1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills."
This
is
a
new
information
collection
request
(
ICR),
and
a
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
has
not
been
assigned.

(
b)
Short
Characterization
(
i)
Applicability.
Respondents
are
owners
and
operators
of
new
and
existing
chemical
recovery
combustion
sources
at
kraft,

soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills.
Chemical
recovery
combustion
sources
are
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions
either
by
themselves,
or
because
they
are
located
with
other
major
sources
of
HAP.
A
major
source
of
HAP
is
a
facility
that
emits,
or
has
the
potential
to
emit,
any
single
HAP
at
a
rate
of
10
tons
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
or
more
per
year.

There
are
currently
114
kraft,
2
soda,
11
sulfite,
and
13
stand­
alone
semichemical
pulp
mills
in
the
United
States.
Of
the
140
facilities
that
comprise
the
pulp
and
paper
production
source
category,
136
are
expected
to
meet
the
applicability
criteria
defined
in
the
final
rule.
No
new
facilities
(
pulp
mills)
are
expected
to
be
constructed
in
the
next
5
years;
however,

approximately
20
new
recovery
furnaces,
20
new
smelt
dissolving
tanks
(
SDT's),
and
15
new
lime
kilns
are
expected
to
be
constructed
at
existing
kraft
pulp
mills
in
the
next
5
years.
In
addition,
two
new
semichemical
combustion
units
and
no
new
soda
2
or
sulfite
combustion
sources
are
expected
to
be
constructed
in
the
next
5
years.

(
ii)
Chemical
recovery
combustion
sources
at
kraft,
soda,

sulfite,
and
stand­
alone
semichemical
pulp
mills.
Owners
or
operators
of
chemical
recovery
combustion
sources
at
kraft,
soda,

sulfite,
and
stand­
alone
semichemical
pulp
mills
subject
to
the
rule
must
install
and
monitor
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level.

Owners
or
operators
are
required
to
install,
operate
and
maintain
a
continuous
monitoring
system
(
CMS),
either
a
continuous
opacity
monitoring
system
(
COMS)
or
a
continuous
parameter
monitoring
system
(
CPMS),
to
demonstrate
compliance
with
the
standards
in
the
final
rule.

To
ensure
compliance
with
the
HAP
metal
standards,
owners
or
operators
of
kraft
and
soda
recovery
furnaces
and
lime
kilns
equipped
with
electrostatic
precipitators
(
ESP's)
would
be
required
to
maintain
opacity
levels
below
a
specified
level.

Owners
or
operators
of
sources
equipped
with
control
devices
other
than
ESP's
would
be
required
to
establish
control
device
or
process
operating
parameter
ranges
that
indicate
the
control
device
or
process
is
being
operated
and
maintained
in
accordance
with
good
air
pollution
control
practices.
The
control
device
or
process
operating
parameter
ranges
would
be
established
during
the
initial
performance
test
or
subsequent
performance
tests.

Owners
or
operators
complying
with
the
gaseous
organic
HAP
standard
for
new
kraft
and
soda
recovery
furnaces
that
use
a
nondirect
contact
evaporator
(
NDCE)
recovery
furnace
with
a
dry
ESP
system
are
exempt
from
monitoring
requirements
for
gaseous
organic
HAP's
because
the
use
of
this
equipment
ensures
continuous
compliance
with
the
standard.

The
respondents
are
subject
to
the
sections
of
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include
those
associated
with
the
initial
notifications;
notifications
of
3
performance
tests;
notifications
of
COMS/
CPMS
performance
evaluations;
notifications
of
compliance
status,
including
the
results
of
performance
tests;
startup,
shutdown,
and
malfunction
reports;
and
semiannual
compliance
reports.

All
reports
are
to
be
submitted
to
the
respondent's
State
or
local
agency
or
to
the
EPA
Regional
Office,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
rule
are
achieving
the
standards
in
the
rule.

(
iii)
Violations
of
the
standard.
The
rule
includes
two
levels
of
monitoring.
Each
monitoring
level
specifies
maximum
opacities
(
ESP's
only)
and
maximum
frequencies
with
which
the
opacity
or
monitored
parameters
may
exceed
established
levels.

If
the
maximum
exceedance
frequencies
of
the
first
monitoring
level
are
exceeded,
the
owner
or
operator
would
be
required
to
implement
the
corrective
actions
contained
in
their
startup,

shutdown,
and
malfunction
plan
to
bring
the
operating
parameter
or
opacity
levels
back
to
established
levels.
Exceedance
of
the
maximum
exceedance
frequencies
of
the
second
monitoring
level
would
constitute
a
violation
of
the
applicable
standard.
The
purpose
of
the
two­
level
monitoring
approach
is
to
prevent
a
violation
from
occurring
by
requiring
the
owner
or
operator
to
correct
operating
parameter
or
opacity
exceedances
before
the
threat
of
a
violation
arises.

If
the
owner
or
operator
identifies
any
deviation
resulting
from
a
known
cause
for
which
no
Federally­
approved
or
promulgated
exemption
from
an
emission
limitation
or
standard
applies,
the
compliance
report
must
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
action
taken
to
minimize
each
deviation
and
action
taken
to
4
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
monitoring
protocol.

(
iv)
Record
retention.
Owners
or
operators
of
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
standalone
semichemical
pulp
mills
subject
to
the
rule
must
maintain
a
copy
of
all
monitoring
data
that
demonstrate
compliance
with
the
applicable
standards
in
the
rule.
In
addition,
owners
or
operators
electing
to
comply
with
the
emission
limit
or
emission
reduction
requirements
as
described
in
the
rule
must
record
the
average
values
of
equipment
operating
parameters
as
specified
in
§
§
63.864
and
63.866
of
the
rule.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
a
source,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Those
records
must
be
maintained
for
a
minimum
of
5
years.
At
a
minimum,
the
most
recent
2
years
of
data
must
be
retained
onsite.
The
remaining
3
years
of
data
may
be
retained
offsite.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
emission
standards
for
each
category
or
subcategory
of
major
and
area
sources
of
HAP
listed
for
regulation
in
section
112(
b).
These
standards
are
applicable
to
new
or
existing
sources
of
HAP
and
will
require
the
maximum
degree
of
emission
reduction.

The
predominant
HAP's
emitted
from
chemical
recovery
combustion
sources
at
pulp
mills
include
acetaldehyde,
benzene,

formaldehyde,
hydrochloric
acid
(
HCl),
methanol,
methyl
ethyl
ketone,
and
toluene.
In
the
Administrator's
judgement,
the
pollutants
emitted
from
pulp
and
paper
production
cause
or
5
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
this
source
category
was
listed
for
regulation
under
section
112.
(
Note:

Chemical
recovery
combustion
sources
at
pulp
mills
are
a
segment
of
the
larger
pulp
and
paper
production
source
category.)

Section
114(
a)
of
the
CAA
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
the
CAA
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,
as
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.

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
rule
and
to
ensure
that
the
standards,
which
are
based
on
maximum
achievable
control
technology
(
MACT)
for
combustion
sources
at
kraft,
soda,

sulfite,
and
stand­
alone
semichemical
pulp
mills,
are
being
achieved.
After
the
compliance
date,
all
respondents
must
submit
a
semiannual
(
every
6
months)
report
of
compliance
for
chemical
recovery
combustion
sources,
including
the
excess
emissions
and
continuous
monitoring
system
report
containing
the
information
requested
in
§
63.867
of
the
rule.
These
records
and
reports
are
required
under
the
General
Provisions
of
40
CFR
part
63,

subpart
A
(
as
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
CAA
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,

7412,
7414,
7416,
7601]).
6
(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
EPA
enforcement
personnel
to:
(
1)
identify
new,
modified,
reconstructed,
and
existing
sources
subject
to
the
rule;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
EPA
to
identify
facilities
that
are
not
in
compliance
with
the
standards
in
the
rule.
Based
on
reported
information,
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
standards
in
the
rule.

Much
of
the
information
EPA
needs
to
determine
compliance
will
be
recorded
on
a
continuous,
hourly,
operating
shift,
or
daily
basis
and
compiled
monthly.
Such
information
will
be
reviewed
by
enforcement
personnel
during
an
inspection
and
will
need
to
be
summarized
and
reported
on
a
semiannual
basis.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule
(
such
as,
reports
of
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule,
as
indicated
in
§
63.867,
which
references
the
reporting
requirements.

A
search
of
existing
rules
revealed
some
duplication
of
information­
gathering
efforts
where
facilities
are
subject
to
another
rule
(
e.
g.,
Kraft
Pulp
Mills
New
Source
Performance
7
Standards
[
NSPS])
in
addition
to
the
chemical
recovery
combustion
sources
NESHAP.
An
effort
has
been
made
to
eliminate
this
duplication
by
allowing
facilities
to
combine
excess
emission
and/
or
summary
reports
for
the
facility,
as
indicated
in
§
63.867.

(
b)
Consultations
The
EPA
published
a
list
of
categories
of
major
and
area
sources
of
HAP's
on
July
16,
1992
(
57
FR
31576),
under
authority
of
section
112(
c);
this
notice
listed
pulp
and
paper
production
as
a
category
of
major
sources
of
HAP's.
(
As
noted
above,

chemical
recovery
combustion
sources
at
pulp
mills
are
a
segment
of
the
larger
pulp
and
paper
production
source
category.)

Representatives
of
the
affected
companies
and
industry
trade
associations
were
consulted
throughout
the
development
of
the
rule.
The
industry
trade
associations
include
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,

Inc.
(
NCASI)
and
the
American
Forest
and
Paper
Association
(
AF&
PA).
The
State
of
Washington
and
NCASI
provided
all
of
the
long­
term
particulate
matter
(
PM)
emissions
data
that
were
used
to
support
the
PM
emission
limits.
Much
of
the
HAP
emissions
test
data
that
were
used
to
determine
baseline
HAP
emissions
and
emission
reductions
were
collected
as
part
of
an
industrysponsored
test
program
carried
out
by
NCASI.
Since
1991,
EPA
has
met
with
the
pulp
and
paper
industry
groups
four
to
five
times
a
year.
During
these
meetings,
the
industry
representatives
were
given
opportunities
to
comment
on
the
establishment
of
subcategories
and
MACT
floors,
applicable
control
options,

emission
control
costs,
and
the
level
and
format
of
the
standards.
No
specific
information
was
provided
with
respect
to
burden
estimates.
8
(
c)
Effects
of
Less
Frequent
Collection
In
the
first
3
years
following
the
effective
date
of
the
rule,
owners
or
operators
of
existing
sources
will
submit
only
one­
time
notifications
to
EPA.
In
this
instance,
less
frequent
reporting
would
not
be
practical
because
EPA
needs
the
information
provided
in
these
one­
time
notifications.
In
addition
to
the
one­
time
notifications,
owners
or
operators
of
new
and
reconstructed
sources
will
also
submit
semiannual
compliance
reports
in
the
first
3
years
following
the
effective
date
of
the
rule.
If
the
relevant
information
was
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
facilities
are
in
compliance
with
the
standards
in
the
rule.

Less
frequent
collection
could
result
in
long­
term
exceedances
of
the
applicable
standards.

In
addition,
EPA's
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
fewer
resources
than
judicial
proceedings,
both
EPA
and
the
regulated
community
benefit
from
preservation
of
EPA's
administrative
powers.

Also,
the
reporting
frequency
in
the
rule
is
consistent
with
the
requirements
of
title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

(
d)
General
Guidelines
The
rule
requires
that
facilities
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
specified
in
the
general
information
collection
guidelines
in
5
CFR
1320.6(
f)
of
the
Office
of
Management
and
Budget
(
OMB)

regulations
implementing
the
Paperwork
Reduction
Act.
However,

the
5­
year
retention
period
is
consistent
with
the
retention
9
requirement
in
the
General
Provisions
in
subpart
A
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
40
CFR
part
70.
All
of
the
facilities
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71.
Thus,
the
5­
year
record
retention
requirement
of
the
rule
adds
no
additional
burden.
At
a
minimum,
respondents
will
be
required
to
retain
onsite
the
most
recent
2
years
of
data.
The
remaining
3
years
of
data
could
be
retained
at
a
readily­
accessible
onsite
or
offsite
storage
facility.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
e)
Confidentiality
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,

Subpart
B
 
Confidentiality
of
Business
Information.
(
See
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979.)

(
f)
Sensitive
Questions
The
information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.

Therefore,
this
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.
10
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
114
kraft,
2
soda,

8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills
meeting
the
applicability
criteria
in
the
final
rule
and
classified
as
major
sources
under
section
112
of
CAA.
Thus,
a
total
of
136
respondents
will
be
required
to
comply
with
the
monitoring,

recordkeeping,
and
reporting
requirements
of
the
rule.
The
primary
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)
codes
for
the
respondents
affected
by
the
rule
are
2611/
32211
(
Pulp
Mills),

2621/
32212
(
Paper
Mills),
and
2631/
32213
(
Paperboard
Mills).

(
b)
Information
Requested
(
i)
Data
items.
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
rule
in
the
first
3
years
following
the
effective
date
are
listed
in
the
first
columns
of
Tables
1a
through
1f,
and
are
discussed
in
section
6(
a).
The
respondent
activities
are
described
in
more
detail
in
Attachment
2,
Description
of
Respondent
Activities.
One­
time
and
recurrent
respondent
activities
are
presented
in
Tables
1a
and
1b
for
the
first
year,

Tables
1c
and
1d
for
the
second
year,
and
Tables
1e
and
1f
for
the
third
year.
11
5.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
The
Agency
activities
in
the
first
3
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
2a
through
2c
and
are
discussed
in
section
6(
c).
Tables
2a,
2b,
and
2c
present
the
Agency
activities
for
the
first,

second,
and
third
years,
respectively,
after
the
effective
date
of
the
rule.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
notifications
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
AIRS
is
EPA's
data
base
for
the
collection,

maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
agencies
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
AIRS
data
base
can
be
publicly
accessed
via
the
Internet
at
http://
www.
epa.
gov/
enviro/
index_
java.
html
or
through
a
Freedom
of
Information
Act
request
to
EPA.
Data
obtained
during
periodic
visits
by
EPA
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semiannual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

The
rule
does
not
require
the
use
of
automated,
electronic,

mechanical,
or
other
technological
data
collection
techniques
or
other
forms
of
information
technology.
Although
most
facilities
12
monitor
a
wide
variety
of
process
and
air
pollution
control
device
parameters
on
a
continuous
basis,
store
this
information
using
data
acquisition
systems,
and
record
most
of
these
values
on
an
hourly
basis
using
operator
log
sheets,
the
presence
of
these
data
acquisition
systems,
while
reducing
the
burden
of
data
collection,
is
not
expected
to
reduce
the
burden
of
reporting.

(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
by
EPA.
The
EPA
has
reduced
the
reporting
and
recordkeeping
burden
for
respondents
to
include
only
the
information
that
EPA
needs
to
determine
compliance
with
the
standards
in
the
rule.
The
EPA
has
determined
that
3
companies
meet
the
definition
of
small
entity
 
a
small
business
that
has
fewer
than
750
employees
for
SIC
codes
2611,
2621,
or
2631.
These
3
companies
own
only
3
of
the
136
mills
subject
to
the
final
rule.
The
small
business
analysis
reported
in
the
Economic
Analysis
shows
that
the
affected
mills
have
costs
as
a
percentage
of
sales
ratios
of
less
than
1
percent,
that
these
mills
are
not
expected
to
close
nor
are
the
owning
companies
expected
to
encounter
financial
distress
as
a
result
of
this
rule.

(
d)
Collection
Schedule
Collection
of
data
will
begin
after
the
effective
date
of
the
chemical
recovery
combustion
sources
NESHAP.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

For
all
existing
sources,
the
initial
notification
must
be
submitted
no
later
than
6
months
after
the
effective
date
of
the
rule.
New
sources
for
which
construction
or
reconstruction
has
commenced
and
initial
startup
has
occurred
before
the
effective
date
of
the
rule
must
submit
the
initial
notification
as
soon
as
13
practicable
before
startup
but
no
later
than
60
days
after
the
effective
date
of
the
rule.
New
sources
for
which
the
construction
or
reconstruction
commenced
after
the
effective
date
of
the
rule
must
submit
the
initial
notification
as
soon
as
practicable
before
the
construction
or
reconstruction
commences
(
but
no
sooner
than
the
effective
date
of
the
rule).
New
or
reconstructed
combustion
sources
at
pulp
and
paper
mills
must
comply
immediately
upon
the
effective
date
of
the
promulgated
rule
if
their
startup
date
is
before
the
effective
date
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date.

Facilities
required
to
conduct
a
performance
test
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.

For
each
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
60
days
following
the
completion
of
the
performance
test.

Records
necessary
to
determine
compliance
must
be
compiled
on
a
monthly
basis,
and
compliance
reports
must
be
submitted
to
the
Administrator
on
a
semiannual
basis,
as
discussed
in
section
2(
b).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
for
the
first
3
years
after
the
effective
date
of
the
rule
are
presented
in
Tables
1a
through
1f.
One­
time
and
recurrent
burden
estimates
to
the
industry
are
presented
in
Tables
1a
and
1b
for
the
first
year,
Tables
1c
and
1d
for
the
second
year,
and
Tables
1e
and
1f
for
the
third
year.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.
14
(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs.
The
annual
labor
costs
for
reporting
and
recordkeeping
activities
are
also
presented
in
Tables
1a
through
1f.
The
costs
of
these
activities
were
estimated
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.

Labor
costs
are
divided
into
the
following
three
categories:

(
1)
technical,
(
2)
management,
and
(
3)
clerical.
The
cost
of
technical
labor
was
estimated
at
$
45.04
per
hour
($
45.04/
hr),
the
cost
of
management
labor
at
$
66.73/
hr,
and
the
cost
of
clerical
labor
at
$
28.14/
hr.
These
estimates
include
fringe
benefits,

overhead,
and
profit
rate.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities:
capital
costs
and
operation
and
maintenance
(
O&
M)

costs.
One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
rate.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
(
planning
and
selection),
and
a
data
acquisition
system
(
data
logger,
computer,
logging
and
reporting
software,
and
printer).

No
capital
costs
were
estimated
for
monitoring
equipment
for
the
first
3
years
after
the
effective
date
for
the
following
reasons:

(
1)
no
costs
need
to
be
estimated
for
COMS
or
CPMS
for
the
new
kraft
recovery
furnaces,
SDT's,
and
lime
kilns
installed
during
the
first
3
years
after
the
effective
date
because
those
combustion
units
would
be
subject
to
the
Kraft
Pulp
Mills
NSPS,

which
already
requires
the
monitoring
equipment;
(
2)
no
new
soda
15
or
sulfite
combustion
units
are
expected
to
be
installed
during
the
first
3
years
after
the
effective
date;
and
(
3)
because
thermocouples
and
strip
chart
recorders
are
included
in
the
cost
of
the
regenerative
thermal
oxidizers
(
RTO's)
used
to
control
emissions
from
semichemical
combustion
units,
no
additional
monitoring
costs
would
be
necessary
for
new
semichemical
units
installed
during
the
first
3
years
after
the
effective
date.

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
annualized
capital
cost
per
file
cabinet
is
$
35,

based
on
annualizing
the
capital
cost
over
15
years
and
including
administrative
charges,
property
taxes,
and
insurance
at
4
percent
of
the
capital
cost.
An
estimated
8
mills
will
purchase
this
equipment
in
the
first
year
after
the
effective
date
of
the
rule
and
7
mills
in
the
second
and
third
years.
(
The
number
of
mills
was
determined
based
on
the
assumption
that
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also,
one
existing
stand­
alone
semichemical
pulp
mill
is
projected
to
install
one
new
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.)

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
Only
new
sources
will
be
required
to
conduct
performance
tests
during
the
first
3
years
after
the
effective
date.
Performance
test
costs
for
new
semichemical
combustion
units
were
estimated
based
on
the
following
assumptions:
(
1)
semichemical
mills
will
perform
initial
THC
performance
tests
using
Method
25A,
(
2)
the
cost
of
a
Method
25A
test
is
$
9,500
(
annualized
over
15
years
to
$
1,043),

(
3)
an
estimated
one
new
semichemical
combustion
unit
will
be
16
required
to
conduct
an
initial
THC
performance
test
over
the
first
3
years
after
the
effective
date
(
based
on
an
estimated
two
new
units
installed
over
5
years),
and
(
4)
no
new
semichemical
combustion
units
are
expected
to
have
to
repeat
the
initial
THC
performance
test
due
to
failure
of
the
first
test.

No
capital
costs
were
estimated
for
Method
5
PM
performance
tests
for
new
kraft
combustion
units
installed
during
the
first
3
years
after
the
effective
date
because
those
units
would
be
subject
to
the
Kraft
Pulp
Mills
NSPS.
The
PM
test
costs
for
units
subject
to
the
NSPS
are
assumed
to
be
existing
costs
for
complying
with
existing
State
permits
or
other
State/
local
programs.
Because
no
new
soda
or
sulfite
combustion
units
are
expected
to
be
installed
over
the
first
3
years
after
the
effective
date,
no
Method
5
test
costs
were
estimated
for
those
combustion
units
for
the
first
3
years.

No
capital
costs
were
estimated
for
Method
308
methanol
performance
tests
for
new
kraft
and
soda
recovery
furnaces
installed
during
the
first
3
years
after
the
effective
date.
New
recovery
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
dry
ESP
systems,
which
are
exempted
from
testing
requirements.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
Because
no
monitoring
equipment
costs
are
being
estimated
for
new
combustion
units
installed
during
the
first
3
years
after
the
effective
date
(
for
the
reasons
cited
above),
there
are
no
O&
M
costs
associated
with
monitoring
equipment.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
17
respondents
to
submit
notifications
and
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
were
applied
to
the
200
responses
submitted
during
the
first
year,
the
81
responses
submitted
during
the
second
year,
and
the
95
responses
submitted
during
the
third
year.
(
The
number
of
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents
during
each
of
the
first
3
years
after
the
effective
date,
as
shown
in
Tables
1a
through
1f.)

(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
estimated
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
these
requirements.

In
addition,
no
operational
costs
will
be
incurred
by
the
Federal
Government
because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
Facility
Subsystem,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
facilities.
Periodic
inspections
are
part
of
EPA's
overall
compliance
and
enforcement
program.

Therefore,
this
examination
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
by
the
facilities
in
one­
time
notifications
and
semiannual
compliance
reports
(
unless
the
compliance
report
indicates
a
violation,
thereby
triggering
an
enforcement
action).

Tables
2a,
2b,
and
2c
present
the
estimated
annual
burden
to
the
18
Federal
Government
during
the
first,
second,
and
third
years,

respectively,
after
the
effective
date
of
the
rule.
Labor
costs
were
estimated
based
on
estimated
wage
rates
of
$
45.04/
hr
for
technical
labor,
$
66.73/
hr
for
management
labor,
and
$
28.14/
hr
for
clerical
labor.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Once
the
burden
and
costs
per
activity
have
been
established
on
a
per
respondent
basis,
the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
the
Agency.
To
calculate
the
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.

The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."
The
respondent
universe
varies
among
the
activities
listed
because
not
all
respondents
must
complete
each
activity.

Burden
and
costs
were
estimated
for
an
existing
respondent
universe
of
114
kraft,
2
soda,
8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills
and
a
projected
new
respondent
universe
of
12
kraft
recovery
furnaces
and
associated
SDT's,
9
kraft
lime
kilns,
and
1
semichemical
combustion
unit
over
the
3
years
after
the
effective
date.
Based
on
these
projections,
an
estimated
4
new
kraft
recovery
furnaces
and
SDT's
and
3
new
kraft
lime
kilns
were
assumed
to
be
installed
during
each
of
the
3
years
after
the
effective
date.
The
new
semichemical
combustion
unit
was
assumed
to
be
installed
during
the
first
year
after
the
effective
date.

To
determine
the
burden
for
each
activity
for
technical
staff,
the
number
of
burden
hours
per
respondent
was
multiplied
by
the
number
of
respondents.
Management
and
clerical
labor
hours
were
calculated
at
5
percent
and
10
percent
of
technical
labor
hours,
respectively.
The
total
burden
was
determined
by
summing
the
technical,
management,
and
clerical
burden
hour
19
estimates.
To
determine
the
total
labor
cost,
the
burden
hour
estimates
for
technical,
management,
and
clerical
labor
were
multiplied
by
their
respective
wage
rates
and
then
summed.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
1a
through
1f
and
dividing
the
sums
by
the
3­
year
review
period.
The
total
annual
respondent
burden
hours
and
costs
are
summarized
as
follows:

Total
burden,
hours
Total
costs,
$

Tables
1a
+
1b
(
first
year)
15,300
681,067
Tables
1c
+
1d
(
second
year)
20,935
931,873
Tables
1e
+
1f
(
third
year)
28,349
1,261,898
Total
64,584
2,874,838
Bottom
line
annual
burden
21,528
958,279
The
bottom
line
annual
burden,
averaged
over
the
first
3
years
after
the
effective
date,
is
21,528
labor
hours,
at
a
cost
of
$
958,279.
The
bottom
line
annual
burden
is
presented
in
Box
13c
of
OMB
83­
I.
The
average
annual
burden
per
respondent,
based
on
136
respondents,
is
158
labor
hours,
at
a
cost
of
$
7,046.
The
average
number
of
respondents
is
presented
in
Box
13a
of
OMB
83­
I.

On
average,
there
are
an
estimated
125
total
annual
responses
for
the
first
3
years
after
the
effective
date
of
the
rule.
Of
the
125
total
annual
responses,
approximately
50
percent
are
assumed
to
be
collected
electronically.
The
total
annual
responses
are
an
average
of
the
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
first,
second,
and
third
years
after
the
effective
date.
An
estimated
200
notifications
and
reports
will
be
submitted
during
the
first
20
year,
81
during
the
second
year,
and
95
during
the
third
year.

The
total
annual
responses
and
the
percent
of
responses
collected
electronically
are
presented
in
Boxes
13b
and
13b.
1
of
OMB
83­
I.

As
stated
in
section
6(
b)(
ii),
there
are
no
nationwide
capital
costs
associated
with
monitoring
equipment
for
the
136
existing
pulp
mills
or
the
new
kraft
and
semichemical
combustion
units
installed
during
the
first
3
years
after
the
effective
date.
The
total
nationwide
capital
cost
associated
with
file
cabinets
for
storing
collected
data
and
reports
was
estimated
to
be
$
1,880
in
the
first
year
after
the
effective
date
and
$
1,645
in
each
of
the
second
and
third
years.
The
average
annualized
capital
cost
for
file
cabinets
is
$
525
for
the
3
years
following
the
effective
date.
The
total
nationwide
capital
cost
for
performance
tests
was
estimated
to
be
$
9,500
for
the
first
year
after
the
effective
date,
based
on
one
THC
test
for
one
new
semichemical
combustion
unit.
No
tests
are
anticipated
for
the
other
2
years
after
the
effective
date.
The
average
annualized
capital
cost
for
performance
tests
is
$
1,043
for
the
3
years
following
the
effective
date.
Annual
O&
M
costs,
which
include
photocopying
and
postage
for
the
reports,
average
$
2,720
for
the
3
years
following
effective
date.
Combining
the
annualized
capital
costs
for
file
cabinets
and
performance
tests
results
in
a
total
annualized
capital
cost
of
$
1,568
for
the
3
years
following
the
effective
date.
Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
4,288
for
the
3
years
following
the
effective
date.
The
total
annualized
capital
cost,
annual
O&
M
cost,
and
total
annualized
cost
are
presented
in
Boxes
14a,
14b,
and
14c,

respectively,
of
OMB
83­
I.

A
discussion
of
the
respondent
burden
and
costs
in
later
years
is
provided
in
Attachment
3,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date.
21
(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
2a,
2b,
and
2c
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
Agency
burden
hours
and
costs
are
summarized
as
follows:

Total
burden,
hours
Total
costs,
$

Table
2a
(
first
year)
534
24,252
Table
2b
(
second
year)
285
13,195
Table
2c
(
third
year)
317
14,629
Total
1,136
52,076
Bottom
line
annual
burden
379
17,359
The
bottom
line
annual
burden,
averaged
over
the
first
3
years
after
the
effective
date,
is
379
labor
hours,
at
a
cost
of
$
17,359.
A
discussion
of
the
Agency
burden
and
costs
in
later
years
is
provided
in
Attachment
3,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date.

(
iii)
The
complex
collection.
This
section
does
not
apply
because
this
collection
is
a
simple
collection.

(
iv)
Variations
in
the
annual
bottom
line.
The
annual
burden
hours
and
costs
associated
with
one­
time
activities
vary
over
the
course
of
the
3­
year
review
period
because
sources
are
subject
to
different
requirements
in
each
year.
Both
existing
and
new
sources
will
be
required
to
read
instructions
and
submit
initial
notifications
in
the
first
year.
Increasing
numbers
of
new
sources
installed
after
the
effective
date
will
be
subject
to
ongoing
requirements
over
the
3­
year
review
period,
such
as
recordkeeping
and
submitting
semiannual
compliance
reports.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
EPA
will
be
reviewing
initial
notifications
from
existing
sources
in
the
first
year
and
initial
22
notifications
and
semiannual
reports
from
new
sources
in
all
3
years.

(
f)
Reasons
for
Change
in
Burden
This
section
does
not
apply
because
this
collection
is
a
new
collection.

(
g)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
CAA
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).

(
ii)
The
respondents
will
be
subject
to
applicable
recordkeeping,
reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10,
the
General
Provisions
for
the
part
63
rules.

(
iii)
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:
(
1)
review
instructions;

(
2)
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;
(
3)
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
(
4)
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
5)
search
data
sources;
(
6)
complete
and
review
the
collection
of
information;
and
(
7)
transmit
or
otherwise
disclose
the
information.

(
iv)
The
information
is
needed
as
part
of
the
overall
compliance
and
enforcement
program.
The
information
stored
in
the
initial,
one­
time
initial
notifications
and
reports
will
be
stored
in
EPA's
AIRS
Facility
Subsystem
and
will
be
available
to
stakeholders.

(
v)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection
averaged
over
the
first
3
years
after
23
the
effective
date
of
the
rule
were
estimated
to
be
21,528
labor
hours
and
$
958,279.
The
average
burden
and
cost,
per
respondent,

are
158
labor
hours
and
$
7,046.

During
these
3
years,
the
rule
requires
certain
initial
onetime
notifications
from
all
sources.
In
addition,
new
sources
are
required
to
submit
an
initial
one­
time
notification
of
compliance
status
and
semiannual
compliance
report
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
rule.

(
vi)
The
total
capital
cost
is
$
11,380
the
first
year
after
the
effective
date
of
the
rule
and
$
1,645
for
each
of
the
second
and
third
years.
The
annualized
capital
cost
is
$
1,568
for
the
3
years
after
the
effective
date.
The
average
annual
O&
M
cost
is
$
2,720
for
the
3
years
after
the
effective
date.
Combining
the
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
4,288
for
the
3
years
after
the
effective
date.

(
vii)
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
a
table
in
40
CFR
part
9.
The
EPA
will
amend
part
9
when
the
ICR
is
approved.

(
viii)
Send
comments
on
EPA'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,
Office
of
Environmental
Information,
Collection
Strategies
Division
(
2822),
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue
NW,
Washington,
DC
20460,
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street
NW,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
24
(
v)
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,

Subpart
B
 
Confidentiality
of
Information
(
see
40
CFR
part
2;

41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).
25
TABLE
1a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
136c
272
14
27
313
13,924
B.
Required
activities
°
Performance
evaluation
CPMS
10d
1
10
5e,
f
49
2.4
4.9
56
2,500
COMS
27d
1
27
7e,
f
191
9.6
19
220
9,800
°
Repeat
performance
evaluation
CPMS
10d
1
10
0e,
f
0
0
0
0
0
COMS
27d
1
27
0e,
f
0
0
0
0
0
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
8
e
16
0.8
1.6
18
819
°
Notification
of
anticipated
startup
2
1
2
8e
16
0.8
1.6
18
819
°
Notification
of
actual
startup
2
1
2
8e
16
0.8
1.6
18
819
°
Notification
of
applicability
of
the
standard
2
1
2
136c
272
14
27
313
13,924
°
Notification
of
initial
performance
test
2
1
2
8g
16
0.8
1.6
18
819
°
Notification
of
performance
evaluation
2
1
2
8e
16
0.8
1.6
18
819
°
Notification
of
compliance
status
80
1
80
8e
640
32
64
736
32,762
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
26
TABLE
1a.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
C.
Implement
activities
N/
A
D.
Develop
record
system
40h
1
40
8
e
320
16
32
368
16,381
E.
Develop
startup,
shutdown,
and
malfunction
plan
100i
1
100
8e
800
40
80
920
40,952
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
8
e
64
3.2
6.4
74
3,276
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
8
e
16
0.8
1.6
18
819
°
Records
certifying
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces
2
1
2
4
j
8
0.4
0.8
9.2
410
G.
Time
to
train
personnel
40k
1
40
8
e
320
16
32
368
16,381
H.
Time
for
audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
l
3,032
152
303
3,487
155,224
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

dPerson­
hours
per
occurrence
are
based
on
the
cost
of
the
performance
evaluation
divided
by
the
composite
hourly
labor
rate.
The
performance
evaluation
costs
are
$
500
for
each
CPMS
and
$
1,400
for
each
COMS.

eAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
one­
time
requirements
was
estimated
to
be
eight
for
the
first
year
after
the
effective
date
and
seven
for
the
second
and
third
years.

fAssumes
four
new
SDT's
will
be
required
to
conduct
a
CPMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date;
also
assumes
one
new
semichemical
combustion
unit
will
be
required
to
conduct
a
CPMS
performance
evaluation
the
first
year
after
the
effective
date.
Assumes
four
new
recovery
furnaces
and
three
new
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date.
Assumes
5
percent
of
the
CPMS/
COMS
performance
evaluations
must
be
repeated
due
to
the
failure
of
the
first
performance
evaluation.

gAssumes
the
seven
new
kraft
combustion
units
will
be
required
to
submit
notifications
of
initial
performance
test
each
year
over
the
first
3
years
after
the
effective
date.
Also,
assumes
the
new
semichemical
combustion
unit
will
be
required
to
submit
a
notification
of
initial
performance
test
on
the
first
year
after
the
effective
date.
27
TABLE
1a.
(
continued)

hAssumes
1
week
(
40
hours)
to
develop
a
record
system
for
recording
parameter
monitoring
information.

iAssumes
1
person
would
take
2
weeks
(
80
hours)
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

jAssumes
4
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each
year
over
the
3­
year
review
period.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
a
dry
ESP
system.

kAssumes
1
week
(
40
hours)
to
train
personnel.

lThe
one­
time
burden
and
cost
in
the
first
year
are
equal
to
the
totals
added
down
each
column.
28
TABLE
1b.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
N/
A
D.
Gather
existing
information
N/
A
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
0d,
e
0
0
0
0
0
Semiannual
report
of
no
exceedances
8f
2
16
8d,
e
128
6.4
13
147
6,552
4.
Recordkeeping
Requirements
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
8d
624
31
62
718
31,943
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
5d
390
20
39
449
19,964
°
Records
of
lime
production
rates
for
lime
kilns
1.5
52
78
3d
234
12
23
269
11,979
29
TABLE
1b.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
°
Records
of
CPMS/
COMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
8d
4,200
210
420
4,830
215,000
Compile
monthly
data
16
12
192
8d
1,536
77
154
1,766
78,629
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
8
d
128
6.4
13
147
6,552
F.
Time
to
train
personnel
N/
A
G.
Time
for
refresher
training
for
personnel
16g
1
16
0
0
0
0
0
0
H.
Time
for
audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
h
7,240
362
724
8,326
370,619
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
16
person­
hours
per
report
per
affected
facility
per
pollutant
for
an
exceedances
report.

dAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
recurrent
requirements
was
estimated
to
be
8
for
the
first
year
after
the
effective
date.

eAssumes
5
percent
of
respondents
(
0.05
*
8
=
0)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
8
=
8)
report
no
exceedances..

fAssumes
8
person­
hours
per
report
per
affected
facility
per
pollutant
for
a
report
of
no
exceedances.

gAssumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

hThe
recurrent
burden
and
cost
in
the
first
year
are
equal
to
the
totals
added
down
each
column.
30
TABLE
1c.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATEa
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
7c
14
0.7
1.4
16
717
B.
Required
activities
CPMS
10d
1
10
4c,
e
39
2.0
3.9
45
2,000
COMS
27d
1
27
7c,
e
191
9.6
19
220
9,800
°
Repeat
performance
evaluation
CPMS
10d
1
10
0c,
e
0
0
0
0
0
COMS
27d
1
27
0c,
e
0
0
0
0
0
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
anticipated
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
actual
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
applicability
of
the
standard
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
initial
performance
test
2
1
2
7f
14
0.7
1.4
16
717
°
Notification
of
performance
evaluation
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
compliance
status
80
1
80
7c
560
28
56
644
28,667
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
31
TABLE
1c.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
D.
Develop
record
system
40g
1
40
7
c
280
14
28
322
14,333
E.
Develop
startup,
shutdown,
and
malfunction
plan
100h
1
100
7c
700
35
70
805
35,933
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
7
c
56
2.8
5.6
64
2,867
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
7
c
14
0.7
1.4
16
717
°
Records
certifying
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces
2
1
2
4
i
8
0.4
0.8
9.2
410
G.
Time
to
train
personnel
40j
1
40
7
c
280
14
28
322
14,333
H.
Time
for
audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
k
2,227
111
223
2,560
113,976
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
one­
time
requirements
was
estimated
to
be
eight
for
the
first
year
after
the
effective
date
and
seven
for
the
second
and
third
years.

dPerson­
hours
per
occurrence
are
based
on
the
cost
of
the
performance
evaluation
divided
by
the
composite
hourly
labor
rate.
The
performance
evaluation
costs
are
$
500
for
each
CPMS
and
$
1,400
for
each
COMS.

eAssumes
three
new
SDT's
will
be
required
to
conduct
a
CPMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date;
also
assumes
one
new
semichemical
combustion
unit
will
be
required
to
conduct
a
CPMS
performance
evaluation
the
first
year
after
the
effective
date.
Assumes
four
new
recovery
furnaces
and
three
new
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date.
Assumes
5
percent
of
the
CPMS/
COMS
performance
evaluations
must
be
repeated
due
to
the
failure
of
the
first
performance
evaluation.

fAssumes
the
seven
new
kraft
combustion
units
will
be
required
to
submit
notifications
of
initial
performance
test
each
year
over
the
first
3
years
after
the
effective
date.
Also,
assumes
the
new
semichemical
combustion
unit
will
be
required
to
submit
a
notification
of
initial
performance
test
only
the
first
year
after
the
effective
date.

gAssumes
1
week
(
40
hours)
to
develop
a
record
system
for
recording
parameter
monitoring
information.

hAssumes
1
person
would
take
2
weeks
(
80
hours)
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

iAssumes
4
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each
year
over
the
3­
year
review
period.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
a
dry
ESP
system.
32
TABLE
1c.
(
continued)

jAssumes
1
week
(
40
hours)
to
train
personnel.

kThe
one­
time
burden
and
cost
in
the
second
year
are
equal
to
the
totals
added
down
each
column.
33
TABLE
1d.
RECURRENT
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
N/
A
D.
Gather
existing
information
N/
A
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
1d,
e
64
3.2
6.4
74
3,276
Semiannual
report
of
no
exceedances
8f
2
16
14d,
e
224
11
22
258
11,467
4.
Recordkeeping
Requirements
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
15d
1,170
59
117
1,346
59,893
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
9d
702
35
70
807
35,936
°
Records
of
lime
production
rates
for
lime
kilns
1.5
52
78
6d
468
23
23
538
23,957
34
TABLE
1d.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
°
Records
of
CPMS/
COMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
15d
7,875
394
788
9,056
403,125
Compile
monthly
data
16
12
192
15d
2,880
144
288
3,312
147,429
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
15d
240
12
24
276
12,286
F.
Time
to
train
personnel
N/
A
G.
Time
for
refresher
training
for
personnel
16g
1
16
8
d
128
6.4
13
147
6,552
H.
Time
for
audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
h
13,751
688
1,375
15,814
703,921
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
16
person­
hours
per
report
per
affected
facility
per
pollutant
for
an
exceedances
report.

dAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
recurrent
requirements
was
estimated
to
be
15
for
the
second
year
after
the
effective
date
(
8
mills
in
the
first
year
+
7
mills
in
the
second
year).

eAssumes
5
percent
of
respondents
(
0.05
*
15
=
1)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
15
=
14)
report
no
exceedances..

fAssumes
8
person­
hours
per
report
per
affected
facility
per
pollutant
for
a
report
of
no
exceedances.

gAssumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

hThe
recurrent
burden
and
cost
in
the
second
year
are
equal
to
the
totals
added
down
each
column.
35
TABLE
1e.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATEa
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
7c
14
0.7
1.4
16
717
B.
Required
activities
B.
Required
activities
°
Performance
evaluation
CPMS
10d
1
10
4c,
e
39
2.0
3.9
45
2,000
COMS
27d
1
27
7c,
e
191
9.6
19
220
9,800
°
Repeat
performance
evaluation
CPMS
10d
1
10
0c,
e
0
0
0
0
0
COMS
27d
1
27
0c,
e
0
0
0
0
0
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
anticipated
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
actual
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
applicability
of
the
standard
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
initial
performance
test
2
1
2
7f
14
0.7
1.4
16
717
°
Notification
of
performance
evaluation
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
compliance
status
80
1
80
7c
560
28
56
644
28,667
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
36
TABLE
1e.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
40g
1
40
7
c
280
14
28
322
14,333
E.
Develop
startup,
shutdown,
and
malfunction
plan
100h
1
100
7c
700
35
70
805
35,833
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
7
c
56
2.8
5.6
64
2,867
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
7
c
14
0.7
1.4
16
717
°
Records
certifying
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces
2
1
2
4
i
8
0.4
0.8
9.2
410
G.
Time
to
train
personnel
40j
1
40
7
c
280
14
28
322
14,333
H.
Time
for
audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
k
2,227
111
223
2,560
113,976
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
one­
time
requirements
was
estimated
to
be
eight
for
the
first
year
after
the
effective
date
and
seven
for
the
second
and
third
years.

dPerson­
hours
per
occurrence
are
based
on
the
cost
of
the
performance
evaluation
divided
by
the
composite
hourly
labor
rate.
The
performance
evaluation
costs
are
$
500
for
each
CPMS
and
$
1,400
for
each
COMS.

eAssumes
three
new
SDT's
will
be
required
to
conduct
a
CPMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date;
also
assumes
one
new
semichemical
combustion
unit
will
be
required
to
conduct
a
CPMS
performance
evaluation
the
first
year
after
the
effective
date.
Assumes
four
new
recovery
furnaces
and
three
new
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
each
year
over
the
first
3
years
after
the
effective
date.
Assumes
5
percent
of
the
CPMS/
COMS
performance
evaluations
must
be
repeated
due
to
the
failure
of
the
first
performance
evaluation.

fAssumes
the
seven
new
kraft
combustion
units
will
be
required
to
submit
notifications
of
initial
performance
test
each
year
over
the
first
3
years
after
the
effective
date.
Also,
assumes
the
new
semichemical
combustion
unit
will
be
required
to
submit
a
notification
of
initial
performance
test
only
the
first
year
after
the
effective
date.

gAssumes
1
week
(
40
hours)
to
develop
a
record
system
for
recording
parameter
monitoring
information.
37
TABLE
1e.
(
continued)

hAssumes
1
person
would
take
2
weeks
(
80
hours)
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

iAssumes
4
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each
year
over
the
3­
year
review
period.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
a
dry
ESP
system.

jAssumes
1
week
(
40
hours)
to
train
personnel.

kThe
one­
time
burden
and
cost
in
the
third
year
are
equal
to
the
totals
added
down
each
column.
38
TABLE
1f.
RECURRENT
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
N/
A
D.
Gather
existing
information
N/
A
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
1d,
e
64
3.2
6.4
74
3,276
Semiannual
report
of
no
exceedances
8f
2
16
21d,
e
336
17
34
386
17,200
4.
Recordkeeping
Requirements
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
22d
1,716
86
172
1,973
87,843
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
13d
1,014
51
101
1,166
51,907
°
Records
of
lime
production
rates
for
lime
kilns
1.5
52
78
9d
702
35
70
807
35,936
39
TABLE
1f.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
°
Records
of
CPMS/
COMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
22d
11,550
577
1,155
13,283
591,250
Compile
monthly
data
16
12
192
22d
4,224
211
422
4,858
216,229
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
22d
352
18
35
405
18,019
F.
Time
to
train
personnel
N/
A
G.
Time
for
refresher
training
for
personnel
16g
1
16
15
d
240
12
24
276
12,286
H.
Time
for
audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
h
20,198
1,010
2,020
23,228
1,033,946
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
16
person­
hours
per
report
per
affected
facility
per
pollutant
for
an
exceedances
report.

dAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
recurrent
requirements
was
estimated
to
be
22
for
the
third
year
after
the
effective
date
(
8
mills
in
the
first
year
+
7
mills
in
the
second
year
+
7
mills
in
the
third
year).
eAssumes
5
percent
of
respondents
(
0.05
*
22
=
1)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
22
=
21)
report
no
exceedances..

fAssumes
8
person­
hours
per
report
per
affected
facility
per
pollutant
for
a
report
of
no
exceedances.

gAssumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

hThe
recurrent
burden
and
cost
in
the
third
year
are
equal
to
the
totals
added
down
each
column.
40
TABLE
2a.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
1.
Attend
initial
performance
test
40
1
40
1b
40
2.0
4.0
46
2,048
2.
Attend
repeat
performance
test
A.
Retesting
preparation
8
1
8
1c
8.0
0.4
0.8
9.2
410
B.
Attend
retesting
40
1
40
0d
0
0
0
0
0
3.
Litigation
2,080
1
2,080
0e,
f
0
0
0
0
0
4.
Excess
emissions­­
enforcement
activities
48
1
48
0b,
g
0
0
0
0
0
5.
Report
review
°
Review
of
notification
of
construction/

reconstruction
2
1
2
8
f
16
0.8
1.6
18
819
°
Review
of
notification
of
anticipated
startup
2
1
2
8f
16
0.8
1.6
18
819
°
Review
of
notification
of
actual
startup
2
1
2
8f
16
0.8
1.6
18
819
°
Review
of
notification
of
applicability
2
1
2
136h
272
14
27
313
13,924
°
Review
of
notification
of
initial
performance
test
2
1
2
8b,
f
16
0.8
1.6
18
819
°
Review
of
notification
of
performance
evaluation
2
1
2
8
f
16
0.8
1.6
18
819
°
Review
of
notification
of
compliance
status
4
1
4
8f
32
1.6
3.2
37
1,638
°
Review
of
excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
0f,
i
0
0
0
0
0
Semiannual
report
of
no
exceedances
2
2
4
8f,
i
32
1.6
3.2
37
1,638
41
TABLE
2a.
(
continued)

Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
TOTAL
BURDEN
AND
COST
(
SALARY)
j
464
23
46
534
23,752
TRAVEL
EXPENSES
FOR
TESTS
ATTENDEDk
=
(
1
person
*
1
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trip/
yr)
500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
24,252
aCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+
0.1
*
$
28.14
=
$
51.19).

bAn
estimated
4
new
recovery
furnaces,
4
new
SDT's,
3
new
lime
kilns,
and
1
new
semichemical
combustion
unit
will
be
required
to
conduct
an
initial
performance
test
in
the
first
year.
Assumes
EPA
personnel
attend
8
percent
of
the
tests
(
0.08
*
12
combustion
units
=
1
test
attended).

cOf
the
5
percent
that
are
assumed
to
fail
the
initial
performance
test,
assume
all
repeat
the
performance
test
(
0.05
*
12
combustion
units
=
1
retest).

dAssumes
10
percent
of
the
retests
are
attended
by
EPA
personnel
(
0.1
*
1
retest
=
0
retests
attended).

eAssumes
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
8
mills
=
0
mills).

fAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
requirements
was
estimated
to
be
eight
for
the
first
year
after
the
effective
date.
gAssumes
5
percent
of
the
affected
facilities
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
12
new
combustion
units
*
0.1
=
0
units).

hThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
semichemical
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

iAssumes
5
percent
of
respondents
(
0.05
*
8
=
0)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
8
=
8)
report
no
exceedances..

jThe
burden
and
cost
in
the
first
year
are
equal
to
the
totals
added
down
each
column.

kTests
attended
=
1
(
initial
tests)
+
0
(
repeat
tests)
+
0
(
excess
emissions
enforcement
tests)
=
1
test.
42
TABLE
2b.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
1.
Attend
initial
performance
test
40
1
40
1b
40
2.0
4.0
46
2,048
2.
Attend
repeat
performance
test
A.
Retesting
preparation
8
1
8
1c
8.0
0.4
0.8
9.2
410
B.
Attend
retesting
40
1
40
0d
0
0
0
0
0
3.
Litigation
2,080
1
2,080
0e,
f
0
0
0
0
0
4.
Excess
emissions­­
enforcement
activities
48
1
48
0b,
g
0
0
0
0
0
5.
Report
review
°
Review
of
notification
of
construction/

reconstruction
2
1
2
7
f
14
0.7
1.4
16
717
°
Review
of
notification
of
anticipated
startup
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
actual
startup
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
applicability
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
initial
performance
test
2
1
2
7b,
f
14
0.7
1.4
16
717
°
Review
of
notification
of
performance
evaluation
2
1
2
7
f
14
0.7
1.4
16
717
°
Review
of
notification
of
compliance
status
4
1
4
7f
28
1.4
2.8
32
1,433
°
Review
of
excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
1f,
h
32
1.6
3.2
38
1,638
Semiannual
report
of
no
exceedances
2
2
4
14f,
h
56
2.8
5.6
64
2,867
43
TABLE
2b.
(
continued)

Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
TOTAL
BURDEN
AND
COST
(
SALARY)
i
248
12.0
25
285
12,695
TRAVEL
EXPENSES
FOR
TESTS
ATTENDEDj
=
(
1
person
*
1
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trip/
yr)
500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
13,195
aCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+
0.1
*
$
28.14
=
$
51.19).

bAn
estimated
4
new
recovery
furnaces,
4
new
SDT's,
and
3
new
lime
kilns
will
be
required
to
conduct
an
initial
performance
test
in
the
second
year.
Assumes
EPA
personnel
attend
8
percent
of
the
tests
(
0.08
*
11
combustion
units
=
1
test
attended).

cOf
the
5
percent
that
are
assumed
to
fail
the
initial
performance
test,
assume
all
repeat
the
performance
test
(
0.05
*
11
combustion
units
=
1
retest).

dAssumes
10
percent
of
the
retests
are
attended
by
EPA
personnel
(
0.1
*
1
retest
=
0
retests
attended).

eAssumes
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
7
mills
=
0
mills).

fAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
for
the
second
year
after
the
effective
date
was
estimated
to
be
7
for
one­
time
requirements
and
15
for
recurrent
requirements
(
8
mills
in
the
first
year
+
7
mills
in
the
second
year).

gAssumes
5
percent
of
the
affected
facilities
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
11
new
combustion
units
*
0.1
=
0
units).

hAssumes
5
percent
of
respondents
(
0.05
*
15
=
1)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
15
=
14)
report
no
exceedances..

iThe
burden
and
cost
in
the
second
year
are
equal
to
the
totals
added
down
each
column.

jTests
attended
=
1
(
initial
tests)
+
0
(
repeat
tests)
+
0
(
excess
emissions
enforcement
tests)
=
1
test.
44
TABLE
2c.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
1.
Attend
initial
performance
test
40
1
40
1b
40
2.0
4.0
46
2,048
2.
Attend
repeat
performance
test
A.
Retesting
preparation
8
1
8
1c
8.0
0.4
0.8
9.2
410
B.
Attend
retesting
40
1
40
0d
0
0
0
0
0
3.
Litigation
2,080
1
2,080
0e,
f
0
0
0
0
0
4.
Excess
emissions­­
enforcement
activities
48
1
48
0b,
g
0
0
0
0
0
5.
Report
review
°
Review
of
notification
of
construction/

reconstruction
2
1
2
7
f
14
0.7
1.4
16
717
°
Review
of
notification
of
anticipated
startup
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
actual
startup
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
applicability
2
1
2
7f
14
0.7
1.4
16
717
°
Review
of
notification
of
initial
performance
test
2
1
2
7b,
f
0
0
0
0
0
°
Review
of
notification
of
performance
evaluation
2
1
2
7
f
14
0.7
1.4
16
717
°
Review
of
notification
of
compliance
status
4
1
4
7f
28
1.4
2.8
32
1,433
°
Review
of
excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
1f,
h
32
1.6
3.2
38
1,638
Semiannual
report
of
no
exceedances
2
2
4
21f,
h
84
4.2
8.4
97
4,300
45
TABLE
2c.
(
continued)

Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
TOTAL
BURDEN
AND
COST
(
SALARY)
i
276
14
28
317
14,129
TRAVEL
EXPENSES
FOR
TESTS
ATTENDEDj
=
(
1
person
*
1
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trip/
yr)
500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
14,629
aCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+
0.1
*
$
28.14
=
$
51.19).

bAn
estimated
4
new
recovery
furnaces,
4
new
SDT's,
and
3
new
lime
kilns
will
be
required
to
conduct
an
initial
performance
test
in
the
third
year.
Assumes
EPA
personnel
attend
8
percent
of
the
tests
(
0.08
*
11
combustion
units
=
1
test
attended).

cOf
the
5
percent
that
are
assumed
to
fail
the
initial
performance
test,
assume
all
repeat
the
performance
test
(
0.05
*
11
combustion
units
=
1
retest).

dAssumes
10
percent
of
the
retests
are
attended
by
EPA
personnel
(
0.1
*
1
retest
=
0
retests
attended).

eAssumes
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
7
mills
=
0
mills).

fAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
3­
year
review
period
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
for
the
third
year
after
the
effective
date
was
estimated
to
be
7
for
one­
time
requirements
and
22
for
recurrent
requirements
(
8
mills
in
the
first
year
+
7
mills
in
the
second
year
+
7
mills
in
the
third
year).

gAssumes
5
percent
of
the
affected
facilities
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
11
new
combustion
units
*
0.1
=
0
units).

hAssumes
5
percent
of
respondents
(
0.05
*
22
=
1)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
22
=
21)
report
no
exceedances..

iThe
burden
and
cost
in
the
third
year
are
equal
to
the
totals
added
down
each
column.

jTests
attended
=
1
(
initial
tests)
+
0
(
repeat
tests)
+
0
(
excess
emissions
enforcement
tests)
=
1
test.
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
rule.

3
attachments
ATTACHMENT
1
Source
Data
and
Information
Requirements
Attachment
1
SUMMARY
OF
RECORDKEEPING
REQUIREMENTS
Requirements
Regulation
reference
Record
retention
63.10(
b)(
1)

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

Records
of
startup,
shutdown,
and
malfunction
63.6(
e)(
3)(
iii)­(
iv)
and
63.10(
b)(
2)(
i)­(
v)

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

Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)

Records
of
exceedances
requiring
corrective
action
and
violations
63.866(
b)

Black
liquor
solids
firing
rates
for
all
recovery
furnaces
and
semichemical
combustion
units
63.866(
c)(
1)

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

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

Supporting
calculations
for
compliance
determinations
made
under
63.865(
a)
through
(
e)
63.866(
c)(
4)

Compliant
monitoring
parameter
ranges
established
for
each
affected
source
63.866(
c)(
5)

Certification
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
in
63.862(
c)(
1)
63.866(
c)(
6)

SUMMARY
OF
REPORTING
REQUIREMENTS
Requirement
Regulation
Reference
Initial
notifications
(
including
construction/
reconstruction)
63.5
and
63.9(
b)

Notification
of
performance
test
63.7(
b)
and
63.9(
e)

Notification
of
initial
CMS/
COMS
demonstration
63.9(
g)

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

Reporting
results
of
performance
test
63.10(
d)(
2)

Startup,
shutdown,
and
malfunction
reports
63.10(
d)(
5)

Reporting
results
of
CMS/
COMS
demonstration
63.10(
e)(
2)

Excess
emissions
reports
63.10(
e)(
3)
and
63.867(
c)
ATTACHMENT
2
Description
of
Respondent
Activities
Attachment
2
DESCRIPTION
OF
RESPONDENT
ACTIVITIES
(
1)
Read
Instructions
represents
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
combustion
sources
at
a
pulp
mill.

(
2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
scheduling
as
well
as
drafting
the
implementation
plan,
and
selecting
methods
of
compliance.
The
costs
for
planning
and
selection
are
included
in
the
capital
costs
for
the
performance
test,
as
explained
in
item
(
4)
below.

(
3)
Train
Personnel
represents
activities
involved
in
communicating
specific
definitions,
compliance
limits,
and
other
requirements,
such
as
recordkeeping,
monitoring,
and
reporting.
An
average
mill
may
elect
to
provide
classroom
instructions
for
all
workers
directly
impacted
by
the
requirements.
However,
the
rule
does
not
require
specific
training
itself.

(
4)
Create
Information
represents
the
activities
involving
testing,
retesting,
establishing
operating
range
parameters,
and
analyzing
point­
by­
point
applicability.
Monitor­
related
refit,
calibration,
and
maintenance
activities
are
also
included
under
this
heading.
Because
respondents
are
expected
to
hire
outside
contractors
to
conduct
the
performance
tests,
these
costs
are
not
included
in
the
burden
tables.
Instead,
the
costs
associated
with
the
performance
test
are
included
as
capital
costs
and
are
discussed
in
the
text.

(
5)
Gather
Existing
Information
represents
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data,
and
other
related
activities.

(
6)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
rule
requires
no
standard
forms,
these
activities
relate
to
the
preparation
of
formal
reports
and
cover
letters,
as
appropriate.

(
7)
Enter
Information
represents
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance,
and
appropriate
reports
and
records
required
as
a
result;
software
translation,
duplication,
or
archival
proceses
normally
associated
with
data
management
and
storage;
and
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
at
which
they
are
disposed.
ATTACHMENT
3
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
1
Attachment
3
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
1.
The
Information
Collected
 
Respondent
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
in
the
3
years
between
the
effective
date
of
the
rule
and
the
compliance
date
for
existing
sources,
both
existing
and
new
sources
must
determine
their
applicability
and
notify
EPA
that
the
facility
is
subject
to
the
rule.
New
sources
are
also
required
to
submit
notifications
of
construction/
reconstruction
and
notifications
of
anticipated
and
actual
startup,
as
well
as
semiannual
compliance
reports.

In
the
3
years
following
the
compliance
date
for
existing
sources,
existing
sources
must
submit
other
one­
time
notifications
and
reports,
and
ongoing
recordkeeping
and
reporting
begins.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
existing
facilities
must
notify
EPA
of
upcoming
performance
tests
and
COMS/
CPMS
performance
evaluations,
conduct
the
tests
and
evaluations,
and
submit
the
notification
of
compliance
status,
which
includes
the
results.

Existing
facilities
also
must
develop
their
startup,
shutdown,

and
malfunction
plans
and
begin
ongoing
monitoring
and
recordkeeping
for
opacity
and
various
operating
parameters.

Existing
facilities
will
begin
to
submit
semiannual
compliance
reports.

The
respondent
activities
required
by
the
rule
in
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
1a
through
1d
of
this
attachment.
One­
time
and
recurrent
respondent
activities
are
presented
in
Tables
1a
and
1b
for
the
fourth
year
and
Tables
2
1c
and
1d
for
the
fifth
and
sixth
years.
(
Separate
tables
were
not
prepared
for
the
fifth
and
sixth
years
after
the
effective
date
because
the
estimated
recordkeeping
and
reporting
burden
for
those
2
years
is
identical.)

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
over
the
3
years
between
the
effective
date
of
the
rule
and
the
compliance
date
for
existing
sources,
EPA
will
review
the
notifications
of
applicability
submitted
by
both
new
and
existing
sources
and
review
the
notifications
of
construction/
reconstruction,

notifications
of
anticipated
and
actual
startup,
and
semiannual
compliance
reports
submitted
by
new
sources.

In
the
3
years
following
the
compliance
date
for
existing
sources,
EPA
will
continue
to
review
the
notifications
and
semiannual
compliance
reports
submitted
by
new
sources.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
EPA
will
also
review
notifications
and
reports
submitted
by
existing
sources,
including
the
notifications
of
performance
tests,

notifications
of
COMS/
CPMS
performance
evaluations,
notifications
of
compliance
status,
and
semiannual
compliance
reports.
The
EPA
will
review
the
ongoing
semiannual
compliance
reports
for
existing
sources
in
the
fifth
and
sixth
years
following
the
effective
date
of
the
rule.
Agency
activities
are
listed
in
the
first
columns
of
Table
2a
for
the
fourth
year
following
the
effective
date
and
Table
2b
for
the
fifth
and
sixth
years.

(
Separate
tables
were
not
prepared
for
the
fifth
and
sixth
years
after
the
effective
date
because
the
estimated
recordkeeping
and
reporting
burden
for
those
2
years
is
identical.)
3
2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.
Tables
1a
through
1d
of
this
attachment
present
the
annual
respondent
burden
estimates
and
labor
costs
for
reporting
and
recordkeeping
activities
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.
The
one­
time
and
recurrent
burden
and
cost
estimates
are
presented
in
Tables
1a
and
1b
for
the
fourth
year
and
Tables
1c
and
1d
for
the
fifth
and
sixth
years.

The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.

The
costs
of
the
reporting
and
recordkeeping
activities
in
each
table
were
estimated
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.
Labor
costs
are
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
management,
and
(
3)

clerical.
The
cost
of
technical
labor
was
estimated
at
$
45.04/
hr,
the
cost
of
management
labor
at
$
66.73/
hr,
and
the
cost
of
clerical
labor
at
$
28.14/
hr.
These
estimates
include
fringe
benefits,
overhead,
and
profit
rate.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities:
capital
costs
and
O&
M
costs.
One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,

machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
rate.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
4
(
planning
and
selection),
and
a
data
acquisition
system
(
data
logger,
computer,
logging
and
reporting
software,
and
printer).

The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
the
following
assumptions:
(
1)
COMS
for
monitoring
opacity
will
be
required
for
an
estimated
137
existing
kraft
and
soda
recovery
furnaces
and
73
existing
kraft
and
soda
lime
kilns
not
already
subject
to
the
Kraft
Pulp
Mills
NSPS;
(
2)
the
capital
costs
for
COMS
were
determined
based
on
a
cost
of
$
34,800
per
COMS,
escalated
to
current
dollars;
the
annualized
capital
costs
were
determined
based
on
a
cost
of
$
1,400
per
COMS,
also
escalated
to
current
dollars;
(
3)
CPMS
for
monitoring
scrubber
liquid
flow
rate
and
scrubber
pressure
drop
will
be
required
for
an
estimated
147
existing
kraft
and
soda
smelt
dissolving
tanks
and
53
existing
kraft
and
soda
lime
kilns
not
already
subject
to
the
Kraft
Pulp
Mills
NSPS;
(
4)
the
capital
costs
for
CPMS
were
determined
based
on
a
cost
of
$
13,800
per
CPMS;
(
5)
scrubbers
used
to
control
emissions
from
sulfite
combustion
units
are
already
equipped
with
devices
for
monitoring
scrubber
flow
rate
and
pressure
drop,
so
no
additional
monitoring
costs
are
necessary
for
sulfite
combustion
units;
and
(
6)
because
thermocouples
and
strip
chart
recorders
are
included
in
the
cost
of
the
RTO's
used
to
control
emissions
from
semichemical
combustion
units,
no
additional
costs
are
necessary
for
those
units.

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
annualized
capital
cost
per
file
cabinet
is
$
35.

An
estimated
114
existing
mills
will
purchase
file
cabinets
in
the
fourth
year
after
the
effective
date.
(
The
number
of
mills
was
determined
based
on
22
existing
mills,
which
installed
new
combustion
units
during
the
first
3
years
after
the
effective
date,
having
already
purchased
file
cabinets,
leaving
the
5
remaining
114
mills
to
purchase
the
file
cabinets
in
the
fourth
year).
No
mills
are
expected
to
purchase
file
cabinets
after
the
fourth
year.

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
Method
5
PM
performance
tests
for
kraft
and
soda
recovery
furnaces,
SDT's,

and
lime
kilns
and
sulfite
combustion
units
and
Method
25A
THC
performance
tests
for
semichemical
combustion
units.
Only
the
PM
test
costs
for
combustion
units
not
subject
to
the
Kraft
Pulp
Mills
NSPS
are
included.
The
PM
test
costs
for
kraft
combustion
units
already
subject
to
the
NSPS
are
not
included
because
those
costs
are
assumed
to
be
existing
costs
for
complying
with
existing
State
permits
or
other
State/
local
programs.

No
initial
costs
were
estimated
for
Method
308
methanol
performance
tests
for
kraft
and
soda
recovery
furnaces.
Only
new
recovery
furnaces
are
subject
to
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces,
and
new
recovery
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
dry
ESP
systems,
which
are
exempted
from
testing
requirements.

Performance
test
costs
were
estimated
based
on
the
following
assumptions:
(
1)
capital
costs
are
$
8,500
per
Method
5
test
and
$
9,500
per
Method
25A
test;
(
2)
an
estimated
418
existing
combustion
units
will
be
required
to
conduct
initial
PM
performance
tests
during
the
fourth
year
after
the
effective
date;
(
3)
the
existing
combustion
units
include
137
kraft
and
soda
recovery
furnaces,
147
kraft
and
soda
SDT's,
126
kraft
and
soda
lime
kilns,
and
8
sulfite
combustion
units
(
one
source
was
assumed
per
sulfite
mill
based
on
the
fact
that
sulfite
mills
typically
route
emissions
from
multiple
combustion
units
to
the
same
stack);
(
4)
an
estimated
13
existing
semichemical
combustion
units
and
1
new
semichemical
combustion
unit
will
be
required
to
6
conduct
initial
THC
performance
tests
during
the
fourth
year
after
the
effective
date;
(
5)
an
estimated
5
percent
of
the
initial
performance
tests
must
be
repeated
due
to
failure
of
the
first
test;
and
(
6)
test
costs
will
be
annualized
for
15
tests,

which
include
the
tests
for
the
13
existing
semichemical
combustion
units
and
the
2
new
semichemical
combustion
units
installed
during
the
first
and
fourth
years
after
the
effective
date.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
Operation
and
maintenance
costs
were
determined
for
the
estimated
137
existing
recovery
furnaces
and
73
existing
lime
kilns
not
already
subject
to
the
Kraft
Pulp
Mills
NSPS
that
are
expected
to
install
COMS.
(
No
O&
M
costs
were
determined
for
new
sources
because
they
would
be
subject
to
the
Kraft
Pulp
Mills
NSPS.)
The
O&
M
costs
for
COMS
were
estimated
based
on
a
cost
of
$
7,000
per
source,
escalated
to
current
dollars.
The
scrubbers
used
to
control
emissions
from
sulfite
combustion
units
are
already
equipped
with
devices
for
monitoring
scrubber
flow
rate
and
pressure
drop,
so
no
additional
monitoring
O&
M
costs
are
necessary
for
sulfite
combustion
units.
Because
thermocouples
and
strip
chart
recorders
are
included
in
the
cost
of
the
RTO's
used
to
control
emissions
from
semichemical
combustion
units,
no
additional
O&
M
costs
are
necessary
for
those
units.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
respondents
to
submit
notifications
and
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
7
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
were
applied
to
the
672
responses
submitted
during
the
fourth
year
and
the
281
responses
submitted
during
each
of
the
fifth
and
sixth
years.

(
The
number
of
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents
during
the
fourth,
fifth,

and
sixth
years
after
the
effective
date,
as
shown
in
Tables
1a
through
1f
of
this
attachment.)

(
b)
Estimating
Agency
Burden
and
Costs
Tables
2a
and
2b
of
this
attachment
present
the
estimated
annual
burden
to
the
Federal
Government
during
the
fourth,
fifth,

and
sixth
years
following
the
effective
date
of
the
rule.
The
only
burden
and
costs
that
the
Federal
Government
will
incur
as
a
result
of
the
information
collection
requirements
are
associated
with
the
analysis
of
the
information
reported
by
facilities
in
one­
time
notifications
and
semiannual
compliance
reports
(
unless
the
compliance
report
indicates
a
violation,
thereby
triggering
an
enforcement
action).
Labor
costs
were
estimated
based
on
estimated
wage
rates
of
$
45.04/
hr
for
technical
labor,
$
66.73/
hr
for
management
labor,
and
$
28.14/
hr
for
clerical
labor.

(
c)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
1a
and
1b
to
the
total
personhours
and
costs
from
Tables
1c
and
1d
multiplied
by
2,
and
then
dividing
the
sum
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).
The
total
annual
respondent
burden
hours
and
costs
are
summarized
as
follows:
8
Total
burden,
hours
Total
costs,
$

Tables
1a
+
1b
(
fourth
year)
235,146
10,467,169
Tables
1c
+
1d
(
fifth
and
sixth
years)
134,535
5,988,624
Total
504,216
22,444,417
Bottom
line
annual
burden
168,072
7,481,472
The
bottom
line
annual
burden,
averaged
over
the
fourth,

fifth,
and
sixth
years
after
the
effective
date,
is
168,072
labor
hours,
at
a
cost
of
$
7,481,472.
The
average
annual
burden
per
respondent,
based
on
136
respondents,
is
1,236
labor
hours,
at
a
cost
of
$
55,011.

On
average,
there
are
an
estimated
411
total
annual
responses
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Of
the
411
total
annual
responses,
approximately
50
percent
are
assumed
to
be
collected
electronically.
The
total
annual
responses
are
an
average
of
the
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
An
estimated
672
one­
time
and
recurrent
notifications
and
reports
will
be
submitted
during
the
fourth
year
and
281
during
each
of
the
fifth
and
sixth
years.

The
total
nationwide
capital
costs
associated
with
monitoring
equipment
were
estimated
to
be
$
10.6
million.
The
average
annualized
capital
cost
for
the
monitoring
equipment
is
$
314,600
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
associated
with
file
cabinets
were
estimated
to
be
$
26,800.
The
average
annualized
capital
cost
for
the
file
cabinets
is
$
4,800
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
for
performance
tests
were
estimated
to
be
$
3.69
million.
The
average
annualized
9
capital
cost
for
the
performance
tests
is
$
405,600
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

Annual
O&
M
costs,
which
include
O&
M
costs
for
monitoring
equipment
as
well
as
photocopying
and
postage
costs,
average
$
1.58
million
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.

Combining
the
annualized
capital
costs
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
results
in
a
total
annualized
capital
cost
of
$
725,000
for
the
fourth,
fifth,

and
sixth
years
following
the
effective
date.
Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
2.31
million
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Table
2a
to
the
total
person­
hours
and
costs
from
Table
2b
multiplied
by
2
and
then
dividing
the
sum
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).
The
total
annual
Agency
burden
hours
and
costs
are
summarized
as
follows:

Total
burden,
hours
Total
costs,
$

Table
2a
(
fourth
year)
6,431
305,757
Table
2b
(
fifth
and
sixth
years)
883
39,814
Total
8,197
385,386
Bottom
line
annual
burden
2,732
128,462
The
bottom
line
annual
burden,
averaged
over
the
fourth,

fifth,
and
sixth
years,
is
2,732
labor
hours,
at
a
cost
of
$
128,462.
10
(
d)
Burden
Statement
(
i)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection
averaged
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
were
estimated
to
be
168,072
labor
hours
and
$
7,481,472.
The
average
burden
and
cost,
per
respondent,
are
1,236
labor
hours
and
$
55,011.

During
these
3
years,
new
facilities
are
required
to
submit
notifications
of
construction/
reconstruction
and
notifications
of
anticipated
and
actual
startup.
Both
new
and
existing
facilities
are
required
to
submit
notifications
of
performance
tests,

notifications
of
performance
evaluations,
and
notifications
of
compliance
status,
as
well
as
semiannual
compliance
reports
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
rule.
The
collection
requirements
are
applicable
to
an
estimated
136
respondents.

(
ii)
The
total
capital
cost
for
monitoring
equipment,
file
cabinets,
and
performance
tests
is
$
14.3
million.
The
annualized
capital
cost
and
average
annual
O&
M
cost
for
the
fourth,
fifth,

and
sixth
years
after
the
effective
date
are
$
725,000
and
$
1.58
million,
respectively.
Combining
the
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
2.31
million
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
11
11
TABLE
1a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
8c
16
0.8
1.6
18
819
B.
Required
activities
°
Performance
evaluation
CPMS
10d
1
10
226e
2,207
110
221
2,539
113,000
COMS
27d
1
27
217e
5,935
297
593
6,825
303,800
°
Repeat
performance
evaluation
CPMS
10d
1
10
11
e
107
5.4
11
124
$
5,500
COMS
27d
1
27
11
e
301
15
30
346
$
15,400
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
8
c
16
0.8
1.6
18
819
°
Notification
of
anticipated
startup
2
1
2
8c
16
0.8
1.6
18
819
°
Notification
of
actual
startup
2
1
2
8c
16
0.8
1.6
18
819
°
Notification
of
applicability
of
the
standard
2
1
2
8
c
16
0.8
1.6
18
819
°
Notification
of
initial
performance
test
2
1
2
136f
272
14
27
313
13,924
°
Notification
of
performance
evaluation
2
1
2
136f
272
14
27
313
13,924
°
Notification
of
compliance
status
80
1
80
136f
10,880
544
1,088
12,512
556,953
12
TABLE
1a.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
12
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
40g
1
40
136
f
5,440
272
544
6,256
278,476
E.
Develop
startup,
shutdown,
and
malfunction
plan
100h
1
100
136f
13,600
680
1360
15,640
696,191
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
136
f
1,088
54
109
1,251
55,695
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
136
f
272
14
27
313
13,924
°
Records
certifying
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces
2
1
2
4
i
8
0.4
0.8
9.2
410
G.
Time
to
train
personnel
40j
1
40
136
f
5,440
272
544
6,256
278,476
H.
Time
for
audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
k
45,902
2,295
4,590
52,788
2,349,768
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
fourth
year
after
the
effective
date.
Therefore,

the
total
number
of
existing
mills
subject
to
these
one­
time
requirements
for
new
sources
was
estimated
to
be
eight
for
the
fourth
year
after
the
effective
date
and
seven
for
the
fifth
and
sixth
years.
13
TABLE
1a.
(
continued)

13
dPerson­
hours
per
occurrence
are
based
on
the
cost
of
the
performance
evaluation
divided
by
the
composite
hourly
labor
rate.
The
performance
evaluation
costs
are
$
500
for
each
CPMS
and
$
1,400
for
each
COMS.

eAssumes
147
existing
SDT's,
53
existing
lime
kilns,
8
existing
sulfite
combustion
units,
13
existing
semichemical
combustion
units,
and
1
new
semichemical
combustion
unit
will
be
required
to
conduct
a
CPMS
performance
evaluation
during
the
fourth
year
after
the
effective
date;
also
assumes
4
new
SDT's
will
be
required
to
conduct
a
CPMS
performance
evaluation
each
year
over
the
fourth,

fifth,
and
sixth
years
after
the
effective
date.
Assumes
137
existing
recovery
furnaces
and
73
existing
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
during
the
fourth
year
after
the
effective
date;
also
assumes
4
new
recovery
furnaces
and
3
new
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Assumes
5
percent
of
the
CPMS/
COMS
performance
evaluations
must
be
repeated
due
to
the
failure
of
the
first
performance
evaluation.

fThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

gAssumes
1
week
(
40
hours)
to
develop
a
record
system
for
recording
parameter
monitoring
information.

hAssumes
1
person
would
take
2
weeks
(
80
hours)
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

iAssumes
4
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
a
dry
ESP
system.

jAssumes
1
week
(
40
hours)
to
train
personnel.

kThe
one­
time
burden
and
cost
in
the
fourth
year
are
equal
to
the
totals
added
down
each
column.
14
14
TABLE
1b.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
N/
A
D.
Gather
existing
information
N/
A
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
6d,
e
384
19
38
442
19,657
Semiannual
report
of
no
exceedances
8f
2
16
104d,
e
1,664
83
166
1,914
85,181
4.
Recordkeeping
Requirements
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
136d
10,608
530
1,061
12,199
543,029
15
TABLE
1b.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
15
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
128d
9,984
499
998
11,482
511,086
°
Records
of
lime
production
rates
for
lime
kilns
1.5
52
78
116d
9,048
452
905
10,405
463,172
°
Records
of
CPMS/
COMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
110d,
e
57,750
2,888
5,775
66,413
2,956,251
Compile
monthly
data
16
12
192
110d,
e
21,120
1,056
2,112
24,288
1,081,143
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
110d,
e
1,760
88
176
2,024
90,095
F.
Time
to
train
personnel
N/
A
G.
Time
for
refresher
training
for
personnel
16g
1
16
22
h
352
18
35
405
18,019
H.
Time
for
audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
i
112,670
5,634
11,267
129,571
5,767,634
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
16
person­
hours
per
report
per
affected
facility
per
pollutant
for
an
exceedances
report.

dThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

eAssumes
a
75
percent
reduction
in
the
recordkeeping
and
reporting
burden
for
an
estimated
35
mills
with
at
least
half
of
their
combustion
sources
currently
subject
to
the
NSPS.
Therefore,
the
equivalent
recordkeeping
and
reporting
burden
=
calculated
number
of
respondents:
136
­
(
35
*
0.75)
=
110.
Also
assumes
5
percent
of
respondents
(
0.05
*
110
=
6)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
110
=
104)
report
no
exceedances..

fAssumes
8
person­
hours
per
report
per
affected
facility
per
pollutant
for
a
report
of
no
exceedances.

gAssumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

hAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
first
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
with
refresher
training
in
the
fourth
year
after
the
effective
date
is
22
(
8
in
the
fourth
year
+
7
in
the
fifth
year
+
7
in
the
sixth
year).
16
TABLE
1b.
(
continued)

16
iThe
recurrent
burden
and
cost
in
the
fourth
year
are
equal
to
the
totals
added
down
each
column.
17
17
TABLE
1c.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
FIFTH
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATEa
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
7e
14
0.7
1.4
16
717
B.
Required
activities
CPMS
10d
1
10
4c,
e
39
2.0
3.9
45
2,000
COMS
27d
1
27
7c,
e
191
9.6
19
220
9,800
°
Repeat
performance
evaluation
CPMS
10d
1
10
0c,
e
0
0
0
0
0
COMS
27d
1
27
0c,
e
0
0
0
0
0
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
anticipated
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
actual
startup
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
applicability
of
the
standard
2
1
2
7
c
14
0.7
1.4
16
717
°
Notification
of
initial
performance
test
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
performance
evaluation
2
1
2
7c
14
0.7
1.4
16
717
°
Notification
of
compliance
status
80
1
80
7c
560
28
56
644
28,667
4.
Recordkeeping
Requirements
18
TABLE
1c.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)

Cost,
$
b
18
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Develop
startup,
shutdown,
and
malfunction
plan
N/
A
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
7
c
56
2.8
5.6
64
2,867
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
7
c
14
0.7
1.4
16
717
°
Records
certifying
that
an
NDCE
recovery
furnace
equipped
with
a
dry
ESP
system
is
used
to
comply
with
the
gaseous
organic
HAP
standard
for
kraft
and
soda
recovery
furnaces
2
1
2
4
f
8
0.4
0.8
9.2
410
G.
Time
to
train
personnel
40g
1
40
7
c
280
14
28
322
14,333
H.
Time
for
audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
h
1,247
62
125
1,433
63,810
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
fourth
year
after
the
effective
date.

Therefore,
the
total
number
of
existing
mills
subject
to
these
one­
time
requirements
for
new
sources
was
estimated
to
be
eight
for
the
fourth
year
after
the
effective
date
and
seven
for
the
fifth
and
sixth
years.
19
TABLE
1c.
(
continued)

19
dPerson­
hours
per
occurrence
are
based
on
the
cost
of
the
performance
evaluation
divided
by
the
composite
hourly
labor
rate.
The
performance
evaluation
costs
are
$
500
for
each
CPMS
and
$
1,400
for
each
COMS.

eAssumes
four
new
SDT's
will
be
required
to
conduct
a
CPMS
performance
evaluation
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date;
also
assumes
one
new
semichemical
combustion
unit
will
be
required
to
conduct
a
CPMS
performance
evaluation
the
fourth
year
after
the
effective
date.
Assumes
four
new
recovery
furnaces
and
three
new
lime
kilns
will
be
required
to
conduct
a
COMS
performance
evaluation
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Assumes
5
percent
of
the
CPMS/
COMS
performance
evaluations
must
be
repeated
due
to
the
failure
of
the
first
performance
evaluation.

fAssumes
4
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
NDCE
recovery
furnaces
equipped
with
a
dry
ESP
system.

gAssumes
1
week
(
40
hours)
to
train
personnel.

hThe
one­
time
burden
and
cost
in
the
fifth
and
sixth
years
are
equal
to
the
totals
added
down
each
column.
20
20
TABLE
1d.
RECURRENT
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
FIFTH
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
N/
A
D.
Gather
existing
information
N/
A
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
6d,
e
384
19
38
442
19,657
Semiannual
report
of
no
exceedances
8f
2
16
104d,
e
1,664
83
166
1,914
85,181
4.
Recordkeeping
Requirements
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
136d
10,608
530
1,061
12,199
543,029
21
TABLE
1d.
(
continued)

Burden
itema
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
b
21
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
128d
9,984
499
998
11,482
511,086
°
Records
of
lime
production
rates
for
lime
kilns
1.5
52
78
116d
9,048
452
905
10,405
463,172
°
Records
of
CPMS/
COMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
110d,
e
57,750
2,888
5,775
66,413
2956,251
Compile
monthly
data
16
12
192
110d,
e
21,120
1,056
2,112
24,288
1,081,143
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
110d,
e
1,760
88
176
2,024
90,095
F.
Time
to
train
personnel
N/
A
G.
Time
for
refresher
training
for
personnel
16g
1
16
136h
2,176
109
218
2,502
111,391
H.
Time
for
audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
i
114,494
5,725
11,449
131,668
5,861,005
aSee
Attachment
2
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+

0.1
*
$
28.14
=
$
51.19).

cAssumes
16
person­
hours
per
report
per
affected
facility
per
pollutant
for
an
exceedances
report.

dThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
stand­
alone
semichemical
pulp
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

eAssumes
a
75
percent
reduction
in
the
recordkeeping
and
reporting
burden
for
an
estimated
35
mills
with
at
least
half
of
their
combustion
sources
currently
subject
to
the
NSPS.
Therefore,
the
equivalent
recordkeeping
and
reporting
burden
=
calculated
number
of
respondents:
136
­
(
35
*
0.75)
=
110.
Also
assumes
5
percent
of
respondents
(
0.05
*
110
=
6)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
110
=
104)
report
no
exceedances..

fAssumes
8
person­
hours
per
report
per
affected
facility
per
pollutant
for
a
report
of
no
exceedances.

gAssumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

hThe
total
number
of
existing
mills
with
refresher
training
in
the
fifth
and
sixth
years
after
the
effective
date
is
136.

iThe
recurrent
burden
and
cost
in
the
fifth
and
sixth
years
are
equal
to
the
totals
added
down
each
column.
22
22
TABLE
2a.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
1.
Attend
initial
performance
test
40
1
40
35b
1,400
70
140
1,610
71667
2.
Attend
repeat
performance
test
A.
Retesting
preparation
8
1
8
22c
176
8.8
18
202
9,010
B.
Attend
retesting
40
1
40
2d
80
4.0
8.0
92
4,095
3.
Litigation
2,080
1
2,080
1e,
f
2,080
104
208
2,392
106,476
4.
Excess
emissions­­
enforcement
activities
48
1
48
2b,
g
96
4.8
9.6
110
4,914
5.
Report
review
°
Review
of
notification
of
construction/

reconstruction
2
1
2
8
h
16
0.8
1.6
18
819
°
Review
of
notification
of
anticipated
startup
2
1
2
8h
16
0.8
1.6
18
819
°
Review
of
notification
of
actual
startup
2
1
2
8h
16
0.8
1.6
18
819
°
Review
of
notification
of
applicability
2
1
2
8h
16
0.8
1.6
18
819
°
Review
of
notification
of
initial
performance
test
2
1
2
136e
272
14
27
313
13,924
°
Review
of
notification
of
performance
evaluation
2
1
2
136e
272
14
27
313
13,924
°
Review
of
notification
of
compliance
status
4
1
4
136e
544
27
54
626
27,848
°
Review
of
excess
emissions
report
23
TABLE
2a.
(
continued)

Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
23
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
6e,
i
192
9.6
19
221
9,829
Semiannual
report
of
no
exceedances
2
2
4
104e,
i
416
21
42
478
21,295
TOTAL
BURDEN
AND
COST
(
SALARY)
j
5,592
280
559
6,431
286,257
TRAVEL
EXPENSES
FOR
TESTS
ATTENDEDk
=
(
1
person
*
39
facilities/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
39
round
trips/
yr)
19,500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
305,757
aCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+
0.1
*
$
28.14
=
$
51.19).

bAn
estimated
137
existing
recovery
furnaces,
126
existing
lime
kilns,
147
existing
SDT's,
8
existing
sulfite
combustion
units,
13
existing
semichemical
combustion
units,

and
1
new
semichemical
combustion
unit
will
be
required
to
conduct
an
initial
performance
test
in
the
fourth
year
after
the
effective
date.
Also,
an
estimated
4
new
recovery
furnaces,
4
new
SDT's,
and
3
new
lime
kilns
will
be
required
to
conduct
an
initial
performance
test
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.

Assumes
EPA
personnel
attend
8
percent
of
the
tests
(
0.08
*
443
combustion
units
=
35
tests
attended).

cOf
the
5
percent
that
are
assumed
to
fail
the
initial
performance
test,
assume
all
repeat
the
performance
test
(
0.05
*
443
combustion
units
=
22
retests).

dAssumes
10
percent
of
the
retests
are
attended
by
EPA
personnel
(
0.1
*
22
retest
=
2
retests
attended).

eThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
semichemical
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

fAssumes
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
136
mills
=
1
mills).

gAssumes
5
percent
of
the
affected
facilities
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
443
existing
and
new
combustion
units
*
0.1
=
2
units).

hAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
fourth
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
subject
to
these
requirements
was
estimated
to
be
eight
for
the
fourth
year
after
the
effective
date.

iAssumes
a
75
percent
reduction
in
the
recordkeeping
and
reporting
burden
for
an
estimated
35
mills
with
at
least
half
of
their
combustion
sources
currently
subject
to
the
NSPS.
Therefore,
the
equivalent
recordkeeping
and
reporting
burden
=
calculated
number
of
respondents:
136
­
(
35
*
0.75)
=
110.
Also
assumes
5
percent
of
respondents
(
0.05
*
110
=
6)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
110
=
104)
report
no
exceedances..
24
TABLE
2a.
(
continued)

24
jThe
burden
and
cost
in
the
fourth
year
are
equal
to
the
totals
added
down
each
column.

kTests
attended
=
1
(
initial
tests)
+
0
(
repeat
tests)
+
0
(
excess
emissions
enforcement
tests)
=
1
test.
25
25
TABLE
2b.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
FIFTH
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
1.
Attend
initial
performance
test
40
1
40
1b
40
2.0
4.0
46
2,048
2.
Attend
repeat
performance
test
A.
Retesting
preparation
8
1
8
1c
8.0
0.4
0.8
9.2
410
B.
Attend
retesting
40
1
40
0d
0
0
0
0
0
3.
Litigation
2,080
1
2,080
0e,
f
0
0
0
0
0
4.
Excess
emissions­­
enforcement
activities
48
1
48
0b,
g
0
0
0
0
0
5.
Report
review
°
Review
of
notification
of
construction/

reconstruction
2
1
2
7
e
14
0.7
1.4
16
717
°
Review
of
notification
of
anticipated
startup
2
1
2
7e
14
0.7
1.4
16
717
°
Review
of
notification
of
actual
startup
2
1
2
7e
14
0.7
1.4
16
717
°
Review
of
notification
of
applicability
2
1
2
7e
14
0.7
1.4
16
717
°
Review
of
notification
of
initial
performance
test
2
1
2
7
e
14
0.7
1.4
16
717
°
Review
of
notification
of
performance
evaluation
2
1
2
7
e
14
0.7
1.4
16
717
°
Review
of
notification
of
compliance
status
4
1
4
7e
28
1.4
2.8
32
1,433
°
Review
of
excess
emissions
report
26
TABLE
2b.
(
continued)

Activity
(
A)

EPAhours
per
operation
(
B)
Number
of
operations
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C=
A*
B)
(
D)
Facilities
per
year
(
E)
Technical
personhours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
personhours
per
year
(
G=
E*
0.1)
(
H)
Total
personhours
per
year
(
H=
E+
F+
G)
(
I)
Cost,

$
a
26
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
6h,
i
192
9.6
19
221
9,829
Semiannual
report
of
no
exceedances
2
2
4
104h,
i
416
21
42
478
21,295
TOTAL
BURDEN
AND
COST
(
SALARY)
j
768
38.0
77
883
39,314
TRAVEL
EXPENSES
FOR
TESTS
ATTENDEDk
=
(
1
person
*
1
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trip/
yr)
500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
39,814
aCosts
assume
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.
The
composite
hourly
labor
rate
is
$
51.19/
hour
($
45.04
+
0.05
*$
66.73
+
0.1
*
$
28.14
=
$
51.19).

bAn
estimated
4
new
recovery
furnaces,
4
new
SDT's,
and
3
new
lime
kilns
will
be
required
to
conduct
an
initial
performance
test
in
the
fifth
and
sixth
years.
Assumes
EPA
personnel
attend
8
percent
of
the
tests
(
0.08
*
11
combustion
units
=
1
test
attended).

cOf
the
5
percent
that
are
assumed
to
fail
the
initial
performance
test,
assume
all
repeat
the
performance
test
(
0.05
*
11
combustion
units
=
1
retest).

dAssumes
10
percent
of
the
retests
are
attended
by
EPA
personnel
(
0.1
*
1
retest
=
0
retests
attended).

eAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
SDT,
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Also
assumes
one
existing
stand­
alone
semichemical
pulp
mill
will
install
one
semichemical
combustion
unit
during
the
fourth
year
after
the
effective
date.
Therefore,
the
total
number
of
existing
mills
for
the
fifth
and
sixth
years
after
the
effective
date
was
estimated
to
be
7.

fAssumes
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
7
mills
=
0
mills).

gAssumes
5
percent
of
the
affected
facilities
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
11
new
combustion
units
*
0.1
=
0
units).

hThere
are
an
estimated
136
existing
major
source
pulp
mills,
which
include
114
kraft,
2
soda,
8
sulfite,
and
12
semichemical
mills.
No
new
major
source
pulp
mills
are
projected
to
be
built
within
the
next
5
years.

iAssumes
a
75
percent
reduction
in
the
recordkeeping
and
reporting
burden
for
an
estimated
35
mills
with
at
least
half
of
their
combustion
sources
currently
subject
to
the
NSPS.
Therefore,
the
equivalent
recordkeeping
and
reporting
burden
=
calculated
number
of
respondents:
136
­
(
35
*
0.75)
=
110.
Also
assumes
5
percent
of
respondents
(
0.05
*
110
=
6)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
110
=
104)
report
no
exceedances..

jThe
burden
and
cost
in
the
fifth
and
sixth
years
are
equal
to
the
totals
added
down
each
column.

kTests
attended
=
1
(
initial
tests)
+
0
(
repeat
tests)
+
0
(
excess
emissions
enforcement
tests)
=
1
test.
