SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and 

Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone 

Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal), EPA ICR Number 1805.06, 

OMB Control Number 2060-0377

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP), for chemical 

recovery combustion sources at kraft, soda, sulfite, and stand-alone semichemical pulp mills were 

published at 40 CFR part 63, subpart MM, proposed on April 15, 1998, and promulgated on 

January 12, 2001. These regulations apply to existing and new chemical recovery combustion 

sources at kraft, soda, sulfite, and stand-alone semichemical pulp mills where the total hazardous 

air pollutants (HAPs) emitted are greater than or equal to 10 tons per year of any one HAP; or 

where the total HAPs emitted are greater than or equal to 25 tons per year of any combination of 

HAPs. New facilities include those that commenced construction or reconstruction after the date 

of the proposal. This information is being collected to ensure compliance with 40 CFR part 63, 

subpart MM.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports. In addition, owners or operators are required to maintain records of the 

occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected 

facility, or any period during which the monitoring system is inoperative. These notifications, 

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

to NESHAP standards.

Any owner or operator subject to the provisions of this part will maintain a file of these 

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

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

the event that there is no such delegated authority, the reports are sent directly to the United States 

Environmental Protection Agency regional office.

Approximately 111 sources are currently subject to the standard. There are 89 kraft mills, 

9 kraft and semichemical mills, 1 kraft and sulfite mill, 7 stand-alone semichemical mills, 4 sulfite 

mills, and 1 soda mill. It is estimated that no additional sources will become subject to the 

regulation; however, one of the existing facilities will be engaged in a modification each year over 

the three-year period of this rule.
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There are approximately 111 chemical recovery combustion sources at kraft, soda, sulfite, 

and stand-alone semichemical pulp mills in the United States. None of the 111 facilities in the 

United States are owned by state, local, tribal or the Federal government. They are owned and 

operated by privately owned for-profit businesses. You can find the burden to the “Affected 

Public” listed below in Table 1a, and 1b: Annual Respondent Burden and Cost - NESHAP for 

Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical 

Pulp Mills (40 CFR Part 63, Subpart MM). The Federal government burden does not include work 

performed by Federal employees. The burden refers only to work performed by contractors, 

which could be found listed below in Table 2: Average Annual EPA Burden - NESHAP for

Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical 

Pulp Mills (40 CFR Part 63, Subpart MM).

In the development of the ICR, we addressed the Office of Management and Budget (OMB) 

“Terms of Clearance (TOC)” on the active ICR. The TOC are as follows:

When this ICR is renewed, EPA should review the respondent 

burden, universe, labor rates, and capital costs, and ensure these 

estimates have been updated.

EPA has addressed each item of concern in the TOC. The respondent burden, universe, 

labor rates, and capital cost, have been thoroughly checked and all estimates updated.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP 

and shall require the maximum degree of emission reduction. In addition, section 114(a) states 

that the Administrator may require any owner or operator subject to any requirement of this Act to:

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

install, use, and maintain such monitoring equipment, and use such 

audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); and 

(G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, acetaldehyde, benzene formaldehyde, hydrochloric acid 

(HCI), methanol, methyl ethyl ketone, and toluene hazardous air pollutant (HAP) emissions from 
3

chemical recovery combustion sources at kraft, soda, sulfite, and stand-alone semichemical pulp 

mill cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR 

part 63, subpart MM.

2(b) Practical Utility/Users of the Data

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

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

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

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

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

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

parameters under which compliance was achieved may be recorded and used to determine 

compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

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

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

met. The performance test may also be observed.

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 the control equipment in compliance with the regulation.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart 

MM.

3(a) Non-duplication

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

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

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

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

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

exists.

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

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

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

published in the Federal Register.

3(c) Consultations
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The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

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

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

comment on the burden associated with the standard as it was being developed. In developing this 

ICR, we contacted the American Forest and Paper Association (AF&PA) at (202) 463-2700, and 

the America Wood Council at (202) 463-2766.

It is our policy to respond after a thorough review of comments received since the last ICR 

renewal as well as those submitted in response to the First Federal Register Notice.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities 

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

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

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

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

detecting violations would be less likely.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to the 

standards. EPA believes that the five-year records retention requirement is consistent with the Part 

70 permit program and the five-year statute of limitations on which the permit program is based. 

The retention of records for five years allows EPA to establish the compliance history of a source, 

any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA 

has found that the most flagrant violators have violations extending beyond the five years. In 

addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B -

Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 
5

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/SIC Codes

The respondents to the recordkeeping and reporting requirements are chemical recovery

combustion sources at kraft, soda, sulfite, and stand-alone semichemical pulp mills. The United 

States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, 

which corresponds to The North American Industry Classification System (NAICS) codes, are 

listed below for source category description.

Standard (40 CFR Part 63, Subpart MM) SIC Codes NAICS Codes

Pulp Mills 2611 32211

Paper Mills 2621 32212

Paperboard Mills 2631 32213

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

In this ICR, all the data recorded or reported is required by 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).

A source must make the following reports:

Notification Reports

Initial notifications, reports of startups, shutdowns, 

malfunctions, construction/reconstruction, and modification

63.5, 63.9(b), 63.10(d)(5), 

63.867(a)

Notification and report of performance test and results 63.7(b), 63.9(e), 63.10(d)(2), 

63.867(a)

Notification of initial continuous monitoring system (CMS)/ 

continuous opacity monitoring system (COMS) demonstration

63.9(g), 63.867(a)

Notification and report of compliance status 63.9(h), 63.867(b)(1)-(2)

Reporting results of CMS/COMS demonstration 63.10(e)(2), 63.867(a)
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Notification Reports

Excess emissions reports (quarterly and semiannual) 63.10(e)(3), 63.867(c)

Certification that a non-direct contact evaporator (NDCE) 

recovery furnace equipped with a dry electrostatic precipitation 

(ESP) system is used to comply with a gaseous organic HAP 

standard in 63.862(c)(1)

63.866(c)(6)

A source must keep the following records:

Recordkeeping

Five years retention of records 63.10(b)(1) 

Startup, shutdown, and malfunction plan 63.6(e)(3), 63.866(a)

Records of startup, shutdown, and malfunction 63.6(e)(3)(iii)-(iv), 

63.10(b)(2)(i)-(v)

Records of performance tests 63.10(b)(2)(viii)

Documentation supporting initial notifications and notification 

of compliance status

63.10(b)(2)(xiv)

Records of exceedances requiring corrective action and 

violations

63.866(b)

Black liquor solids firing rates for all recovery furnaces and 

semichemical combustion units

63.866(c)(1)

Lime production rates for all lime kilns 63.866(c)(2)

All parameter monitoring data required in section 63.864 63.866(c)(3)

Supporting calculations for compliance determinations made 

under section 63.865(a) through (e)

63.866(c)(4)

Compliant monitoring parameter ranges established for each 

affected source

63.866(c)(5)

Certification that an NDCE recovery furnace equipped with a 

dry ESP system is used to comply with the gaseous organic 

HAP standard in section 63.862(1)

63.866(c)(6)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must continue to evaluate the data, 

internal automation has significantly reduced the burden associated with monitoring and 

recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

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

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

reporting.
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(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply

pressure for wet scrubber.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 

5, 17, 25A, 29, or 308 as applicable, and repeat performance tests if necessary.

Write the notification and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

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

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way e.g., continuous parameter monitoring system. Although personnel at the source 

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

burden associated with monitoring and recordkeeping.

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

Management

5(a) Agency Activities

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

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).
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5(b) Collection Methodology and Management

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

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

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

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

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

enforcement programs.

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

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

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

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

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

edit, store, retrieve and analyze the data.

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

years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

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

overall burden will be reduced.

5(d) Collection Schedule

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

in Table 1a: One-time Annual Respondent Burden and Cost, NESHAP for Chemical Recovery

Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR 

Part 63, Subpart MM), and in Table 1b: Recurrent Annual Respondent Burden and Cost, NESHAP 

for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone 

Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1a and 1b documents the computation of individual burdens for the recordkeeping 

and reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

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

major assumptions have been identified. Responses to this information collection are mandatory.
9

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 126,207 (Total Labor Hours from Tables 1a, and 1b). 

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

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

This ICR uses the following labor rates:

Managerial $118.92 ($56.63 + 110%) 

Technical $97.78 ($46.56 + 110%)

Clerical $48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 

2010, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from 

column 1, "Total Compensation." The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

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

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

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device 1

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost,

(B X C)

(E)

Annual 

O&M Costs 

for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

COMS $41,000 0 $0 $8,000 89 $712,000

CPMS $0 0 $0 $0 0 $0

Total $41,000 0 $0 $8,000 89 $712,000

1 No costs are included for continuous opacity monitoring system (COMS) installed for recovery furnaces or 

for continuous parameter monitoring systems (CPMS) because the monitoring equipment is already required for 

compliance with the NSPS for Kraft Pulp Mills (40 CFR Subpart BB).
10

The total capital/startup costs for this ICR is $0. This is the total of column D in the above 

table.

The total operation and maintenance (O&M) cost is $712,000 for photocopying, and 

postage. This is the total of column G.

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

over the next three years of the ICR is estimated to be $712,000.

6(c) Estimating Agency Burden and Cost

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

information. The EPA compliance and enforcement program includes activities such as: the 

examination of records maintained by the respondents; periodic inspection of sources of 

emissions; and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$17,585.

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

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

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

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011 General 

Schedule” which excludes locality rates of pay. The rates have been increased by 60 percent to 

account for the benefit packages available to government employees. Details upon which this 

estimate is based appear in Table 2: Average Annual EPA Burden, NESHAP for Chemical 

Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills

(40 CFR Part 63, Subpart MM) (Renewal).

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

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

111 respondents will be subject to the standard. It is estimated that no additional new sources will 

become subject to the rule. The overall average number of respondents, as shown in the table 

below is 111 per year. 

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.
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Number of Respondents

Year

(A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(D)

Number of Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 111 0 1 111

2 1 111 0 1 111

3 1 111 0 1 111

Average 1 111 0 1 111

1 The new respondent includes sources with constructed, reconstructed, and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 111.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of 

Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total 

Annual 

Responses

E=(BxC)+D

Notification of construction/reconstruction 1 1 0 1

Notification of actual startup 1 1 0 1

Notification of applicability of standards 1 1 0 1

Notification of initial performance test 1 1 0 1

Notification of performance evaluation 1 1 0 1

Notification of compliance status 1 1 0 1

Quarterly report of monitoring exceedances 

and periods of noncompliance

6 4 0 24

Semiannual report of no exceedances 105 2 0 210

Total 240

The number of Total Annual Responses is 240.

The total annual labor costs are $11,918,524. Details regarding these estimates may be 

found in Table 1a and 1b: Annual Industry Burden and Cost - NESHAP for Chemical Recovery

Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR 

Part 63, Subpart MM) (Renewal).

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor costs are $11,918,524. Details regarding these estimates may be 

found in Table 1a. One-Time Annual Respondent Burden and Cost: NESHAP for Chemical 

Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills 

(40 CFR Part 63, Subpart MM) (Renewal), and Table 1b. Recurrent Annual Respondent Burden 

and Cost: NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and 

Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal).

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

information is estimated to average 526 hours per response.

The total annual capital/startup and operation and maintenance (O&M) costs to the 

regulated entity are $721,000. 

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 476

-labor hours at a cost of $17,585. See Table 2. Annual Agency Burden and Cost: NESHAP for

Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical 

Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal).

6(f) Reasons for Change in Burden

The adjusted decrease in burden from the most recently approved ICR is due to a more 

accurate estimate of existing and anticipated new sources. After consulting the Office of Air 

Quality Planning and Standards (OAQPS) and trade associations, our data indicates that there are 

approximately 111 sources subject to the rule, as compared with the active ICR that shows 130

sources. No new facilities are expected to be constructed over the next three years of this ICR. 

The decline in the number of sources is due mainly to plant closures. This industry is undergoing 

widespread consolidation and corporate restructuring. However, there is an increase in cost per 

labor hours due to the updated labor rates.

Because there are no new sources with reporting requirements, no capital/startup costs are 

incurred. The only cost that is incurred is for the operation and maintenance (O&M) of the 

monitoring equipment.

6(g) Burden Statement

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

estimated to average 526 hours per response. Burden means the total time, effort, or financial 

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

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

install, and utilize technology and systems for the purposes of collecting, validating, and verifying 
13

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

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

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

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

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

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

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

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

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

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

ID Number EPA-HQ-OECA-2011-0209. An electronic version of the public docket is available at 

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

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

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

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

documents are also available for public viewing at the Enforcement and Compliance Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, N.W., Washington, D.C. The EPA Docket Center Public Reading Room is 

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

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

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

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

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

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0209 and 

OMB Control Number 2060-0377 in any correspondence.

Part B of the Supporting Statement

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

information.
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Table 1a: One-Time Annual Respondent Burden and Cost – NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, 

Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM)

Burden item

(A)

Person

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

 A. Read instructions c2 1 2 1 2 0.1 0.2 $217.20

 B. Required activities See 3E

 C. Create information See 3E

 D. Gather existing information See 3E

 E. Write Report

 Notification of construction/reconstruction c , d 2 1 2 1 2 0.1 0.2 $217.20

 Notification of actual startup c, d 2 1 2 1 2 0.1 0.2 $217.20

 Notification of applicability of standard c, d 2 1 2 1 2 0.1 0.2 $217.20

 Notification of initial performance test c, d2 1 2 1 2 0.1 0.2 $217.20

 Notification of performance evaluation c, d 2 1 2 1 2 0.1 0.2 $217.20

 Notification of compliance status c, e 80 1 80 1 80 4 8 $8,688.16

Subtotal for Reporting Requirements 105.8

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities See 4D

 C. Implement Activities See 4D

 D. Develop record system c, f 40 1 40 1 40 2 4 $4,344.08

 E. Develop startup, shutdown, and

 malfunction plans c, g 

100 1 100 1 100 5 10 $10,860.20

 F. Time to enter information

 - Records and documentation of supporting

 calculations for compliance determinations c, h

8 1 8 1 8 0.4 0.8 $868.82

 - Record of compliant monitoring parameter

 ranges c 

2 1 2 1 2 0.1 0.2 $217.20
15

Burden item

(A)

Person

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Cost, $ b

 - Records certifying that an NDCE recovery

 furnace equipped with a dry ESP system is

 used to comply with the gaseous organic

 HAP standard for kraft and soda recovery

 furnaces c, i

2 1 2 1 2 0.1 0.2 $217.20

G. Time to train personnel c, j 40 1 40 1 40 2 4 $4,341.68

Subtotal for Recordkeeping Requirements 220.08

Subtotals Labor Burden and cost 284 14.2 28.4 $30,840.54

TOTAL LABOR BURDEN AND COST 

(rounded)

326.6

327(rounded)

$30,840

Assumptions:

a

 We have assumed that the average number of existing sources subject to the rule will be 111. There will be no additional new sources per year that will become subject

to the rule, and one affected facility will be engaged in some kind of modification over the three-year period of this ICR. 

b This ICR uses the following labor rates: $118.92 per hour for Executive, Administrative, and Managerial labor; $97.78 per hour for Technical labor, and $48.76 per hour

for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December, 2010, Table 2. Civilian Workers, by Occupational

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

those employed by private industry.

c

 We have assumed that one existing kraft pulp mills will install one new recovery furnace and smelt dissolving tank (SDT) each year.

d

 We have assumed that it will take respondent 2 hours once per year to complete report.

e

 We have assumed that it will take respondent 80 hours once per year to write the notification of compliance status report.

f

 We have assumed that it will take respondent 40 hours to develop a record system for recording parameter monitoring information.

g

 We have assumed that it will take respondent 80 hours once per year to draft the startup, shutdown, and malfunction plan, and an additional 20 hours to review/revisions, for 

a total of 100 hours.

h

 We have assumed that it will take respondent eight hours (1 day) each year to enter records and documentation of supporting calculation for compliance determinations.

i

 We have assumed that one existing kraft and soda pulp mill will install new recovery furnaces. Based on current industry trends, the new furnace is expected to be non-direct 

contact evaporator (NDCE) recovery furnaces equipped with a dry electrostatic precipitator (ESP) system.

j

 We have assumed that it will take respondent 40 hours (1 week) once per year to train personnel.
16

Table 1b: Recurrent Annual Respondent Burden and Cost – NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, 

Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM)

Burden item

(A)

Person

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

a. Read instructions See 3E

b. Required activities See 3E

c. Create information See 3E

d. Gather existing information See 3E

e. Write report

 Excess emissions report

 Quarterly report of monitoring

 exceedances and periods of 

 noncompliance c

16 4 64 6 384 19.2 38.4 $41,703.16

 Semiannual report of no exceedances d8 2 16 105 1,680 84 168 $182,451.36

Subtotal for Reporting Requirements 2,373.6

4. Recordkeeping requirements

a. Read instructions See 4E

 b. Plan activities See 4E

 c. Implement activities See 4E

 d. Develop record system See 4E

 e. Time to enter information

 Records of startup, shutdown, and 

 malfunction e 

1.5 52 78 111 8,658 432.9 865.8 $940,276.12

 Records of black liquor solids firing

 rates for recovery furnaces and 

 semichemical combustion units e

1.5 52 78 111 8,658 432.9 865.8 $940,276.12

 Records of lime production for lime

 kilns f

1.5 52 78 89 6,942 347.1 694.2 $753,915.08

 Records of CMS data 

 Record continuously monitored g

 parameters (per shift)

0.5 1,050 525 111 58,275 2,913.75 5,827.5 $6,328,781.55
17

Burden item

(A)

Person

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Cost, $ b

 Compile monthly data h16 12 192 111 21,312 1,065.6 2,131.2 $2,314,525.82

 Enter/verify information for quarterly/

 semiannual reports i

8 2 16 111 1,776 88.8 177.6 $192,877.16

 F. Time to train personnel N/A

 G. Time for refresher training for personnel j16 1 16 111 1,776 88.8 177.6 $192,877.16

Subtotal for Recordkeeping Requirements 123,506.55

Subtotals Labor Burden and cost 109,461 5,473.05 10,946.1 $11,887,683.53

TOTAL LABOR BURDEN AND COST

(rounded)

125,880.15

125,880 (rounded)

$11,887,683

Assumptions:

a

 We have assumed that the average number of existing sources subject to the rule will be 111. There will be no additional new sources per year that will become subject

to the rule over the three-year period of this ICR. 

b This ICR uses the following labor rates: $118.92 per hour for Executive, Administrative, and Managerial labor; $97.78 per hour for Technical labor, and $48.76 per hour

for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December, 2010, Table 2. Civilian Workers, by Occupational

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

those employed by private industry.

c

 We have assumed that five percent of respondents will each take 16 hours four times per year to complete reports of monitoring exceedances and periods of noncompliance.

d

 We have assumed that 95 percent of respondents will each take 8 hours two times per year to write reports of no exceedances.

e

 We have assumed that each respondent will take 1.5 hours 52 times per year to accomplish the task.

f

 We have assumed that each of the respondents of kraft pulp mills will take 1.5 hours 52 times per week to enter the lime production rates information. All of the 89 existing 

kraft pulp mills have lime kilns.

g

 We have assumed that each respondent will take 0.5 hours 1,050 times per year to record continuously monitoring parameters.

h

 We have assumed that each respondent will take 16 hours once per month to compile data.

i

 We have assumed that each respondent will take 8 hours two times per year to verify information for reports.

j

 We have assumed that it will take each respondent 16 hours to provide refresher training for personnel.
18

Total Annual Respondent Burden and Cost – NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and 

Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM)

Annual Burden to Industry Total Burden Hours 

Reporting

Total Burden Hours 

Recordkeeping

Total Burden 

Hours

Total Costs, $

Table 1a: One-Time Annual Respondent 

Burden and Cost

105.8 220.8 326.6 $30,840.54

Table 1b: Recurrent Annual Respondent 

Burden and Cost

2,373.6 123,506.55 125,880.15 $11,887,683.53

TOTAL LABOR BURDEN AND COST 

(rounded)

2,479.4 123,727.35 126,206.75

(rounded) 126,207

 $11,918,524.07

(rounded) $11,918,524
19

Table 2: Average Annual EPA Burden - NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and 

Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM)

Activity

(A)

EPA 

personhours per

occurrence

(B)

No. of

occurrences

per plant

per year

(C)

EPA 

person

hours per

plant per 

year

(C=AxB)

(D)

Plants 

per 

year b 

(E)

Technical

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours per 

year

(Ex0.1)

(H)

Cost, $ a

Report review

 Notification of construction/reconstruction c2 1 2 1 2 0.1 0.2 $103.65

 Notification of actual startup c2 1 2 1 2 0.1 0.2 $103.65

 Notification of applicability c2 1 2 1 2 0.1 0.2 $103.65

 Notification of initial performance test c2 1 2 1 2 0.1 0.2 $103.65

 Notification of performance evaluation c2 1 2 1 2 0.1 0.2 $103.65

 Review of notification of compliance status d4 1 4 1 2 0.1 0.2 $103.65

 Review of excess emissions report

 Quarterly reports of monitoring

 exceedances and periods of noncompliance e

8 4 32 6 192 9.6 19.2 $6.079.98

 Semiannual reports of no exceedances f2 2 4 105 210 10.5 21 $10,883.14

Subtotals Labor Burden and cost 414 20.7 41.4 $17,585.02

TOTAL ANNUAL BURDEN AND COST 

(rounded)

476.1

476 (rounded)

$17,585

Assumptions:

a

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

Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.99 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are 

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

 

b

 We have assumed that the average number of existing sources subject to the rule will be 111. There will be no additional new sources per year that will become 

subject to the rule, and one affected facility will be engaged in some kind of modification each year over the three-year period of this rule.

c

 We have assumed that it will take respondent 2 hours once per year to complete report review.

d

 We have assumed that it will take respondent 4 hours once per year to review the compliance status report.

e

 We have assumed that five percent of respondents (5% x 111 = 6) will each take 8 hours four times per year to review the monitoring exceedances and periods of 

noncompliance report.

f

 We have assumed that 95 percent of respondents (95% x 111 = 105) will each take 2 hours two times per year to review the no exceedances report.