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 

May 27, 2010 

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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-1990’s) 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 

386 respondents) will be 127,906 hours and $12,100,453 which includes $2,316 in operation and 

maintenance (O&M) costs for postage for mailing survey responses to EPA. The average burden 

per respondent is 331 hours and $31,342. 

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 paper or paperboard are manufactured, but no pulp is manufactured on-site), 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 and legal petitions suggest the need to review the pulp and paper NESHAP. For 

example, the EPA received a petition for rulemaking in January 2009 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. Also, 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. To the extent that these legal actions need to be 

addressed in the pulp and paper NESHAP, EPA intends to investigate potential rule revisions at 

the same time as the CAA statutory reviews are conducted. 

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 interpreting those requirements, the Agency has 

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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” 

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

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 

                                                      

1

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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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 

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 conducting 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 

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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. 

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

public, 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 

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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. 

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). 

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

This ICR is being submitted for public review 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). EPA will address public comments before 

submitting the ICR to OMB. 

(c) Consultations 

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

paper sector survey. An opportunity for detailed comments on the electronic survey will be 

provided by the Federal Register notice concerning the availability of the ICR for public review 

and comment. 

(d) Effects of Less Frequent Collection 

This ICR will require the owner/operator of each pulp and paper facility to complete an 

electronic update of their 2005 NATA NEI data set to be used for RTR purposes. In addition, 

facilities will be asked to complete an electronic survey of general facility information 

(production processes and capacities), equipment details (for pulping, bleaching, papermaking, 

and wastewater treatment emissions sources), permit limits, emission control measures, and 

emissions test data (previously conducted tests only). EPA expects the information requested in 

this survey to be a one-time effort. 

 (e) General Guidelines 

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

1320.6. 

(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 

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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 matter 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” of HAP emissions and produce pulp, perform bleaching, or manufacture paper or 

paperboard products. 2

 In the U.S., there are a total of 386 mills including: 

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

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

• 102 mills that perform bleaching, and 

• 369 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 preliminary counts 

of potential respondents based on the Lockwood-Post Online (as of March 2009), including mills 

reported to be closed, idle, or bankrupt in 2009 (the base year for which production data will be 

requested). 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 

                                                      

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. 

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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 Microsoft Excel 

spreadsheet file that is divided into several worksheets (“tabs” within the spreadsheet). Table 1 

below denotes which pulp and paper sector survey spreadsheet tabs are to be completed 

depending on the type of mill. The Facility, Inventory, Equip detail and Emissions test data tabs 

must be completed for all mills that are major sources of HAP emissions and produce pulp, 

perform bleaching, or manufacture paper or paperboard products. The Facility and Inventory

tabs include the NEI update as well as other pulp and paper sector survey information (e.g., 

general facility information in the Facility tab, and permit limits in the Inventory tab). Mills will 

also be asked to supply process flow diagrams for the following mills areas (as applicable): 

pulping process, chemical recovery area, wastewater treatment, and black liquor gasification (if 

used). 

Table 1. Survey Spreadsheets and Tabs to Complete 

Spreadsheet and 

tab 

Types of mills that should complete this spreadsheet tab Estimated number 

of mills 

P&P sector 

survey.xls 

Facility All mills 386 

Inventory All mills 386 

Equip detail All mills 386 

Controls Mills with add-on air pollution controls on pulping emission units, 

bleaching emission units, papermaking emission units, or boilers. 386 

Potential changes Chemical pulp mills 120 

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

mechanical/groundwood, secondary fiber, including non-wood pulp) 167 

Byproducts Mills that produce turpentine or tall oil byproducts from pulping 

processes 104 

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

precipitated calcium carbonate (PCC) plant 30 

Kraft condensates Mills that perform kraft pulping 104 

CCA Mills that perform kraft pulping and use the clean condensate 

compliance alternative (CCA) 521

Bleaching Mills that perform bleaching 102 

Paper prod Mills the produce paper or paperboard products 369 

HAP additives Mills the produce paper or paperboard products 369 

WW Mills with onsite wastewater treatment plants 386 

Emissions test data All mills 386 

1. Assumes that up to 50% of kraft mills use the CCA. 

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In addition to the pulp and paper sector survey spreadsheet tabs 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. Emissions data collected will allow EPA to characterize the performance of 

equipment and controls, reevaluate emissions limits, and consider variability. Emissions data 

(test reports or 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), 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 emissions test data and CEMS 

spreadsheet are provided for the different pollutants. 

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, and respondents are given an additional 60 days beyond the due date 

for the other portions of the survey response for submittal of the optional cost information. The 

Agency wishes to receive enough cost information on a voluntary basis to perform the CAArequired 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 the burden 

associated with multiple collections. The EPA will pre-populate survey 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). 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 and 

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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 be 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 being requested for the HAP surrogates defined in the MACT standards, as 

opposed to speciated chlorinated HAP or speciated non-chlorinated organic HAP. 

(3) EPA has developed a matrix of emission units and pollutants for which test data are 

requested. 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. 

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. 

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 (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 

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. 

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 (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 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. 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 mid-2010. These CAA section 

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

and paper sector survey spreadsheet (including NEI update) and submit emissions test data 

within 60 days of receipt of the survey. Additional time (120 days) is allowed for completion of 

the optional control measure cost spreadsheet. EPA will compile and analyze survey response 

data upon receipt. 

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 

15
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) indicate that the 

potential respondent universe consists of 386 mills. All 386 of these mills will be required to 

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

documentation to EPA showing 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 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. 

16
 (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 386 respondents is 127,906 hours and 

$12,098,137. No capital or annualized costs are applicable because this is a one-time submittal. 

O&M costs of $2,316 are estimated for postage to mail in 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 386 respondents is 22,801 hours and $1,225,025, which includes $8,288 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 

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 

17
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 

127,906 hours and $12,098,137 (331 hours and $31,342 per respondent for 386 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 $2,316 ($6 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. 

18
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 386 mills. All 386 of these mills will be required to 

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

documentation to EPA showing that either: (1) they are not a “major 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 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 as follows: 

Chemical pulp mills Count

 kraft (including kraft/mechanical) 95 

 soda 1 

 sulfite 6 

 kraft/semichemical 9 

 semichemical 9 

 120 

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

 mechanical 20 

 specialty (recycled) 23 

 nonwood 4 

 47 

 Paper/paperboard only + Integrated paper mills 369 

 Number of mills that perform bleaching 102 

19
20

 

 TOTAL NUMBER OF MILLS 386 

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. 
List of Attachments 

1. Draft Questionnaire Content 

2. Industry Burden and Costs for Responding to the Questionnaire 

3. Agency Burden and Costs 

21
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 

P&P survey instructions.doc This is the draft survey overview document. This file provides 

instructions for completing and submitting the survey (including 

CBI and non-CBI responses); the request for flow diagrams; 

instructions for completing the NEI update; the request for 

emission test data (emissions test reports or CEMS); and the 

request for optional control measure cost information. 

Attachments to this document are: (1) a list of emission units to 

include in the survey response; (2) NSPS and NESHAP 

definitions; (3) small business size standards, (4) acronyms and 

abbreviations used in the survey materials, (5) resources for 

estimating emissions, and(6) a table of emission units and 

pollutants for which existing emissions test data are requested. 

P&P survey.xls This multi-tabbed spreadsheet file is the main portion of the 

survey. It includes the NEI update portion of the survey (in the 

Facility and Inventory tabs to the left of the orange vertical line), 

and several additional pulp and paper sector tabs with questions 

needed to specify and characterize emission units and control 

systems. A listing of the tabs in this file is provided in Table 1 

of the survey overview document described above. 

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. 

P&P CEMS Spreadsheet.xls The spreadsheet contains templates for submittal of CEMS or 

COMS data (for mills that currently operate CEMS or COMS). 

Separate tabs are provided for 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.xls This file contains control device and process change cost 

questions. These cost questions are optional, and are included in 

a separate spreadsheet so mills can be given additional time to 

respond. 

22
Attachment 2. 

Industry Burden and Costs for Responding to the Questionnaire 

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) Ma

Hour

(E x 

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 12 386 4,632 

B. Required Activities 

a. Update NEI data 

 Mills that previously updated their NEI for RTR 16 1 16 105 1,680  Mills that have not previously updated NEI for RTR 40 1 40 182 7,280  Mills with no prior NEI data 220 1 220 99 21,780 b. Submit flow diagrams 8 1 8 386 3,088 c. Complete and submit survey spreadsheet tabs, as follows:  Facility (general information) 6 1 6 386 2,316 

 Inventory (permit information) 32 1 32 386 12,352 

 Equip detail 60 1 60 386 23,160 

 Controls 30 1 30 386 11,580  Potential changes 4 1 4 120 480  Pulp prod 6 1 6 167 1,002  Byproducts 4 1 4 104 416 

 PCC 4 1 4 30 120  Kraft condensates 8 1 8 104 832 

 CCA2 8 1 8 52 416 

 Bleaching 6 1 6 102 612 

 Paper prod 6 1 6 369 2,214 

 HAP additives 8 1 8 369 2,952  WW 6 1 6 386 2,316 

 Emissions test data3

Reports for chemical pulping (18 reports) 1 18 18 120 2,160 

Reports for non-chemical pulping, papermaking, and bleaching (1 report for each process) 1 1 1 518 518 

d. Gather and scan/copy emission test reports for submittal3,4

 Reports for chemical pulping (18 reports) 1.5 18 27 120 3,240 

 Reports for non-chemical pulping, papermaking, and 

bleaching (1 report for each process) 1.5 1 1.5 518 777 

e. Complete and submit CEMS spreadsheet5 12 1 12 120 1,440 

f. Complete and submit optional cost spreadsheet6 40 1 40 96.5 3,860 

C. Create Information (Included in 4B) D. Gather Existing Information (Included in 4B) 

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24

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) Ma

Hour

(E x 

E. Write Report (Not Applicable) 

5. RECORDKEEPING REQUIREMENTS (Not applicable) TOTAL ANNUAL LABOR BURDEN AND COST 

111,223 

total= 127,906 avg 

ANNUAL CAPITAL COSTS (Not Applicable) ANNUALIZED CAPITAL COSTS (Not Applicable) TOTAL ANNUAL COSTS (O&M)7 TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) 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, and that non-chemical pulp mills, bleach plants, and paper mills will each submit 1 test report. 

4. It is estimated that it would take 1.5 hour 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. 6. Assumes that 25% of mills will provide cost information. 7. Postage Costs for mailing survey responses to EPA are estimated at $6 for Federal Express letter size envelope flat rate (1 per respondent).
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) 

Develop/revise questionnaire spreadsheets and instructions 400 1 400 1 400 Develop survey webpage 10 1 10 1 10 Pre-populate mill spreadsheets with existing NEI data2 1 1 1 287 287 Mail out questionnaire3 0.7 1 0.7 386 270 Analyze and respond to 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 57.9 58 Answer respondent questions via phone, email, and/or frequently asked questions posted on webpage5 1 1 1 96.5 97 Analyze requests for confidentiality6 1 1 1 96.5 97 Review and analyze responses (including follow-up) 

NEI data 12 1 12 386 4,632 Sector survey spreadsheet data 20 1 20 386 7,720 CEMS data7 8 1 8 120 960 Optional cost data8 8 1 8 96.5 772 

Print emissions test reports9 0.1 2450 245 1 268 _. Enter emissions test data from test reports 

Reports for chemical pulping (18 reports) 

Enter PM, chlorine, HCl, methanol, THC, NOx, 

SO2, CO 1 16 16 120 1,920 

Enter speciated HAP metals, PM2.5 (filterable 

and condensable), CDD/CDF, speciated TRS, POM/PAH 2 2 4 120 480 

Reports for non-chemical pulping, papermaking, and 

bleaching (1 report for each process) 1 1 1 518 518 

Review/analyze emissions test data10 0.5 2450 1225 1 1,339 Total Annual Hours 19,827 

 

Expenses (O&M)11 Printing questionnaire  Flash drives  Postage  Computer storage of data Total Expenses TOTAL ANNUAL LABOR BURDEN AND COST 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. 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 m

25
26

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 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. Assume all chemical pulp mills populate the CEMS spreadsheet with CEMS and/or COMS data. 8. Assume 25% of mills will provide cost information. 9. Assumes 18 test reports for chemical pulp mills, plus 1 test report each for non-chemical pulp mills, bleach plants, and paper mills. 

10. 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). 

test result. 

11. 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. D

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