1 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

November 1 6 , 20102 SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST FOR P ULP 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 (N SPS ) and National Emission Standards f or Hazardous Air Pollutants (NESHAP ) Residual Risk and Technology Review (RTR) .” T his is a new information collection request (I CR). (b ) Short Characterization This information collection is being conducted b y EPA’s Office of Air and Radiation (OAR) to assist the EPA Administrator, as required by section s 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 standard s for this source category

. The information from this I CR 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 (NE I). Neither the Lockwood

- Post n or the N EIcontain all of the details (capacity, fuel type s , operating schedule, emission source design, materials processed, emissions collection and control s ys tems, regulatory alternatives used, and emission test data) necessary

to characterize pulp and paper N SPS and NE S HAP affected sources for purposes of regulatory

analy ses. 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 previousl y conducted emissions test results (since the mid

- 1990s) that will provide data for emissions of the variety of pollutants under consideration . To obtain this information , EPA is soliciting information with a survey , under authority of CAA section 114, from all potentially affected units. EPA intends to administer the survey in electronic (spreadsheet) format. The survey will be s ent to all pulp and paper manufacturing f acilities listed in the L ockwood

- Post.3

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 183,746 h ours and $17,386,690 , which includes $6,948 in operation and maintenance (O&M) costs for postage for mailing survey responses to EPA

. The average burden per res pondent is 476 hours and $45,025

. 2. Nee d for and Use of the Collection (a ) Ne ed/Authority fo r 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 manu factured on

- site), non

- integrated mills (where either paper/ paperboard or pulp are manufactured onsite , but no t both), and secondary fiber mills (where waste paper is used as the primary raw material). The pulp and paper production process units include o perations 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 feder al emission standards that are the subject of this information collection include: 1. Standards of P erformance for Kraft Pulp M ills (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 ) currentl y 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 s ys te m vents, pulping process condensates ) at chemical, mechanical,
secon dary fiber, and non

- wood pulp mills; bleaching operations; and papermaking s ys tems

. The subpart S standards include several alternative emission limits for each covered process that are d esigned to provide flexibility and to promote and encourage the use of new technology , particularl y combined air/water controls and pollution prevention technologies. The NESHAP subpart MM regulates HAP emissions from the chemical recovery combustion area s of chemical pulp mills (k

raft, sulfite, semi

- chemical, and soda wood pulping processes)

. For existing kraft4

and soda combustion units, the subpart MM standards also include a compliance alternative that allows netting of PM emissions for the entire chem ical recovery s ys tem. 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 ye ars 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 , proc esses, 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 1 12(f)(2) and 112(d)(6). Likewise, the NESHAP for chemical recovery combustion sources at kraft, soda, sulfite, and stand

- alone semichemical pulp mills (40 CFR part 63, subpart MM) was promulgated in 2001 and is also due for review

. In addition to the CAA

- required reviews, recent case law , legal petitions , and a notice of intent (NOI) to sue suggest the need to review the pulp and paper NESHAP and NSPS . For example, in December 2008 , the U.S. Court of Appeals for the D.C. Circuit vacated the startup, shut down, and malfunction (SSM) provisions contained in the NESHAP General Provisions that apply to pulp and paper mills. In January 2009, EPA received a petition for rulemaking requesting that EPA revise various NESHAP, including the NESHAP for chemical reco very combustion sources at pulp mills, to make the NESHAP consistent with CAA precedent established in recent judicial rulings. In July 2010 , EPA received a NOI from Californians for Alternatives to Toxics (CATs) and the Center for Biological Diversity (C BD), contending that EPA failed to review the NSPS for kraft pulp mills within the statutory deadline under CAA section 111(b)(1)(B). To the extent that these legal actions need to be addressed in the pulp and paper NESHAP and NSPS , EPA intends to investi gate potential rule revisions at the same time as the CAA statutory reviews are conducted. The data used as the basis for the originall y promulgated pulp and paper NESHAP are over 15 years old , and data used to review the NSPS are over 20 ye ars old . The Agency is aware that significant changes have been made in the intervening ye ars in the number of affected5

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 section s 111(b) and 112 and the recent case law , legal petitions, and NOI regarding those requirements, the Agency has concluded that obtaining updated information will be crucial to informing its decision s on th e 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 pu lp and paper NESHAP subparts S and MM

. Data sets derived from the EPA’s 2005 National S cale 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 NE I data sets for these mills . However, there remain a number of pulp and paper mills for which substantial upd ates 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, the re may be some mills for which no pulp and paper MACT category NEI data are currentl y available. Preliminary risk analy sis results for the pulp and paper sector (based on the current NEIdata sets) indicate that some mills may present risk above the thres holds for further consideration under the residual risk process. Addition al mill

- specific information would allow EPA to better characterize emission sources, refine the risk anal ys is, and to address an y unacceptable residual risk that remains. An update of the 2005 NATA NEI data sets and more specific information needed for rulemaking re gulatory anal ys es would be derived from the ICR. Information collected directl y from pulp and paper mills will have the greatest practical utility for purposes of perfor

ming 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 I CR 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 currentl y available inventory does not yet reflect recent changes in equipment). 1

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 info rmation 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 re viewed).6

To allow respondents more time to complete the survey , the ICR has been divided into three parts , with each part due on a different date . Part Irequests information on the pulp and paper production process addressed under the subpart S NESHAP and subpart BB NSPS and will be due within 30 day s of receipt of the survey . Part II requests the NEI update and will be due within 100 days of receipt of the survey . Part III requests information on the chemical recovery combustion process addressed under the subpart MM NESHAP and subpart BB NSPS and will be due within 180 day s of receipt of the survey

. CAA section 114(a) states that the Administrator may require any

owner or operator
subject to any

requirement of the Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3) ; and (G) provide such other information as the Administrator may

reasonably

require. (b ) Use/Users of the Data As mentioned previously, the data used for the originall y 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 standard s. 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 configuration s 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 anal ys es required under CAA sections 112(d) and 112(f)(2). In addition, this updated information will be used to perform the NSPS review required under CAA section 111(b). By collecting information for all of the CAA

- required reviews at the same time (i.e., the subpart S and MM RTR reviews and the subpart BB NSPS review), the Agency can make use of a single collection of information that wou ld allo w the Agency to consider control strategies that are the most effective for both HAP and criteria air pollutants (such as PM,7

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 way s 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 es timates of the populati on 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 l imits, and to determine the performance of superior control measures considered for purposes of reducing residual risk or as options for best demonstrated technology (BDT) under the NSPS review. Emissions data will also be used along with process and emis sion 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 analy ses for the pu lp and paper sector , it is EPA’s intent that the NEIupdates supplied through this information collection be used in future versions of the NEI and its successor, the Emissions Inventory Sy stem (EIS). The NEI is used by EPA, States, and the public for a v ariety 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 I CR wo uld also be available to the public, including pulp and paper industry trade groups that may

find the information useful for their ongoing data gathering, analy ses, and publications. Inaddition, such trade groups may wish to use the data collected to rev iew 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 i n the submittals made by individual companies, pursuant to S tate and national emission inventories, operating permits applications, initial notification forms , and compliance reports

. However, the complete extent of the data fields8

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 cyc les. 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 e quipment configuration and operational data for the 2009 operating ye ar, and thus avoids the effec ts of any such lag time o n data availability

. Although some S tate permits are provided to the public as searchable portable document format files (pdfs ) , man y S tates 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 hard

copy onl y, whereas onl y the facility

- level information (facility name, location, contact) is available in an electronic format

. In order to address SSM issues, the Agency has obtained numerous semi

- annual compliance reports for pulp and paper processes and found the reports to contain a widel y varyi ng 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 analy ses from existing documents (assuming that these documents were readil y available to EPA) , and that significant data gaps would remain even after data from existing documents were compiled

. Emissions test reports are oft en retained as hard copies by State agencies and thus are not readil y available for all mills. Although one pulp and paper industry trade organization (National Council for Ai r and Stream Improvement [NCASI ]) collects and compiles emission s test data in t echnical bulletins, these bulletins alone (while quite informative and valuable) do not inform all of EPA’s emissions data anal ys es because: (1) the NCASI technical bulletins are coded to mask mill identities such that the emissions data cannot be reconcil ed with other emissions data available to EPA; (2) the data contained in the NCASI reports may no t be reported in the units of measure needed for anal ys is of emission limits; (3) much of the data pre

dates implementation of the MACT standards, and (4 ) the data are generally representative of NCASImember mills , whereas information collected by EPA would be requested from the entire population of affected mills

.9

To summarize, the i nformation requested relevant to the current (post

- MACT) equipment configuration and operation , regulatory alternatives, emissions data, and effectiveness of various control sy stems at removing HAP is not readil y 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 yi eld incomplete information. In formation collected directly from pulp and paper mills would provide the most timely and comple te post

- MACT data set with the greatest practical utility for purposes of performing the NSPS and RTR reviews that are due to be completed under CAA sections 111(b) and 112(d) and (f)(2)

. (b ) Public Notice Required Prior to ICR Submission to OMB Th e IC R was submitted for public review on June 23, 2010 (75 FR 35792) as required b y 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)

. A 60

- day comment period ( ending August 23, 2010) was provided for the public to submit comments to EPA regarding the proposed new data collection. A total of three comments were received by EPA regarding the proposed ICR

. E PA revised the ICR to address the public comments prior to submitting the I CR to OMB. (c) Consultations Initial feedback was received from the affecte d industry regarding the scope of a pulp and paper sector survey

. D etailed comment s on the proposed IC R were received from the industry in August 2010, followed by meetings with the industry in October 2010 to discuss in greater detail the design and content of the I CR. The EPA has implemented many changes to specific ICR questions as a result of these consultations. In addition, EPA revised the survey so that it would be administered in three parts with staggered due dates to provide respondents with additional time to complete the survey

. Part I of the I CR will request information on the pulp and paper production process addressed under the subpart S NESHAP and subpart BB NSPS and will be due 30 day s after receipt of the survey . Part II of the I CR will require the facilities to complete an electronic update of their 2005 NATA NEI data set to be used for RTR purposes and will be10

due 100 day s after receipt of the survey . Part III of the I CR will request information on the chemical recovery

combustion process addressed under the subpart MM NESHAP and subpart BB NSPS and will be due 180 day s after receipt of the survey

. (d ) Effe cts of Less Frequent Collection T his I CR will require the owner/operator of each pulp and paper facility to c omplete an electronic survey in three parts, with staggered due dates. Each part requests different information. EPA expects the information requested in all three parts of this survey to be a one

time effort. (e) General Guidelines This I CR 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. I f 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 proce dure 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 b y 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979)

. An y information subsequently determined to co nstitute 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)

. Becaus e 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 p rovided in 40 CFR 2.301(a)(2)(i). (g ) Sensitive questions This section is not applicable because this ICR will not involve matter s of a sensitive nature

. 4. The Respondents and the Information Requested11

(a ) Respondents/NAICS Codes. Respondents affected b y 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 Inthe U.S., there are a total of 386 mills including:

 12 0 mills that c arry

out chem ical wood pulping (kraft, sulf ite, soda, or semi

- chemical),

 47 mills that c arry

out mechani cal, groundwood , secondary fiber, and non

- wood pulping,

 102 mills that perform bleaching, and

 36 6 mills that m anufacture 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

- Po st Online (as of March 2009), in cluding mills reported to be closed, idle, or bankrupt in 2009 (the base ye ar 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) a re not affected b y this action. The North American Industry

Classification Sy stem (NAICS) codes for respondents affected by the information collection include 32211 for pulp mills, 32212 for paper mills, and 32213 for paperboard mills. (b ) Information Collected (i ) Data Items. Each owner/operator of each affected mill will be required to complete an electronic survey that contains s everal components. Some survey components are not applicable for some types of mills. The draft electronic survey is a s eries of Microsoft Excel spreadsheet file s, each of which is divided into a series of worksheets (“tabs” within the spreadsheet file )

. Table 1 below denotes which pulp and paper sector survey spreadsheet tabs are to be completed depending on the part of the survey and ty pe of mill

. S urvey spreadsheet tab s must be completed for all mills that are major sources of HAP emissions and produce pulp , perform bleaching, or manufacture paper or paperboard products

. Mills will also be asked to

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 a ggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or mo re 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.12

supply process flow diagrams for the following mill 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 tab Types of mills that should c omplete this spreadsheet tab Estimated number of mi lls P&P survey_PI .xls Mill All mills 386 PI Equip detail All mills 386 PI Permit limits All mills 386 PI Controls Mills with add

- on air pollution controls on pulping emission units,

bleaching emission units, or papermaking emission units. 386 Pulp prod Mills that produce any type of pulp (including chemical,

mechanical/groundwood, secondary fiber, including non

- wo od pulp) 1 67 By products Mills that produce turpentine or tall oil byproducts from pulpi ng processes 104 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 perform bleaching 102 Paper prod Mills the produce paper or paperboard products 3 6 6 HAP additives Mills the produce paper or paperboard products 3 6 6 WW Mills with onsite wastewater treatment plants 386 PI Emissions test data All mills 386 P&P NEI update .xls (or P&P NEI blank.xls) Facility (or New Facility) All mills 386 Inventory (or New Facility) All mills 386 P&P survey_PIII.xls PIII Equip detail M ills that use chemical recovery combustion processes 120 PIII Permit limits M ills that use chemical recovery combustion processes 120 PIII Controls Mills with add

- on air pollution controls on chemical recovery combustion

processes . 120 PCC Mills that route lime kiln, boiler, or other process exhaust to a precipitated

calcium carbonate (PCC) plant 30 PIII Emissions test data M ills that use chemical recovery combustion processes 120 1. Assumes that up to 50% of kraft mills use the CCA. In addition to the pulp and paper sector survey spreadsheet s listed in Table 1, s eparat e spreadsheets are provided for submittal of continuous emissions monitoring s ys tem ( CEMS) and/or continuous opacity monitoring s ys tem (COMS) data , or optional control measure cost information. Separate versions of these spreadsheets are to be submitted under Parts I and III of the survey

for the different emissions units covered under th ose parts. E missions data collected under the Emissions test data tab s listed in Table 1 or the CEMS spreadsheet s mentioned above will allow EPA to characterize the performance of equipment and13

controls, reevaluate emissions li mits, 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 m atter (PM), filterable PM less than 2.5 microns (PM 2.5 ), condensable PM 2.5 , speciated HAP metals, chlorine (as a surrogate for chlorinated HAP), hydrochloric acid, methanol (as a surrogate for organic HAP), acetaldeh yd e, formaldeh yd e, total hydrocarbon (as carbon), dioxin/furan (CDD/CDF), polycyclic organic matter/polycyclic aromatic h ydrocarbon (POM/PAH), total reduced sulfur (TRS), nitrogen oxides (NOx), sulfur dioxide (SO 2 ), and carbon monoxide (CO). Separate “tabs” of the CEMS spreadsheet are provided for the different pollutants for which CEMS are available

. The control cost spreadsheet requests information related to the capital and operating costs of selected air pollution controls or process/equipment changes. Submittal of the control cost information is optional . The Agency wishes to receive enough cost information on a voluntary basis to perform the CAA

- required regulatory anal ys es. However, should additional cost information be needed, EPA reserves the right to follow up with mills that have in stalled 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 an d paper information collection in a way to minimize the burden associated with supplying and processing this information. The survey will collect information to supply multiple regulatory

actions in order to minimize duplication and burden associated with multiple collections for the different rules

. For mills with prior NEI data, th e EPA will pre - populate the Part II spreadsheets with each mill’s 2005 NATA NEI data set to be review ed (thereb y reducing respondent burden to locate and import their mill’s N EIdata). For mills with no prior NEIdata, a blank spreadsheet containing the NE I data fields to be populated will be provided. The burden associated with the NEI update has also been further reduced because updates to criteria air pollutant and inclusi on of total reduced sulfur data in the NEI update are optional. A lookup spreadsheet containing onl y 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 to reduce respondent time associated with locating codes on the NEI website. The pulp and paper14

information collection is being administered in spreadsheet form (as opposed to data base software ) because respondents are likel y 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 b y the Agency (eliminating the time require d for EPA to key

enter 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 s urvey spreadsheets. The burden associated with collection of emissions test data has be en reduced in several way s: (1) Onl y existing emissions data (CEMS data or emissions test reports) are being requested at this time. Mills are not required to conduc t any new emissions testing or to install or operate any new CEMS or COMS to respond to this survey. (2) Data are , for the most part, being requested for the HAP surrogates defined in the MACT standards, as opposed to speciated chlorinated HAP or speci ated non

chlorinated organic HAP. Speciated data are being requested for acetaldehyde and formaldeh yde (in addition to the methanol surrogate for organic HAP) because these pollutants are expected to be of interest for residual risk. (3) EPA has developed a matrix of emission units and pollutants for which test data are requested for the emissions units covered in Part I and Part II . Emissions data are only being requested for emissions unit and pollutant combinations for which emissions limits may

be ree valuated under NSPS review or RTR (or for pollutant that may serve as an indicator or surrogate for emission unit or control sy stem performance). The matrix provides cutoff d ates for selected emission unit and pollutant combinations ( or in some cases, onl y 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) fami liar with extracting test data from test reports to enter the data in a manner that ensures consist ent and reliable treatment of the data (e.g., with respect to data averaging, non - detects , etc ). (5) Respondents may

provide electronic or hard copy emission s test reports, whichever they find to be less burdensome. (6) The survey

instructions allow respondents to provide CEMS data in an alternative format if they

cannot fit it into the survey spreadsheet provided. The EPA has minimized the burden associated with providing permit limits by allowing submittal of the permit or summary of permit limits in an alternative format. The EPA is not requesting state mass

- based limits. The survey instruction s also include a table of suggested permit limit units of meas ure that are of the most interest (based on the units of measure for Federal limits )

.15

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 cha nges of particular interest for purposes of the NSPS review or RTR (as opposed to all control measures employed b y 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 anal yz e the cost impacts of regulatory options. ( ii ) Respondent Activities

. The activities a respondent must undertake to fulfill the requirements of the information collection are presented in Attachment 2

. These include: i) read instructions; ii) provide inf ormation 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) de velop electronic questionnaire and packages for mailout; ii) answer respondent questions (including claims of tru e area source status or that mill in not engaged in processes of interest); iii) review and anal yz e responses and emissions data; and iv) anal yz e requests for confidentiality. (b ) Collection Methodology and Management In collecting and anal yz ing the infor mation associated with this I CR, 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

que stions, 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 anal ys is. Survey responses claimed as CBI will be housed in a separate data base16

from the non

- CBIsurvey responses. In addition, a copy of the NEI updates submitted will be routed for inclusion in EPA’s residual risk input data ba se, and for inclusion in future versions of the NEI and its successor, the Em issions Inventory Sy stem (EIS). Emissions test report data will be entered into a data base by EPA (or EPA contractor personnel) familiar with extract ing test data from t est reports. In addition CEMS data would be uploaded in a data base for anal ys is of emissions variability

. The resulting data bases will be QA’d prior to and as part of regulatory anal ys es. (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 re spondents may be small entities. Small entities are likel y 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 sy nthetic 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 sy nthetic area source s of HAP emissions, s mall entities (and other non

- integrated mills) would have fewer portions of the survey to complete as their operations would likely be less e xtensive. Also, any individual small entity

would be expected to receive onl y one CAA section 114 letter so their response burden will be minimized

. The Agency

also plans to use an electro nic format of the questionnaire in order to reduce the burden and improve the data accuracy from all respondents, including small entities

. Inaddition, 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 EP A anticipates issuing the CAA s ection 114 letters by late 2010 /earl y 2011

. These CAA section 114 letters would require the owner/operator of each pulp and paper mill to complete P art I of the IC R w ithi n 30 day s of receipt of the survey , Part II within 100 day s , and Part III within 180 day s . EPA will compile and analyze the survey response data upon receipt

.17

6 . Estimating the Burden and Cost of the Collection ( a ) Estimating Respond ent 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 hourl y rates for priv ate industry workers and were taken from the United States Department of Labor, Bureau of L abor Statistics, Sep tember 2009 , “Table 2. Civilian Workers, by

occupational and industry group,” available at www.bls.gov/news.release/ecec.t02.htm

. Wages for occupational groups are used as the basis for the labor rates with a total compensation of $46. 76 per hour for technical, $5 4

. 52 per hour for managerial, and $23

. 11 per hour for clerical

. These rat es 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 full y- burdened hourl y wage rates used to represent respondent labor costs are: technical at $9 8.20 , management at $11 4

. 49 , and clerical at $4 8.53

. These estimates represent the one

- time burden that will be incurred b y 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) 200 9 General Schedule which excludes locality

rates of pay

. These rates can b e 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 ), $ 34.3 4 for technical (GS

1 3 , Step 1), and $ 47.74 for managerial (GS

- 1 5 , Step 1 )

. These rates were increas ed b y 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 $ 54.9 4 , and managerial at $ 76.38

. ( c ) Estimating the Respondent Universe and Total Burden an d Costs Estimates based on the Lockwood

- Post Online (as of March 2009) indicate that the potential respondent universe consists of 386 mills. A ll 386 of these mills will be re quired to complete some portion of the electronic survey , with the exception of m ills that provide documentation (a one

- page form) to EPA within 20 day s certifying 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, pe rform bleaching, or manufacture paper or paperboard products

. The government burden estimate provided in Attachment 3 assumes that18

1 5 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 pro vides an estimated number of mills required to complete each portion of the survey

. Specific counts of the different types of mills used in the burden estimates are provided in Part B of this supporting statement. ( d ) Bottom Line Burden Hours and Costs Tables (i ) Respondent tally

. The bottom line industry burden hours and costs, presented in Attachment 2 , are calculated by summing the pers on - hours column and b y summing the cost column

. The total burden and cost to the industry for 386 resp ondents is 18 3, 746 hours and $17,379 , 742

. No capital or annualized costs are applicable because this is a one

- time submittal. O&M costs of $6,948 are estimated for postage to mail in the three parts of the survey response to EPA. (ii) Agency tally

. The bottom line Agency burden and cost, presented in Attachment 3 is calculated in th e same manner as the industry burden and cost

. The estimated burden and cost for 386 respondents is 12,4 68 hours and $6 73 , 617 , which includes $ 8,28 4 in O &M costs to send certified CAA s ection 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 I CR is a simple collectio n; therefore , this section does not apply

. (iv) Variations in the annual bottom line

. This section does not apply as this is a one

time collection. ( e ) Reasons for Change in Burden This is the initial estimation of burden for this information collection; therefore, this section does not appl y. ( f ) Burden Statement Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency

. This19

includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y 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 otherwi se 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 currentl y valid OMB control number

. The OMB control numbers for EPA’ s regulations are listed i n 40 CFR part 9 and 48 CFR chapter 15. The tota l cost burden for the pulp and paper data gathering effort is estimated to be 183, 746 hours and $17,379 , 742 ( 47 6 hours and $45,02 5 per respondent for 386 respondents )

. This I CR does not include any requirements that would cause the respondents to incur either capital or start

- up costs

. O&M costs of $6,948 ( $18 per respond ent) 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 I CR under Docket ID No. EPA

- HQ

- OAR

- 2007

- 0544 , which is available for onl ine viewing at www.regulations.gov, or in hard cop y 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 holiday s . 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 key in the Docket ID Number identified ab ove . 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

.2021

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 S tatement 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 re quired to complete some portion of the electronic survey , with the exception of mills that provide documentation to EPA certifying that either: (1) they are not a “major source” or “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 manufacture paper or paperboard products

. An y mill that meets one of these criteria will need to complete the one - page form in the survey overview document certifying their status and submit it to EPA within 20 day s of receiving the ICR. The government burden estimate provided in Attachment 3 assumes that 1 5 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 kn own 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 e ach 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 12 0 Mechanical/groundwood, secondary fiber, and non
- wood pulp mills mechanical 20 specialty (recycled) 23
nonwood 4 4722 Paper/paperboard only + Integrated paper mills 3 6 6 Number of mills that per form bleaching 102
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

.23 List of Attach ments

1. Draft Questionnaire Content 2. Industry

Burden and Costs for Responding to the Questionnaire 3. Agency

Burden and Costs24 Attachment 1. Draft Questionnaire Content The draft electronic questionnaire may be found in separate files accompanying this supporting statement, including the following:

File nam e Description Phased Instructions Overview.doc This is the draft survey overview document. This file provides an overvie w of the sources covered under the pulp and paper sector survey, the sourc es exempt from the survey, the components and due dates of the three

- part survey, and the base year for the survey. Attachments to this document are: (1) documentation of true area, non

- operational, or non

- applicable status; (2) NSPS and NESHAP definition s; (3) acronyms and abbreviations used in the survey materials ; and (4) signed certification form

. Part I

– Mill Overview and Subpart S Data P& P survey instructions_PI

.doc This file provides instructions for completing and submitting Part I of the

surve y (including CBI and non

- CBI responses); the request for flow diagrams; the request for emission test data (emissions test reports or CEMS) for pulp and paper production units ; and the request for optional control measure cost information for those units

. Attachments to this document are: (1) a list of emission units to include in Part I of the survey response; (2) small business size standards ; and ( 3 ) a table of pulp and paper production emission units and pollutants for which existing emission test data are requested. P& P survey_PI

.xls This multi

- tabbed spreadsheet file is the main portion of Part I of the survey.

It includes a number of pulp and paper sector tabs with questions needed to specify and characterize pulp and paper production emission unit s and control systems. A listing of the tabs in this file is provided in Table 1 of the Part I survey instructions document described above. P& P CEMS _PI .xls The spreadsheet contains templates for submittal of CEMS or COMS data for

pulp and paper production units (for mills that currently operate CEMS or COMS). Separate tabs are provided for TRS, NOx, SO 2 , CO, methanol, chlorine, and PM. An optional tab is included for CEMS cost information, and an example tab is provided. P& P costs OPTIONAL_PI

.xls Thi s file contains control device and process change cost questions for pulp

and paper production emission units . These cost questions are optional. Part II

– NEI Update P& P NEI instructions.doc This file provides instructions for completing and submitting the NEI update in Part II of the survey . Attachments to this document are: (1) a list of emission units to include in the NEI update ; (2) resources for estimating emissions ; and (3) instructions for accessing the FTP site

. P& P NEI update.xls This spread sheet file includes the NEI update portion of Part II of the survey for mills with existing NEI data. It includes pre

- populated Facility and Inventory tabs with additional specified columns for respondents to enter any revisions. P& P NEI blank.xls This s preadsheet file includes the NEI update portion of Part II of the survey for mills for which NEI data do not exist. It includes blank New Facility and New Inventory tabs with specified columns for respondents to enter the relevant information. Lookups fo r 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.25 File nam e Description Part III

– Chemical Recovery Combustion Sources P& P survey instructions_PIII .doc This file provides instructions for completing and submitting Part III of the survey (including CBI and non

- CBI responses); the request for emission test data (emissions test reports or CEMS) for chemical recovery combustion units ; and the request for optional control measure cost information for those units . Attachments to this document are: (1) a list of emission units to include in Part III of the survey response; and (2) a table of chemical recovery combustion units and pollutants for which existing emissions test data are requested. P& P survey_PIII

.xls This multi

- tabbed spr eadsheet file is the main portion of Part III of the survey.

It includes a number of pulp and paper sector tabs with questions needed to specify and characterize chemical recovery combustion units and control systems. A listing of the tabs in this file i s provided in Table 1 of the Part III survey instructions document described above. P& P CEMS _PIII .xls The spreadsheet contains templates for submittal of CEMS or COMS data for

chemical recovery combustion units (for mills that currently operate CEMS or C OMS). Separate tabs are provided for TRS, NOx, SO 2 , CO, methanol, chlorine, and PM. An optional tab is included for CEMS cost information, and an example tab is provided. P& P costs OPTIONAL_PIII .xls This file contains control device and process change c ost questions for

chemical recovery combustion units . These cost questions are optional.26 Attachment 2. Industry Burden and Costs for Responding to the Questionnaire
Respondent Activity (A) Hours per Occurrence (B) Occurrences/

Respondent/Year (C) Hou rs/ Respondent/ Year (A x B) (D)

Respondents/ Year 1 (E) Technical

Hours/Year (C x D) (F) Managerial

Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/ Year 1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable) 4. REPORT REQUIREMENTS A. Read I nstructions 12 1 12 386 4,632 232 463 $503,840 B. Required Activities a. Part I: Mill Overview and Subpart S Data i . Submit flow diagrams 20 1 20 386 7,720 386 772 $ 839,733 ii . Complete and submit survey spreadsheet tabs, as follows: Mill (general information) 6 1 6 386 2,316 116 232 $251,920 PI Equip detail 4 0 1 4 0 386 15,440 772 1,544 $1,679,466 PI Permit limits 40 1 40 386 15,440 772 1,544 $1,679,466 PI Controls 15 1 15 386 5,790 290 579 $629,800 Pulp prod 6 1 6 167 1,002 50 100 $108,991 Byproducts 4 1 4 104 416 21 42 $45,250 Kraft condensates 8 1 8 104 832 42 83 $90,500 CCA2 8 1 8 52 416 21 42 $45,250 Bleaching 6 1 6 102 612 31 61 $66,5 70 Paper prod 6 1 6 366 2,196 110 220 $2 38,867 HAP additives 20 1 20 366 7,320 366 732 $ 796,223 WW 6 1 6 386 2,316 116 232 $251,920 PI Emissions test data 3 Reports for chemical pulpin g ( 4 reports) 1 4 4 120 480 24 48 $ 52,211 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1 1 1 515 515 26 52 $56, 018 iii . Gather and scan/copy emission test reports for submittal 3,4 Reports for chemical pulping (4 reports) 1.5 4 6 120 720 36 72 $ 78,317 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1.5 1 1.5 515 773 39 77 $84, 028 iv . Complete and submit Part I CE MS spreadsheet 5 10 1 1 0 120 1,200 60 120 $1 30,528
v . Complete and submit Part I optional cost spreadsheet 6 10 1 10 96.5 965 48 97 $ 104,967 vii. Complete signed certification form for part I 0.2 1 0.2 386 77 4 8 $8,397 b

. Part II: NEI Update i. Complete and submit survey spreadsheet tabs, as follows: Mills that previously updated their NEI for RTR 120 1 120 105 12,600 630 1,260 $1,370,549 Mills that have not previously updated NEI for RTR 180 1 180 182 32,760 1,638 3,276 $3,563,426 Mills with no prior NEI

data 28 0 1 28 0 99 27,720 1, 386 2, 772 $3,015,20727 Respondent Activity (A) Hours per Occurrence (B) Occurrences/

Respondent/Year (C) Hou rs/ Respondent/ Year (A x B) (D)

Respondents/ Year 1 (E) Technical

Hours/Year (C x D) (F) Managerial

Hours/Year (E x 0.05) (G) Clerical

Hours/Year (E x 0.10) (H) Cost/ Year ii. Complete signed certification form for part II 0.2 1 0.2 386 77 4 8 $8,397 a. Part III: Chemical Recovery Combusti on Sources i . Complete and submit survey spreadsheet tabs, as follows: PI II Equip detail 20 1 20 120 2,400 120 240 $261,057 PI II Permit limits 20 1 20 120 2,400 120 240 $261,057 PI II Controls 15 1 15 120 1,800 90 180 $195,793 PCC 4 1 4 30 120 6 12 $13,053 PI II Emissions test data 3 1 14 14 120 1,680 84 168 $182,740 ii. Gather and scan/copy emission test reports for submittal 3,4 1.5 14 21 120 2,520 126 252 $274,110 iii . Complete and submit Part III CEMS spreadsheet 5 30 1 30 120 3,600 180 360 $391,585 i v . Complete and submit Part III optional cost spreadsheet 6 30 1 30 30 900 45 90 $97,896 v. Complete signed certification form for part III 0 .2 1 0.2 120 24 1 2 $2,611 C. Create I

nformation (I

ncluded in 4B) D. Gather Existing I

nformation (I

ncluded in 4B) E. Write Report (Not Applicable) 5. RECORDKEEPI

NG REQUIREMENTS (Not applicable) TOTAL ANNUAL LABOR BURDEN AND COST 159,779 7,98 9 15,9 78 $17,379 , 742 total= 18 3 , 746 avg hr/mill= 476 $ 4 5,025 ANNUAL CAPITAL COSTS (Not Applicable) $

- ANNUALIZED CAPITAL COSTS (Not Applicable) $

- TOTAL ANNUAL COSTS (O&M) 7 $ 6,948 TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) $ 6,948
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

. Itis estimated that chemical pulp mills will submit 18 test reports each (4 in response to Part I and 14 in response to Part III) , and that non

- chemical pulp mills, bleach plants, and paper mills will each submit 1 test report. 4

. Itis estimated that it would take 1.5 hour s to locate and scan or copy each te st report. 5

. Assumes that all chemical pulp mills will populate the CEMS spreadsheet with CEMS and/or COMS data. The majority of CEMS data are expected to be submitted for the emissions units covered under Part III. 6

. Assumes that 25% of mills will provide cost information. 7. Postage Costs for mailing survey re s ponses to EPA are estimated at $6 for Federal Express letter size envelope flat rate (1 per respondent

– i

. e., 3 total ).28 Attachment 3. Agency Burden and Costs

Agency Activity (A) EPA Hours/ Occur rence (B) Occurrences/

Respondent/Year (C) EPA

Hours/Respondent/Year (A x B) (D)

Respondents/Year 1 (E) EPA

Technical Hours/ Year (C x D) (F) EPA

Managerial Hours/Year (E x 0.05) (G) EPA

Clerical Hours/Year (E x 0.10) (H) Cost, $ Develop/revise questionna ire spreadsheets and instructions 400 1 400 1 400 20 40 $24,547 Develop survey webpage 1 0 1 1 0 1 10 1 1 $614 Pre

- populate mill spreadsheets with existing NEI data 2 1 1 1 287 287 14 29 $17,613 Mail out questionnaire 3 0.7 1 0.7 386 270 14 27 $16,582 Revi ew 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 products 4 1 1 1 57.9 58 3 6 $3,553 Answer respondent questions via phone, email, and/or frequently asked questions posted on webpage 5 1 1 1 96.5 97 5 10 $5,922 Analyze requests for confidentiality6 1 1 1 96.5 97 5 10 $5,922 Review signed certifi cation forms 0.1 1 0.1 386 39 2 4 $2,639 Review and analyze responses (including follow

- up) NEI data (from Part II) 4 1 4 386 1,544 77 154 $ 94,753 Sector survey spreadsheet data (from Parts I and III) 8 1 8 386 3,088 154 309 $ 189,504 CEMS data (from Parts I

and III) 7 2 1 2 120 240 12 24 $ 14,728 Optional cost data (from Par ts I and III) 8 2 1 2 96.5 193 10 19 $ 11,844 Print emissions test reports 9 0.1 2 ,675 267.5 1 268 13 27 $16,416 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 96 192 $117,827 Enter speciated HAP metals, PM2.5 (filterable and condensable), CDD/CDF, speciated TRS, POM/PAH 2 2 4 120 480 24 48 $29,457 Reports for non

- chemical pulping, papermaking, and bleaching (1 report for each process) 1 1 1 51 5 515 26 52 $31,605 Review/analyze emissions test data 10 0.5 2 ,675 1,337.5 1 1,338 67 134 $82, 080
Total Annual Hours 10,8 42 54 2 1, 08 4 $ 665 , 333 1 2, 4 68 hours Expenses (O &M) 11 Printing questionnaire $1,351 Flash drives $2,702 Postage $2,316 Computer storage of data $1,91 5 Total Expenses $8,284 TOTAL ANNUAL LABOR BURDEN AND COST $ 673 , 617 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 ex c ludes mills that are not already included in the NEI

.29

3. Mailout package includes section 114 letter with standard enclosures, hard copy of survey overview document, and flash drive containing spreadsheet files. Assumes EPA will mail one questionnaire per facility. 4. Assumes 1 5% of mills provide documentation of area s ource status , mill closure, or that pulping, bleaching, papermaking is not performed at the mill. Itis not known how many of these claims will be valid so this number of mills has not been subtracted from the burden estimates associated with completing t he 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 pro vide cost information. 9. Assumes 18 test reports for chemical pulp mills (from Parts I and III) , plus 1 test report each for non

- chemical pulp mills, bleach plants, and paper mills. 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). Expe ct to spend an average of 0.5 hr per test result. 11. Copy costs are estimated for 70 pages at $0.05/page. Flash drives were quote d at $7/each. Postage Costs are estimated at $6 for Federal Express letter size envelope flat rate. Data storage estimated at $21/GB/mo, assuming 25 MB per response for chemical pulp mills and 5 MB per response for non

- chemical pulping, papermaking, and bleaching mills. Webpage cost estimated at $85/mo for 6 months.