### SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY NESHAP for**  **Pulp and Paper Production (40 CFR Part 63, Subpart S) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Pulp and Paper Prod uction (40 CFR Part 63, Subpart S) (Renewal), EPA ICR Number 1657.07, OMB Control Number 2060

- 0387 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Pulp and Paper Production were proposed on December 17, 1993, and promulgated on April 15, 1998. These regulations apply

to facilities that produce pulp, paper, or paperboard by employing kraft , soda, sulfite, semi

- chemical, or mechanical pulping processes using wood; or any process using secondary o r non - wood fiber and that emits 10 tons per year or more of an y h azardous air pollutant or 25 tons per ye ar or more of any combinatio n of hazardous air pollutants. Affected sources are all the hazardous air pollutant (HAP) emission points or the HAP em ission points in the pulping and bleaching s ys tem for mechanical pulping processes using wood and any process usin g secondary or non - wood fiber. This information is being collected to assure complianc e with 40 CFR part 63, subpart S

. In general, NESHAP require initial notifications, performance tests, and periodic reports. Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any perio d during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in de termining compliance, and are required of all sources subject to NESHAP

. Any owner or operator subject to the provisions of this part shall maintai n a file of these measurements, and retain the file onsite for at least two years following the date of such measurement s , maintenance report, and records. All reports are sent to the delegated state or local a uthority

. In the event that there is no such delegated authority, the reports are sent directl y to the United States Environmental Protection Agency (EPA) regional office

. Approximately

115 sources are currently subject to the standard which includes: 111 chemical pulp mills, and 4 non

- integrated paper mills that bleach with chlorinated compounds. It is further assumed that no additional new sources will become subject to the regulation in the next three ye ars, though approximately 15 percent of the affected facilities will rebuild one or mo re process units in a given year. In the United States, there are approximately 1 15 pulp and paper production facilities which are owned and operated b y the pulp and paper industry . None of the 1 15 facilities in the United States are owned by state, local, tribal or the Federal government. They are owned and

### 2

operated b y privatel y owned for

- profit businesses. You can find the burden to the “Affected Public” listed below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Pulp and Paper Production (40 CFR Part 6 3 , Subpart S ). The Federal government burden does not include work performed by Federal employees. The burden refers onl y t o work performed by contractors, which could be found listed below in Table 2: Average Annual EPA Burden

- NESHAP for Pulp and Paper Production (40 CFR Part 6 3 , Subpart S ).
In the development of the IC R, we addressed the Office of Management and Budget (OMB) “Terms of Clearance (TOC)” on the active ICR. The TOC are as follows:

When this I CR is renewed, EPA should re vi ew the respondent burden, universe, labor rates, and capital costs and ensure these estimates have been updated. EPA addressed each item of concern in the TOC. The respondent burden, universe , labor rates, and capital cost have been thoroughl y checked an d all estimates updated. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of majo r sources and area sources of h azardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may requi re an y o wner or operator subject to any requirement of this 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 emissi ons (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 indirec t 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 reasonabl y require. In the Administrator's judgment, HAP emissions from pulp and paper plants cause or contribute to air pollution that may reasonabl y b e anticipated to endanger public health or welfare. These HAP emissions are acetaldeh yde, benzene carbon disulfide, chloroform, formaldehyde, methanol, methyl

- ethyl

- ketone, toluene, and x yl ene emissions. Therefore, the NESHAP for this source category was promulgated at 40 CFR part 63, subpart S

. **2(b) Practical Utility/Users of the Data**

### 3

The recordkeeping and reporting requirements in the standard ensure compl iance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determin e an affected facility’s i nitial capability to comp ly

with the emission standard. Continuous emission monitors are used to ensure compliance w ith the standard at all times. During the performance tests, a record of the operating parameters under which co mpliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirem ents of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performan ce test may also be observed. The information generated by the monitoring, recordkeeping, and reporting requirements described in this I CR is used by the agency

to ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation. **3. Nonduplication, Consultations, and Other Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 63, subpart S

. **3(a) Nonduplication** If the subject standards have not been delegat ed, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal s tandards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register ( 7 6 FR 2 6 900 ) on May 9, 20 11 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations**
T he Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the

### 4

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agen cy ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was b eing developed

. In dev eloping this ICR, we contacted the American Forest and Paper Association (AF&PA) at (202) 463

- 2588 , and the National Paper Trade A ssociation (NPT A) at ( 31 2) 3 21

- 40 92

. It is our polic y t o respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the First Federal Register Notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are cont inuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guidelines** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. T his is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allows EP A to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years. In addition, EP A would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any i nformation submitted to the Agency for which a claim of confidentiality i s 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** None of the reporting or recordkeeping requirements contain sensitive questions.

### 5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are pulp and paper production facilities. The United States Standard Industrial Classification (SI C) codes for the respondents affected b y the standards, which corresponds to The North American Industry Classification System (NAI CS) codes, are liste d below for source category description. **Standard (40 CFR Part 63, Subpart S**  **) SIC Codes**  **NAICS Codes** Pulp Mills 2611 32 2 11 Paper Mills 26 21 32 2 1 2 Paperboard Mills 2 631 32 21 3 **4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items** In this ICR, all the data recorded or reported is required by National Emission Standards for Hazardous Air Pollutants for Pulp and Paper Producti on (40 CFR Part 63, Subpart S ). A source must make the following reports: **Notification Reports** Notification of construction and reconstruction 63.5(d) Construction or modification application 63.455(d) Initial notification 63.9 (b)(2) Anticipated star

tup 63. 9 (b ) Actual startup 63. 9 (b ) (4)(v) Initial performance test results 63.1 0 ( d)(2) Initial performance test 63. 7 (b ) , 63.9(e) Rescheduled initial performance test 63. 7 (b ) (2) Demonstration of continuous monitoring sy stem 63.9( g ) Compliance status 63

. 9 (h) Phy sical or operational change 63.5 (b ) (4) Opacity or visible emissions N/A Periodic startup, shutdown, malfunction reports 63. 10 (d)(5)(I)

### 6
**Reports** Source status report 63.10( e )( 3 ) Semiannual Control Strategy Update (thru 2006) 63. 455 (b )
A so urce must keep the following records: **Recordkeeping** Startup, shutdown, malfunctions, periods where the continuous monitoring sy stem is inoperative 63 .1 0 (b)( 2 )
Emission test results and other data needed to determine emissions 63. 454 ( a) All reports and notifications 63.1 0 (b ) Record of applicability 63.1 0 (b )( 3 ) Records for sources with continuous monitoring systems 63.1 0 ( 3 ) (c) Records are required to be retained for five years. Records must be kept onsite for the first two years. F or the remaining three years , records can be kept in a readily accessible off

- site location. 63. 454
Site specific inspection plans 63. 454 (b ) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although p ersonnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue t o create reporting sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 1 0 percent of the respondents use electronic reporting. **Respondent Activities** Read instructions. Install, calibrate, maintain, and operate continuous monitoring sy stems (CMS) for each of the following affected units: 1.1 Non

- Sulfite pulping process choice of: a. Provide documentation that vent streams are introduced to the flame zo ne of a boiler, lime kiln, or recovery

furnace, or b. Provide documentation that the control incinerator is operating at a minimum level of 1600F and 0.75 second residence time, or c. Performance test of c ontrol device using Method 308.

### 7 **Respondent Activities** 1.2 Sulfite pulping p rocess

– performance test of control device using test method 308. 2

. 1 Bleaching process vent scrubber (MACT I Mills) choice of: a. Provide documentation of scrubber operating parameters or previous performance test results, or b. Performance tes t of scrubber or control device using test Method 26A. 2.2 Bleaching process vent scrubber (MACT III Mills) choice of: a. Provide documentation of scrubber operating parameters, or previous performance test results, or b. Performance test of scrubber or control device using test Method 26A. 3.1 Non

- Sulfi te pulping wastewater treatment a. Performance test of condensate segregation and control device using method 305 or b. Performan ce test of bio

- treatment unit using test Method 304

. 3.2 Sulfite p ulping process a. Performance test of control device using test Method 305. Perform initial performance test, Reference Method 26A , 304 , 30 5 , and 30 8 test, and repeat perfo rmance tests if necessary

. Conduct initial and annual inspection of enclosures, closed vent, and wastewater conveyance sy stems using test Method 21. Write the notification and reports for: initial notification; compliance status; initial compliance strat egy report; compliance strategy report update; semiannual summary report; continuous monitoring/exceedance reports; notifications of performance tests, construction/reconstruction, and actual startup. Enter information required to be recorded for continuo us monitoring for operating parameters, periodic inspections (monthly visual and annual Method 21) startups, shutdowns and malfunctions, personnel training and time for audits

. Submit the required reports developing, acquiring, installing, and utilizing t echnology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize te chnology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit , or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way

e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

### 8

**5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conduct s the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and repor ts, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Managem ent**  Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y i nstalled and operational. P erformance test reports are used b y the Agency to discern a source’s initi al capability to comply

with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and governm ent

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve , and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. T o the ex tent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

### 9

**5(d) Collection Schedule** The specific frequency

f or each information collection activity w ithin this request is shown in Table 1: Annual Respondent Burden and Cost, NESHAP for Pulp and Paper Production ( 40 CFR Part 63, Subpart S ) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in thi s I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The av erage annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 35,358 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs** This I CR uses the following labor rates: Managerial $118.92 ($56.63 + 110%) Technic al $97.78 ($46.56 + 110%) Clerical $48.76 ($23.22 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2010, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from column 1, "Total Compensation." T he rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs as sociated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associat ed with continuous monitoring. The capital/startup costs are one

- time costs when a facility be comes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

### 10 **(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** Since this rule does not require any continuous emission monitoring or electronic data submittal, total capital costs are zero. Continuous monitoring requirements are for parametric monitoring , and these s ys tems are already in place; therefore, no new equipment would be required by

the recordkeepi ng and reporting requirements. Iti s assumed that all mills will contract a testing company to provide sampling and anal yt ical services for air and water tests. Based on EPA’s experience the testing methods required for this rule, the purchase of service for each method is estimated as follows:

Method 308

- $14,000 Method 26A

- $10,000 Method 304

- $11,000 Method 305

- $16,000 Method 21

- $3,000 These estimates include labor, materials, and analytical costs. F or the entire industry , the number of mills assumed to contract testing companies annuall y for demonstrating compliance and the associated cost are estimated as follows:

Method 308

- 0 T ests x $14,000 = $ 0 Method 26A

- 0 Tests x $10,000 = $0 Method 304

- 4.3 Tests x $11,000 = $ 47,300 M ethod 305

- 6.45 Tests x $16,000 = $ 103,200 Method 21

- 74 Tests x $ 3,000 = $2 22 ,000

TOTAL $3 72 , 5 00 The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 37 2 , 5 00

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA c ompliance and enforcement program includes activities such as: the examination of record s maintained by the respondents; periodic ins pection of sources of emissions; and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 43,014

. This cost is based on the average hourl y labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)

### 11 Clerical $25.01 (GS

- 6 , Step 3, $15.63 + 60%) These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NESHAP for Pulp and Paper Productio n (40 CFR Part 63, Subpart S ) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on o ur research for this I CR, on average over the next three ye ars, approximately 115 respondents will be subject to the standard. It is estimated that no additional new sources will become subject to the rule . The overall average number of respondents, as s hown in the table below is 115 per ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR. **Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)
1 17 1 15 0 17 1 15 2 17 1 15 0 17 1 15 3 17 1 15 0 17 1 15 Average 17 1 1 5 0 17 1 15

1 New respondent include sources with constructed, reconstructed and modified affected facilities. 

### To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 1 15

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That K eep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D
Semiannual report 115 2 N/A 230 Exceedance report 17 2 N/A 34 Com pliance strategy report update 0 1 N/A 0

### 12 **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That K eep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D
Notification of performance test 19 1 N/A 19 Notification of construction/reconstruction 17 1 N/A 17 Notification of actual startup 17 1 N/A 17 Total 317 

### The number of Total Annual Responses is 317

. The total annual labor costs are $ 3,339,077 . Details regarding these estimates may be found in Table 1: Annual Respond ent Burden and Cost

- NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S ) (Renewal)

. **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally**  The total annual labor hours are 35,358

. D etails regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost: NESHAP for Pulp and Paper Produ ctio n (40 CFR Part 63, Subpart S ) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 111 hours per response. The total annual capital/startup and o peration and m ainten ance ( O&M ) costs to the regulated entity are $ 37 2 , 5 00

.

**(ii) The Agency Tally**  The average annual Agency burden and cost over next three years is estimated to be 954 labor hours at a cost of $ 43,014

. S ee Table 2. Annual Agency B urden and Cost: NESHAP f or Pulp and Paper Production (40 CFR Part 63, Subpart S ) (Renewal). **6(f) Reasons for Change in Burden** The adjustment decrease in burden from the most recentl y approved ICR is due to a more accurate estimate of existing and anticipated new sources. Afte r consulting with the Office of Air Quality Planning and Standards ( OAQPS ) and trade associations, and based on a recently

### 13

completed research conducted by E PA, our data indicates that there are approximately 115 sources subject to the rule , as compared with the active ICR that shows 137 sources. There are no new facilities expected to be constructed over the next three ye ars of this ICR. The decline in the number of sources is mainly due to plant closures . The industry is undergoing widespread consolidation and corporate restructuri ng
. However, there is an increase in cost per labor hour s due to the updated labor rates. Because there are no new sources with reporting requirements, no capital/startup costs are incurred. The only

cost that is incurred is for the operation and maintenance (O&M) of the monitoring equipment. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 111 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 no t required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA = s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, th e accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 11

- 020 8

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index l isting of the content of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, D

. C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 17 52

. Also, yo u can se nd comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D

. C

. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0 2 0 8 and OMB Control Number 2060

- 03 8 7 in any correspondence.

### 14

**Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this informatio n.

### 15

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for**  **Pulp and Paper Prod**  **uction (40 CFR Part 63, Subpart S**  **)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Mana gem**  **ent person hours**  **per year (Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions 1) MACT I Mills c, d, e 40 1 40 6 240 12 24 $ 26,064.48 2) MACT III Mills c, d, e 20 1 20 0 0 0 0 $0 B. Required activities 1.1) Pulping processes (non

- sulfite) a) Provide documentation that the vent streams are introduced to the flame zone of a boil er, lime kiln, or recovery furnace, or f 24 1 24 5 120 6 12 $ 13,032.24

b) Provide documentation that the control incinerator is operating at a minimum level of 1600F and 0.75 sec residence time, or g 60 1 60 0 0 0 0 $ 0

c) Performance test of control device

- test M ethod 308 h 24 1 24 0 0 0 0 $ 0 1.2) Pulping processes (sulfite)

- Performance test of

c ontrol device

- test M ethod 308 h 2 4 1 2 4 0 0 0 0 $0 2.1) Bleaching process vent scrubber (MACT I Mills)

- choice of a) Provide documentation of scrubber operating parameters, or previous performance test results, or k 60 1 60 3 180 9 18 $ 19,548.36
b) Performance test of scrubber or control device

- test M ethod 26A h , k 24 1 24 0 0 0 0 $0 3.1) Pulping wastewater tr eatment (non

- sulfite)

### 16

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Mana gem**  **ent person hours**  **per year (Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

a) Performance test of condensate segregation and control device (test M ethod 305), or i, l 24 1 24 3 72 3.6 7 .2 $ 7,8 1 9. 34
b) Performance test of bio

- treatment unit

- test M ethod 304 i, j , m 24 1 24 2 48 2.4 4.8 $5,212.90 3.2) Pulping wastewater treatment (sulfite) Performance test control device

- test M ethod 305 i , n 24 1 24 0 0 0 0 $0 Repeat of performance test 1) Test M ethod 308

– pulping h, o 24 1 24 0 0 0 0 $0 2) Test M ethod 26A

– bleaching h, o 24 1 24 0 0 0 0 $0 3) Test M ethod 305

- kraft pulping w astewater i , o 24 1 24 3.45 82.8 4.14 8.28 $ 8,992.24 4) Test M ethod 304

- kraft pulping w astewater i, j , o 24 1 24 2.3 55.2 2.76 5. 52 $ 5,994.83 5) Test M ethod 305

- sulfite pulping w astewater . i, o 24 1 24 0 0 0 0 $0 Initial/annual inspection (enclosures, closed vent, w astewater conveyance system)

– test M ethod 21 p 8 1 8 74 592 29.6 59.2 $ 64,292.38 Monthly visual inspection of enclosures, closed v ent system, and waste water conveyance system q 4 12 48 1 11 5,328 266.4 532.8 $ 578,631.4 6 C. Create information See 3B D. Gather information See 3B E. Report preparation Initial notificatio n report 16 1 16 0 0 0 0 $0 Notification of compliance status 16 1 16 0 0 0 0 $0 Initial compliance strategy report r 40 1 40 0 0 0 0 $0 Compliance strategy report update r 16 1 16 0 0 0 0 $0 Semiannual summary

report s 16 2 32 1 15 3,680 184 368 $ 399,655.3 6 Continuous monitoring/exceedance reports t 24 2 48 17 816 40.8 81.6 $88,619.24 Notification of performance test u 4 1 4 19 76 3.8 7.6 $8,253.76 Notification of constructi on/reconstruction v 4 1 4 17 68 3.4 6.8 $ 7,384.94 Notification of actual startup v 4 1 4 17 68 3.4 6.8 $7,384.94

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**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Mana gem**  **ent person hours**  **per year (Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

Subtotal for Reporting Requirements 13,139.9 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 3B C. Implement Activities See 3B D. Develop record system 40 1 40 0 0 0 0 $0 E. Record information Records of continuous monitoring for operating parame ters w 2 52 104 115 11,960 598 1,196 $ 1,298,880. 36 Records of periodic inspections (monthly visual inspections and annual method 21) See 3B Record startup, shutdown, and malfunction x 4 12 48 115 5,520 276 552 $599,48 3.0 4 F. Time to train personnel N/A G. Time for audits y 8 2 16 115 1,840 92 184 $199,827.6 8 Subtotal for Recordkeeping Requirements 22,218 Subtotals Labor Burden and cost 30,746 1, 537.3 3, 074.6 $3,339,077. 55 **TOTAL LABOR BURDEN AND COST**  **(rounded)** 35,357.9 35,358 (rounded) $3,339,077

**Assu mptions:**  a We have assumed that the average number of existing sources subject to the rule will be 1 15 . There will be no additional new source s pe r year that will become subject to the rule over th e three

- year period of this ICR. b This ICR uses the following labor rates: $118.92 per hour for Executive, Administrative, and Managerial labor; $97.78 per ho ur for Technical labor, and $48.76 per hour for Clerical labor. Th ese rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2010, Table 2. Civilian Workers, by Occupational and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110 per cent to account for the benefit packages available to those employed by private industry. c We have a ssume d that MACT I mills include pulping system s at kra f t, sulfite, soda, and semi

- c hemical operations; and that MA C T III mills include mechanical, non

- wood, and secondary fiber operations, along with paper making at all types of mills that are major sources are subject to subpart S. d We have assumed that this is a one

- time

- only activity. After the initial compliance date , 5 percent of mills will be aff ected as a result of unexpected exceedances. e We have assumed that this is p erformed by all major source mills. There are 1 11 major MACT I category mills, and 60 major stand

- alone (MACT III) category mills. We

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assume that all MA CT I category mills wi ll be affected by this rule, and that the only MACT III category mills to be affected by this rule are the stand

- alone mills with chlorine bleaching com

pounds (4 mills). The total number of mills affected by this rule is 1 15 (1 11 + 4 = 1 15 ). f We have a s sume d that 5 percent of non - sulfite pulping mills respondents will provide documentation

. It is estimated that 85 percent of mills will use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non - sulfite pulping mill s ( 85 % of 1 06 = 90 x 5% = 5 )

. g We have estimated that 15 percent of mills will use incineration for pulping lines [ assuming half of these p rovide acceptable design specs (8) , and half conduct performance tests (8)]

. h We have a ssume d that it will take 2 4 hours once per year to com plete the per formance test of a control device, which includes the test plan, the test report, and the parametric mo nitoring setup. Method 308 tests for pulping lines and M etho d 26 A tests for bleaching lines do not incur compli ance testing cost s
. i This e stimate includes the test plan, the test report, and the parametric monitoring setup. Method 30 4 and 305 for pulping waste water streams incur com pliance testing cost s
. j We a ssume that it will take each sulfite pulping mill respondent 24 hours once per year to conduct performance tests

. k We have estimated that MACT I and MACT III category mills have bleaching lines that use chlorinated compounds. We a s sume that 90 percent provide acceptable performance specs or previous t est results, and 10 percent wi ll conduct performance tests. l We a ssume that each kraft mill has one pulping waste water control device, with 60 percent of mills using stream strippers (60% x 97 = 58) and (5% x 58 = 3). See footnote “c.” Facilities with steam strippers are assumed to perform initial condensate segregation and performance tests. m We have a ssume d that 40 percent of kraft mills use biotreatment (40 % x 97 = 39) and (5% x 39 = 2). Facilities with biotreatment control will perform initial p erformance tests. n We have a ssume d that sulfite mills will monitor gas scrubber parameters and use Wat er - 9 Model for emission estimates. o We have a ssume d that 15 percent of performance test would have to be repeated because of failure. p We have a ssum e d that 2/3 of all MACT I mills that have positive pressu re points in their vent systems will have to test using Method 21 (2/3 x 1 11 = 74 )

. Method 21 for the wa stewater conveyance system incurs compliance testing costs. q We have assumed that each respo ndent will take 4 hours once per mo nth to com plete the mo nthly visual inspection. This monthly inspection of enclosures will be performed by MACT I category mills which will be affected by this rule. r We have a ssume d that the requirements for either the initial or the update d compliance strategy report are now considered obsolete . These were required before 2006 only

. s We have a ssume d that each respondent will each take 16 hours twice per year to prepare the semiannual summary report. t We have a ssum e d that 15 percent of all affected mills during any one quarter will be required to submit an exceedance report in addition to the summary report (15% x 115 = 17). u We have a ssume d affected respondents must notify EPA of all tests including repeat perfo rmance tests (111 x 0.05 = 5.6) and (5.6 x 1.15 x 3 = 19).
v We have assumed that 15 percent of mills will conduct reconstruction per year (15% of 115 = 17).
w We have assumed that each respondent will take 2 hours 52 times per year to record continuous monitoring for operating parameters.
x We have assumed that each respondent will take 4 hours once per monthly to record startups, shutdowns, and malfunctions. y We have assumed that each respondent will take 8 hours twice per year to train personnel.

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**Table 2: Average Annual EPA Burden**
**- NESHAP for**  **Pulp and Paper Production (40 CFR Part 63, Subpart**  **S )** 

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**R espondents**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1)** (H)

Total Cost Per year b

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions c 6 1 6 6 36 1.8 3.6 $1,865.69 B. Required activities Initial performance tests : c 1.1) Pulping processes ( n on - s ulfite)

– choice of : a) Revie w documentation that vent streams are introduced to the flame zone of a boiler, lime kiln, or recovery furnace, or d 8 1 8 5 40 2 4 $2,072.98
b) Revie w documentation that the control incinerator is operating at a level of at least 1600 F and 0.75 sec residence time, or e 8 1 8 0 0 0 0 $0
c) Review performance test of control device e 8 1 8 0 0 0 0 $0 1.2) Pulping processes (sulfite) c

- Review performance test of control device f 8 1 8 0 0 0 0 $0 2.1) Bleaching process vent scrubber (MACT I Mills)

– choice of

: c a) Revie w documentation of scrubber operating p arameters , or g 8 1 8 3 24 1.2 2.4 $ 1,243.78 b) Revie w performance test of control device h 8 1 8 0 0 0 0 $0 3.1) Pulping wastewater treatment system (non

- s ulfite)

– choice of: c a) Revie w performance test of condensate segregation and control device, or g 8 1 8 3 24 1.2 2.4 $1,243.78 b) Revie w performance test of bi o - treatment unit g 8 1 8 2 16 0.8 1.6 $829.20 3.2) Pulping wastewater treatment (sulfite) c

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**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**R espondents**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1)** (H)

Total Cost Per year b

- Revie w performance test of control device g , i 8 1 8 0 0 0 0 $0 Review repeat performance tests c , j 1) Test M ethod 308

– pulping 4 1 4 0 0 0 0 $0 2) Test M ethod 26A

– bleaching 4 1 4 3 12 0. 6 1.2 $621.89 3) Test M ethod 305

– kraft pulping wa stewater 4 1 4 3 12 0. 6 1.2 $621.89 4) Test M ethod 304

– kraft pulping wa stewater 4 1 4 2 8 0 .4 0 .8 $414.60 5) Test M ethod 305

– sulfite pulpi ng wa stewater 4 1 4 1 4 0.2 0.4 $207.29 Initial/annual inspection (enclosures, closed vent wastewater conveyance system)

– T est M ethod 21 k 4 1 4 0 0 0 0 $0
Monthly visual inspection of enclosures, closed vent system, and wastewater conveyance system l 4 1 4 0 0 0 0 $0

C. Create information N/A D. Gather information N/A E. Report preparation Review initial notification report c , l 4 1 4 0 0 0 0 $0 Review notification of compliance status c , l 4 1 4 0 0 0 0 $0 Review initial compliance strategy report c , m 4 1 4 0 0 0 0 $0 Review co mp liance strategy report update c , m 4 1 4 0 0 0 0 $0 Review semiannual summary r eport n 1 2 2 115 230 11.5 23 $11,919.63 Review continuous monitoring/exceedance r eports o 8 1 8 17 136 6.8 13.6 $7,048.14 Review notification of performance test c , p 8 1 8 19 152 7.6 15.2 $7,877.32 Revie w notification of construction/ r econstruction c , q 4 1 4 17 68 3.4 6.8 $ 3,524.07 Review notification of actual startup c , r 4 1 4 17 68 3.4 6.8 $3,524.07 4. Recordkeeping requirements a. Read instructions N/A b. Plan activities N/A

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**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**R espondents**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1)** (H)

Total Cost Per year b

c. Im plement activities N/A d. Develop record system 4 1 4 0 0 0 0 $0 e. Record information Records of monitoring parameters 4 1 4 0 0 0 0 $0 Records of periodic inspection (monthly visual inspections and annual Method 21) 4 1 4 0 0 0 0 $0 Record startups, shutdow ns, and malfunctions 4 1 4 0 0 0 0 $0 f. Personnel training 4 1 4 0 0 0 0 $0 g. Time for audits 4 1 4 0 0 0 0 $0 Subtotals Labor Burden and Cost 830 41.5 83 $43,014.33 **TOTAL LABOR BURDEN AND COST (rounded)**  954.5 954 (rounded) $43,014

**Assu mptions:**  a We have assumed that the average number of existing sources subject to the rule will be 115. There will be no additional new sources per year that will become subject to the rule over the three

- year period of this ICR. b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62. 27 Managerial rate (GS

- 13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS

- 6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) 2011 General Schedule which exclude s locality rates of pay. c We have assumed that this is a one

- time only activity. After the initial compliance date , 5 percent of mills will be affected as a result of unexpected exceedances. d We have assumed that 5 percent of non - sulfite pulping mills respondents will provide documentation I t is estimated that 85 percent of mills will use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non

- sulfite pulping mills (85 % of 106 = 90 x 5% = 5).
e We assumed that 15 percent of mills use incineration for pulping lines (assuming half of these provide acceptable design specs (8), and half conduct performance tests (8). f We have assumed that all of the 8 sulfite pulping mills will conduct performance tests. g We have assumed that each kraft mill has one pulping wastewater control device, with 60 percent of mills using stream strippers (60% of 97 = 58). Facilities installing ne w biotreatment control will perform initial performance tests. h We have assumed that 69 MACT I and 4 MACT III category mills have bleaching lines that use chlorinated compounds. We a ssume 90 percent provide acceptable performance specs or previous test results, and 10 percent conduct performance test for a total of 7 (0.9 x 69 + 4 = 66 x 10% = 7)

. i We have assumed that 40 percent of kraft mills use biotreatment (40 % of 97 = 39). j We have assumed that 15 percent of performance tests wo uld have to be repeated because of failure. k We have assumed that 2/3 of all MACT I mills have positiv e pressure points in their vent systems. All affected mills are required to perform initial and annual activity. EPA is notified of testing each year.

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l We have assumed that this task will be performed by all affected mills.
m We have assumed that the requirements for either initial or update d compliance strategy reports are now considered obsolete . These were required before 2006 only

. n We have assumed that each respondent will take 1hour to review the semiannual summary report.
o We have assumed that 15 percent of all mills during any one quarter will be required to submit an exceedance report in addition to the summary report ( 15% of 115 = 17). p We have assumed affected respondents must notify EPA of all tests including repeat performance tests (111 x 0.05 = 5.6) and (5.6 x 1.15 x 3 = 19). q We have assumed that 15 percent of mills will conduct construction or reconstruction per year (15% of 115 = 17)

. r We have assumed that affected respondent will take 4 hours to review notification of actua l startup report.