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 (N SPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLL UTANTS (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

1SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE PERFORMANCE STANDARDS (N SPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLL UTANTS (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 Administ rator, as required by sections 111(b), 112(d), and 112(f)(6) of the Clean Air Act (CAA), as amended, to determin e the current affected population of pulp and paper processes and to re evaluate 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 Lockw ood-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, operat ing schedule, emission source design, materials processed, emissions collection a nd control systems, regulatory al ternatives 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 th e detail needed and are not readily available from any single source. Fu rthermore, 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 auth ority 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 pul p and paper manufacturing facilities listed in the Lockwood-Post.

2The EPA estimates the total cost to industry of the electronic information collection (gathering, entering, and quality assu ring (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 su rvey 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 categor y includes any facility engaged in the production of pulp and/or paper. This category in cludes, but is not limited to, integrated mills (where pulp alone or pulp and paper or paperb oard 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 ar e 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 subj ect 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 polluta nt (HAP) emissions from the pulp production areas (e.g., pulping system vents, pulping pro cess condensates) at chemical, mechanical, secondary fiber, and non-wood pulp mills; bleachi ng operations; and papermaking systems. The subpart S standards include several alternative em ission limits for each covered process that are designed to provide flexibility and to promote and encourag e the use of new technology, particularly combined air/water controls and pollution prevention tec hnologies. The NESHAP subpart MM regulates HAP emissions from the chem ical recovery combustion areas of chemical pulp mills (kraft, sulfite, semi-chemical, and s oda wood pulping processes). For existing kraft

3and soda combustion units, the s ubpart MM standards also include a compliance alternative that allows netting of PM emissions for th e 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 N SPS 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 ach ievable control technology (MACT) standards and determine if

additional standards are needed to reduce residua l 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 ne cessary, taking into account developments in practices, processes, and control technologies. Th e section 112(d)(6) tec hnology review is to be done at least every 8 years. The NESHAP fo r 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 combus tion sources at kraft, soda, sulfite, and stand-alone semichemical pul p 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 rulema king in January 2009 requesting that EPA revise various NESHAP, including the NESHAP for chem ical 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) provi sions contained in the NESHAP General Provisions that apply to pulp and pa per 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 N SPS are over 20 years old. The Agency is aware that significant changes have been made in th e intervening years in the number of affected facilities, in industry ownership practices, and in emission collection and c ontrol configurations. Further, in light of the statutory requirem ents for reviewing emission standards under CAA sections 111(b) and 112 and the r ecent case law interpreting those requirements, the Agency has

4concluded 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 fo r 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) Na tional 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 refine ments 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 w ould be useful in order for EPA to accurately consider RTR for the pulp and paper NESHAP standards. In addi tion, 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 c onsideration under the resi dual risk process. Additional mill-specific information would allow EPA to better characterize emission sources, refine the risk analysis, and to address any unacceptable residual ri sk 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. Info rmation collected directly from pulp and paper mills will have the greatest pr actical 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 m ill. The ICR will request that new information be supplied for a 2009 base year, and therefore, w ill not suffer from the considerable “lag time”

that can be associated with different inve ntory 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 Admini strator 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 inte rvals, during such periods, and in such

1 There is a “lag time” associ ated 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 tim e” associated with posting of recent permits to State websites (particularly if permits are only posted every 5 years as they are reviewed).

5manner 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 refl ect the significant changes in emissions collection and control configurations that have occu rred since promulgation of the MACT standards. The MACT

standards contain a number of co mpliance alternatives to allo w for a variety of equipment configurations and process change s 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 re quired under CAA sections 112(d) and 112(f)(2). In addition, this updated information will be us ed to perform the NSPS review required under CAA section 111(b). By conducting all of the C AA-required reviews at the same time (i.e., the subpart S and MM RTR reviews a nd the subpart BB NSPS review), the Agency can make use of a single collection of information th at would allow the Agency to c onsider control strategies that

are the most effective for both HAP and criteria air pollutants (such as PM, SO 2 , and NOx) that are regulated under NSPS. The data would also allow the Agency to evaluate compliance options for startup and shutdown periods, and to consider ways to consolidate monitoring, reporting, and recordkeeping requirements am ong the different rule s under review. The data collected will be used to upda te facility information and equipment configuration, develop new estimates of the populati on of affected units, and identify the control measures and alternative emission limits being us ed for compliance with the existing rules that are under review. This information, along with ex isting 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 emi ssion 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

6with process and emission unit details to consid er subcategories for further regulation and to estimate the environmental and cost impacts associat ed 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 gr oups that may find the information useful for their ongoing data gathering, analyses, and public ations. 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. Howeve r, 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 i nventories, and permit review cycles. There is also a lag time associated with obtaining emission te st reports from State agencies (i.e., agencies may be reluctant to release emission test resu lts 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 provi de electronic versions of their issued Title V permits. Even when the permit is available, the unit-specific op erating data are often not contained within thepermit. Some of the initial notifications and compliance reports submitted are available in hardcopy only, whereas only the facility-level info rmation (facility name, location, contact) is

available in an electronic format. In order to address SSM issues, the Agency has obtained

7numerous 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 extrem ely 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 EP A), and that significant da ta gaps would remain even after data from existing documents were compiled. Emissions test reports are often retained as ha rd 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 Improveme nt [NCASI]) collects and compiles emissions test data in technical bulletins, these bulletins al one (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 su ch 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 analys is of emission limits; (3) much of the data predates implementation of the MACT standards, a nd (4) the data are generally representative of

NCASI member mills whereas information collect ed by EPA would be requested from the entire population of affected mills. To summarize, the information requested rele vant 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 av ailable from other sources. In the absence of an industry data collection, the EPA would be for ced 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 fr om existing reports would require more time than an industry data collection, and ul timately 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 comp leted under CAA sections 111(b) and 112(d) and (f)(2).

8(b) Public Notice Required Pr ior to ICR Submission to OMB This ICR is being submitted for public revi ew as required by the Paperwork Reduction Act of 1995 (PRA) and the subsequent rule i ssued 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 affect ed industry regarding the scope of a pulp and paper sector survey. An opportunity for deta iled 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 NAT A NEI data set to be used for RTR purposes. In addition, facilities will be asked to complete an elec tronic survey of general facility information (production processes and capacitie s), equipment details (for pulping, bleaching, papermaking, and wastewater treatment emissions sources), permit limits, emission control measures, and emissions test data (previously conducted tests on ly). 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 Fede ral data requestors, as provided at 5 CFR

1320.6. (f) Confidentiality Respondents will be required to respond unde r 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 acc ording 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). A ny information subsequently determined

9to 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, Septem ber 1, 1976). Because CAA section 114(c) exempts emission data from claims of confiden tiality, the emission data provided may be made available to the public. Theref ore, 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 (k raft, sulfite, soda, or semi-chemical),

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

• 102 mills that perform bleaching, and

• 369 mills that manufacture pape r 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-Po st Online (as of March 2009), including mills reported to be closed, idle, or bankrupt in 2009 (t he 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., c onverting operations) are not aff ected 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 st ationary 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 fr om those specified in this sentence.

10information 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 a ffected mill will be required to complete an electronic survey that contains se veral components. Some survey components are not applicable for some types of mills. Th e draft electronic survey is a Microsoft Excel spreadsheet file that is divided into several wo rksheets (“tabs” within the spreadsheet). Table 1 below denotes which pulp and paper sector surv ey 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 ma jor 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 pu lp 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, wastew ater 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) 52 1 Bleaching Mills that pe rform 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.

11In 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 (C OMS) data, or optional control measure cost

information. Emissions data collected will a llow EPA to characterize the performance of equipment and controls, reevalua te emissions limits, and consider variability. Emissions data (test reports or CEMS data) ar e being requested for affected sources and emissions units for which emissions limits may be reevaluated unde r NSPS review or RTR. The pollutants for which emissions data are requested include partic ulate matter (PM), filter able PM less than 2.5 microns (PM 2.5 ), condensable PM 2.5 , speciated HAP metals, chlo rine (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 sulf ur (TRS), nitrogen oxides (NOx), sulfur dioxide (SO 2 ), and carbon monoxide (CO). Separate “tab s” of the emissions test data and CEMS spreadsheet are provided fo r the different pollutants. The control cost spreadsheet requests inform ation 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 informa tion on a voluntary basis to perform the CAArequired regulatory analyses. However, shoul d additional cost information be needed, EPA reserves the right to follow up w ith mills that have installed eq uipment or implemented process changes of interest to request cost in formation under CAA sec tion 114 authority. Although a large amount of information is n eeded 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 pr ocessing this information. The survey will collect information to supply multiple regulat ory 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 (t hereby reducing respondent burden to locate and import their mill’s NEI data). A lookup spread sheet 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 orde r to ensure that valid NEI codes are used and

12to reduce respondent time associated with lo cating 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 spread sheets 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 surv ey spreadsheets. The burden associated with

collection of emissions test data ha s 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 requi red 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 surr ogates 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 uni ts 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 burde n and to ensure the Agency’s ability to process the data requested. (4) Respondents are required to submit emissions test repor ts 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 a nd reliable treatment of the data (e.g., with respect to data averaging, non-detects, etc). (5) Respondents may provide electronic or ha rd 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 informati on 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 av ailable since the cost data would be specific to pulp and paper applications. In addition, collecti on of cost information from the industry (as opposed to a separate collection from other so urces such as vendors) would accelerate EPA’s ability to analyze the cost im pacts of regulatory options.

13(ii) Respondent Activities. The activities a respondent mu st undertake to fulfill the requirements of the information collection are presen ted in Attachment 2. These include: i) read instructions; ii) provide information on each aff ected source through electronic survey; and iii) submit hard or electronic copies of flow diagra ms, 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 da ta; and iv) analyze requests for confidentiality.

(b) Collection Methodo logy and Management In collecting and analyzing the information associated with this ICR, EPA will use personal computers and applicable spreadsheet a nd 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 comple teness of the collected information by reviewing each submittal. Flow di agrams 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 reviewi ng 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 residu al risk input data base, and for inclusion in future versions of the NEI and its successor, the Emissions Inventory Sy stem (EIS). Emissions test report data will be entered into a data base by EPA (or EPA cont ractor personnel) familiar with extracting test data from test reports. In a ddition 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.

14(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 entitie s 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 in dividual small entity would be expected to receive only one CAA section 114 letter so their respons e burden will be minimized. The Agency also plans to use an electronic fo rmat of the questionnaire in order to reduce the burden and improve the data accuracy from all re spondents, 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 ow ner/operator of each pulp and pa per mill to complete the pulp and paper sector survey spreadsheet (includi ng NEI update) and submit emissions test data within 60 days of receipt of the survey. Additional time (120 da ys) 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 fo r 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

15for the labor rates with a total compensation of $46.76 per hour for te chnical, $54.52 per hour for managerial, and $23.11 per hour for clerical. These ra tes represent salaries plus fringe benefits

and do not include the cost of overhead. An overh ead 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 Govern ment would incur are presen ted 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 cleri cal (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 benef its and overhead. The fully-burdene d wage rates used to represent Agency labor costs are: cler ical at $26.05, technical at $54.94, and managerial at $76.38. (c) Estimating the Respondent Uni verse and Total Burden and Costs

Estimates based on the Lockwood-Post Onlin e (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 surve y, with the exception of mills that provide documentation to EPA showing that either: (1) they are not a major or s ynthetic 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 manufactur e paper or paperboard products. The government burden estimate provided in Attachme nt 3 assumes that 15 percent of mills will provide documentation of true area source stat us, mill closure, or that pulping, bleaching, papermaking is not performed at the mill. Howe ver, it is not known how many of these claims

will be valid so all mills are included in the bu rden estimate for respondents (in Attachment 2). Attachment 2 lists the various portions of the su rvey 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 provide d in Part B of this supporting statement.

16(d) Bottom Line Burden Hours and Costs Tables (i) Respondent tally. The bottom line industry burden hour s 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 th e industry for 386 respondents is 127,906 hours and $12,098,137. No capital or annualized costs are applicab le 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 industr y burden and cost. The estimated burden and cost for 386 respondents is 22,801 hours and $1,225,025, wh ich includes $8,288 in O&M costs to

send certified CAA section 114 letter s to all respondents with el ectronic 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 disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valida ting, and verifying information, processing and maintaining information, and disclosing and provi ding information; adjust the existing ways to comply with any previously applic able instructions and requirements; train personnel to be able to respond to a collection of information; search da ta 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 requir ed to respond to, a collection of information unless it displays a

17currently valid OMB control numb er. 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 EP A Docket, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EP A/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, ex cluding 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 sy stem, select “search,” then ke y in the Docket ID Number

identified above. Also, you can send comments to the O ffice of Information and Regulatory Affairs, Office of Management and Budge t, 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.

18INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE PERFORMANCE STANDARDS (N SPS) AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLL UTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW (RTR)

Part B of the Supporting Statement 1. Respondent Universe

Estimates based on the Lockwood-Post Onlin e (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 surve y, with the exception of mills that provide documentation to EPA showing that either: (1) th ey are not a “major source” of HAP emissions, (2) they were not operational in 2009 and re main 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 th at pulping, bleaching, papermaking is not performed at the mill. However, it is not known how many of these claims will be valid so all mills are included in the burden estimate for respondents (i n Attachment 2). 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, a nd 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

1920 TOTAL NUMBER OF MILLS 386

2. Response Rates Since the information will be requested pur suant 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 fo r Responding to the Questionnaire 3. Agency Burden and Costs

21Attachment 1.

Draft Questionnaire Content

The draft electronic questionnair e may be found in separate fi les 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 th e NEI update; the request for emission test data (emissions te st 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 res ponse; (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 emi ssions 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 pa per 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, SO 2 , CO, methanol, chlorine, and PM. An optional ta b is included for CEMS cost information, and an example tab is provided. P&P costs OPTIONAL.xls This file contains control de vice and process change cost questions. These cost questions ar e optional, and ar e included in a separate spreadsheet so mills can be given additional time to respond.

22Attachment 2.Industry Burden and Costs for Responding to the QuestionnaireRespondent Activity(A) Hours perOccurrence(B) Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year1(E) TechnicalHours/Year(C x D)(F) ManagerialHours/Year(E x 0.05)(G) ClericalHours/Year(E x 0.10)(H) Cost/ Year1. APPLICATIONS (Not Applicable)2. SURVEY AND STUDIES (Not Applicable)3. ACQUISITION, INSTALLATION, AND UTILIZATION OFTECHNOLOGY AND SYSTEMS (Not Applicable)4. REPORT REQUIREMENTSA. Read Instructions121123864,632232463$503,840B. Required Activitiesa. Update NEI dataMills that previously updated their NEI for RTR161161051,68084168$182,740Mills that have not previously updated NEI for RTR401401827,280364728$791,873Mills with no prior NEIdata22012209921,7801,0892,178$2,369,091b. Submit flow diagrams8183863,088154309$335,893c. Complete and submit survey spreadsheet tabs, as follows:Facility (general information)6163862,316116232$251,920Inventory (permit information)3213238612,3526181,235$1,343,573Equip detail6016038623,1601,1582,316$2,519,199Controls3013038611,5805791,158$1,259,599Potential changes4141204802448$52,211Pulp prod6161671,00250100$108,991Byproducts4141044162142$45,250PCC41430120612$13,053Kraft condensates8181048324283$90,500CCA2818524162142$45,250Bleaching6161026123161$66,570Paper prod6163692,214111221$240,825HAP additives8183692,952148295$321,100WW6163862,316116232$251,920Emissions test data3Reports for chemical pulping (18 reports)118181202,160108216$234,951Reports for non-chemicalpulping, papermaking,and bleaching (1 report for eachprocess)1115185182652$56,345d. Gather and scan/copy emission test reports for submittal3,4Reports for chemical pulping (18 reports)1.518271203,240162324$352,427Reports for non-chemicalpulping, papermaking, andbleaching (1 report for each process)1.511.55187773978$84,517e. Complete and submit CEMS spreadsheet5121121201,44072144$156,634f.Complete and submit optional cost spreadsheet64014096.53,860193386$419,866C. Create Information (Included in 4B)D. Gather Existing Information (Included in 4B)2324Respondent Activity(A) Hours perOccurrence(B) Occurrences/Respondent/Year(C) Hours/Respondent/Year (A x B)(D)Respondents/Year1(E) TechnicalHours/Year(C x D)(F) ManagerialHours/Year(E x 0.05)(G) ClericalHours/Year(E x 0.10) (H) Cost/ YearE. Write Report (Not Applicable)5. RECORDKEEPING REQUIREMENTS (Not applicable)TOTAL ANNUAL LABORBURDEN AND COST111,2235,56111,122$12,098,137total=127,906avg hr/mill=331$ 31,342ANNUAL CAPITAL COSTS (Not Applicable)$ -ANNUALIZED CAPITAL COSTS (Not Applicable)$ -TOTAL ANNUAL COSTS (O&M)7$ 2,316TOTAL ANNUALIZED COSTS (Annualized capital + O&Mcosts)$ 2,3161. The number of respondents per year is based on the millcounts listed in Part B, Section 1 - Respondent Universe.2. Assumes that 50% of kraft mills usethe clean condensate alternative (CCA).3. It is estimated that chemical pulp mills will submit 18 testreports 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 hourto 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 (1per respondent).Attachment 3.Agency Burden and CostsAgency Activity(A) EPA Hours/Occurrence(B) Occurrences/Respondent/Year(C) EPAHours/Respondent/Year(A x B)(D)Respondents/Year1(E) EPATechnical Hours/Year (C x D)(F) EPAManagerialHours/Year(E x 0.05)(G) EPAClericalHours/Year(E x 0.10)(H) Cost, $Develop/revise questionnaire spreadsheetsand instructions400140014002040$24,547Develop survey webpage1011011011$614Pre-populate mill spreadsheets with existing NEI data21112872871429$17,613Mail out questionnaire30.710.73862701427$16,582Analyze and respond to claims that survey is not required to becompleted due to area source status, mill closure, or becausemill does not produce pulp, perform bleaching, or manufacturepaper products411157.95836$3,553Answer respondent questionsvia phone, email, and/orfrequently asked questions posted on webpage511196.597510$5,922Analyze requests for confidentiality611196.597510$5,922Review and analyze responses (including follow-up)NEI data121123864,632232463$284,257Sector survey spreadsheet data201203867,720386772$473,761CEMS data78181209604896$58,913Optional cost data881896.57723977$47,376Print emissions test reports90.1245024512681327$16,434_. Enter emissions testdata from test reportsReports for chemical pulping (18 reports)Enter PM, chlorine, HCl, methanol, THC, NOx,SO2, CO116161201,92096192$117,827Enter speciated HAP metals, PM2.5 (filterableand condensable), CDD/CDF, speciated TRS, POM/PAH2241204802448$29,457Reports for non-chemical pulping, papermaking, andbleaching (1 report for each process)1115185182652$31,789Review/analyze emissions test data100.52450122511,33967134$82,172Total Annual Hours19,8279911,983$1,216,73722,801hoursExpenses (O&M)11Printing questionnaire$1,351Flash drives$2,702Postage$2,316Computer storage of data$1,919Total Expenses$8,288TOTAL ANNUAL LABOR BURDEN AND COST$1,225,0251. The number of respondents per year is based on the millcounts 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 letterwith standard enclosures, hard copy ofsurvey overview document, and flash drivecontaining spreadsheet files. Assumes EPA will mail one questionnaire per facility.25264. Assumes 15% of mills provide documentation of area source status, mill closure, orthat pulping, bleaching, papermaking is not performed at the mill. It is not known how manyof these claims will bevalid so this numberof mills has not been subtracted from the burdenestimates 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 testreport 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 rangeof other test results), while others will require additional time(e.g., best performers). Expect to spend an average of 0.5 hr pertest 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 sizeenvelope flat rate. Datastorage estimated at $21/GB/mo,assuming 25 MB per response for chemical pulp mills and 5 MB per response for non-chemical pulping, papermaking, and bleachingmills. Webpage cost estimated at $85/mo for 6 months.