SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
Part
63,
Subpart
S)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
part
63,
subpart
S)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Pulp
and
Paper
Production
were
proposed
on
December
17,
1993,
and
promulgated
on
April
15,
1998.
These
regulations
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
(
HAP)
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.

In
general,
all
NESHAP
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
NESHAP
standards.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
documents,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
notifications,
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Approximately
137
sources
are
subject
to
the
standard,
and
it
is
estimated
that
no
new
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
subpart
S
rule
making,
and
consultation
with
the
industry.
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
percent
of
the
affected
facilities
will
rebuild
one
or
more
process
units
in
a
given
year.
2
The
Office
of
Management
and
Budget
(
OMB)
approved
the
currently
active
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
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,
HAPs
from
pulp
and
paper
plants,
which
include
acetaldehyde;
benzene;
carbon
disulfide;
chloroform;
formaldehyde;
methanol;
methyl
ethyl
ketone;
toluene;
and
xylene
emissions,
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
for
this
source
category
were
promulgated
at
40
CFR
part
63,
subpart
S.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
pulp
and
paper
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
pulp
and
paper
plants
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
collection
of
HAP
emissions
in
enclosed
and
closed
vent
collection.
The
collected
HAPs
are
then
either
incinerated
in
a
boiler
or
lime
kiln
or
treated
in
a
wastewater
treatment
system.
HAPs
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
3
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
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
their
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
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
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

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.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
Office
of
Management
and
Budget
(
OMB)

An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
May
25,
2004,
(
69
FR
29718).
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
EPA
consulted
Timothy
Hunt
of
the
American
Forest
and
Paper
Association
(
202­
463­
2588)
to
obtain
information
on
the
industry
and
associated
burden
for
this
ICR.
EPA
also
4
consulted
its
Air
Facility
System
(
AFS)
to
identify
sources
subject
to
the
standard.

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
at
5
CFR
1320.5.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
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.
5
Standard
SIC
Codes
NAICS
Codes
40
CFR
Part
63,
Subpart
S
2611
Pulp
mills
32211
2621
Paper
mills
32212
2631
Paperboard
mills
32213
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.

A
source
must
make
the
following
reports:

Notification
Reports
Requirement
Regulation
reference
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)

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)
6
Notification
Reports
Source
status
report
63.10(
e)(
3)

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

A
source
must
maintain
the
following
records:

Recordkeeping
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
five
years.
Records
must
be
kept
onsite
for
the
first
two
years,
for
the
remaining
three
years
records
can
be
kept
in
a
readily
accessible
off­
site
location.
63.454
Site
Specific
Inspection
Plans
63.454(
b)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
automated
parameter
data
in
an
automated
way,
e.
g.,
inlet
and
outlet
concentrations
when
determining
percent
efficiency.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
Modern
pulp
and
paper
facilities
employ
distributive
controls
on
their
manufacturing
process
and
have
integrated
many
of
the
compliance
record
keeping
and
reporting
requirements
into
their
systems.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
7
electronic
reporting.

(
ii)
Respondent
Activities
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
the
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;
semiannual
summary
report;
continuous
monitoring/
exceedance
reports;
notifications
of
performance
tests,
construction/
reconstruction,
and
actual
startup.

Enter
information
required
to
be
recorded
for
continuous
monitoring
for
operating
parameters,
periodic
inspections
(
monthly
visual
and
annual
Method
21)
startups,
shutdowns
and
malfunctions,
personnel
training
and
time
for
audits.
8
Respondent
Activities
Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

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

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

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

Transmit,
or
otherwise
disclose
the
information.

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
Air
Facility
System
(
AFS).

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,
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
9
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

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

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
dominant
in
their
field
of
operations.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

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
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
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
part
63,
subpart
S).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
To
minimize
burden,
much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
onsite
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.
10
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
42,444
hours
(
Total
Labor
Hours
from
Table
1).
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
NESHAP
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:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
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/
Startup
vs.
Operation
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
are
for
parametric
monitoring
and
these
systems
are
already
in
place;
therefore,
no
new
equipment
would
be
required
by
the
recordkeeping
and
reporting
requirements.
It
is
assumed
that
all
mills
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
for
air
and
water
tests.

Based
on
EPA's
experience
the
testing
methods
required
for
this
rule,
the
purchase
of
service
for
each
method
is
estimated
as
follows:
11
°
Method
308
­
$
14,000;
°
Method
26A
­
$
10,000;
°
Method
304
­
$
11,000;
°
Method
305
­
$
16,000;
and
°
Method
21
­
$
3,000.

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

°
Method
308
­
1
Tests
x
$
14,000
=
$
14,000
°
Method
26A
­
0
Tests
x
$
10,000
=
$
0
°
Method
304
­
2
Tests
x
$
11,000
=
$
22,000
°
Method
305
­
5
Tests
x
$
16,000
=
$
80,000
°
Method
21­
87
Tests
x
$
3,000
=
$
261,000
TOTAL
$
377,000
Based
on
these
estimates
for
testing
costs
and
the
number
of
mills
assumed
to
perform
compliance
tests,
the
total
annual
cost
to
the
industry
is
$
377,000.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
48,813
see
Table
2
in
Section
6(
e).

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

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost.
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
and
reports
maintained
by
the
respondents,
periodic
evaluation
of
sources
of
emissions,
and
the
analysis,
publication
and
distribution
of
collected
12
information.
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
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.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
there
are
approximately
137
existing
sources
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Respondents
that
Keep
Records
But
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
137
0
0
137
2
0
137
0
0
137
3
0
137
0
0
137
Average
0
137
0
0
137
To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
137.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
13
Total
Annual
Responses
Semiannual
report
137
2
0
274
Exceedance
report
21
2
0
42
Compliance
strategy
report
update
27
1
0
27
Notification
of
performance
test
24
1
0
24
Notification
of
construction/
reconstruction
21
1
0
21
Notification
of
actual
startup
21
1
0
21
Total
409
The
number
of
Total
Annual
Responses
is
409.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
2,708,125.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
part
63,
subpart
S)
attached.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
377,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
1,240
labor
hours
at
a
cost
of
$
49,158.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
part
63,
subpart
S)
attached.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
2,708,125.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
part
63,
subpart
S)
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
14
average
104
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
377,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
1,240
labor
hours
at
a
cost
of
$
49,158.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Pulp
and
Paper
Production
(
40
CFR
Part
63,
Subpart
S)
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
reduction
in
annual
burden
due
to
an
improved
estimate
of
the
number
of
facilities.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
104
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0019,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
The
EPA
Docket
15
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0019
and
OMB
Control
Number
2060­
0387
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
