small. For this reason, we estimate no more than 2 or 3 such occurrences 

for all sources within a given category over the 3-year period covered by this ICR. For the purpose 

of this estimate, we are adding two instances of affirmative defense. We expect to gather 

information on such events in the future and will revise this estimate as better information becomes 

available.

(c) Estimating Agency Burden and Cost

The costs to the Agency of this NSPS revision are documented in Table 2: Average Annual 

EPA Burden and Cost - NSPS Review for Kraft Pulp Mills. The only costs to the Agency are those 

costs associated with analysis of the reported information. Publication and distribution of the 

information are part of the AFS program. Examination of records to be maintained by the 

respondents will occur as part of the periodic inspection of sources, which is part of EPA’s overall 

compliance and enforcement program. The average annual Agency cost during the three years of 

the ICR is estimated to be $12,748.

The Agency labor rates are from the Office of Personnel Management (OPM) “2012 

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

Table 2012-GS, available on the OPM website at 

http://www.opm.gov/oca/12tables/html/gs_h.asp. The government employee labor rates are 

$15.63 per hour for clerical (GS-6, Step 3), $28.88 for technical (GS-12, Step 1), and $38.92 for 

managerial (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits 

and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at 

$25.01, technical at $46.21, and managerial at $62.27.

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

It is estimated that two kraft pulp mills per year (for a total of six mills) will have new, 

modified, or reconstructed emission units that become subject to subpart BBa in the next three 

years. The total annual labor costs are $186,324. Details regarding these estimates may be found 

below in Table 1: Annual Respondents Burden and Cost – NSPS Review for Kraft Pulp Mills (40 

CFR Part 60, Subpart BBa).

(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally. The total annual labor hours are 1,905. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost - NSPS Review 

for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa). Furthermore, the annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 22 hours per 
11

response.

The total annual capital/startup and O&M costs to the regulated entity are $567,180. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally. The average annual Agency burden and cost over the next three 

years is estimated to be 136 labor hours, at a cost of $12,748. See below Table 2: Average Annual 

EPA Burden and Cost - NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa).

(f) Reasons for Change in Burden

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

(g) Burden Statement

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

estimated to average 22 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose or provide information to or 

for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA”s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-OAR-2012-0640. An electronic version of the public docket is available at 

http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of 

information, submit or view public comments, access the index listing of the content of the docket, 

and to access those documents in the public docket that are available electronically. When in the 

system, select “search” than key in the docket ID number identified in this document. The

documents are also available for public viewing at the EPA Docket Center, EPA West, Room 3334, 

Room 3334, 1301 Constitution Avenue, NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1742. Send comments to the Office of Information and 

Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 

725 17th Street, NW, Washington, DC 20503. Please include the EPA Docket ID Number 

EPA-HQ-OAR-2012-0640 and OMB Control Number 2060-NEW in any correspondence.
12

Part B of the Supporting Statement

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

associated with the rule.
Table 1: Annual Respondent Burden and Cost – NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa)

Burden item

(A)

Person 

hours per 

occurrence 

(B) 

No. of 

occurrences 

per 

respondent 

per year 

(C) 

Person 

hours per 

respondent 

per year

(A × B)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(C × D)

(F)

Management 

person hours 

per year

(E × 0.05)

(G)

Clerical 

person 

hours 

per year

(E × 0.1)

(H)

Total 

cost per 

year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read and understand rule requirements 30 1 30 2 60 3.0 6.0 $6,749

B. Required activities

Initial performance tests c,d 80 1 80 2 160 8.0 16 $17,998

5-year repeat performance tests c,d 80 1 80 0 0 0 0 $0

Repeated performance tests due to failure c,e 80 1 80 0.4 32 1.6 3.2 $3,600

C. Gather existing information See 3B

D. Write report

Notification of construction/ reconstruction 2 1 2 2 4.0 0.2 0 $450

Notification of performance test e 2 1.2 2 2 4.8 0.2 0 $540

Notification of actual startup 2 1 2 2 4.0 0.2 0 $450

Notification of CMS demonstration 2 1 2 2 4.0 0.2 0 $450

Notification of physical or operational changes 2 1 2 2 4.0 0.2 0 $450

Notification of opacity observations 2 1 2 2 4.0 0.2 0 $450

Report of performance test (including submittal 

through EPA's ERT)e,f 4 1.2 5 2 9.6 0.5 1.0 $1,080

Semiannual report g,h 8 2 16 4 64 3.2 6.4 $7,199

Excess emissions/monitoring systems report h,i 20 2 40 4 160 8.0 16 $17,998

Malfunction report (affirmative defense) h,j 30 2 60 4 240 12 24 $26,997

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 3B

C. Implement Activities See 3B

D. Develop record system k 40 1 40 2 80 4.0 8.0 $8,999

E. Time to enter and transmit information

Records of operating parameters l 0.5 365 183 4 730 37 73 $82,116

Records of malfunctions 2 12 24 4 96 4.8 9.6 $10,799

TOTAL LABOR BURDEN AND COST (rounded) 1,905 $186,324

Total annual responses: 26

Hours per response: 22

Assumptions:

a

 Assumes an average of 2 mills responding each year over the next 3 years based on rulemaking projections that 10 mills will be impacted by the NSPS review (subpart BBa) over 5 years 

(10 mills/5 years = 2 mills per year)

b This ICR uses the following labor rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour for Technical labor, and $50.80 per hour for Clerical 
14

labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, “Table 2 - Employer costs per hour worked for employee compensation and costs as a percent 

of total compensation: Civilian workers, by occupational and industry group, September 2012.”The rates have been increased by 110 percent to account for the benefit packages available 

to those employed by private industry.

c Assumes it will take 80 hours for each new respondent to coordinate the initial performance tests for PM, CPM, opacity, and TRS. Testing contractor costs are included in the 

capital/startup and O&M costs.

d No 5-year repeat test would be conducted during the initial 3-year ICR approval. Repeat tests would begin in year 5.

e Assumes that 20 percent of respondents would repeat a performance test due to failure.

f Hard copy report of performance test is included in 3B. Submittal of performance test data through EPA's ERT is estimated to require 4 hours per test. g Assumes that it will take each respondent 8 hours to complete the semiannual report.

h Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods. Year 1 = 2, Year 2 = 2+2 = 4, Year 3 = 2+2+2 = 6. Average(2,4,6) = 4 

respondents.

i

Assumes respondents will each take 20 hours two times per year to review monitoring data (e.g., to document compliance with allowances) and complete the excess emissions report.

j

Assumes that it will take each respondent 30 hours to complete the affirmative defense report. Assumes each respondent will have 2 malfunctions per year for which they provide 

affirmative defense.

k Includes time to adjust existing data acquisition systems at modified sources to include startup and shutdown periods and comply with revised monitoring allowances. One-time activity. l Assumes that it will take each respondent 15 minutes per day to document operating parameters (e.g., wet scrubber parameters, ESP parameters).
15

Table 2: Average Annual EPA Burden and Cost - NSPS Review for Kraft Pulp Mills (40 CFR Part 60, Subpart BBa)

Activity

(A)

EPA 

personhours per 

occurrence 

(B)

No. of 

occurrences 

per plant 

per year 

(C)

EPA personhours per 

plant per 

year

(A × B)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year

(C × D)

(F)

Management 

person-hours 

per year

(E × 0.05)

(G)

Clerical 

person-hours 

per year

(E × 0.1)

(H)

Cost b

1. Attend initial performance test c 24 1 24 2 48 2.4 4.8 $2,487

2. Attend repeat performance test c,d 24 0.2 5 2 10 0.5 1.0 $497

3. Report review

Review notification of construction/reconstruction 2 1 2 2 4.0 0.2 0.4 $207

Review notification of performance test e 0.5 1.2 1 2 1.2 0.06 0.1 $62

Review notification of actual startup 0.5 1 1 2 1.0 0.05 0.1 $52

Review notification of CMS demonstration 0.5 1 1 2 1.0 0.05 0.1 $52

Review notification of physical/operational changes 0.5 1 1 2 1.0 0.05 0.1 $52

Review notification of opacity observations 0.5 1 1 2 1.0 0.05 0.1 $52

Review performance test reports e 8 1.2 10 2 19 1.0 1.9 $995

Review semiannual report f,g 4 2 8 4 32 1.6 3.2 $1,658

Review excess emissions/monitoring systems report f,g 8 2 16 4 64 3.2 6.4 $3,317

Review malfunction report f,g 8 2 16 4 64 3.2 6.4 $3,317

Subtotals Labor Burden and Cost 118 5.9 12

TOTAL ANNUAL BURDEN AND COST (rounded) 136 $12,748

Assumptions: a Assumes an average of 2 respondents impacted each year over the next 3 years.

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 

x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2012 General 

Schedule” which excludes locality rates of pay. c Assumes that it will take EPA personnel 24 hours to attend each performance test. d Assumes that 20 percent of respondents will repeat performance test due to failure. e Only initial performance tests are included in this first 3-year ICR period. In later years, 5-year repeat tests will need to be included. f Assumes that it will take EPA personnel 4 hours to review each semiannual report and 8 hours to review each excess emissions report and malfunction report. g Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods. Year 1 = 2, Year 2 = 2+2 = 4, Year 3 = 2+2+2 = 6. Average(2,4,6) = 4 

respondents.