1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
/
Maximum
Achievable
Control
Technology
(
MACT),
40
CFR
Part
63
Subpart
S,
Pulp
and
Paper
Source
Category
­
Process
Operations
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
­
MACT
Subpart
S,
Pulp
and
Paper
Production
Source
Category
­
Process
Operations
1(
b)
Short
Characterization/
Abstract
In
general,
all
MACT
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
MACT
standards.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

The
Maximum
Achievable
Control
Technology
(
MACT)
standards
for
the
Pulp
and
Paper
Production
Source
Category
were
proposed
on
December
17,
1993,
and
promulgated
on
April
15,
1998.
These
standards
apply
to
facilities
that
produce
pulp,
paper,
or
paperboard
by
employing
kraft,
soda,
sulfite,
semi­
chemical,
or
mechanical
pulping
processes
using
wood;
or
any
process
using
secondary
or
non­
wood
fiber
and
that
emits
10
tons
per
year
or
more
of
any
hazardous
air
pollutant
or
25
tons
per
year
or
more
of
any
combination
of
hazardous
air
pollutants.
Affected
sources
are
all
the
hazardous
air
pollutant
emission
points
or
the
HAP
emission
points
in
the
pulping
and
bleaching
system
for
mechanical
pulping
processes
using
wood
and
any
process
using
secondary
or
non­
wood
fiber.

This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
SUBPART
S.

Approximately
162
sources
are
subject
to
the
standard,
and
it
is
estimated
that
no
new
2
sources
will
become
subject
to
the
standard
in
the
next
three
years.
It
is
further
assumed
that
there
is
one
affected
facility
per
plant.
These
assumptions
are
based
on
the
research
conducted
by
EPA
during
the
recent
rule
making.
EPA
is
also
aware
that
this
industry
is
undergoing
widespread
consolidation
and
corporate
restructuring,
and
that
no
new
facilities
are
being
built,
though
approximately
15%
of
the
affected
facilities
will
re­
build
units
in
a
given
year.

Respondents
are
required
to
monitor
and
keep
records
of
specific
operating
parameters
for
each
control
device
and
to
perform
and
document
periodic
inspections
of
the
closed
vent
and
wastewater
conveyance
systems.
All
respondents
must
submit
semi­
annual
summary
reports
of
monitored
parameters.
Respondents
must
submit
an
additional
monitoring
report
during
each
quarter
in
which
monitored
parameters
were
outside
the
ranges
established
in
the
standard
or
during
initial
performance
tests.
A
source
identified
to
be
out
of
compliance
with
the
NESHAP
will
be
required
to
submit
quarterly
reports
until
the
Administrator
is
satisfied
that
the
source
has
corrected
its
compliance
problem.

The
cost
of
this
Information
Collection
Request
for
the
162
respondents
subject
to
the
standards
is
estimated
at
$
3,128,838.

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.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

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

In
the
Administrator's
judgment,
total
hazardous
air
pollutants,
which
include:
acetaldehyde,
benzene,
carbon
disulfide,
chloroform,
formaldehyde,
methanol,
methyl
ethyl
ketone,
toluene
and
xylenes
emissions
from
Pulp
and
Paper
Source
Category
­
Process
Operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
3
Therefore,
MACT
standards
were
promulgated
for
this
source
category
at
40
CFR
Part
63
Subpart
S.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
Total
Hazardous
Air
Pollutants
from
Pulp
and
Paper
Source
Category
­
Process
Operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
Total
Hazardous
Air
Pollutants
from
Pulp
and
Paper
Source
Category
­
Process
Operations
result
from
the
operation
of
the
pulping,
bleaching
and
wastewater
handling
units.
These
standards
rely
on
the
collection
of
total
hazardous
air
pollutant
emissions
in
enclosed
and
closed
vent
collection.
The
collected
total
HAP's
are
then
either
incinerated
in
a
boiler
or
lime
kiln
or
treated
in
a
wastewater
treatment
system.
HAP's
captured
from
bleaching
systems
are
controlled
with
a
chlorine
gas
scrubber.
Equipment
inspection,
performance
tests,
and
leak
detection
and
repair
procedures
are
critical
components
of
the
standards.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
system
is
properly
installed
and
operated
and
that
leaks
are
being
detected
and
repaired
and
that
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.

The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
MACT
continue
to
operate
their
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
S.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
a
copy
of
the
report
submitted
to
the
State
or
Local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
4
exists.

To
minimize
burden,
much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
on­
site
at
the
facility.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
the
EPA.
In
addition,
in
many
cases
the
EPA
has
selected
parameters
for
monitoring
that
are
already
monitored
by
facilities
for
other
purposes.

Some
of
the
facilities
subject
to
this
NESHAP
will
also
be
subject
to
requirements
under
the
New
Source
Performance
Standard
(
NSPS)
for
kraft
pulp
mills,
40
CFR
60
Subpart
BB.
The
burden
requested
for
this
NESHAP
does
not
duplicate
any
of
the
burden
accounted
for
under
NSPS
Subpart
BB.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
February
1,
2001,
(
66
FR
8591);
no
comments
were
received.

3(
c)
Consultations
No
consultations
were
conducted..

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
5
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
Respondents
are
owners
or
operators
of
sources
associated
with
the
production
of
wood
pulp,
including
but
not
limited
to
kraft,
soda,
sulfite,
semi­
chemical,
mechanical,
non­
wood
pulping,
secondary
fiber,
or
any
combination
of
these
types
of
pulping
processes.
Affected
processes
at
the
wood
pulping
sources
include
pulping,
bleaching,
and
wastewater
handling.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
2611
(
pulp
mills).
The
NAICS
code
is
3221
(
pulp,
paper
and
paperboard
mills).

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
S,
Pulp
and
Paper
Production
Source
Category,
and
referenced
portions
of
Subpart
A,
General
Provisions.

A
source
must
make
the
following
reports
Reports
for
MACT
SUBPART
S
Construction/
reconstruction
63.5
Construction
or
modification
application
63.455(
d)

Initial
notifications
63.9(
b)(
2)

Anticipated
startup
63.9
(
b)

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

Initial
performance
test
results
63.10(
d)(
2)
Reports
for
MACT
SUBPART
S
6
Initial
performance
test
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Compliance
status
63.9(
h)

Physical
or
operational
change
63.5(
b)(
4)

Opacity
or
visible
emissions
n/
a
Periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Source
status
report
63.10(
e)(
3)

Semi­
annual
Control
Strategy
Update
(
thru
2006)
63.455(
b)

A
source
must
maintain
the
following
records
Recordkeeping
for
MACT
SUBPART
S
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

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

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
are
required
to
be
retained
for
5
of
Years.
Records
must
be
kept
onsite
for
the
first
2
years,
for
the
remaining
3
years
records
can
be
kept
in
a
readily
accessible
off­
site
locate.
63.454
Site
Specific
Inspection
Plans
63.454(
b)

ii.
Respondent
Activities
7
Respondent
Activities
Read
instructions.

Install,
calibrate,
certify,
maintain,
and
operate
Continuous
Monitoring
Systems
(
CMS)
for
each
of
the
following
affected
units:
1.1
Non­
Sulfite
Pulping
Process
choice
of:
a.
provide
documentation
that
vent
streams
are
introduced
to
the
flame
zone
of
a
boiler,
lime
kiln,
or
recovery
furnace,
or
b.
provide
documentation
that
the
control
incinerator
is
operating
at
a
minimum
level
of
1600
F
and
0.75
second
residence
time,
or
c.
Performance
test
of
control
device
using
Method
308.
1.2.
Sulfite
Pulping
Process
­
performance
test
of
control
device
using
test
method
308
2.1.
Bleaching
Process
Vent
Scrubber
(
MACT
I
Mills)
choice
of:
a.
provide
documentation
of
scrubber
operating
parameters
or
previous
performance
test
results,
or
b.
performance
test
of
scrubber
or
control
device
using
test
Method
26A.
2.2
Bleaching
Process
Vent
Scrubber
(
MACT
III
Mills)
choice
of:
a.
provide
documentation
of
scrubber
operating
parameters,
or
previous
performance
test
results,
or
b.
performance
test
of
scrubber
or
control
device
using
test
Method
26A.
3.1
Non­
Sulfite
Pulping
Wastewater
Treatment
a.
performance
test
of
condensate
segregation
and
control
device
using
test
method
305
or
b.
performance
test
of
biotreatment
unit
using
test
Method
304.
3.2
Sulfite
Pulping
Process
a.
performance
test
of
control
device
using
test
Method
305.

Perform
following
initial
performance
test
using
appropriate
Reference
test
Methods
26A,
304,
305,
308,
and
repeat
performance
tests
if
necessary.

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

Write
the
notifications
and
reports
for:
Initial
Notification;
compliance
status;
initial
compliance
strategy
report;
compliance
strategy
report
update;
semi­
annual
summary
report;
continuous
monitoring/
exceedance
reports;
notifications
of
­
performance
tests,
construction/
reconstruction,
anticipated
startup,
and
actual
startup.

Enter
information
required
to
be
recorded
for
continuous
monitoring
for
operating
paramaters,
periodic
inspections
(
monthly
visual
and
annual
Method
21)
startups,
shutdowns
and
malfunctions,
personnel
training
and
time
for
audits.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.
Respondent
Activities
8
Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

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

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

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

Transmit,
or
otherwise
disclose
the
information.

While
it
possible
that
some
State
Agencies
to
whom
this
regulation
has
been
delegated
may
have
established
electronic
means
of
reporting
for
their
permittees
the
staff
contacted
by
EPA
had
only
knew
only
of
regular
mail
submissions.
Modern
pulp
and
paper
facilities
employ
distributive
controls
on
their
manufacturing
process
and
have
integrated
many
of
the
compliance
record
keeping
and
reporting
requirements
into
their
systems.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions,
such
as,
control
device
fire
box
temperature,
9
gas
and
liquid
flow
rates,
production
volume,
wood
species,
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.
Records
must
be
kept
on­
site
for
the
first
2
years.
For
the
remaining
3
years,
the
records
must
be
stored
on­
site
or
at
a
location
where
they
can
be
readily
accessed.

5(
c)
Small
Entity
Flexibility
Approximately
20
percent
of
the
industry
are
considered
small
business
entities,
defined
as
being
independently
owned
and
operated
and
not
dominate
in
their
field
of
operations.
Even
though
the
recordkeeping
requirements
are
the
same
for
small
and
large
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant(
s).
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
Even
though,
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
Subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
10
major
assumptions
have
been
identified.
To
minimize
burden,
much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
on
site
at
the
facility.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
the
EPA.
In
addition,
in
many
cases
the
EPA
has
selected
parameters
for
monitoring
that
are
already
monitored
by
the
industry
for
other
purposes.
Responses
to
this
information
collection
are
mandatory.

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

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
50,232
(
from
Table
2)
total
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
MACT
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial,
$
55.34
per
hour
for
Technical,
and
$
35.64
per
hour
for
Clerical.
These
rate(
s)
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate(
s)
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
78.54
($
37.40
+
110%)
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+
110%)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Since
no
continuous
emission
monitors
are
used
to
comply
with
this
rule,
the
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs
and
emission
testing
costs
described
below.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Since
this
rule
does
not
require
any
continuous
emission
monitoring
or
electronic
data
submittal,
total
capital
costs
are
expected
to
be
insignificant.
Continuous
monitoring
requirements
11
are
for
parametric
monitoring
and
these
systems
are
already
in
place;
therefore,
no
new
equipment
would
be
required
by
the
recordkeeping
and
reporting
requirements.
Start
up
costs
are
expected
to
be
attributed
to
emissions
testing
activities.
It
is
assumed
that
all
mills
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
for
air
and
water
tests.
Based
on
EPA's
experience
the
testing
methods
required
for
this
rule,
the
purchase
of
service
for
each
method
is
estimated
as
follows:
·
Method
308
­
$
12,000;
·
Method
26A
­
$
8,500;
·
Method
304
­
$
9,500;
·
Method
305
­
$
14,000;
and
·
Method
21
­
$
2,500.

These
estimates
include
labor,
materials,
and
analytical
costs.
The
number
of
mills
assumed
to
contract
testing
companies
for
compliance
is
presented
in
Table
2.
For
the
entire
industry,
the
number
of
tests
required
annually
for
demonstrating
compliance
and
the
associated
cost
are
estimated
as
follows:

·
Method
308
­
2
Tests
x
$
12,000
=
$
24,000
·
Method
26A
­
0
Tests
x
$
8,500
=
0
·
Method
304
­
2
Tests
x
$
9,500
=
19,000
·
Method
305
­
5
Tests
x
$
14,000
=
70,000
·
Method
21­
103
Tests
x
$
2,500
=
257,500
TOTAL
$
370,500
Based
on
these
estimates
for
testing
costs
and
the
number
of
mills
assumed
to
perform
compliance
tests,
the
total
annual
cost
to
the
industry
is
$
370,500.
The
total
cost
for
this
3
year
ICR
is
$
1,482,000.
($
370,000
x
3
=
$
1,482,000)

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
189,483
(
from
Table
1).
This
cost
is
based
on
an
hourly
labor
rate
of
$
68.19
for
managerial
staff,
$
36.86
for
technical
staff,
and
$
27.36
for
administrative/
clerical
staff.
These
rates
are
from
OPM's
2001
General
Schedule
(
GS)
base
annual
salary
data,
excluding
locality
pay,
basic
rates,
and
travel
associated
with
compliance
activities.
To
derive
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080
which
is
the
average
number
of
hours
worked
during
the
Federal
calendar
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
to
account
for
overhead
expenses.
Details
upon
which
this
estimate
is
based
appear
12
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Title
(
A)
#
new
sources
per
year
(
B)
#
of
initial
reports
for
new
sources
(
C)
#
existing
sources
(
D)
#
of
reports
for
existing
sources
(
E)
total
annual
responses
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
the
Pulp
and
Paper
Industry
0
0
162
162
semi­
annual
reports
x
2
=
324
24
exceedance
reports
x
2
=
48
Other
once
annual
reports
=
128
(
notifications
for:
performance
test,
construction/
recons
truction,
anticipated
startup,
actual
startup)
324+
48+
128
=
500
The
number
of
total
respondents
is
162.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year.

The
total
annual
responses
is
500.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
hours
are
50,232.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
370,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
These
costs
are
detailed
in
section
6
b
(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
For
details
on
industry
and
agency
burden
see
attached
tables,
Table
1
Annual
Agency
Burden
and
Cost
of
Record
Keeping
and
Reporting
requirements
of
the
NESHAP
for
the
Pulp
and
Paper
Production
Source
Category
 
Process
Operations
and
Table
2
Annual
Respondent
Burden
and
Cost
of
record
Keeping
and
Reporting
Requirements
of
the
13
NESHAP
for
the
Pulp
and
Paper
Production
Source
Category
 
Process
Operations
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.

(
1)
The
sharp
reduction
in
burden
for
respondent
facilities
is
due
to
the
fact
that
nearly
all
sources
have
completed
the
required
one­
time
activities,
such
as
initial
performance
tests,
during
the
first
3
years
of
the
ICR
cycle,
which
corresponds
to
the
compliance
date
of
this
MACT
standard.

(
2)
Adjustments
have
also
been
made
to
simplify
the
annual
cost
calculations,
which
are
now
calculated
with
simple
averages
instead
of
the
amortization
schedules
used
previously.

(
3)
Adjustments
to
the
labor
rates
used
to
estimate
burden
for
this
ICR
also
impacted
the
total
costs.

(
4)
Having
made
their
initial
notification,
331
facilities,
the
non­
bleaching
MACT
III
mills,
that
were
accounted
for
in
the
original
ICR,
have
been
eliminated
from
the
respondent
total
since
they
have
no
further
obligation
under
the
MACT.

6(
g)
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1657.04
and
OMB
Control
Number
2060­
0387
in
any
correspondence.
14
Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
