**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 Collectio n**  **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 6 3 , Subpart MM ) (Renewal) , EPA ICR Number 180 5 .0 6 , OMB Control Number 2060

- 03 7 7 **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 M M , proposed on April 15, 1998, and promulgated on January 12, 2001. These regulations appl y 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 reconstructi on 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, o wners 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 s ys tem 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 ye ars 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 Envi ronmental Protection Agency regional office. Approximately

1 11 sources are currentl y subject to the standard. T here are 8 9 kraft mills, 9 kraft and semi chemical mills, 1 kraft and sulfite mill, 7 stand

- alone semi chem i cal mills, 4 sulfite mills, and 1 sod a 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

- ye ar period of this rule.2

There are approximately 1 11 chemical re covery c ombustion sources at kraft, soda , sulfite, and stand

- alone semi chemical pulp mills in the United States. None of the 1 11 facilities in the United States are owned by state, local, tribal or the Federal government. They are owned and operated b y p rivatel y owned for

- profit businesses. You can find the burden to the “Affected Public” listed below in Table 1 a, and 1b : Annual Respondent Burden and Cost

- NESHAP for Chemical Recovery

Combustion Sources at Kraft, Soda, Sulfite, and Stand

- Alone Semichemi cal Pulp Mills (40 CFR Part 6 3 , Subpart MM ). T he Federal government burden does not include work performed b y 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 6 3 , Subpart MM ).
In the development of the IC R, we addressed the Office of Management and Budget (OMB) “Terms of Clearance (TOC)” on the active ICR. The TOC are as follows:

When this I CR 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 TO C. 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). T hese 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 an y o wner 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 reasonabl y require. In the Administrator's judgment, acetaldeh yd e, benzene formaldeh yd e, h ydrochloric acid (HCI), methanol, meth ylethyl ketone, and toluene hazardous air pollutant (HAP) emissions from3

chemical rec overy

combustion sources at kraft, soda, sulfite, and stand

- alone semichemical pulp mill cause or contribute to air pollution that may reasonabl y 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 i nitial capability to comply

with the emission standard. Continuous emissio n 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 emiss ion 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 properl y 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 report ing requirements described in this I CR 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**
Th e 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 directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrat or in lieu of the report required b y 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 IC R was published in the Federal Register ( 7 6 FR 2 6 900 ) on May 9, 20 11 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations**4

T he 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) 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 Agen cy ’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 dev eloping this ICR, we contacted the American Forest and Paper Association (AF& PA ) at (202) 463

- 2 700, and the America Wood Council at (202) 463

- 2766

. It is our polic y t o 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 b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of det ecting 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 maint ain all records, including reports and notifications for at least five years. T his is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar 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) Co nfidentiality**  Any i nformation submitted to the Agency for which a claim of confidentiality i s 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 C FR 2; 41 FR 36902, September 1, 1976;5

amended b y 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 (SI C) codes for the respondents affected by the standards, which corresponds to The North American Industry Classification Sy stem (NAICS) codes, are listed below for source category description. **Standard (40 CFR Part 63, Subpart MM)**  **SIC Codes NAICS Codes**  Pulp Mills 2 611 32 2 11 Paper Mills 26 21 32 2 1 2 Paperboard Mills 2631 32213 **4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

O MB 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 n otification s, reports of startups, shutdowns, malfunctions, construction/reconstruction , and modification 63.5, 63.9(b), 63.10 (d)(5), 63.8 67(a) N otification and report of performance test and results 63.7(b), 63.9 (e) , 63.10(d)(2), 63.8 67 ( a) Notification of initial continuous monitoring sy stem (CMS)/ continuous opacity

monitoring s ys tem (COMS) demonstration 63. 9 ( g ), 63. 867 ( a )
Notification and report o f compliance status 63. 9 (h), 63.8 67 (b ) (1 )

- ( 2) Reporting results of CMS/COMS demonstration 63.1 0 ( e )(2), 63.8 67 ( a )6 **Notification Reports** Excess emissions reports (quarterl y and semiannual) 63.10(e)(3), 63.8 67 ( c ) Certification that a non

- direct contact evaporator (NDCE) recovery furnace equipped with a dry electrostatic precipitation ( ESP ) sy stem 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 ye ars retent ion of records 63 .1 0 (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 ini tial notifications and notification of compliance status 63.1 0 (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. 8 66( c )( 1 ) Lime production rates for all lime kilns 63. 8 66( c )( 2 ) All parameter monitoring data required in section 63.864 63. 8 6 6 ( c )( 3 ) Supporting calculations for compliance determinations made under section 63.865(a) through (e) 63. 866 ( c )( 4 ) Compliant monitori ng parameter ranges established for each affected source 63. 86 6( 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 Reporti ng 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 significantl y reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this ti me, it is estimate d that approximately 1 0 percent of the respondents use electronic reporting.7

**(ii) Respondent Activities Respondent Activities**  Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liqu id 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install , and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y 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 d ata in an automated way

e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this ty pe 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, analy sis, storage, and distribution of the required info rmation. **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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S).8

**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 properl y i nstalled and operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance was achiev ed. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OT IS i s the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexib ility**  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 invo lving the process operations and the ty pes 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 an d, therefore, cannot reduce them further for small entities. T o the ex tent 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

f or each informatio n collection activity w ithin this request is shown in Table 1 a : One

- time Annual R espondent 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 i n 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 Col lection**  Table 1 a and 1b documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings bel ieved 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 sp onsor, 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 recordke eping and reporting requirements is estimated to be 126,207 (Total Labor Hours from Table s 1 a, 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 an y comments received. **6(b) Estimating Respondent Costs** This I CR uses the following labor rates: Managerial $118.92 ($56.63 + 110%) Technical $97.78 ($46.56 + 110%) Clerical $48.76 ($23.22 + 110%)
These r ates 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." T he rates have been increased by 110 perce nt to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe 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 mainten ance 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 Monitori ng 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 $ 7 12,000 CPMS $ 0 0 $0 $0 0 $0 Total $ 41,000 0 $ 0 $8,000 89 $ 7 12 ,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 requir ed for compliance with the NSPS for Kraft Pulp Mills (40 CFR Subpart BB).10

The total capital/startup costs for this ICR is $0 . T his 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 ye ars of the I CR is estimated to be $ 7 12 ,000

. **6(c) Estimating Agency Burd en and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of record s maintained by the respondents; periodic ins p ection 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 hourl y 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 Combust ion 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 I CR, on average over the next three ye ars, 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 ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR.11 **Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Recor ds 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 1 11 0 1 1 11 2 1 1 11 0 1 1 11 3 1 1 11 0 1 1 11 Average 1 1 11 0 1 1 11

1 The n ew respondent include s sources with constr ucted, 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

- ye ar period of this ICR is 1 11

. The total number of annual responses p er 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 2 4
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 1 a and 1b : Annual Industry Burden and Cost

- NESHAP for Chemical Recovery Combustion Source s at Kraft, Soda, Sulfite, and S tand

- 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 the12

Agency are shown in Tables 1 a, 1b, and 2, respectively , and summarized bel ow. **(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 o peration and m aintenance ( O&M ) cos ts 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 R ecovery

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 ac curate 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 th e active I CR that shows 130 sources. No new facilities are expected to be constructed over the next three years of this I CR. The decline in the number of sources is due mainly to plant closures. This industry is undergoing widespread consolidation and c orporate 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, effo rt, 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 s ys tem s for the purposes of collecting, validating, and verifying13

information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y previously

applicable instructions and requirements; trai n 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 require d 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 11

- 020 9

. An electroni c 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 sy stem, 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 In formation 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 holiday s. 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

- 17 52

. Also, yo u 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

- 20 11

- 0 2 0 9 and OMB Control Number 206 0

- 037 7 in an y correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1**  **a :**  **One**
**- Time**  **Annual Respondent**  **Burden and**  **Cost**

**– NESHAP**  **for Chemical**  **Recovery Co**  **mbustion 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 c 2 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 s tandard c , d 2 1 2 1 2 0 .1 0.2 $ 217.20 Notification of initial performance test c , d 2 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 N otification 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 Activi ties 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 docume ntation of supporting calculations for compliance determinations c, h 8 1 8 1 8 0.4 0.8 $ 868.82

- Record of compliant monitoring parameter r anges c 2 1 2 1 2 0. 1 0.2 $ 217.2015

**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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 f urnaces c, i 2 1 2 1 2 0 .1 0 .2 $ 217.2 0

G. Time to train personnel c , j 4 0 1 4 0 **1** 40 2 4 $ 4,341.68 Subtotal for Recordkeeping Requirements 220.08 Subtotals Labor Burden and cost 28 4 14. 2 28. 4 $ 30, 840

. 5 4 **TOTAL LABOR BURDEN AND COST (rounded)**  32 6

. 6 32 7 (rounded) $ 30, 840

**Assu mptions:**  a We have assumed that the average number of ex isting sources subject to the rule will be 1 11 . There will be no additional new source s 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 ho ur 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 Occ upational 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 a ssume d that one existing kraft pulp mills will install one new recovery furnace and smelt dissolving tank (SDT) each year. d We have a ssume d that it will take re spondent 2 hours once per year to complete report. e We have a ssume d that it will take respondent 80 hours once per year to w rite the notification of compliance status report. f We have a ssume d that it will take respondent 40 hours to develop a record sy stem for recording parameter monitoring information. g We have a ssume d 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 W e have a ssume d 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 a ssume d that one existing kraft and soda pulp mill will install new recovery furnaces. B ased on current industry trends, th e new furnace is expected to be non - direct contact evaporator (NDCE) recovery furnaces equipped with a dry electrostatic precipitator (ESP) system. j We have a ssume d that it will take respondent 40 hours (1 we ek) once per year to train personnel

.16

**Table 1**  **b :**  **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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Cler ical**  **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 1 9.2 38.4 $ 41,703.16

Semiannual report of no exceedances d 8 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 ac tivities See 4E c. Implement activities See 4E d. Develop record system See 4E e. Time to enter information Records of startup, shutdown, and ma lfunction 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 semi chemical com

bustion 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 $ 6,328,781.5517

**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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Cler ical**  **person hours**  **per year (Ex0.1)**  **(H)**

**Cost, $ b** 

Compile monthly data h 16 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 j 16 1 16 1 11 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

**Assu mptions:**  a We have assumed that the average number of existing sources subject to the rule will be 1 11 . There will be no additional new sources per year that will become subject to the rul e over the three

- year period of this IC R. b This ICR uses the following labor rates: $118.92 per hour for Executive, Administrative, and Managerial labor; $97.78 per ho ur 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 accou nt fo r the benefit packages available to those employed by private industry. c We have assumed that five percent of respondents will each take 16 hours fo ur times per year to com plete reports of monitoring exceedances and periods of noncompliance. d We have a ssumed that 95 percent of respondents will each take 8 hours two times per year to w rite 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 re spondents 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 h ave 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 Pu**  **lp 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, 91**  **8,52 4**  **.0 7** 

**(rounded) $11,918,524**19

**Tabl e**  **2: A** **verage 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 person**  **** **hours 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ a** 

Report review Notification of construction/reconstruction c 2 1 2 1 2 0.1 0.2 $ 103.65 Notification of actual startup c 2 1 2 1 2 0.1 0.2 $ 103.65 Notification of applicability c 2 1 2 1 2 0.1 0.2 $ 103.65 Notification of initial performance test c 2 1 2 1 2 0.1 0.2 $ 103.65 Notification of performance evaluation c 2 1 2 1 2 0.1 0.2 $ 103.65 Review of notification of compliance status d 4 1 4 1 2 0.1 0.2 $ 103.65 Review of excess emission s report Quarterly reports of monitoring e xceedances and periods of noncompliance e 8 4 32 6 192 9.6 19.2 $ 6.079.98 Semiannual reports of no exceedances f 2 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

**Assu mptions:** 
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, S tep 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 s ubject to the rule will be 1 11

. There will be no additional ne w 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 pe r 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 9 5 percent of respondents (95% x 111 = 105) will each take 2 hours two times per year to r eview the no exceedances report.