MILESTONES
PLANS
EFFLUENT
LIMITATIONS
GUIDELINES
AND
STANDARDS
BLEACHED
PAPERGRADE
KRAFT
AND
SODA
SUBCATEGORY
PULP,
PAPER,
AND
PAPERBOARD
MANUFACTURING
CATEGORY
(
40
CFR
PART
430)
(
Renewal)

EPA
ICR
#
1877.03
OMB
Control
Number
2040­
0202
June
2005
U.
S.
Environmental
Protection
Agency
Office
of
Water
Office
of
Wastewater
Management
1200
Pennsylvania
Avenue,
NW
Washington,
D.
C.
20460
ii
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
.........................
1
1(
a).
Title
of
the
Information
Collection
..............................................................
1
1(
b).
Short
Characterization/
Abstract
..................................................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
................................................
2
2(
a).
Need/
Authority
for
the
Collection
...............................................................
2
2(
b).
Practical
Utility/
Users
of
the
Data
...............................................................
2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
.............................................................................................................
3
3(
a).
Nonduplication
.............................................................................................
3
3(
b).
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
..........................
3
3(
c).
Consultations
................................................................................................
3
3(
d).
Effects
of
Less
Frequent
Collection
.............................................................
3
3(
e).
General
Guidelines
.......................................................................................
3
3(
f).
Confidentiality
..............................................................................................
3
3(
g).
Sensitive
Questions
......................................................................................
4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
...................
4
4(
a).
Respondents/
SIC
Codes
...............................................................................
4
4(
b).
Information
Requested
.................................................................................
4
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
...........................
5
5(
a).
Agency
Activities
..........................................................................................
5
5(
b).
Collection
Methodology
and
Management
...................................................
6
5(
c).
Small
Entity
Flexibility
.................................................................................
6
5(
d).
Collection
Schedule
......................................................................................
6
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
...............
6
6(
a).
Estimating
Respondent
Burden
....................................................................
6
6(
b).
Estimating
Respondent
Costs
......................................................................
8
6(
c).
Estimating
Agency
Burden
and
Costs
.........................................................
9
6(
d).
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
...............
10
6(
e).
Bottom
Line
Burden
Hours
and
Cost
Tables
...............................................
11
6(
f).
Reasons
for
Change
in
Burden
.....................................................................
12
6(
g).
Burden
Statement
.........................................................................................
12
iii
LIST
OF
TABLES
Table
1
Summary
of
Estimated
Industry
Respondent
Burden
............................
7
Table
2
Breakdown
Estimate
of
Hours/
Mill
.......................................................
8
Table
3
Summary
of
Estimated
Industry
Respondent
Costs
...............................
9
Table
4
Total
Industry
Respondent
Burden
and
Cost
.........................................
11
Table
5
Bottom
Line
Burden
and
Costs
Based
on
29
Mills
in
2000
Dollars
...................................................................
12
Table
6
Bottom
Line
Burden
and
Costs
(
annualized)............................................
12
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a).
Title
of
the
Information
Collection
ICR:
Milestones
Plans
of
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Manufacturing
Category
(
40
CFR
Part
430)
(
EPA
ICR
No.
1877.03)

1(
b).
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
presents
estimates
of
the
burden
and
costs
to
the
eligible
community
(
direct
discharging
bleached
papergrade
kraft
and
soda
mills)
and
NPDES
permitting
authorities
for
activities
associated
with
the
development
of
a
Milestones
Plan,
which
is
required
as
part
of
a
Voluntary
Advanced
Technology
Incentives
Program
(
VATIP)
established
under
the
Pulp,
Paper,
and
Paperboard
Effluent
Limitations
Guidelines
and
Standards
(
40
CFR
Part
430)
portion
of
the
Cluster
Rule
promulgated
on
April
15,
1998.
The
Milestones
Plan
is
required
only
of
those
mills
that
voluntarily
choose
to
enroll
in
the
incentives
program.
This
is
a
renewal
ICR.

The
VATIP
(
40
CFR
430.24(
b))
is
intended
to
encourage
existing
and
new
direct
discharging
mills
to
move
beyond
today's
baseline
BAT
and
NSPS
technologies
toward
the
"
mill
of
the
future,"
which
EPA
believes
will
have
a
minimum
impact
on
the
environment.
In
order
to
facilitate
achievement
of
the
ultimate
effluent
limitations
required
by
this
Incentives
Program,
existing
mills
that
choose
to
enroll
in
this
voluntary
program
are
required
to
submit
plans
(
referred
to
as
"
Milestones
Plans")
detailing
the
strategy
the
mill
will
follow
to
develop
and
implement
the
technologies
or
processes
it
intends
to
use
to
achieve
the
requirements
of
the
program.
See
40
CFR
430.24(
c).
New
sources
enrolling
in
the
Incentives
Program
are
not
required
to
develop
Milestones
Plans
because
they
must
achieve
the
ultimate
VATIP
standards
as
soon
as
they
commence
discharge.

The
purpose
of
the
Milestones
Plan
is
to
provide
information
necessary
for
the
development
of
interim
limitations
or
permit
conditions
under
40
CFR
430.24(
b)(
2)
that
lead
to
achievement
of
the
Voluntary
Advanced
Technology
BAT
limitations
codified
at
40
CFR
430.24(
b)(
3)
and
(
4).
Each
Milestones
Plan
must
be
developed
by
the
participating
mill
and
submitted
to
the
NPDES
permitting
authority
(
i.
e.,
EPA
or
the
State,
if
it
is
authorized
to
administer
the
NPDES
permitting
program).
EPA
expects
the
permitting
authority
to
use
the
information
contained
in
the
Milestones
Plan
to
establish
enforceable
permit
limitations
and
conditions
for
the
participating
mill.
These
milestones
would
also
provide
valuable
benchmarks
for
reasonable
inquiries
into
progress
being
made
by
participating
mills
toward
achievement
of
the
interim
and
ultimate
effluent
limitations.
EPA's
legal
authority
to
require
such
Milestones
Plans
in
effluent
limitations
guidelines
and
standards
is
found
in
Section
308(
a)
of
the
Clean
Water
Act
2
(
CWA).
For
additional
information
on
the
VATIP,
see
the
Technical
Support
Document
for
the
Voluntary
Advanced
Incentives
Program
(
EPA­
821­
R­
97­
014;
DCN
14488).

For
the
regulated
community,
the
burden
and
costs
of
the
Milestones
Plan
are
those
associated
with
its
development.
For
the
government,
the
burden
and
costs
are
those
sustained
by
the
NPDES
permitting
authority
and
EPA
in
reviewing
the
Milestones
Plan,
deriving
and
enforcing
interim
permit
requirements
and
generally
tracking
the
mill's
implementation
of
the
Milestones
Plan.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a).
Need/
Authority
for
the
Collection
The
Incentives
Program
requires
achievement
of
ultimate
effluent
limitations
that
go
beyond
the
baseline
BAT
limitations.
Mills
that
choose
to
enroll
in
the
program
are
given
additional
time
to
achieve
those
ultimate
effluent
limitations.
During
this
additional
time
period
during
which
the
mill
is
preparing
to
meet
the
ultimate
limitations,
the
regulation
requires
participating
mills
to
meet
interim
limitations
or
permit
conditions.
See
40
CFR
430.24(
b)(
2).
In
order
to
determine
interim
limitations
or
permit
conditions
that
will
take
into
account
the
special
circumstances
at
each
mill
while
at
the
same
time
promote
timely
achievement
by
the
mill
of
the
ultimate
limitations,
the
permitting
authority
needs
to
know
the
details
of
how
the
mill
is
planning
to
develop
and
implement
the
technologies
and
processes
to
achieve
the
ultimate
limitations.
The
Milestones
Plan,
prepared
by
the
mill,
will
provide
this
information.
Even
when
not
used
as
the
basis
for
enforceable
permit
conditions,
the
Milestones
Plan
will
also
provide
valuable
benchmarks
for
reasonable
inquiries
into
progress
being
made
toward
achievement
of
the
ultimate
limitations
and
will
help
ensure
that
mills
enrolled
in
the
program
are
making
a
good­
faith
effort
to
fulfill
the
requirements
of
the
program.

EPA's
legal
authority
to
require
Milestones
Plans
for
meeting
effluent
limitations
is
found
in
Section
308(
a)
of
the
Clean
Water
Act.
Section
308(
a)
gives
the
EPA
Administrator
the
authority
to
require
the
owner
or
operator
of
any
point
source
(
e.
g.,
a
pulp
and
paper
mill)
to
make
reports
or
provide
such
other
information
that
the
Administrator
determines
is
necessary
to
(
1)
develop
any
effluent
limitation
or
other
limitation
under
the
Act,
(
2)
determine
compliance
with
effluent
limitations,
or
(
3)
carry
out
the
NPDES
permit
program.
The
Milestones
Plan
fits
all
three
criteria
for
the
reasons
set
forth
in
paragraph
2(
b)
below.

2(
b).
Practical
Utility/
Users
of
the
Data
The
Milestones
Plan
will
assist
the
permitting
authority
(
i.
e.,
the
State
or
EPA)
to
set
appropriate
interim
limitations
and
permit
conditions
for
that
interim
period
when
the
mill
is
preparing
to
achieve
the
ultimate
limitations.
An
individualized
Milestones
Plan
will
make
it
easier
for
the
permitting
authority
to
account
for
any
unique
situations
at
the
mill
and
to
provide
appropriate
flexibility
for
the
mill.
3
The
Milestones
Plan
will
also
enable
the
permitting
authority
to
track
the
progress
being
made
by
the
mill
to
achieve
the
interim
and
ultimate
effluent
limitations
and
to
enable
the
permitting
authority
to
recognize
if
and
when
a
mill
is
not
making
expected
progress
toward
fulfilling
the
requirements
of
the
program
and
take
appropriate
action.
By
advancing
these
purposes,
the
Milestones
Plan
thus
helps
to
carry
out
the
NPDES
permit
program.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a).
Nonduplication
The
information
in
the
Milestones
Plan
is
necessarily
mill­
specific
and,
to
EPA's
knowledge
has
never
been
collected
by
another
source.
Therefore,
none
of
the
information
to
be
collected
by
the
Milestones
Plan
is
available
elsewhere.
Moreover,
although
EPA
expects
that
many
participating
mills
will
already
be
developing
such
plans
for
their
own
planning
purposes,
the
permitting
authority
would
have
no
access
to
this
information
without
this
information
collection
request.

3(
b).
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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
has
discussed
this
information
collection
with
the
State
NPDES
permitting
authorities.

3(
d).
Effects
of
less
Frequent
Collection
Since
the
Milestones
Plan
is
a
one­
time
information
collection
and
not
a
collection
with
periodic
reporting,
consideration
of
the
effects
of
less
frequent
collection
is
not
relevant.

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
received
two
comments
on
the
proposed
Milestones
Plan
regulation
(
63
FR
18796,
April
15,
1998)
indicating
that
a
mill
may
wish
to
claim
as
CBI
the
technologies
or
processes
by
4
which
it
intends
to
achieve
the
ultimate
VATIP
limitations.
Therefore,
EPA
promulgated
language
in
the
final
rule
to
provide
that,
in
those
situations,
a
mill
may
claim
that
portion
of
the
Milestones
Plan
as
confidential
(
64
FR
36582,
July
7,
1999).
Such
claims
are
handled
pursuant
to
40
CFR
Part
2
when
EPA
is
the
permitting
authority
and
applicable
State
rules
and
regulations
governing
CBI
when
States
are
the
permitting
authorities.
EPA
also
added
language
to
the
final
regulations
that
requires
mills
asserting
a
CBI
claim
to
prepare
a
public
summary
of
the
confidential
portion
of
the
plan
and
to
submit
that
summary
to
the
permitting
authority
along
with
the
Milestones
Plan.
This
requirement
allows
the
public,
on
request,
to
obtain
information
about
the
mill's
progress
in
achieving
its
VATIP
limitations.

3(
g)
Sensitive
Questions
No
sensitive
questions
are
anticipated
in
this
information
collection.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes
The
respondents
will
be
those
existing,
direct­
discharging
bleached
papergrade
kraft
and
soda
pulp
and
paper
mills
that
have
chosen
to
enroll
in
the
VATIP.
The
SIC
code
associated
with
these
potential
respondents
is
2611
(
pulp
mills).
The
associated
NAICS
code
is
322110.

4(
b).
Information
Requested
An
existing
mill
choosing
to
enroll
in
the
VATIP
must
submit
a
Milestones
Plan.

(
i)
Data
items:

°
A
Milestones
Plan
required
under
40
CFR
430.24(
c).

­­
The
Milestones
Plan
must
describe
each
anticipated
new
technology
component
or
process
modification
the
mill
intends
to
implement
in
order
to
achieve
the
ultimate
effluent
limitations
(
i.
e.,
the
Voluntary
Advanced
Technology
BAT
limits).
This
information
is
required
under
40
CFR
430.24(
c)(
1)
(
see
DCN
14488).

­­
In
addition,
the
Milestones
Plan
must
include
a
master
schedule
(
1)
showing
the
sequence
of
implementing
the
new
technology
components
or
process
modifications
and
(
2)
identifying
critical
path
relationships.
This
information
is
required
under
40
CFR
430.24(
c)(
2).
5
­­
For
each
individual
new
technology
component
or
process
modification,
the
Milestones
Plan
must
include
a
schedule
that
identifies
the
anticipated
dates
when
associated
construction,
installation,
and
operational
"
shakedown"
will
be
initiated,
the
anticipated
dates
those
steps
will
be
completed,
and
the
anticipated
date
that
the
full
Advanced
Technology
process
or
individual
component
will
be
fully
demonstrated
as
operational.
EPA
also
intends
that
the
Milestones
Plan
describe
the
anticipated
improvements
in
effluent
quality
and
reductions
in
effluent
quantity
as
measured
at
the
bleach
plant
and
at
the
end
of
the
pipe.
­­
The
schedule
must
also
identify
the
anticipated
dates
of
initiation
and
completion
of
associated
research,
process
development
and
mill
trials
when
applicable,
i.
e.,
when
the
mill
intends
to
employ
technologies
or
process
modifications
that
are
not
commercially
available
or
demonstrated
on
a
full­
scale
basis
at
the
time
the
Milestones
Plan
is
developed.
This
"
R&
D
Schedule,"
which
should
be
part
of
the
Master
Schedule,
should
show
major
milestone
dates
and
the
anticipated
date
the
technology
or
process
change
will
be
available
for
mill
implementation.
This
information
is
required
under
40
CFR
430.24
(
c)(
3)(
i).

­­
The
Milestones
Plan
must
also
include
contingency
plans
in
the
event
that
any
of
the
technologies
or
processes
need
to
be
adjusted
or
alternative
approaches
developed
to
ensure
that
the
ultimate
effluent
limitations
are
achieved
by
deadlines
specified
in
40
CFR
430.24(
b)(
4)(
ii).
This
information
is
required
under
40
CFR
430.24(
c)(
3)(
iii).

(
ii)
Respondent
Activities:

°
Preparation
of
the
Milestones
Plan,
containing
the
information
described
above.

°
Signature
by
the
responsible
corporate
officer
as
defines
by
40
CFR
122.22,
and
submittal
of
the
Milestones
Plan
to
the
permitting
authority.
These
activities
are
required
by
40
CFR
430.24(
c)
and
(
c)(
4).

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a).
AGENCY
ACTIVITIES
Agency
(
i.
e.,
permitting
authority)
activities
associated
with
the
Milestones
Plans
consist
of
6
the
following:

°
Review
Milestones
Plans
for
completeness.

°
Consider
the
information
in
those
plans
when
establishing
enforceable
interim
effluent
limitations
and
permit
conditions
that
facilitate
the
achievement
of
the
ultimate
effluent
limitations;
include
reopener
clauses
to
allow
the
permitting
authority
to
adjust
the
permits
to
reflect
the
results
of
research,
process
development,
mill
trials,
and
possible
contingencies.

°
Monitor
progress
of
the
participating
mills
toward
achieving
the
ultimate
effluent
limitations,
using
the
milestones
in
the
Milestones
Plan
as
benchmarks.
Take
appropriate
action
if
and
when
progress
falters.

5(
b).
COLLECTION
METHODOLOGY
AND
MANAGEMENT
After
having
enrolled
in
the
VATIP,
a
particular
mill
is
required
to
submit
the
Milestones
Plan
to
the
permitting
authority,
which
would
consider
the
Plan
as
described
in
5(
a).
The
Milestones
Plan
is
intended
to
be
a
dynamic
document
that
will
be
adjusted
to
reflect
the
results
of
research,
process
development,
mill
trials,
etc.
EPA
expects
the
Plan
to
be
maintained
on
file
by
the
mill
and
the
permitting
authority.
Public
access
will
be
managed
through
standard
procedures
under
the
codified
authorities
(
see
3(
f)
above).

5(
c).
SMALL
ENTITY
FLEXIBILITY
EPA
considered
less
burdensome
information
collection
mechanisms
for
small
entities,
but
chose
not
to
alter
the
collection
procedure
for
the
following
reasons:

°
This
information
collection
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
EPA
has
determined
that,
of
all
the
pulp
and
paper
mills
that
are
eligible
for
the
VATIP
only
three
mills
are
small
businesses,
and
EPA
does
not
believe
this
is
a
substantial
number
as
that
term
is
used
in
EPA's
Regulatory
Flexibility
Analysis
for
the
Final
Pulp
and
Paper
Cluster
Rules.
(
See
the
Economic
Analysis,
DCN
14649).

°
Moreover,
these
three
mills
will
be
subject
to
the
information
collection
only
if
they
choose
to
enroll
in
the
VATIP.

°
Finally,
the
cost
of
this
information
collection
to
any
small
entity
choosing
to
enroll
in
the
VATIP
is
not
substantial.
EPA
has
calculated
the
cost
to
be
between
$
4,000
and
$
24,000
per
mill.

5(
d).
COLLECTION
SCHEDULE
7
This
is
a
one­
time
information
collection.
The
participating
mill
must
submit
the
Milestones
Plan
by
the
date
the
mill
applies
for
its
NPDES
permit
limitations.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a).
ESTIMATING
RESPONDENT
BURDEN
The
respondent
burden
of
this
information
collection
has
been
estimated
by
calculating
the
labor
requirements
(
in
hours)
of
preparing
typical
Milestones
Plans
for
each
of
the
three
possible
technology
tiers
in
the
VATIP.
The
labor
estimates
assume
that
the
Milestones
Plans
will
be
prepared
by
mill
or
corporate
process
engineering
staff,
with
senior
management
input.
These
burden
estimates
cover
the
total
time
and
effort
expended
by
persons
to
generate,
maintain,
retain,
and
disclose
or
provide
the
information
collection.
This
includes
the
time
needed
to
review
regulations
and
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
or
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

Additionally,
for
Tiers
II
and
III
plan
development,
a
budget
is
included
to
perform
scoping
studies
to
determine
implementation
at
the
mills.
The
estimates
do
not
reflect
the
cost
of
detailed
engineering
studies
or
feasibility
studies
that
a
company
may
perform
when
investigating
whether
to
pursue
the
development
and
installation
of
advanced
technology,
nor
do
the
estimates
include
the
labor
hours
related
to
internal
corporate
discussions
about
a
decision
to
enroll
in
the
incentives
program.
Such
activities
are
considered
part
of
the
corporate
strategic
planning
function
and
are
not
considered
part
of
the
burden
associated
with
the
Milestones
Plan.

The
labor
estimates
are
based
on
the
anticipated
level
of
complexity
for
each
of
the
tiers.
The
estimates
reflect
the
greater
complexity
of
higher
tiers
and
were
prepared
by
an
EPA
contractor
with
much
experience
preparing
plans
and
schedules
for
projects
with
similar
complexities.
The
estimate
for
a
Tier
I
Milestones
Plan
assumes
the
mill
will
implement
readily
available
technology
(
e.
g.,
oxygen
delignification
and
100
percent
chlorine
dioxide
substitution)
and
will
not
perform
research
and
development
(
R
&
D)
activities.
The
estimate
for
a
Tier
II
Milestones
Plan
assumes
the
mill
will
conduct
one
research
and
development
project
related
to
condensate
reuse,
but
otherwise
will
implement
readily
available
technology
(
e.
g.,
a
two­
stage
oxygen
delignification
system
followed
by
ozone
bleaching
and
100
percent
chlorine
dioxide
substitution).
Additionally,
the
burden
estimate
for
R
&
D
scheduling
only
includes
the
cost
of
producing
a
schedule
for
this
project.
The
estimate
for
a
Tier
III
Milestones
Plan
assumes
the
mill
will
conduct
six
research
and
development
projects
designed
to
upgrade
condensate
quality
from
evaporators,
to
improve
treatment
of
condensates,
to
provide
advanced
process
control,
to
optimize
water
balance
strategies
to
achieve
nearly
closed
loop
processing,
and
to
remove
minerals
and/
or
chloride;
the
burden
estimate
for
R
&
D
scheduling
only
includes
the
cost
of
producing
a
schedule
for
this
project.
The
following
tables
summarize
the
estimated
industry
respondent
8
burden:

Table
1
Summary
of
Estimated
Industry
Respondent
Burden
Technology
Tier
Hours
/
Mill
Tier
I
56
Tier
II
154
Tier
III
328
Table
2
Breakdown
Estimate
of
Hours
/
Mill
Milestones
Plan
Element
Tier
I
Hours
(
X
+
Y)
a
Tier
II
Hours
(
X
+
Y)
a
Tier
III
Hours
(
X
+
Y)
a
Overview
of
Strategy
12
+
4
20
+
8
24
+
8
Description
of
New
Technology
Components
or
Process
Modifications
10
+
2
20
+
4
32
+
8
Master
Schedule
20
+
4
46
+
8
64
+
16
R
&
D
Schedule
­­­­
24
+
8
112
+
40
Appendix
of
Documentationb
4
+
0
16
+
0
24
+
0
Subtotal
Hours
46
+
10
126
+
28
256
+
72
Total
Hours
56
154
328
a
X
=
process
engineering
hours
Y
=
senior
management
hours
b
Tier
I:
Includes
vendor
documentation
or
preliminary
engineering
studies.
Tier
II:
Includes
the
above
(
for
Tier
I)
plus
feasibility
studies,
research
proposals
and
reports,
and
review
of
literature
on
minimum
effluent
technology.
Tier
III:
Includes
the
above
(
for
Tier
II)
plus
review
of
literature
on
closed­
cycle
1Estimates
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.
The
mean
hourly
wage
for
engineers,
including
50
percent
for
overhead
and
fringe
benefits
and
adjusted
to
January
2004
dollars
with
the
Employment
Cost
Index,
is
$
45.64.

9
technology.

6(
b).
ESTIMATING
RESPONDENT
COSTS
The
respondent
costs
of
this
information
collection
have
been
estimated
by
taking
the
labor
hours
(
in
Table
2
above)
and
multiplying
them
by
the
appropriate
wage
rates
applicable
to
process
engineering
time
and
senior
management
time.
EPA
estimates
an
average
hourly
cost
(
labor
plus
overhead)
of
$
45.64
for
process
engineering
time
and
$
88.49
for
senior
management
time1.
(
There
are
no
capital
costs
or
O&
M
costs
associated
with
this
information
collection.)

The
following
Table
3
summarizes
the
estimated
industry
respondent
costs
based
on
labor
effort:

Table
3
Summary
of
Estimated
Industry
Respondent
Costs
Technology
Tier
Engineering
Hours
/
Mill
Management
Hours
/
Mill
Costs
/
Milla
Tier
I
46
10
$
3,000
Tier
II
126
28
$
8,272
Tier
III
256
72
$
18,141
aAssumes
$
45.64
and
$
88.49
per
hour
for
process
engineering
time
and
senior
management
time,
respectively
(
labor
plus
overhead).

Additionally,
for
Tiers
II
and
III,
an
allowance
for
scoping
studies
was
included.
For
Tier
II,
EPA
estimated
approximately
$
14,000
for
each
scoping
study,
which
may
be
performed
by
a
consultant.
A
scoping
study
estimate
of
$
26,000
was
applied
to
Tier
III.
The
extended
costs,
including
labor
and
the
scoping
study
estimate,
are
reflected
in
Table
4.

6(
c).
ESTIMATING
AGENCY
BURDEN
AND
COSTS
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,
10
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).

EPA
estimates
the
initial
burden
to
State
and
local
NPDES
permitting
authorities
for
the
review
of
the
Milestones
Plan
to
be
an
average
of
16
hours
per
mill
respondent.
With
29
mills
anticipated
to
enter
the
program
(
see
Section
6(
d)
below),
the
total
initial
State
NPDES
permitting
authority
burden
is
estimated
at
464
hours.
Based
on
the
Federal
and
State
labor
rates,
total
initial
labor
costs
are
estimated
at
$
16,815
for
State
permitting
authorities.
It
is
anticipated
that
no
one
State
permitting
authority
will
incur
the
entire
burden,
because
anticipated
mill
respondents
are
located
in
different
States.
There
exists
no
more
than
four
anticipated
mill
respondents
in
any
one
State.
Therefore,
the
maximum
initial
burden
that
any
one
State
permitting
authority
is
64
hours
for
a
cost
of
$
2,319.

EPA
estimates
the
recurring
burden
to
State
permitting
authorities
to
be
an
average
of
6
hours
per
year
per
mill
for
periodic
review
of
the
mill's
progress
in
implementation
of
the
Milestones
Plan
and
to
take
appropriate
action
if
and
when
progress
falters
(
see
section
5(
a)
above).
The
total
recurring
burden
for
State
permitting
authorities
is
estimated
at
174
hours
per
year
at
a
total
cost
of
$
6,305.
The
maximum
recurring
burden
any
one
State
permitting
authority
could
incur
is
24
hours
per
year
at
a
cost
of
$
870.
This
maximum
burden
represents
no
more
than
14%
of
the
total
estimated
recurring
burden.

The
initial
Agency
burden
is
estimated
to
be
an
average
of
20
hours
per
mill
respondent.
With
29
mills
anticipated
to
enter
the
program
(
see
Section
6(
d)
below),
the
total
initial
Agency
burden
is
estimated
at
580
hours.
Based
on
the
Federal
and
State
labor
rates,
total
initial
labor
costs
are
estimated
at
$
21,019
for
the
Agency.
EPA
estimates
recurring
burden
to
the
Agency
to
be
an
average
additional
4
hours
per
year
per
mill
respondent
for
support
of
State
and
local
NPDES
permitting
authorities.
The
total
recurring
burden
for
the
Agency
is
estimated
at
116
hours
per
year
at
a
total
cost
of
$
4,204.

6(
d).
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COST
As
discussed
previously,
EPA
estimates
the
potential
respondent
universe
(
i.
e.,
the
mills
likely
to
enroll
in
the
incentives
program)
to
be
29
mills.
The
estimates
of
how
many
mills
are
likely
to
enroll
in
the
incentives
program
for
each
of
the
three
tiers
are
based
on
the
following:

°
There
are
16
mills
that
already
have
technology
in
place
that
is
comparable
to
that
specified
as
the
model
technology
required
for
Tier
I
or
have
a
corporate
commitment
to
install
the
technology.
Two
of
those
16
mills,
however,
are
projected
to
go
to
Tier
III
(
see
below).
Therefore,
the
EPA
estimate
of
how
many
mills
are
likely
to
enroll
for
Tier
I
is
14.

°
EPA's
projection
on
how
many
mills
are
likely
to
enroll
for
Tier
II
is
based
on
the
11
assumption
that
mills
with
over
400
kkg/
day
softwood
production
and
with
technology
using
minimal
chlorine
dioxide
substitution
are
likely
candidates
to
adopt
Tier
II
technology.
There
are
12
mills
that
meet
these
criteria.
One
existing
totally
chlorine
free
kraft
mill
is
also
projected
to
enroll
for
Tier
II,
making
a
total
of
13
mills
projected
to
enroll
for
Tier
II.

°
There
are
two
mills
operated
by
a
company
developing
technology
to
recycle
bleach
plant
filtrate.
These
two
mills
are
projected
to
enroll
for
Tier
III.

The
result
is
that
29
mills
are
projected
to
enroll
in
the
incentives
program
­­
14
for
Tier
I,
13
for
Tier
II,
and
2
for
Tier
III.

Total
respondent
burden
and
cost
are
calculated
by
multiplying
the
hours
per
mill
and
the
costs
per
mill
for
each
technology
tier
by
the
projected
number
of
mills
likely
to
enroll
in
the
incentives
program
at
that
tier.
The
following
Table
4
summarizes
the
total
respondent
burden
and
cost:

Table
4
Total
Industry
Respondent
Burden
and
Cost
Technology
Tier
Hours
/
Mill
Costs
/
Mill
#
of
Enrolled
Mills
Total
Hours
Total
Labor
Costa
Tier
I
56
$
3000
14
784
$
42,000
Tier
II
154
$
22,272
13
2,002
$
289,536
Tier
III
328
$
44,141
2
656
$
88,282
TOTAL
29
3,442
$
419,818
Annualized
1,147
a
Includes
the
cost
of
a
scoping
study
for
each
mill.

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.
There
are
no
associated
Operating
and
Maintenance
or
capital
start
up
costs
associated
with
this
ICR.

(
i)
Respondent
Tally
12
The
bottom
line
respondent
(
mills
and
State
governments)
is
presented
in
Table
5.

(
ii)
The
Agency
Tally
The
bottom
line
Agency
tally
is
also
presented
in
Table
5
Table
5
Bottom
Line
Burden
and
Costs
Based
on
29
Mills
in
2004
Dollars
Category
Year
1
Labor
Hours/
Costs
Year
2
Labor
Hours/
Costs
Year
3
Labor
Hours/
Costsa
3­
year
Total
Burden
Respondents
­
Subpart
B
and
E
mills
3,442
$
419,818
n/
a
n/
a
3,442
hours
Respondents­
State
governments
464
$
16,815
174
$
6,305
174
$
6,305
812
hours
Total
Respondents
Hours
4,254
hours
Agency
580
$
21,019
116
$
4,204
116
$
4,204
812
hours
a
Includes
the
cost
of
a
scoping
study
for
each
mill.

Table
6:
Bottom
Line
Burden
Hour
and
Cost
Table
Annual
Respondent
burden
1,418
hours
Annual
Respondent
Cost
(
O&
M)
0
6(
f).
REASONS
FOR
CHANGE
IN
BURDEN
13
There
is
no
change
in
the
total
estimated
burden
hours
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.

6(
g).
BURDEN
STATEMENT
EPA
estimates
that
29
mills
will
voluntarily
enroll
into
VATIP.
The
burden
for
a
mill
(
which
chooses
to
participate
voluntarily
in
the
incentives
program)
to
prepare
and
submit
a
Milestones
Plan
is
estimated
to
average
approximately
120
hours
per
respondent.
This
is
a
one­
time
burden.
State
NPDES
permitting
authorities
burden
to
review
the
Milestones
Plans
is
estimated
at
16
hours
per
respondent
as
an
initial
burden
with
a
average
recurring
annual
review
burden
of
6
hours
per
respondent.
Agency
burden
to
review
the
Milestones
Plans
is
estimated
at
20
hours
per
respondent
as
an
initial
burden
with
a
average
recurring
annual
review
burden
of
4
hours
per
respondent.
The
total
initial
cost
for
the
29
mills
anticipated
to
enroll
in
the
VATIP
and
thus
be
required
to
develop
a
Milestones
Plan
is
estimated
at
$
419,818.
The
total
initial
burden
incurred
by
State
permitting
authorities
and
EPA
for
review
the
Milestones
Plans
is
estimated
at
$
16,815
and
$
21,019,
respectively.
The
total
recurring
burden
incurred
by
State
permitting
authorities
and
EPA
for
periodic
review
of
the
Milestones
Plans
is
estimated
at
$
6,305
and
$
4,204,
respectively.
There
is
no
recurring
burden
for
mill
respondents
associated
with
this
information
collection.

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.

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
0024,
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,
14
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2004­
0024)
and
OMB
control
number
(
2040­
0202)
in
any
correspondence.
