INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
BEST
MANAGEMENT
PRACTICES
FOR
THE
BLEACHED
PAPERGRADE
KRAFT
AND
SODA
SUBCATEGORY
AND
THE
PAPERGRADE
SULFITE
SUBCATEGORY
OF
THE
PULP,
PAPER
AND
PAPERBOARD
POINT
SOURCE
CATEGORY
(
40
CFR
PART
430)

EPA
ICR
Number
1829.03
OMB
Control
Number
2040­
0207
June
2005
U.
S.
Environmental
Protection
Agency
Office
of
Water
Engineering
and
Analysis
Division
1200
Pennsylvania
Avenue,
NW
Washington,
D.
C.
20460
Best
Management
Practices
ICR
i
i
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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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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2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3
3(
a)
Nonduplication
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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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3
3(
d)
Effects
of
Less
Frequent
Data
Collection
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3
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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4
3(
g)
Sensitive
Questions
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4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4
4(
a)
Respondents
and
Sic
Codes
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4
4(
b)
Information
Requested
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4
4(
c)
Respondent
Activities
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6
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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7
5(
a)
Agency
Activities
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7
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
Agency
Burden
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11
6(
c)
Bottom
Line
Burden
and
Costs
Tables
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12
6(
d)
Reasons
for
Change
of
Burden
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13
6(
e)
Burden
Statement
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13
Best
Management
Practices
ICR
ii
ii
LIST
OF
TABLES
Table
1.
Summary
of
Mill
Status
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10
Table
2.
Mill
Labor
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Recordkeeping
and
Training
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11
Table
3.
Mill
Costs
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Recordkeeping
and
Training
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11
Table
4.
Recurring
Respondent
Burden
and
Costs
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11
Table
5.
Summary
of
Burden
and
Costs
to
Respondents
and
Government
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12
Table
6.
Bottom
Line
Initial
Burden
and
Costs
Based
in
2000
Dollars
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12
Table
7.
Bottom
Line
Recurring
Burden
and
Costs
Based
in
2000
Dollars
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13
Best
Management
Practices
ICR
1
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
ICR:
Best
Management
Practices
for
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper
and
Paperboard
Point
Source
Category
(
Renewal)
(
EPA
ICR
No.
1829.03).

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
presents
estimates
of
the
burden
and
costs
to
the
regulated
community
(
approximately
94
bleached
papergrade
kraft,
soda
and
sulfite
mills)
and
NPDES
permit
and
pretreatment
control
authorities
for
data
collection
and
recordkeeping
associated
with
implementation
of
the
Best
Management
Practices
requirements
of
the
Pulp
and
Paper
Effluent
Limitations
Guidelines
and
Standards
(
40
CFR
Part
430.03).
This
is
a
renewal
ICR.

The
Clean
Water
Act
(
CWA)
authorizes
the
Environmental
Protection
Agency
(
EPA)
to
include
Best
Management
Practices
(
BMPs)
in
effluent
limitations
guidelines
and
standards
regulations.
EPA's
legal
authority
to
promulgate
BMPs
is
found
in
Section
304(
e),
Section
307(
b)
and
(
c),
Section
308(
a),
Section
402(
a)(
1)(
B)
and
Section
501(
a)
of
the
Clean
Water
Act,
33
U.
S.
C.
§
1251,
et.
seq.
EPA
also
relies
on
40
CFR
122.44(
k).
The
BMP
regulation
is
consistent
with
the
Pollution
Prevention
Act
of
1990,
42
U.
S.
C.
§
13101,
et.
seq.

The
objectives
of
the
BMPs
are
to
prevent
leaks
and
spills
of
spent
pulping
liquors,
soap
and
turpentine
for
mills
in
bleached
papergrade
kraft
and
soda
(
Subpart
B)
and
papergrade
sulfite
(
Subpart
E)
subcategories;
and,
to
contain,
collect
and
recover
at
the
immediate
process
area,
or
otherwise
control,
those
leaks,
spills
and
intentional
diversions
of
spent
pulping
liquor
that
do
occur.
EPA
has
emphasized
control
of
spent
pulping
liquors,
intentional
liquor
diversions,
soap
and
turpentine
for
the
following
reasons:
(
1)
losses
of
spent
pulping
liquor
contribute
significant
portions
of
untreated
wastewater
loadings
and
discharge
loadings
of
color,
oxygen­
demanding
substances,
and
non­
chlorinated
toxic
compounds
from
chemical
pulp
mills;
(
2)
spent
pulping
liquor
spills
and
intentional
liquor
diversions
are
a
principal
cause
of
upsets
and
loss
of
efficiency
of
biological
treatment
systems
that
are
used
for
treatment
of
Subpart
B
and
E
mill
wastewaters,
thus
contributing
to
increased
effluent
discharges
of
toxic,
conventional
and
nonconventional
pollutants;
(
3)
soap
and
turpentine
are
substances
that
are
highly
toxic
to
biological
treatment
systems;
and
(
4)
control
of
spent
pulping
liquors
is
a
form
of
pollution
prevention
that
can
result
in
cost
savings,
less
demand
for
make­
up
pulping
chemicals,
increased
energy
efficiency,
more
effective
wastewater
treatment
and
incidental
reductions
in
atmospheric
emissions
of
total
reduced
sulfur
(
TRS)
compounds
from
kraft
mills
and
volatile
hazardous
air
pollutants
from
Subpart
B
and
E
mills.

The
regulation
requires
that
owners
or
operators
of
Subpart
B
and
E
mills
prepare
and
implement
site­
specific
BMPs
for
management
of
spent
pulping
liquors
and
prevent
and
control
losses
of
soap
and
turpentine.
In
addition,
the
regulation
requires
mills
to
monitor
the
effectiveness
of
BMP
implementation
on
a
continuing
basis
by
tracking
the
influent­
to­
treatment
wastewater
loading.
EPA
has
structured
the
BMP
regulation
to
provide
maximum
flexibility
to
Best
Management
Practices
ICR
2
2
the
regulated
community
and
to
minimize
administrative
burdens
on
NPDES
permit
and
pretreatment
control
authorities
that
regulate
Subpart
B
and
E
mills.
In
fact,
the
final
BMP
regulation
provides
flexibility
for
mill
owners
or
operators
to
select
any
reasonable
measure
of
organic
loading
and/
or
spent
pulping
liquor
losses
to
monitor
the
effectiveness
of
BMPs.
Also,
the
final
regulation
is
less
prescriptive
than
the
proposed
rule
with
regard
to
inspection,
repair
and
log­
keeping
requirements.
EPA
determined
that
the
final
rule
language
allows
mills
to
use
existing
maintenance
and
repair
tracking
systems
to
fulfill
the
aforementioned
requirements
thereby
reducing
burden
to
the
industry.
By
promulgating
a
national
regulation
for
BMPs,
EPA
has
effectively
removed
substantial
administrative
and
technical
burdens
on
NPDES
and
pretreatment
control
authorities
to
devise
and
implement
these
requirements
on
a
case­
by­
case
basis
through
their
permit
programs.

In
summary,
implementation
of
effective
BMPs
has
been
shown
to
provide
a
potential
significant
payback
to
a
mill.
In
one
incident
at
an
indirect­
discharging
kraft
mill
in
the
southeastern
U.
S.
in
July
1993,
a
process
upset
caused
a
release
of
excess
spent
pulping
liquor
to
the
POTW,
which
then
caused
a
fish
kill.
The
resulting
costs
for
cleanup
and
mill
shutdown
were
approximately
equal
to
the
cost
of
full
implementation
of
BMPs
at
the
mill.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
In
the
BMP
regulation,
EPA
is
requiring
mills
with
pulp
production
Subpart
B
and
E
Subcategories
to
develop
and
implement
BMPs
to
prevent
or
otherwise
contain
leaks
and
spills
and
to
control
intentional
diversions
of
spent
pulping
liquor,
soap
and
turpentine.
These
BMPs
apply
to
direct
and
indirect
discharging
mills
within
these
subcategories
and
are
intended
to
reduce
wastewater
loadings
of
color,
oxygen­
demanding
substances,
and
non­
chlorinated
toxic
compounds
and
hazardous
substances
in
mill
wastewater,
with
incidental
reductions
in
conventional
water
pollutants
and
certain
air
pollutants.

EPA's
legal
authority
to
promulgate
this
BMP
regulation
is
found
in
Section
304(
e),
Section
307(
b)
and
(
c),
Section
308(
a),
Section
402(
a)(
1)(
B),
Section
402(
a)(
2)
and
Section
501(
a)
of
the
Clean
Water
Act,
33
U.
S.
C.
§
1251,
et
seq.
EPA
also
relies
on
40
CFR
§
122.44(
k).
This
BMP
regulation
is
also
consistent
with
the
Pollution
Prevention
Act
of
1990,
42
U.
S.
C.
§
13101,
et
seq.
For
further
discussion
of
EPA's
legal
authority
to
require
mills
to
develop
and
implement
BMPs,
including
the
information
collection
requirements
discussed
in
this
document,
see
the
BMP
Technical
Support
Document
(
BMP
TSD,
DCN
14489).

2(
b)
Practical
Utility/
Users
of
the
Data
The
primary
users
of
the
information
generated
through
BMP
Plans
will
be
the
owners
and
operators
of
the
Subpart
B
and
E
pulp
and
paper
mills.
EPA
intends
that
the
data
collected
(
in
the
form
of
BMP
monitoring
reports)
will
be
used
by
mill
operators
to
track
the
effectiveness
and
progress
of
BMP
implementation
through
comparisons
with
action
levels
established
by
the
mill.
Under
the
regulation,
whenever
monitoring
results
exceed
action
levels
for
particular
periods,
the
mill
must
complete
an
investigation
or
corrective
action,
as
appropriate.
Best
Management
Practices
ICR
3
3
EPA
also
expects
that
the
monitoring
reports
required
by
the
BMP
regulations
will
be
used
by
NPDES
and
pretreatment
control
authorities
to
determine
compliance
with
the
regulation.
EPA
anticipates
that
State
and
local
control
authorities
will
conduct
detailed
technical
reviews
of
BMP
Plans
only
in
the
event
the
monitoring
reports
indicate
noncompliance
with
BMP
conditions
contained
in
the
mill's
NPDES
permit
or
pretreatment
control
mechanism.

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

°
the
EPA
Information
Systems
Inventory,
°
the
Government
Information
Locator
System
(
GILS),
and
°
the
Toxic
Chemical
Release
Inventory.

Examination
of
these
databases
revealed
no
duplicative
reporting
requirements.

EPA
has
examined
a
similar
reporting
requirement
for
notice
of
spills
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
for
duplication
of
the
requirements
of
this
regulation.
The
requirements
for
reporting
of
pollutant
releases
under
RCRA
is
different
than
reporting
of
spills
or
losses
of
spent
pulping
liquor,
soap
or
turpentine
outside
the
immediate
process
areas
under
this
regulation.
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
to
formal
submission
to
OMB.
EPA
published
a
formal
notice
in
the
Federal
Register
on
August
30,
2004
(
69
FR
52883­
52888).
EPA
received
no
comments.

3(
c)
Consultations
EPA
had
extensive
discussions
with
the
regulated
community
and
selected
federal
and
State
NPDES
permitting
authorities
regarding
development
of
this
regulation
and
the
attendant
recordkeeping
and
reporting
requirements.

3(
d)
Effects
of
Less
Frequent
Data
Collection
The
regulation
requires
collection
of
daily
influent­
to­
treatment
data.
Most
mill
operators
collect
such
data
independent
of
this
requirement
for
purposes
of
monitoring
and
optimizing
wastewater
treatment
plant
operations.
Because
spill,
leaks
and
losses
of
spent
pulping
liquors
can
and
do
occur
frequently
and
at
any
time,
less
frequent
monitoring
would
not
provide
the
timely
information
to
mill
operators
to
identify
and
respond
to
a
spill,
leak
or
loss
event.
Best
Management
Practices
ICR
4
4
3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.6
and
1320.12.

3(
f)
Confidentiality
EPA
does
not
expect
that
confidential
business
information
or
trade
secrets
will
be
required
from
mill
operators
as
part
of
this
ICR.
In
the
event
that
the
information
submitted
in
conjunction
with
this
ICR
is
claimed
to
be
confidential
business
information
(
CBI)
by
the
mill
owner
or
operator,
the
information
would
then
be
handled
pursuant
to
40
CFR
Part
2
when
EPA
is
the
permitting
authority
and
applicable
State
and
local
government
rules
and
regulations
governing
CBI
when
States
or
local
governments
are
the
permitting
or
pretreatment
control
authorities.
Any
mills
that
may
consider
asserting
CBI
claims
should
do
so
carefully
as
they
may
be
asked
to
support
any
such
claims
at
a
later
date.

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
respondents
for
this
ICR
will
be
approximately
94
direct
and
indirect
discharging
Subpart
B
and
E
pulp
mills
in
the
Pulp,
Paper
and
Paperboard
Manufacturing
Category
(
SIC
2611,
2631)
(
NAICS
32211,322121,
322122,
32213).
Government
respondents
are
estimated
to
be
34
State
and
local
authorities
(
24
NPDES
and
pretreatment
approval­
authorized
States
and
10
local
pretreatment
control
authorities)
for
preparation
of
new
NPDES
permits
and
pretreatment
conditions
for
implementing
the
BMP
regulation
and
conducting
detailed
technical
reviews
of
BMP
Plans
in
the
event
the
monitoring
reports
indicate
noncompliance
with
BMP
conditions
contained
in
the
mill's
NPDES
permit
or
pretreatment
control
mechanism.

4(
b)
Information
Requested
The
BMP
regulations
at
40
CFR
430.03
include
the
following
major
components:
(
1)
development,
review
and
certification
of
a
BMP
plan;
(
2)
amendment
and
periodic
review
of
the
BMP
plan;
(
3)
reporting
of
spills;
(
4)
additional
monitoring
and
reporting;
and
(
5)
additional
recordkeeping.
See
40
CFR
430.03(
c)
through
(
i)
and
the
BMP
TSD
for
more
detailed
information
on
the
requirements.
The
development,
review,
and
certification
of
a
BMP
plan
is
an
initial
one­
time
component
of
the
BMP
regulations,
and
the
associated
burden
was
already
accounted
for
in
the
original
ICR
(
No.
1829.01).
Therefore,
that
burden
is
not
included
in
this
renewal
ICR.

(
1)
Development,
review
and
certification
of
a
BMP
plan
[
§
430.03(
d)
and
(
f)]:

Central
to
the
BMP
regulation
is
the
development
of
a
BMP
plan.
This
plan
is
intended
to
Best
Management
Practices
ICR
5
5
be
the
initial
and
ongoing
BMP
planning
and
implementation
tool
for
mills.
The
BMP
plan
must,
at
a
minimum,
include
programs:
(
a)
to
identify
and
repair
leaking
equipment;
(
b)
to
track
equipment
repairs;
(
c)
to
train
personnel;
(
d)
to
report
and
evaluate
spills;
(
e)
to
review
planned
mill
modifications;
and
(
f)
to
establish
wastewater
treatment
system
influent
action
levels
(
including
an
initial
six­
month
monitoring
program).

Also,
as
part
of
the
BMP
plan
development,
each
mill
must
conduct
a
detailed
engineering
review
of
the
pulping
and
chemical
recovery
areas
to
determine
the
magnitude
and
routing
of
potential
leaks,
spills,
and
intentional
diversions
of
spent
pulping
liquors,
soap
and
turpentine
and
to
determine
the
adequacy
of
containment
and
collection
facilities
(
see
40
CFR
430.03
(
d)
(
3)
for
additional
details).
The
BMP
plan
and
any
amendments
require
review
by
the
senior
technical
manager
and
certification
by
the
mill
manager.

(
2)
Amendment
and
periodic
review
of
a
BMP
Plan
[
§
430.03(
e)]:

Owners
or
operators
must
amend
their
BMP
Plans
whenever
there
is
a
change
in
mill
design,
construction,
operation,
or
maintenance
that
materially
affects
the
potential
for
leaks
or
spills
of
spent
pulping
liquor,
soap
or
turpentine
from
the
immediate
process
areas.
Notwithstanding
this
requirement,
owners
or
operators
must
complete
a
review
and
evaluation
of
their
BMP
Plans
at
least
once
every
five
years
and
amend
the
plan
within
three
months
of
such
review,
if
warranted.
As
mentioned
above,
any
BMP
plan
amendments
require
review
by
the
senior
technical
manager
and
certification
by
the
mill
manager.

(
3)
Reporting
of
spills
[
§
430.03(
c)(
5)]:

Owners
or
operators
are
required
to
prepare
brief
reports
of
spills
of
spent
pulping
liquor,
soap
or
turpentine
not
contained
in
the
immediate
process
area
(
e.
g.,
a
failure
of
the
management
practices
and
control
systems
identified
by
the
owner
or
operator
in
the
BMP
Plan).
The
report
must
list
the
equipment
items
involved,
the
circumstances
leading
to
the
incident,
the
effectiveness
of
corrective
actions
taken
and
plans
to
implement
future
changes.
These
reports
must
be
maintained
by
the
mill
owner
or
operator
for
three
years
and
they
need
only
be
submitted
to
the
NPDES
permit
or
pretreatment
control
authority
upon
request.

(
4)
Additional
monitoring
and
reporting
[
§
430.03
(
c)(
3),
(
g),
(
h)
and
(
i)]:

Mills
are
required
to
operate
continuous,
automatic
monitoring
systems
that
the
mill
determines
are
necessary
to
detect
and
control
leaks,
spills,
and
intentional
diversions
of
spent
pulping
liquor,
soap,
and
turpentine.
See
40
CFR
430.03(
c)(
3).
As
part
of
this
requirement,
all
mills
(
with
the
exception
of
new
sources)
are
required
to
perform
two
six­
month
monitoring
programs
in
order
to
determine
the
characteristics
(
or
action
levels)
of
their
wastewater
treatment
system
influent.
See
40
CFR
430.03(
h).
(
New
sources
are
required
to
perform
only
one
six­
month
monitoring
program
for
this
purpose.
See
40
CFR
430.03(
h)(
5).)
All
mills
are
also
required
to
perform
additional
monitoring
to
revise
those
action
levels
after
any
change
in
mill
design,
construction,
operation,
or
maintenance
that
materially
affects
the
potential
for
leaks
or
spills
or
spent
pulping
liquor,
soap,
or
turpentine
from
the
immediate
process
area.
See
40
CFR
430.03(
h)(
6).
The
regulation
also
requires
all
mills
to
conduct
daily
monitoring
of
wastewater
treatment
system
influent
for
the
purpose
of
detecting
leaks
and
spills,
tracking
the
effectiveness
Best
Management
Practices
ICR
6
6
of
the
BMPs,
and
detecting
trends
in
spent
pulping
liquor
losses.
See
40
CFR
430.03(
i).

Mill
operators
are
required
to
provide
their
NPDES
permit
or
pretreatment
control
authorities
reports
of
the
monitoring
required
by
the
BMP
regulation.
See
40
CFR
430.03(
i)(
4).
The
reports
must
include
a
summary
of
the
monitoring
results,
the
number
and
dates
of
exceedances
of
the
applicable
action
levels,
and
brief
descriptions
of
any
corrective
actions
taken
to
respond
to
such
exceedances.
Submission
of
such
reports
shall
be
at
the
frequency
established
by
the
NPDES
permit
or
pretreatment
control
authority,
but
in
no
case
less
than
once
per
year.

(
5)
Recordkeeping
requirements
[
§
430.03(
g)]:

The
regulation
requires
that
certain
equipment
repair
records,
records
of
employee
training,
reports
of
spills
outside
the
immediate
process
area,
and
records
of
monitoring
conducted
as
part
of
the
BMP
program
be
maintained
for
three
years.

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


Preparing
basic
information.
This
includes
reviewing
regulatory
and
permit
requirements;
conducting
initial
and
refresher
employee
training;
developing
and
certifying
the
BMP
Plan;
tracking
equipment
repair;
conducting
influent­
to­
treatment
monitoring;
preparing
reports
of
spill
incidents
outside
the
immediate
process
area;
and,
making
reports
to
the
NPDES
permit
or
pretreatment
control
authority.


Maintaining
records.
All
mills
in
Subparts
B
and
E
must
keep
records
of
monitoring
information,
equipment
repair,
employee
training,
and
spill
reports
as
required
by
the
regulation.

State
permitting
and
local
pretreatment
control
authority
activities
include
the
following:


Preparing
NPDES
permit
and
pretreatment
conditions.
This
includes
reviewing
the
development
of
each
mill's
BMP
plans
in
accordance
with
40
CFR
430.03.
State
permitting
and
local
pretreatment
control
authority
respondents
are
responsible
for
the
incorporation
of
BMP
provisions
in
NPDES
permits
and
pretreatment
conditions.


Periodic
Review.
State
and
local
respondents
are
authorized
to
conduct
periodic
review
of
monitoring
reports
submitted
by
each
mill
and
perform
compliance
reviews.
Detailed
technical
reviews
of
BMP
Plans
may
be
performed
in
the
event
the
monitoring
reports
indicate
noncompliance
with
BMP
conditions
contained
in
the
mill's
NPDES
permit
or
pretreatment
control
mechanism.

The
initial
one­
time
burden
associated
with
mill
respondents
conducting
initial
employee
training
and
developing
and
certifying
the
BMP
plan
and
State
permitting
and
local
pretreatment
control
authority
activities
in
preparing
NPDES
permit
and
pretreatment
conditions
was
already
accounted
for
in
the
original
ICR
(
No.
1829.01)
and,
therefore,
is
not
included
in
this
renewal
ICR.
Best
Management
Practices
ICR
7
7
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Upon
approval
of
this
renewal
ICR,
permittees
must
continue
to
maintain
records
as
described
above
in
Section
4(
c)
and
at
least
annually,
must
submit
to
the
NPDES
or
pretreatment
control
authority
a
report
summarizing
the
results
of
daily
monitoring,
the
number
and
dates
of
any
exceedances
of
action
levels
and
corrective
actions
taken
when
action
levels
are
exceeded.
The
permitting
authority
can
be
either
an
approved
NPDES
State
or
one
of
EPA's
regional
offices.
The
permitting
authority
or
pretreatment
control
authority
is
authorized
to
conduct
compliance
audits
of
facility
records,
review
the
data,
and
where
necessary,
conduct
follow­
up
actions.
Follow­
up
activities
may
include
informal
contact
with
the
permittee
(
by
telephone
or
letter)
to
discuss
the
cause
of
any
exceedances
of
action
levels
and
responses
taken
to
correct
the
exceedences.
Because
the
requirements
to
implement
the
BMPs
and
maintain
records
will
be
incorporated
in
a
mill's
NPDES
permit
or
pretreatment
control
mechanism
as
enforeceable
conditions,
the
permitting
authority
will
be
responsible
for
assessing
whether
the
mill
is
properly
maintaining
records
(
including
the
BMP
Plan)
and
thus,
performing
equipment
repairs,
employee
training
and
responding
to
any
exceedance
events
in
a
timely
manner.
Review
of
monitoring
records
may
also
be
helpful
to
the
permit
writers
in
the
development
of
future
NPDES
permit
conditions.

The
extent
to
which
EPA
reviews
data
will
depend
on
available
resources
and
the
specific
reviewing
procedures
of
the
permitting
authority
(
State
or
EPA
region).
In
NPDES
States,
State
environmental
agencies
generally
review
permittee
data.
EPA
regions
may
also
review
data
from
major
permittees
in
NPDES
States
while
performing
program
oversight
functions,
particularly
since
the
assessment
of
compliance
is
subjective.

5(
b)
Collection
Methodology
and
Management
As
with
the
minimum
effluent
monitoring
requirements
associated
with
the
Cluster
Rule,
mill
owners
and
operators
are
required
to
maintain
information
for
in­
mill
use
to
assess
BMP
effectiveness
and
for
preparation
of
the
summary
report
of
daily
monitoring.
The
regulation
provides
a
framework
for
compliance,
but
mill
owner
and
operators
can
develop
the
necessary
data
collection
and
management
protocols
to
achieve
an
effective
BMP
program.
EPA
expects
that
mill
owners
and
operators
will
most
likely
use
existing
in­
mill
and
effluent
monitoring
capabilities
to
perform
the
daily
monitoring
and
existing
computer
capabilities
to
develop
and
maintain
records.

5(
c)
Small
Entity
Flexibility
EPA
has
already
certified
that
the
Cluster
Rules,
including
the
BMP
requirements
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)
Best
Management
Practices
ICR
8
1Estimates
for
operator
and
engineer
labor
costs
were
prepared
using
industry­
specific
labor
rates
identical
to
those
used
for
the
EPA
ICR
Number
1878.01,
included
overhead
and
fringe
benefits,
and
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index.
To
verify
the
validity
of
the
adjusted
rates
EPA
obtained
national
industry­
specific
wage
estimates
for
the
pulp,
paper,
and
paperboard
mills
from
the
Labor
Department.
Noting
that
the
Labor
Department
wages
were
lower,
EPA
decided
to
apply
the
more
conservative
estimates
from
the
previous
ICR.

2Estimates
for
management
labor
rate
from
the
May
2003
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates
for
NAICS
322100
­
Pulp.
Paper,
and
Paperboard
Mills.
The
mean
hourly
wage
for
General
and
Operation
Managers
(
SOC
Code
11­
1021),
including
50
percent
for
overhead
and
fringe
benefits
and
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index,
is
88.49.

8
5(
d)
Collection
Schedule
The
majority
of
information
collection
activities
included
in
this
ICR
are
anticipated
to
coincide
with
existing
monitoring,
recordkeeping,
and
reporting
requirements
(
e.
g.,
Discharge
Monitoring
Reports),
although
some
recordkeeping
may
be
non­
routine,
such
as
spill
reporting.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
Burden
and
costs
will
vary
based
upon
mill
complexity,
see
Table
1.
Tables
2
presents
estimates
of
the
recurring
mill
respondent
burdens
for
labor
hours
and
costs
associated
with
this
ICR.
The
assumptions
made
are
listed
in
each
Table.
A
summary
of
the
mill
respondents'
burden
hours
and
costs
is
presented
in
Table
3.
A
brief
description
of
the
basis
for
the
burden
estimates
is
presented
below.

(
1)
Development,
review
and
certification
of
a
BMP
plan:

Development
of
a
site­
specific
BMP
plan
is
a
one­
time
initial
burden.
As
part
of
the
BMP
plan
development,
mills
must
also
establish
a
training
program
for
technical
personnel.
This
training
program
must
include
both
an
initial
training
effort
and
refresher
training,
which
at
a
minimum,
must
be
performed
annually.
The
burden
associated
with
the
development
of
the
BMP
plan
and
initial
training
were
already
accounted
for
in
the
original
ICR
(
No.
1829.01)
and
are,
therefore,
not
included
in
the
burden
estimates
of
this
renewal
ICR.
The
refresher
training
is
based
on
bi­
annual
effort
of
four
hours
each,
including
nine
operators
and
one
consultant
acting
as
trainer.
The
total
burden
for
refresher
training
per
mill
is
estimated
to
be
72
hours
of
operator
effort
(
at
$
32.81
per
hour)
and
eight
hours
of
consultant
engineering
effort
(
at
$
64.58
per
hour).
1
(
2)
Amendment
and
periodic
review
of
a
BMP
Plan:

EPA
anticipates
less
than
50
hours
of
mill
labor
per
amendment
and
has
based
the
ICR
burden
on
an
assumption
that
each
mill
would
need
to
amend
its
BMP
plan
twice
every
five
years
for
an
annual
burden
of
20
hours,
estimating
18
hours
of
mill
engineer
effort
(
at
$
64.58
per
hour)
and
two
hours
of
management
effort
(
at
$
88.49
per
hour),
which
is
included
in
the
annual
estimates
presented
in
Tables
2
and
3.2
Best
Management
Practices
ICR
9
9
(
3)
Reporting
of
spills:

EPA
anticipates
that
the
burden
of
preparing
a
spill
report
is
approximately
four
hours
and
can
be
conducted
by
a
mill
engineer
(
at
$
64.58
per
hour).
ICR
burden
is
calculated
on
an
annual
basis
using
an
assumption
of
one
spill
per
mill
per
month
and
is
included
in
the
annual
estimates
presented
in
Table
2
and
3.

(
4)
Additional
monitoring
and
reporting:

Mills
are
required
to
operate
continuous,
automatic
monitoring
systems
that
the
mills
determine
are
necessary
to
detect
and
control
leaks,
spills,
and
intentional
diversions
of
spent
pulping
liquor,
soap,
and
turpentine.
The
burden
for
designing,
testing,
and
operating
the
monitoring
system,
expressed
in
the
form
of
costs,
is
included
in
the
compliance
cost
estimates
developed
for
the
regulation
(
see
Table
9.2
of
the
BMP
TSD,
DCN
14489).

In
addition,
all
mills
with
the
exception
of
new
sources
are
required
to
perform
two
six­
month
monitoring
programs
in
order
to
determine
the
characteristics
(
or
action
levels)
of
their
wastewater
treatment
system
effluent.
See
40
CFR
430.03(
h).
(
New
sources
are
required
to
perform
only
one
six­
month
monitoring
program
for
this
purpose.)
All
mills
are
also
required
to
perform
additional
monitoring
to
revise
those
action
levels
after
any
change
in
mill
design,
construction,
operation,
or
maintenance
that
materially
affects
the
potential
for
leaks
or
spills
or
spent
pulping
liquor,
soap,
or
turpentine
from
the
immediate
process
area.
The
effort
required
to
implement
the
initial
monitoring
program
and
perform
the
associated
statistical
analysis
to
establish
the
action
levels
is
included
in
the
compliance
cost
estimates
developed
for
the
regulation,
and
the
burden
to
perform
monitoring
to
revise
those
action
levels
is
included
in
the
incremental
monitoring
burden
discussed
below.

The
regulation
also
requires
all
mills
to
conduct
daily
monitoring
of
wastewater
treatment
system
influent
for
the
purpose
of
detecting
leaks
and
spills,
tracking
the
effectiveness
of
the
BMPs,
and
detecting
trends
in
spent
pulping
liquor
losses.
EPA
estimates
the
burden
associated
with
this
monitoring
to
be
an
increment
of
one
additional
hour
per
day
of
operator
time
over
existing
burden
imposed
by
minimum
monitoring;
this
increment
is
included
in
the
annual
estimates
shown
in
Tables
2
and
3.
Costs
for
monitoring
equipment
were
included
as
initial
capital
costs
in
the
original
ICR
(
No.
1829.01).
Therefore,
these
one­
time
costs
are
not
included
in
the
burden
estimates
of
this
renewal
ICR.

Mill
operators
are
required
to
provide
their
NPDES
permit
or
pretreatment
control
authorities
reports
of
the
monitoring
required
by
the
BMP
regulation.
Submission
of
such
reports
shall
be
at
the
frequency
established
by
the
NPDES
permit
or
pretreatment
control
authority,
but
in
no
case
less
than
once
per
year.
EPA
has
based
the
burden
estimates
on
a
semi­
annual
reporting
frequency
and
estimates
that
each
report
will
take
16
hours
to
complete,
based
on
14
hours
of
mill
engineer
effort
and
two
hours
of
management
effort
(
also
included
in
estimates
presented
in
Tables
2
and
3).
Best
Management
Practices
ICR
10
3Estimates
for
clerical
labor
rate
from
the
May
2003
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates
for
NAICS
322100
­
Pulp.
Paper,
and
Paperboard
Mills.
The
mean
hourly
wage
for
File
Clerks
(
SOC
Code
43­
4071),
including
50
percent
for
overhead
and
fringe
benefits
and
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index,
is
$
18.42.

10
(
5)
Recordkeeping
requirements:

Burden
estimates
for
recordkeeping
are
based
on
an
incremental
level
of
effort
to
comply
with
BMP
requirements
consisting
of
two
to
four
hours
per
month
for
the
operators/
shift
supervisors
over
current
shift
log
recordkeeping
(
at
$
32.81per
hour),
two
to
four
hours
per
months
for
mill
engineers
(
at
$
64.58
per
hour),
and
two
hours
per
month
for
clerical
support
(
at
$
18.42
per
hour).
These
burden
estimates
are
also
included
in
the
annual
estimates
presented
in
Tables
2
and
3
.3
(
6)
NPDES
permit
provisions,
pretreatment
conditions
and
periodic
review
The
initial
burden
to
State
NPDES
permitting
and
pretreatment
control
authorities
for
preparation
of
NPDES
permit
provisions
and
pretreatment
conditions
for
implementing
the
BMP
regulation
was
already
accounted
for
in
the
new
ICR.
Therefore,
this
burden
is
not
included
in
this
renewal
ICR.
For
the
82
facilities
located
in
states
with
NPDES
authority
and
the
10
facilities
located
in
pretreatment
control
authorities
EPA
estimates
an
incremental
ten
hours
per
year
per
facility
for
reviewing
periodic
(
e.
g.,
annual
or
semi­
annual)
monitoring
reports
and
conducting
compliance
reviews.

Estimates
for
Federal
and
State
labor
rates
were
based
on
the
2003
US
Labor
department
figures
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index,
whereby
the
average
annual
salary
for
Federal
and
State
employees
is
$
47,112;
this
is
equivalent
to
the
salary
of
a
GS­
9,
Step
10
Federal
employee.
At
2,080
available
labor
hours
per
year,
the
hourly
rate
is
$
22.65.
Overhead
costs
for
Federal
and
State
employees
are
estimated
by
EPA
to
be
60
percent
(
EPA
ICR
Handbook),
or
$
13.59
per
hour,
which
results
in
a
total
hourly
rate
of
$
36.24
($
22.65
+
$
13.59).

Estimates
for
local
pretreatment
control
authority
employees
(
i.
e.,
POTW
employees)
were
based
on
the
2002
US
Labor
department
figures
for
the
wages
and
salaries
value
for
State
and
local
government
workers
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index
plus
a
50
percent
overhead
burden;
this
is
equivalent
to
an
hourly
rate
of
$
33.36
($
22.24
+
$
11.12).

Table
1.
Summary
of
Mill
Status
CATEGORY
Simple
Moderately
Complex
Complex
Total
Kraft
&
Soda
41
30
13
84
Sulfite
10
0
0
10
Total
Mills
51
30
13
94
Best
Management
Practices
ICR
11
11
Table
2.
Mill
Labor
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Recordkeeping
and
Training
(
hours)

Item
Kraft
&
Soda
Sulfite
TOTAL
HOURS
Simple
Moderately
Complex
Complex
Total
Simple
Total
Amendment
and
Review
of
BMP
Plan
820
600
260
1,680
200
200
1880
Reporting
of
Spills
1,968
1,440
624
4,032
480
480
4512
Additional
Monitoring
and
Reporting
16,277
11,910
5,161
33,348
3,970
3,970
37318
Recordkeeping
2,952
2,880
1,560
7,392
720
720
8112
Refresher
Training
3,280
2,400
1,040
6,720
800
800
7520
TOTAL
25,297
19,230
8,645
53,172
6,170
6,170
59,342
Table
3.
Mill
Costs
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Recordkeeping
and
Training
Item
Kraft
&
Soda
Sulfite
TOTAL
COSTS
Simple
Moderately
Complex
Complex
Total
Simple
Total
Amendment
and
Review
of
BMP
Plan
$
54,916
$
40,183
$
17,412
$
112,511
$
13,394
$
13,394
$
125,905
Reporting
of
Spills
$
127,093
$
92,995
$
40,298
$
260,387
$
30,998
$
30,998
$
291,385
Additional
Monitoring
and
Reporting
$
579,652
$
424,136
$
183,792
$
1,187,579
$
141,379
$
141,379
$
1,328,958
Recordkeeping
$
113,957
$
118,444
$
66,518
$
298,919
$
27,794
$
27,794
$
326,713
Refresher
Training
$
118,037
$
86,369
$
37,426
$
241,833
$
28,790
$
28,790
$
270,623
TOTAL
$
993,655
$
762,127
$
345,446
$
2,101,229
$
242,355
$
242,355
$
2,343,584
Table
4.
Recurring
Mill
Respondent
Burden
and
Costs
Status
Total
Labor
Hours
Total
Recurring
Costs
Kraft
&
Soda
Simple
25,297
$
993,655
Moderately
Complex
19,230
$
762,127
Complex
8,645
$
345,446
Total
Kraft
&
Soda
53,172
$
2,101,229
Sulfite
Simple
6,170
$
242,355
Total
Sulfite
6,170
$
242,355
TOTAL
MILLS
59,342
$
2,343,584
6(
b)
Estimating
Agency
Burden
The
initial
burden
to
EPA
from
non­
authorized
State
NPDES
permitting
and
pretreatment
control
authorities
for
preparation
of
NPDES
permit
provisions
and
pretreatment
conditions
for
implementing
the
BMP
regulation
was
already
accounted
for
in
the
new
ICR.
Therefore,
this
Best
Management
Practices
ICR
12
12
burden
is
not
included
in
this
renewal
ICR.
For
the
2
facilities
located
in
states
without
NPDES
authority
EPA
estimates
an
incremental
ten
hours
per
year
per
facility
for
reviewing
periodic
(
e.
g.,
annual
or
semi­
annual)
monitoring
reports
and
conducting
compliance
reviews,
for
a
total
of
20
hours
annually.

EPA
estimates
an
incremental
labor
burden
of
approximately
eight
hours
per
facility
for
a
total
of
752
hours
annually.
This
burden
accounts
for
anticipated
support
of
State
and
local
authority
efforts
described
in
Section
6(
a).
The
estimated
incremental
labor
burden
for
the
BMP
regulation
is
772
(
752
+
20)
hours.
Using
the
hourly
labor
rate
of
$
36.24
(
see
Section
6(
a)(
6)),
recurring
Agency
costs
are
estimated
at
$
27,977.
A
summary
of
the
Agency
burden
hours
and
costs
is
presented
in
Table
5.

Table
5.
Summary
of
Burden
and
Costs
to
Respondents
and
EPA
Category
Total
Labor
Hours
Total
Costs
Respondents
­
Annual
Burden
Kraft
&
Soda
Mills
Sulfite
Mills
Total
53,172
6,170
59,342
$
2,101,229
$
242,355
$
2,343,584
States
&
Local
Governments
Annual
Burden
States
Local
Governments
(
pretreatment)
820
100
$
29,717
$
3,336
EPA
Annual
Burden
772
$
27,977
6(
c)
Bottom
Line
Burden
and
Costs
Tables
The
bottom
line
burden
hours
and
cost
tables
for
respondents
are
the
summaries
of
all
the
hours
and
costs
incurred
for
all
activities.
There
are
no
Operating
and
Maintenance
costs
associated
with
this
Information
Collection
Request.

(
1)
Respondent
Tally
The
bottom
line
respondent
(
mills,
State
permitting
and
local
pretreatment
authorities)
tally
is
presented
in
Table
6.

Table
6.
Total
Estimated
Respondent
Burden
and
Cost
Summary
(
2004
Dollars)

Category
Number
of
Respondents
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Respondents
­
Subpart
B
and
E
mills
94
59,342
$
2,343,584
Respondents
­
State
Athorities
24
820
$
29,717
Respondents
­
Local
authorities
10
100
$
3,336
Total
Respondents
128
60,262
$
2,376,637
Best
Management
Practices
ICR
13
13
(
2)
Agency
Tally
The
bottom
line
Agency
tally
is
presented
in
Table
7.

Table
7.
Total
Estimated
Agency
Burden
and
Cost
Summary
(
2000
Dollars)

Category
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Agency
772
$
27,977
6(
d)
Reasons
for
Changes
in
Burden
As
this
is
a
renewal
information
collection,
the
change
in
burden
for
this
collection
includes
adjusting
from
2000
to
2004
dollars
and
account
for
new
NPDES
authorized
states.

6(
e)
Burden
Statement
The
recurring
burden
for
a
mill
to
periodically
review
and
amend
the
BMP
plan,
prepare
spill
reports,
perform
additional
monitoring,
hold
refresher
training,
and
conduct
recordkeeping
and
reporting
is
estimated
to
be
617,
641
and
665
hours
annually
per
mill
for
simple,
moderately
complex
and
complex
mills,
respectively.
The
total
recurring
cost
for
mills
associated
with
the
BMP
requirements
is
estimated
at
$
2,343,811
The
recurring
burden
to
State
NPDES
and
pretreatment
control
authorities
is
estimated
at
ten
hours
per
year
per
facility
for
reviewing
periodic
(
e.
g.,
annual
or
semi­
annual)
monitoring
reports
and
conducting
compliance
reviews.
The
total
recurring
costs
for
State
NPDES
and
pretreatment
control
authorities
is
estimated
at
$
29,716
and
$
3,336
respectively.

The
recurring
burden
to
EPA
is
estimated
at
ten
hours
per
year
per
facility
in
non
NPDES
authorized
states
and
eight
hours
per
year
per
facility
for
support
of
State
and
local
authority
efforts
in
reviewing
periodic
(
e.
g.,
annual
or
semi­
annual)
monitoring
reports
and
conducting
compliance
reviews.
The
total
recurring
costs
for
EPA
is
estimated
at
$
27,977.

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.
Best
Management
Practices
ICR
14
14
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2004­
0023,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2004­
0023)
and
OMB
control
number
(
2040­
0207)
in
any
correspondence.
