Minimum
Monitoring
Requirements
ICR
Page
i
MINIMUM
MONITORING
REQUIREMENTS
FOR
DIRECT
AND
INDIRECT
DISCHARGING
MILLS
IN
THE
BLEACHED
PAPERGRADE
KRAFT
AND
SODA
SUBCATEGORY
AND
THE
PAPERGRADE
SULFITE
SUBCATEGORY
OF
THE
PULP,
PAPER
AND
PAPERBOARD
MANUFACTURING
CATEGORY
(
40
CFR
PART
430)

EPA
ICR
Number
1878.01
November
2001
U.
S.
Environmental
Protection
Agency
Office
of
Water
Engineering
and
Analysis
Division
401
M
Street,
SW
Washington,
D.
C.
20460
Minimum
Monitoring
Requirements
ICR
Page
ii
TABLE
OF
CONTENTS
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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1
2(
a)
Need/
Authority
for
the
Collection
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1
2(
b)
Practical
Utility/
Users
of
the
Data
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3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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2
3(
a)
Non­
duplication
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2
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Data
Collection
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3
3(
e)
General
Guidelines
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5
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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6
4(
c)
Recordkeeping
Requirements
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4(
d)
Respondent
Activities
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5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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11
5(
a)
Agency
Activities
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11
5(
b)
Collection
Methodology
and
Management
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11
5(
c)
Small
Entity
Flexibility
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12
5(
d)
Collection
Schedule
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12
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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12
6(
a)
Estimating
Respondent
Burden
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12
6(
b)
Estimating
Respondent
Cost
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19
6(
c)
Estimating
Agency
Burden
and
Cost
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21
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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22
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
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23
6(
f)
Burden
Statement
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24
Minimum
Monitoring
Requirements
ICR
Page
iii
LIST
OF
TABLES
Table
4.1
Minimum
Monitoring:
Mill
Respondent
Requirements
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6
Table
4.2
Reduced
Effluent
Monitoring
for
TCDD,
TCDF,
Chloroform,
and
the
12
Chlorinated
Phenolics
for
Mills
Participating
in
the
Voluntary
Advanced
Technology
Incentives
Program
(
VATIP)
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7
Table
4.3
Duration
of
Reduced
Effluent
Monitoring
for
TCDD,
TCDF,
Chloroform,
and
the
12
Chlorinated
Phenolics
for
Mills
Participating
in
the
VATIP
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8
Table
4.4
Reduced
Effluent
Monitoring
for
AOX
for
Mills
Participating
in
the
VATIP
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8
Table
4.5
NPDES­
authorized
State
Requirements
(
As
Users
of
Data)
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9
Table
4.6
State
and
Local
Pretreatment
Control
Authorities
Requirements
(
As
Users
of
Data)
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10
Table
6.1
Regulated
Pollutants
and
Number
of
Affected
Mills
and
Lines
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12
Table
6.2
Annual
Sampling
Burden
for
Subpart
B
Bleached
Papergrade
Kraft
and
Soda
Mills
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14
Table
6.3
Annual
Sampling
Burden
for
Subpart
E
Papergrade
Sulfite
Mills
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15
Table
6.4
Annual
Reporting
Burden
for
Each
Pollutant
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16
Table
6.5
Annual
Reporting
Burden
for
Subpart
B
and
E
Mills
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16
Table
6.6
Annual
Recordkeeping
Burden
for
Subpart
B
and
E
Mills
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17
Table
6.7
Summary
of
Annual
Respondent
Burden
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18
Table
6.8
Total
Mill
Respondent
Capital
Costs
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20
Table
6.9
Analytical
Sample
Costs
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21
Table
6.10
Annual
(
O&
M)
Estimate
of
Analytical
Costs
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21
Table
6.11
Summary
of
Annual
Agency
Burden
and
Costs
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22
Table
6.12
Summary
of
Annual
Respondent
Burden
and
Costs
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23
Minimum
Monitoring
Requirements
ICR
Page
iv
LIST
OF
TABLES
(
Continued)

Table
6.13
Total
Estimated
Annual
Respondent
Burden
and
Cost
Summary
(
2000
Dollars)
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24
Table
6.14
Total
Estimated
Annual
Agency
Burden
and
Cost
Summary
(
2000
Dollars)
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24
LIST
OF
APPENDICES
Appendix
A:
Supporting
Assumptions
and
Calculations
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26
Minimum
Monitoring
Requirements
ICR
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
ICR:
Minimum
Monitoring
Requirements
for
Direct
and
Indirect
Discharging
Mills
in
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
EPA
ICR
No.
1878.01).

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
presents
estimates
of
the
burden
and
costs
to
the
regulated
community
and
to
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
and
pretreatment
approval
and
control
authorities
for
monitoring,
reporting,
recordkeeping,
and
follow­
up
actions
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)
and
the
Papergrade
Sulfite
Subcategory
(
Subpart
E).
See
63
FR
18504­
18751.
The
regulated
community
consists
of
approximately
94
direct
and
indirect
discharging
papergrade
kraft,
soda
and
papergrade
sulfite
mills.

The
Cluster
Rules
establish
minimum
monitoring
requirements
for
certain
pollutants,
namely
adsorbable
organic
halides
(
AOX),
2,3,7,8­
tetrachlorodibenzo­
p­
dioxin
(
TCDD),
2,3,7,8­
tetrachlorodibenzofuran
(
TCDF),
chloroform
and
12
chlorinated
phenolics.
Pursuant
to
the
Paperwork
Reduction
Act,
EPA
intends
to
add
these
specific
monitoring
requirements
contained
in
the
Cluster
Rules
(
see
40
CFR
§
430.02)
to
the
ICR
for
NPDES/
Sewage
Sludge
Monitoring
Reports
ICR
(
OMB
2040­
0004)
and
the
National
Pretreatment
Program
ICR
(
OMB
2040­
0009).
The
current
National
Pretreatment
Program
ICR
includes
burden
for
indirect
dischargers
regulated
under
the
Cluster
Rules.
This
ICR
serves
to
clarify
and
augment
the
burden
already
identified
in
the
National
Pretreatment
Program
ICR
incurred
by
indirect
dischargers
for
compliance
with
minimum
monitoring
requirements.

This
ICR
covers
the
minimum
monitoring
requirements
for
94
direct
and
indirect
discharging
mills
as
well
as
the
alternative
requirements
for
those
Subpart
B
mills
that
choose
to
enroll
in
the
Voluntary
Advanced
Technology
Incentives
Program
(
VATIP)
until
such
time
that
these
requirements
are
subsumed
under
the
NPDES/
Sewage
Sludge
Monitoring
Reports
ICR
(
OMB
2040­
0004).
This
is
a
new
ICR.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
As
mentioned
above,
EPA
established
minimum
monitoring
frequencies
for
AOX,
TCDD,
TCDF,
chloroform,
and
12
chlorinated
phenolics
for
existing
and
new
direct
and
indirect
discharging
mills
within
Subparts
B
and
E
under
authority
of
CWA
Section
308.
Discharge
of
Minimum
Monitoring
Requirements
ICR
Page
2
these
pollutants
into
the
freshwater,
estuarine
and
marine
ecosystems
may
alter
aquatic
habitats,
affect
aquatic
life
and
adversely
impact
human
health.
Chlorinated
organic
compounds
from
chlorine
bleaching,
particularly
TCDD
and
TCDF,
are
human
carcinogens
and
human
system
toxicants
and
are
extremely
toxic
to
aquatic
life.
Additionally,
Section
402(
a)(
2)
of
the
Clean
Water
Act
(
CWA)
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
E
and
NPDES
permitting,
pretreatment
control,
and
enforcement
authorities.
Citizen
groups
also
use
this
data
to
independently
assess
facility
compliance.

EPA
expects
that
the
monitoring
reports
will
be
used
by
NPDES
and
pretreatment
control
authorities
to
determine
compliance
with
the
Cluster
Rules
effluent
limitations
and
standards.
EPA,
States,
and
local
authorities
also
analyze
monitoring
data
when
establishing
permit
and
control
agreement
conditions
and
revise
permit
and
pretreatment
control
agreement
requirements
based
on
data
from
monitoring
reports.
Furthermore,
EPA
and
States
refer
to
discharge
monitoring
reports
and
facility
monitoring
data
on
toxic
pollutants
when
developing
lists
of
waters
not
meeting
applicable
water
quality
standards.
EPA
anticipates
that
State
NPDES
permitting
and
pretreatment
control
authorities
will
only
need
to
conduct
detailed
technical
reviews
of
monitoring
reports
in
the
event
the
monitoring
reports
indicate
noncompliance
with
the
NPDES
permit
or
pretreatment
control
agreement
conditions.

EPA
anticipates
that
permittees
will
use
the
monitoring
data
to
track
the
effectiveness
and
progress
of
reducing
pollutant
discharges.
For
this
reason,
most
permittees
usually
collect
additional
data
(
e.
g.,
product
quality
and
production
efficiency
information)
that
may
or
may
not
be
included
with
monitoring
reports.
Collection
and
reporting
of
data
to
permitting
and
pretreatment
control
authorities
also
provides
permittees
with
an
incentive
to
remain
in
compliance
with
their
established
permit
limitations
and
conditions.

As
public
information,
monitoring
data
is
used
by
public
environmental/
citizen
groups
for
a
variety
of
purposes.
Citizen
groups
review
monitoring
data
to
independently
assess
discharger
compliance.
In
some
instances
the
data
forms
the
basis
for
citizen
suits
that
are
authorized
under
Section
505
of
the
CWA.
In
addition,
environmental
groups,
academicians
and
others
use
monitoring
data
to
estimate
pollutant
loadings
to
streams,
lakes,
oceans
and
estuaries.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
Minimum
Monitoring
Requirements
ICR
Page
3
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.

Examination
of
these
databases
revealed
no
duplicate
collection
requirements.
Any
monitoring
requirements
imposed
by
individual
permits
for
the
affected
pollutants
would
be
superseded
by
these
requirements,
unless
they
require
more
frequent
monitoring
than
the
Cluster
Rules.
EPA
has
concluded
that
there
is
no
other
way
to
obtain
the
compliance
assessment
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.

3(
c)
Consultations
EPA
consulted
with
the
public,
industry
and
States
on
the
minimum
monitoring
requirements
through
the
rulemaking
process
for
the
Cluster
Rules.
As
mentioned
above,
EPA
received
no
comments
on
this
ICR.

3(
d)
Effects
of
Less
Frequent
Data
Collection
EPA
has
determined
the
minimum
monitoring
frequencies
established,
at
40
CFR
§
430.02(
a)
and
(
b),
are
necessary
to
demonstrate
compliance
with
the
Cluster
Rules'
effluent
limitations
guidelines
and
standards.
The
regulation
requires
collection
of
daily,
weekly,
or
monthly
discharge
data,
depending
on
the
pollutant.
Some
mill
operators
may
collect
such
data
independent
of
this
requirement
for
purposes
of
monitoring
and
optimizing
bleach
plant,
chemical
recovery,
and
wastewater
treatment
plant
operations.
EPA
determined
that
the
minimum
required
monitoring
frequencies
were
necessary
because
of
the
degree
of
change
that
is
expected
to
occur
to
and
temporal
variability
in
pulping
and
bleaching
processes
and
the
resulting
variations
in
effluent
discharges
of
each
fiber
line
that
can
and
do
occur
frequently
and
at
any
time.
Therefore,
EPA
was
concerned
that
less
frequent
monitoring
would
not
provide
the
information
necessary
to
ensure
compliance
with
the
effluent
limitations
guidelines
and
standards
promulgated
as
part
of
the
Cluster
Rules.
See
63
Fed.
Reg.
at
18571­
72.

In
establishing
the
minimum
monitoring
frequencies
for
the
regulated
pollutants,
EPA
has
struck
a
balance
between
the
cost
of
the
monitoring
regimen
and
the
need
to
ensure
that
sufficient
data
is
consistently
available
to
permitting
and
pretreatment
control
authorities.
Permitting
and
Minimum
Monitoring
Requirements
ICR
Page
4
pretreatment
control
authorities
need
to
have
an
adequate
basis
to
verify
compliance
with
the
effluent
limitations
and
standards
given
the
environmental
significance
of
these
pollutants
that
are
highly
toxic
and
bioaccumulative,
and
the
generation
of
which
is
variable
as
available
data
clearly
demonstrate.
This
monitoring
regimen
also
ensures
sufficient
data
is
available
to
the
mill
so
that
the
mill
may
quickly
become
aware
of
and
react
to
releases
that
may
be
harmful
to
the
environment.

EPA
selected
a
minimum
monitoring
frequency
of
once
per
month
for
TCDD,
TCDF,
and
chlorinated
phenolic
pollutants.
These
pollutants
are
the
most
toxic
and
bioaccumulative
among
those
regulated
yet
are
also
the
most
costly
to
analyze.
EPA
expects
the
12
data
points
for
each
pollutant
per
year,
together
with
daily
end­
of­
pipe
AOX
data
and
information
on
process
conditions
from
detailed
mill
logs,
will
yield
a
meaningful
basis
for
establishing
compliance
with
the
promulgated
effluent
limitations
and
standards.

EPA
selected
a
minimum
monitoring
frequency
of
once
per
week
for
chloroform.
This
monitoring
frequency
has
been
selected
because
data
available
indicates
there
can
be
considerable
temporal
variability
of
this
pollutant
in
bleach
plant
wastewaters.
This
variability
is
attributable
to
a
number
of
process
and
operational
variables.
Therefore,
more
data
is
required
to
adequately
assess
compliance
with
the
limitations
and
standards
on
both
a
long­
term
and
short­
term
basis.
The
cost
of
laboratory
analysis
of
chloroform
is
much
lower
than
for
TCDD,
TCDF,
and
chlorinated
phenolics.
Weekly
data
and
information
on
process
conditions
from
detailed
mill
logs
will
yield
a
meaningful
basis
for
establishing
long­
term
compliance
trends
in
chloroform
discharge
loadings
and
developing
process
control
strategies
to
also
ensure
the
short­
term
compliance
with
the
promulgated
effluent
limitations
and
standards.

EPA
selected
a
minimum
monitoring
frequency
of
once
daily
for
AOX
for
non­
TCF
(
totally
chlorine
free)
mills.
This
monitoring
frequency
has
been
selected
because
there
can
be
considerable
daily
variability
in
chlorinated
organic
discharge
loadings
to
receiving
streams.
Discharge
loadings
reflect
bleach
plant
discharge
patterns
and
secondary
biological
treatment
system
performance
that
is
readily
measured
at
reasonable
cost.
AOX
analysis
costs
are
anticipated
to
decrease
as
the
number
of
mills
(
in
the
respondent
universe
of
this
ICR)
begin
compliance
monitoring
efforts
with
the
Cluster
Rules.
Daily
monitoring
for
AOX
provides
a
continuous
data
stream
of
all
chlorinated
organic
constituents
in
wastewater,
allowing
mill
operators
and
permit
authorities
to
assess
and
control
both
process
technologies
and
end­
of­
pipe
biological
treatment
systems.

The
minimum
monitoring
frequencies
as
described
above
will
provide
sufficient
information
to:
(
1)
evaluate
mill
compliance
with
the
Cluster
Rules
limitations
and
standards
over
the
long
term;
and
(
2)
allow
permitting
and
pretreatment
control
authorities
to
judge
whether
a
different
frequency
of
monitoring
is
warranted
after
the
initial
compulsory
period
of
minimum
monitoring
has
been
completed.

Additionally,
EPA
has
offered
Subpart
B
mills
several
options
to
reduce
monitoring
burden
over
the
course
of
the
permit
cycle.
These
options
include:
Minimum
Monitoring
Requirements
ICR
Page
5

Enrollment
in
the
VATIP,
which
was
established
by
the
Cluster
Rules.


Certification
in
lieu
of
monitoring
for
chloroform
(
proposed
on
April
15,
1998,
63
FR
18796).

Mills
participating
in
the
VATIP
may
be
eligible
for
further
reductions
in
monitoring
requirements.
See
40
CFR
430.02(
c)­(
e).
Mills
enrolling
in
the
VATIP
are
subject
to
more
stringent
BAT
limitations
and
NSPS
than
EPA
could
otherwise
compel
through
its
minimum
BAT
and
NSPS
effluent
limitations
guidelines
and
standards.
To
encourage
participation
in
the
incentives
program,
EPA
has
provided
for
reduced
monitoring
requirements
for
participating
mills.
The
reduced
monitoring
incentive
applicable
to
AOX,
TCDD,
TCDF,
chloroform
and
the
12
chlorinated
phenolics
is
available
as
soon
as
participating
mills
achieve
baseline
BAT
limitations,
and
for
AOX
after
mills
achieve
the
ultimate
VATIP
limitations
(
see
Table
4.2).
See
also
63
FR
18609­
18610.

EPA
has
proposed
a
certification
mechanism
for
Subpart
B
mills
that
demonstrate
to
the
NPDES
permitting
authority
that
they
have
achieved
the
applicable
limitations
or
standards
for
chloroform
for
a
period
of
two
years
and
that
certain
process
and
operating
conditions
are
maintained.
See
63
FR
18796­
18802.
Each
mill
voluntarily
choosing
to
certify
in
lieu
of
monitoring
for
a
fiber
line
would
be
required
to
maintain
records
documenting
that
process
and
operational
conditions
are
maintained
within
the
range
established
during
the
initial
compliance
demonstration.
Following
the
required
two
year
minimum
monitoring
period,
mills
would
no
longer
be
subject
to
minimum
monitoring
requirements
for
chloroform
as
required
by
40
CFR
§
430.02.
As
a
result,
the
total
monitoring
burden
would
be
reduced,
if
this
proposed
rule
is
promulgated
by
EPA.

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

3(
f)
Confidentiality
EPA
does
not
expect
that
confidential
business
information
(
CBI)
or
trade
secrets
will
be
required
from
mill
operators
as
part
of
this
ICR.
Where
information
submitted
in
conjunction
with
this
ICR
contains
CBI,
the
respondent
may
request
that
this
information
be
treated
as
confidential
business
information.
All
data
so
designated
will
be
handled
pursuant
to
40
CFR
Part
2
when
EPA
is
the
permitting
or
pretreatment
control
authority,
and
pursuant
to
applicable
state
rules
and
regulations
governing
CBI
when
states
are
the
permitting
or
pretreatment
control
authorities.
Pursuant
to
Section
308(
b)
of
the
Clean
Water
Act,
effluent
data
may
not
be
treated
as
confidential.

3(
g)
Sensitive
Questions
The
reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.
Minimum
Monitoring
Requirements
ICR
Page
6
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
respondent
universe
for
this
ICR
will
be:
1)
approximately
94
direct
and
indirect
discharging
chemical
pulp
mills
included
in
Subpart
B
(
Bleached
Papergrade
Kraft
and
Soda)
and
Subpart
E
(
Papergrade
Sulfite)
of
the
Pulp,
Paper
and
Paperboard
Manufacturing
Category
(
SIC
2611,
2631);
and
2)
the
23
NPDES
and
pretreatment
approval­
authorized
States
and
10
local
pretreatment
control
authorities
responsible
for
ensuring
compliance
with
NPDES
and
pretreatment
regulations.
Pretreatment
approval
authorities
are
defined
as
regulatory
agencies,
EPA
or
States,
that
oversee
programs
implemented
by
individual
pretreatment
control
authorities
(
i.
e.,
publically
owned
treatment
works
(
POTWs)).

4(
b)
Information
Requested
The
following
sections
outline
the
monitoring,
reporting,
and
recordkeeping
requirements
for
direct
and
indirect
discharging
facilities
under
40
CFR
430.
Table
4.1
outlines
the
information
requirements
for
each
category
of
respondents.
The
data
requirements
are
listed
by
regulation
number.

Table
4.1
Minimum
Monitoring:
Mill
Respondent
Requirements
40
CFR
Citation
Regulatory
Description
Monitoring
and/
or
Reporting
Frequency
Monitoring
Requirements:
Sample
Collection
and
Analysis
430.02
(
a)
For
each
non­
TCF
(
Totally
Chlorine
Free)
bleaching
fiber
line,
mills
must
conduct
minimum
monitoring
at
the
following
frequencies:
°
AOX
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
chloroform
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDD
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDF
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
each
of
the
12
chlorinated
phenolics
.
.
.
.
.
.
.
.
.
Daily
Weekly
Monthly
Monthly
Monthly
430.54
(
a),
430.56
(
a)
AOX
limits
are
reserved
for
non­
TCF
bleaching
lines
at
direct
and
indirect
Subpart
E
mills,
therefore
no
minimum
monitoring
requirements
for
AOX
exist
for
these
mills.

430.02
(
a)
There
are
no
specified
minimum
monitoring
frequencies
for
fiber
lines
with
exclusively
TCF
bleaching.
None
430.02
(
b)
For
direct
dischargers,
minimum
monitoring
frequencies
apply
for
a
duration
of
five
years
commencing
on
the
date
the
applicable
limitations
or
standards
are
first
included
in
the
discharger's
NPDES
permit.
Minimum
Monitoring
Requirements
ICR
Page
7
Table
4.1
Minimum
Monitoring:
Mill
Respondent
Requirements
430.02(
b)
For
existing
indirect
dischargers,
minimum
monitoring
frequencies
apply
until
April
17,
2006.
For
new
indirect
dischargers,
minimum
monitoring
frequencies
apply
for
a
duration
of
five
years
commencing
on
the
date
the
indirect
discharger
commences
operation.

Reporting
and
Recording
Requirements
122.41(
l)(
4)
Requires
direct
dischargers
to
report
all
monitoring
results
to
the
permitting
authority
using
Discharge
Monitoring
Reports
(
DMRs).
Permit­
specific/
At
Least
Annually
122.44(
i)(
2)
403.12
(
b),
(
d),
(
e),
(
g)
Requires
indirect
dischargers
to
report
monitoring
results
to
the
pretreatment
control
authority
using
Periodic
Compliance
Reports
(
PCRs).
Agreement­
specific/
At
Least
Biannually
122.41(
j)(
2)
Requires
direct
dischargers
to
retain
ongoing
monitoring
records
and
copies
of
all
reports
for
at
least
3
years
from
the
date
of
the
sample.

403.12(
o)(
2)
Requires
indirect
dischargers
to
retain
ongoing
monitoring
records
and
copies
of
all
reports
for
at
least
3
years
from
the
date
of
the
sample.

Tables
4.2,
4.3
and
4.4
outline
the
reduced
monitoring
requirements
for
those
mills
enrolled
in
the
VATIP.

Table
4.2
Reduced
Effluent
Monitoring
for
TCDD,
TCDF,
Chloroform,
and
the
12
Chlorinated
Phenolics
for
Mills
Participating
in
the
Voluntary
Advanced
Technology
Incentives
Program
(
VATIP)

40
CFR
Reference
Regulatory
Description
Monitoring
Frequency
430.02(
c)
Requires
non­
ECF1
Subpart
B
mills
enrolled
in
the
VATIP
to
conduct
minimum
monitoring
for
these
pollutants
at
the
following
frequencies:
°
chloroform
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDD
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDF
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
each
of
the
12
chlorinated
phenolics
.
.
.
.
.
.
.
.
Weekly
Monthly
Monthly
Monthly
430.02(
c)
Requires
Advanced
ECF2
Subpart
B
mills
enrolled
in
the
VATIP
to
conduct
minimum
monitoring
for
these
pollutants
at
the
following
frequencies:
°
chloroform
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDD
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCDF
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
each
of
the
12
chlorinated
phenolics
.
.
.
.
.
.
.
.
Monthly
Monthly
Monthly
Monthly
Minimum
Monitoring
Requirements
ICR
Page
8
Table
4.2
Reduced
Effluent
Monitoring
for
TCDD,
TCDF,
Chloroform,
and
the
12
Chlorinated
Phenolics
for
Mills
Participating
in
the
Voluntary
Advanced
Technology
Incentives
Program
(
VATIP)

430.02
(
c)­(
e)
Subpart
B
mills
enrolled
in
the
VATIP
that
use
exclusively
TCF
bleaching
have
no
specified
limits
or
monitoring
frequencies
for
these
pollutants.
None
Notes:
1
Non­
ECF
pertains
to
any
fiber
line
that
does
not
use
exclusively
ECF
or
TCF
bleaching
processes.
2
Advanced
ECF
pertains
to
any
fiber
line
that
uses
exclusively
Advanced
ECF
bleaching
processes,
or
exclusively
ECF
and
TCF
bleaching
processes
as
disclosed
by
the
discharger
in
its
permit
application
under
40
CFR
122.21(
g)(
3)
and
certified
under
40
CFR
122.22.

Table
4.3
Duration
of
Reduced
Effluent
Monitoring
for
TCDD,
TCDF,
Chloroform,
and
the
12
Chlorinated
Phenolics
for
Mills
Participating
in
the
VATIP
40
CFR
Reference
Regulatory
Description
Duration
430.02(
c)
The
duration
of
monitoring
is
five
years,
commencing
after
achievement
of
the
applicable
VATIP
limitations
or
standards
for
those
pollutants.

Subpart
B
mills
that
certify
that
the
fiber
line
uses
Advanced
ECF
bleaching
processes
in
their
NPDES
permit
application
or
other
communication
to
the
permitting
authority
may
discontinue
monitoring
at
these
frequencies
after
one
year.
The
permitting
authority
will
determine
monitoring
frequency
beyond
that
time.
5
Years
1
Year
Table
4.4
Reduced
Effluent
Monitoring
for
AOX
for
Mills
Participating
in
the
VATIP
40
CFR
Reference
Regulatory
Description
Monitoring
Frequency
430.02
(
d)
Subpart
B
mills
enrolled
in
the
VATIP
may
reduce
monitoring
frequencies
for
AOX
for
the
first
year
after
achievement
of
the
applicable
Stage
2
or
ultimate
VATIP
limitations
or
standards
for
AOX,
as
follows:
°
Non­
ECF
­
Tiers
I,
II,
&
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
Advanced
ECF
­
Tiers
I,
II,
&
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCF
­
Tiers
I,
II,
&
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Daily
Weekly
None
Minimum
Monitoring
Requirements
ICR
Page
9
Table
4.4
Reduced
Effluent
Monitoring
for
AOX
for
Mills
Participating
in
the
VATIP
430.02
(
e)
Subpart
B
mills
enrolled
in
the
VATIP
may
reduce
monitoring
frequencies
for
AOX
for
years
two
through
five
after
achievement
of
the
applicable
Stage
2
or
ultimate
VATIP
limitations
or
standards
for
AOX,
as
follows:
°
Non­
ECF
­
Tiers
I,
II,
&
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
Advanced
ECF
­
Tier
I
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
Advanced
ECF
­
Tier
II
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
Advanced
ECF
­
Tier
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
°
TCF
­
Tiers
I,
II,
&
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Daily
Monthly
Quarterly
Annually
None
Should
a
facility
choose
to
collect
and
analyze
more
samples
than
specified
in
its
permit,
the
permittee
must
include
all
monitoring
data
in
the
reports.
See
40
CFR
122.41(
j)(
4)(
ii).
As
indicated
in
Table
4.1,
submission
of
reports
shall
be
at
the
frequency
established
by
the
NPDES
permit
or
pretreatment
control
authority,
but
in
no
case
less
than
once
per
year
for
direct
dischargers
and
twice
per
year
for
indirect
dischargers.
Also,
the
permittee
must
collect
and
analyze
representative
samples
and
must
conduct
all
monitoring
requirements
according
to
permit
specific
conditions
and/
or
approved
test
procedures
as
set
forth
under
40
CFR
Parts
136,
430,
and
503.
See
40
CFR
122.41(
j).

4(
c)
Recordkeeping
requirements
A
sample
of
a
pre­
printed
discharge
monitoring
form
may
be
obtained
from
the
NPDES/
Sewage
Sludge
Monitoring
Reports
ICR.
Direct
and
indirect
dischargers
are
required
to
maintain
monitoring
records,
copies
of
all
reports
required
by
the
NPDES
permit
or
pretreatment
control
agreement
and
records
of
all
data
used
to
complete
the
permit
application
for
at
least
3
years.
See
40
CFR
122.41(
j)(
2)
and
40
CFR
403.12(
o)(
2).

4(
d)
Respondent
Activities
(
i)
Mill
respondent
activities
include
the
following:


Preparing
basic
information.
This
includes
reviewing
regulatory
and
permit
requirements;
conducting
monitoring;
preparing
chain
of
custody
forms;
coordinating
with
lab
facilities;
tracking
of
shipments;
receipt
and
review
of
lab
reports;
preparation
of
DMRs
or
PCRs;
and
submitting
reports
to
the
NPDES
permit
or
pretreatment
control
authority.


Maintaining
records.
All
direct
and
indirect
discharging
mills
in
Subparts
B
and
E
must
keep
records
of
monitoring
information
and
spill
reports
as
required
by
the
regulation.
The
burden
for
preparing
spill
reports
and
recordkeeping
under
430.03(
c)(
5)
and
(
g)
is
included
in
the
Best
Management
Practices
ICR
(
ICR
No.
1829.01;
OMB
No.
2040­
0207),
and
thus
is
not
accounted
for
in
this
ICR.
Minimum
Monitoring
Requirements
ICR
Page
10
(
ii)
NPDES
and
pretreatment
approval­
authorized
States
and
pretreatment
control
authorities
respondent
activities
include:

°
Discharge
Monitoring
Report
(
DMR)
and
Periodic
Compliance
Report
(
PCR)
Review
°
Follow­
up
Activities
°
Reporting
and
Recordkeeping
Requirements
Data
review
varies
from
State
to
State.
Generally,
the
permitting
and
pretreatment
control
authority
routinely
screens
data
to
identify
permit
violations
and
conducts
a
more
thorough
technical
review
and
follow­
up
when
violations
are
detected.
Follow­
up
activities
may
include
informal
contact
with
the
permittee
(
by
telephone
or
letter)
requesting
prompt
corrective
action,
technical
assistance,
field
inspections
to
further
substantiate
violations,
in
the
case
of
indirect
dischargers
request
assistance
from
the
pretreatment
approval
authority,
or
a
formal
enforcement
action
such
as
an
Administrative
Order
or
referral
to
the
EPA
regional
office
and/
or
the
U.
S.
Attorney
(
or
State's
Attorney
General
in
the
case
of
NPDES
and
pretreatment
control­
authorized
States).
Table
4.5
summarizes
NPDES­
authorized
State
requirements.

Table
4.5.
NPDES­
authorized
State
Requirements
(
As
Users
of
Data)

40
CFR
Citation
Regulatory
Description
Response
Frequency
DMR
data
review
§
123.26(
a)
Requires
the
NPDES
permitting
authority
to
have
procedures
for
reviewing
DMR
submissions,
using
the
reported
data
to
evaluate
permittee
compliance.
The
permitting
authority
must
also
have
procedures
for
conducting
an
initial
screening
of
compliance­
related
information.
Variable/
Permit­
specific
§
123.26(
e)
When
warranted,
requires
the
permitting
authority
to
have
procedures
to
follow­
up
the
initial
screening
with
a
substantive
technical
evaluation
to
determine
permittee
compliance
with
permit
conditions.
As
Necessary
Reporting
and
recordkeeping
requirements
§
123.26(
e)(
4)
Requires
the
permitting
authority
to
have
the
procedures
and
ability
for
maintaining
a
management
information
system
that
supports
the
compliance
evaluation
activities.
Ongoing
Table
4.6
summarizes
State
and
local
pretreatment
control
authorities
requirements.

Table
4.6.
State
and
Local
Pretreatment
Control
Authorities
Requirements
(
As
Users
of
Data)

40
CFR
Citation
Regulatory
Description
Response
Frequency
PCR
data
review
Minimum
Monitoring
Requirements
ICR
Page
11
§
403.8(
f)
Requires
the
pretreatment
control
authority
to
have
procedures
for
reviewing
PCR
submissions,
using
the
reported
data
to
evaluate
permittee
compliance.
The
permitting
authority
must
also
have
procedures
for
conducting
an
initial
screening
of
compliance­
related
information.
Variable/
Permit­
specific
§
403.8(
f)
When
warranted,
requires
the
pretreatment
control
authority
to
have
procedures
to
follow­
up
the
initial
screening
with
a
substantive
technical
evaluation
to
determine
permittee
compliance
with
permit
conditions.
As
Necessary
Reporting
and
recordkeeping
requirements
§
403.8(
f)
Requires
the
pretreatment
control
authority
to
have
the
procedures
and
ability
for
maintaining
a
management
information
system
that
supports
the
compliance
evaluation
activities.
Ongoing
EPA
anticipates
that
under
40
CFR
§
403.8(
f),
the
pretreatment
control
authority
may
request
assistance
from
the
pretreatment
approval
authority
in
its
follow­
up
activities
to
determine
an
indirect
discharger's
compliance
with
applicable
pretreatment
standards.
Minimum
Monitoring
Requirements
ICR
Page
12
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
program,
and
where
EPA
is
the
NPDES­
permitting,
pretreatment
approval
or
control
authority,
review
of
monitoring
data,
and
where
necessary,
follow­
up
actions.
Agency
activities
as
the
NPDES
permitting
or
pretreatment
control
authority
are
essentially
the
same
for
NPDES­
authorized
States
summarized
in
Table
4.5
and
State
and
local
pretreatment
control
authorities
summarized
in
Table
4.6.

The
extent
to
which
EPA
reviews
data
in
assessing
permit
compliance
may
vary.
For
example,
EPA
may
conduct
a
more
extensive
review
of
permittees
that
are,
or
have
been,
in
violation
of
their
permit
requirements,
than
of
permittees
who
have
been
in
full
compliance.
In
cases
of
continued
non­
compliance,
EPA
may
use
monitoring
report
data
to
identify
patterns
of
non­
compliance
and/
or
to
support
Agency
enforcement
efforts.
EPA
and/
or
the
permitting
authorities
may
limit
its
review
of
data
submitted
by
fully
compliant
permittees
to
a
simple
determination
of
continuing
compliance.
After
the
initial
period
of
minimum
monitoring
is
complete,
monitoring
requirements
may
be
reduced
by
the
permitting
authorities
for
permittees
that
consistently
demonstrate
an
ability
to
reduce
pollutants
in
their
discharge
below
their
permit
limitations.
EPA
also
expects,
however,
permitting
authorities
to
consider
whether
poor
performance,
compliance
or
enforcement
history,
or
other
site­
specific
factors
indicate
a
need
to
impose
more
frequent
monitoring
than
that
specified
in
§
430.02.
EPA
may
also
review
data
from
minor
permittees
that
may
cause
water
quality
problems
(
i.
e,
significant
minors).
EPA
may
review
data
from
other
minor
permittees
less
frequently.
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
direct
and
indirect
discharging
permittees
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
Respondents
typically
report
collected
compliance
data
on
DMRs
and
PCRs.
Use
of
preprinted
DMR
and
PCR
forms
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
DMR/
PCR
data
is
voluntary
and
will
be
an
Minimum
Monitoring
Requirements
ICR
Page
13
alternative
to
the
paper
DMR/
PCR
submission.
EPA
makes
use
of
the
PCS
database
to
store,
track
and
access
this
information.

5(
c)
Small
Entity
Flexibility
EPA
has
certified
that
the
Cluster
Rules,
including
the
minimum
monitoring
requirements
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Only
four
mills
are
considered
"
a
small
business
concern"
as
defined
by
SBA
regulations.
EPA
does
not
believe
this
is
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).

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

°
Monitoring
and
recordkeeping
are
performed
on
a
continual
basis
(
see
Table
4.1);

°
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
for
direct
dischargers
or
twice
per
year
(
June
and
December)
for
indirect
dischargers.
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
This
section
describes
the
methods
EPA
used
to
estimate
the
burden
to
respondents
associated
with
collecting,
reporting
and
maintaining
records
of
monitoring
data.
Although
Subpart
B
mills
may
qualify
for
reduced
monitoring
frequencies
by
enrolling
in
the
VATIP,
EPA
did
not
account
for
these
possible
reductions
in
order
to
estimate
the
full
potential
burden
to
Subpart
B
mills.
The
assumptions
made
and
a
brief
description
of
the
basis
for
the
burden
estimates
are
presented
below.
Further
supporting
calculations
and
assumptions
may
be
found
in
Appendix
A.
The
number
of
affected
facilities
and
the
pollutants
regulated
associated
with
this
ICR
are
listed
in
Table
6.1
below.
Minimum
Monitoring
Requirements
ICR
Page
14
Table
6.1
Regulated
Pollutants
and
Number
of
Mills
and
Lines
Category
Number
of
Affected
Direct
Discharging
Facilities
Number
of
Affected
Indirect
Discharging
Facilities
Number
of
Bleach
Lines
Regulated
Pollutants
Direct
Indirect
Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
75
9
120
14
AOX,
TCDD,
TCDF,
chloroform,
chlorinated
phenolics
Subpart
E,
Calcium/
Sodium/
Magnesium
Sulfite
5
0
5
0
AOX
Subpart
E,
Ammonium
Sulfite
2
1
2
1
TCDD,
TCDF,
chlorinated
phenolics
Subpart
E,
Specialty
Grade
2
0
2
0
TCDD,
TCDF,
chlorinated
phenolics
Total
84
10
129
15
(
i)
Sampling
Activities
All
Subpart
B
and
E
direct
discharging
mills
will
be
required
to
monitor
for
new
BAT
and
NSPS
pollutants
at
the
minimum
frequency
specified
in
40
CFR
430.02
(
see
Table
4.1).
Direct
discharging
mills
typically
have
one
wastewater
final
effluent
outfall
with
continuous
monitoring
capabilities.
For
AOX
monitoring,
which
must
be
performed
daily
on
the
mill's
final
effluent,
EPA
anticipates
that
mill
personnel
will
take
an
additional
15
minutes
(
0.25
hour)
to
prepare
the
AOX
aliquot,
labels
and
paperwork
and
to
ship
the
sample
to
the
laboratory
for
analysis.

All
Subpart
B
and
E
indirect
discharging
mills
will
be
required
to
monitor
for
new
PSES
and
PSNS
pollutants
at
the
minimum
frequency
specified
in
40
CFR
430.02
(
see
Table
4.1).
For
indirect
dischargers,
AOX
monitoring
must
be
performed
daily
at
the
point
where
the
wastewater
containing
that
pollutant
leaves
the
bleach
plant.
See
40
CFR
430.26(
c)
and
430.26(
c).
Some
mills
have
a
combined
sewer
containing
both
acidic
and
alkaline
wastewaters,
but
most
mills
have
bleach
lines
with
separate
acid
and
alkaline
sewers,
thus
typically,
there
will
be
two
monitoring
stations
per
bleach
line.
These
samples
can
be
collected
either
automatically
or
manually.
The
samples
can
be
either
grab
or
composite.
The
bleach
plant
sampling
burden
is
calculated
assuming
manual
grab
composite
sampling:

Sampling
Burden
(
hours)
=
Avg.
Number
of
Samples
x
Avg.
Hours
to
Collect
Sample
When
bleach
acid
and
alkaline
wastewater
samples
are
collected
separately,
additional
labor
for
flow­
proportioned
composite
sampling
is
anticipated
(
see
Appendix
A,
Section
I
for
supporting
assumptions
and
calculations).
The
labor
required
for
daily
monitoring
for
AOX
for
indirect
Minimum
Monitoring
Requirements
ICR
Page
15
dischargers
includes
time
to
collect
samples
plus
shipping
of
samples
to
the
laboratory
for
analysis;
this
burden
is
estimated
to
be
30
minutes
(
0.5
hour)
per
sample.

For
bleach
plant
monitoring,
the
Cluster
Rules
require
all
Subpart
B
and
E
mills
to
monitor
for
TCDD,
TCDF,
chloroform,
and
the
12
chlorinated
phenolics
at
the
point
were
the
water
containing
these
pollutants
leaves
the
bleach
plant.
See
40
CFR
430.24(
e),
430.25(
e),
430.54(
c)
and
430.55(
d).
Some
mills
have
a
combined
sewer
containing
both
acidic
and
alkaline
wastewaters,
but
most
mills
have
bleach
lines
with
separate
acid
and
alkaline
sewers,
thus
typically,
there
will
be
two
monitoring
stations
per
bleach
line.
These
samples
can
be
collected
either
automatically
or
manually.
The
samples
can
be
either
grab
or
composite.
The
bleach
plant
sampling
burden
is
calculated
assuming
manual
grab
composite
sampling:

Sampling
Burden
(
hours)
=
Avg.
Number
of
Samples
x
Avg.
Hours
to
Collect
Sample
When
bleach
acid
and
alkaline
wastewater
samples
are
collected
separately,
additional
labor
for
flow­
proportioned
composite
sampling
is
anticipated
(
see
Appendix
A,
Section
I
for
supporting
assumptions
and
calculations).
The
labor
required
for
monthly
sampling
for
TCDD,
TCDF
and
the
12
chlorinated
phenolics
includes
time
to
collect
samples
plus
shipping
of
samples
to
the
laboratory
for
analysis;
this
burden
is
estimated
to
be
30
minutes
(
0.5
hour)
per
sample.
For
chloroform,
however,
separate
samples
and
analyses
of
all
bleach
plant
filtrates
discharged
separately
are
required
to
prevent
the
loss
of
chloroform
either
through
air
stripping
as
the
samples
are
collected,
measured,
and
composited
or
through
chemical
reaction
when
the
acid
and
alkaline
samples
are
combined.
The
labor
required
for
weekly
sampling
of
chloroform
includes
time
to
collect
samples
plus
shipping
of
samples
to
the
laboratory
for
analysis
and
is
estimated
to
be
1.5
hours
per
sample.
For
Subpart
B
bleached
papergrade
kraft
and
soda
mills,
the
annual
sampling
burden
is
summarized
in
Table
6.2.
For
Subpart
E
papergrade
sulfite
mills,
the
annual
sampling
burden
is
summarized
in
Table
6.3
(
see
Appendix
A,
Section
II
for
supporting
assumptions
and
calculations).

Table
6.2
Annual
Sampling
Burden
for
Subpart
B
Bleached
Papergrade
Kraft
and
Soda
Mills
Pollutant
Facilities
Sampling
Labor
per
sample
(
hours)
Sample
frequency
Total
Annual
Burden
(
hours)

AOX
(
Direct)
75
mills
1
final
effluent
0.25
daily
6,844
AOX
(
Indirect)
14
bleach
lines
2
bleach
plant
0.5
daily
5,110
AOX
(
Indirect)
50
percent
of
14
bleach
lines
flow­
proportioned
composite
0.25
daily
639
chloroform
134
bleach
plants
2
bleach
plant
1.5
weekly
20,904
TCDD,
TCDF,
12
chlorinated
phenolics
134
bleach
plants
2
bleach
plant
0.5
monthly
1,608
Minimum
Monitoring
Requirements
ICR
Page
16
Table
6.2
Annual
Sampling
Burden
for
Subpart
B
Bleached
Papergrade
Kraft
and
Soda
Mills
TCDD,
TCDF,
12
chlorinated
phenolics
50
percent
of
134
bleach
lines
flow­
proportioned
composite
0.25
monthly
201
Total
Sampling
Burden
for
Subpart
B
mills
(
hours)
35,306
Table
6.3
Annual
Sampling
Burden
for
Subpart
E
Papergrade
Sulfite
Mills
Pollutant
Facilities
Sampling
Labor
per
sample
(
hours)
Sample
frequency
Total
Annual
Burden
(
hours)

AOX
(
Direct)
5
calcium,
magnesium,
and
sodium
sulfite
mills
1
final
effluent
0.25
daily
456
TCDD,
TCDF,
12
chlorinated
phenolics
3
ammonium
sulfite
bleach
lines
2
bleach
plant
0.5
monthly
36
TCDD,
TCDF,
12
chlorinated
phenolics
2
specialty
grade
bleach
lines
2
bleach
plant
0.5
monthly
24
TCDD,
TCDF,
12
chlorinated
phenolics
50
percent
of
5
bleach
lines
(
ammonium
sulfite
and
specialty
grade)
flowproportioned
composite
0.25
monthly
8
Total
Sampling
Burden
for
Subpart
E
mills
(
hours)
524
(
ii)
Analysis
of
Samples
Collected
samples
are
either
analyzed
on­
site
using
the
facility's
own
laboratory
or
the
samples
are
sent
to
an
outside
laboratory
for
analysis.
For
the
purposes
of
this
ICR,
analysis
burden
is
assumed
to
be
contracted
to
outside
laboratories
for
the
purpose
of
estimating
the
full
potential
burden
of
minimum
monitoring
on
Subpart
B
and
E
mills.
This
respondent
burden
is
expressed
as
an
"
operation
and
maintenance"
cost
(
see
Section
6(
b),
particularly
Table
6.9).

(
iii)
Reporting
and
Recordkeeping
Requirements
Reporting
of
monitoring
data
involves
compilation
of
data
from
various
pollutant
analyses
and
calculation
of
average
pollutant
concentrations
and/
or
loadings.
The
respondent
records
this
information
on
the
DMR
or
PCR
and
submits
this
information
to
the
NPDES
permitting
or
pretreatment
control
authority.
For
the
purposes
of
this
ICR,
EPA
assumed
that
DMRs
and
Minimum
Monitoring
Requirements
ICR
Page
17
PCRs
are
submitted
monthly
to
the
NPDES
permit
or
pretreatment
control
authority
in
order
to
express
the
full
potential
reporting
and
recordkeeping
costs
associated
with
the
minimum
monitoring
requirements
for
Subpart
B
and
E
mills.
EPA
estimates
of
the
reporting
burden
per
pollutant
for
the
Cluster
Rule
effluent
minimum
monitoring
are
summarized
in
Table
6.4.
Total
annual
reporting
burden
for
Subpart
B
and
E
mills,
using
annual
burden
estimated
per
regulated
pollutant
as
described
in
Table
6.4,
is
summarized
in
Table
6.5
(
see
Appendix
A,
Section
III
for
supporting
assumptions
and
calculations).

Table
6.4
Annual
Reporting
Burden
for
Each
Pollutant
per
Mill
Pollutant
Burden
Assumptions
Reporting
Burden
(
hours/
month)
Annual
Burden
(
hours)

AOX
daily
results
are
averaged
for
monthly
report
0.1
1.2
chloroform
weekly
reports
averaged
for
monthly
report
0.17
2.0
TCDD,
TCDF,
12
chlorinated
phenolics
monthly
reports
at
2
minutes
for
each
of
14
pollutants
0.47
5.6
Total
0.74
8.8
Table
6.5
Annual
Reporting
Burden
for
Subpart
B
and
E
Mills
Category
Regulated
Pollutants
Number
of
Affected
Mills
Annual
Reporting
Burden
per
mill
(
hours)
Total
Annual
Burden
(
hours)

Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
AOX,
TCDD,
TCDF,
chloroform,
chlorinated
phenolics
84
8.8
739
Subpart
E,
Calcium/
Sodium/
Magnesium
Sulfite
AOX
5
1.2
6
Subpart
E,
Ammonium
Sulfite
TCDD,
TCDF,
12
chlorinated
phenolics
3
5.6
17
Subpart
E,
Specialty
Grade
TCDD,
TCDF,
12
chlorinated
phenolics
2
5.6
11
Total
Annual
Reporting
Burden
for
Subpart
B
and
E
mills
(
hours)
773
Facilities
that
are
required
to
submit
monitoring
data
are
also
required
to
maintain
records
of
that
information.
EPA
assumes
the
time
devoted
to
recordkeeping
at
these
facilities
generally
involves
copying
and
filing
DMRs
or
PCRs.
EPA
estimates
this
burden
to
be
10
minutes
(
0.17
Minimum
Monitoring
Requirements
ICR
Page
18
hour)
per
DMR
or
PCR
submitted
with
an
extended
amount
of
40
minutes
or
0.67
hour
annually
for
quarterly
reports
for
a
total
annual
recordkeeping
burden
of
2.71
hours
per
mill.
Total
annual
recordkeeping
burden
for
Subpart
B
and
E
mills
is
summarized
in
Table
6.6.

Table
6.6
Annual
Recordkeeping
Burden
for
Subpart
B
and
E
Mills
Category
Number
of
Affected
Facilities
Annual
Recordkeeping
Burden
per
mill
(
hours)
Total
Annual
Burden
(
hours)

Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
84
2.71
228
Subpart
E,
Calcium/
Sodium/
Magnesium
Sulfite
5
2.71
14
Subpart
E,
Ammonium
Sulfite
3
2.71
8
Subpart
E,
Specialty
Grade
2
2.71
5
Total
Annual
Recordkeeping
Burden
for
Subpart
B
and
E
mill
(
hours)
255
(
iv)
NPDES­
authorized
State
Respondent
Burden
The
burden
and
associated
costs
to
NPDES­
authorized
State
permitting
for
processing
and
analyzing
monitoring
data
are
a
function
of:
1)
the
number
of
DMRs
received
by
the
permitting
authority;
2)
the
time
it
takes
to
process
and
analyze
monitoring
data
(
including
entry
into
the
PCS
database);
and,
3)
the
salary
and
associated
overhead
costs
of
the
State
employees
who
process
DMRs.
In
addition
to
entering
monitoring
data
into
PCS,
staff
may
need
to
conduct
follow­
up
actions
in
instances
of
non­
compliance.
This
follow­
up
could
be
a
phone
conversation
or
a
letter
to
verify,
clarify
or
substantiate
the
information
reported.

Of
the
84
direct
discharging
mills
in
Subparts
B
and
E,
the
States
are
authorized
NPDES
permit
authorities
for
74
mills.
Compliance
monitoring
for
the
remaining
10
mills
is
overseen
by
EPA.
Recurring
incremental
State
burden
for
those
that
are
authorized
NPDES
permit
authorities
for
processing
and
analyzing
monitoring
data,
including
entry
into
the
PCS
database
is
estimated
to
be
an
average
of
30
minutes
(
0.5
hour)
per
facility
per
DMR
(
74
mills
x
12
DMRs
per
year)
for
an
annual
incremental
burden
of
444
hours.
In
addition,
staff
may
need
to
conduct
follow­
up
actions
in
instances
of
non­
compliance.
This
follow­
up
could
be
a
phone
conversation
or
a
letter
to
verify,
clarify
or
substantiate
the
information
reported.
EPA
estimates
that
20
percent
of
the
DMRs
submitted
will
require
follow­
up
action
by
the
delegated
States,
particularly
due
to
the
unique
nature
of
the
new
monitoring
requirements
imposed
by
the
recently­
promulgated
effluent
limitations
guidelines.
EPA
estimates
that
recurring
incremental
State
burden
for
this
follow­
up
action
requires
an
average
of
30
minutes
(
0.5
hour)
per
facility
per
DMR
or
approximately
89
additional
incremental
hours
per
year
for
a
total
annual
incremental
burden
of
533
hours.

(
iv)
State
and
Local
Pretreatment
Control
Authority
and
State
Pretreatment
Approval
Authority
Respondent
Burden
Minimum
Monitoring
Requirements
ICR
Page
19
EPA
estimates
that
the
10
indirect
discharging
mills
in
Subparts
B
and
E
are
all
regulated
by
local
pretreatment
control
authorities,
with
States
acting
as
pretreatment
approval
authorities
for
all
ten
mills.
Recurring
incremental
burden
for
pretreatment
control
authorities
for
processing
and
analyzing
monitoring
data,
including
entry
into
the
PCS
database
is
estimated
to
be
an
average
of
30
minutes
(
0.5
hour)
per
facility
per
PCR
(
10
mills
x
12
PCRs
per
year)
for
an
annual
incremental
burden
of
60
hours.
In
addition,
staff
may
need
to
conduct
follow­
up
actions
in
instances
of
non­
compliance.
This
follow­
up
could
be
a
phone
conversation
or
a
letter
to
verify,
clarify
or
substantiate
the
information
reported.
EPA
estimates
that
20
percent
of
the
PCRs
submitted
will
require
follow­
up
action
by
the
pretreatment
control
authorities
with
assistance
by
the
pretreatment
approval
authority,
particularly
due
to
the
unique
nature
of
the
new
monitoring
requirements
imposed
by
the
recently­
promulgated
effluent
limitations
guidelines.
EPA
estimates
that
recurring
incremental
burden
for
this
follow­
up
action
requires
an
average
of
30
minutes
(
0.5
hour)
per
facility
per
PCR
or
approximately
12
additional
incremental
hours
per
year
for
a
total
annual
incremental
burden
of
72
hours.

State
pretreatment
approval
activities
include
program
support,
such
as
review
of
pretreatment
control
agreement
renewal
applications,
and
review
of
monitoring
data
(
10
total
mills).
To
estimate
State
pretreatment
approval
authority
burden
support
activities,
EPA
assumes
that
approximately
20
percent
of
all
PCRs
submitted
will
require
follow­
up
assistance
from
State
pretreatment
approval
authorities
with
an
estimated
burden
of
one
hour
per
PCR
for
a
total
annual
incremental
burden
of
24
hours.

A
summary
of
annual
respondent
burden
for
Subpart
B
and
Subpart
E
mills
and
States
is
presented
in
Table
6.7.

Table
6.7
Summary
of
Annual
Respondent
Burden
Category
Sampling
Burden
(
hours)
Reporting
Burden
(
hours)
Recordkeeping
Burden
(
hours)
Total
Annual
Respondent
Burden
(
hours)

Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
35,306
739
228
36,273
Subpart
E,
Calcium/
Sodium/
Magnesium
Sulfite
456
6
14
476
Subpart
E,
Ammonium
Sulfite
40
17
8
65
Subpart
E,
Specialty
Grade
28
11
5
44
Totals
for
Subpart
B
and
E
mills
35,830
773
255
36,858
NPDES­
authorized
States
°
Processing
and
analyzing
monitoring
data...............
°
Follow­
up
actions
for
20
percent
of
DMRs............................
0
0
0
0
0
0
444
89
Minimum
Monitoring
Requirements
ICR
Page
20
Table
6.7
Summary
of
Annual
Respondent
Burden
Totals
for
State
NPDES
Authorities
0
0
0
533
Local
Pretreatment
Control
Authorities
°
Processing
and
analyzing
monitoring
data...............
°
Follow­
up
actions
for
20
percent
of
PCRs............................
0
0
0
0
0
0
60
12
Totals
for
Local
Pretreatment
Control
Authorities
0
0
0
72
State
Pretreatment
Approval
Authorities
°
Follow­
up
actions
for
20
percent
of
PCRs............................
0
0
0
24
Totals
for
State
Pretreatment
Approval
Authorities
0
0
0
24
Totals
for
all
Respondents
37,473
6(
b)
Estimating
Respondent
Cost
EPA
evaluated
the
total
cost
for
each
respondent
activity
based
on
the
following
three
cost
items:

°
Labor
Costs
°
Capital/
Start­
up
Cost
°
Operations
and
Maintenance
(
O&
M)
Costs
(
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,
and
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.

Estimates
for
Federal
and
State
labor
rates
were
based
on
the
1998
US
Labor
department
figures
adjusted
to
2000
dollars
with
the
Consumer
Price
Index,
whereby
the
average
annual
salary
for
Federal
and
State
employees
is
$
43,926;
this
is
equivalent
to
the
salary
of
a
GS­
9,
Step
Minimum
Monitoring
Requirements
ICR
Page
21
10
Federal
employee.
At
2,080
available
labor
hours
per
year,
the
hourly
rate
is
$
21.12.
Overhead
costs
for
Federal
and
State
employees
are
estimated
by
EPA
to
be
60
percent
(
EPA
ICR
Handbook),
or
$
12.67
per
hour,
which
results
in
a
total
hourly
rate
of
$
33.79
($
21.12
+
$
12.67).

Estimates
for
local
pretreatment
control
authority
employees
(
i.
e.,
POTW
employees)
were
based
on
the
2000
US
Labor
department
figures
for
the
wages
and
salaries
value
for
State
and
local
government
workers
plus
a
50
percent
overhead
burden;
this
is
equivalent
to
an
hourly
rate
of
$
30.86
($
20.57
+
$
10.29).

(
ii)
Estimating
Capital/
Start­
up
Costs
The
anticipated
capital
costs
associated
with
this
ICR
comprise
installing
bleach
plant
effluent
flow
monitoring
stations,
which
includes:


flowmeters
for
bleach
plant
flow
measurements

bleach
plant
chloroform
sampling
train

composite
samplers
for
required
bleach
plant
monitoring
°
sample
point
installation
EPA
estimated
costs
for
two
monitoring
stations
per
bleach
line,
assuming
one
acid
stage
filtrate
and
one
alkaline
stage
filtrate,
in
order
to
express
the
full
potential
capital
costs
of
minimum
monitoring
on
Subpart
B
and
E
mills.
EPA
assumed
that
end­
of­
pipe
monitoring
stations
are
already
in
place
at
all
Subpart
B
and
E
mills.
Therefore,
no
capital
costs
are
associated
with
final
effluent
minimum
monitoring.
Total
capital
costs
for
the
installation
of
bleach
plant
effluent
flow
monitoring
stations
were
estimated
to
be
$
128,210
(
2000
dollars)
per
bleach
plant.
This
cost
was
based
on
an
October
29,
1993
memorandum
entitled
"
Bleach
Plant
Flow
Monitoring
Station
Costs,'
found
in
the
Record
for
the
Rulemaking
and
Section
6.5.12.1
of
the
BAT
Cost
Model
Support
Document
(
DCN
13953,
June
1996),
adjusted
to
2000
dollars
with
the
Marshall
and
Swift
Equipment
Costs
Index.

Table
6.8
Total
Mill
Respondent
Capital
Costs
Category
Number
of
Bleach
Lines
Total
Capital
Cost
(
2000
Dollars)

Subpart
B,
Bleached
Papergrade
Kraft
and
Soda
134
$
17,180,140
Subpart
E,
Calcium/
Sodium/
Magnesium
Sulfite
5
$
641,050
Subpart
E,
Ammonium
Sulfite
3
$
384,630
Subpart
E,
Specialty
Grade
2
$
256,420
Total
144
$
18,462,240
(
iii)
Operations
and
Maintenance
(
O&
M)
Costs
Minimum
Monitoring
Requirements
ICR
Page
22
To
estimate
O&
M
costs
associated
with
this
ICR,
EPA
assumes
that
mills
would
send
their
collected
samples
to
outside
laboratories
for
analysis.
Some
facilities
may
perform
in­
house
analysis
for
some
pollutants
(
e.
g.,
AOX
and/
or
chloroform).
However,
for
the
purposes
of
this
ICR,
EPA
assumed
that
all
analyses
will
be
contracted
to
outside
laboratories
in
order
to
express
the
full
potential
analytical
costs
of
minimum
monitoring
on
Subpart
B
and
E
mills.
In
the
future,
facilities
may
elect
to
conduct
analysis
in
house,
particularly
AOX
analyses,
since
the
monitoring
requirement
is
daily.

Analytical
costs
performed
at
outside
laboratories
were
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.
These
costs
are
as
follows:

Table
6.9
Analytical
Sample
Costs
Analyte
Cost/
sample
(
2000
dollars)

AOX
130
TCDD
/
TCDF
948
chlorinated
phenolics
541
chloroform
292
Table
6.10
shows
the
cost
of
sampling
analysis
for
contracted
lab
work
(
see
Appendix
A
for
supporting
assumptions
and
calculations).

Table
6.10
Annual
(
O&
M)
Estimate
of
Analytical
Costs1
Affected
Category
Sampling
Parameter
Analyses/
year
Cost
(
2000
dollars)

Subpart
B:
bleached
papergrade
kraft
and
soda
mills
AOX2
TCDD/
TCDF2
chlorinated
phenolics2
chloroform
35,040
2,412
2,412
13,936
4,555,200
2,286,576
1,304,892
4,069,312
Total
Analytical
Costs
for
Subpart
B
mills
$
12,215,980
Subpart
E:
papergrade
sulfite
AOX
(
calcium
only)
2
TCDD/
TCDF2
chlorinated
phenolics2
1825
90
90
237,250
85,320
48,690
Total
Analytical
Costs
for
Subpart
E
mills
$
371,260
Total
Analytical
Costs
for
Subpart
B
and
E
mills
$
12,587,240
Notes:
1
Costs
presented
assume
that
all
analytical
work
is
contracted
to
outside
laboratories.
Minimum
Monitoring
Requirements
ICR
Page
23
2
Analyses/
year
reflect
that
50
percent
of
bleach
lines
will
use
one
flow­
proportioned
composite
for
analysis
in
lieu
of
two
separate
bleach
plant
samples
(
see
Appendix
A)

6(
c)
Estimating
Agency
Burden
and
Cost
The
estimates
of
EPA
burden
for
direct
dischargers
are
based
on
management
and
support
activities
for
mills
located
in:


States
without
NPDES
authority:
EPA
activities
include
analysis
of
monitoring
data
and
review
of
DMRs
(
10
total
mills);
this
would
translate
to
an
incremental
burden
in
addition
to
current
activities.
Recurring
incremental
EPA
burden
for
processing
and
analyzing
monitoring
data,
including
entry
into
the
PCS
database
(
reporting
and
recordkeeping),
is
estimated
to
be
30
minutes
(
0.5
hour)
per
facility
per
DMR.
In
addition,
EPA
assumes
that
approximately
20
percent
of
all
DMRs
submitted
will
require
follow­
up
action
(
as
was
assumed
in
Section
6(
a)(
iv)),
with
an
estimated
burden
of
one
hour
per
DMR.


States
with
NPDES
authority:
EPA
activities
include
program
support,
such
as
review
of
NPDES
permit
renewal
applications
and
draft
permits,
and
review
of
monitoring
data
(
74
total
mills).
To
estimate
Agency
burden
support
activities,
EPA
assumes
that
approximately
20
percent
of
all
DMRs
submitted
will
require
follow­
up
assistance
from
EPA
with
an
estimated
burden
of
one
hour
per
DMR.

The
estimates
of
EPA
burden
for
indirect
dischargers
are
based
on
management
and
support
activities
for
mills
located
in
States
acting
as
the
pretreatment
approval
authority.
EPA
activities
include
program
support,
such
as
review
of
pretreatment
agreement
renewal
applications
and
draft
permits,
and
review
of
monitoring
data
(
10
total
mills).
To
estimate
Agency
burden
support
activities,
EPA
assumes
that
approximately
20
percent
of
all
PCRs
submitted
will
require
followup
assistance
from
EPA
with
an
estimated
burden
of
one
hour
per
PCR.

Table
6.11
Summary
of
Annual
Agency
Burden
and
Costs
Category
Affected
Subpart
B
and
E
Mills
Activity
Annual
Labor
Hours
Annual
Costs
(
2000
Dollars)

Agency
Burden
Associated
with
Direct
Dischargers
States
without
NPDES
Permit
Authority
10
Processing
and
analyzing
monitoring
data
Follow­
up
actions
for
20
percent
of
DMRs
60
24
$
2,030
$
810
States
with
NPDES
Permit
Authority
74
Follow­
up
actions
for
20
percent
of
DMRs
178
$
6,010
Agency
Burden
Associated
with
Indirect
Dischargers
Minimum
Monitoring
Requirements
ICR
Page
24
Table
6.11
Summary
of
Annual
Agency
Burden
and
Costs
Category
Affected
Subpart
B
and
E
Mills
Activity
Annual
Labor
Hours
Annual
Costs
(
2000
Dollars)

States
with
Pretreatment
Approval
Authority
10
Follow­
up
actions
for
20
percent
of
PCRs
24
$
810
Total
Annual
Agency
Burden
and
Costs
94
­
286
$
9,660
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Table
6.12
summarizes
the
total
annual
industry
burden
and
costs
inclusive
of
the
sampling,
analysis,
reporting
and
recordkeeping
burden
and
annual
burden
and
costs
to
State
NPDES
permitting
authorities.
Minimum
Monitoring
Requirements
ICR
Page
25
Table
6.12
Summary
of
Annual
Respondent
Burden
and
Costs
Category
Annual
Labor
Hours
Annual
Costs
(
2000
Dollars)

Respondents
­
Sampling
Burden
Subpart
B,
Kraft
&
Soda
Mills
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Subpart
E,
Sulfite
Mills
.
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Total
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
35,306
524
35,830
1,020,700
15,150
$
1,035,850
Respondents
­
Analytical
Costs
Subpart
B,
Kraft
&
Soda
Mills
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Subpart
E,
Sulfite
Mills
.
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Total
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
­
­
­
12,215,980
371,260
$
12,587,240
Respondents
­
Reporting
Burden
Subpart
B,
Kraft
&
Soda
Mills
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Subpart
E,
Sulfite
Mills
.
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Total
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
739
34
773
42,060
1,940
$
44,000
Respondents
­
Recordkeeping
Burden
Subpart
B,
Kraft
&
Soda
Mills
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Subpart
E,
Sulfite
Mills
.
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Total
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
228
27
255
12,980
1,540
$
14,520
Respondents
­
Subpart
B
and
E
mills
36,858
$
13,681,610
Respondents
­
State
NPDES
Authorities
533
$
18,010
Respondents
­
State
Pretreatment
Approval
Authorities
24
$
810
Respondents
­
Local
Pretreatment
Control
Authorities
72
$
2220
Total
Annual
Respondent
Burden
and
Cost
37,487
$
13,702,650
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
respondents
are
the
summaries
of
all
the
hours
and
costs
incurred
for
all
activities.

(
i)
Respondent
Tally
The
bottom
line
respondent
burden
(
affected
facilities
and
local
and
State
authorities)
is
presented
in
Table
6.13.
Total
annualized
capital
cost
for
Subpart
B
and
E
mills
was
estimated
using
the
formula
for
Annualized
Net
Present
Value
with
a
discount
rate
of
7.0
percent
and
a
timeframe
of
three
years,
equal
to
the
duration
of
minimum
monitoring
required
by
this
ICR.
Minimum
Monitoring
Requirements
ICR
Page
26
Table
6.13
Total
Estimated
Annual
Respondent
Burden
and
Cost
Summary
(
2000
Dollars)

Category
Number
of
Respondents
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Total
Annualized
Capital
Costs
Total
Annual
O&
M
Costs
(
analytical
costs)

Respondents
­
Subpart
B
and
E
mills
94
36,858
$
1,094,370
$
6,414,910
$
12,587,240
Respondents
­
Local
and
State
authorities
33
629
$
21,040
$
0
$
0
Total
Respondents
127
37,487
$
1,115,410
$
6,414,910
$
12,587,240
(
ii)
The
Agency
Tally
The
bottom
line
Agency
tally
is
presented
in
Table
6.14
(
see
supporting
assumptions
in
Section
6(
c)).

Table
6.14
Total
Estimated
Annual
Agency
Burden
and
Cost
Summary
(
2000
Dollars)

Category
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Total
Annualized
Capital
Costs
Total
Annual
O
&
M
Costs
Agency
286
$
9,660
$
0
$
0
6(
f)
Burden
Statement
EPA
estimates
that
there
are
94
affected
mills
(
direct
and
indirect
dischargers)
in
Subpart
B
and
Subpart
E
of
the
Pulp,
Paper
and
Paperboard
Point
Source
Category
with
a
total
of
144
bleach
lines.
These
mills
will
perform
the
additional
sample
collection
and
pollutant
analyses;
reporting
and
recordkeeping
to
permit
and
pretreatment
authorities,
as
part
of
NPDES
permit
and
pretreatment
control
requirements,
will
not
change
significantly
from
existing
conditions.
EPA
estimates
affected
mills
to
incur
a
burden
of
35,830
hours
per
year
for
sample
collection,
corresponding
to
a
cost
of
$
1,035,850.
Capital
costs
estimated
for
the
minimum
monitoring
requirements
include
the
installation
of
bleach
plant
monitoring
stations,
resulting
in
an
annualized
capital
cost
of
$
6,414,910
for
all
mill
respondents.
Contracted
laboratories
are
anticipated
to
perform
all
required
analyses
of
collected
samples
for
minimum
monitoring
with
an
estimated
O&
M
cost
for
all
mill
respondents
of
$
12,587,240.
Annual
reporting
burden
incurred
by
affected
facilities
is
estimated
to
be
773
hours
for
a
cost
of
$
44,000,
and
annual
recordkeeping
burden
is
estimated
to
be
255
hours
for
a
cost
of
$
14,520
per
year.
Total
mill
respondent
burden
for
the
minimum
monitoring
requirements
is
estimated
to
be
36,858
labor
hours
at
a
cost
of
$
20,096,520
($
1,035,850
+
$
6,414,910
+
$
12,587,240
+
$
44,000
+
$
14,520).
On
a
per­
facility
basis,
mills
are
anticipated
to
incur
an
average
of
400
hours
per
year
for
sampling,
reporting
and
recordkeeping
for
monthly
DMRs
or
PCRs
for
an
average
annual
cost
of
$
213,790,
including
capital
and
O&
M
costs.
Minimum
Monitoring
Requirements
ICR
Page
27
NPDES­
authorized
States
are
estimated
to
incur
533
burden
hours
for
processing
and
analyzing
monitoring
data
captured
in
submitted
DMRs
and
for
follow­
up
activities
associated
with
20
percent
of
all
DMRs
submitted.
This
hourly
burden
translates
to
an
estimated
$
18,010
annually
for
these
activities.

Local
pretreatment
control
authorities
are
estimated
to
incur
72
burden
hours
for
processing
and
analyzing
monitoring
data
captured
in
submitted
PCRs
and
for
follow­
up
activities
associated
with
20
percent
of
all
PCRs
submitted.
This
hourly
burden
translates
to
an
estimated
$
2,220
annually
for
these
activities.
State
pretreatment
approval
authorities
are
estimated
to
incur
24
burden
hours
per
year
for
support
of
local
follow­
up
activities
at
a
cost
of
$
810.

EPA
burden
is
estimated
to
be
286
hours
per
year
for
support
of
State
follow­
up
activities
as
well
as
acting
as
the
NPDES
permit
authority
for
10
mills
where
the
States
are
not
authorized
NPDES
authorities
at
a
cost
of
$
9,660.

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
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
Don
Anderson,
U.
S.
Environmental
Protection
Agency,
Ariel
Rios
Building,
1200
Pennsylvania
Avenue
N.
W.
(
4303),
Washington,
D.
C.
20460.
Include
the
EPA
ICR
number
1878.01
in
any
correspondence.
Minimum
Monitoring
Requirements
ICR
Page
28
Appendix
A:
Supporting
Assumptions
and
Calculations
I.
Flow­
Proportioned
Composite
Sampling
The
Preamble
to
the
Cluster
Rules
specifies
"
For
dioxin,
furan,
and
chlorinated
phenolic
compounds,
compliance
with
the
effluent
limitations
and
standards
can
be
demonstrated
by
collecting
separate
samples
of
the
acid
and
alkaline
discharges
and
preparing
a
flow­
proportioned
composite
of
these
samples,
resulting
in
one
sample
of
bleach
plant
effluent
for
analysis".
See
63
FR
18569.

To
prepare
a
flow­
proportioned
composite,
the
operator:
1)
must
know
the
flow
in
each
sampled
sewer;
2)
add
them
together
to
estimate
total
flow;
and
3)
calculate
the
proportion
of
the
flow
attributable
to
each
sewer.
Knowing
the
total
volume
of
sample
required
for
analysis,
the
operator
must
then:
1)
calculate
the
volume
of
sample
from
each
sewer
that
should
make
up
the
total
sample
volume;
2)
measure
out
each
volume;
and
3)
combine
and
mix
them
together.
This
mixture
is
then
dispensed
into
the
sample
containers
and
sent
to
the
laboratories
for
analysis.

It
is
assumed
that
for
50
percent
of
the
bleach
lines,
flow­
proportioned
composites
will
be
prepared,
requiring
15
minutes
of
operator
labor.
For
these
bleach
lines
there
will
be
one
instead
of
two
samples
to
be
analyzed
for
AOX,
TCDD,
TCDF,
and
the
12
chlorinated
phenolic
compounds.

II.
Example
of
Total
Sampling
Burden
calculation:

Refer
to
Tables
6.2
and
6.3
Assuming
a
manual
grab
composite
methodology
is
used
for
TCDD,
TCDF
and
the
12
chlorinated
phenolics,
the
labor
requirement
may
be
estimated
as
follows:

5
minutes/
point/
grab
x
6
grabs/
sample
=
30
minutes/
point/
sample
Assuming
a
manual
grab
composite
methodology
is
used
for
chloroform,
the
labor
requirement
may
be
estimated
as
follows:

15
minutes/
point
/
grab
x
6
grabs/
sample
=
90
minutes/
sample
For
Subpart
B
mills,
the
annual
sampling
burden
is:

Daily
AOX
sampling
of
final
effluent
(
direct
dischargers):
75
mills
x
1
final
effluent
discharge/
mill
x
0.25
hours/
day
x
365
day/
year
=
6,844
hours
Daily
AOX
sampling
of
bleach
plants
(
indirect
dischargers):
14
bleach
lines
x
2
sample/
bleach
line
x
0.5
hours/
day
x
365
day/
year
=
5,110
hours
Monthly
flow­
proportioned
composites
for
AOX
(
indirect
dischargers):
Minimum
Monitoring
Requirements
ICR
Page
29
50
percent
of
14
bleach
lines
x
0.25
hours/
day
x
365
days/
year
=
639
hours
Weekly
chloroform
sampling
at
bleach
plant:
134
bleach
lines
x
2
sample/
bleach
line
x
1.5
hours/
week
x
52
weeks/
year
=
20,904
hours
Monthly
TCDD,
TCDF
and
the
12
chlorinated
phenolics
sampling
at
the
bleach
plant:
134
bleach
lines
x
2
sample/
bleach
line
x
0.5
hours/
month
x
12
months/
year
=
1,608
hours
Monthly
flow­
proportioned
composites
for
TCDD,
TCDF
and
the
12
chlorinated
phenolics:
50
percent
of
134
bleach
lines
x
0.25
hours/
month
x
12
months/
year
=
201
hours
TOTAL
ANNUAL
SAMPLING
BURDEN
FOR
SUBPART
B
MILLS
35,306
For
Subpart
E
mills,
the
annual
sampling
burden
is:

Daily
AOX
sampling
of
final
effluent
(
direct
dischargers):
5
mills
x
1
final
effluent
discharge/
mill
x
0.25
hours/
day
x
365
day/
year
=
456
hours
Monthly
TCDD,
TCDF
and
the
12
chlorinated
phenolics
sampling
at
the
bleach
plant
(
Ammonium
sulfite
bleach
lines):
3bleach
lines
x
2
sample/
bleach
line
x
0.5
hours/
month
x
12
months/
year
=
36
hours
Monthly
TCDD,
TCDF
and
the
12
chlorinated
phenolics
sampling
at
the
bleach
plant
(
Specialty
grade
bleach
lines):
2
bleach
lines
x
2
sample/
bleach
line
x
0.5
hours/
month
x
12
months/
year
=
24
hours
Monthly
flow­
proportioned
composites
for
TCDD,
TCDF
and
the
12
chlorinated
phenolics
(
Ammonium
sulfite
and
Specialty
grade
lines)
50
percent
of
5
bleach
lines
x
0.25
hours/
month
x
12
months/
year
=
8
hours
TOTAL
ANNUAL
SAMPLING
BURDEN
FOR
SUBPART
E
MILLS
524
hours
III.
Example
of
Total
Reporting
and
Recordkeeping
Burden
calculation:

Refer
to
Tables
6.5
and
6.6
For
Subpart
B
mills,
the
annual
reporting
and
recordkeeping
burden
is:

Annual
Reporting
burden:
84
mills
x
8.8
hours
=
739
hours
Minimum
Monitoring
Requirements
ICR
Page
30
Annual
Recordkeeping
burden:
84
mills
x
0.17
hours/
DMR
x
12
DMRs
+
84
mills
x
0.67
hours/
quarterly
reports
=
228
hours
TOTAL
ANNUAL
REPORTING
AND
RECORDKEEPING
BURDEN
FOR
SUBPART
B
MILLS
967
hours
For
Subpart
E
mills,
the
annual
reporting
and
recordkeeping
burden
is:

Annual
Reporting
burden:
5
Calcium/
Sodium/
Magnesium
Sulfite
mills
x
1.2
hours
=
6
hours
3
Ammonium
Sulfite
mills
x
5.6
hours
=
17
hours
2
Specialty
Grade
mills
x
5.6
hours
=
11
hours
Annual
Recordkeeping
burden:
5
Calcium/
Sodium/
Magnesium
Sulfite
mills
x
0.17
hours/
DMR
x
12
DMRs
+
5
Calcium/
Sodium/
Magnesium
Sulfite
mills
x
0.67
hours/
quarterly
reports
=
14
hours
3
Ammonium
Sulfite
mills
x
0.17
hours/
DMR
x
12
DMRs
+
3
Ammonium
Sulfite
mills
x
0.67
hours/
quarterly
reports
=
8
hours
2
Specialty
Grade
mills
x
0.17
hours/
DMR
x
12
DMRs
+
2
Specialty
Grade
mills
x
0.67
hours/
quarterly
reports
=
5
hours
TOTAL
ANNUAL
REPORTING
AND
RECORDKEEPING
BURDEN
FOR
SUBPART
E
MILLS
61
hours
IV.
Example
of
TCDD,
TCDF
and
12
Chlorinated
Phenolics
Analyses
per
Year
calculation:

Refer
to
Table
6.10
For
Subpart
B
mills,
the
analyses
per
year
for
TCDD,
TCDF
and
12
Chlorinated
Phenolics
is:

Flow­
proportional
composite
(
derived
from
2
bleach
plant
samples
per
month
per
bleach
line)
analysis:

50
percent
of
134
bleach
lines
x
12
composites/
year
=
804
analyses
Bleach
plant
sampling
(
portion
of
Subpart
B
mills
not
conducting
flow­
proportioned
composites)
analysis:

50
percent
of
134
bleach
lines
x
2
samples/
month
x
12
months/
year
=
1,608
analyses
TOTAL
TCDD,
TCDF
AND
12
CHLORINATED
PHENOLICS
Minimum
Monitoring
Requirements
ICR
Page
31
ANALYSES
PER
YEAR
FOR
SUBPART
B
MILLS
2,412
analyses
For
Subpart
E
mills,
the
analyses
per
year
for
TCDD,
TCDF
and
12
Chlorinated
Phenolics
is:

Flow­
proportional
composite
(
derived
from
2
bleach
plant
samples
per
month
per
bleach
line)
analysis:

50
percent
of
5
bleach
lines
(
Ammonium
Sulfite
and
Specialty
Grade)
x
12
composites/
year
=
30
analyses
Bleach
plant
sampling
(
portion
of
Subpart
E
mills
not
conducting
flow­
proportioned
composites)
analysis:

50
percent
of
5
bleach
lines
(
Ammonium
Sulfite
and
Specialty
Grade)
x
2
samples/
month
x
12
months/
year
=
60
analyses
TOTAL
TCDD,
TCDF
AND
12
CHLORINATED
PHENOLICS
ANALYSES
PER
YEAR
FOR
SUBPART
E
MILLS
90
analyses
