STANDARD FORM 83-I SUPPORTING STATEMENT

FOR OMB REVIEW OF EPA ICR No.____.__:

INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE
PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW
(RTR)

Sector Policies and Programs Division

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

November 16, 2010

SUPPORTING STATEMENT

INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE
PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW
(RTR)

Part A of the Supporting Statement

1.	Identification of the Information Collection

(a)	Title of the Information Collection 

“Information Collection Request for Pulp and Paper Sector New Source
Performance Standards (NSPS) and National Emission Standards for
Hazardous Air Pollutants (NESHAP) Residual Risk and Technology Review
(RTR).”  This is a new information collection request (ICR). 

(b)	Short Characterization

This information collection is being conducted by EPA’s Office of Air
and Radiation (OAR) to assist the EPA Administrator, as required by
sections 111(b), 112(d), and 112(f)(6) of the Clean Air Act (CAA), as
amended, to determine the current affected population of pulp and paper
processes and to reevaluate emission standards for this source category.
 The information from this ICR would also be made available to the
public.

This is a one-time information collection.  Currently, information
necessary to identify pulp and paper mills is available from the
Lockwood-Post (facility name and address) and from EPA’s National
Emissions Inventory (NEI).  Neither the Lockwood-Post nor the NEI
contain all of the details (capacity, fuel types, operating schedule,
emission source design, materials processed, emissions collection and
control systems, regulatory alternatives used, and emission test data)
necessary to characterize pulp and paper NSPS and NESHAP affected
sources for purposes of regulatory analyses.  Although some of the
needed information may be included in title V or State air emission
permits, many permits do not contain all of the detail needed and are
not readily available from any single source.  Furthermore, there are no
readily available sources for previously conducted emissions test
results (since the mid-1990s) that will provide data for emissions of
the variety of pollutants under consideration.  To obtain this
information, EPA is soliciting information with a survey, under
authority of CAA section 114, from all potentially affected units.  EPA
intends to administer the survey in electronic (spreadsheet) format. 
The survey will be sent to all pulp and paper manufacturing facilities
listed in the Lockwood-Post. 

The EPA estimates the total cost to industry of the electronic
information collection (gathering, entering, and quality assuring (QA)
of data submitted in response to the survey for 386 respondents) will be
183,746 hours and $17,386,690, which includes $6,948 in operation and
maintenance (O&M) costs for postage for mailing survey responses to EPA.
 The average burden per respondent is 476 hours and $45,025.  

2.	Need for and Use of the Collection

(a)	Need/Authority for the Collection

The pulp and paper production source category includes any facility
engaged in the production of pulp and/or paper.  This category includes,
but is not limited to, integrated mills (where pulp alone or pulp and
paper or paperboard are manufactured on-site), non-integrated mills
(where either paper/paperboard or pulp are manufactured onsite, but not
both), and secondary fiber mills (where waste paper is used as the
primary raw material).  The pulp and paper production process units
include operations such as pulping, bleaching, chemical recovery, and
papermaking.  Different pulping processes are used, including chemical
processes (kraft, soda, sulfite, and semi-chemical) and mechanical,
secondary fiber, or non-wood processes.  The three federal emission
standards that are the subject of this information collection include:  

Standards of Performance for Kraft Pulp Mills (40 CFR part 60, subpart
BB), 

National Emission Standards for Hazardous Air Pollutants from the Pulp
and Paper Industry (40 CFR part 63, subpart S), and

National Emission Standards for Hazardous Air Pollutants for Chemical
Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills (40 CFR part 63, subpart MM).

The Standards of Performance (i.e., the NSPS) currently regulates
particulate matter (PM) and total reduced sulfur (TRS) emissions from
kraft pulping processes.  In general, NESHAP subpart S covers hazardous
air pollutant (HAP) emissions from the pulp production areas (e.g.,
pulping system vents, pulping process condensates) at chemical,
mechanical, secondary fiber, and non-wood pulp mills; bleaching
operations; and papermaking systems.  The subpart S standards include
several alternative emission limits for each covered process that are
designed to provide flexibility and to promote and encourage the use of
new technology, particularly combined air/water controls and pollution
prevention technologies.  The NESHAP subpart MM regulates HAP emissions
from the chemical recovery combustion areas of chemical pulp mills
(kraft, sulfite, semi-chemical, and soda wood pulping processes).  For
existing kraft and soda combustion units, the subpart MM standards also
include a compliance alternative that allows netting of PM emissions for
the entire chemical recovery system.

Section 111(b)(1)(B) of the CAA mandates that EPA review and, if
appropriate, revise existing NSPS at least every 8 years. The NSPS for
kraft pulp mills was promulgated in 1978, and reviewed in 1986.  Another
review of the kraft pulp mill NSPS is required under the CAA. 
Similarly, Section 112(f)(2) of the CAA directs EPA to conduct risk
assessments on each source category subject to maximum achievable
control technology (MACT) standards and determine if additional
standards are needed to reduce residual risks.  The section 112(f)(2)
residual risk review is to be done 8 years after promulgation.  Section
112(d)(6) of the CAA requires EPA to review and revise the MACT
standards, as necessary, taking into account developments in practices,
processes, and control technologies.  The section 112(d)(6) technology
review is to be done at least every 8 years.  The NESHAP for the pulp
and paper industry (40 CFR part 63, subpart S) was promulgated in 1998
and is due for review under CAA sections 112(f)(2) and 112(d)(6). 
Likewise, the NESHAP for chemical recovery combustion sources at kraft,
soda, sulfite, and stand-alone semichemical pulp mills (40 CFR part 63,
subpart MM) was promulgated in 2001 and is also due for review.  In
addition to the CAA-required reviews, recent case law, legal petitions,
and a notice of intent (NOI) to sue suggest the need to review the pulp
and paper NESHAP and NSPS.  For example, in December 2008, the U.S.
Court of Appeals for the D.C. Circuit vacated the startup, shutdown, and
malfunction (SSM) provisions contained in the NESHAP General Provisions
that apply to pulp and paper mills.  In January 2009, EPA received a
petition for rulemaking requesting that EPA revise various NESHAP,
including the NESHAP for chemical recovery combustion sources at pulp
mills, to make the NESHAP consistent with CAA precedent established in
recent judicial rulings.  In July 2010, EPA received a NOI from
Californians for Alternatives to Toxics (CATs) and the Center for
Biological Diversity (CBD), contending that EPA failed to review the
NSPS for kraft pulp mills within the statutory deadline under CAA
section 111(b)(1)(B).  To the extent that these legal actions need to be
addressed in the pulp and paper NESHAP and NSPS, EPA intends to
investigate potential rule revisions at the same time as the CAA
statutory reviews are conducted.  

The data used as the basis for the originally promulgated pulp and paper
NESHAP are over 15 years old, and data used to review the NSPS are over
20 years old.  The Agency is aware that significant changes have been
made in the intervening years in the number of affected facilities, in
industry ownership practices, and in emission collection and control
configurations.  Further, in light of the statutory requirements for
reviewing emission standards under CAA sections 111(b) and 112 and the
recent case law, legal petitions, and NOI regarding those requirements,
the Agency has concluded that obtaining updated information will be
crucial to informing its decisions on the NSPS review and NESHAP RTR for
pulp and paper manufacturing sources.  

The EPA has already begun assembling data for a preliminary residual
risk assessment for the pulp and paper NESHAP subparts S and MM.  Data
sets derived from the EPA’s 2005 National Scale Air Toxics Assessment
(NATA) National Emissions Inventory (NEI) will be used for the RTR. 
Several pulp and paper mills have voluntarily updated their NEI data
sets for RTR purposes in recent years and few additional refinements are
expected on the NEI data sets for these mills.  However, there remain a
number of pulp and paper mills for which substantial updates to their
NEI data sets would be useful in order for EPA to accurately consider
RTR for the pulp and paper NESHAP standards.  In addition, there may be
some mills for which no pulp and paper MACT category NEI data are
currently available.  Preliminary risk analysis results for the pulp and
paper sector (based on the current NEI data sets) indicate that some
mills may present risk above the thresholds for further consideration
under the residual risk process.  Additional mill-specific information
would allow EPA to better characterize emission sources, refine the risk
analysis, and to address any unacceptable residual risk that remains. 
An update of the 2005 NATA NEI data sets and more specific information
needed for rulemaking regulatory analyses would be derived from the ICR.
 Information collected directly from pulp and paper mills will have the
greatest practical utility for purposes of performing the RTR and NSPS
reviews as information from the affected industry will contain the most
up-to-date, accurate, and reliable equipment and operational data for
each mill.  The ICR will request that new information be supplied for a
2009 base year, and therefore, will not suffer from the considerable
“lag time” that can be associated with different inventory and
permit review cycles (e.g., where the currently available inventory does
not yet reflect recent changes in equipment).

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

CAA section 114(a) states that the Administrator may require any owner
or operator subject to any requirement of the Act to:

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

(b)	Use/Users of the Data

As mentioned previously, the data used for the originally promulgated
NESHAP and NSPS are outdated and do not reflect the significant changes
in emissions collection and control configurations that have occurred
since promulgation of the MACT standards.  The MACT standards contain a
number of compliance alternatives to allow for a variety of equipment
configurations and process changes to be used in meeting the emission
standards and effluent limitations established under the Clean Water
Act.  At present, the EPA does not have a data base reflecting the
post-MACT and post-effluent guidelines configurations of pulp and paper
emission units and air pollution control systems.  It is essential for
the EPA to have updated information to use in the regulatory analyses
required under CAA sections 112(d) and 112(f)(2).  In addition, this
updated information will be used to perform the NSPS review required
under CAA section 111(b).  By collecting information for all of the
CAA-required reviews at the same time (i.e., the subpart S and MM RTR
reviews and the subpart BB NSPS review), the Agency can make use of a
single collection of information that would allow the Agency to consider
control strategies that are the most effective for both HAP and criteria
air pollutants (such as PM, SO2, and NOx) that are regulated under NSPS.
 The data would also allow the Agency to evaluate compliance options for
startup and shutdown periods, and to consider ways to consolidate
monitoring, reporting, and recordkeeping requirements among the
different rules under review.  

The data collected will be used to update facility information and
equipment configuration, develop new estimates of the population of
affected units, and identify the control measures and alternative
emission limits being used for compliance with the existing rules that
are under review.  This information, along with existing permitted
emission limits will be used to establish a baseline for purposes of the
regulatory reviews.  The emissions test data (test reports and CEMS
data) collected will be used to verify the performance of existing
control measures, examine variability in emissions, evaluate emission
limits, and to determine the performance of superior control measures
considered for purposes of reducing residual risk or as options for best
demonstrated technology (BDT) under the NSPS review.  Emissions data
will also be used along with process and emission unit details to
consider subcategories for further regulation and to estimate the
environmental and cost impacts associated with any regulatory options
considered.  

In addition to informing the CAA-required RTR and NSPS regulatory
analyses for the pulp and paper sector, it is EPA’s intent that the
NEI updates supplied through this information collection be used in
future versions of the NEI and its successor, the Emissions Inventory
System (EIS).  The NEI is used by EPA, States, and the public for a
variety of purposes including tracking of national trends in emissions
of criteria and hazardous air pollutants.  More information in the NEI
can be found at http://www.epa.gov/air/data/neidb.html.

The non-confidential information collected with this ICR would also be
available to the public, including pulp and paper industry trade groups
that may find the information useful for their ongoing data gathering,
analyses, and publications.  In addition, such trade groups may wish to
use the data collected to review and verify EPA’s regulatory
conclusions. 

3.	Non-duplication, Consultations, and Other Collection Criteria 

(a)	Non-duplication 

The Agency recognizes that some of the information requested in the
information collection effort may already be included in the submittals
made by individual companies, pursuant to State and national emission
inventories, operating permits applications, initial notification forms,
and compliance reports.  However, the complete extent of the data fields
requested under this survey is not available in any consistent or usable
format.  Additionally, these sources do not provide detailed emissions
test data.  As mentioned previously, there is a lag time associated with
State and national emission inventories, and permit review cycles. 
There is also a lag time associated with obtaining emission test reports
from State agencies (i.e., agencies may be reluctant to release emission
test results they have not yet processed).  The EPA’s proposed
information collection seeks up-to-date equipment configuration and
operational data for the 2009 operating year, and thus avoids the
effects of any such lag time on data availability.  Although some State
permits are provided to the public as searchable portable document
format files (pdfs), many States do not provide electronic versions of
their issued Title V permits.  Even when the permit is available, the
unit-specific operating data are often not contained within the permit. 
Some of the initial notifications and compliance reports submitted are
available in hard-copy only, whereas only the facility-level information
(facility name, location, contact) is available in an electronic format.
 In order to address SSM issues, the Agency has obtained numerous
semi-annual compliance reports for pulp and paper processes and found
the reports to contain a widely varying level of detail.  Such variation
in the level of detail of permits and compliance reports means that it
would be extremely time consuming for the Agency to extract the level of
process detail needed for regulatory analyses from existing documents
(assuming that these documents were readily available to EPA), and that
significant data gaps would remain even after data from existing
documents were compiled.  

Emissions test reports are often retained as hard copies by State
agencies and thus are not readily available for all mills.  Although one
pulp and paper industry trade organization (National Council for Air and
Stream Improvement [NCASI]) collects and compiles emissions test data in
technical bulletins, these bulletins alone (while quite informative and
valuable) do not inform all of EPA’s emissions data analyses because:
(1) the NCASI technical bulletins are coded to mask mill identities such
that the emissions data cannot be reconciled with other emissions data
available to EPA; (2) the data contained in the NCASI reports may not be
reported in the units of measure needed for analysis of emission limits;
(3) much of the data pre-dates implementation of the MACT standards, and
(4) the data are generally representative of NCASI member mills, whereas
information collected by EPA would be requested from the entire
population of affected mills.  

To summarize, the information requested relevant to the current
(post-MACT) equipment configuration and operation, regulatory
alternatives, emissions data, and effectiveness of various control
systems at removing HAP is not readily available from other sources.  In
the absence of an industry data collection, the EPA would be forced to
try to obtain permits, compliance reports, and emissions test reports
from States; extract information from these reports (which vary in
detail); and then to fill data gaps where information is not available
from the reports obtained.  This process of acquiring and extracting
data from existing reports would require more time than an industry data
collection, and ultimately would be expected to yield incomplete
information.  Information collected directly from pulp and paper mills
would provide the most timely and complete post-MACT data set with the
greatest practical utility for purposes of performing the NSPS and RTR
reviews that are due to be completed under CAA sections 111(b) and
112(d) and (f)(2).  

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

The ICR was submitted for public review on June 23, 2010 (75 FR 35792)
as required by the Paperwork Reduction Act of 1995 (PRA) and the
subsequent rule issued by the Office of Management and Budget (OMB) on
August 29, 1995 (60 FR 44978).  A 60-day comment period (ending August
23, 2010) was provided for the public to submit comments to EPA
regarding the proposed new data collection.  A total of three comments
were received by EPA regarding the proposed ICR.  EPA revised the ICR to
address the public comments prior to submitting the ICR to OMB.

(c)	Consultations 

Initial feedback was received from the affected industry regarding the
scope of a pulp and paper sector survey.  Detailed comments on the
proposed ICR were received from the industry in August 2010, followed by
meetings with the industry in October 2010 to discuss in greater detail
the design and content of the ICR.  The EPA has implemented many changes
to specific ICR questions as a result of these consultations.  In
addition, EPA revised the survey so that it would be administered in
three parts with staggered due dates to provide respondents with
additional time to complete the survey.  Part I of the ICR will request
information on the pulp and paper production process addressed under the
subpart S NESHAP and subpart BB NSPS and will be due 30 days after
receipt of the survey.  Part II of the ICR will require the facilities
to complete an electronic update of their 2005 NATA NEI data set to be
used for RTR purposes and will be due 100 days after receipt of the
survey.  Part III of the ICR will request information on the chemical
recovery combustion process addressed under the subpart MM NESHAP and
subpart BB NSPS and will be due 180 days after receipt of the survey.  

(d)	Effects of Less Frequent Collection

This ICR will require the owner/operator of each pulp and paper facility
to complete an electronic survey in three parts, with staggered due
dates.  Each part requests different information.   EPA expects the
information requested in all three parts of this survey to be a one-time
effort.

 (e)	General Guidelines

This ICR will adhere to the guidelines for Federal data requestors, as
provided at 5 CFR 1320.6.

(f)	Confidentiality

Respondents will be required to respond under the authority of CAA
section 114.  If a respondent believes that disclosure of certain
information requested would compromise a trade secret, it should be
clearly identified as such and will be treated as confidential until and
unless it is determined in accordance with established EPA procedure as
set forth in 40 CFR Part 2 not to be entitled to confidential treatment.
 All information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart
B–Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR
42251, September 28, 1978; 44 FR 17674, March 23, 1979).  Any
information subsequently determined to constitute a trade secret will be
protected under 18 U.S.C. 1905.  If no claim of confidentiality
accompanies the information when it is received by EPA, it may be made
available to the public without further notice (40 CFR 2.203, September
1, 1976).  Because CAA section 114(c) exempts emission data from claims
of confidentiality, the emission data provided may be made available to
the public.  Therefore, emissions data should not be marked
confidential.  A definition of what EPA considers emissions data is
provided in 40 CFR 2.301(a)(2)(i).

 (g)	Sensitive questions 

This section is not applicable because this ICR will not involve matters
of a sensitive nature.

4.	The Respondents and the Information Requested

(a)	Respondents/NAICS Codes.

Respondents affected by this action are owners/operators of mills that
are “major sources” of HAP emissions and produce pulp, perform
bleaching, or manufacture paper or paperboard products.    In the U.S.,
there are a total of 386 mills including:

120 mills that carry out chemical wood pulping (kraft, sulfite, soda, or
semi-chemical),

47 mills that carry out mechanical, groundwood, secondary fiber, and
non-wood pulping,

102 mills that perform bleaching, and

366 mills that manufacture paper or paperboard products.

Some mills perform multiple operations (e.g., chemical pulping,
bleaching, and papermaking; pulping and unbleached papermaking; etc.). 
The counts provided above are preliminary counts of potential
respondents based on the Lockwood-Post Online (as of March 2009),
including mills reported to be closed, idle, or bankrupt in 2009 (the
base year for which production data will be requested).  Mills that only
purchase pre-consumer paper or paperboard products and convert them into
other products (i.e., converting operations) are not affected by this
action.  The North American Industry Classification System (NAICS) codes
for respondents affected by the information collection include 32211 for
pulp mills, 32212 for paper mills, and 32213 for paperboard mills.

(b)	Information Collected   

(i)	Data Items.  Each owner/operator of each affected mill will be
required to complete an electronic survey that contains several
components.  Some survey components are not applicable for some types of
mills.  The draft electronic survey is a series of Microsoft Excel
spreadsheet files, each of which is divided into a series of worksheets
(“tabs” within the spreadsheet file).  Table 1 below denotes which
pulp and paper sector survey spreadsheet tabs are to be completed
depending on the part of the survey and type of mill.  Survey
spreadsheet tabs must be completed for all mills that are major sources
of HAP emissions and produce pulp, perform bleaching, or manufacture
paper or paperboard products.  Mills will also be asked to supply
process flow diagrams for the following mill areas (as applicable):
pulping process, chemical recovery area, wastewater treatment, and black
liquor gasification (if used).  

Table 1.  Survey Spreadsheets and Tabs to Complete

Spreadsheet tab	Types of mills that should complete this spreadsheet tab
Estimated number of mills

P&P survey_PI.xls

Mill	All mills	386

PI Equip detail	All mills	386

PI Permit limits	All mills	386

PI Controls	Mills with add-on air pollution controls on pulping emission
units, bleaching emission units, or papermaking emission units. 	386

Pulp prod	Mills that produce any type of pulp (including chemical,
mechanical/groundwood, secondary fiber, including non-wood pulp)	167

Byproducts	Mills that produce turpentine or tall oil byproducts from
pulping processes	104

Kraft condensates	Mills that perform kraft pulping	104

CCA	Mills that perform kraft pulping and use the clean condensate
compliance alternative (CCA)	521

Bleaching	Mills that perform bleaching 	102

Paper prod	Mills the produce paper or paperboard products  	366

HAP additives	Mills the produce paper or paperboard products 	366

WW	Mills with onsite wastewater treatment plants	386

PI Emissions test data	All mills	386

P&P NEI update.xls (or P&P NEI blank.xls)

Facility (or New Facility)	All mills	386

Inventory (or New Facility)	All mills	386

P&P survey_PIII.xls

PIII Equip detail	Mills that use chemical recovery combustion processes
120

PIII Permit limits	Mills that use chemical recovery combustion processes
120

PIII Controls	Mills with add-on air pollution controls on chemical
recovery combustion processes. 	120

PCC	Mills that route lime kiln, boiler, or other process exhaust to a
precipitated calcium carbonate (PCC) plant	30

PIII Emissions test data	Mills that use chemical recovery combustion
processes	120

1.  Assumes that up to 50% of kraft mills use the CCA.

In addition to the pulp and paper sector survey spreadsheets listed in
Table 1, separate spreadsheets are provided for submittal of continuous
emissions monitoring system (CEMS) and/or continuous opacity monitoring
system (COMS) data, or optional control measure cost information. 
Separate versions of these spreadsheets are to be submitted under Parts
I and III of the survey for the different emissions units covered under
those parts.

Emissions data collected under the Emissions test data tabs listed in
Table 1 or the CEMS spreadsheets mentioned above will allow EPA to
characterize the performance of equipment and controls, reevaluate
emissions limits, and consider variability.  Emissions data (test
reports or CEMS data) are being requested for affected sources and
emissions units for which emissions limits may be reevaluated under NSPS
review or RTR.  The pollutants for which emissions data are requested
include particulate matter (PM), filterable PM less than 2.5 microns
(PM2.5), condensable PM2.5, speciated HAP metals, chlorine (as a
surrogate for chlorinated HAP), hydrochloric acid, methanol (as a
surrogate for organic HAP), acetaldehyde, formaldehyde, total
hydrocarbon (as carbon), dioxin/furan (CDD/CDF), polycyclic organic
matter/polycyclic aromatic hydrocarbon (POM/PAH), total reduced sulfur
(TRS), nitrogen oxides (NOx), sulfur dioxide (SO2), and carbon monoxide
(CO).  Separate “tabs” of the CEMS spreadsheet are provided for the
different pollutants for which CEMS are available.

The control cost spreadsheet requests information related to the capital
and operating costs of selected air pollution controls or
process/equipment changes.  Submittal of the control cost information is
optional.  The Agency wishes to receive enough cost information on a
voluntary basis to perform the CAA-required regulatory analyses. 
However, should additional cost information be needed, EPA reserves the
right to follow up with mills that have installed equipment or
implemented process changes of interest to request cost information
under CAA section 114 authority.  

Although a large amount of information is needed for regulatory reviews
of the two NESHAP and NSPS, the EPA has designed the pulp and paper
information collection in a way to minimize the burden associated with
supplying and processing this information.  The survey will collect
information to supply multiple regulatory actions in order to minimize
duplication and burden associated with multiple collections for the
different rules.  For mills with prior NEI data, the EPA will
pre-populate the Part II spreadsheets with each mill’s 2005 NATA NEI
data set to be reviewed (thereby reducing respondent burden to locate
and import their mill’s NEI data).  For mills with no prior NEI data,
a blank spreadsheet containing the NEI data fields to be populated will
be provided.  The burden associated with the NEI update has also been
further reduced because updates to criteria air pollutant and inclusion
of total reduced sulfur data in the NEI update are optional.  A lookup
spreadsheet containing only the NEI codes included in the 2005 NEI data
set will be provided, along with a simplified crosswalk of the pulp and
paper source classification codes SCC codes in order to ensure that
valid NEI codes are used and to reduce respondent time associated with
locating codes on the NEI website.  The pulp and paper information
collection is being administered in spreadsheet form (as opposed to data
base software) because respondents are likely to be more familiar with
spreadsheet use than with data bases, and (following QA) data from the
Excel spreadsheet rows can be readily imported into Access data base
software for use by the Agency (eliminating the time required for EPA to
key-enter data).  The pulp and paper survey spreadsheets can be provided
to mills on a flash drive which respondents can use to save and submit
their survey materials such as electronic copies of flow diagrams,
emission test reports, and the survey spreadsheets.  The burden
associated with collection of emissions test data has been reduced in
several ways:  

(1) Only existing emissions data (CEMS data or emissions test reports)
are being requested at this time.  Mills are not required to conduct any
new emissions testing or to install or operate any new CEMS or COMS to
respond to this survey.    

(2) Data are, for the most part, being requested for the HAP surrogates
defined in the MACT standards, as opposed to speciated chlorinated HAP
or speciated non-chlorinated organic HAP.  Speciated data are being
requested for acetaldehyde and formaldehyde (in addition to the methanol
surrogate for organic HAP) because these pollutants are expected to be
of interest for residual risk.

(3) EPA has developed a matrix of emission units and pollutants for
which test data are requested for the emissions units covered in Part I
and Part II.  Emissions data are only being requested for emissions unit
and pollutant combinations for which emissions limits may be reevaluated
under NSPS review or RTR (or for pollutant that may serve as an
indicator or surrogate for emission unit or control system performance).
 The matrix provides cutoff dates for selected emission unit and
pollutant combinations (or in some cases, only requests the most recent
test data) in order to minimize respondent burden and to ensure the
Agency’s ability to process the data requested.

(4) Respondents are required to submit emissions test reports in order
for EPA (or EPA contractor personnel) familiar with extracting test data
from test reports to enter the data in a manner that ensures consistent
and reliable treatment of the data (e.g., with respect to data
averaging, non-detects, etc).

(5) Respondents may provide electronic or hard copy emissions test
reports, whichever they find to be less burdensome.

(6) The survey instructions allow respondents to provide CEMS data in an
alternative format if they cannot fit it into the survey spreadsheet
provided.

The EPA has minimized the burden associated with providing permit limits
by allowing submittal of the permit or summary of permit limits in an
alternative format.  The EPA is not requesting state mass-based limits. 
The survey instructions also include a table of suggested permit limit
units of measure that are of the most interest (based on the units of
measure for Federal limits).

Finally, the EPA has minimized the collection of control measure cost
information by focusing the collection of cost information on air
pollution controls and process changes of particular interest for
purposes of the NSPS review or RTR (as opposed to all control measures
employed by pulp and paper mills).  The EPA expects cost information
obtained from the industry to be some of the most reliable and valid
information available since the cost data would be specific to pulp and
paper applications.  In addition, collection of cost information from
the industry (as opposed to a separate collection from other sources
such as vendors) would accelerate EPA’s ability to analyze the cost
impacts of regulatory options. 

 (ii)	Respondent Activities.  The activities a respondent must undertake
to fulfill the requirements of the information collection are presented
in Attachment 2.  These include:  i) read instructions; ii) provide
information on each affected source through electronic survey; and iii)
submit hard or electronic copies of flow diagrams, previous emission
test reports, and available CEMS or COMS data.

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

(a)	Agency Activities

A list of activities required of the EPA is provided in Attachment 3. 
These include: i) develop electronic questionnaire and packages for
mailout; ii) answer respondent questions (including claims of true area
source status or that mill in not engaged in processes of interest);
iii) review and analyze responses and emissions data; and iv) analyze
requests for confidentiality.

 (b)	Collection Methodology and Management

In collecting and analyzing the information associated with this ICR,
EPA will use personal computers and applicable spreadsheet and database
software.  To better facilitate uniformity in the format of the
requested data, and, thus, increase the ease of database entry,
standardized survey questions, example responses, and Excel spreadsheet
forms will be distributed to respondents.  EPA will ensure the accuracy
and completeness of the collected information by reviewing each
submittal.  Flow diagrams may be used to answer any questions revealed
during quality assurance (QA) of each submittal.  The EPA may place
follow-up calls to mills should questions remain after reviewing all
materials submitted.  Following QA of each submittal, the spreadsheet
information from each mill will be uploaded into an Access data base for
further analysis.  Survey responses claimed as CBI will be housed in a
separate data base from the non-CBI survey responses.  In addition, a
copy of the NEI updates submitted will be routed for inclusion in
EPA’s residual risk input data base, and for inclusion in future
versions of the NEI and its successor, the Emissions Inventory System
(EIS).  Emissions test report data will be entered into a data base by
EPA (or EPA contractor personnel) familiar with extracting test data
from test reports.  In addition CEMS data would be uploaded in a data
base for analysis of emissions variability.  The resulting data bases
will be QA’d prior to and as part of regulatory analyses.

 (c)	Small Entity Flexibility

All respondents required to comply with the pulp and paper data
gathering effort will be subject to the same requirements.  EPA expects
that a small percentage of the respondents may be small entities.  Small
entities are likely to be non-integrated mills with lower-capacity pulp
and paper processes (e.g., smaller mills that produce paper from
purchased pulp). Small entities and other mills that are not major or
synthetic area sources of HAP emissions (i.e., true area sources) would
not be required to complete the survey provided that they submit
documentation of their true area source status.  Even if major or
synthetic area sources of HAP emissions, small entities (and other
non-integrated mills) would have fewer portions of the survey to
complete as their operations would likely be less extensive.  Also, any
individual small entity would be expected to receive only one CAA
section 114 letter so their response burden will be minimized.  The
Agency also plans to use an electronic format of the questionnaire in
order to reduce the burden and improve the data accuracy from all
respondents, including small entities.  In addition, the survey will
contain a question to determine the small entity status of a facility. 
This question will help to identify, quantify, and minimize the burden
on small entities during the revised rulemaking process.  

(d)	Collection Schedule

EPA anticipates issuing the CAA section 114 letters by late 2010/early
2011.  These CAA section 114 letters would require the owner/operator of
each pulp and paper mill to complete Part I of the ICR within 30 days of
receipt of the survey, Part II within 100 days, and Part III within 180
days.  EPA will compile and analyze the survey response data upon
receipt.

6.	Estimating the Burden and Cost of the Collection

(a)	Estimating Respondent Burden and Costs

Attachment 2 presents estimated costs for the required data collection
activities.  Labor rates and associated costs are based on Bureau of
Labor Statistics (BLS) data.  Technical, management, and clerical
average hourly rates for private industry workers and were taken from
the United States Department of Labor, Bureau of Labor Statistics,
September 2009, “Table 2. Civilian Workers, by occupational and
industry group,” available at   HYPERLINK
"http://www.bls.gov/news.release/ecec.t02.htm" 
www.bls.gov/news.release/ecec.t02.htm .  Wages for occupational groups
are used as the basis for the labor rates with a total compensation of
$46.76 per hour for technical, $54.52 per hour for managerial, and
$23.11 per hour for clerical.  These rates represent salaries plus
fringe benefits and do not include the cost of overhead.  An overhead
rate of 110 percent is used to account for these costs.  The
fully-burdened hourly wage rates used to represent respondent labor
costs are: technical at $98.20, management at $114.49, and clerical at
$48.53.  These estimates represent the one-time burden that will be
incurred by the recipients.

(b)	Estimating Agency Burden and Costs

The costs the Federal Government would incur are presented in Attachment
3.  The Agency labor rates are from the Office of Personnel Management
(OPM) 2009 General Schedule which excludes locality rates of pay.  These
rates can be obtained from Salary Table 2010-GS, available on the OPM
website at   HYPERLINK "http://www.opm.gov/oca/10tables/html/gs_h.asp" 
www.opm.gov/oca/10tables/html/gs_h.asp .  The government employee labor
rates are $16.28 per hour for clerical (GS-7, Step 1), $34.34 for
technical (GS-13, Step 1), and $47.74 for managerial (GS-15, Step 1). 
These rates were increased by 60 percent to include fringe benefits and
overhead.  The fully-burdened wage rates used to represent Agency labor
costs are: clerical at $26.05, technical at $54.94, and managerial at
$76.38.

(c)	Estimating the Respondent Universe and Total Burden and Costs

Estimates based on the Lockwood-Post Online (as of March 2009) indicate
that the potential respondent universe consists of 386 mills. All 386 of
these mills will be required to complete some portion of the electronic
survey, with the exception of mills that provide documentation (a
one-page form) to EPA within 20 days certifying that either: (1) they
are not a major or synthetic area source of HAP emissions, (2) they were
not operational in 2009 and remain closed, or (3) they do not produce
pulp, perform bleaching, or manufacture paper or paperboard products. 
The government burden estimate provided in Attachment 3 assumes that 15
percent of mills will provide documentation of true area source status,
mill closure, or that pulping, bleaching, papermaking is not performed
at the mill.  However, it is not known how many of these claims will be
valid so all mills are included in the burden estimate for respondents
(in Attachment 2).  Attachment 2 lists the various portions of the
survey in detail and provides an estimated number of mills required to
complete each portion of the survey.  Specific counts of the different
types of mills used in the burden estimates are provided in Part B of
this supporting statement. 

 (d)	Bottom Line Burden Hours and Costs Tables

(i)	Respondent tally.  The bottom line industry burden hours and costs,
presented in Attachment 2, are calculated by summing the person-hours
column and by summing the cost column.  The total burden and cost to the
industry for 386 respondents is 183,746 hours and $17,379,742.  No
capital or annualized costs are applicable because this is a one-time
submittal.  O&M costs of $6,948 are estimated for postage to mail in the
three parts of the survey response to EPA.   

(ii)	Agency tally. The bottom line Agency burden and cost, presented in
Attachment 3 is calculated in the same manner as the industry burden and
cost.  The estimated burden and cost for 386 respondents is 12,468 hours
and $673,617, which includes $8,284 in O&M costs to send certified CAA
section 114 letters to all respondents with electronic return receipt
and a flash drive containing pre-populated spreadsheets, questionnaire
printing costs, and computer storage of data received.

(iii)	The complex collection.  This ICR is a simple collection;
therefore, this section does not apply.

(iv)	Variations in the annual bottom line.  This section does not apply
as this is a onetime collection.

(e)	Reasons for Change in Burden

This is the initial estimation of burden for this information
collection; therefore, this section does not apply. 

(f)	Burden Statement

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or 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 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 currently valid OMB
control number.  The OMB control numbers for EPA’s regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.

The total cost burden for the pulp and paper data gathering effort is
estimated to be 183,746 hours and $17,379,742 (476 hours and $45,025 per
respondent for 386 respondents).  This ICR does not include any
requirements that would cause the respondents to incur either capital or
start-up costs.  O&M costs of $6,948 ($18 per respondent) are estimated
for postage to mail in the survey response to EPA. 

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a docket for this ICR under Docket ID No.
EPA-HQ-OAR-2007-0544, which is available for online viewing at
www.regulations.gov, or in hard copy at EPA Docket, EPA/DC, EPA West,
Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA/DC
Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays.  The telephone number for the Reading
Room is 202-566-1744, and the telephone number for the Air and Radiation
Docket Center is 202-566-1742.

An electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “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 17th Street, NW, Washington, DC 20503, Attention:  Desk
Office for EPA.  Please include EPA Docket ID No. EPA-HQ-OAR-2007-0544
in any correspondence.

INFORMATION COLLECTION REQUEST FOR PULP AND PAPER SECTOR NEW SOURCE
PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP) RESIDUAL RISK AND TECHNOLOGY REVIEW
(RTR)

Part B of the Supporting Statement

1.	Respondent Universe

Estimates based on the Lockwood-Post Online (as of March 2009) indicate
that the potential respondent universe consists of 386 mills. All 386 of
these mills will be required to complete some portion of the electronic
survey, with the exception of mills that provide documentation to EPA
certifying that either: (1) they are not a “major source” or
“synthetic area source” of HAP emissions, (2) they were not
operational in 2009 and remain closed, or (3) they do not produce pulp,
perform bleaching, or manufacture paper or paperboard products.  Any
mill that meets one of these criteria will need to complete the one-page
form in the survey overview document certifying their status and submit
it to EPA within 20 days of receiving the ICR.  The government burden
estimate provided in Attachment 3 assumes that 15 percent of mills will
provide documentation of true area source status, mill closure, or that
pulping, bleaching, papermaking is not performed at the mill.  However,
it is not known how many of these claims will be valid so all mills are
included in the burden estimate for respondents (in Attachment 2). 
Attachment 2 lists the various portions of the survey in detail and
provides an estimated number of mills required to complete each portion
of the survey.  Specific counts of the different types of mills used in
the burden estimates are as follows:

Chemical pulp mills 	Count

      kraft (including kraft/mechanical)	95

      soda 	1

      sulfite 	6

      kraft/semichemical 	9

      semichemical 	9

 	120

Mechanical/groundwood, secondary fiber, and non-wood pulp mills

	      mechanical 	20

      specialty (recycled) 	23

      nonwood 	4

 	47

 Paper/paperboard only + Integrated paper mills 	366



	 Number of mills that perform bleaching 	102

 

	 TOTAL NUMBER OF MILLS 	386



2.	Response Rates

Since the information will be requested pursuant to the authority of CAA
section 114, EPA expects that all respondents requested to submit
information will do so.     

List of Attachments

1.	Draft Questionnaire Content

2.	Industry Burden and Costs for Responding to the Questionnaire

3.	Agency Burden and Costs

Attachment 1.

Draft Questionnaire Content

The draft electronic questionnaire may be found in separate files
accompanying this supporting statement, including the following:

File name	Description

Phased Instructions Overview.doc	This is the draft survey overview
document.  This file provides an overview of the sources covered under
the pulp and paper sector survey, the sources exempt from the survey,
the components and due dates of the three-part survey, and the base year
for the survey.  Attachments to this document are: (1) documentation of
true area, non-operational, or non-applicable status; (2) NSPS and
NESHAP definitions; (3) acronyms and abbreviations used in the survey
materials; and (4) signed certification form.

	Part I – Mill Overview and Subpart S Data

P&P survey instructions_PI.doc	This file provides instructions for
completing and submitting Part I of the survey (including CBI and
non-CBI responses); the request for flow diagrams; the request for
emission test data (emissions test reports or CEMS) for pulp and paper
production units; and the request for optional control measure cost
information for those units.  Attachments to this document are: (1) a
list of emission units to include in Part I of the survey response;
(2) small business size standards; and (3) a table of pulp and paper
production emission units and pollutants for which existing emission
test data are requested.

P&P survey_PI.xls	This multi-tabbed spreadsheet file is the main portion
of Part I of the survey.  It includes a number of pulp and paper sector
tabs with questions needed to specify and characterize pulp and paper
production emission units and control systems.  A listing of the tabs in
this file is provided in Table 1 of the Part I survey instructions
document described above. 

P&P CEMS_PI.xls	The spreadsheet contains templates for submittal of CEMS
or COMS data for pulp and paper production units (for mills that
currently operate CEMS or COMS).  Separate tabs are provided for TRS,
NOx, SO2, CO, methanol, chlorine, and PM.  An optional tab is included
for CEMS cost information, and an example tab is provided.

P&P costs OPTIONAL_PI.xls	This file contains control device and process
change cost questions for pulp and paper production emission units. 
These cost questions are optional.

Part II – NEI Update

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

P&P NEI update.xls	This spreadsheet file includes the NEI update portion
of Part II of the survey for mills with existing NEI data.  It includes
pre-populated Facility and Inventory tabs with additional specified
columns for respondents to enter any revisions.

P&P NEI blank.xls	This spreadsheet file includes the NEI update portion
of Part II of the survey for mills for which NEI data do not exist.  It
includes blank New Facility and New Inventory tabs with specified
columns for respondents to enter the relevant information.

Lookups for P&P survey.xls	This spreadsheet contains lookup code tables
needed to complete the NEI revisions.  There are lookup tables for the
pulp and paper source classification codes (SCC) codes grouped according
to process, and for all SCC codes.  Also included are lookup tables
needed to review and/or revise the various NEI data fields that contain
codes. 

Part III – Chemical Recovery Combustion Sources

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

P&P survey_PIII.xls	This multi-tabbed spreadsheet file is the main
portion of Part III of the survey.  It includes a number of pulp and
paper sector tabs with questions needed to specify and characterize
chemical recovery combustion units and control systems.  A listing of
the tabs in this file is provided in Table 1 of the Part III survey
instructions document described above. 

P&P CEMS_PIII.xls	The spreadsheet contains templates for submittal of
CEMS or COMS data for chemical recovery combustion units (for mills that
currently operate CEMS or COMS).  Separate tabs are provided for TRS,
NOx, SO2, CO, methanol, chlorine, and PM.  An optional tab is included
for CEMS cost information, and an example tab is provided.

P&P costs OPTIONAL_PIII.xls	This file contains control device and
process change cost questions for chemical recovery combustion units. 
These cost questions are optional.

Attachment 2.

Industry Burden and Costs for Responding to the Questionnaire

Respondent Activity	(A)  Hours per Occurrence	(B)  Occurrences/
Respondent/Year	(C)  Hours/ Respondent/ 

Year (A x B)	(D)  Respondents/ Year1	(E)  Technical Hours/Year 

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

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

(E x 0.10)	(H)  Cost/ Year

1. APPLICATIONS (Not Applicable)	 	 	 	 	 	 	 	 

2. SURVEY AND STUDIES (Not Applicable)	 	 	 	 	 	 	 	 

3.  ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS
(Not Applicable)	 	 	 	 	 	 	 	 

4. REPORT REQUIREMENTS	 	 	 	 	 	 	 	 

 	A. Read Instructions	12	1	12	386	4,632	232	463	$503,840

 	B. Required Activities	 	 	 	 	 	 	 	 



a. Part I: Mill Overview and Subpart S Data	 	 	 	 	 	 	 	 

 	 	    i. Submit flow diagrams	20	1	20	386	7,720	386	772	$839,733

 	 	    ii. Complete and submit survey spreadsheet tabs, as follows:
 	 	 	 	 	 	 	 

 	 	        Mill (general information)	6	1	6	386	2,316	116	232
$251,920

 	 	        PI Equip detail	40	1	40	386	15,440	772	1,544	$1,679,466



        PI Permit limits	40	1	40	386	15,440	772	1,544	$1,679,466

 	 	        PI Controls	15	1	15	386	5,790	290	579	$629,800

 	 	        Pulp prod	6	1	6	167	1,002	50	100	$108,991

 	 	        Byproducts	4	1	4	104	416	21	42	$45,250

 	 	        Kraft condensates	8	1	8	104	832	42	83	$90,500

 	 	        CCA2	8	1	8	52	416	21	42	$45,250

 	 	        Bleaching 	6	1	6	102	612	31	61	$66,570

 	 	        Paper prod	6	1	6	366	2,196	110	220	$238,867

 	 	        HAP additives	20	1	20	366	7,320	366	732	$796,223

 	 	        WW	6	1	6	386	2,316	116	232	$251,920

 	 	        PI Emissions test data3	 	 	 	 	 	 	 	 

 	 	Reports for chemical pulping (4 reports)	1	4	4	120	480	24	48
$52,211

 	 	Reports for non-chemical pulping, papermaking, and bleaching (1
report for each process)	1	1	1	515	515	26	52	$56,018

 	 	    iii.  Gather and scan/copy emission test reports for
submittal3,4	 	 	 



	 

 	 	        Reports for chemical pulping (4 reports)	1.5	4	6	120	720
36	72	$78,317

 	 	        Reports for non-chemical pulping, papermaking, and
bleaching  (1 report for each process)	1.5	1	1.5	515	773	39	77	$84,028

 	 	    iv. Complete and submit Part I CEMS spreadsheet5	10	1	10	120
1,200	60	120	$130,528

 	 	    v. Complete and submit Part I optional cost spreadsheet6	10	1
10	96.5	965	48	97	$104,967



vii.  Complete signed certification form for part I	0.2	1	0.2	386	77	4	8
$8,397



b. Part II: NEI Update









 	 	    i. Complete and submit survey spreadsheet tabs, as follows:	 
 	 	 	 	 	 	 

 	 	       Mills that previously updated their NEI for RTR	120	1	120
105	12,600	630	1,260	$1,370,549

 	 	       Mills that have not previously updated NEI for RTR	180	1
180	182	32,760	1,638	3,276	$3,563,426

 	 	       Mills with no prior NEI data	280	1	280	99	27,720	1,386
2,772	$3,015,207



ii.  Complete signed certification form for part II	0.2	1	0.2	386	77	4	8
$8,397



a. Part III: Chemical Recovery Combustion Sources











    i. Complete and submit survey spreadsheet tabs, as follows:











        PIII Equip detail	20	1	20	120	2,400	120	240	$261,057



        PIII Permit limits	20	1	20	120	2,400	120	240	$261,057



        PIII Controls	15	1	15	120	1,800	90	180	$195,793

 	 	        PCC	4	1	4	30	120	6	12	$13,053



        PIII Emissions test data3	1	14	14	120	1,680	84	168	$182,740

 	 	    ii. Gather and scan/copy emission test reports for
submittal3,4	 1.5	 14	 21	120	2,520	126	252	 $274,110

 	 	    iii. Complete and submit Part III CEMS spreadsheet5	30	1	30
120	3,600	180	360	$391,585

 	 	    iv. Complete and submit Part III optional cost spreadsheet6	30
1	30	30	900	45	90	$97,896

	         v.  Complete signed certification form for part III	0.2	1	0.2
120	24	1	2	$2,611

 	C. Create Information (Included in 4B)	 	 	 	 	 	 	 	 

 	D. Gather Existing Information (Included in 4B)	 	 	 	 	 	 	 
 

 	E. Write Report (Not  Applicable)	 	 	 	 	 	 	 	 

5. RECORDKEEPING REQUIREMENTS (Not applicable)	 	 	 	 	 	 	 	 

TOTAL ANNUAL LABOR BURDEN AND COST	 	 	 	 	159,779	7,989	15,978
$17,379,742

	 	 	 	total= 	              183,746	avg hr/mill=	476	 $         
45,025

 	 	 	 	 	 	 	 

 	 

ANNUAL CAPITAL COSTS (Not Applicable)	 	 	 	 	 	 	 	 $           
      -   

ANNUALIZED CAPITAL COSTS (Not Applicable)	 	 	 	 	 	 	 	 $       
          -   

TOTAL ANNUAL COSTS (O&M)7	 	 	 	 	 	 	 	 $                  6,948

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)	 

	 	 	 	 	 	 	 $                  6,948



1. The number of respondents per year is based on the mill counts listed
in Part B, Section 1 - Respondent Universe. 

2. Assumes that 50% of kraft mills use the clean condensate alternative
(CCA).

3. It is estimated that chemical pulp mills will submit 18 test reports
each (4 in response to Part I and 14 in response to Part III), and that
non-chemical pulp mills, bleach plants, and paper mills will each submit
1 test report.

4. It is estimated that it would take 1.5 hours to locate and scan or
copy each test report.

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

6. Assumes that 25% of mills will provide cost information.

7. Postage Costs for mailing survey responses to EPA are estimated at $6
for Federal Express letter size envelope flat rate (1 per respondent –
i.e., 3 total).Attachment 3.

Agency Burden and Costs

Agency Activity	(A) EPA Hours/ Occurrence	(B) Occurrences/
Respondent/Year	(C) EPA Hours/Respondent/Year (A x B)	(D)
Respondents/Year1	(E) EPA Technical Hours/ Year (C x D)	(F) EPA
Managerial Hours/Year 

(E x 0.05)	(G) EPA Clerical Hours/Year (E x 0.10)	(H) Cost, $

Develop/revise questionnaire spreadsheets and instructions	400	1	400	1
400	20	40	$24,547

Develop survey webpage	10	1	10	1	10	1	1	$614

Pre-populate mill spreadsheets with existing NEI data2	1	1	1	287	287	14
29	$17,613

Mail out questionnaire3	0.7	1	0.7	386	270	14	27	$16,582

Review claims that survey is not required to be completed due to area
source status, mill closure, or because mill does not produce pulp,
perform bleaching, or manufacture paper products4	1	1	1	57.9	58	3	6
$3,553

Answer respondent questions via phone, email, and/or frequently asked
questions posted on webpage5 	1	1	1	96.5	97	5	10	$5,922

Analyze requests for confidentiality6	1	1	1	96.5	97	5	10	$5,922

Review signed certification forms	0.1	1	0.1	386	39	2	4	$2,639

Review and analyze responses (including follow-up)	 	 	 	 	 	 	 
 

NEI data (from Part II)	4	1	4	386	1,544	77	154	$94,753

Sector survey spreadsheet data (from Parts I and III)	8	1	8	386	3,088
154	309	$189,504

CEMS data (from Parts I and III)7	2	1	2	120	240	12	24	$14,728

Optional cost data (from Parts I and III)8	2	1	2	96.5	193	10	19	$11,844

Print emissions test reports9	0.1	2,675	267.5	1	268	13	27	$16,416

Enter emissions test data from test reports	 	 	 	 	 	 	 	 

Reports for chemical pulping (18 reports)	 	 	 	 	 	 	 	 

Enter PM, chlorine, HCl, methanol, THC, NOx,

SO2, CO	1	16	16	120	1,920	96	192	$117,827

Enter speciated HAP metals, PM2.5 (filterable

and condensable), CDD/CDF, speciated TRS,

POM/PAH	2	2	4	120	480	24	48	$29,457

Reports for non-chemical pulping, papermaking, and

bleaching  (1 report for each process)	1	1	1	515	515	26	52	$31,605

Review/analyze emissions test data10	0.5	2,675	1,337.5	1	1,338	67	134
$82,080

 	 	 	 	 	 	 	 	 

Total Annual Hours	 	 	 	 	10,842	542	1,084	$665,333

 	 	 	 	 	 	            12,468 	hours	 

Expenses (O&M)11	 	 	 	 	 	 	 	 

   Printing questionnaire	 	 	 	 	 	 	 	$1,351

   Flash drives	 	 	 	 	 	 	 	$2,702

   Postage	 	 	 	 	 	 	 	$2,316

  Computer storage of data	 	 	 	 	 	 	 	$1,915

Total Expenses	 	 	 	 	 	 	 	$8,284

TOTAL ANNUAL LABOR BURDEN AND COST	 	 	 	 	 	 	 	$673,617



1. The number of respondents per year is based on the mill counts listed
in Part B, Section 1 - Respondent Universe. 

2. The number of respondents per year excludes mills that are not
already included in the NEI.

3. Mailout package includes section 114 letter with standard enclosures,
hard copy of survey overview document, and flash drive containing
spreadsheet files. Assumes EPA will mail one questionnaire per facility.

4. Assumes 15% of mills provide documentation of area source status,
mill closure, or that pulping, bleaching, papermaking is not performed
at the mill.  It is not known how many of these claims will be valid so
this number of mills has not been subtracted from the burden estimates
associated with completing the survey.

5. Assumes that 25% of the facilities will have questions.

6. Assumes that 25% of facilities will have confidential data.

7. Assume all chemical pulp mills populate the CEMS spreadsheet with
CEMS and/or COMS data.

8. Assume 25% of mills will provide cost information. 

9. Assumes 18 test reports for chemical pulp mills (from Parts I and
III), plus 1 test report each for non-chemical pulp mills, bleach
plants, and paper mills. 

10. Some emissions test results will require little time for analysis
(e.g., those within the range of other test results), while others will
require additional time (e.g., best performers).  Expect to spend an
average of 0.5 hr per test result.

11. Copy costs are estimated for 70 pages at $0.05/page.  Flash drives
were quoted at $7/each.  Postage Costs are estimated at $6 for Federal
Express letter size envelope flat rate.  Data storage estimated at
$21/GB/mo, assuming 25 MB per response for chemical pulp mills and 5 MB
per response for non-chemical pulping, papermaking, and bleaching mills.
 Webpage cost estimated at $85/mo for 6 months.

There is a “lag time” associated with compiling large State or
national emission inventories.  For example, an updated version of the
NEI database is compiled every three years, but the information
contained in the NEI may be based on prior years if states do not submit
current data.  There can also be a “lag time” associated with
posting of recent permits to State websites (particularly if permits are
only posted every 5 years as they are reviewed).  

 As defined in 40 CFR Part 63, subpart A, “Major source” means any
stationary source or group of stationary sources located within a
contiguous area and under common control that emits or has the potential
to emit considering controls, in the aggregate, 10 tons per year or more
of any hazardous air pollutant or 25 tons per year or more of any
combination of hazardous air pollutants, unless the Administrator
establishes a lesser quantity, or in the case of radionuclides,
different criteria from those specified in this sentence.

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