SUPPORTING STATEMENT

ENVIRONMENTAL PRO TECTION AGENCY

NESHAP for Pulp and Paper Producti on (40 CFR Part 63, Subpart S) (Proposed Amendments)

1. Identification of th e Information Collection

1(a) Title of the Information Collection

NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) (Proposed Amendments), EPA ICR Number 2452.01, OMB C ontrol Number 2060-NEW

1(b) Short Charac terization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Pulp and Paper Production were proposed on December 17, 1993, and promulgated on April 15, 1998. Amendments to the Pulp and Paper Production NE SHAP are being propose d as a result of the residual risk and technology re view (RTR) required under by the Clean Air Act (as discussed further below). The Pulp and Paper Production NE SHAP applies to facil ities that produce pulp, paper, or paperboard by employing kraft, soda , sulfite, semi-chemical, or mechanical pulping processes using wood; or any process using seco ndary or non-wood fiber and that emits 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. Affected sources ar e all the hazardous air pollutant (HAP) emission points or the HAP emission points in the pulping and bleaching system for mechanical pulping processes using wood and any pro cess using secondary or non-wood fiber. This information is being collected to assure complian ce with 40 CFR Part 63, subpart S.

In general, all NESHAP requi re initial notificat ions, performance tests, and periodic reports. Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is i noperative. These notifications, reports, and records are essential in determining compliance, and are required of all sources subject to

NESHAP.

Any owner or operator subject to the provisions of this part sh all maintain a file of these measurements, and retain the file onsite for at least two years following the date of such measurements, maintenance reports, and records. All re ports are sent to th e delegated state or local authority. In the event that there is no such delegated authorit y, the reports are sent directly to the United States Environmenta l Protection Agency (EPA) regional office.

The amendments to the rule eliminate th e startup, shutdown, and malfunction exemption, remove the SSM plan requirement, add provisions to provide an affirmative defense against civil penalties for exceedances of emission standard s caused by malfunctions, and a requirement for electronic submittal of performance test data, and correct editorial errors. The remaining2

portions of the NESHAP remain unchanged.

Of 171 major source mills, approximately 114 mills have equipment subject to the standard, and it is estimated that no new major sources will become subject to the standard in the next three years. These assu mptions are based on the research conducted by EPA during the subpart S rule making, consultati on with the industry, and an information collection request (ICR) conducted by EPA’s Office of Air Qual ity Planning and Standa rds (OAQPS) in 2011. EPA is also aware that this industry is underg oing widespread consolidation and corporate restructuring, and that no new major source f acilities are being built, though approximately 15 percent of the affected facilities will rebuild one or more process units in a given year.

The Office of Management and Budget (OMB) approved the currently active Information Collection Request (ICR) without any “Terms of Clearance."

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

Section 112 of the Clean Air Act (CAA) requi res EPA to establish NESHAP for major sources of HAP that are listed for regulati on under CAA section 112(c). A major source is a stationary source that emits or ha s the potential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combin ation of HAP. For major sources, these technology-based standards must reflect the maximum degree of emi ssion reductions of HAP achievable (after considering cost, energy re quirements, and non-air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. In the Administrator's judgment, HAPs from pulp and paper plants cause or contribute to ai r pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP for this source category were promulgated at 40 CFR part 63, subpart S.

Section 112(d)(6) of the CAA requires EP A to review the technology-based MACT standards and revise them “as necessary (tak ing into account developments in practices, processes, and control technologies )” no less frequently than every 8 years. In addition, section 112(f) of the CAA requires EPA to determine wh ether the MACT emissions limitations provide an ample margin of safety to protect public heal th. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer risks to the individual most expos ed to emissions from a source in the category or subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to pr otect public health. In doing so, EPA may adopt standards equal to existi ng MACT standards, if EPA determines that the existing standards are sufficiently protective. EPA must also adopt more stringent standards, if necessary, to prevent an adve rse environmental effect, but must consider cost, energy, safety, and other relevant factors in doing so.

Certain records and reports are necessary for the Administrator to confirm the compliance status of sources subject to NE SHAP, identify any new or recons tructed sources subject to the3

standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are speci fically authorized by s ection 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Pr ovisions (40 CFR part 63, subpart A). CAA Section 114(a ) states that the Administra tor may require any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such re cords; (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 peri ods, and in such manner as the Administrator shall prescribe) ; (E) keep records on control equipment parameters, production vari ables or other indirect data when direct monitoring of emi ssions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other inform ation as the Administrator may reasonably require.

2(b) Practical Utility/Users of the Data

The control of emissions of HAP from pulp and paper plants requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of HAP from pulp and pa per plants are the resu lt of operation of the affected facilities. These standards rely on the collection of HAP emissions in enclosed and closed vent collection. Then, the collected HAPs are incinerated in a boi ler, recovery furnace, lime kiln, or thermal incinerator. HAPs associ ated with kraft pulping condensates are either treated with steam stripping (or equivalent technology) or in a wastewater treatment system. HAPs captured from bleaching systems are controlle d with a chlorine gas scrubber. Equipment inspection, performance tests, and leak detection and repair procedures are critical components of the standards. The required notifications are used to inform the Agency or delegated authority when a source becomes subject to the standard. Then, the reviewing authority may inspect the source to ensure that the polluti on control system is properly in stalled and operated, that leaks are being detected and repaired, a nd that the standard is being met. Performance test reports are needed as these are the Agency's record of a source's initial capability to comply with the emission standard, and serve as a record of th e operating conditions under which compliance was achieved. Repeat performance tests (at 5-year intervals) are needed to ensure ongoing compliance. The semiannual reports are used fo r problem identification, as a check on source operation and maintenance, and for compliance de terminations. The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP continue to operate their control equipment and achieve continuous compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure complian ce with these standards, as required by the Clean Air Act. The informati on collected from recordkeeping and reporting requirements is also used for targeting inspections , and is of sufficient quality to be used as

evidence in court.4

3. Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is required under 40 CFR part 63, subpart S.

3(a) Nonduplication

If the subject standards have not been delega ted, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a st ate or local agency has adopted its own simila r standards to implement the Federal standards, a copy of the report submitted to the state or local agency can

be sent to the Administrator in lieu of the report required by the Fe deral standards. Therefore, no duplication exists.

Some of the facilities subject to this NESHAP will also be subject to requirements under the New Source Performance Standard (NSPS) fo r Kraft Pulp Mills, 40 CFR 60 subpart BB. The burden requested for this NESHAP does not duplicate any of the burden accounted for under NSPS subpart BB.

3(b) Public Notice Required Pr ior to ICR Submission to OMB

The preamble to the proposed RTR will provide public notice of this ICR.

3(c) Consultations a nd Stakeholder Outreach

The proposed amendments were developed in consultation with the Nez Perce, Forest County Potowatomi and Leech Lake Band of Ojibewa.

Stakeholder outreach occurred with industry gr oups including American Forest and Paper Association (AF&PA), National Council for Air and Stream Improvement (NCASI) and member companies of these organizations. Stakeholder m eetings were also held with Sierra Club, Earth Justice, and with organizations that participated in EPA Environmental Ju stice outreach efforts. Further stakeholder and public input is e xpected through public comment and follow-up meetings with interested stakeholders.

In addition, EPA/OAQPS conducte d a three-part ICR to gath er data from the pulp and paper industry. The results from Part I of this ICR were used in updating the burden estimates contained in this supporting statement.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the required stan dards. Requirements for information gathering and recordkeeping are useful techniques to ensu re that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the likelihood of de tecting poor operation and maintenance of control equipment and noncompliance would decrease.5

3(e) General Guidelines

None of these reporting or recordkeeping re quirements violate a ny of the regulations established by OMB in 5 CFR 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency pol icies set forth in Title 40, Chapter 1, part 2, subpart B - Confidentiality of Busine ss Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,
1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

Respondents included in the subpart S source ca tegory are owners/operators of mills that are “major sources” of HAP emissions and produce pulp, perform bleaching, or manufacture paper or paperboard products. 1 According to results of EP A’s 2011 pulp and paper ICR, there are a total of 171 major source mills in the U.S. including:

 111 major source mills that carry out chemical wood pulping (kraft [97], sulfite [5], soda [1], or semi-chemical [8]),

 33 major source mills that carry out mech anical, groundwood, secondary fiber, and nonwood pulping, and

 27 major source mills that produce paper or paperboard (but do not produce pulp)

Some mills perform multiple operations (e.g., chemical pulping, bleaching, and papermaking; pulping and unbleached papermaking; etc.). For example, 72 of the major source

mills listed above bleach with chlorinated co mpounds, and 156 major source mills manufacture paper or paperboard products (including both inte grated and non-integrated paper mills). Mills that only purchase pre-consumer paper or paperboard stock products and convert them into other products (i.e., converting operations ) are not part of the Subpart S source category and are not affected by Subpart S. The North American I ndustry Classification System (NAICS) codes for respondents affected by the information collec tion include 32211 for pulp mills, 32212 for paper

1 As defined in 40 CFR Part 63, subpart A, “ Major source ” means any stationary sour ce or group of stationary sources located within a contiguous area and under comm on control that emits or has the potential to emit considering controls, in the aggr egate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous ai r pollutants, unless the Administrator es tablishes a lesser quantity, or in the case of radionuclides, different criteria fr om those specified in this sentence.6

mills, and 32213 for paperboard mills.

Of the 171 major sources, 114 are estimated to be affected by the Subpart S standards (including 111 chemical pulp mills, and 3 non-integrat ed paper mills that bleach with chlorinated compounds. Some major source mills (e.g., stand- alone mechanical pulp mills, non-integrated paper mills) are not affected because they do not have any emission sources with requirements under Subpart S.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded a nd/or reported is required by 40 CFR part 63, subpart S. Subpart S references 40 CFR part 63, subpart A for several general reporting and recordkeeping requirements that apply for all NESHAP.

A source must make the following reports:

Notification Reports

Requirement Regulation Reference (40 CFR part 63)

Construction/reconstruction 63.5

Construction or modification application 63.455(d)

Initial notifications 63.9(b)(2)

Anticipated startup 63.9(b)

Actual startup 63.9(b)(4)(v)

Performance test results 63.10(d)(2), 63.455(h)

Performance tests 63.7(b), 63.9(e)

Rescheduled initial performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Compliance status 63.9(h)

Physical or operational change 63.5(b)(4)

Periodic malfunction reports 63.455(g)

Source status report 63.10(e)(3)

Semiannual Control Strategy Update (thru 2006) 63.455(b)

Reports of malfunctions that result in an exceedances of the standard for the purpose of affirmative defense 63.4567

A source must maintain the following records:

Recordkeeping

Requirement Regulation Reference (40 CFR part 63)

Periods where the continuous monitoring system is inoperative 63.10(b)(2)

Records of malfunctions 63.454(g)

Emission test results and other data need ed to determine emissions 63.454(a)

All reports and notifications 63.10(b)

Record of applicability 63.10(b)(3)

Records for sources with continu ous monitoring systems 63.10(c)

Records are required to be retained for five years. Records must be kept onsite for the first two years, for the remaining three years records can be kept in a readily accessible off-site location. 63.454

Site Specific Inspection Plans for closed vent systems 63.454(b)

Records of paper machine new substance reviews 63.454(h)

Electronic Reporting

Currently, sources are using monitoring equipment that provides automated parameter data in an automated way, e.g., inlet and outlet concentrati ons when determining percent efficiency. Although personnel at the source still need to ev aluate the data, this type of monitoring equipment has significantly reduced the burden asso ciated with monitoring and recordkeeping. Modern pulp and paper facilities employ distributive controls on their manufacturing process and have integrated many of the compliance record keeping and reporting requirements into their systems. In addition, some regulatory agencies are setting up electronic reporting systems to allow sources to report electronically which is reducing the reporting burden. However, electronic reporting systems are stil l not widely used by the regulator y agencies. It is estimated that approximately 10 percent of the respondents cu rrently use electronic reporting. As part of the RTR amendments, respondents would be requ ired to report test results using EPA’s Electronic Reporting Tool (ERT) for test methods supported by the ERT. 2

2 As of 2011, Method 26A is the only test method re ferenced in subpart S that is included in the ERT.8

(ii) Respondent Activities

Respondent activities are as follows:

Respondent Activities

Read instructions.

Install, calibrate, certify, maintain, and operate Continuous Monitoring Systems (CMS) for each of the following affected units: 1.1 Non-Sulfite Pulping Process choice of: a. provide documentation that vent streams are introduced to the flame zone of a boiler, lime kiln, or recovery furnace, or b. provide documentation that the control incinerator is ope rating at a minimum level of 1600 F and 0.75 second residence time, or c. Performance test of control device using Method 308. 1.2. Sulfite Pulping Process - performance test of control device using test method 308. 2.1. Bleaching Process Vent Scrubber - performance test of scrubber or control device using test

Method 26A. 3.1 Non-Sulfite Pulping Wastewater Treatment a. performance test of condensate segregati on and control device using test method 305 or b. performance test of biotreatment unit using test Method 304. 3.2 Sulfite Pulping Process a. performance test of control device using test Method 305.

Conduct performance tests using appropriate Referen ce Test Methods 26A, 304, 305, 308, and repeat performance tests if necessary.

Conduct initial and annual inspections of enclosures, closed vent and wastewater conveyance systems using test Method 21.

Write the notifications and reports for: initial notification; compliance status; initial compliance strategy report; compliance strategy report update; semiannual summary report; continuous monitoring/exceedance reports; notifications of perfo rmance tests, construction/ reconstruction, and actual startup.

Enter information required to be recorded for cont inuous monitoring for opera ting parameters, periodic inspections (monthly visual and annual Method 21 ), malfunctions, personnel training and time for

audits.

Submit the required reports developing, acquiring, in stalling, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

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

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Adjust the existing ways to comply with any prev iously applicable instructions and requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.9

In addition to the respondent activities listed ab ove, EPA is including an estimate of the burden associated with performing an affirmative defens e. EPA is providing this as an illustrative example of the potential additi onal administrative burden a source may incur to assert in an Affirmative Defense in response to an action to en force the standards set fo rth in the applicable subpart. See section 6(b)(iv) of this ICR for details.

5. The Information Collected -- Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial and repeat performance tests.

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

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the review ing authority might inspect the source to determine whether the pollution control devi ces are properly installed and operated. Performance test reports are used by the Agen cy to discern a source’s initial and ongoing capability to comply with the emission standa rd, and note the operating conditions, such as, control device fire box temperatur e, gas and liquid flow rates, production volume, wood species, under which compliance was achieved. Data a nd records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

The records required by this regulation must be retained by the ow ner or operator for five years.

5(c) Small Entity Flexibility

Approximately 5 percent of the affected HAP major source faci lities are considered small business entities, defined as be ing independently owned and opera ted and not dominant in their field of operations. Due to technical consider ations involving the pr ocess operations and the types of control equipment employed, the recordk eeping and reporting requirements are the same for both small and large entities. The Agency considers these requirements the minimum needed to ensure compliance and, therefor e, cannot reduce them further for small entities. To the extent that larger businesses can use ec onomies of scale to reduce thei r burden, the overall burden will

be reduced.10

The recordkeeping and reporting requirements we re selected within the context of this specific subpart and the specific process equi pment and pollutants. The impact on small

businesses was accounted for in the regulation development. The requirements reflect the burden on small businesses. Even though, the re cordkeeping and reporting requirements are the same for small and larger businesse s. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. The Agency considers these requirements the minimum needed to ensure compliance and cannot reduce them further for

small businesses.

5(d) Collection Schedule

The specific frequency for each information co llection activity within this request is shown in Table 1: Annual Respondent Burden and Cost, NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S), (Proposed Amendments).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of indi vidual burdens for the recordkeeping and reporting requirements applicable to the industry fo r each of the subparts included in this ICR. The individual burdens are expre ssed under standardized headings be lieved to be consistent with the concept of burden under the Paperwork Reduction Act. Wher e appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, a nd a person is not required to respond to, a collection of information unless it displa ys a currently valid OMB control number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 52, 304 (Total Labor Hours from Table 1). These hours are based on Agency studies and backgrou nd documents from the development of the standards or test methods, Agency knowledge and experience with the NESHAP program, the previously approved ICR and any comments r eceived. No burden estimates are provided for new sources because no new facilities are expected to become affected sources during the 3-year period of this ICR.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $118.92 ($56.63 + 110%) Technical $97.78 ($46.56 + 110%)11

Clerical $48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics (BLS), December 2010, “Table 2. Civilian Workers, by occupational and industry group,” available at www.bls.gov/news.release/ecec.t02.htm . The rates are from column 1, “Total compensation.”

The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital and Operation and Maintenance Costs

Since no new continuous emission or paramete r monitors beyond those that may already be in place are used to comply w ith this rule, the only type of industry costs associated with the information collection activity in the standard s are labor costs and emission testing costs

described below.

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

Since this rule does not require any new c ontinuous emission mon itoring or electronic monitoring data submittal, total capital costs are zero. Continuous monitoring requirements are for parametric monitoring and these systems ar e already in place; ther efore, no new equipment would be required by the recordkeeping and reporti ng requirements. It is assumed that all mills will contract a testing company to provide sampling and analytical services for air and water

tests.

Based on EPA’s experience the testing methods required for this rule, the purchase of

service for each method is estimated below. These estimates include labor, materials, and analytical costs. The number of mills assumed to contract testing companies for compliance is presented in Table 1. For the entire industry, the number of tests required annually for demonstrating compliance and the associ ated cost are estimated as follows:

Method Count Cost, $ Total, $ Method 308 9 $14,000 $126,000 Method 26A 38 $10,000 $380,000 Method 304 3 $11,000 $ 33,000 Method 305 5 $16,000 $ 80,000 Method 21 74 $ 3,000 $222,000 TOTAL $841,000

Based on these estimates for testing costs and the number of mills assumed to perform compliance tests, the total annual cost to the industry is $841,000.

(iv) Affirmative Defense, Root Ca use Analysis, and Malfunction Costs

EPA’s estimate for a affirmative defense a nd root cause analysis is based on general experience to calculate the time and effort required of a source to review relevant data, interview12

plant employees, and reconstruct th e events prior to a malfunction in order to determine primary and contributing causes. The level of effort also includes time to produce and retain the report in

document form so that the source will have it available should EPA or state enforcement agencies ever request to review it.

To provide the public with an estimate of th e relative magnitude of the burden associated

with an assertion of the affirmative defens e position adopted by a source, EPA provides an administrative adjustment to this ICR that estim ates the costs of the no tification, recordkeeping and reporting requirements associated with the as sertion of the affirmative defense. EPA’s estimate for the required notific ation, reports and records, incl uding the root cause analysis, associated with a single incident totals approximately $3,258 and is based on the time and effort required of a source to review re levant data, interview plant em ployees, and document the events surrounding a malfunction that has ca used an exceedance of an emi ssion limit. The estimate also includes time to produce and retain the record s and reports for submission to EPA. EPA provides this illustrative estimate of this burden b ecause these costs are only incurred if there has

been a violation and a source chooses to take advantage of the affirmative defense.

Of the number of excess emission events reported by source operators, only a small number would be expected to result from a ma lfunction, and only a subset of excess emissions caused by malfunctions would result in the source choosing to assert the affirmative defense.

Thus we believe the number of instances in wh ich source operators might be expected to avail

themselves of the affirmative defense will be ex tremely small. For this reason, we estimate no

more than 2 or 3 such occurrences for all sour ces within a given categor y over the 3-year period covered by this ICR. For the purpose of this estimate, we are adding two (2) instances of affirmative defense. We expect to gather inform ation on such events in the future and will revise

this estimate as better information becomes available.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with anal ysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the resp ondents, periodic insp ection of sources of emissions, and the publication and dist ribution of collected information.

The average annual Agency cost during the th ree years of the ICR is estimated to be $310,058, see Table 2 in Section 6(e).13

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

Managerial $62.27 (GS-13, Step 5, $38.92 x 1.6) Technical $46.21 (GS-12, Step 1, $28.88 x 1.6) Clerical $25.01 (GS-6, Step 3, $15.63 x 1.6)

These rates are from the Office of Personne l Management (OPM) “2011 General Schedule” ( http://www.opm.gov/o ca/11tables/pdf/gs_h.pdf ) which excludes locality rates of pay. These rates were increased by 60 percent to include fringe benefits and overhead. Details upon which this estimate is based appear in Table 2: Annual Agency Burden and Cost. The only costs to the Agency are those costs associated with analys is of the reported information. EPA's overall compliance and enforcement program includes activiti es such as the examination of records and reports maintained by the respondents, periodic evaluation of sources of emissions, and the analysis, publication and distribut ion of collected information. The only Federal costs are user costs associated with analysis of the reported information. Pub lication and distribution of the information are part of the AFS program. Exam ination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA's overall compliance and enforcement program.

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

Based on our research for this ICR, th ere are approximately 114 existing sources currently subject to the standard, all of whic h will keep records and submit reports. It is estimated that no additional sources will become subj ect to the regulation in the next three years. The average number of respondents over the three-ye ar period of this ICR is 114. The number of total annual responses (calculated based on section 3.E in Table 1) is 522.

6(e) Bottom Line Burden Hours And Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor costs are $4,939,270. Details regardin g these estimates may be found in Table 1. Annual Respondent Burden and Cost, NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) attached. Furt hermore, the annual public reporting and recordkeeping burden for this collection of info rmation is estimated to average 100 hours per

response.

The total annual capital/ startup and O&M costs to the regulated entity are $841,000.

The cost calculations are detailed in Secti on 6(b)(iii), Capital/St artup vs. Operation and Maintenance (O&M) Costs.14

(ii) The Agency Tally

The average annual Agency burden and cost ove r next three years is estimated to be 6,874 labor hours at a cost of $310,058. See Ta ble 2. Annual Agency Burden and Cost, NESHAP for Pulp and Paper Production ( 40 CFR Part 63, Subpart S) attached.

6(f) Reasons for Change in Burden

This ICR is prepared for amendments to the Pulp and Paper Production NESAHP (40 CFR, Part 63, Subpart S). These amendments: (1 ) adjusted references to the Part 63 General Provisions (40 CFR, Part 63, Subpart A) to remove the startup, shutdown, and malfunction exemption; (2) added affirmative defense reportin g to subpart S; (3) added repeat (5-year) air emissions testing requirements for selected equi pment; and (4) increased the stringency of the kraft condensates standards. Adjustments for th ese amendments are reflected in Tables 1 and 2

of this ICR.

The number of affected mills changed becau se of: (1) continued consolidation and closures within the pulp and paper industry which reduced the number of mills previously affected by Subpart S; and (2) updates to the nu mber of affected major source mills based on EPA’s 2011 pulp and paper sector survey. Furthe r, the percentages of mills using various compliance options were refined based on the results of EPA’s 2011 pulp and paper sector

survey.

Costs per labor hour increased due to increases in labor rates. In addition, some rows in

the former Table 1 were consolidated to elim inate obsolete references to “MACT I” versus “MACT III” since subpart S covers MACT I a nd MACT III processes. This consolidation eliminates redundancy and the potential for double c ounting mills with both types of processes.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 100 hours per response. Bu rden means the total time, effort, or financial resources expended by persons to generate, maintai n, retain, or disclose or provide information to or for a Federal agency. This includes th e time needed to review instructions; develop, acquire, install, and utilize technology and syst ems for the purposes of collecting, validating, and verifying information, processing and maintain ing information, and disclosing and providing information; adjust the existing ways to comply with any previously appl icable instructions and requirements; train personnel to be able to respond to a collecti on of information; search data sources; complete and review the collection of informa tion; and transmit or otherwise disclose

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.15

To comment on the Agency’s need for this information the accuracy of the provided burden estimates, and any suggestions for mini mizing respondent burden, including through the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2007-0544, whic h is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday thro ugh Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air Docket is (202) 566-1927. An electronic vers ion of the public docket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public doc ket, and to access those documents in the public

docket that are available electroni cally. When in the system, sele ct “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Pl ease include Docket ID Number EPA-HQ-OAR2007-0544 and OMB Control Number 2060-NEW in any correspondence.

Part B of the Supporting Statement

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

information.Table 1. Annual Respondent Burden and Cost - NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) - Proposed Amendments(A) (B) (C) (D) (E) (F) (G) (H)Burden ItemPerson-hoursperoccurrenceNumber ofoccurrencesper yearEmissionsTesting CostPerOccurrencePerson-hoursperrespondentper year(C=AxB)Number ofrespondents peryear (a) NoteTechnicalpersonhours peryear(E=CxD)Managementperson-hoursper year(F=Ex0.05)Clericalpersonhours peryear(G=Ex0.1)Total costper year1. ApplicationsNot applicable2. Surveys and StudiesNot applicable3. Reporting RequirementsA. Read and Understand Rule Requirements301 $0 30171b,d 5,130 257 513 $557,110B. Required Activities1.1) Pulping processes (Non-Sulfite)a. Provide documentation that vent streams areintroduced to the flame zone of a boiler, lime kiln, or241 $0 245c,e 120 6 12 $13,032b. Provide documentation that the control incinerator isoperating at a minimum level of 1600 F and 0.75 secresidence time, or601 $0 601c,f 60 3 6 $6,516c. Performance test of control device - test method 308241 $14,000 241c,f,g,n 24 1 2 $2,6061.2) Pulping Processes (Sulfite)241 $14,000 241c,g,i,n 24 1 2 $2,606Performance test of control device - test method 3082.1) Bleaching process vent scrubberPerformance test of scrubber or control device - testmethod 26A241 $10,000 245c,g,j,n 120 6 12 $13,0323.1) Pulping wastewater treatment (Non-Sulfite)a. Performance test of condensate segregation andcontrol device (test method 305), or241 $16,000 244c,h,k,n 96 5 10 $10,425b. Performance test of biotreatment unit - test method 304241 $11,000 243c,h,l,n 72 4 7 $7,8193.2) Pulping wastewater treatment (Sulfite)Performance test of control device - test method 305241 $16,000 241c,h,m,n 24 1 2 $2,6064.1) Repeat of performance test (5-yr intervals)a. Test method 308 - pulping241 $14,000 247g,n,t 168 8 17 $18,245b. Test method 26A - bleaching241 $10,000 2433g,n,t 792 40 79 $86,0104.2) Inspection of enclosures, closed vent, wastewaterconveyance systema. Initial/Annual inspection - test method 2181 $3,000 874o 592 30 59 $64,290b. Monthly visual inspection412 $0 48111o 5,328 266 533 $578,612C. Create InformationIncluded in 3.BD. Gather InformationIncluded in 3.BE. Report Preparation1) Initial Notification Report (<45 days after promulgation)161 $0 160c,d 0 0 0 $02) Notification of compliance status161 $0 160c,d 0 0 0 $03) Initial Compliance Strategy Report401 $0 400c,p 0 0 0 $04) Compliance Strategy Report Update161 $0 160p 0 0 0 $05) Semi-annual summary report162 $0 32114d 3,648 182 365 $396,1676) Continuous monitoring/Exceedance reports242 $0 4817q 816 41 82 $88,6167) Notification of performance test (>75 days before test)41 $0 4129c,r 516 26 52 $56,0378) Notification of construction/reconstruction (>180 daysbeforehand)41 $0 417c,s 68 3 7 $7,3859) Notification of actual startup (<150 days after startup)41 $0 417c,s 68 3 7 $7,38510) Affirmative defense301 $0 30228u 6,840 342 684 $742,8134. Recordkeeping RequirementsA. Read InstructionsIncluded in 3.AB. Plan ActivitiesIncluded in 3.BC. Implement ActivitiesIncluded in 3.BD. Develop Record System401 $0 40114c,d,v 4,560 228 456 $495,208E. Record informationRecords of continuous monitoring for operating parameters252 $0 104114d 11,856 593 1,186 $1,287,542Table 1, Page 1 of 2(A) (B) (C) (D) (E) (F) (G) (H)Burden ItemPerson-hoursperoccurrenceNumber ofoccurrencesper yearEmissionsTesting CostPerOccurrencePerson-hoursperrespondentper year(C=AxB)Number ofrespondents peryear (a) NoteTechnicalpersonhours peryear(E=CxD)Managementperson-hoursper year(F=Ex0.05)Clericalpersonhours peryear(G=Ex0.1)Total costper yearRecords of periodic inspections (monthly visual inspectionsand annual method 21)Included in 3.BRecord of malfunctions212 $0 24114d 2,736 137 274 $297,125F. Personnel TrainingNot applicableG. Time for audits82 $0 16114d 1,824 91 182 $198,083Total:45,482 2,274 4,548 $4,939,270TOTAL INDUSTRY BURDEN SUMMARY:Total annual responses (based on 3.E) 522Total annual labor hours 52,304Average hours per response 100Annual costs in dollars $4,939,270Footnotesa Values are rounded up to the nearest whole number.b MACT I Mills include kraft, sulfite, soda, and semi-chemical operations. MACT III Mills include mechanical, non-wood, and secondary fiber operations; along with papermaking at all types of mills.Only major sources are subject to Subpart S.c One-time activity. In out years, after initial compliance date, assume that 5% of mills affected as a result of unexplainedexceedances.d Performed by all major source mills. (111 major MACT I Category Mills, 60 major stand-alone MACT III category mills)All MACT I category mills are affected by this rule. The only MACT III category mills affected by this rule are those bleaching with chlorinated compounds (3 mills).Total number of mills affected by this rule is 111 + 3 = 114e Approximately 85% of mills use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non-sulfite pulping mills. (85% of 106 = 90)f Approximately 15% of mills use incineration for pulping lines (assuming half of these provide acceptable design specs (8),and half conduct performance tests (8))g Estimate includes test plan, test report, and parametric monitoring setup. Method 308 tests for pulping lines and method 26A tests for bleaching lines.h Estimate includes test plan, test report, and parametric monitoring setup. Method 304 and 305 are for wastewater streams.i Assume that all 5 sulfite pulping mills will conduct performance tests.j 69 MACT I and 3 MACT III category mills have bleaching lines that use chlorinated compounds.k Estimated that each kraft mill has one pulping wastewater control device, with 60% of mills using stream strippers (60% of 97 = 58). Per footnote "c," 5% of 58= 3.Facilities with steam strippers are assumed to perform initial condensate segregation and performance tests.l Approximately 40% of kraft mills use biotreatment. (40% of 97 = 39) Per footnote "c," 5% of 39 = 2.Facilities with biotreatment control will perform initial performance tests.m Assume sulfite mills will monitor gas scrubber parameters and use Water-9 Model for emission estimates.n Assumed that 15% of performance tests are failed and need to be repeated.o Initial and annual activity. Assumed that EPA is notified each year of the testing. Assumed 2/3 of all MACT I mills have positive pressure points in their vent systemsand will have to test using method 21 (2/3 x 111 = 74). Monthly visual inspections are to be conducted by chemical pulp mills (111).p The requirement for a compliance strategy report is now obsolete (required before 2006 only).q Assumed that 15% of all affected mills during any one quarter will be required to submit an exceedance report in addition tothe summary report. (15% of 115 = 17)r EPA must be notified of all tests including out-year repeat performance tests and tests conducted at 5-year intervals.s Assumed 15% of all affected mills conduct construction or reconstruction per year. (15% of 114 = 17)t Kraft/soda/semichemical mills using compliance options requiring testing (8 mills) are likely to have 3 emission points that would require 5-year repeat testing (LVHC, HVLC, and stripper off gases).Sulfite mills (5) are likely to have 1 emission point to be tested. Total no. M308 tests = [(8 mills x 3 points) + (5 millsx 1 point)] x 1.15 = 33. Annual no. of 5-year repeat M308 tests = 33/5 = 7 tests.Mills bleaching with chlorinated compounds (72 mills) are likely to have two emission points requiring M26A testing. Totalno. of M26A tests = (72 x 2) x 1.15 = 166. Annual no. of 5-yrrepeat M26A tests = 166/5=33 tests.u Assumes all affected mills (114) will have 2 malfunctions per year requiring affirmative defense review.v For this amendment ICR, includes time for reevaluating previously developed SSM-record system at 114 mills according to rulechanges. [This time may be eliminated in future 3-year ICR renewals.]Table 1, Page 2 of 2Table 2. Annual Agency Burden and Cost of the NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) - Proposed Amedments(A) (B) (C) (D) (E) (F)Burden ItemNumber ofRespondentsPer Year (a) NoteEPA HoursPerRespondentTech HoursPer Year(CxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear1. Applications Not applicable2. Surveys and Studies Not applicable3. Reporting RequirementsA. Read and Understand Rule Requirements171a 6 1026 51 103 $53,170B. Required ActivitiesInitial performance tests:1.1) Pulping processes (Non-Sulfite) - Choice of:a. Review Documentation that vent streams are introduced to theflame zone of a boiler, lime kiln, or recovery furnace, or5b,c 8 40 2 4 $2,073b. Review documentation that the control incinerator is operatingat a level of at least 1600 F and 0.75 sec residence time, or1b,d 8 8 0 1 $415c. Review performance test of control device1b,d,i 8 8 0 1 $4151.2) Pulping Processes (Sulfite)1b,e,i 8 8 0 1 $415-Revew performance test of control device2.1) Bleaching process vent scrubber-Review performance test of control device5b,f,i 8 40 2 4 $2,0733.1) Pulping wastewater treatment system (Non-Sulfite) - Choice of:a. Review performance test of condensate segregation andcontrol device, or4b,g,i 8 32 2 3 $1,658b. Review performance test of biotreatment unit3b,h,i 8 24 1 2 $1,2443.2) Pulping wastewater treatment (Sulfite)-Review performance test of control device1b,e,i 8 8 0 1 $4154.1) Review repeat performance tests (5-yr intervals)a. Test method 308 - pulping7i,q 8 56 3 6 $2,902b. Test method 26A - bleaching33i,q 8 264 1 1 $12,2864.2) Inspection of enclosures, closed vent, wastewater conveyancesystema. Initial/Annual inspection - test method 2174j 0 0 0 0 $0b. Monthly visual inspection111j 0 0 0 0 $0C. Create InformationIncluded in 3.BD. Gather InformationIncluded in 3.BE. Report PreparationReview Initial Notification Report0b 4 0 0 0 $0Review Notification of compliance status0b 4 0 0 0 $0Review initial compliance strategy report0b,p 4 0 0 0 $0Review compliance strategy report update0b,p 4 0 0 0 $0Review Semi-annual summary report114k 2 228 11 23 $11,816Review Continuous monitoring/Exceedance reports17m 8 136 7 14 $7,048Review Notification of performance test129b,n 8 1032 52 103 $53,481Review Notification of construction/reconstruction17b,o 4 68 3 7 $3,524Review Notification of actual startup17b,o 4 68 3 7 $3,524Review Affirmative Defense228r 8 1824 91 182 $94,5244. Recordkeeping RequirementsA. Read InstructionsIncluded in 3.AB. Plan ActivitiesIncluded in 3.BC. Implement ActivitiesIncluded in 3.BD. Develop Record System114b,k 0 0 0 0 $0E. Record informationReview records of monitoring parameters114k 1 114 6 11 $5,908Table 2, Page 1 of 2(A) (B) (C) (D) (E) (F)Burden ItemNumber ofRespondentsPer Year (a) NoteEPA HoursPerRespondentTech HoursPer Year(CxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYearReview records of periodic inspections (monthly visual inspectionsand annual method 21)Included in 3.BReview records of malfunctions114k 1 114 6 11 $5,908F. Personnel TrainingNot applicableG. Time for audits114k 8 912 46 91 $47,262Total: 6010 288 576 $310,058TOTAL FEDERAL GOVERNMENT BURDEN SUMMARY:Total hours per year 6,874Annual costs in dollars $310,058Footnotesa Values are rounded up to nearest whole number. There are 171 majour source mills (111 MACT mills producing chemical pulp, and 60 stand-alone MACT III category mills).All MACT I category mills are afftected by this rule. The only MACT III category mills affected by this rule are those bleaching with chlorinated compounds (3 mills).Total number of mills affected by this rule is 111 + 3 = 114b One-time activity. After initial compliance date, assume that 5% of mills affected as a result of unexplained exceedances.c Approximately 85% of mills use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non-sulfite pulping mills. (85% of 106 = 90)d Approximately 15% of mills use incineration for pulping lines (assuming half of these provide acceptable design specs (8), and half conduct performance tests (8))e Assume that all 5 sulfite pulping mills will conduct performance tests.f 69 MACT I and 3 MACT III category mills have bleaching lines that use chlorinated compounds.g Estimated that each kraft mill has one pulping wastewater control device, with 60% of mills using stream strippers (60% of 97 = 58).Facilities installing new biotreatment control will perform initial performance tests.h Approximately 40% of kraft mills use biotreatment. (40% of 97 = 39)i Assumed that 15% of performance tests are failed and need to be repeated.j Initial and annual activity. Assumed that EPA is notified each year of the testing. Assumed 2/3 of all MACT I mills have positive pressure points in their vent systemsand will have to test using method 21 (2/3 x 111 = 74). Monthly visual inspections are to be conducted by chemical pulp mills (111).k Performed for all affected mills. (114)l Performed for all kraft mills. (97)m Assumed that 15% of all mills during any one quarter will be required to submit an exceedance report in addition to the summary report. (15% of 114 = 17)n EPA must be notified of all tests including out-year repeat performance tests and tests conducted at 5-year intervals.o Assumed 15% of mills conduct construction or reconstruction per year. (15% of 114 = 17)p The requirement for a compliance strategy report is now obsolete (required before 2006 only).q Kraft/soda/semichemical mills using compliance options requiring testing (8 mills) are likely to have 3 emission points thatwould require 5-year repeat testing (LVHC, HVLC, and stripper off gases).Sulfite mills (5) are likely to have 1 emission point to be tested. Total no. M308 tests = [(8 mills x 3 points) + (5 millsx 1 point)] x 1.15 = 33. Annual no. of 5-year repeat M308 tests = 33/5 = 7 tests.Mills bleaching with chlorinated compounds (72 mills) are likely to have two emission points requiring M26A testing. Totalno. of M26A tests = (72 x 2) x 1.15 = 166. Annual no. of 5-yrrepeat M26A tests = 166/5=33 tests.r Assumes all affected mills (114) will have 2 malfunctions per year requiring affirmative defense review.Table 2, Page 2 of 2