SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
part
63,
subpart
MM)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
part
63,
subpart
MM)
(
Renewal).

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills
published
at
40
CFR
part
63,
subpart
MM
were
proposed
on
April
15,
1998,
and
promulgated
on
January
12,
2001.
These
regulations
apply
to
existing
and
new
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills
where
the
total
Hazardous
Air
Pollutants
(
HAPs)
emitted
are
greater
than
or
equal
to
10
tons
per
year
of
any
one
HAP;
or
where
the
total
HAPs
emitted
are
greater
than
or
equal
to
25
tons
per
year
of
any
combination
of
HAPs.
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
the
proposal.
This
information
is
being
collected
to
ensure
compliance
with
40
CFR
part
63,
subpart
MM.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance
and
are
required
of
all
sources
subject
to
NESHAP
standards.

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

Approximately
130
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
2
The
active
(
previous)
Information
Collection
Request
(
ICR)
had
the
following
Terms
of
Clearance
(
TOC):

This
ICR
is
approved
for
three
years.
Before
submitting
a
renewal
ICR,
EPA
should
review
the
burden
of
this
collection
and
the
other
collections
associated
with
NESHAPs
for
pulp
and
paper
manufacturing
facilities
in
light
of
its
experience
implementing
these
rules
to
determine
whether
burden
can
be
reduced
by
further
consolidation
or
elimination
of
reporting
and
recordkeeping
requirements.

EPA
has
addressed
each
item
of
concern
in
the
TOC
by
reviewing
the
burden
of
this
collection
and
the
other
collections
associated
with
NESHAPs
for
pulp
and
paper
manufacturing
facilities
in
light
of
its
experience
implementing
these
rules
to
determine
whether
burden
can
be
reduced
by
further
consolidation
or
elimination
of
reporting
and
recordkeeping
requirements.
EPA
determined
that
the
information
collected
is
the
minimum
necessary
to
ensure
compliance
with
applicable
regulations,
and
burden
cannot
be
reduced
by
further
consolidation
or
elimination
of
reporting
and
recordkeeping
requirements.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

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

In
the
Administrator's
judgment,
acetaldehyde,
benzene,
formaldehyde,
hydrochloric
acid
(
HCl),
methanol,
methyl
ethyl
ketone,
and
toluene
hazardous
air
pollutant
(
HAP)
emissions
from
3
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
for
this
source
category
were
promulgated
at
40
CFR
part
63,
subpart
MM.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills
are
the
result
of
operation
of
the
affected
mills.
These
standards
rely
on
the
capture
and/
or
reduction
of
HAP
emissions
by
recovery
furnaces,
smelt
dissolving
tanks
(
SDTs),
lime
kilns,
or
soda
or
sulfite
combustion
units.
Required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
on
an
on­
going
basis
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
also
is
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
part
63,
subpart
MM.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.
4
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
Office
of
Management
and
Budget
(
OMB)

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

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

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

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
5
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

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

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
chemical
recovery
combustion
sources
at
kraft,
soda,
sulfite,
and
stand­
alone
semichemical
pulp
mills.

Standard
SIC
Codes
NAICS
Codes
40
CFR,
subpart
MM
2611
(
pulp
mills)
32211
2621
(
paper
mills)
32212
2631
(
paperboard
mills)
32213
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
part
63,
subpart
MM.

A
source
must
make
the
following
reports:

Notification
Reports
Requirement
Regulation
reference
Initial
notifications,
reports
of
startups,
shutdowns,
malfunctions,
construction/
reconstruction,
and
modification
63.867(
a)
63.5,
63.9(
b),
63.10(
d)(
5)

Notification
and
report
of
performance
tests
and
results
63.867(
a)
63.7(
b),
63.9(
e),
63.10(
d)(
2)
6
Notification
Reports
Requirement
Regulation
reference
Notification
of
initial
continuous
monitoring
system
(
CMS)/
continuous
opacity
monitoring
system
(
COMS)
demonstration
63.867(
a)
63.9(
g)

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

Reporting
results
of
CMS/
COMS
demonstration
63.867(
a),
63.10(
e)(
2)

Excess
emissions
reports
(
quarterly
and
semiannual)
63.867(
c)
63.10(
e)(
3)

A
source
must
keep
the
following
records:

Recordkeeping
Five­
year
retention
of
records
63.10(
b)(
1)

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

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

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

Documentation
supporting
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)
7
Notification
Reports
Requirement
Regulation
reference
Certification
that
a
nondirect
contact
evaporator
(
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)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
inlet
and
outlet
concentrations
when
determining
percent
efficiency.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10%
of
the
respondents
use
electronic
reporting.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
compliance
monitoring
system
(
CMS)
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber.

Perform
initial
performance
test,
Reference
Method
1,
1A,
2,
2A,
2C,
2D,
2F,
2G,
3,
3A,
3B,
4,
5,
17,
25A,
29,
or
308
as
applicable,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.
8
Respondent
Activities
Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

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

Transmit,
or
otherwise
disclose
the
information.
9
5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

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

Review
notifications
and
reports,
including
performance
test
reports,
excess
emissions
reports,
startup,
shutdown,
malfunction
plan,
and
quality
control
plan
for
CMS
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

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

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
Subpart
and
the
specific
process
equipment
and
pollutant.
The
requirements
reflect
the
10
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Although
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1a:
One­
Time
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM)
and
Table
1b:
Recurrent
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1a
and
1b
document
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
To
minimize
burden,
much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
onsite
at
the
facility.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
the
EPA.
In
addition,
in
many
cases
the
EPA
has
selected
parameters
for
monitoring
that
are
already
monitored
by
the
industry
for
other
purposes.
Responses
to
this
information
collection
are
mandatory.

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

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
150,043
hours
(
Total
Labor
Hours
calculated
from
Tables
1a
and
1b
as
follows).

Annual
burden
to
industry
Total
burden,
hours
Total
costs,
$

Table
1a
2,279
116,671
Table
1b
147,764
7,563,627
11
Total
150,043
7,680,298
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

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

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

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard(
s)
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

COMS1
$
41,000
3
$
123,000
8,000
108
$
864,000
CPMS1
$
0
0
$
0
0
0
$
0
Total
$
41,000
3
$
123,000
8,000
108
$
864,000
12
1
No
costs
are
included
for
continuous
opacity
monitoring
systems
(
COMS)
installed
for
recovery
furnaces
or
for
continuous
parameter
monitoring
systems
(
CPMS)
because
the
monitoring
equipment
is
already
required
for
compliance
with
the
New
Source
Performance
Standards
(
NSPS)
for
Kraft
Pulp
Mills
(
40
CFR
Subpart
BB).

The
total
capital/
startup
costs
for
this
ICR
are
$
123,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
864,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
987,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

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

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
53,097.

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

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

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
13
Based
on
our
research
for
this
ICR,
approximately
130
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
zero
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
130
0
0
130
2
0
130
0
0
130
3
0
130
0
0
130
Average
0
130
0
0
130
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
130.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
construction/
reconstruction
7
1
0
7
Notification
of
actual
startup
7
1
0
7
Notification
of
applicability
of
the
standard
7
1
0
7
Notification
of
initial
performance
test
7
1
0
7
Notification
of
performance
evaluation
7
1
0
7
14
Total
Annual
Responses
Notification
of
compliance
status
7
1
0
7
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
7
4
0
28
Semiannual
report
of
no
exceedances
123
2
0
246
Total
316
The
number
of
Total
Annual
Responses
is
316.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
7,680,298.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1a:
One­
Time
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM)
and
Table
1b:
Recurrent
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM).

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
987,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
1,037
labor
hours
at
a
cost
of
$
53,097.
See
Table
2:
Annual
Agency
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM),
below.

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

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
7,680,298.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1a:
One­
Time
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM)
and
Table
1b:
15
Recurrent
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM).
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
475
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
987,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
1,037
labor
hours
at
a
cost
of
$
53,097.
See
Table
2:
Annual
Agency
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM),
below.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
increase
in
burden
is
due
to
more
accurate
estimates
of
existing
and
anticipated
new
sources,
as
well
as
correction
of
a
calculation
error
that
applied
recurring
burden
to
only
those
facilities
installing
new
equipment,
when
in
actuality
recurring
burden
is
incurred
by
all
facilities
subject
to
the
NESHAP.
As
recalculated,
recurring
burden
is
the
overall
annual
facility
burden
for
NESHAP
compliance
(
Table
1b).
This
is
contrasted
with
the
one­
time
burden
incurred
by
the
facility
for
the
installation
of
new
control
equipment
(
Table
1a).
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
have
also
been
revised
to
include
both
capital/
startup
and
operation
and
maintenance
(
O&
M)
costs
that
were
omitted
from
the
previous
ICR.
The
costs
now
include
continuous
opacity
monitoring
systems
(
COMS)
that
were
not
previously
required
for
compliance
with
the
New
Source
Performance
Standards
(
NSPS)
for
Kraft
Pulp
Mills
(
40
CFR
Subpart
BB).

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
475
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
16
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

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

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0020,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0020
and
OMB
Control
Number
2060­
0377
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
1a.
One­
Time
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,

Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM)

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
16.1
824
B.
Required
activities
included
in
3E
C.
Create
information
included
in
3E
D.
Gather
existing
information
included
in
3E
E.
Write
report
°
Notification
of
construction/

reconstruction
2
1
2
7
c
14
0.7
1.4
16.1
824
°
Notification
of
actual
startup
2
1
2
7c
14
0.7
1.4
16.1
824
°
Notification
of
applicability
of
the
standard
2
1
2
7c
14
0.7
1.4
16.1
824
°
Notification
of
initial
performance
test
2
1
2
7f
14
0.7
1.4
16.1
824
°
Notification
of
performance
evaluation
2
1
2
7c
14
0.7
1.4
16.1
824
°
Notification
of
compliance
status
80
1
80
7c
560
28.0
56.0
644.0
32,965
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
Included
in
4D
C.
Implement
activities
Included
in
4D
D.
Develop
record
system
40g
1
40
7
c
280
14
28.0
322.0
16,482
E.
Develop
startup,
shutdown,
and
malfunction
plan
100h
1
100
7
c
700
35
70.0
805.0
41,206
F.
Time
to
enter
information
°
Records
and
documentation
of
supporting
calculations
for
compliance
determinations
8
1
8
7
c
56
2.8
5.6
64.4
3,296
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
°
Records
of
compliant
monitoring
parameter
ranges
2
1
2
7
c
14
0.7
1.4
16.1
824
°
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
471
G.
Time
to
train
personnel
40j
1
40
7
c
280
14
28.0
322.0
16,482
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDE:
k
1,982
99
198
2,279
$
116,671
Footnotes
aSee
Section
4(
b)(
ii)
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
64.60/
hour
for
technical
labor,
$
95.32/
hour
for
management
labor,
and
$
40.09/
hour
for
clerical
labor.

cAssumes
four
existing
kraft
pulp
mills
will
each
install
one
new
recovery
furnace
and
smelt
dissolving
tank
(
SDT)
and
three
existing
kraft
pulp
mills
will
each
install
one
new
lime
kiln
each
year.

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
continuous
parameter
monitoring
system
(
CPMS)
performance
evaluation
each
year.
Assumes
four
new
recovery
furnaces
and
three
new
lime
kilns
will
be
required
to
conduct
a
continuous
opacity
monitoring
system
(
COMS)
performance
evaluation
each
year.
Assumes
five
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
year.

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

hAssumes
one
person
would
take
two
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
four
existing
kraft
and
soda
pulp
mills
will
install
new
recovery
furnaces
each.
Based
on
current
industry
trends,
these
new
furnaces
are
expected
to
be
nondirect
contact
evaporator
(
NDCE)

recovery
furnaces
equipped
with
a
dry
electrostatic
precipitator
(
ESP)
system.

jAssumes
one
week
(
40
hours)
to
train
personnel.

kThe
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.
TABLE
1b.
Recurrent
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,

Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM).

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
included
in
3E
B.
Required
activities
included
in
3E
C.
Create
information
included
in
3E
D.
Gather
existing
information
included
in
3E
E.
Write
report
°
Excess
emissions
report
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
16c
4
64
7d,
e
448
22.4
44.8
515.2
26,372
Semiannual
report
of
no
exceedances
8f
2
16
123d,
e
1,968
98.4
196.8
2263.2
115,847
4.
Recordkeeping
Requirements
A.
Read
instructions
included
in
4E
B.
Plan
activities
included
in
4E
C.
Implement
activities
included
in
4E
D.
Develop
record
system
included
in
4E
E.
Time
to
enter
information
°
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
130
d
10,140
507.0
1,014.0
11,661.0
596,896
°
Records
of
black
liquor
solids
firing
rates
for
recovery
furnaces
and
semichemical
combustion
units
1.5
52
78
130
d
10,140
507.0
1,014.0
11,661.0
596,896
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
lime
production
rates
for
lime
kilns
1.5
52
78
108
d
8,424
421.2
842.4
9687.6
495,883
°
Records
of
CMS
data
Record
continuously
monitored
parameters
(
per
shift)
0.5
1,050
525
130d
68,250
3,412.5
6,825
78,487.5
4,017,570
Compile
monthly
data
16
12
192
130d
24,960
1,248
2,496
28,704
1,469,283
Enter/
verify
information
for
quarterly/
semiannual
reports
8
2
16
130d
2,080
104
208.0
2,392.0
122,440
F.
Time
to
train
personnel
N/
Ag
G.
Time
for
refresher
training
for
personnel
16g
1
16
130
d
2,080
104
208.0
2,392.0
122,440
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
h
128,490
6,425
12,849
147,764
$
7,563,627
Footnotes
aSee
Section
4(
b)(
ii)
for
a
further
explanation
of
respondent
activities.

bCosts
assume
a
rate
of
$
64.60/
hour
for
technical
labor,
$
95.32/
hour
for
management
labor,
and
$
40.09/
hour
for
clerical
labor.

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

dAssumes
130
existing
mills
subject
to
the
MACT,
all
108
existing
kraft
pulp
mills
have
lime
kilns.

eAssumes
five
percent
of
respondents
(
0.05
*
130
=
7)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
130
=
123)
report
no
exceedances.

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

gAssumes
two
days
(
16
hours)
to
provide
refresher
training
for
personnel.
Initial
time
to
train
personnel
included
in
Table
1a.

hThe
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.
TABLE
2.
Annual
Agency
Burden
and
Cost:
NESHAP
for
Chemical
Recovery
Combustion
Sources
at
Kraft,
Soda,
Sulfite,
and
Stand­
Alone
Semichemical
Pulp
Mills
(
40
CFR
Part
63,
Subpart
MM).

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
2,355
2.
Excess
emissions­­
enforcement
activities
48
1
48
1d,
e
48
2.4
4.8
55.2
2,826
3.
Report
review
°
Review
of
notification
of
construction/
reconstruction
2
1
2
7
b
14
0.7
1.4
16.1
824
°
Review
of
notification
of
actual
startup
2
1
2
7b
14
0.7
1.4
16.1
824
°
Review
of
notification
of
applicability
2
1
2
7b
14
0.7
1.4
16.1
824
°
Review
of
notification
of
initial
performance
test
2
1
2
7b
14
0.7
1.4
16.1
824
°
Review
of
notification
of
performance
evaluation
2
1
2
7b
14
0.7
1.4
16.1
824
°
Review
of
notification
of
compliance
status
4
1
4
7b
28
1.4
2.8
32.2
1,648
°
Review
of
excess
emissions
report
Quarterly
reports
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
7d,
f
224
11.2
22.4
257.6
13,186
Semiannual
reports
of
no
exceedances
2
2
4
123d,
f
492
24.6
49.2
565.8
28,962
TOTAL
BURDEN
AND
COSTg
902
45
90
1,037
53,097
aCosts
assume
a
rate
of
$
40.56/
hour
for
technical
labor,
$
54.66/
hour
for
management
labor,
and
$
21.95/
hour
for
clerical
labor.

bAssumes
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.

Seven
mills
will
be
required
to
conduct
an
initial
performance
test.
Assumes
EPA
personnel
attend
eight
percent
of
the
tests
(
0.08
*
11
tests
=
1
test
attended).

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

dAssumes
130
existing
mills
subject
to
the
MACT.

eAssumes
five
percent
of
mills
are
required
to
retest
as
a
result
of
excess
emissions,
and
that
EPA
personnel
attend
10
percent
of
these
tests
(
0.05
*
130
*
0.1
=
1
retest
attended).

fAssumes
five
percent
of
respondents
(
0.05
*
130
=
7)
report
monitoring
exceedances
and
95
percent
of
respondents
(
0.95
*
22
=
123)
report
no
exceedances..

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