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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) RESIDUAL RISK 

AND TECHNOLOGY REVIEW (RTR)

Sector Policies and Programs Division

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

February 4, 2011
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SUPPORTING STATEMENT

INFORMATION COLLECTION REQUEST FOR PULP 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 (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP)

Residual Risk and Technology Review (RTR).” This 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 sections 111(b), 112(d), and 112(f)(6) of 

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

paper processes and to reevaluate emission standards for this source category. The information 

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

This is 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 (NEI). Neither the Lockwood-Post nor the NEI contain all 

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

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

test data) necessary to characterize pulp and paper NSPS and NESHAP 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 any 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 sent to all pulp and paper manufacturing facilities listed in the Lockwood-Post.
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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 

352 respondents) will be 161,106 hours 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 respondent is 458 hours and $43,291. 

2. Need for and Use of the Collection

(a) Need/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 manufactured on-site), non-integrated 

mills (where either paper/paperboard or pulp are manufactured onsite, but not both), and 

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

paper production process units include operations 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 federal emission standards that are the subject of this information collection include: 

1. Standards of Performance for Kraft Pulp Mills (40 CFR part 60, subpart BB), 

2. National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper 

Industry (40 CFR 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,

secondary 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 

designed 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 kraft 
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and soda combustion units, the subpart MM standards also include a compliance alternative that 

allows netting of PM emissions for the entire chemical 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 mill 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, processes, 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 112(f)(2) and 

112(d)(6). Likewise, the 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, shutdown, 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 recovery 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 (CBD), 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 investigate 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 (Part 2). Identified synthetic area sources will not be used to 

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

to Part 1 of the survey and, if applicable, Part 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 years 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 statutory requirements for reviewing emission standards under CAA 

sections 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 decisions 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 pulp and paper NESHAP subparts S and MM. Data sets derived from the EPA’s 2005 

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 expected on the NEI data sets for 

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

updates 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 above the thresholds for further consideration under the residual risk process. 

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

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

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

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

mills will have the greatest practical utility for purposes 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 base year, and therefore, will not suffer from the considerable “lag time” 
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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 respondents more time to complete the survey, the 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 and 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 days 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 Part 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 

subject 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 

methods; (D) sample such emissions (in accordance with such procedures or 

methods, at such locations, at such intervals, during such periods, and in such 

manner as the Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data when direct 

monitoring of emissions is impractical; (F) submit compliance certifications in 

accordance with section 114(a)(3); and (G) provide such other information as the 

Administrator may reasonably require.

(b) Use/Users 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 MACT standards. 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 

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There is a “lag time” associated with compiling large State or national emission inventories. For example, an 

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 “lag time” associated with posting of 

recent permits to State websites (particularly if permits are only posted every 5 years as they are reviewed). 
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limitations established under the Clean Water Act. At present, the EPA does not have a data 

base reflecting the post-MACT and post-effluent guidelines configurations 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 same 

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 would allow the Agency to consider 

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

SO2, 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 requirements among the different rules 

under review. 

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

configuration, develop new estimates of the population of affected units, and identify the control 

measures and alternative emission 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 (test 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 reducing 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 environmental 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 

collection 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 air pollutants. More 

information in the NEI can be found at http://www.epa.gov/air/data/neidb.html.
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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 industry 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, Consultations, 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 State and national emission inventories, operating permits applications, initial 

notification forms, and compliance reports. However, the complete extent of the data fields 

requested under this survey is not available in any consistent or usable format. Additionally, 

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 test 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 effects of any such lag time on data availability. 

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

files (pdfs), many States 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 hardcopy only, whereas only the facility-level information (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 varying 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 (assuming 

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

even after data from existing documents were compiled. 
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Emissions test reports are often retained as hard copies by State agencies and thus are not 

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

(National Council for Air and Stream Improvement [NCASI]) collects and compiles emissions 

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 contained in the NCASI reports may not be 

reported in the units of measure needed for analysis of emission limits; (3) much of the data predates implementation of the MACT standards, and (4) the data are generally representative of 

NCASI member mills, whereas information collected by EPA would be requested from the entire 

population of affected mills. 

To summarize, the information requested relevant to the current (post-MACT) equipment

configuration and operation, regulatory alternatives, emissions data, and effectiveness 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 industry 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 purposes 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

As 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), the

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 period (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. EPA revised the ICR to address the public comments prior to submitting the 
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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 available in the regulatory docket established for this rule, EPAHQ-OAR-2007-0544 at www.regulations.gov.

(c) Consultations

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

paper sector survey. Detailed comments 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 ICR. 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 for 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 will 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) Effects of Less Frequent Collection

This ICR will require the owner/operator of each pulp and paper facility to complete 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 survey to be a onetime effort.

(e) General Guidelines

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

1320.6.
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(f) Confidentiality

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

respondent 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 as 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 constitute 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 provided in 40 CFR 2.301(a)(2)(i).

(g) Sensitive questions

This section is not applicable because this ICR will not involve matters 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 352 mills including:

• 112 mills that carry out chemical wood pulping (kraft, sulfite, soda, or semi-chemical),

• 39 mills that carry out mechanical, groundwood, secondary fiber, and non-wood pulping,

 2 As defined in 40 CFR Part 63, subpart A, “major 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 hazardous 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-enforceable conditions that limit its potential to emit to below major 

source thresholds.
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• 93 mills that perform bleaching, and

• 334 mills that manufacture paper or paperboard products.

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-Post Online (as of March 2009), updated 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 products (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 paperboard mills.

(b) Information Collected 

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

complete an electronic survey that contains several components. Some survey components are 

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

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

spreadsheet file). Table 1 below denotes which pulp and paper sector survey spreadsheet tabs 

are to be completed depending on the part of the survey and type of mill. Survey spreadsheet

tabs 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 manufacture 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, chemical recovery area, wastewater 

treatment, and black liquor gasification (if used). 
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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.xls

Mill All mills 352

PI Equip detail All mills 352

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. 

352

Pulp prod Mills that produce any type of pulp (including chemical, 

mechanical/groundwood, secondary fiber, including non-wood pulp)

151

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)

491

Bleaching Mills that perform bleaching 93

Paper prod Mills the produce paper or paperboard products 334

HAP additives Mills the produce paper or paperboard products 334

WW Mills with onsite wastewater treatment plants 352

PI Emissions test 

data

All mills 352

P&P NEI update.xls (or P&P NEI blank.xls)

Facility (or New 

Facility)

All major source mills 3522

Inventory (or New 

Facility)

All major source mills 3522

P&P survey_PIII.xls

PIII Equip detail Mills that use chemical recovery combustion processes 112

PIII Permit limits Mills that use chemical recovery combustion processes 112

PIII Controls Mills with add-on air pollution controls on chemical recovery combustion 

processes. 

112

PCC Mills that route lime kiln, boiler, or other process exhaust to a precipitated 

calcium carbonate (PCC) plant

30

PIII Emissions test 

data

Mills that use chemical recovery combustion processes 112

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 spreadsheets listed in Table 1, separate 

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

and/or continuous opacity monitoring system (COMS) data, or optional control measure cost 

information. Separate versions of these spreadsheets are to be submitted under Parts I and III of 

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

Emissions data collected under the Emissions test data tabs listed in Table 1 or the CEMS 

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

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

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

are requested include particulate matter (PM), filterable PM less than 2.5 microns (PM2.5), 

condensable PM2.5, speciated HAP metals, chlorine (as a surrogate for chlorinated HAP), 

hydrochloric 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 (SO2), 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 

costs of selected air pollution controls or process/equipment changes. Submittal of the control 

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

voluntary basis to perform the CAA-required regulatory analyses. However, 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, 

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

be reviewed (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 minimized 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 updates has also 

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

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

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

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

paper information collection is being administered 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 software for use by the Agency (eliminating the time required for EPA to keyenter 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 been 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 standards, as opposed to speciated chlorinated HAP or speciated nonchlorinated 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 pollutant 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 dates for selected emission 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 reports 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 consistent 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 spreadsheet 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 the 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 instructions also include a table of suggested 
16

permit 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 controls 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 

instructions; 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) 

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

(including 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 and 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, 

standardized 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 any 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 each 
17

submittal, the spreadsheet information from each mill will 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 base, and for inclusion in future versions of 

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

be entered into a data base by EPA (or EPA contractor personnel) familiar with extracting 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 respondents 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 respondents may 

be small entities. Small entities are likely to be non-integrated mills with lower-capacity pulp 

and paper processes (e.g., smaller mills that produce paper from purchased 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 survey, provided that they submit documentation 

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

emissions, small entities (and 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, any individual small 

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

will be minimized. The Agency also plans to use an electronic 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 determine 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

EPA anticipates issuing the CAA section 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 within 30 days of receipt of the survey, Part II within 100 days, and Part III within 

180 days. EPA will compile and analyze 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 costs 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, September 2009, “Table 2. 

Civilian 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 compensation of $46.76 per hour for technical, $54.52 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 $98.20, management at $114.49, and clerical at $48.53. 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) 2009 General Schedule 

which excludes locality rates of pay. These rates can be 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), $34.34 for technical (GS13, Step 1), and $47.74 for managerial (GS-15, 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 $54.94, 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 respondent universe consists of 352 mills. All 352

of these mills will be required 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 are 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 estimate 
19

provided in Attachment 3 assumes that 15 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, are calculated by summing the person-hours column and by summing the cost 

column. The total burden and cost to the industry for 352 respondents is 161,106 hours and 

$15,238,347. No capital or annualized costs are applicable because this is a one-time submittal. 

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

to EPA. 

(ii) Agency tally. The bottom line Agency burden and cost, presented in Attachment 3

is calculated in the same manner as the industry burden and cost. The estimated burden and cost

for 352 respondents is 10,062 hours and $625,071, which includes $7,611 in O&M costs to send 

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

drive containing pre-populated 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 not apply as this is a onetime 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 financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 
20

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

and systems for the purposes of collecting, validating, and verifying information, processing and 

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

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

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

information; and transmit or otherwise disclose the information. An agency may not conduct or 

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

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 total cost burden for the pulp and paper data gathering effort is estimated to be

161,106 hours and $15,238,347 (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 per respondent) 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 

use 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 

Constitution 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 Radiation 

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 documents 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.
21
22

INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW 

SOURCE PERFORMANCE STANDARDS (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 that the 

potential respondent universe consists of 352 mills. All 352 of these mills will be required 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 major 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 15 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). 

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). 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 as 

follows:
23

Chemical pulp mills Count

 kraft (including kraft/mechanical) 89

 soda 1

 sulfite 5

 kraft/semichemical 9

 semichemical 8

112

Mechanical/groundwood, secondary fiber, and non-wood pulp mills

 mechanical 14

 specialty (recycled) 22

 nonwood 3

39

Paper/paperboard only + Integrated paper mills 334

Number of mills that perform bleaching 93

TOTAL NUMBER OF MILLS 352

2. Response Rates

Since the information will be requested pursuant to the authority 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 Costs
25

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 this document are: (1) documentation of true area, nonoperational, 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 Subpart 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 standards; 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 number 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, SO2, CO, methanol, 

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. These 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 – NEI 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 estimating 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 with 

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 Inventory

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 classification 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; 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 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 

characterize 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 CEMS 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, SO2, 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 the Information Collection

Respondent Activity (A) Hours per 

Occurrence

(B) Occurrences/ 

Respondent/Year

(C) Hours/ 

Respondent/ 

Year (A x B)

(D) 

Respondents/ 

Year1

(E) Technical 

Hours/Year 

(C x D)

(F) Managerial 

Hours/Year 

(E x 0.05)

(G) Clerical 

Hours/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. REPORT 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 $765,767

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

 Mill (general information) 6 1 6 352 2,112 106 211 $229,730

 PI Equip detail 40 1 40 352 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 6 151 906 45 91 $98,549

 Byproducts 4 1 4 98 392 20 39 $42,639

 Kraft condensates 8 1 8 98 784 39 78 $85,279

 CCA2 8 1 8 49 392 20 39 $42,639

 Bleaching 6 1 6 93 558 28 56 $60,696

 Paper prod 6 1 6 334 2,004 100 200 $217,982

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

 WW 6 1 6 352 2,112 106 211 $229,730

 PI Emissions test data3

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 $50,689

 iii. Gather and scan/copy emission test reports for 

submittal3,4

 Reports for chemical pulping (4 reports) 1.5 4 6 112 672 34 67 $73,096

 Reports for non-chemical pulping, papermaking, and 

bleaching (1 report for each process) 1.5 1 1.5 466 699 35 70 $76,033

 iv. Complete and submit Part I CEMS spreadsheet5 10 1 10 112 1,120 56 112 $121,827

 v. Complete and submit Part I optional cost spreadsheet6 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 Update7

 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 280 1 280 30 8,400 420 840 $913,699
28

Respondent Activity (A) Hours per 

Occurrence

(B) Occurrences/ 

Respondent/Year

(C) Hours/ 

Respondent/ 

Year (A x B)

(D) 

Respondents/ 

Year1

(E) Technical 

Hours/Year 

(C x D)

(F) Managerial 

Hours/Year 

(E x 0.05)

(G) Clerical 

Hours/Year 

(E x 0.10) (H) Cost/ Year

ii. Complete signed certification 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 20 112 2,240 112 224 $243,653

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

 PIII Controls 15 1 15 112 1,680 84 168 $182,740

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

 PIII Emissions test data3 1 14 14 112 1,568 78 157 $170,557

 ii. Gather and scan/copy emission test reports for submittal3,4 1.5 14 21 112 2,352 118 235 $255,836

 iii. Complete and submit Part III CEMS spreadsheet5 30 1 30 112 3,360 168 336 $365,480

 iv. Complete and submit Part III optional cost spreadsheet6 30 1 30 28 840 42 84 $91,370

 v. Complete signed certification form for part III 0.2 1 0.2 112 22 1 2 $2,437

C. Create Information (Included in 4B)

D. Gather Existing Information (Included in 4B)

E. Write Report (Not Applicable)

5. RECORDKEEPING REQUIREMENTS (Not applicable)

TOTAL ANNUAL LABOR BURDEN AND COST

140,092 7,005 14,009 $15,238,347

total = 161,106 avg hr/respondent = 458 8 $ 43,291

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 mills 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 hours 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 expected to be submitted for the emissions units covered under Part III.

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

7. Synthetic area sources will not be required to 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. 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 responses 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/Year1

(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 10 1 10 1 10 1 1 $614

Pre-populate mill spreadsheets with existing NEI data2 1 1 1 322 322 16 32 $19,760

Mail out questionnaire3 0.7 1 0.7 352 246 12 25 $15.121

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 paper 

products4 1 1 1 52.8 53 3 5 $3,240

Answer respondent questions via phone, email, and/or 

frequently asked questions posted on webpage5 1 1 1 88 88 4 9 $5,400

Analyze requests for confidentiality6 1 1 1 88 88 4 9 $5,400

Review signed certification forms 0.1 1 0.1 352 35 2 4 $2,160

Review and analyze responses (including follow-up)

NEI data (from Part II)7 4 1 4 352 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 (from Parts I and III)8 2 1 2 112 224 11 22 $13,746

Optional cost data (from Parts I and III)9 2 1 2 88 176 9 18 $10,801

Print emissions test reports10 0.1 2,482 248.2 1 248 12 25 $15,232

Enter emissions test data from test reports

Reports 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 4 112 448 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 data11 0.5 2,482 1,241 1 1,241 62 124 $76,158

Total Annual Hours 10,062 503 1,006 $617,460

 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 $625,071

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

2. The number of respondents per year excludes mills that are not already included in the NEI.
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3. Mailout package includes section 114 letter with standard enclosures, hard copy of survey overview document, and flash drive containing spreadsheet files. Assumes EPA will mail one questionnaire per facility.

4. Assumes 15% 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 to 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 each 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), while 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 estimated 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.