SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS Review for Kraft Pulp Mills

(40 CFR Part 60, Subpart BB a )

May 2013

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection

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

The EPA information collection request ( ICR ) tracking n umber is 2485.01

. The OMB control

number is 2060

- NEW.

(b) Short Characterization/Abstract

The New Sour ce 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.

Revision s to the standards w ere promulgated on May 20, 1986 as a result of the NSPS review

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

, which will apply to emission units which commence construction , modifi cation, or reconstruction

after the proposal date for subpart BBa . The se standards limit emissions of p articulate 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 exem pt 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 p a rt 60, subpart BB a

.

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 det ermining 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. In2

the event tha t there is no such delegated authority, the reports are sent directly to the U

. S

. Environmental Protection Agency (EPA) r egional o ffice.

Compared to a related NSPS (Subpart BB), S ubpart BBa eliminate s the startup, shutdown,

and malfunction (SSM) exemptio n

, add s provisions to provide an affirmative defense against civil

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

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

Potential r espondents are owners and operators of new , modified, or reconstructed source s (emission units) at kr aft 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 p ulp m ill

i ndustry (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 BB a ).

T he burden to the “Federal Government” is attributed to work perf ormed by either federal

employees or government contractors . T his 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

BB a ).

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 determine s 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

Administrato r 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) ma ke 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 i n 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 S ection 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 en danger 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 kra ft 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 report s 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 mai ntenance, 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 the ir

processes an d 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 requ irements 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 i nformation 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 the4

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 develo pment of the NSPS revisions, the EPA held meetings and conference calls

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

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

Projection s 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 Guidelin es

None of t hese 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 t he reporting or recordkeeping requirements contain sensitive questions.5

4. The Res pondents and the Information Requested

(a) Respondents/ NAICS Codes

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

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

stand ards is 3221

— Pulp, Paper, and Paperboard Mills

.

(b) Information Requested

( i) Data Items , Including Recordkeeping Requirements

. All data i n this ICR that are

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

s ubpart BB a ).

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), 60.284 a (d)

Excess emissions/monitoring systems report 60.7(c) , 60.284 a (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 so urce s still need to

evaluate the data, this type of monitoring equipment has significantly reduced the burden6

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 Electroni c 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 test s using EPA Reference Method s 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 ab ove.

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 informat ion.

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, inc luding 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 reco rds 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.

In formation 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 AF S 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

- NSP S Review for Kraft Pulp Mills (40

CFR Part 60, Subpart BB a ).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 iden tified. 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 (To tal Labor Hours from Table

1). These hours are based on Agency studies and bac kground 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 ra tes 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, Septemb er, 201 2 , “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, wit h 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 a nd 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 tabl e 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 $ 9 2 ,000

ESP voltage and current monitors $ 31

, 000 2 $62,000 $4,200 4 $16,800

Scrubber pressure drop monitor a $350 2 $ 700 $ 7 0 4 $ 28 0

Scrubber liquid flow rate monitor a $15,500 2 $ 31,000 $ 3,10 0 4 $ 12,40 0

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 $155,8 80

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 durin g 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 $ 155,8 80

. 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 $ 567,1 80

. 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 sourc e 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 a nd 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 cost s are only incurred if there has

been a violation and a source chooses to take advantage of the affirmative defense. Of the number10

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

result from a malfunction, a nd 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

d efense 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 affirmati ve 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

T he 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 esti mated 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 c an be obtained from Salary

Table 201 2

- 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 an nual 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 BB a ).

(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

esti mates may be found below in Table 1 : Annual Respondent Burden and Cost

- NSPS Review

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

recordkeeping burden for this collection of information is estimated to av erage 22 hours per11

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 BB a ).

(f) Reas ons 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 ap plicable 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 A gency ’ 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 Docke t

ID Number EPA

- HQ

- O AR

- 201 2

- 0 640

. 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 pub lic 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, e xcluding legal

holidays. The telephone number for the Reading Room is (202) 566

- 1744 , and the telephone

number for the docket center is (202) 566

- 17 4 2

. S end comments to the Office of Information and

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

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

EPA

- HQ

- O AR

- 201 2

- 0 640 and OMB Control Number 2060

- NEW in any correspondence.12

Part B of the Supporting Statement

This part is not ap plicable because statistical methods are not used in data collecti o n

associated with the rule

.Table 1: Annual Respondent Burden and Cost

– NSPS Review for Kraft Pulp Mills (40 C FR 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

person

hours per

year (C × D) (F)

Manage m ent

person hours

per year (E × 0.05) (G)

Clerical

person

hours

per year (E × 0.1) (H)

Total

c ost p er

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 b e impacted by the NSPS review (subpart BBa) over 5 years

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

b This ICR uses the following labo r rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour for Technical labor, and $50 .80 per hour for Clerical14

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 T RS. 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 inclu ded 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 respo ndents 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 a l lowances) 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 In cludes time to adjust existing data acquisition systems at modified sources to include startup and shutdown periods and compl y 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

person

hours per

occurrence (B)

No. of

occurrences

per plant

per year (C)

EPA person

hours per

plant per

year (A × B) (D)

Plants

per

year a (E)

Technical

person

hours 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 o verhead 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 Ass umes that 20 percent of respondents will repeat p erformance test due to failure.

e Only initial performance tests are included in this first 3

- year ICR period. In later years, 5

- year repeat t ests will need to be included.

f Assumes that it will take EPA p ersonnel 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.