Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
i
VOLUNTARY
CERTIFICATION
IN
LIEU
OF
CHLOROFORM
MINIMUM
MONITORING
REQUIREMENTS
FOR
DIRECT
AND
INDIRECT
DISCHARGING
MILLS
IN
THE
BLEACHED
PAPERGRADE
KRAFT
AND
SODA
SUBCATEGORY
OF
THE
PULP,
PAPER
AND
PAPERBOARD
MANUFACTURING
CATEGORY
(
40
CFR
PART
430)

November
2001
U.
S.
Environmental
Protection
Agency
Office
of
Water
Engineering
and
Analysis
Division
401
M
Street,
SW
Washington,
D.
C.
20460
TABLE
OF
CONTENTS
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
ii
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
Need/
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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3
3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3
3(
a)
Non­
duplication
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3
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
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3
3(
c)
Consultations
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4
3(
d)
Effects
of
Less
Frequent
Data
Collection
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4
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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5
3(
g)
Sensitive
Questions
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5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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5
4(
a)
Respondents
and
SIC
Codes
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5
4(
b)
Information
Requested
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5
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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6
5(
a)
Agency
Activities
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6
5(
b)
Collection
Methodology
and
Management
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7
5(
c)
Small
Entity
Flexibility
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7
5(
d)
Collection
Schedule
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8
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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8
6(
a)
Estimating
Respondent
Burden
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8
6(
b)
Estimating
Respondent
Cost
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11
6(
c)
Estimating
Agency
Burden
and
Cost
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12
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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12
6(
e)
Burden
Statement
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13
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
iii
LIST
OF
TABLES
Table
6.1
Number
of
Eligible
Mills
and
Lines
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8
Table
6.2
Recurring
Burden
for
Activities
Related
to
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
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10
Table
6.3
Recurring
Burden
Reduction
from
Minimum
Monitoring
required
by
40
CFR
430.02
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10
Table
6.4
Total
Burden
Reduction
Resulting
from
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
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11
Table
6.5
Summary
of
Incurred
and
reduced
Annual
Respondent
Burden
and
Costs
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13
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Voluntary
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
for
Direct
and
Indirect
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
EPA
ICR
No.
2015.01).

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
presents
estimates
of
the
burden
and
costs
to
the
regulated
community
for
voluntary
certification
in
lieu
of
chloroform
monitoring,
reporting,
and
recordkeeping
associated
with
implementation
of
the
minimum
monitoring
requirements
of
the
Pulp,
Paper
and
Paperboard
Effluent
Limitations
Guidelines
and
Standards
(
Cluster
Rules;
40
CFR
Part
430),
which
were
published
on
April
15,
1998
for
mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
(
Subpart
B).
See
63
FR
18504­
18751.
Certification
in
lieu
of
chloroform
minimum
monitoring
requirements
allows
direct
and
indirect
discharging
Subpart
B
mills
to
demonstrate
compliance
with
applicable
chloroform
limitations
and
standards
under
40
CFR
Part
430
in
lieu
of
monitoring
at
a
fiber
line
required
by
40
CFR
430.02
by
voluntarily
certifying
(
1)
that
the
fiber
line
is
not
using
elemental
chlorine
or
hypochlorite
as
bleaching
agents
and
(
2)
that
it
also
maintains
certain
process
and
operating
conditions
identified
during
the
initial
compliance
demonstration
period.

Initial
compliance
demonstration
consists
of
the
time
period,
not
less
than
two
years,
during
which
104
monitoring
data
measurements
are
collected
per
minimum
monitoring
required
by
40
CFR
430.02
(
or
more
frequently
if
required
by
the
permitting
or
pretreatment
control
authority)
for
each
fiber
line
the
facility
wishes
to
certify.
During
this
time
period,
the
facility
will
monitor
and
maintain
records
of
the
range
of
certain
process
and
operating
conditions
that
the
fiber
lines
are
operated
within.
The
collected
monitoring
data
will
be
used
to
demonstrate
compliance
with
applicable
chloroform
limitations
and
standards
for
each
fiber
line
and
provide
confirmation
that
the
fiber
line,
if
operated
within
the
range
of
certain
process
and
operating
conditions
identified
during
the
initial
compliance
demonstration
period,
continues
to
comply
with
the
chloroform
limitations
and
standards.

Facilities
that
choose
to
certify
any
or
all
of
their
fiber
lines
with
their
NPDES
permit
or
pretreatment
control
authority,
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
Part
430,
will
be
required
to
submit
periodic
reports
certifying
that
the
fiber
line(
s)
are
operating
within
the
range
of
certain
process
and
operating
conditions
identified
during
the
initial
compliance
demonstration
period.
Mills
that
voluntarily
choose
to
certify
will
be
required
to
maintain
records
of
certain
process
and
operating
conditions,
and
also
will
be
required
to
notify
their
NPDES
permit
or
pretreatment
control
authority
if
their
certified
fiber
lines
no
longer
operate
within
the
range
of
process
and
operating
conditions.
At
the
discretion
of
the
NPDES
permit
or
pretreatment
control
authority,
the
facility
may
then
be
required
to
again
monitor
at
their
fiber
lines
as
required
by
40
CFR
430.02.
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
2
Applicable
facilities
that
choose
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
will
experience
a
total
reduction
in
overall
monitoring,
reporting,
and
analytical
burden
and
costs
associated
with
the
minimum
monitoring
required
by
40
CFR
430.02.
The
universe
eligible
for
certification
in
lieu
of
chloroform
minimum
monitoring
consists
of
84
direct
and
indirect
discharging
Subpart
B
mills.

This
is
a
new
ICR
covering
the
incurred
burden
and
costs
for
the
estimated
80
out
of
the
universe
of
84
direct
and
indirect
discharging
Subpart
B
mills
that
are
anticipated
to
voluntarily
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
and
the
subsequent
overall
reduction
in
burden
and
costs
incurred
by
these
facilities
as
a
result
of
reduced
monitoring,
reporting,
and
analytical
requirements
per
40
CFR
430.02.
This
ICR
does
not
cover
the
burden
and
costs
for
State
NPDES
permit
and
pretreatment
control
authorities
or
EPA
associated
with
facilities
certifying
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
because
it
is
anticipated
that
there
will
be
an
exact
trade­
off
between
the
burden
and
costs
incurred
from
reviewing
periodic
certification
reports
for
voluntarily
participating
fiber
lines
versus
reviewing
periodic
chloroform
monitoring
data
for
facilities
complying
with
40
CFR
430.02.
Incurred
burden
and
costs
of
certification
for
State
NPDES
permit
authorities
or
EPA
are
described
in
the
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB
2040­
NEW)
for
direct
dischargers.
The
burden
and
cost
of
certification
for
pretreatment
control
authorities
are
generically
covered
by
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers.
Review
functions
that
may
incur
burden
include
actions
in
response
to
a
mill
voluntarily
choosing
to
certify
in
lieu
of
monitoring
that
notifies
their
NPDES
permit
or
pretreatment
control
authority
that
its
participating
fiber
line(
s)
are
operating
outside
the
range
of
process
and
operating
conditions
identified
during
the
initial
compliance
demonstration
period.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
As
mentioned
above,
EPA
established
minimum
monitoring
frequencies
for
chloroform
for
existing
and
new
direct
and
indirect
discharging
mills
within
Subpart
B
under
authority
of
Clean
Water
Act
(
CWA)
Section
308
to
demonstrate
compliance
with
existing
effluent
limitations
and
standards
for
chloroform
(
and
other
pollutant
parameters)
promulgated
under
40
CFR
Part
430.
EPA
is
also
allowing
applicable
facilities
to
voluntarily
demonstrate
compliance
with
chloroform
limitations
and
standards
by
certifying
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02.
EPA
has
determined
that
this
voluntary
certification
option
significantly
reduces
the
overall
compliance
burden
and
costs
associated
with
meeting
and
demonstrating
compliance
with
applicable
chloroform
limitations
and
standards.
EPA
has
also
determined
that
an
initial
compliance
demonstration
is
necessary
for
each
participating
mill
to
establish
the
range
of
normal
variability
in
process
and
operating
parameters
that
are
consistent
with
compliance
with
the
chloroform
effluent
limitations.
Once
this
range
is
established
for
each
participating
fiber
line,
periodic
certification
reports
are
submitted
to
the
NPDES
permit
or
pretreatment
control
authority
to
confirm
and
certify
that
the
fiber
line
continues
to
comply
with
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
3
the
chloroform
effluent
limitations
and
standards.
The
Agency's
authority
to
provide
for
this
voluntary
certification
option
in
lieu
of
minimum
monitoring
is
Section
402(
a)(
2)
of
the
CWA
which
directs
EPA
to
prescribe
permit
conditions
to
assure
compliance
with
requirements
"
including
conditions
on
data
and
information
collection,
reporting
and
such
other
requirements
as
[
the
Administrator]
deems
appropriate."

2(
b)
Practical
Utility/
Users
of
the
Data
The
primary
users
of
the
data
are
the
owners
and
operators
of
direct
and
indirect
discharging
pulp
and
paper
mills
in
Subparts
B
and
NPDES
permitting,
pretreatment
control
and
enforcement
authorities.
Citizen
groups
also
use
this
data
to
independently
assess
facility
compliance.

EPA
expects
that
the
initial
compliance
demonstration
and
periodic
certification
reports
will
be
used
by
NPDES
and
pretreatment
control
authorities
to
determine
compliance
with
the
Cluster
Rules
effluent
limitations
and
standards
for
chloroform,
establish
permit
and
pretreatment
control
agreement
conditions
to
include
the
voluntary
certification
option,
and
revise
permit
requirements
as
may
be
necessary
based
on
data
from
the
initial
compliance
demonstration,
certification
reports,
and
any
additional
information
and
data
the
mill
may
be
required
to
report.
EPA
anticipates
that
State
and
NPDES
permitting
and
pretreatment
control
authorities
will
only
need
to
conduct
detailed
technical
reviews
of
certification
reports
in
the
event
the
reports
indicate
noncompliance
with
the
NPDES
permit
or
pretreatment
control
agreement.

Mills
that
voluntarily
choose
to
participate
may
elect
to
assert
claims
of
confidential
business
information
(
CBI),
according
to
the
provisions
of
40
CFR
Part
2,
on
any
portions
of
the
process
and
operating
data
submitted
to
support
a
certification
in
lieu
of
minimum
monitoring
for
chloroform.
However,
CBI
claims
will
not
be
appropriate
for
periodic
reports
simply
certifying
that
mill
operations
remain
within
the
ranges
of
process
and
operating
parameters
established
during
the
initial
compliance
demonstration.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
430,
501,
and
503.
The
Agency
also
has
consulted
the
following
sources
of
information
to
determine
if
similar
or
duplicate
information
is
available
elsewhere:

$
EPA
Information
Systems
Inventory,

$
Government
Information
Locator
System
(
GILS),
and
$
Toxic
Chemical
Release
Inventory.
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
4
Examination
of
these
databases
revealed
no
duplicate
collection
requirements.
EPA
has
concluded
that
there
is
no
other
way
to
obtain
the
initial
compliance
demonstration
and
certification
information
addressed
in
this
ICR.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
EPA
solicited
comments
on
this
ICR
prior
formal
submission
to
OMB.
EPA
published
a
formal
notice
in
the
Federal
Register
on
March
19,
2001
(
66
FR
15424­
15427).
EPA
received
no
comments.
EPA
received
one
comment.

3(
c)
Consultations
As
mentioned
above,
EPA
solicited
public
comments
on
the
current
draft
ICR.
Additionally,
EPA
has
consulted
with
the
public,
industry
and
States
on
the
certification
in
lieu
of
chloroform
minimum
monitoring
requirements.

3(
d)
Effects
of
Less
Frequent
Data
Collection
The
certification
option
requires
the
collection
of
104
measurements
of
chloroform
data
over
a
period
not
less
than
two
years
during
the
initial
compliance
demonstration
period
per
minimum
monitoring
required
by
40
CFR
430.02
(
or
more
frequently
if
required
by
the
permitting
or
pretreatment
control
authority),
documenting
of
process
and
operating
conditions,
and
subsequent
monthly
reporting
and
recordkeeping
via
periodic
certification
reports.
Chloroform
minimum
monitoring
required
by
40
CFR
Part
430
as
part
of
the
initial
compliance
demonstration
is
described
in
the
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB
____­____)
for
direct
dischargers
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers.
Mill
operators
collect
such
data
on
process
and
operating
conditions
independent
of
this
requirement
for
purposes
of
monitoring
and
optimizing
bleach
plant,
chemical
recovery,
and
wastewater
treatment
plant
operations.
EPA
determined
that
the
number
of
chloroform
data
points
collected
during
the
initial
compliance
demonstration
are
necessary
because
there
are
potentially
many
sources
of
variability
in
effluent
discharges
of
unit
operations
in
each
participating
fiber
line.
While
available
information
used
by
EPA
to
understand
and
establish
certification
requirements
capture
the
most
likely
sources
of
variability,
all
mill
specific
sources
of
variability
may
not
be
accounted
for.
Therefore,
EPA
was
concerned
that
less
frequent
monitoring
would
not
provide
the
information
necessary
to
ensure
that
mills
collect
adequate
data
to
define
ranges
of
process
and
operating
parameters
within
which
they
will
subsequently
be
required
to
operate
to
assure
compliance
with
the
chloroform
effluent
limitations
guidelines
and
standards
promulgated
as
part
of
the
Cluster
Rules
while
also
successfully
producing
products
of
acceptable
quality.
See
63
FR
18571­
72.
EPA
determined
that
periodic
certification
reports
are
necessary
to
confirm
that
facilities
with
participating
fiber
lines
are
operating
within
the
range
of
process
and
operating
conditions
identified
during
the
initial
compliance
demonstration
period.
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
5
The
frequency
of
submission
of
periodic
certification
reports
is
the
same
as
discharge
monitoring
reports
(
DMRs)
required
for
other
pollutant
parameters
for
direct
dischargers
by
their
NPDES
permits,
Periodic
Compliance
Reports
(
PCRs)
for
other
pollutant
parameters
for
indirect
dischargers,
and
provides
an
efficient
means
for
submitting
information
to
the
permit
writer
and
pretreatment
control
authority.

3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2).

3(
f)
Confidentiality
As
noted
in
2(
b)
above,
mills
that
voluntarily
choose
to
participate
may
elect
to
assert
claims
of
confidential
business
information
(
CBI),
according
to
the
provisions
of
40
CFR
Part
2,
on
any
portions
of
the
process
and
operating
data
submitted
to
support
a
certification
in
lieu
of
minimum
monitoring
for
chloroform.
However,
CBI
claims
will
not
be
appropriate
for
periodic
reports
simply
certifying
that
mill
operations
remain
within
the
ranges
of
process
and
operating
parameters
established
during
the
initial
compliance
demonstration.

3(
g)
Sensitive
Questions
The
reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
respondent
universe
for
this
ICR
will
be:
1)
approximately
84
direct
and
indirect
discharging
chemical
pulp
mills
included
in
Subpart
B
(
Bleached
Papergrade
Kraft
and
Soda)
of
the
Pulp,
Paper
and
Paperboard
Manufacturing
Category
(
SIC
2611,
2631).

4(
b)
Information
Requested
The
following
section
outlines
the
requirements
of
the
voluntary
certification
option
and
information
requested.
During
the
initial
compliance
demonstration
period,
the
facility
must
collect
24­
hour
composite
samples
of
its
representative
bleach
plant
effluent(
s)
on
a
weekly
(
or
more
frequent)
basis
and
analyze
these
samples
for
chloroform.
All
of
the
monitoring
results
during
the
initial
compliance
demonstration
period
must
be
in
compliance
with
the
chloroform
effluent
limitations
and
standards.
If
a
mill
chooses
to
sample
more
frequent
than
weekly,
then
it
is
the
mill's
responsibility
to
ensure
that
such
more
frequent
sampling
captures
the
range
of
process
and
operating
parameter
variability
that
occurs
during
normal
operations.
Once
this
range
is
established,
if
mill
operations
do
not
remain
within
that
range
during
the
subsequent
period
of
certification
in
lieu
of
minimum
monitoring,
violation
will
occur
and
minimum
monitoring
to
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
6
recertify
will
be
required.
During
each
24­
hour
sampling
period,
the
facility
must
maintain
records
of
the
following
bleach
plant
process
and
operating
parameters:

(
a)
The
pH
of
the
first
chlorine
dioxide
bleaching
stage;
(
b)
The
chlorine
(
Cl
2
)
content
of
chlorine
dioxide
(
ClO
2)
used
on
the
bleach
line;
(
c)
The
kappa
factor
of
the
first
chlorine
dioxide
bleaching
stage;
(
d)
The
total
bleach
line
chlorine
dioxide
application
rate;
and
(
e)
The
chlorine­
containing
compounds
used
for
bleaching
(
i.
e.,
the
bleach
sequence).

At
many
mills
monitoring
of
process
and
operating
parameters
is
accomplished
electronically
by
computerized
distributed
control
systems
(
DCS).

When
the
facility
has
completed
its
initial
compliance
demonstration,
it
may
request
that
its
permitting
or
pretreatment
control
authority
modify
its
permit
or
pretreatment
control
agreement
to
discontinue
weekly
chloroform
monitoring
of
bleach
plant
effluent.
At
the
time
that
it
makes
this
request,
the
facility
must:

(
a)
Certify
that
the
fiber
line
does
not
use
either
elemental
chlorine
or
hypochlorite;
(
b)
Provide
records
demonstrating
that,
based
on
104
measurements
collected
over
a
period
not
less
than
two
years,
that
the
fiber
line
complies
with
applicable
chloroform
limitations
or
standards;
and
(
c)
Document
the
range
of
process
and
operating
conditions
that
occurred
during
the
collection
of
samples
used
to
demonstrate
initial
compliance.
Specifically,
the
facility
must
identify
the
chlorine­
containing
compounds
used
for
bleaching
(
i.
e.,
the
bleach
sequence).
The
facility
must
also
document
the
maximum
values,
observed
during
sample
collection
of:
(
i)
The
pH
of
the
first
chlorine
dioxide
bleaching
stage;
(
ii)
The
chlorine
(
Cl
2)
content
of
chlorine
dioxide
(
ClO
2)
used
on
the
bleach
line;
(
iii)
The
kappa
factor
of
the
first
chlorine
dioxide
bleaching
stage;
and
(
iv)
The
total
bleach
line
chlorine
dioxide
application
rate.

Thereafter,
at
the
same
frequency
that
the
facility
submits
discharge
monitoring
reports
(
DMRs)
to
its
permitting
authority
or
periodic
compliance
reports
(
PCRs)
to
its
pretreatment
control
authority,
the
facility
must
certify
that:

(
a)
The
pH
of
the
first
chlorine
dioxide
bleaching
stage
has
not
exceeded
the
pH
range
measured
during
initial
compliance
demonstration
sample
collection;
(
b)
The
chlorine
(
Cl
2)
content
of
chlorine
dioxide
(
ClO
2)
used
on
the
bleach
line
has
not
exceeded
the
maximum
Cl
2
content
of
ClO
2
used
during
initial
compliance
demonstration
sample
collection;
(
c)
The
kappa
factor
of
the
first
chlorine
dioxide
bleaching
stage
has
not
exceeded
the
maximum
kappa
factor
employed
during
initial
compliance
demonstration
sample
collection;
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
7
(
d)
The
total
bleach
line
chlorine
dioxide
application
rate
has
not
exceeded
the
maximum
chlorine
dioxide
application
rate
employed
during
initial
compliance
demonstration
sample
collection;
and
(
e)
The
chlorine­
containing
compounds
used
for
bleaching
are
unchanged
from
those
used
during
initial
compliance
demonstration
sample
collection.

The
facility
must
also
maintain
on­
site
records
for
the
fiber
line
of
these
process
and
operating
conditions.
If
the
facility
purposely
changes
or
unintentionally
fails
to
maintain
process
and
operating
conditions
on
the
fiber
line
representative
of
those
employed
during
initial
compliance
demonstration,
the
facility
must
notify
the
permitting
or
pretreatment
control
authority
and
again
monitor
for
chloroform,
and
recertify
the
fiber
line
to
continue
the
certification
option
to
demonstrate
compliance
in
lieu
of
minimum
monitoring.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Activities
undertaken
by
EPA
under
this
information
collection
primarily
include
oversight
of
the
NPDES
and
pretreatment
control
programs,
and
where
EPA
is
the
NPDES
permitting
or
pretreatment
control
authority,
review
of
data
and
information
collected
during
the
initial
compliance
demonstration
period,
review
of
periodic
certification
reports,
and
where
necessary,
follow­
up
actions.

The
extent
to
which
EPA
reviews
reports
and
data
in
assessing
permit
and
pretreatment
control
agreement
compliance
with
the
certification
option
may
vary.
For
example,
EPA
may
conduct
a
more
extensive
review
of
permittees
that
are,
or
have
been,
in
violation
of
their
certification
and
permit
or
pretreatment
control
agreement
requirements,
than
of
permittees
who
have
been
in
full
compliance.
EPA
may
limit
its
review
of
data
submitted
by
fully
compliant
permittees
to
a
simple
determination
of
continuing
compliance
through
certification.
In
most
cases,
EPA
will
forward
copies
of
reports
to
the
States.
EPA
does
not
require
the
unauthorized
States
to
review
data,
but
several
States
voluntarily
conduct
the
review
and
use
the
results
in
their
own
programs.

EPA
regions
may
also
review
data
from
major
permittees
in
NPDES
and
pretreatment
control
authorized
States
while
performing
program
oversight
functions
(
e.
g.,
during
file
audits
and
when
compiling
statistical
compliance
summaries).

Reported
data
is
often
stored
in
the
Permit
Compliance
System
(
PCS)
for
reference.
EPA
and
States
may
use
this
data
to
evaluate
potential
compliance
problems,
focus
inspection
efforts,
conduct
spot
check
reviews
and
determine
appropriate
enforcement
action.
PCS
is
available
for
public
review
at
http://
www.
epa.
gov/
enviro/
html/
water.
html#
pcs.

5(
b)
Collection
Methodology
and
Management
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
8
Respondents
typically
report
collected
compliance
data
for
all
pollutant
parameters
on
Discharge
Monitoring
Reports
(
DMRs)
for
direct
dischargers
and
periodic
compliance
reports
(
PCRs)
for
indirect
dischargers.
For
those
facilities
that
choose
to
certify
in
lieu
of
chloroform
minimum
monitoring
at
a
fiber
line,
periodic
certification
reports
may
be
submitted
with
DMRs
and
PCRs.
Allowing
combined
reporting
for
both
the
certification
option
(
for
chloroform)
and
compliance
(
for
all
other
pollutant
parameters)
is
one
method
that
EPA
has
used
to
improve
its
collection
methodology.
EPA
has
developed
policy
guidance
for
the
electronic
submission
of
data
(
see
61
FR
46683­
46694).
The
electronic
submission
of
certification
reports,
DMR
and
PCR
data
is
voluntary
and
will
be
an
alternative
to
the
paper
submissions.
EPA
makes
use
of
the
PCS
database
to
store,
track
and
access
this
information.

5(
c)
Small
Entity
Flexibility
EPA
considered
less
burdensome
information
collection
mechanisms
for
small
entities,
but
chose
not
to
alter
the
collection
procedure
for
the
following
reasons:

°
The
certification
in
lieu
of
minimum
monitoring
for
chloroform
required
by
40
CFR
430.02
provides
an
overall
reduction
in
burden
and
costs
from
the
minimum
monitoring
requirements
included
in
the
Cluster
Rules,
for
which
EPA
has
already
certified
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities
as
that
term
is
used
in
the
RFA
(
see
Section
X.
C.
of
the
Preamble
to
the
final
Cluster
Rules
published
in
the
Federal
Register
on
April
15,1998
(
see
63
FR
18611).

°
Moreover,
mills
will
be
subject
to
the
information
collection
only
if
they
choose
to
participate
in
the
chloroform
certification
program.

5(
d)
Collection
Schedule
The
information
collection
activities
included
in
this
ICR
are
anticipated
to
coincide
with
existing
reporting
schedules.
The
timeframes
for
submitting
periodic
certification
reports
and
associated
activities
are
outlined
below:

°
Monitoring,
reporting,
and
recordkeeping
are
performed
on
a
continual
basis;

°
Reports
are
to
be
prepared
for
submission
to
NPDES
permit
or
pretreatment
control
authorities
at
a
frequency
to
be
determined
by
these
authorities,
but
no
less
than
once
per
year.
EPA
expects
that
such
reporting
frequencies
will
be
consistent
with
existing
reporting
requirements
already
applicable
to
mills.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
9
This
section
describes
the
methods
EPA
used
to
estimate
the
burden
to
respondents
associated
with
the
initial
compliance
demonstration
and
periodic
compliance
reports
required
with
the
certification
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
Part
430.
The
number
of
facilities
potentially
affected
by
this
ICR
are
listed
in
Table
6.1
below.

Table
6.1
Number
of
Eligible
Mills
and
Lines
Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
Number
of
Facilities
Number
of
Bleach
Lines
Direct
Dischargers
75
120
Indirect
Dischargers
9
14
Total
84
134
(
i)
Initial
Compliance
Demonstration
All
direct
and
indirect
discharging
Subpart
B
mills
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
must
collect
104
monitoring
data
measurements
per
minimum
monitoring
required
by
40
CFR
430.02
(
or
more
frequently
if
required
by
the
permitting
or
pretreatment
control
authority)
for
each
fiber
line
the
facility
wishes
to
certify.
The
time
period
for
collecting
these
measurements
is
not
less
than
two
years.
Because
this
monitoring
requirement
adheres
to
the
minimum
monitoring
required
by
40
CFR
Part
430,
the
burden
and
cost
associated
with
this
activity
is
described
in
the
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB2040­
NEW)
for
direct
dischargers
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers.

During
the
initial
compliance
demonstration
period,
the
facility
will
monitor
and
maintain
records
of
the
range
of
certain
process
and
operating
conditions
that
the
fiber
lines
are
operated
within.
The
collected
monitoring
data
will
be
used
to
demonstrate
compliance
with
applicable
chloroform
limitations
and
standards
for
each
fiber
line.
The
requirement
to
monitor
process
and
operating
conditions
and
to
maintain
records
of
these
conditions
places
no
new
burden
on
the
facility.
Mills
continuously
monitor
bleach
plant
process
and
operating
conditions
in
order
to
ensure
the
quality
of
their
product
and
the
efficiency
of
their
operations.
They
also
routinely
maintain
records
of
process
and
operating
conditions.
At
many
mills
monitoring
of
process
and
operating
parameters
is
accomplished
electronically
by
computerized
distributed
control
systems
(
DCS).

The
Agency
estimates
a
one­
time
reporting
burden
of
0.5
hours
per
facility
to
certify
to
the
permitting
or
pretreatment
control
authority
that
the
participating
fiber
line(
s),
which
the
mill
has
chosen
to
certify,
do
not
use
elemental
chlorine
or
hypochlorite
as
a
bleaching
agent
and
to
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
10
identify
the
range
of
certain
process
and
operating
conditions
during
the
initial
compliance
demonstration
period.
This
burden
consists
of
compiling
regularly
collected
information
into
a
report
submitted
to
the
permitting
or
pretreatment
control
authority.

(
ii)
Periodic
Certification
Reports
and
Recordkeeping
EPA
estimates
a
recurring
reporting
burden
of
0.5
hours
monthly
per
facility
for
submitting
periodic
certification
reports
to
the
permitting
or
pretreatment
control
authority
to
confirm
that
the
certified
fiber
lines
are
not
using
elemental
chlorine
or
hypochlorite
as
bleaching
agents
and
are
maintaining
the
process
and
operating
conditions
within
the
range
documented
during
the
initial
compliance
period.
This
burden
consists
of
a
certification
report
submitted
to
the
permitting
or
pretreatment
control
authority
and
maintaining
records
which
document
and
substantiate
submitted
certification
reports.
This
burden
estimate
is
based
upon
monthly
submissions
of
DMRs
for
direct
dischargers
and
PCRs
for
indirect
dischargers,
including
certification
reports.

For
the
purpose
of
estimating
the
total
burden
incurred
by
facilities
voluntarily
electing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02,
the
burden
associated
with
reporting
for
the
initial
compliance
demonstration
period
is
assumed
to
be
the
first
month
of
periodic
certification
reporting
and
will
be
accounted
for
as
part
of
the
recurring
burden.
EPA
estimates
of
the
75
existing
direct
discharging
Subpart
B
mills
eligible
for
certification
in
lieu
of
chloroform
minimum
monitoring
requirements,
consisting
of
a
total
of
120
fiber
lines,
74
facilities,
for
a
total
of
118
fiber
lines,
will
choose
to
certify.
EPA
estimates
of
the
nine
existing
indirect
discharging
Subpart
B
mills
eligible
for
certification
in
lieu
of
chloroform
minimum
monitoring
requirements,
consisting
of
a
total
of
14
fiber
lines,
six
facilities,
for
a
total
of
9
fiber
lines,
will
choose
to
certify.

The
total
recurring
burden
incurred
by
the
80
direct
and
indirect
discharging
mills
anticipated
to
certify
their
127
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
for
chloroform
is
summarized
below.

Table
6.2
Recurring
Burden
for
Activities
Related
to
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Activity
Number
of
Affected
Facilities
Monthly
Burden
(
hours)
Total
Annual
Burden
(
hours)

Submission
of
monthly
certification
reports1
80
0.5
480
1
Accounts
for
a
one­
time
burden
of
0.5
hours
for
reporting
for
the
initial
compliance
demonstration
period
(
iii)
Recurring
Burden
Reduction
from
Minimum
Monitoring
Required
by
40
CFR
430.02
Facilities
that
have
certified
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02
will
experience
a
reduction
in
recurring
burden
associated
with
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
11
reduced
monitoring
and
reporting,
namely
the
discontinuance
of
weekly
chloroform
monitoring
at
bleach
plant
effluent(
s).
Annual
sampling
burden
associated
with
chloroform
minimum
monitoring
per
fiber
line
is
estimated
at
156
hours.
Annual
reporting
burden
associated
with
chloroform
minimum
monitoring
per
facility
is
estimated
at
2
hours.
Description
of
these
estimates
can
be
found
in
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB
____­____)
for
direct
dischargers
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers.

Table
6.3
Recurring
Burden
Reduction
from
Minimum
Monitoring
Required
by
40
CFR
430.02
Activity
Number
of
Affected
Facilities
Annual
Burden
(
hours)
Total
Annual
Burden
(
hours)

Sampling
for
minimum
monitoring
required
by
40
CFR
430.02
127
fiber
lines
156
19,812
Reporting
for
minimum
monitoring
required
by
40
CFR
430.02
80
mills
2
160
ANNUAL
BURDEN
REDUCTION
19,972
EPA
does
not
estimate
a
reduction
in
recurring
recordkeeping
burden
associated
with
minimum
monitoring
requirements
for
those
facilities
that
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
because
records
are
maintained
for
the
monitoring
for
other
pollutant
parameters,
regardless
of
the
discontinuation
of
minimum
monitoring
for
chloroform.

(
iv)
NPDES
and
Pretreatment
Control
authorized
State
Respondent
Burden
The
burden
and
associated
costs
to
NPDES
and
pretreatment
control
authorized
State
authorities
for
reviewing
reports
for
the
initial
compliance
demonstration
for
facilities
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring,
revising
NPDES
permits
and
pretreatment
control
agreements,
reviewing
periodic
certification
reports,
and
conducting
followup
actions
are
estimated
to
exactly
offset
previous
recurring
burden
for
processing
and
analyzing
chloroform
monitoring
data
included
in
the
facility's
DMR
or
PCR
and
conducting
follow­
up
actions
related
to
compliance.
Therefore,
the
Agency
does
not
estimate
any
addition
or
reduction
of
recurring
burden
for
NPDES
and
pretreatment
control
authorities
with
facilities
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring.

The
additional
and
reduced
burden
for
facilities
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02,
showing
an
overall
reduction
in
total
recurring
burden,
is
summarized
below.

Table
6.4
Total
Burden
Reduction
Resulting
from
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Activity
Total
Annual
Burden
(
hours)
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
12
Annual
burden
reduction
from
sampling
and
reporting
for
minimum
monitoring
required
by
40
CFR
430.02
19,972
Annual
burden
for
reporting
for
certification
in
lieu
of
chloroform
minimum
monitoring
480
TOTAL
ANNUAL
BURDEN
REDUCTION
19,492
6(
b)
Estimating
Respondent
Cost
(
i)
Estimating
Labor
Costs
(
2000
Dollars)

Estimates
for
respondent
labor
costs
were
prepared
using
industry­
specific
labor
rates
identical
to
those
used
for
the
BAT
Cost
Model
(
in
1995
dollars;
see
BAT
Cost
Model
Support
Document,
DCN
13953),
which
included
overhead
and
fringe
benefits,
were
adjusted
with
the
Consumer
Price
Index
to
2000
dollars:

Technician
$
56.91
/
hour
Operator
$
28.91
/
hour
Technician
labor
is
applied
to
reporting
and
recordkeeping
burdens.
Operator
labor
is
applied
to
sampling
burden.

This
ICR
covers
an
increase
in
recurring
reporting
burden
related
to
periodic
certification
reports
and
a
reduction
in
sampling
and
reporting
burden
related
to
the
discontinuance
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02.

(
ii)
Operations
and
Maintenance
(
O&
M)
Costs
Facilities
that
choose
to
certify
their
fiber
lines
in
lieu
of
minimum
monitoring
for
chloroform
required
by
40
CFR
430.02
will
experience
an
overall
reduction
in
O&
M
costs
related
to
the
discontinuance
of
collecting
and
shipping
chloroform
samples
to
outside
laboratories
for
analysis.
The
analytical
cost
for
chloroform
performed
at
outside
laboratories
is
estimated
at
$
292
per
sample,
taken
from
the
BAT
cost
model
in
the
"
BAT
Cost
Model
Support
Document"
(
DCN
13953)
and
adjusted
with
the
Consumer
Price
Index
to
2000
dollars.
Collection
of
two
chloroform
samples
per
fiber
line
(
i.
e.,
bleach
plant)
per
week
is
estimated
to
meet
minimum
monitoring
requirements.
This
estimate
is
described
in
the
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB
____­____)
for
direct
dischargers
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers.

The
reduction
in
recurring
O&
M
burden
for
facilities
that
choose
to
certify
their
fiber
lines
in
lieu
of
minimum
monitoring
for
chloroform
required
by
40
CFR
430.02
consists
of
the
elimination
of
sample
collection
and
shipping
costs,
and
chloroform
analytical
costs.

6(
c)
Estimating
Agency
Burden
and
Cost
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
13
EPA
burden
is
based
on
management
and
support
activities
for
facilities
that
choose
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
required
by
40
CFR
430.02
located
in:


States
without
NPDES
or
pretreatment
control
authority:
EPA
activities
include
reviewing
reports
for
the
initial
compliance
demonstration
for
facilities
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring,
revising
NPDES
permits
and
pretreatment
control
agreements,
reviewing
periodic
certification
reports,
and
conducting
follow­
up
actions.
Burden
associated
with
these
activities
are
estimated
to
exactly
offset
previous
recurring
burden
for
processing
and
analyzing
chloroform
monitoring
data
included
in
the
facility's
DMR
or
PCR
and
conducting
follow­
up
actions
related
to
compliance.


States
with
NPDES
and
pretreatment
control
authority:
EPA
activities
include
program
support,
such
as
review
of
NPDES
permit
and
pretreatment
control
agreements
renewal
applications
and
draft
permits
and
agreements,
and
review
of
information
submitted
by
the
facilities,
including
certification
reports.
Burden
associated
with
these
activities
are
described
in
the
Minimum
Monitoring
Requirements
for
Direct
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
ICR
(
OMB
2040­
NEW)
for
direct
dischargers
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009)
for
indirect
dischargers
and
will
not
be
impacted
by
the
certification
option.

The
Agency
does
not
estimate
any
addition
or
reduction
of
recurring
burden
for
EPA
associated
with
facilities
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Table
6.5
summarizes
the
total
annual
burden
and
costs
incurred
for
facilities
that
choose
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
and
the
associated
overall
reduction
in
annual
burden
and
costs
for
reduced
minimum
monitoring
requirements.

Table
6.5
Summary
of
Incurred
and
Reduced
Annual
Respondent
Burden
and
Costs
Activity
Annual
Labor
(
Hours)
Annual
Costs
(
2000
Dollars)

Incurred
Annual
Burden
and
Costs
(
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements)

Submission
of
monthly
certification
reports1
.
.
.
.
.
.
.
.
.
.
.
.
.
480
$
27,320
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
14
Table
6.5
Summary
of
Incurred
and
Reduced
Annual
Respondent
Burden
and
Costs
Reduced
Annual
Burden
and
Costs
(
Minimum
Monitoring
Required
by
40
CFR
430.02)

Sampling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Analytical
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Total
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19,812
160
­
19,972
$
572,760
$
9,110
$
3,856,740
$
4,438,610
Total
Reduction
in
Annual
Respondent
Burden
and
Costs
19,492
$
4,411,290
1
Accounts
for
a
one­
time
burden
of
0.5
hours
for
reporting
for
the
initial
compliance
demonstration
period
6(
e)
Burden
Statement
Certification
in
lieu
of
chloroform
minimum
monitoring
eliminates
all
sampling
burden
associated
with
the
minimum
monitoring
requirements
for
chloroform.
A
total
of
19,492
hours
annually
would
be
saved
by
the
80
direct
and
indirect
discharging
Subpart
B
mills
that
EPA
anticipates
will
choose
to
certify
their
127
fiber
lines.
At
an
hourly
operator
rate
of
$
28.91
per
hour
for
sampling
activities,
reduction
in
sampling
costs
associated
with
certifying
fiber
lines
in
lieu
of
minimum
monitoring
required
by
40
CFR
430.02
for
the
80
mills
would
be
$
572,760
per
year
($
28.91
x
19,812).
In
addition,
the
elimination
of
chloroform
sampling
activities
results
in
an
associated
reduction
in
analytical
costs
for
the
outside
lab
analysis
of
chloroform
samples.
The
total
reduction
in
analytical
costs
associated
with
certifying
fiber
lines
in
lieu
of
minimum
monitoring
required
by
40
CFR
430.02
for
the
80
mills
would
be
$
3,856,740
per
year
(
127
fiber
lines
x
2
samples
per
fiber
line
x
52
weeks
x
$
292
per
analysis).
An
increase
in
reporting
burden
for
the
80
mills
would
be
320
(
480
­
160)
hours
annually,
based
on
the
submission
of
periodic
certification
reports
in
lieu
of
reporting
chloroform
compliance
data
in
DMRs
and
PCRs.
At
an
hourly
technician
rate
of
$
56.91
for
reporting
activities,
an
increase
in
reporting
costs
associated
with
certifying
fiber
lines
in
lieu
of
minimum
monitoring
required
by
40
CFR
430.02
for
the
80
mills
would
be
$
18,210
per
year
($
56.91
x
320).
Therefore,
the
overall
reduction
in
the
total
burden
and
cost
to
demonstrate
compliance
with
minimum
monitoring
requirements
by
certifying
fiber
lines
in
lieu
of
minimum
monitoring
required
by
40
CFR
430.02
for
the
80
mills
would
be
$
4,411,290
per
year
($
572,760
+
$
3,856,740
­
$
18,210).
This
reduction
in
cost
translates
to
approximately
$
55,140
annually
per
mill.

The
Agency
does
not
estimate
any
change
in
burden
for
State
authorized
NPDES
and
pretreatment
control
authorities
or
EPA
from
the
burden
associated
with
minimum
monitoring
required
by
40
CFR
430.02
for
facilities
(
i.
e.,
permitees)
wishing
to
certify
their
fiber
lines
in
lieu
of
chloroform
minimum
monitoring
requirements.

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
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
15
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques
to
M.
Ahmar
Siddiqui,
U.
S.
Environmental
Protection
Agency,
Ariel
Rios
Building,
1200
Pennsylvania
Avenue
N.
W.
(
4303),
Washington,
D.
C.
20460.
Include
the
EPA
ICR
number
2015.01
in
any
correspondence.
Certification
in
Lieu
of
Chloroform
Minimum
Monitoring
Requirements
Page
16
Response
to
Comment
Received
EPA
received
one
comment
regarding
this
Information
Collection
Request.
The
commenter
asserted
that
the
cost
of
the
voluntary
chloroform
certification
program
would
be
greater
than
the
cost
of
the
existing
sampling
requirements
in
the
Cluster
Rules
and
that
only
a
small
number
of
mills
would
choose
to
enter
the
program.
The
commenter
proposed,
in
order
to
further
save
cost,
that
initial
monitoring
of
bleach
plant
chloroform
levels
as
part
of
the
certification
program
should
only
be
required
for
one
year,
not
two
years
as
the
Agency
proposed.
The
commenter
also
asserted
that
the
addition
of
several
bleaching
parameters
to
be
monitored
as
part
of
the
certification
program
would
lead
to
an
increased
risk
of
permit
violations.
Moreover,
the
commenter
further
proposed
that
the
certification
program
should
be
expanded
to
include
all
other
pollutants
regulated
by
BAT,
including
chlorinated
phenolics,
dioxins
and
furans,
and
AOX.
However,
the
Agency
notes
that
the
commenter
provided
no
new
information
either
to
justify
reducing
the
initial
monitoring
period
from
two
years
to
one
year,
or
to
support
the
assertion
of
increased
risk
of
violation
attributable
to
monitoring
several
bleaching
parameters,
or
to
expand
the
certification
program
to
all
regulated
pollutants.
EPA
concludes
that
the
voluntary
program
as
described
here
is
appropriate
and
will
provide
a
significant
reduction
in
burden
to
a
substantial
number
of
mills.
Although
EPA
has
not
yet
completed
final
action
on
the
proposed
amendment
to
the
Cluster
Rules
that
would
establish
a
voluntary
certification
program
as
an
alternative
to
monitoring
for
chloroform,
EPA
does
not
see
a
basis
at
this
time
to
adopt
the
changes
suggested
by
the
commenter
in
the
context
of
the
proposed
ICR.
Accordingly,
the
ICR
sent
to
OMB
for
approval
reflects
the
certification
program
originally
contemplated
by
EPA.
If
EPA
promulgates
a
final
certification
amendment
that
incorporates
any
changes,
EPA
would
need
to
modify
the
ICR
accordingly.
