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), EPA ICR Number 1805.06, OMB Control Number 2060-0377

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 were published at 40 CFR part 63,
subpart MM, 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.  In addition, owners or
operators are 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 will
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency regional office.

Approximately 111 sources are currently subject to the standard.  There
are 89 kraft mills, 9 kraft and semichemical mills, 1 kraft and sulfite
mill, 7 stand-alone semichemical mills, 4 sulfite mills, and 1 soda
mill.  It is estimated that no additional sources will become subject to
the regulation; however, one of the existing facilities will be engaged
in a modification each year over the three-year period of this rule.

There are approximately 111 chemical recovery combustion sources at
kraft, soda, sulfite, and stand-alone semichemical pulp mills in the
United States.  None of the 111 facilities in the United States are
owned by state, local, tribal or the Federal government.  They are owned
and operated by privately owned for-profit businesses.  You can find the
burden to the “Affected Public” listed below in Table 1a, and 1b:
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 Federal government burden
does not include work performed by Federal employees.  The burden refers
only to work performed by contractors, which could be found listed below
in Table 2: Average Annual EPA Burden - NESHAP for Chemical Recovery
Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical
Pulp Mills (40 CFR Part 63, Subpart MM).

In the development of the ICR, we addressed the Office of Management and
Budget (OMB) “Terms of Clearance (TOC)” on the active ICR.  The TOC
are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, labor rates, and capital costs, and ensure these estimates
have been updated.

EPA has addressed each item of concern in the TOC.  The respondent
burden, universe, labor rates, and capital cost, have been thoroughly
checked and all estimates updated.

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 (HAP). 
These standards are applicable to new or existing sources of HAP 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 (HCI), methanol, methyl ethyl ketone, and toluene
hazardous air pollutant (HAP) emissions from chemical recovery
combustion sources at kraft, soda, sulfite, and stand-alone semichemical
pulp mill cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare.  Therefore, the NESHAP
was promulgated for this source category at 40 CFR part 63, subpart MM.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations.  The reviewing authority may then inspect the source
to ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

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.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart MM.

3(a)  Non-duplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted 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.

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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts.  

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed.  In developing this ICR, we contacted the
American Forest and Paper Association (AF&PA) at (202) 463-2700, and the
America Wood Council at (202) 463-2766.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the 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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents 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.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

3(f)  Confidentiality

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

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

	

The respondents to the recordkeeping and reporting requirements are
chemical recovery combustion sources at kraft, soda, sulfite, and
stand-alone semichemical pulp mills.  The United States Standard
Industrial Classification (SIC) codes for the respondents affected by
the standards, which corresponds to The North American Industry
Classification System (NAICS) codes, are listed below for source
category description.

Standard (40 CFR Part 63, Subpart MM)	SIC Codes	NAICS Codes

Pulp Mills	2611	32211

Paper Mills	2621	32212

Paperboard Mills	2631	32213



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants for Chemical Recovery
Combustion Sources at Kraft, Soda, Sulfite and Stand-Alone Semichemical
Pulp Mills (40 CFR Part 63, Subpart MM).

A source must make the following reports:

Notification Reports

Initial notifications, reports of startups, shutdowns, malfunctions,
construction/reconstruction, and modification	63.5, 63.9(b),
63.10(d)(5), 

63.867(a)

Notification and report of performance test and results	63.7(b),
63.9(e), 63.10(d)(2), 63.867(a)

Notification of initial continuous monitoring system (CMS)/ continuous
opacity monitoring system (COMS) demonstration	63.9(g), 63.867(a)

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

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

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

Certification that a non-direct contact evaporator (NDCE) recovery
furnace equipped with a dry electrostatic precipitation (ESP) system is
used to comply with a gaseous organic HAP standard in 63.862(c)(1)
63.866(c)(6)



A source must keep the following records:

Recordkeeping

Five years retention of records	63.10(b)(1) 

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

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 notification 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 section 63.864	63.866(c)(3)

Supporting calculations for compliance determinations made under section
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
section 63.862(1)	63.866(c)(6)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must continue to evaluate the data, internal
automation has significantly reduced the burden associated with
monitoring and recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate 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 notification 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.

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.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  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.

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, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA 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 majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these to be the minimum
requirements needed to ensure compliance and, therefore, cannot reduce
them further for small entities.  To the extent that larger businesses
can use economies of scale to reduce their burden, the overall burden
will be reduced.

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 in 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) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1a and 1b documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Wherever appropriate,
specific tasks and major assumptions have been identified.  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
126,207 (Total Labor Hours from Tables 1a, and 1b).  These hours are
based on Agency studies and background documents from the development of
the regulation, Agency knowledge and experience with the NESHAP program,
the previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

This ICR uses the following labor rates:

Managerial	$118.92 ($56.63 + 110%)   

Technical	$97.78 ($46.56 + 110%)

Clerical	$48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2010, "Table 2. Civilian Workers, by
Occupational and Industry group."  The rates are from column 1, "Total
Compensation."  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

	

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The type of industry costs associated with the information collection
activities in the subject standard 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 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 1	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents 	(D)

Total Capital/Startup 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)

COMS	$41,000	0	$0	$8,000	89	$712,000

CPMS	$0	0	$0	$0	0	$0

Total	$41,000	0	$0	$8,000	89	$712,000

 	1 No costs are included for continuous opacity monitoring system
(COMS) installed for recovery furnaces or for continuous parameter
monitoring systems (CPMS) because the monitoring equipment is already
required for compliance with the NSPS for Kraft Pulp Mills (40 CFR
Subpart BB).

The total capital/startup costs for this ICR is $0.  This is the total
of column D in the above table.

The total operation and maintenance (O&M) cost is $712,000 for
photocopying, and postage.  This is the total of column G.

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 $712,000.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $17,585.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP for Chemical
Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

	

	Based on our research for this ICR, on average over the next three
years, approximately 111 respondents will be subject to the standard. 
It is estimated that no additional new sources will become subject to
the rule.  The overall average number of respondents, as shown in the
table below is 111 per year. 

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

Number of Respondents

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	1	111	0	1	111

2	1	111	0	1	111

3	1	111	0	1	111

Average	1	111	0	1	111

1 The new respondent includes 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 111.

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	1	1	0	1

Notification of actual startup	1	1	0	1

Notification of applicability of standards	1	1	0	1

Notification of initial performance test	1	1	0	1

Notification of performance evaluation	1	1	0	1

Notification of compliance status	1	1	0	1

Quarterly report of monitoring exceedances and periods of noncompliance
6	4	0	24

Semiannual report of no exceedances	105	2	0	210



	Total	240



The number of Total Annual Responses is 240.

The total annual labor costs are $11,918,524.  Details regarding these
estimates may be found in Table 1a and 1b: Annual Industry 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) (Renewal).

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, 1b, and 2,
respectively, and summarized below. 

(i)  Respondent Tally

The total annual labor costs are $11,918,524.  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) (Renewal), 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) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 526 hours per
response.

The total annual capital/startup and operation and maintenance (O&M)
costs to the regulated entity are $721,000.  

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 476 -labor hours at a cost of $17,585.  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) (Renewal).

6(f)  Reasons for Change in Burden

The adjusted decrease in burden from the most recently approved ICR is
due to a more accurate estimate of existing and anticipated new sources.
 After consulting the Office of Air Quality Planning and Standards
(OAQPS) and trade associations, our data indicates that there are
approximately 111 sources subject to the rule, as compared with the
active ICR that shows 130 sources.  No new facilities are expected to be
constructed over the next three years of this ICR.  The decline in the
number of sources is due mainly to plant closures.  This industry is
undergoing widespread consolidation and corporate restructuring. 
However, there is an increase in cost per labor hours due to the updated
labor rates.

Because there are no new sources with reporting requirements, no
capital/startup costs are incurred.  The only cost that is incurred is
for the operation and maintenance (O&M) of the monitoring equipment.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 526 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA 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
EPA-HQ-OECA-2011-0209.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
http://www.regulations.gov/  which may be used to obtain a copy of the
draft collection of information, submit or view public comments, access
the index listing of the content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than key in the docket ID number
identified in this document.  The documents are also available for
public viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301
Constitution Avenue, N.W., 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. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, N.W.,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0209 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 item	(A)

Person

hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours per year

(Ex0.1)	(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting requirements









     A.  Read instructions c 	2	1	2	1	2	0.1	0.2	$217.20

  B.  Required activities	See 3E







	  C.  Create information	See 3E







	  D.  Gather existing information	See 3E







	  E.  Write Report









        Notification of construction/reconstruction c , d               
                                                 	2	1	2	1	2	0.1	0.2
$217.20

        Notification of actual startup c, d	2	1	2	1	2	0.1	0.2	$217.20

        Notification of applicability of  standard c, d	2	1	2	1	2	0.1
0.2	$217.20

        Notification of initial performance test c, d	2	1	2	1	2	0.1	0.2
$217.20

        Notification of  performance evaluation  c, d                   
                                        	2	1	2	1	2	0.1	0.2	$217.20

        Notification of compliance status  c, e	80	1	80	1	80	4	8
$8,688.16

Subtotal for Reporting Requirements





105.8



4.  Recordkeeping requirements









  A.  Read instructions 	See 3A







	  B.  Plan activities	See 4D







	  C.  Implement Activities 	See 4D







	  D.  Develop record system c, f	40	1	40	1	40	2	4	$4,344.08

  E.  Develop startup, shutdown, and

        malfunction plans c, g     	100	1	100	1	100	5	10	$10,860.20

  F.  Time to enter information









      -  Records and documentation of supporting 

         calculations for compliance determinations c, h	8	1	8	1	8	0.4
0.8	$868.82

     -  Record of compliant monitoring parameter

         ranges c   	2	1	2	1	2	0.1	0.2	$217.20

     -  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 c, i	2	1	2	1	2	0.1	0.2	$217.20

  G.  Time to train personnel c, j	40	1	40	1	40	2	4	$4,341.68

Subtotal for Recordkeeping Requirements





220.08



Subtotals Labor Burden and cost  



	284	14.2	28.4	$30,840.54

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	326.6

327(rounded)	$30,840



Assumptions:

a  We have assumed that the average number of existing sources subject
to the rule will be 111.  There will be no additional new sources per
year that will become subject

to the rule, and one affected facility will be engaged in some kind of
modification over the three-year period of this ICR.                    
                                         

b This ICR uses the following labor rates:  $118.92 per hour for
Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour

for Clerical labor.  These rates are from the United States Department
of Labor, Bureau of Labor Statistics, December, 2010, Table 2. Civilian
Workers, by Occupational

and Industry groups.  The rates are from column 1, Total Compensation. 
The rates have been increased by 110 percent to account for the benefit
packages available to

those employed by private industry.

c  We have assumed that one existing kraft pulp mills will install one
new recovery furnace and smelt dissolving tank (SDT) each year.

d  We have assumed that it will take respondent 2 hours once per year to
complete report.

e  We have assumed that it will take respondent 80 hours once per year
to write the notification of compliance status report.

f  We have assumed that it will take respondent 40 hours to develop a
record system for recording parameter monitoring information.

g  We have assumed that it will take respondent 80 hours once per year
to draft the startup, shutdown, and malfunction plan, and an additional
20 hours to review/revisions, for a total of 100 hours.

h  We have assumed that it will take respondent eight hours (1 day) each
year to enter records and documentation of supporting calculation for
compliance determinations.

i  We have assumed that one existing kraft and soda pulp mill will
install new recovery furnaces.  Based on current industry trends, the
new furnace is expected to be non-direct contact evaporator (NDCE)
recovery furnaces equipped with a dry electrostatic precipitator (ESP)
system.

j  We have assumed  that it will take respondent 40 hours (1 week) once
per year to train personnel. 

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 item	(A)

Person

hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours per year

(Ex0.1)	(H)

Cost, $  b

1.  Applications	N/A







	2.  Surveys and studies	N/A







	3.  Reporting requirements









 Read instructions	See 3E







	 Required activities	See 3E







	 Create information	See 3E







	 Gather existing information	See 3E







	 Write report









                Excess emissions report









                Quarterly report of monitoring

                exceedances and periods of  

                noncompliance c	16	4	64	6	384	19.2	38.4	$41,703.16

                Semiannual report of no exceedances d	8	2	16	105	1,680
84	168	$182,451.36

Subtotal for Reporting Requirements





2,373.6



4.  Recordkeeping requirements









Read instructions 	See 4E







	     b.    Plan activities	See 4E







	     c.    Implement activities	See 4E







	       d.    Develop record system  	See 4E







	    e.     Time to enter information









  Records of startup, shutdown, and 

  malfunction e        	1.5	52	78	111	8,658	432.9	865.8	$940,276.12

  Records of black liquor solids firing

  rates for recovery furnaces and   

         semichemical combustion units e	1.5	52	78	111	8,658	432.9	865.8
$940,276.12

              Records of lime production for lime

              kilns f	1.5	52	78	89	6,942	347.1	694.2	$753,915.08

              Records of CMS data      









                  Record continuously monitored g

                  parameters (per shift)	0.5	1,050	525	111	58,275
2,913.75	5,827.5	$6,328,781.55

                 Compile monthly data h	16	12	192	111	21,312	1,065.6
2,131.2	$2,314,525.82

                 Enter/verify information for quarterly/

                 semiannual reports i	8	2	16	111	1,776	88.8	177.6
$192,877.16

  F.  Time to train personnel 	N/A







	  G.  Time for refresher training for personnel j	16	1	16	111	1,776
88.8	177.6	$192,877.16

Subtotal for Recordkeeping Requirements





123,506.55



Subtotals Labor Burden and cost  



	109,461	5,473.05	10,946.1	$11,887,683.53

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	125,880.15

125,880 (rounded)	$11,887,683



Assumptions:

a  We have assumed that the average number of existing sources subject
to the rule will be 111.  There will be no additional new sources per
year that will become subject

to the rule over the three-year period of this ICR. 

b This ICR uses the following labor rates:  $118.92 per hour for
Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour

for Clerical labor.  These rates are from the United States Department
of Labor, Bureau of Labor Statistics, December, 2010, Table 2. Civilian
Workers, by Occupational

and Industry groups.  The rates are from column 1, Total Compensation. 
The rates have been increased by 110 percent to account for the benefit
packages available to

those employed by private industry.

c  We have assumed that five percent of respondents will each take 16
hours four times per year to complete reports of monitoring exceedances
and periods of noncompliance.

d  We have assumed that 95 percent of respondents will each take 8 hours
two times per year to write reports of no exceedances.

e  We have assumed that each respondent will take 1.5 hours 52 times per
year to accomplish the task.

f  We have assumed that each of the respondents of  kraft pulp mills
will take 1.5 hours 52 times per week to enter the lime production rates
information.  All of the 89 existing kraft pulp mills have lime kilns.

g  We have assumed that each respondent will take 0.5 hours 1,050 times
per year to record continuously monitoring parameters.

h  We have assumed that each respondent will take 16 hours once per
month to compile data.

i  We have assumed that each respondent will take 8 hours two times per
year to verify information for reports.

j  We have assumed  that it will take each respondent 16 hours to
provide refresher training for personnel. 



Total 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)

 

Annual Burden to Industry	Total Burden Hours Reporting	Total Burden
Hours Recordkeeping	Total Burden Hours	Total Costs, $

Table 1a: One-Time Annual Respondent Burden and Cost	105.8	220.8	326.6
$30,840.54

Table 1b: Recurrent Annual Respondent Burden and Cost	2,373.6	123,506.55
125,880.15	$11,887,683.53

TOTAL LABOR BURDEN AND COST  

(rounded)	2,479.4	123,727.35	126,206.75

(rounded) 126,207	        $11,918,524.07

(rounded) $11,918,524



Table 2:  Average Annual EPA Burden - NESHAP for Chemical Recovery
Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical
Pulp Mills (40 CFR Part 63, Subpart MM)

Activity	(A)

EPA person-

hours per

occurrence	(B)

No. of

occurrences

per plant

 per year	(C)

EPA person

hours per

plant per year

(C=AxB)	(D)

Plants per year b  	(E)

Technical

person-

hours

per year

(E=CxD)	(F)

Management

person-hours

per year

(Ex0.05)

	(G)

Clerical

person-

hours per year

(Ex0.1)	(H)

Cost, $ a

Report review









     Notification of construction/reconstruction c	2	1	2	1	2	0.1	0.2
$103.65

     Notification of actual startup c	2	1	2	1	2	0.1	0.2	$103.65

     Notification of applicability c	2	1	2	1	2	0.1	0.2	$103.65

     Notification of initial performance test c	2	1	2	1	2	0.1	0.2
$103.65

     Notification of performance evaluation c	2	1	2	1	2	0.1	0.2	$103.65

     Review of notification of compliance status d	4	1	4	1	2	0.1	0.2
$103.65

     Review of excess emissions report 









        Quarterly reports of monitoring

        exceedances and periods of noncompliance e	8	4	32	6	192	9.6	19.2
$6.079.98

        Semiannual reports of no exceedances f	2	2	4	105	210	10.5	21
$10,883.14

Subtotals Labor Burden and cost



	414	20.7	41.4	$17,585.02

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	476.1

476 (rounded)	$17,585



 	Assumptions:

a  This cost is based on the following labor rates which incorporate a
1.6 benefits multiplication factor to account for government overhead
expenses: $62.27

Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate
(GS-12, Step 1, $28.99 x 1.6), and $25.01 Clerical rate (GS-6, Step 3,
$15.63 x 1.6).  These rates are 

from the Office of Personnel Management (OPM) 2011 General Schedule
which excludes locality rates of pay.

      b  We have assumed that the average number of existing sources
subject to the rule will be 111.  There will be no additional new
sources per year that will become                                       


 subject to the rule, and one affected facility will be engaged in some
kind of modification  each year over the three-year period of this rule.

c  We have assumed that it will take respondent 2 hours once per year to
complete report review.

d  We have assumed that it will take respondent 4 hours once per year to
review the compliance status report.

e  We have assumed that five percent of respondents (5% x 111 = 6) will
each take 8 hours four times per year to review the monitoring
exceedances and periods of noncompliance report.

f  We have assumed that 95 percent of respondents (95% x 111 = 105) will
each take 2 hours two times per year to review the no exceedances
report.

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