1 STANDARD FORM 83

- I SUPPORTING STATEMENT
FOR OMB REVIEW OF EPA ICR No.

____ .

__ :

INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDU AL RISK
AND TECHNOLOGY REVIEW (RTR)

Sector Policies and Programs Division U.S. Environmental Protection Agency Research Triangle Park, North Carolina 27711

February 4 , 20112 SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST FOR PU LP AND PAPER SECTOR NEW SOURCE PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection

“ Information Collection Request for Pulp and Paper Sector New Source Performance

Standards (N SPS ) and National Emission Standards f or Hazardous Air Pollutants (NESHAP )

Residual Risk and Technology Review (RTR) .” Th is is a new information collection request

(ICR).

(b) Short Characterization

This information collection is being conducted by EPA’s Office of Air and Radiation

(OAR) to assist the EPA Administrator, as required by section s 111(b)

, 112(d) , and 112(f)(6) o f

the Clean Air Act (CAA) , as amended, to determine the current affected population of pulp and

paper processes and to reevaluate emission standard s for this source category

. The information

from this ICR would also be made available to the public.

This i s a one

- time information collection. Currently, information necessary to identify

pulp and paper mills is available from the Lockwood

- Post (facility name and address) and from

EPA’s National Emissions Inventory (NE I). Neither the Lockwood

- Post n or the NE I contain all

of the details (capacity, fuel type s , operating schedule, emission source design, materials

processed, emissions collection and control systems, regulatory alternatives used, and emission

test data) necessary to characte rize pulp and paper NS PS and NE S H AP affected sources for

purposes of regulatory analyses. Although some of the needed information may be included in

title V or State air emission permits, many permits do not contain all of the detail needed and are

not readily available from a ny single source

. Furthermore, there are no readily available sources

for previously conducted emissions test results (since the mid

- 1990s) that will provide data for

emissions of the variety of pollutants under consideration . To obtain this information, EPA is

soliciting information with a survey

, under authority of CAA section 114, from all potentially

affected units. EPA intends to administer the survey in electronic (spreadsheet) format. The

survey will be s ent to all pulp and paper manufacturing fa cilities listed in the Lockwood

- Post.3 The EPA estimates the total cost to industry of the electronic information collection

( gathering, entering, and quality assuring ( QA ) of data submitted in response to the survey for

3 52 responden ts ) will be 161,106 ho urs and $15,244,683

, which includes $6,336 in operation

and maintenance (O&M) costs for postage for mailing survey responses to EPA

. The average

burden per res pondent is 458 hours and $43,291

.
2. Nee d for and Use of the Collection

(a) Ne ed/Authority for the Collection

The pulp and paper production source category includes any facility engaged in the

production of pulp and/or paper. This category includes, but is not limited to, integrated mills

(where pulp alone or pulp and paper or paperboard are manuf actured on

- site), non

- integrated

mills (where either paper / paperboard or pulp are manufactured onsite , but no t both ), and

secondary fiber mills (where waste paper is used as the primary raw material). The pulp and

paper production process units include op erations such as pulping, bleaching, chemical recovery,

and papermaking. Different pulping processes are used, including chemical processes (kraft,

soda, sulfite, and semi

- chemical) and mechanical, secondary fiber, or non

- wood processes. The

three federa l emission standards that are the subject of this information collection include:

1

. Standards of P erformance for Kraft Pulp M ills (40 CFR part 60, subpart BB),

2

. National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry (40 C FR part 63, subpart S), and

3

. National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand

- Alone Semichemical Pulp Mills (40 CFR part 63, subpart MM).

The Standards of Performance (i.e. , the NSPS ) currently regulates particulate matter

(PM) and total reduced sulfur (TRS) emissions from kraft pulping processes. In general,

NESHAP subpart S covers hazardous air pollutant ( HAP ) emissions from the pulp production

areas (e.g., pulping system vents, pulping process condensates ) at chemical, mechanical,

secon dary fiber, and non

- wood pulp mills; bleaching operations; and papermaking systems

. The

subpart S standards include several alternative emission limits for each covered process that are

de signed to provide flexibility and to promote and encourage the use of new technology,

particularly combined air/water controls and pollution prevention technologies. The NESHAP

subpart MM regulates HAP emissions from the chemical recovery combustion areas of chemical

pulp mills ( kraft, sulfite, semi

- chemical, and soda wood pulping processes)

. For existing kraft4 and soda combustion units, the subpart MM standards also include a compliance alternative that

allows netting of PM emissions for the entire chemi cal recovery system.

Section 111(b)(1)(B) of the CAA mandates that EPA review and, if appropriate, revise

existing NSPS at least every 8 years. The NSPS for kraft pulp mills was promulgated in 1978

,
and reviewed in 1986. Another review of the kraft pulp m ill NSPS is required under the CAA

. Similarly, Section 112(f)(2) of the CAA directs EPA to conduct risk assessments on each source

category subject to maximum achievable control technology (MACT) standards and determine if

additional standards are needed to reduce residual risks. The section 112(f)(2) residual risk

review is to be done 8 years after promulgation. Section 112(d)(6) of the CAA requires EPA to

review and revise the MACT standards, as necessary, taking into account developments in

practices, proc esses, and control technologies. The section 112(d)(6) technology review is to be

done at least every 8 years. The NESHAP for the pulp and paper industry (40 CFR part 63,

subpart S) was promulgated in 1998 and is due for review under CAA sections 11 2(f)(2) and

112(d)(6). Likewise, t he NESHAP for chemical recovery combustion sources at kraft, soda,

sulfite, and stand

- alone semichemical pulp mills (40 CFR part 63, subpart MM) was
promulgated in 2001 and is also due for review

. In addition to the CAA

- required reviews, recent

case law

, legal petitions , and a notice of intent (NOI) to sue suggest the need to review the pulp

and paper NESHAP and NSPS . For example, in December 2008 , the U.S. Court of Appeals for

the D.C. Circuit vacated the startup, shutd own, and malfunction (SSM) provisions contained in

the NESHAP General Provisions that apply to pulp and paper mills. In January 2009, EPA

received a petition for rulemaking requesting that EPA revise various NESHAP, including the

NESHAP for chemical recov ery combustion sources at pulp mills, to make the NESHAP

consistent with CAA precedent established in recent judicial rulings. In July 2010 , EPA received

a NOI from Californians for Alternatives to Toxics (CATs) and the Center for Biological

Diversity (CB D), contending that EPA failed to review the NSPS for kraft pulp mills within the

statutory deadline under CAA section 111(b)(1)(B). To the extent that these legal actions need

to be addressed in the pulp and paper NESHAP and NSPS , EPA intends to investig ate potential

rule revisions at the same time as the CAA statutory reviews are conducted.

EPA is not asking synthetic area sources for emissions information to respond the NEI

update section of the survey ( P art 2). Identified synthetic area sources will not be used to

develop risk assessments for this rule. We have requested plants to identi fy whether they are a5 synthetic area source or not in their survey response. These sources are still required to respond

to P art 1 of the survey and, if applicable, P art 3 in order to identify new technology and/or

manufacturing practices that may reduce HAP emissions.

The data used as the basis for the originally promulgated pulp and paper NESHAP are

over 15 years old , and data used to review the NSPS are over 20 ye ars old . The Agency is aware

that significant changes have been made in the intervening years in the number of affected

facilities , in industry ownership practices, and in emission collection and control configurations.

Further, in light of the statutor y requirements for reviewing emission standards under CAA

section s 111(b) and 112 and the recent case law , legal petitions, and NOI regarding those

requirements, the Agency has concluded that obtaining updated information will be crucial to

informing its de cision s on the NSPS review and NESHAP RTR for pulp and paper

manufacturing sources.

The EPA has already begun assembling data for a preliminary residual risk assessment

for the pu l p and paper NESHAP subparts S and MM

. Data sets derived from the EPA’s 20 05

National Scale Air Toxics Assessment (NATA) National Emissions Inventory (NEI) will be used

for the RTR. Several pulp and paper mills have voluntarily updated their NEI data sets for RTR

purposes in recent years and few additional refinements are expec ted on the NEI data sets for

these mills . However, there remain a number of pulp and paper mills for which substantial

upd ates to their NEI data sets would be useful in order for EPA to accurately consider RTR for

the pulp and paper NESHAP standards. In addition, there may be some mills for which no pulp

and paper MACT category NEI data are currently available. Preliminary risk analysis results for

the pulp and paper sector (based on the current NEI data sets) indicate that some mills may

present risk ab ove the thresholds for further consideration under the residual risk process.

Addition al mill

- specific information would allow EPA to better characterize emission sources,

refine the risk analysis, and to address any unacceptable residual risk that remain s. An update of

the 2005 NATA NEI data sets and more specific information needed for rulemaking re gulatory

analyses would be derived from the ICR. Information collected directly from pulp and paper

mills will have the greatest practical utility for purpo ses of performing the RTR and NSPS

reviews as information from the affected industry will contain the most up

- to

- date, accurate, and

reliable equipment and operational data for each mill

. The ICR will request that new information

be supplied for a 2009 ba se year , and therefore, will not suffer from the considerable “lag time”6 that can be associated with different inventory and permit review cycles (e.g., where the

currently available inventory does not yet reflect recent changes in equipment). 1

To allow re spondents more time to complete the survey , t he ICR has been divided into

three parts , with each part due on a different date . Part I requests information on the pulp and

paper production process addressed under the subpart S NESHAP and subpart BB NSPS an d will

be due within 30 days of receipt of the survey

. An additional 15 days is provided for up to 40

percent of the mills owned by pulp and paper companies operating multiple (more than two)

mills. Part II requests the NEI update and will be due within 100 da ys of receipt of the survey

. Part III requests information on the chemical recovery combustion process addressed under the

subpart MM NESHAP and subpart BB NSPS and will be due within 180 days of receipt of the

survey

. Mills required to complete Pa rt III may postpone until the deadline for Part III submittal

of criteria air pollutant emissions test data and continuous emissions monitoring system ( CEMS )

data required for the emission units listed in Part I Attachment 1.

CAA section 114(a) states that the Administrator may require any owner or operator

su bject to any requirement of the Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or
metho ds; (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.

(b) Use/Use rs of the Data

As mentioned previously, the data used for the originally promulgated NESHAP and

NSPS are outdated and do not reflect the significant changes in emissions collection and control

configurations that have occurred since promulgation of the MAC T standard s. The MACT

standards contain a number of compliance alternatives to allow for a variety of equipment

configurations and process changes to be used in meeting the emission standards and effluent

1 There is a “lag time” associated with compiling large State or national emission inventories. For example, a n updated version of the NEI database is compiled every three years , but the information contained in the NEI may be based on prior years if states do not submit current data

. There can also be a “la g time” associated with posting of recent permits to State websites (particularly if permits are only posted every 5 years as they are reviewed).7 limitations established under the Clean Water Act

. At present, t he EPA does not have a data

base reflecting the post

- MACT and post

- effluent guidelines configuration s of pulp and paper

emission units and air pollution control systems. It is essential for the EPA to have updated

information to use in the regulatory analyses required under CAA sections 112(d) and 112(f)(2).

In addition, this updated information will be used to perform the NSPS review required under

CAA section 111(b). By collecting information for all of the CAA

- required reviews at the sa me

time (i.e., the subpart S and MM RTR reviews and the subpart BB NSPS review), the Agency

can make use of a single collection of information that wou ld allow the Agency to consider

control strategies that are the most effective for both HAP and criteria air pollutants (such as PM,

SO 2 , and NOx) that are regulated under NSPS . The data would also allow the Agency to

evaluate compliance options for startup and shutdown periods, and to consider ways to

consolidate monitoring, reporting, and recordkeeping req uirements among the different rules

under review.

The data collected will be used to update facility information and equipment

configuration

, develop new estimates of the populati on of affected units, and identify the control

measures and a lternative emi ssion limits being used for compliance with the existing rules that

are under review . This information, along with existing permitted emission limits will be used to

establish a baseline for purposes of the regulatory reviews. The emissions test data (te st reports

and CEMS data) collected will be used to verify the performance of existing control measures,

examine variability in emissions, evaluate emission limits, and to determine the performance of

superior control measures considered for purposes of re ducing residual risk or as options for best

demonstrated technology (BDT) under the NSPS review. Emissions data will also be used along

with process and emission unit details to consider subcategories for further regulation and to

estimate the environment al and cost impacts associated with any regulatory options considered.

In addition to informing the CAA

- required RTR and NSPS regulatory analyses for the

pulp and paper sector , it is EPA’s intent that the NEI updates supplied through this information

col lection be used in future versions of the NEI and its successor, the Emissions Inventory

System (EIS). The NEI is used by EPA, States, and the public for a variety of purposes

including tracking of national trends in emissions of criteria and hazardous ai r pollutants. More

information in the NEI can be found at http://www.epa.gov/air/data/neidb.html

.8 The non

- confidential information collected with this ICR would also be available to the

public in the docket and upon request , including pulp and paper indus try trade groups that may

find the information useful for their ongoing data gathering, analyses, and publications. In

addition, such trade groups may wish to use the data collected to review and verify EPA’s

regulatory conclusions.

3. Non

- duplication, C onsultations, and Other Collection Criteria

(a) Non

- duplication

The Agency recognizes that some of the information requested in the information

collection effort may already be included in the submittals made by individual companies,

pursuant to S tate an d national emission inventories, oper ating permits applications, initial

notification forms , and compliance reports

. However, the complete extent of the data fields

requested under this survey is not available in a ny consistent or usable format

. Addition ally,

these sources do not provide detailed emissions test data. As mentioned previously, there is a lag

time associated with State and national emission inventories, and permit review cycles. There is

also a lag time associated with obtaining emission t est reports from State agencies (i.e., agencies

may be reluctant to release emission test results they have not yet processed). The EPA’s

proposed information collection seeks up

- to

- date equipment configuration and operational data

for the 2009 operating year, and thus avoids the effec ts of any such lag time o n data availability.

Although some S tate permits are provided to the public as searchable portable document format

files ( pdfs ) , many S tates do not provide electronic versions of their issued Title V permits

. Even

when the permit is available, the unit

- specific operating data are often not contained within the

permit

. Some of the initial notifications and compliance reports submitted are available in hard

copy only, whereas only the facility

- level i nformation (facility name, location, contact) is

available in an electronic format

. In order to address SSM issues, the Agency has obtained

numerous semi

- annual compliance reports for pulp and paper processes and found the reports to

contain a widely vary ing level of detail. Such variation in the level of detail of permits and

compliance reports means that it would be extremely time consuming for the Agency to extract

the level of process detail needed for regulatory analyses from existing documents (assu ming

that these documents were readily available to EPA) , and that significant data gaps would remain

even after data from existing documents were compiled

.9 Emissions test reports are often retained as hard copies by State agencies and thus are not

readi ly available for all mills. Although one pulp and paper industry trade organization

( National Council for Ai r and Stream Improvement [NCASI]) collects and compiles emission s

test data in technical bulletins, these bulletins alone (while quite informative and valuable) do not

inform all of EPA’s emissions data analyses because: (1) the NCASI technical bulletins are

coded to mask mill identities such that the emissions data cannot be reconciled with other

emissions data available to EPA; (2) the data contain ed in the NCASI reports may no t be

reported in the units of measure needed for analysis of emission limits; (3) much of the data pre

dates implementation of the MACT standards, and (4 ) the data are generally representative of

NCASI member mills

, whereas in formation collected by EPA would be requested from the entire

population of affected mills

. To summarize, the i nformation requested relevant to the current (post

- MACT) equipment

configuration and operation

, regulatory alternatives, emissions data, and ef fectiveness of various

control systems at removing HAP is not readily available from other sources . In the absence of

an industry data collection, the EPA would be forced to try to obtain permits, compliance reports,

and emissions test reports from States ; extract information from these reports (which vary in

detail); and then to fill data gaps where information is not available from the reports obtained.

This process of acquiring and extracting data from existing reports would require more time than

an i ndustry data collection, and ultimately would be expected to yield incomplete information.

Information collected directly from pulp and paper mills would provide the most timely and

complete post

- MACT data set with the greatest practical utility for purpo ses of performing the

NSPS and RTR reviews that are due to be completed under CAA sections 111(b) and 112(d) and

(f)(2)

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

A s required by the Paperwork Reduction Act of 1995 (PRA) and the subsequent rule

issued by the Office of Management and Budget ( OMB ) on August 29, 1995 (60 FR 44978) , t h e

ICR was submitted for a first public review on June 23, 2010 (75 FR 35792), and a second public

review on December 7, 2010 (75 FR 76005 )

. A 60

- day comment peri od (ending August 23,

2010) was provided during the first review for the public to submit comments to EPA regarding

the proposed new data collection. A total of three comments were received by EPA regarding

the proposed ICR

. E PA revised the ICR to addres s the public comments prior to submitting the10 ICR to OMB. The second public review (ending January 6 , 2011) resulted in two public

comments which also have been incorporated into the ICR. The comments received and EPA’s

response to each comment is availa ble in the regulatory docket established for this rule, EPA

HQ

- OAR

- 2007

- 0544 at www.regulations.gov

. (c) Consultations

Initial feedback was received from the affecte d industry regarding the scope of a pulp and

pape r sector survey

. D etailed comment s on the proposed ICR were received from the industry in

August 2010 and December 2010 , followed by meetings with the industry in October 2010 and

November 2010 to discuss in greater detail the design and content of the IC R. The EPA has

implemented many changes to specific ICR questions as a result of these consultations. In

addition, EPA revised the survey so that it would be administered in three parts with staggered

due dates to provide respondents with additional time to complete the survey. Part I of the ICR

will request information on the pulp and paper production process addressed under the subpart S

NESHAP and subpart BB NSPS and will be due 30 days after receipt of the survey. An

additional 15 days is provided f or up to 40 percent of the mills owned by pulp and paper

companies operating multiple (more than two) mills. Part II of the ICR will require the facilities

to complete an electronic update of their 2005 NATA NEI data set to be used for RTR purposes

and wi ll be due 100 days after receipt of the survey. Part III of the ICR will request information

on the chemical recovery combustion process addressed under the subpart MM NESHAP and

subpart BB NSPS and will be due 180 days after receipt of the survey. Mills required to

complete Part III may postpone submittal of criteria air pollutant emissions test data and CEMS

data required for the emission units listed in Part I Attachment 1 until the deadline for Part III.

(d) Effe cts of Less Frequent Collection

This IC R will require the owner/operator of each pulp and paper facility to c omplete an

electronic survey in three parts, with staggered due dates. Each part requests different

information. EPA expects the information requested in all three parts of this surve y to be a one

time effort.

(e) General Guidelines

This ICR will adhere to the guidelines for Federal data requestors, as provided at 5 CFR

1320. 6

.11 (f) Confidentiality

Respondents will be required to respond under the authority of CAA section 114. If a

re spondent believes that disclosure of certain information requested would compromise a trade

secret, it should be clearly identified as such and will be treated as confidential until and unless it

is determined in accordance with established EPA procedure a s set forth in 40 CFR Part 2 not to

be entitled to confidential treatment

. All 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 (see 40 CFR 2; 41 FR

36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251,

September 28, 1978; 44 FR 17674, March 23, 1979)

. Any information subsequently determined

to constitu te a trade secret will be protected under 18 U.S.C. 1905

. If no claim of confidentiality

accompanies the information when it is received by EPA, it may be made available to the public

without further notice (40 CFR 2.203, September 1, 1976)

. Because CAA section 114(c)

exempts emission data from claims of confidentiality, the emission data provided may be made

available to the public

. Therefore, emissions data should not be marked confidential

. A

definition of what EPA considers emissions data is provide d in 40 CFR 2.301(a)(2)(i).

(g) Sensitive questions

This section is not applicable because this ICR will not involve matter s of a sensitive

nature

.
4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Respondents affected by this action are owners/operators of mills that are major sources

or synthetic area sources of HAP emissions and produce pulp , perform bleaching, or

manufacture paper or paperboard products

. 2 In the U.S., there are a total of 3 52 mills including:

• 1 12 mills t hat c arry out chemical wood pulping (kraft, sulf ite, soda, or semi

- chemical),

• 39 mills that c arry out mechani cal, groundwood , secondary fiber, and non

- wood pulping,

2 As defined in 40 CFR Part 63, subpart A, “ m ajor source ” means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of haz ardous air pollutants, unless the Administrator establishes a lesser quantity, or in the case of radionuclides, different criteria from those specified in this sentence. A “synthetic area source” is a stationary source which is subject to federally

- enforc eable conditions that limit its potential to emit to below major
source thresholds.12 • 93 mills that perform bleaching, and

• 334 mills that m anufacture paper or paperboard product s.
Some mills perform multiple operations (e.g., chemical pulping, bleaching, and papermaking;

pulping and unbleached papermaking; etc.). The counts provided above are counts of potential

respondents based on the Lockwood

- Po st Online (as of March 2009), u pdated with feedback

from mills called to verify contacts and comments submitted to EPA in response to the draft mill

list published for public comment. Mills that only purchase pre

- consumer paper or paperboard

products and convert them into other product s (i.e., converting operations) are not affected by

this action. The North American Industry Classification System (NAICS) codes for respondents

affected by the information collection include 32211 for pulp mills, 32212 for paper mills, and

32213 for pape rboard mills.

(b) Information Collected

(i) Data Items. Each owner/operator of each affected mill will be required to

complete a n electronic survey that contains s everal components. Some survey components are

not applicable for some types of mills. T he draft electronic survey is a series of Microsoft Excel

spreadsheet file s, each of which is divided into a series of worksheets (“tabs” within the

spreadsheet file )

. Table 1 below denotes w hich pulp and paper sector survey spreadsheet tabs

are to be com pleted depending on the part of the survey and type of mill

. S urvey spreadsheet

tab s for Parts I and III of the ICR must be completed for all mills that are major or synthetic area

sources of HAP emissions and produce pulp , perform bleaching, or manufactu re paper or

paperboard products ; survey spreadsheet tabs for Part II of the ICR must only completed for

mills that are major sources. Mills will also be asked to supply process flow diagrams for the

following mill areas (as applicable): pulping process, c hemical recovery area, wastewater

treatment, and black liquor gasification (if used).13 Table 1. Survey Spreadsheets and Tabs to Complete

Spreadsheet tab Types of mills that should complete this spreadsheet tab Estimated
number of
mills P&P survey _PI .xl s Mill All mills 3 52

PI Equip detail All mills 3 52

PI Permit limits All mills 352

PI Controls Mills with add

- on air pollution controls on pulping emission units, bleaching emission units, or papermaking emission units. 3 52

Pulp prod Mills that produc e any type of pulp (including chemical, mechanical/groundwood, secondary fiber, including non

- wood pulp) 1 51

Byproducts Mills that produce turpentine or tall oil byproducts from pulping processes 98

Kraft condensates Mills that perform kraft pulping 98

CCA Mills that perform kraft pulping and use the clean condensate compliance alternative (CCA) 49 1

Bleaching Mills that perform bleaching 93 Paper prod Mills the produce paper or paperboard products 3 34

HAP additives Mills the produce paper or paperb oard products 3 34

WW Mills with onsite wastewater treatment plants 3 52

PI Emissions test

data All mills 3 52

P&P NEI update .xls (or P&P NEI blank.xls) Facility (or New Facility) All major source mills 352 2

Inventory (or New Facility) All major source mills 352 2

P&P survey_PIII.xls

PIII Equip detail M ills that use chemical recovery combustion processes 1 12

PIII Permit limits M ills that use chemical recovery combustion processes 112

PIII Controls Mills with add

- on air pollution controls on chemical r ecovery combustion

processes

. 1 12

PCC Mills that route lime kiln, boiler, or other process exhaust to a precipitated calcium carbonate (PCC) plant 30

PIII Emissions test

data M ills that use chemical recovery combustion processes 1 12

1. Assumes that up to 50% of kraft mills use the CCA. 2. Overestimate; EPA will not know the number of synthetic area sources that are exempt from Part II until the

Part I survey responses have been received.

In addition to the pulp and paper sector survey spreadsheet s li sted in Table 1, s eparat e

spreadsheets are provided for submittal of continuous emissions monitoring system (CEMS)

and/or continuous opacity monitoring system (COMS) data

, or optional control measure cost

informat ion. Separate versions of these spreadshee ts are to be submitted under Parts I and III of

the survey for the different emissions units covered under those parts.

E missions data collected under the Emissions test data tab s listed in Table 1 or the CEMS

spreadsheet s mentioned above will allow EPA to characterize the performance of equipment and

controls, reevaluate emissions li mits, and consider variability. Emissions data ( test reports or14 CEMS data) are being requested for affected sources and emissions units for which emissions

limits may be reeva luated under NSPS review or RTR. The pollutants for which emissions data

are requested include particulate matter (PM), filterable PM less than 2.5 microns (PM 2.5 ),

condensable PM 2.5 , speciated HAP metals, chlorine (as a surrogate for chlorinated HAP),

hy drochloric acid, methanol (as a surrogate for organic HAP), acetaldehyde, formaldehyde, total

hydrocarbon (as carbon), dioxin/furan (CDD/CDF), polycyclic organic matter/polycyclic

aromatic hydrocarbon (POM/PAH), total reduced sulfur (TRS), nitrogen oxides (NOx), sulfur

dioxide (SO 2 ), and carbon monoxide (CO). Separate “tabs” of the CEMS spreadsheet are

provided for the different pollutants for which CEMS are available

.
The control cost spreadsheet requests information related to the capital and operating

c osts of selected air pollution controls or process/equipment changes. Submittal of the contr ol

cost information is optional . The Agency wishes to receive enough cost information on a

voluntary basis to perform the CAA

- required regulatory analyses. Howev er, should additional

cost information be needed, EPA reserves the right to follow up with mills that have installed

equipment or implemented process changes of interest to request cost information under CAA

section 114 authority.

Although a large amount of information is needed for regulatory reviews of the two

NESHAP and NSPS, the EPA has designed the pulp and paper information collection in a way to

minimize the burden associated with supplying and processing this information. The survey will

collect information to supply multiple regulatory actions in order to minimize duplication and

burden associated with multiple collections for the different rules

. For mills with prior NEI data,

t h e EPA will pre

- populate the Part II spreadsheets with each mill’s 2005 NATA NEI data set to

be review ed (thereby reducing respondent burden to locate and import their mill’s NEI data).

For mills with no prior NEI data, a blank spreadsheet containing the NEI data fields to be

populated will be provided. The EPA has mini mized the burden associated with providing these

NEI updates by exempting synthetic area sources from this requirement; only major source mills

would be required to provide NEI updates. The burden associated with the NEI update s has also

been further redu ced because updates to criteria air pollutant and inclusion of total reduced sulfur

data in the NEI update s are optional. A lookup spreadsheet containing only the NEI codes

included in the 2005 NEI data set will be provided, along with a simplified crossw alk of the pulp

and paper source classification codes SCC codes in order to ensure that valid NEI codes are used15 and to reduce respondent time associated with locating codes on the NEI website. The pulp and

paper information collection is being administer ed in spreadsheet form (as opposed to data base

software ) because respondents are likely to be more familiar with spreadsheet use than with data

bases, and (following QA) data from the Excel spreadsheet rows can be readily imported into

Access data base so ftware for use by the Agency (eliminating the time required for EPA to key

enter data)

. The pulp and paper survey spreadsheets can be provided to mills on a flash drive

which respondents can use to save and submit their survey materials such as electronic copies of

flow diagrams, emission test reports, and the survey spreadsheets. The burden associated with

collection of emissions test data has be en reduced in several ways:

(1) Only existing emissions data (CEMS data or emissions test reports) are being requested at this time. Mills are not required to conduct any new emissions testing or to install or operate any new CEMS or COMS to respond to this survey. (2) Data are , for the most part, being requested for the HAP surrogates defined in the

MACT s tandards, as opposed to speciated chlorinated HAP or speciated non

chlorinated organic HAP. Speciated data are being requested for acetaldehyde and formaldehyde (in addition to the methanol surrogate for organic HAP) because these pollutants are expected to be of interest for residual risk. (3) EPA has developed a matrix of emission units and pollutants for which test data are requested for the emissions units covered in Part I and Part II . Emissions data are only being requested for emissions unit and po llutant combinations for which emissions limits may be reevaluated under NSPS review or RTR (or for pollutant that may serve as an indicator or surrogate for emission unit or control system performance). The matrix provides cutoff d ates for selected emiss ion unit and pollutant combinations ( or in some cases, only requests the most recent test data ) in order to minimize respondent burden and to ensure the Agency’s ability to process the data requested

. (4) Respondents are required to submit emissions test r eports in order for EPA (or EPA contractor personnel) familiar with extracting test data from test reports to enter the
data in a manner that ensures consist ent and reliable treatment of the data (e.g., with
respect to data averaging, non

- detects , etc ). (5 ) Respondents may provide electronic or hard copy emissions test reports, whichever they find to be less burdensome. (6) The survey instructions allow respondents to provide CEMS data in an alternative format if they cannot fit it into the survey spreadshe et provided. (7) Mills required to complete Part III may postpone submittal of criteria air pollutant emissions test data and CEMS data required for the emission units listed in Part I
Attachment 1 until the deadline for Part III

.

The EPA has minimized t he burden associated with providing permit limits by allowing

submittal of the permit or summary of permit limits in an alternative format. The EPA is not

requesting state mass

- based limits. The survey instruction s also include a table of suggested16 permi t limit units of measure that are of the most interest ( based on the units of measure for

Federal limits )

. Finally, the EPA has minimized the collection of control measure cost information by

focusing the collection of cost information on air pollution con trols and process changes of

particular interest for purposes of the NSPS review or RTR (as opposed to all control measures

employed by pulp and paper mills). The EPA expects cost information obtained from the

industry to be some of the most reliable and valid information available since the cost data would

be specific to pulp and paper applications. In addition, collection of cost information from the

industry (as opposed to a separate collection from other sources such as vendors) would

accelerate EPA’s ability to analyze the cost impacts of regulatory options.

( ii ) Respondent Activities

. The activities a respondent must undertake to fulfill the

requirements of the information collection are presented in Attachment 2

. These include: i) read

instruct ions; ii) provide information on each affected source through electronic survey; and iii)

submit hard or electronic copies of flow diagrams, previous emission test reports , and available

CEMS or COMS data

.
5. The Information Collected

– Agency Activities, Collection Methodology, and

Information Management

(a) Agency Activities

A list of activities required of the EPA is provided in Attachment 3

. These include: i)

de velop electronic questionnaire and packages for mailout; ii) answer respondent questions

(in cluding claims of true area source status or that mill in not engaged in processes of interest);

iii) review and analyze responses and emissions data; and iv) analyze requests for confidentiality.

(b) Collection Methodology and Management

In collecting an d analyzing the information associated with this ICR, EPA will use

personal computers and applicable spreadsheet and database software

. To better facilitate

uniformity in the format of the requested data , and, thus, increase the ease of database entry,

st andardized survey questions, example responses, and Excel spreadsheet forms will be

distributed to respondents. EPA will ensure the accuracy and completeness of the collected

information by reviewing each submittal

. Flow diagrams may be used to answer an y questions

revealed during quality assurance (QA) of each submittal. The EPA may place follow

- up calls to

mills should questions remain after reviewing all materials submitted. Following QA of each17 submittal, the spreadsheet information from each mill w ill be uploaded into an Access data base

for further analysis. Survey responses claimed as CBI will be housed in a separate data base

from the non

- CBI survey responses. In addition, a copy of the NEI updates submitted will be

routed for inclusion in EPA’ s residual risk input data ba se, and for inclusion in future versions of

the NEI and its successor, the Em issions Inventory System (EIS). Emissions test report data will

be entered into a data base by EPA (or EPA contractor personnel) familiar with extrac t ing test

data from test reports. In addition CEMS data would be uploaded in a data base for analysis of

emissions variability. The resulting data bases will be QA’d prior to and as part of regulatory

analyses.

(c) Small Entity Flexibility

All responden ts required to comply with the pulp and paper data gathering effort will be

subject to the same requirements

. EPA expects that a small percentage of the re spondents may

be small entities. Small entities are likely to be non

- integrated mills with lower

- ca pacity pulp

and paper processes (e.g., smaller mills that produce paper from pu rchased pulp). Small entities

and other mills that are not major or synthetic area sources of HAP emissions (i.e

., true area

sources) would not be required to complete the surv ey , provided that they submit documentation

of their true area source status. Even if they are major or synthetic area source s of HAP

emissions, s mall entities (a nd other non

- integrated mills) would have fewer portions of the

survey to complete

, as their operations would likely be less extensive. In addition, synthetic area

sources would not be required to complete Part II of the survey. Also, a ny individual small

entity would be expected to receive only one CAA section 114 letter so their response burde n

will be minimized

. The Agency also plans to use an electro nic format of the questionnaire in

order to reduce the burden and improve the data accuracy from all respondents, including small

entities

. In addition, the survey will contain a question to det ermine the small entity status of a

facility

. This question will help to identify, quantify, and minimize the burden on small entities

during the revised rulemaking process.

(d) Collection Schedule

EP A anticipates issuing the CAA s ection 114 letters by February 2011

. These CAA

section 114 letters would require the owner/operator of each pulp and paper mill to complete Part

I of the ICR w ithi n 30 days of receipt of the survey , Part II within 100 day s , and Part III within

180 days

. EPA will compile and a nalyze the survey response data upon receipt

.18 6

. Estimating the Burden and Cost of the Collection

( a ) Estimating Respondent Burden and Costs

Attachment 2 presents estimated costs for the required data collection activities

. Labor

rates and associated cost s are based on Bureau of Labor Statistics (BLS) data

. Technical,

management, and clerical average hourly rates for private industry workers and were taken from

the United States Department of Labor, Bureau of Labor Statistics, Se p tember 2009

, “Table 2.

Ci vilian Workers, by occupational and industry group,” available at

www.bls.gov/news.release/ecec.t02.htm

. Wages for occupational groups are used as the basis

for the labor rates with a total compen sation of $46. 76 per hour for technical, $5 4

. 52 per hour for

managerial, and $23

. 11 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 is used to account for

these costs

. The fully

- burdened hourly wage rates used to represent respondent labor costs are:

technical at $9 8.20 , management at $11 4

. 49 , and clerical at $4 8.53

. These estimates represent

the one

- time burden that will be incurred by the recipients.

( b ) Estimating Agency Burden and Costs

The costs the Federal Government would incur are presented in Attachment 3

. The

Agency labor rates are from the Office of Personnel Management (OPM) 200 9 General Schedule

which excludes locality rates of pay

. These ra tes can b e obtained from Salary Table 2010

- GS,

available on the OPM website at www.opm.gov/oca/10tables/html/gs_h.asp

. The government

employee labor rates are $16

. 28 per hour for clerical (GS

- 7 , Step 1 ), $ 34.3 4 for technical (GS

1 3 , Step 1), and $ 47.74 for managerial (GS

- 1 5 , Step 1 )

. 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 $ 26.05 , technical at $ 54.9 4 , and managerial at $ 76.38

. ( c ) Estimating the Respondent Universe and Total Burden and Costs

Estimates based on the Lockwood

- Post Online (as of March 2009) and follow

- up

comments received indicate that the potential responde nt universe consists of 3 52 mills. A ll 3 52

of these mills will be re quired to complete some portion of the electronic survey , with the

exception of mills that provide documentation (a one

- page form) to EPA within 20 days

certifying that either : (1) they ar e not a major or synthetic area source of HAP emissions

, (2) they

were not operational in 2009 and remain closed, or ( 3 ) they do not produce pulp, perform

bleaching, or manufacture paper or paperboard products

. The government burden estimate19 provided in A ttachment 3 assumes that 1 5 percent of mills will provide documentation of true

area source status , mill closure, or that pulping, bleaching, papermaking is not performed at the

mill . However, it is not known how many of these claims will be valid so all mills are included

in the burden estimate for respondents (in Attachment 2)

. Attachment 2 lists the various portions

of the survey in detail and provides an estimated number of mills required to complete each

portion of the survey. Specific counts of the different types of mills used in the burden estimates

are provided in Part B of this supporting statement.

( d

) Bottom Line Burden Hours and Costs Tables

(i) Respondent tally

. The bottom line industry burden hours and costs, presented in

Attachment 2

, a re calculated by summing the pers on

- hours column and by summing the cost

column

. The total burden and cost to the industry for 3 52 resp ondents is 161

, 106 hours and

$15,238

, 347

. No capital or annualized costs are applicable because this is a one

- time subm ittal.

O&M costs of $6,336 are estimated for postage to mail in the th ree parts of the survey response

to EPA.

(ii) Agency tally

. The bottom line Agency burden and cost, presented in Attachment 3

is calculated in th e same manner as the industry burden and cost

. The estimated burden and cost

for 352 respondents is 10,062 hours and $6 25

, 071

, which includes $ 7,611 in O &M costs to send

certified CAA s ection 114 letters to all respondents with electronic return receipt and a flash

drive containing pre

- popul ated spreadsheets , questionnaire printing costs, and computer storage

of data received

. (iii) The complex collection

. This ICR is a simple collection; therefore

, this section

does not apply.

(iv) Variations in the annual bottom line

. This section does no t apply as this is a one

time collection.

( e ) Reasons for Change in Burden

This is the initial estimation of burden for this information collection; therefore, this

section does not apply.

( f

) Burden Statement

Burden means the total time, effort, or finan cial resources expended by persons to

generate, maintain, retain, or disclose or provide information to or for a Federal agency

. This20 includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the pu rposes of collecting, validating, and verifying information, processing and

maintaining information, and disclosing and providing information; adjust the existing ways to

comply with any previously applicable instructions and requirements; train personnel to be able to

respond to a collection of information; search data sources; complete and review the collection of

information; and transmit or otherwise disclose the information

. An agency may not conduct or

sponsor, and a person is not required to respond to, a collection of information unless it displays a

currently valid OMB control number

. The OMB control numbers for EPA’ s regulations are listed

in 40 CFR part 9 and 48 CFR chapter 15.

The tota l cost burden for the pulp and paper data gathering effort i s estimated to be

161

, 106 hours and $1 5,238

, 347 ( 458 hours and $43,291 per respondent for 352 respondents )

. This ICR does not include any requirements that would cause the respondents to incur either

capital or start

- up costs

. O&M costs of $6,336 ( $18 pe r respond ent) are estimated for postage to

mail in the survey response to EPA.

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

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

ID No. EPA

- HQ

- OAR

- 2007

- 0544

, which is available for online viewing at

www.regulations.gov, or in hard copy at EPA Docket, EPA/DC, EPA West, Room 3334, 1301

Consti tution Ave., NW, Washington, DC

. The EPA/DC Public Reading Room is open from

8 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 Air and Radiati on

Docket Center is 202

- 566

- 1742.

An electronic version of the public docket is available at www.regulations.gov

. This site

can be used to submit or view public comments, access the index listing of the contents of the

public docket, and to access those d ocuments in the public docket that are available

electronically

. When in the system, select “search,” then key in the Docket ID Number

identified above

. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503,

Attention: Desk Office for EPA

. Please include EPA Docket ID No. EPA

- HQ

- OAR

- 2007

- 0544

in any correspondence

.2122 INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW
SOURCE PERFORMANCE STANDARD S (NSPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)

Part B of the Supporting Statement

1. Respondent Universe

Estimates based on the Lockwood

- Post Online (as of March 2009) indicate tha t the

potential respondent universe consists of 3 52 mills. All 3 52 of these mills will be re quired to

complete some portion of the electronic survey , with the exception of mills that provide

documentation to EPA certifying that either: (1) they are not a m ajor source or synthetic area

source of HAP emissions , (2) they were not operational in 2009 and remain closed, or (3) they

do not produce pulp, perform bleaching, or manufacture paper or paperboard products

. Any mill

that meets one of these criteria will need to complete the one

- page form in the survey overview

document certifying their status and submit it to EPA within 20 days of receiving the ICR. The

government burden estimate provided in Attachment 3 assumes that 1 5 percent of mills will

provide doc umentation of true area source status , mill closure, or that pulping, bleaching,

papermaking is not performed at the mill . However, it is not known how many of these claims

will be valid

, so all mills are included in the burden estimate for respondents (i n Attachment 2).

Similarly, it is also unknown how many mills are synthetic area sources exempt from the

requirement to complete Part II of the survey, so all mills are included in the burden estimate for

respondents for Part II (in Attachment 2). Attach ment 2 lists the various portions of the survey

in detail and provides an estimated number of mills required to complete each portion of the

survey. Specific counts of the different types of mills used in the burden estimates are as

follows:23 Chemical pu lp mills Count

kraft (including kraft/mechanical) 89

soda 1

sulfite 5

kraft/semichemical 9

semichemical 8

1 12 Mechanical/groundwood, secondary fiber, and non

- wood pulp mills

mechanical 14

specialt y (recycled) 2 2

nonwood 3

39

Paper/paperboard only + Integrated paper mills 3 34

Number of mills that perform bleaching 93

TOTAL NUMBER OF MILLS 3 52

2. Response Rates

Since the information will be requested pursuant to the auth ority of CAA section 114,

EPA expects that all respondents requested to submit information will do so

.24 List of Attachments

1. Draft Questionnaire Content

2. Industry Burden and Costs for Responding to the Questionnaire

3. Agency Burden and Costs25 Attachment 1.

Draft Questionnaire Content

The draft electronic questionnaire may be found in separate files accompanying this supporting statement, including the following:

File name Description

Phased Instructions
Overview.doc This is the draft survey overview document. This file provides an overview of the sources covered under the pulp and paper sector survey, the sources exempt from the survey, the components and due dates of the three

- part survey, and the base year for the survey. Attachments to t his document are: (1) documentation of true area, non

operational, or non

- applicable status; (2) NSPS and NESHAP definitions; (3) acronyms and abbreviations used in the survey materials ; and (4) signed

certification form

. Part I

– Mill Overview and Subpar t S Data P&P survey

instructions _PI .doc This file provides instructions for completing and submitting Part I of the survey (including CBI and non

- CBI responses); the request for flow diagrams; the request for emission test data (emissions test reports or CEMS) for pulp and paper production

units ; and the request for optional control measure cost information for those units

. Attachments to this document are: (1) a list of emission units to include in Part I of the survey response; (2) small business size s tandards ; and ( 3 ) a table of pulp and paper production emission units and pollutants for which existing emission test data are requested. P&P survey _PI .xls This multi

- tabbed spreadsheet file is the main portion of Part I of the survey. It

includes a numb er of pulp and paper sector tabs with questions needed to specify and
characterize pulp and paper production emission units and control systems. A listing of the tabs in this file is provided in Table 1 of the Part I survey instructions

document described above.

P&P CEMS _PI .xls The spreadsheet contains templates for submittal of CEMS or COMS data for pulp and paper production units (for mills that currently operate CEMS or COMS). Separate tabs are provided for pollutants such as TRS, NOx, SO 2 , CO, metha nol, chlorine, and PM. An optional tab is included for CEMS cost information, and an example tab is provided.

P&P costs

OPTIONAL _PI .xls This file contains control device and process change cost questions for pulp and paper production emission units . The se cost questions are optional.

Boiler MACT Code Lookup.xls This file provides Boiler MACT Facility ID and Unit ID codes extracted from the Boiler MACT data base for NAICS 322 for the convenience of respondents wishing to supply these codes.

Part II

– N EI Update

P&P NEI instructions.doc This file provides instructions for completing and submitting the NEI update in Part II of the survey . Attachments to this document are: (1) a list of emission units to
include in the NEI update ; (2) resources for estim ating emissions ; and (3) instructions for accessing the FTP site

. P&P NEI update.xls This spreadsheet file includes the NEI update portion of Part II of the survey for mills with existing NEI data. It includes pre

- populated Facility and Inventory tabs wi th additional specified columns for respondents to enter any revisions.

P&P NEI blank.xls This spreadsheet file includes the NEI update portion of Part II of the survey for mills
for which NEI data do not exist. It includes blank New Facility and New Inv entory tabs with specified columns for respondents to enter the relevant information. Lookups for P&P survey.xls This spreadsheet contains lookup code tables needed to complete the NEI revisions. There are lookup tables for the pulp and paper source clas sification codes (SCC) codes grouped according to process, and for all SCC codes. Also included are lookup
tables needed to review and/or revise the various NEI data fields that contain codes.26 File name Description

Part III

– Chemical Recovery Combustion Sources P&P survey

instructions _PIII .doc This file provides instructions for completing and submitting Part III of the survey (including CBI and non

- CBI responses); the request for emission test data (emissions test reports or CEMS) for chemical recovery combustion units ; an d the request for optional control measure cost information for those units . Attachments to this document are: (1) a list of emission units to include in Part III of the survey response;

and (2) a table of chemical recovery combustion units and pollutants for which existing emissions test data are requested. P&P survey _PIII .xls This multi

- tabbed spreadsheet file is the main portion of Part III of the survey. It

includes a number of pulp and paper sector tabs with questions needed to specify and

character ize chemical recovery combustion units and control systems. A listing of the tabs in this file is provided in Table 1 of the Part III survey instructions document
described above.

P&P CEMS _PIII .xls The spreadsheet contains templates for submittal of CEM S or COMS data for chemical recovery combustion units (for mills that currently operate CEMS or COMS). Separate tabs are provided for pollutants such as TRS, NOx, SO 2 , CO, methanol, chlorine, and PM. An optional tab is included for CEMS cost information, and an example tab is provided.

P&P costs

OPTIONAL _PIII .xls This file contains control device and process change cost questions for chemical recovery combustion units . These cost questions are optional.27 Attachment 2.

Respondent Burden and Costs for th e Information Collection

Respondent Activity (A) Hours per
Occurrence (B) Occurrences/ Respondent/Year (C) Hours/ Respondent/ Year (A x B) (D) Respondents/

Year 1 (E) Technical
Hours/Year

(C x D) (F) Managerial
Hours/Year

(E x 0.05) (G) Clerical

Hou rs/Year

(E x 0.10) (H) Cost/ Year
1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)

4. REP ORT REQUIREMENTS

A. Read Instructions 12 1 12 352 4224 211 422 $ 459,460
B. Required Activities

a. Part I: Mill Overview and Subpart S Data

i . Submit flow diagrams 20 1 20 352 7040 352 704 $ 7 65,767

ii . Complete and submit survey spreadsheet tabs, as follows:

Mill (general information) 6 1 6 3 52 2,112 106 211 $ 229,730

PI Equip detail 4 0 1 4 0 352 14,080 704 1,408 $1,531,534

PI Permit limits 40 1 40 352 14,080 704 1,408 $1,531,534

PI Controls 15 1 15 352 5,280 264 528 $574,325
Pulp prod 6 1 6 1 51 906 45 91 $ 98,549
Byproducts 4 1 4 98 392 20 39 $4 2,639

Kraft condensates 8 1 8 98 784 39 78 $ 85

, 279

CCA 2 8 1 8 49 392 20 39 $4 2

, 639
Bleaching 6 1 6 93 558 28 56 $6 0

, 696
Paper prod 6 1 6 334 2,004 100 200 $2 17,982

HAP additives 20 1 20 334 6,680 334 668 $ 726,608

WW 6 1 6 352 2,11 2 106 211 $229,730

PI Emissions test data 3
Reports for chemical pulping ( 4 reports) 1 4 4 112 448 22 45 $ 48,731 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1 1 1 466 466 23 47 $5 0

, 689

iii . Gather and scan/copy emission test reports for
submittal 3,4
Reports for chemical pulping (4 reports) 1.5 4 6 112 672 34 67 $ 7 3

, 096 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1.5 1 1.5 466 699 35 70 $76

, 0 33

iv . Complete and submit Part I CEMS spreadsheet 5 10 1 1 0 1 1 2 1,120 56 112 $1 21

, 8 2 7

v

. Complete and submit Part I optional cost spreadsheet 6 10 1 10 88 880 44 88 $ 95

, 721

vii. Complete signed certification form for part I 0.2 1 0.2 352 70 4 7 $ 7,658

b

. Part II: NEI Update 7

i. Complete and submit survey spreadsheet tabs, as follows:

Mills that previously updated their NEI for RTR 120 1 120 96 11,520 576 1,152 $1, 253

, 073
Mills that have not previously updated NEI for RTR 180 1 180 226 40,680 2,034 4,068 $ 4,424,914
Mills with no prior NEI data 28 0 1 28 0 30 8,400 420 840 $ 913 ,69928 Respondent Activity (A) Hours per
Occurrence (B) Occurrences/ Respondent/Year (C) Hours/ Respondent/ Year (A x B) (D) Respondents/

Year 1 (E) Technical
Hours/Year

(C x D) (F) Managerial
Hours/Year

(E x 0.05) (G) Clerical

Hou rs/Year

(E x 0.10) (H) Cost/ Year
ii. Complete signed certifi cation form for part II 0.2 1 0.2 352 70 4 7 $7

, 658

a. Part III: Chemical Recovery Combustion Sources

i . Complete and submit survey spreadsheet tabs, as follows:

PIII Equip detail 20 1 20 1 12 2, 2 40 112 224 $243,653

PIII Permit limits 20 1 20 112 2,240 112 224 $243,653

PIII Controls 15 1 15 1 12 1,680 84 168 $1 82 ,7 40

PCC 4 1 4 30 120 6 12 $13,053

PIII Emissions test data 3 1 14 14 1 1 2 1, 568 78 157 $1 70

, 557

ii. Gather an d scan/copy emission test reports for submittal 3,4 1.5 14 21 112 2, 352 118 235 $2 55

, 836

iii . Complete and submit Part III CEMS spreadsheet 5 30 1 30 1 12 3, 3 60 1 6 8 3 3 6 $365

, 480

iv

. Complete and submit Part III optional cost spreadsheet 6 30 1 30 28 840 42 84 $9 1

, 370
v. Complete signed certification form for part III 0.2 1 0.2 1 1 2 2 2 1 2 $2, 437
C. Create Information (Included in 4B)
D. Gather Existing Information (Included in 4B)

E. Writ e Report (Not Applicable)
5. RECORDKEEPING REQUIREMENTS (Not applicable)

TOTAL ANNUAL LABOR BURDEN AND COST 1 40,092 7,005 14,009 $1 5,238

, 347

total = 161

, 106 avg hr/ respondent = 458 8 $ 4 3,291

ANNUAL CAPITAL COSTS (Not Applicable) $

- ANNUALIZED CAPITAL COSTS (Not Applicable) $

- TOTAL ANNUAL COSTS (O&M) 9 $ 6

, 336
TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 6,336

1. The number of respondents per year is based on the mill counts listed in Part B, Section 1

- Respondent Universe.

2

. Assumes that 50% of kraft mill s use the clean condensate alternative (CCA).

3

. It is estimated that chemical pulp mills will submit 18 test reports each (4 in response to Part I and 14 in response to Part III) , and that non

- chemical pulp mills, bleach plants, and paper mills will each submit 1 test report.

4

. It is estimated that it would take 1.5 hour s to locate and scan or copy each test report.
5

. Assumes that all chemical pulp mills will populate the CEMS spreadsheet with CEMS and/or COMS data. The majority of CEMS data are expecte d to be submitted for the emissions units covered under Part III.

6

. Assumes that 25% of mills will provide cost information.

7. S ynthetic area sources will not be required to complete Part II of the survey . However, EPA will not know the number of synthe tic area sources that are exempt from Part II until the Part I survey responses have been
received. Therefore , all mills are included in the burden estimate for respondents for Part II

. 8 . The average number of labor hours per respondent (458) is equal to the total annual labor burden (161,106) divided by the total number of respondents (i.e., mills) (352).

9 . Postage Costs for mailing survey re s ponses to EPA are estimated at $6 for Federal Express letter size envelope flat rate (1 per respondent

– i

. e., 3 total ).29 Attachment 3.

Agency Burden and Costs

Agency Activity (A) EPA Hours/
Occurrence (B) Occurrences/ Respondent/Year (C) EPA Hours/Respondent/Year (A x B) (D) Respondents/Year 1 (E) EPA
Technical Hours/

Year (C x D) (F) EPA Managerial
Hours/Year

(E x 0.05) (G) EPA
Clerical
Hours/Year

(E x 0.10) (H) Cost, $
Develop/revise questionnaire spreadsheets and instructions 400 1 400 1 400 20 40 $24,547
Develop survey webpage 1 0 1 1 0 1 10 1 1 $614

Pre

- populate mill spreadsheets with existing NEI data 2 1 1 1 322 322 16 32 $1 9

, 760 Mail out questionnaire 3 0.7 1 0.7 3 52 246 12 25 $1 5.121 Review claims that survey is not required to be completed due to area source status, mill closure, or because mill does not produce pulp, perform bleaching, or manufacture pape r products 4 1 1 1 5 2.8 53 3 5 $3, 240 Answer respondent questions via phone, email, and/or frequently asked questions posted on webpage 5 1 1 1 88 88 4 9 $5, 400 Analyze requests for confidentiality 6 1 1 1 88 88 4 9 $5, 400
Review signed certifi cation form s 0.1 1 0.1 3 52 35 2 4 $2, 160 Review and analyze responses (including follow

- up)

NEI data (from Part II) 7 4 1 4 3 52 1, 408 70 141 $ 86

, 406 Sector survey spreadsheet data (from Parts I and III) 8 1 8 352 2

, 816 141 282 $ 172

, 812

CEMS data (f rom Parts I and III) 8 2 1 2 1 1 2 224 11 22 $ 1 3

, 746 Optional cost data (from Parts I and III) 9 2 1 2 88 176 9 18 $ 1 0,801 Print emissions test reports 10 0.1 2,482 248.2 1 2 48 12 25 $1 5,232 Enter emissions test data from test reports
Report s for chemical pulping (18 reports)
Enter PM, chlorine, HCl, methanol, THC, NOx, SO2, CO 1 16 16 112 1,792 90 179 $ 109,971 Enter speciated HAP metals, PM2.5 (filterable and condensable), CDD/CDF, speciated TRS,

POM/PAH 2 2 4 1 12 448 22 45 $27

, 493 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1 1 1 466 466 23 47 $ 28

, 597 Review/analyze emissions test data 11 0.5 2, 482 1,241 1 1, 241 62 124 $ 76,158

Total Annual Hours 10, 0 62 503 1,006 $ 6 17,460
11,571 hours Expenses (O&M) 12

Printing questionnaire $1, 232

Flash drives $2, 464
Postage $2, 112 Computer storage of data $1, 803 Total Expenses $ 7,611

TOTAL ANNUAL LABOR BURDEN AND COST $ 6 25

, 071

1. The number of respondents per year is based on the mill counts listed in Part B, Section 1

- Respondent Universe.
2. The nu mber of respondents pe r year ex c l udes mills that are not already included in the NEI.30 3. Mailout package includes section 114 letter with standard enclosures, hard copy of survey overview document, and flash dri ve containing spreadsheet files. Assumes EPA will mail one question naire per facility.

4. Assumes 1 5% of mills provide documentation of area source status , mill closure, or that pulping, bleaching, papermaking is not performed at the mill. It is not known how many of these claims will be valid so this number
of mills has not been subtracted from the burden estimates associated with completing the survey. 5. Assumes that 25% of the facilities will have questions.
6. Assumes that 25% of facilities will have confidential data.

7. Synthetic area sources will not be required t o complete Part II of the survey. However, EPA will not know the number of synthetic area sources that are exempt from Part II until the Part I survey responses have been received. Therefore, all mills are included in the burden estimate for respondents for Part II.

8 . Assume all chemical pulp mills populate the CEMS spreadsheet with CEMS and/or COMS data.

9 . Assume 25% of mills will provide cost information.

10 . Assumes 18 test reports for chemical pulp mills (from Parts I and III) , plus 1 test report e ach for non

- chemical pulp mills, bleach plants, and paper mills.

11 . Some emissions test results will require little time for analysis (e.g., those within the range of other test results), whi le others will require additional time (e.g., best performers). Expect to spend an average of 0.5 hr per
test result.

12 . Copy costs are estimated for 70 pages at $0.05/page. Flash drives were quoted at $7/each. Postage Costs are estimated at $6 for Federal Express letter size envelope flat rate. Data storage esti mated at $21/GB/mo, assuming 25 MB per response for chemical pulp mills and 5 MB per response for non

- chemical pulping, papermaking, and bleaching mills. Webpage cost estimated at $85/mo for 6 months.