SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal), 

EPA ICR Number 1055.10, OMB Control Number 2060-0021. 

1(b) Short Characterization/Abstract

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

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

Revision to the standards was promulgated on May 20, 1986. These regulations apply to the 

following facilities at kraft pulp mills: recovery furnaces, smelt dissolving tanks, lime kilns, 

digester systems, brown stock washer systems, black liquor oxidation systems, multiple effect 

evaporator systems and condensate stripper systems that were constructed, modified or 

reconstructed after the date of proposal. In pulp mills where kraft pulping is combined with 

neutral sulfite semi-chemical pulping, the provisions of this subpart are applicable when any

portion of the material charged to an affected facility is produced by the kraft pulping operation. 

Facilities may be exempt from the total reduced sulfur (TRS) standard if the facility can 

demonstrate that TRS emissions from a new modified or reconstructed brown stock washer can be 

neither technically nor economically and feasibly controlled. This information is being collected 

to assure compliance with 40 CFR part 60, subpart BB.

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

reports by the owners/operators of the affected facilities. They 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 period during which the monitoring system is inoperative. These 

notifications, reports, and records are essential in determining compliance, and are required of all 

affected facilities subject to NSPS. A semiannual summary report is also required.

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

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

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

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

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives during a previous renewal of this 

ICR, there is an average of one affected facility at each plant site and that each plant site has only 

one respondent (i.e., the owner/operator of the plant site).

Over the next three years, an average of 106 respondents per year will be subject to the 
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standard, and two additional respondents per year will become subject to the standard.

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

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

state, local, tribal or the Federal government; all these facilities are privately-owned, for-profit 

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

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

(Renewal). The burden to the “Federal Government” is attributed to work performed by either 

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

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

(Renewal).

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

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

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years. 

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

subject to any requirement of this Act to:

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

(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
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reasonably require.

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

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

the NSPS was promulgated for this source category at 40 CFR part 60, subpart BB.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, 

the collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability 

to comply with the emission standard. Continuous emission monitors are used to ensure 

compliance with the standard at all times. During the performance tests, a record of the operating 

parameters under which compliance 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 requirements of the regulations. The reviewing 

authority may then inspect the source to ensure that the pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations. 

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

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart BB.

3(a) Non-duplication

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

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

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

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

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

exists.

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

An announcement of a public comment period for the renewal of this ICR was published in 

the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the burden 

published in the Federal Register.
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3(c) Consultations

The Agency’s industry experts were consulted, and the Agency’s internal data sources and 

projections of industry growth over the next three years were considered during a previous renewal 

of this ICR. The primary source of information as reported by industry, in compliance with the 

recordkeeping and reporting provisions in the standard, was the Online Tracking Information 

System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the 

EPA database for the collection, maintenance, and retrieval of all compliance data. The growth 

rate for the industry was based on our consultations with the Agency’s internal industry experts. 

We estimated that approximately 106 respondents would be subject to the standard over the 

three-year period covered by this ICR.

Industry trade association and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. For this renewal, we consulted with the following representatives (see below). 

No comments were received on this ICR. 

Contact Organization Phone

Patrick McCarthy

Center for Paper Business and Industry

Studies, Georgia Institute of Technology (404) 894-4914

Kevin Gammonley National Paper Trade Association (312) 321-4092

Donna Harman American Forest and Paper Association (202) 463-2700

It is our policy to respond after a thorough review of comments received from the public 

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

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

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

frequently, the proper operation and maintenance of control equipment and the possibility of 

detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

Any 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 -
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Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

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

United States Standard Industrial Classification (SIC) code for the respondents affected by the 

standards is 2611, which correspond to the North American Industry Classification System 

(NAICS) code 322110 for kraft pulp mills.

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 that is recorded or reported is required by NSPS for Kraft Pulp 

Mills (40 CFR Part 60, Subpart BB).

A source must make the following reports:

Notifications

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

Notification of actual startup 60.7(a)(3)

Notification of initial performance test 60.8(d)

Initial performance test results 60.8(a)

Demonstration of continuous system performance 60.7(a)(5)

Physical or operational changes 60.7(a)(4)

Opacity or visible emissions observations 60.7(a)(6)

Reports

Semiannual report 60.7(c), 60.284(d)

Excess emissions report 60.7(c), 60.284(d)

A source must keep the following records:
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Recordkeeping 

Startup, shutdown, or malfunction period where the continuous 

monitoring system is inoperative 60.7(b)

Record continuous monitoring system parameter data 60.284(a)-(c)

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

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel 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 to create reporting 

systems to transmit data electronically. However, electronic reporting systems are not widely 

used. At this time, it is estimated that approximately 10 percent of the respondents use electronic 

reporting.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate a continuous monitoring system (CMS) to monitor and 

record opacity of gases discharged from any recovery furnace: the concentration of TRS 

emissions on a dry basis and the percent of oxygen by volume in the gases discharged from any 

lime kiln, recovery furnace, digester system, brown stock washer system, multi-effect 

evaporator system or condensate stripper system; the combustion temperature at the point of 

incineration of effluent gases which are emitted from a digester system; the scrubbing liquid 

supply pressure and pressure loss of the gas stream to the scrubber emission control device that 

is discharges from any lime kiln or smelt dissolving tank. 

Perform initial performance test, Reference Method 5, 17, 3B, 9, 16, 16A, 16B, and repeat 

performance test if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.
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Respondent Activities

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 system). Although personnel at the source 

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping.

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

Management

5(a) Agency Activities

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

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports, 

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

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

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

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

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

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

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

source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and maintained 

by the EPA Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and 

retrieval of compliance data for approximately 125,000 industrial and government-owned 

facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state 

regulatory agencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can 

edit, store, retrieve and analyze the data.

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

years.
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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 types 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. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

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

60, Subpart BB) (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 this ICR. The 

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

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

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

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 16,086 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

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

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $121.42 ($57.82 + 110%)

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)
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These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

September, 2011, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are 

from column 1, “Total Compensation.” The 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 type of industry costs associated with the information collection activities in the 

subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes 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.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/

Startup Cost 

for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost 

(B X C) 

(E)

Annual 

O&M Costs 

for One 

Respondent

(F)

Number of 

Respondents 

with O&M 

(G)

Total O&M,

(E X F)

Opacity monitor $40,000 2 $80,000 $8,600 106 $911,600

TRS monitor $108,000 2 $216,000 $23,000 106 $2,438,000

Incinerator 

temperature 

monitor

$8,600 2 $17,200 $4,600 106 $487,600

Scrubber liquid 

supply pressure 

monitor

$350 2 $700 $0 0 $0

Scrubber liquid 

flow rate monitor $15,500 2 $31,000 $0 0 $0

Total cost $344,900 $3,837,200

The total capital/startup costs for this ICR are $344,900. This is the total of column D in 

the above table.

The total operation and maintenance (O&M) costs including photocopying, and postage 

are $3,837,200. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry 

over the next three years of the ICR is estimated to be $4,182,100. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA’s overall compliance and enforcement program includes activities such as: the
10

examination of records maintained by the respondents; periodic inspection 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 

$48,404

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

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 below in Table 2: Average Annual EPA Burden- NSPS for Kraft Pulp Mills (40 CFR Part 

60, Subpart BB) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

104 existing respondents will be subject to the standard. It is estimated that two additional 

respondent per year will become subject. The overall average number of respondents, as shown in 

the table below, is 106 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR.

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 2 102 0 0 104

2 2 104 0 0 106

3 2 106 0 0 108

Average 2 104 0 0 106

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 106.

The total number of annual responses per year is calculated using the following table:
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Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of 

Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total 

Annual 

Responses

E=(BxC)+D

Notification of construction/reconstruction 2 1 0 2

Notification of actual startup 2 1 0 2

Notification of performance test 2 1.2 0 2.4

Notification of CMS demonstration 2 1 0 2

Notification of physical or operational changes 2 1 0 2

Notification of opacity or visible emission

Observations

2 1 0 2

Report of performance test 2 1.2 0 2.4

Semiannual report 106 2 0 212

Excess emissions report 106 2 0 212

Total 438.8

The number of Total Annual Responses is 439 (rounded).

The total annual labor costs are $1,541,377. Details regarding these estimates may be 

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

CFR Part 60, Subpart BB) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 16,086. Details regarding these estimates may be found

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

60, Subpart BB). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 37 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $4,182,100. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup Operation and Maintenance 
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(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is estimated to be 

1,074 labor hours, at a cost of $48,404. See below Table 2: Average Annual EPA Burden and Cost

- NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal).

6(f) Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to two adjustments. 

First, there is an increase in the average number of respondents expected to become subject to the 

standards over the next three years. Second, this ICR uses updates labor rates for each of the three 

labor categories.

The increase in O&M costs is due to an increase in the average number of respondents 

expected to become subject to the standards over the next three years.

There is also an increase in Agency costs which is due to the use of the most updated labor 

rates.

6(g) Burden Statement

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

estimated to average 37 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

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

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

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

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

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

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

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

ID Number EPA-HQ-OECA-2011-0242. An electronic version of the public docket is available at 

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

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

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

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

documents are also available for public viewing at the Enforcement and Compliance Docket and 
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Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public Reading Room 

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

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

Enforcement and Compliance Docket and Information Center Docket is (202) 566-1752. Also, 

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

Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer 

for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0242 and OMB 

Control Number 2060-0021 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
Table 1: Annual Respondent Burden and Cost – NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal)

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 

personhours per 

year

(E=CxD)

(F)

Management 

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 1 1 2 2 0.1 0.2 $220.38 

 B. Required activities

 Initial performance tests c374 1 374 2 748 37.4 74.8 $82,423.62

 Repeat performance tests d370 0.2 74 2 148 7.4 14.8 $16,308.42

 C. Gather existing information See 3B

 D. Write report

Notification of 

construction/reconstruction 2 1 2 2 4 0.2 0.4 $440.76

 Notification of performance test 2 1.2 2.4 2 4.8 0.24 0.48 $534.92

 Notification of actual startup 2 1 2 2 4 0.2 0.4 $440.76

 Notification of CMS 

demonstration 2 1 2 2 4 0.2 0.4 $440.76

 Notification of physical changes 2 1 2 2 4 0.2 0.4 $440.76

 Notification of opacity or visible 

emissions observations 2 1 2 2 4 0.2 0.4 $440.76

Report of performance test See 3B

Semiannual report e8 2 16 106 1,696 84.8 169.6 $186,885.64

Excess emissions report f8 2 16 106 1,696 84.8 169.6 $186,885.64

Subtotal for Reporting 

Requirements 4,962.02

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities See 3B

 C. Implement Activities See 3B

 D. Develop record system N/A

 E. Time to enter and transmit 
15

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 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours per 

year

(Ex0.1)

(H)

Total Cost

Per year b

information

Records of operating parameter g0.25 365 91.25 106 9,673 484 967 $1,065,914.77

Subtotal for Recordkeeping 

Requirements 11,124

TOTAL LABOR BURDEN AND 

COST (rounded) 16,086 $1,541,377

Assumptions:

a

 We have assumed an average of 104 respondents over the next three years. 

b

This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81per hour 

for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 “Table 10. Private industry, by Occupational 

and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to 

those employed by private industry.

c We have assumed that it will take 374 hours for each new respondent to perform the initial performance test.

d We have assumed that 20 percent of respondents would repeat performance test due to failure.

e We have assumed that all respondents will each take eight hours to complete the semi annual report.

f We have assumed that each respondent will take eight hour to two times per year to complete the excess emissions report.

g We have assumed that it will take each respondent 15 minutes per day to record operating parameter.
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Table 2: Average Annual EPA Burden and Cost - NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per yeara

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

person-hours 

per year

(Ex0.1)

(H)

Cost, $b

Initial performance testsc

 New plant 24 1 24 2 48 2.4 4.8 $2,487.58 

Repeat performance test d

New plant 24 0.2 4.8 2 9.6 0.48 0.96 $497.52 

Report Review

New plant

Notification of 

construction 2 1 2 2 4 0.2 0.4 $207.29

Notification of 

performance test 0.5 1.2 0.6 2 1.2 0.06 0.12 $62.19 

Notification of actual 

startup 0.5 1 0.5 2 1 0.05 0.1 $51.82 

Notification of CMS 

demonstration 0.5 1 0.5 2 1 0.05 0.1 $51.82 

Notification of 

physical/operational 

changes

0.5 1 0.5 2 1 0.05 0.1 $51.82 

Notification of opacity or 

visible emissions 

observations

0.5 1 0.5 2 1 0.05 0.1 $51.82 

Review test results 8 1.2 9.6 2 19.2 0.96 1.92 $995.03 

Existing plants

Semiannual reportse4 2 8 106 848 42.4 84.8 $43,947.18 

Subtotals Labor Burden and cost 934 46.7 93.4

TOTAL ANNUAL BURDEN

AND COST (rounded) 1,074 $48,404 

Assumptions:

 a We have assumed an average of 104 respondents over the next three years. 
17

b

This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from 

the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c We have assumed that it will take twenty-four hours for each new respondent to perform the initial performance test.

 d We have assumed that 20 percent of respondents would repeat performance test due to failure.

 

e We have assumed that each respondent will take four hours to review the semiannual report.