1 PART A OF THE SUPPORTING STATEMENT 1. Identification of the Information Collection ( a) Title and Number of the Information Collection " Reporting and Recordkeeping Requirements for the National Emissions Standards for Hazardous Air Pollutants ( NESHAP) for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand Alone Semichemical Pulp Mills." This is a new information collection request ( ICR), and a U. S. Environmental Protection Agency ( EPA) tracking number for this ICR has not been assigned.

( b) Short Characterization ( i) Applicability. Respondents are owners and operators of new and existing chemical recovery combustion sources at kraft,

soda, sulfite, and stand alone semichemical pulp mills. Chemical recovery combustion sources are major sources of hazardous air pollutant ( HAP) emissions either by themselves, or because they are located with other major sources of HAP. A major source of HAP is a facility that emits, or has the potential to emit, any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year.

There are currently 114 kraft, 2 soda, 11 sulfite, and 13 stand alone semichemical pulp mills in the United States. Of the 140 facilities that comprise the pulp and paper production source category, 136 are expected to meet the applicability criteria defined in the final rule. No new facilities ( pulp mills) are expected to be constructed in the next 5 years; however,

approximately 20 new recovery furnaces, 20 new smelt dissolving tanks ( SDT's), and 15 new lime kilns are expected to be constructed at existing kraft pulp mills in the next 5 years. In addition, two new semichemical combustion units and no new soda 2 or sulfite combustion sources are expected to be constructed in the next 5 years.

( ii) Chemical recovery combustion sources at kraft, soda,

sulfite, and stand alone semichemical pulp mills. Owners or operators of chemical recovery combustion sources at kraft, soda,

sulfite, and stand alone semichemical pulp mills subject to the rule must install and monitor a specific control system that reduces HAP emissions to the compliance level.

Owners or operators are required to install, operate and maintain a continuous monitoring system ( CMS), either a continuous opacity monitoring system ( COMS) or a continuous parameter monitoring system ( CPMS), to demonstrate compliance with the standards in the final rule.

To ensure compliance with the HAP metal standards, owners or operators of kraft and soda recovery furnaces and lime kilns equipped with electrostatic precipitators ( ESP's) would be required to maintain opacity levels below a specified level.

Owners or operators of sources equipped with control devices other than ESP's would be required to establish control device or process operating parameter ranges that indicate the control device or process is being operated and maintained in accordance with good air pollution control practices. The control device or process operating parameter ranges would be established during the initial performance test or subsequent performance tests.

Owners or operators complying with the gaseous organic HAP standard for new kraft and soda recovery furnaces that use a nondirect contact evaporator ( NDCE) recovery furnace with a dry ESP system are exempt from monitoring requirements for gaseous organic HAP's because the use of this equipment ensures continuous compliance with the standard.

The respondents are subject to the sections of subpart A of 40 CFR part 63 relating to NESHAP. These requirements include those associated with the initial notifications; notifications of 3 performance tests; notifications of COMS/ CPMS performance evaluations; notifications of compliance status, including the results of performance tests; startup, shutdown, and malfunction reports; and semiannual compliance reports.

All reports are to be submitted to the respondent's State or local agency or to the EPA Regional Office, whichever has been delegated enforcement authority by EPA. The information is used to determine whether or not all sources subject to the rule are achieving the standards in the rule.

( iii) Violations of the standard. The rule includes two levels of monitoring. Each monitoring level specifies maximum opacities ( ESP's only) and maximum frequencies with which the opacity or monitored parameters may exceed established levels.

If the maximum exceedance frequencies of the first monitoring level are exceeded, the owner or operator would be required to implement the corrective actions contained in their startup,

shutdown, and malfunction plan to bring the operating parameter or opacity levels back to established levels. Exceedance of the maximum exceedance frequencies of the second monitoring level would constitute a violation of the applicable standard. The purpose of the two level monitoring approach is to prevent a violation from occurring by requiring the owner or operator to correct operating parameter or opacity exceedances before the threat of a violation arises.

If the owner or operator identifies any deviation resulting from a known cause for which no Federally approved or promulgated exemption from an emission limitation or standard applies, the compliance report must include all records that the source is required to maintain that pertain to the periods during which such deviation occurred, as well as the following: the magnitude of each deviation; the reason for each deviation; a description of the corrective action taken for each deviation, including action taken to minimize each deviation and action taken to 4 prevent recurrence; and a copy of all quality assurance activities performed on any element of the monitoring protocol.

( iv) Record retention. Owners or operators of chemical recovery combustion sources at kraft, soda, sulfite, and standalone semichemical pulp mills subject to the rule must maintain a copy of all monitoring data that demonstrate compliance with the applicable standards in the rule. In addition, owners or operators electing to comply with the emission limit or emission reduction requirements as described in the rule must record the average values of equipment operating parameters as specified in § § 63.864 and 63.866 of the rule. Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of a source, or any period during which the monitoring system is inoperative. Those records must be maintained for a minimum of 5 years. At a minimum, the most recent 2 years of data must be retained onsite. The remaining 3 years of data may be retained offsite.

2. Need For and Use of the Collection ( a) Need/ Authority for the Collection The EPA is charged under section 112( d) of the Clean Air Act ( CAA), as amended, to establish emission standards for each category or subcategory of major and area sources of HAP listed for regulation in section 112( b). These standards are applicable to new or existing sources of HAP and will require the maximum degree of emission reduction.

The predominant HAP's emitted from chemical recovery combustion sources at pulp mills include acetaldehyde, benzene,

formaldehyde, hydrochloric acid ( HCl), methanol, methyl ethyl ketone, and toluene. In the Administrator's judgement, the pollutants emitted from pulp and paper production cause or 5 contribute significantly to air pollution that may reasonably be anticipated to endanger public health. Therefore, this source category was listed for regulation under section 112. ( Note:

Chemical recovery combustion sources at pulp mills are a segment of the larger pulp and paper production source category.)

Section 114( a) of the CAA states that the Administrator may require any owner or operator subject to any requirement of the CAA to:

...( A) establish and maintain such records; ( B) make such reports; ( C) install, use, and maintain such monitoring equipment, and use such audit procedures or methods; ( D) sample such emissions ( in accordance with such procedures or methods, as such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); ( E) keep records on control equipment parameters, production variables, or other indirect data when direct monitoring of emissions is impractical; ( F) submit compliance certifications in accordance with section 114( a)( 3); and ( G) provide such other information as the Administrator may reasonably require.

Certain records and reports are necessary to enable the Administrator to identify sources subject to the rule and to ensure that the standards, which are based on maximum achievable control technology ( MACT) for combustion sources at kraft, soda,

sulfite, and stand alone semichemical pulp mills, are being achieved. After the compliance date, all respondents must submit a semiannual ( every 6 months) report of compliance for chemical recovery combustion sources, including the excess emissions and continuous monitoring system report containing the information requested in § 63.867 of the rule. These records and reports are required under the General Provisions of 40 CFR part 63,

subpart A ( as authorized under sections 101, 112, 114, 116, and 301 of the CAA as amended by Pub. L 101 549 [ 42 U. S. C. 7401,

7412, 7414, 7416, 7601]). 6 ( b) Practical Utility/ Users of the Data The information will be used by EPA enforcement personnel to: ( 1) identify new, modified, reconstructed, and existing sources subject to the rule; ( 2) ensure that MACT is being properly applied; and ( 3) ensure that the emission control devices are being properly operated and maintained on a continuous basis.

In addition, records and reports are necessary to enable EPA to identify facilities that are not in compliance with the standards in the rule. Based on reported information, EPA can decide which facilities should be inspected and what records or processes should be inspected at these facilities. The records that facilities maintain will indicate to EPA whether the owners or operators are in compliance with the standards in the rule.

Much of the information EPA needs to determine compliance will be recorded on a continuous, hourly, operating shift, or daily basis and compiled monthly. Such information will be reviewed by enforcement personnel during an inspection and will need to be summarized and reported on a semiannual basis.

3. Nonduplication, Consultations, and Other Collection Criteria ( a) Nonduplication Certain reports required by State or local agencies may duplicate information required by the rule ( such as, reports of performance tests). In such cases, a copy of the report submitted to the State or local agency can be provided to the Administrator in lieu of the report required by the rule, as indicated in § 63.867, which references the reporting requirements.

A search of existing rules revealed some duplication of information gathering efforts where facilities are subject to another rule ( e. g., Kraft Pulp Mills New Source Performance 7 Standards [ NSPS]) in addition to the chemical recovery combustion sources NESHAP. An effort has been made to eliminate this duplication by allowing facilities to combine excess emission and/ or summary reports for the facility, as indicated in § 63.867.

( b) Consultations The EPA published a list of categories of major and area sources of HAP's on July 16, 1992 ( 57 FR 31576), under authority of section 112( c); this notice listed pulp and paper production as a category of major sources of HAP's. ( As noted above,

chemical recovery combustion sources at pulp mills are a segment of the larger pulp and paper production source category.)

Representatives of the affected companies and industry trade associations were consulted throughout the development of the rule. The industry trade associations include the National Council of the Paper Industry for Air and Stream Improvement,

Inc. ( NCASI) and the American Forest and Paper Association ( AF& PA). The State of Washington and NCASI provided all of the long term particulate matter ( PM) emissions data that were used to support the PM emission limits. Much of the HAP emissions test data that were used to determine baseline HAP emissions and emission reductions were collected as part of an industrysponsored test program carried out by NCASI. Since 1991, EPA has met with the pulp and paper industry groups four to five times a year. During these meetings, the industry representatives were given opportunities to comment on the establishment of subcategories and MACT floors, applicable control options,

emission control costs, and the level and format of the standards. No specific information was provided with respect to burden estimates. 8 ( c) Effects of Less Frequent Collection In the first 3 years following the effective date of the rule, owners or operators of existing sources will submit only one time notifications to EPA. In this instance, less frequent reporting would not be practical because EPA needs the information provided in these one time notifications. In addition to the one time notifications, owners or operators of new and reconstructed sources will also submit semiannual compliance reports in the first 3 years following the effective date of the rule. If the relevant information was collected less frequently, EPA would not be reasonably assured that the facilities are in compliance with the standards in the rule.

Less frequent collection could result in long term exceedances of the applicable standards.

In addition, EPA's authority to take administrative action would be significantly reduced. Section 113( d) of the CAA limits the assessment of administrative penalties to violations which occur no more than 12 months before initiation of the administrative proceeding. Since administrative proceedings are less costly and require fewer resources than judicial proceedings, both EPA and the regulated community benefit from preservation of EPA's administrative powers.

Also, the reporting frequency in the rule is consistent with the requirements of title V permit programs. Consequently, less frequent reports would not result in a reduced burden.

( d) General Guidelines The rule requires that facilities retain records for a period of 5 years, which exceeds the 3 year retention period specified in the general information collection guidelines in 5 CFR 1320.6( f) of the Office of Management and Budget ( OMB)

regulations implementing the Paperwork Reduction Act. However,

the 5 year retention period is consistent with the retention 9 requirement in the General Provisions in subpart A of 40 CFR part 63 and the retention requirement in the operating permit program under 40 CFR part 70. All of the facilities subject to this rule will be required to obtain operating permits either through the State approved permitting program or, if one does not exist, in accordance with the provisions of 40 CFR part 71. Thus, the 5 year record retention requirement of the rule adds no additional burden. At a minimum, respondents will be required to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR 1320.6 are being exceeded.

( e) Confidentiality All information submitted to EPA for which a claim of confidentiality is made will be safeguarded according to EPA policies set forth in Title 40, Chapter 1, Part 2,

Subpart B   Confidentiality of Business Information. ( See 40 CFR part 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999,

September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674,

March 23, 1979.)

( f) Sensitive Questions The information to be reported consists of emissions data and other information that are not of a sensitive nature.

Therefore, this section is not applicable because this ICR does not involve matters of a sensitive nature. 10 4. The Respondents and the Information Requested ( a) Respondents/ SIC and NAICS Codes Respondents are owners or operators of 114 kraft, 2 soda,

8 sulfite, and 12 stand alone semichemical pulp mills meeting the applicability criteria in the final rule and classified as major sources under section 112 of CAA. Thus, a total of 136 respondents will be required to comply with the monitoring,

recordkeeping, and reporting requirements of the rule. The primary Standard Industrial Classification ( SIC) and North American Industrial Classification System ( NAICS) codes for the respondents affected by the rule are 2611/ 32211 ( Pulp Mills),

2621/ 32212 ( Paper Mills), and 2631/ 32213 ( Paperboard Mills).

( b) Information Requested ( i) Data items. Attachment 1, Source Data and Information Requirements, summarizes the recordkeeping and reporting requirements.

( ii) Respondent activities. The respondent activities required by the rule in the first 3 years following the effective date are listed in the first columns of Tables 1a through 1f, and are discussed in section 6( a). The respondent activities are described in more detail in Attachment 2, Description of Respondent Activities. One time and recurrent respondent activities are presented in Tables 1a and 1b for the first year,

Tables 1c and 1d for the second year, and Tables 1e and 1f for the third year. 11 5. Information Collected Agency Activities, Collection Methodology, and Information Management ( a) Agency Activities The Agency activities in the first 3 years following the effective date of the rule are listed in the first columns of Tables 2a through 2c and are discussed in section 6( c). Tables 2a, 2b, and 2c present the Agency activities for the first,

second, and third years, respectively, after the effective date of the rule.

( b) Collection Methodology and Management Information contained in the initial, one time only notifications will be entered in the Aerometric Information Retrieval System ( AIRS) Facility Subsystem operated and maintained by EPA's Office of Air Quality Planning and Standards ( OAQPS). AIRS is EPA's data base for the collection,

maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government owned facilities. The EPA uses AIRS for tracking air pollution compliance and enforcement by State and local agencies and EPA Regional Offices and Headquarters. The EPA and its delegated authorities can edit, store, retrieve, and analyze the data. The AIRS data base can be publicly accessed via the Internet at http:// www. epa. gov/ enviro/ index_ java. html or through a Freedom of Information Act request to EPA. Data obtained during periodic visits by EPA personnel, from records maintained by the respondents, and from information provided in semiannual reports will be tabulated and published for internal EPA use in compliance and enforcement programs.

The rule does not require the use of automated, electronic,

mechanical, or other technological data collection techniques or other forms of information technology. Although most facilities 12 monitor a wide variety of process and air pollution control device parameters on a continuous basis, store this information using data acquisition systems, and record most of these values on an hourly basis using operator log sheets, the presence of these data acquisition systems, while reducing the burden of data collection, is not expected to reduce the burden of reporting.

( c) Small Entity Flexibility Minimizing the information collection burden for all sizes of organizations is a continuing effort by EPA. The EPA has reduced the reporting and recordkeeping burden for respondents to include only the information that EPA needs to determine compliance with the standards in the rule. The EPA has determined that 3 companies meet the definition of small entity   a small business that has fewer than 750 employees for SIC codes 2611, 2621, or 2631. These 3 companies own only 3 of the 136 mills subject to the final rule. The small business analysis reported in the Economic Analysis shows that the affected mills have costs as a percentage of sales ratios of less than 1 percent, that these mills are not expected to close nor are the owning companies expected to encounter financial distress as a result of this rule.

( d) Collection Schedule Collection of data will begin after the effective date of the chemical recovery combustion sources NESHAP. The schedule for notifications and reports required by the rule is summarized below.

For all existing sources, the initial notification must be submitted no later than 6 months after the effective date of the rule. New sources for which construction or reconstruction has commenced and initial startup has occurred before the effective date of the rule must submit the initial notification as soon as 13 practicable before startup but no later than 60 days after the effective date of the rule. New sources for which the construction or reconstruction commenced after the effective date of the rule must submit the initial notification as soon as practicable before the construction or reconstruction commences ( but no sooner than the effective date of the rule). New or reconstructed combustion sources at pulp and paper mills must comply immediately upon the effective date of the promulgated rule if their startup date is before the effective date or upon startup if the startup date is on or after the effective date.

Facilities required to conduct a performance test must submit a notification of intent to conduct a performance test at least 60 days before the performance test is scheduled to begin.

For each performance test, facilities must submit an initial notification of compliance status no later than 60 days following the completion of the performance test.

Records necessary to determine compliance must be compiled on a monthly basis, and compliance reports must be submitted to the Administrator on a semiannual basis, as discussed in section 2( b).

6. Estimating the Burden and Cost of the Collection ( a) Estimating Respondent Burden The annual burden estimates for reporting and recordkeeping activities for the first 3 years after the effective date of the rule are presented in Tables 1a through 1f. One time and recurrent burden estimates to the industry are presented in Tables 1a and 1b for the first year, Tables 1c and 1d for the second year, and Tables 1e and 1f for the third year. The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts. 14 ( b) Estimating Respondent Costs ( i) Estimating labor costs. The annual labor costs for reporting and recordkeeping activities are also presented in Tables 1a through 1f. The costs of these activities were estimated based on data from the U. S. Bureau of Labor Statistics.

Labor costs are divided into the following three categories:

( 1) technical, ( 2) management, and ( 3) clerical. The cost of technical labor was estimated at $ 45.04 per hour ($ 45.04/ hr), the cost of management labor at $ 66.73/ hr, and the cost of clerical labor at $ 28.14/ hr. These estimates include fringe benefits,

overhead, and profit rate.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities: capital costs and operation and maintenance ( O& M)

costs. One time capital costs usually include any produced physical good, such as computers, machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest rate.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs ( planning and selection), and a data acquisition system ( data logger, computer, logging and reporting software, and printer).

No capital costs were estimated for monitoring equipment for the first 3 years after the effective date for the following reasons:

( 1) no costs need to be estimated for COMS or CPMS for the new kraft recovery furnaces, SDT's, and lime kilns installed during the first 3 years after the effective date because those combustion units would be subject to the Kraft Pulp Mills NSPS,

which already requires the monitoring equipment; ( 2) no new soda 15 or sulfite combustion units are expected to be installed during the first 3 years after the effective date; and ( 3) because thermocouples and strip chart recorders are included in the cost of the regenerative thermal oxidizers ( RTO's) used to control emissions from semichemical combustion units, no additional monitoring costs would be necessary for new semichemical units installed during the first 3 years after the effective date.

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file cabinet). The annualized capital cost per file cabinet is $ 35,

based on annualizing the capital cost over 15 years and including administrative charges, property taxes, and insurance at 4 percent of the capital cost. An estimated 8 mills will purchase this equipment in the first year after the effective date of the rule and 7 mills in the second and third years. ( The number of mills was determined based on the assumption that four existing kraft pulp mills will each install one new recovery furnace and SDT, and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also, one existing stand alone semichemical pulp mill is projected to install one new semichemical combustion unit during the first year after the effective date.)

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. Only new sources will be required to conduct performance tests during the first 3 years after the effective date. Performance test costs for new semichemical combustion units were estimated based on the following assumptions: ( 1) semichemical mills will perform initial THC performance tests using Method 25A, ( 2) the cost of a Method 25A test is $ 9,500 ( annualized over 15 years to $ 1,043),

( 3) an estimated one new semichemical combustion unit will be 16 required to conduct an initial THC performance test over the first 3 years after the effective date ( based on an estimated two new units installed over 5 years), and ( 4) no new semichemical combustion units are expected to have to repeat the initial THC performance test due to failure of the first test.

No capital costs were estimated for Method 5 PM performance tests for new kraft combustion units installed during the first 3 years after the effective date because those units would be subject to the Kraft Pulp Mills NSPS. The PM test costs for units subject to the NSPS are assumed to be existing costs for complying with existing State permits or other State/ local programs. Because no new soda or sulfite combustion units are expected to be installed over the first 3 years after the effective date, no Method 5 test costs were estimated for those combustion units for the first 3 years.

No capital costs were estimated for Method 308 methanol performance tests for new kraft and soda recovery furnaces installed during the first 3 years after the effective date. New recovery furnaces are expected to be NDCE recovery furnaces equipped with dry ESP systems, which are exempted from testing requirements.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. Because no monitoring equipment costs are being estimated for new combustion units installed during the first 3 years after the effective date ( for the reasons cited above), there are no O& M costs associated with monitoring equipment.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. The O& M costs for rules that require 17 respondents to submit notifications and reports to EPA and maintain records are estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs were applied to the 200 responses submitted during the first year, the 81 responses submitted during the second year, and the 95 responses submitted during the third year. ( The number of responses was determined by adding the number of reports submitted to EPA by respondents during each of the first 3 years after the effective date, as shown in Tables 1a through 1f.)

( c) Estimating Agency Burden and Costs Because the information collection requirements were estimated as an incidental part of standards development, no costs can be attributed to the development of these requirements.

In addition, no operational costs will be incurred by the Federal Government because reporting and recordkeeping requirements on the part of the respondents are required under section 112 of the CAA. Publication and distribution of the information are part of the AIRS Facility Subsystem, with the result that no Federal costs can be attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of facilities. Periodic inspections are part of EPA's overall compliance and enforcement program.

Therefore, this examination is not attributable to the ICR.

The only costs that the Federal Government will incur are user costs associated with the analysis of the information reported by the facilities in one time notifications and semiannual compliance reports ( unless the compliance report indicates a violation, thereby triggering an enforcement action).

Tables 2a, 2b, and 2c present the estimated annual burden to the 18 Federal Government during the first, second, and third years,

respectively, after the effective date of the rule. Labor costs were estimated based on estimated wage rates of $ 45.04/ hr for technical labor, $ 66.73/ hr for management labor, and $ 28.14/ hr for clerical labor.

( d) Estimating the Respondent Universe and Total Burden and Costs Once the burden and costs per activity have been established on a per respondent basis, the total burden and cost must be calculated for all respondents and for the Agency. To calculate the total burden and costs, the number of respondents needed to complete each information collection activity must be estimated.

The total number of respondents is also referred to as the " respondent universe." The respondent universe varies among the activities listed because not all respondents must complete each activity.

Burden and costs were estimated for an existing respondent universe of 114 kraft, 2 soda, 8 sulfite, and 12 stand alone semichemical pulp mills and a projected new respondent universe of 12 kraft recovery furnaces and associated SDT's, 9 kraft lime kilns, and 1 semichemical combustion unit over the 3 years after the effective date. Based on these projections, an estimated 4 new kraft recovery furnaces and SDT's and 3 new kraft lime kilns were assumed to be installed during each of the 3 years after the effective date. The new semichemical combustion unit was assumed to be installed during the first year after the effective date.

To determine the burden for each activity for technical staff, the number of burden hours per respondent was multiplied by the number of respondents. Management and clerical labor hours were calculated at 5 percent and 10 percent of technical labor hours, respectively. The total burden was determined by summing the technical, management, and clerical burden hour 19 estimates. To determine the total labor cost, the burden hour estimates for technical, management, and clerical labor were multiplied by their respective wage rates and then summed.

( e) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 1a through 1f and dividing the sums by the 3 year review period. The total annual respondent burden hours and costs are summarized as follows:

Total burden, hours Total costs, $

Tables 1a + 1b ( first year) 15,300 681,067 Tables 1c + 1d ( second year) 20,935 931,873 Tables 1e + 1f ( third year) 28,349 1,261,898 Total 64,584 2,874,838 Bottom line annual burden 21,528 958,279 The bottom line annual burden, averaged over the first 3 years after the effective date, is 21,528 labor hours, at a cost of $ 958,279. The bottom line annual burden is presented in Box 13c of OMB 83 I. The average annual burden per respondent, based on 136 respondents, is 158 labor hours, at a cost of $ 7,046. The average number of respondents is presented in Box 13a of OMB 83 I.

On average, there are an estimated 125 total annual responses for the first 3 years after the effective date of the rule. Of the 125 total annual responses, approximately 50 percent are assumed to be collected electronically. The total annual responses are an average of the one time and recurrent notifications and reports submitted during the first, second, and third years after the effective date. An estimated 200 notifications and reports will be submitted during the first 20 year, 81 during the second year, and 95 during the third year.

The total annual responses and the percent of responses collected electronically are presented in Boxes 13b and 13b. 1 of OMB 83 I.

As stated in section 6( b)( ii), there are no nationwide capital costs associated with monitoring equipment for the 136 existing pulp mills or the new kraft and semichemical combustion units installed during the first 3 years after the effective date. The total nationwide capital cost associated with file cabinets for storing collected data and reports was estimated to be $ 1,880 in the first year after the effective date and $ 1,645 in each of the second and third years. The average annualized capital cost for file cabinets is $ 525 for the 3 years following the effective date. The total nationwide capital cost for performance tests was estimated to be $ 9,500 for the first year after the effective date, based on one THC test for one new semichemical combustion unit. No tests are anticipated for the other 2 years after the effective date. The average annualized capital cost for performance tests is $ 1,043 for the 3 years following the effective date. Annual O& M costs, which include photocopying and postage for the reports, average $ 2,720 for the 3 years following effective date. Combining the annualized capital costs for file cabinets and performance tests results in a total annualized capital cost of $ 1,568 for the 3 years following the effective date. Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 4,288 for the 3 years following the effective date. The total annualized capital cost, annual O& M cost, and total annualized cost are presented in Boxes 14a, 14b, and 14c,

respectively, of OMB 83 I.

A discussion of the respondent burden and costs in later years is provided in Attachment 3, Burden and Cost of Reporting and Recordkeeping Requirements for the Fourth, Fifth, and Sixth Years Following the Effective Date. 21 ( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours and costs from Tables 2a, 2b, and 2c and then dividing by the 3 year review period. The total annual Agency burden hours and costs are summarized as follows:

Total burden, hours Total costs, $

Table 2a ( first year) 534 24,252 Table 2b ( second year) 285 13,195 Table 2c ( third year) 317 14,629 Total 1,136 52,076 Bottom line annual burden 379 17,359 The bottom line annual burden, averaged over the first 3 years after the effective date, is 379 labor hours, at a cost of $ 17,359. A discussion of the Agency burden and costs in later years is provided in Attachment 3, Burden and Cost of Reporting and Recordkeeping Requirements for the Fourth, Fifth, and Sixth Years Following the Effective Date.

( iii) The complex collection. This section does not apply because this collection is a simple collection.

( iv) Variations in the annual bottom line. The annual burden hours and costs associated with one time activities vary over the course of the 3 year review period because sources are subject to different requirements in each year. Both existing and new sources will be required to read instructions and submit initial notifications in the first year. Increasing numbers of new sources installed after the effective date will be subject to ongoing requirements over the 3 year review period, such as recordkeeping and submitting semiannual compliance reports.

The Agency burden hours and costs will also vary over the 3 year review period because EPA will be reviewing initial notifications from existing sources in the first year and initial 22 notifications and semiannual reports from new sources in all 3 years.

( f) Reasons for Change in Burden This section does not apply because this collection is a new collection.

( g) Burden Statement ( i) The EPA is required under section 112( d) of the CAA to regulate emissions of HAP's listed in section 112( b).

( ii) The respondents will be subject to applicable recordkeeping, reporting, and other requirements in 40 CFR 63.9 and 63.10, the General Provisions for the part 63 rules.

( iii) 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: ( 1) review instructions;

( 2) 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; ( 3) adjust the existing ways to comply with any previously applicable instructions and requirements; ( 4) train personnel to be able to respond to a collection of information; ( 5) search data sources; ( 6) complete and review the collection of information; and ( 7) transmit or otherwise disclose the information.

( iv) The information is needed as part of the overall compliance and enforcement program. The information stored in the initial, one time initial notifications and reports will be stored in EPA's AIRS Facility Subsystem and will be available to stakeholders.

( v) The total annual reporting and recordkeeping burden and cost for this collection averaged over the first 3 years after 23 the effective date of the rule were estimated to be 21,528 labor hours and $ 958,279. The average burden and cost, per respondent,

are 158 labor hours and $ 7,046.

During these 3 years, the rule requires certain initial onetime notifications from all sources. In addition, new sources are required to submit an initial one time notification of compliance status and semiannual compliance report to indicate their ongoing compliance status. Each respondent also must keep necessary records of data to determine compliance with the rule.

( vi) The total capital cost is $ 11,380 the first year after the effective date of the rule and $ 1,645 for each of the second and third years. The annualized capital cost is $ 1,568 for the 3 years after the effective date. The average annual O& M cost is $ 2,720 for the 3 years after the effective date. Combining the annualized capital cost with the annual O& M cost gives a total annualized cost of $ 4,288 for the 3 years after the effective date.

( vii) 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 a table in 40 CFR part 9. The EPA will amend part 9 when the ICR is approved.

( viii) Send comments on EPA's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, Office of Environmental Information, Collection Strategies Division ( 2822), U. S. Environmental Protection Agency, 1200 Pennsylvania Avenue NW, Washington, DC 20460, and to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street NW, Washington, DC 20503, marked " Attention: Desk Officer for EPA." Include the EPA ICR number and OMB control number in any correspondence. 24 ( v) All information submitted to EPA for which a claim of confidentiality is made will be safeguarded according to EPA policies set forth in Title 40, Chapter 1, Part 2,

Subpart B   Confidentiality of Information ( see 40 CFR part 2;

41 FR 36902, September 1, 1976; amended by 43 FR 39999,

September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674,

March 23, 1979). 25 TABLE 1a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions 2 1 2 136c 272 14 27 313 13,924 B. Required activities ° Performance evaluation CPMS 10d 1 10 5e, f 49 2.4 4.9 56 2,500 COMS 27d 1 27 7e, f 191 9.6 19 220 9,800 ° Repeat performance evaluation CPMS 10d 1 10 0e, f 0 0 0 0 0 COMS 27d 1 27 0e, f 0 0 0 0 0 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report ° Notification of construction/

reconstruction 2 1 2 8 e 16 0.8 1.6 18 819 ° Notification of anticipated startup 2 1 2 8e 16 0.8 1.6 18 819 ° Notification of actual startup 2 1 2 8e 16 0.8 1.6 18 819 ° Notification of applicability of the standard 2 1 2 136c 272 14 27 313 13,924 ° Notification of initial performance test 2 1 2 8g 16 0.8 1.6 18 819 ° Notification of performance evaluation 2 1 2 8e 16 0.8 1.6 18 819 ° Notification of compliance status 80 1 80 8e 640 32 64 736 32,762 4. Recordkeeping Requirements A. Read instructions Included in 3A B. Plan activities N/ A 26 TABLE 1a. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b C. Implement activities N/ A D. Develop record system 40h 1 40 8 e 320 16 32 368 16,381 E. Develop startup, shutdown, and malfunction plan 100i 1 100 8e 800 40 80 920 40,952 F. Time to enter information ° Records and documentation of supporting calculations for compliance determinations 8 1 8 8 e 64 3.2 6.4 74 3,276 ° Records of compliant monitoring parameter ranges 2 1 2 8 e 16 0.8 1.6 18 819 ° Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces 2 1 2 4 j 8 0.4 0.8 9.2 410 G. Time to train personnel 40k 1 40 8 e 320 16 32 368 16,381 H. Time for audits N/ A ONE TIME BURDEN AND COST ( SALARY)

NATIONWIDE: l 3,032 152 303 3,487 155,224 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 stand alone semichemical pulp mills. No new major source pulp mills are projected to be built within the next 5 years.

dPerson hours per occurrence are based on the cost of the performance evaluation divided by the composite hourly labor rate. The performance evaluation costs are $ 500 for each CPMS and $ 1,400 for each COMS.

eAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these one time requirements was estimated to be eight for the first year after the effective date and seven for the second and third years.

fAssumes four new SDT's will be required to conduct a CPMS performance evaluation each year over the first 3 years after the effective date; also assumes one new semichemical combustion unit will be required to conduct a CPMS performance evaluation the first year after the effective date. Assumes four new recovery furnaces and three new lime kilns will be required to conduct a COMS performance evaluation each year over the first 3 years after the effective date. Assumes 5 percent of the CPMS/ COMS performance evaluations must be repeated due to the failure of the first performance evaluation.

gAssumes the seven new kraft combustion units will be required to submit notifications of initial performance test each year over the first 3 years after the effective date. Also, assumes the new semichemical combustion unit will be required to submit a notification of initial performance test on the first year after the effective date. 27 TABLE 1a. ( continued)

hAssumes 1 week ( 40 hours) to develop a record system for recording parameter monitoring information.

iAssumes 1 person would take 2 weeks ( 80 hours) to draft the startup, shutdown, and malfunction plan and then another 20 hours of review/ revisions, for a total of 100 hours.

jAssumes 4 existing kraft and soda pulp mills will install new recovery furnaces each year over the 3 year review period. Based on current industry trends, these new furnaces are expected to be NDCE recovery furnaces equipped with a dry ESP system.

kAssumes 1 week ( 40 hours) to train personnel.

lThe one time burden and cost in the first year are equal to the totals added down each column. 28 TABLE 1b. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions N/ A B. Required activities N/ A C. Create information N/ A D. Gather existing information N/ A E. Write report ° Excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 16c 4 64 0d, e 0 0 0 0 0 Semiannual report of no exceedances 8f 2 16 8d, e 128 6.4 13 147 6,552 4. Recordkeeping Requirements A. Read instructions N/ A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Time to enter information ° Records of startup, shutdown, and malfunction 1.5 52 78 8d 624 31 62 718 31,943 ° Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units 1.5 52 78 5d 390 20 39 449 19,964 ° Records of lime production rates for lime kilns 1.5 52 78 3d 234 12 23 269 11,979 29 TABLE 1b. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b ° Records of CPMS/ COMS data Record continuously monitored parameters ( per shift) 0.5 1,050 525 8d 4,200 210 420 4,830 215,000 Compile monthly data 16 12 192 8d 1,536 77 154 1,766 78,629 Enter/ verify information for quarterly/ semiannual reports 8 2 16 8 d 128 6.4 13 147 6,552 F. Time to train personnel N/ A G. Time for refresher training for personnel 16g 1 16 0 0 0 0 0 0 H. Time for audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: h 7,240 362 724 8,326 370,619 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes 16 person hours per report per affected facility per pollutant for an exceedances report.

dAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these recurrent requirements was estimated to be 8 for the first year after the effective date.

eAssumes 5 percent of respondents ( 0.05 * 8 = 0) report monitoring exceedances and 95 percent of respondents ( 0.95 * 8 = 8) report no exceedances..

fAssumes 8 person hours per report per affected facility per pollutant for a report of no exceedances.

gAssumes 2 days ( 16 hours) to provide refresher training for personnel.

hThe recurrent burden and cost in the first year are equal to the totals added down each column. 30 TABLE 1c. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATEa Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions 2 1 2 7c 14 0.7 1.4 16 717 B. Required activities CPMS 10d 1 10 4c, e 39 2.0 3.9 45 2,000 COMS 27d 1 27 7c, e 191 9.6 19 220 9,800 ° Repeat performance evaluation CPMS 10d 1 10 0c, e 0 0 0 0 0 COMS 27d 1 27 0c, e 0 0 0 0 0 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report ° Notification of construction/

reconstruction 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of anticipated startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of actual startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of applicability of the standard 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of initial performance test 2 1 2 7f 14 0.7 1.4 16 717 ° Notification of performance evaluation 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of compliance status 80 1 80 7c 560 28 56 644 28,667 4. Recordkeeping Requirements A. Read instructions Included in 3A B. Plan activities N/ A C. Implement activities N/ A 31 TABLE 1c. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b D. Develop record system 40g 1 40 7 c 280 14 28 322 14,333 E. Develop startup, shutdown, and malfunction plan 100h 1 100 7c 700 35 70 805 35,933 F. Time to enter information ° Records and documentation of supporting calculations for compliance determinations 8 1 8 7 c 56 2.8 5.6 64 2,867 ° Records of compliant monitoring parameter ranges 2 1 2 7 c 14 0.7 1.4 16 717 ° Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces 2 1 2 4 i 8 0.4 0.8 9.2 410 G. Time to train personnel 40j 1 40 7 c 280 14 28 322 14,333 H. Time for audits N/ A ONE TIME BURDEN AND COST ( SALARY)

NATIONWIDE: k 2,227 111 223 2,560 113,976 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these one time requirements was estimated to be eight for the first year after the effective date and seven for the second and third years.

dPerson hours per occurrence are based on the cost of the performance evaluation divided by the composite hourly labor rate. The performance evaluation costs are $ 500 for each CPMS and $ 1,400 for each COMS.

eAssumes three new SDT's will be required to conduct a CPMS performance evaluation each year over the first 3 years after the effective date; also assumes one new semichemical combustion unit will be required to conduct a CPMS performance evaluation the first year after the effective date. Assumes four new recovery furnaces and three new lime kilns will be required to conduct a COMS performance evaluation each year over the first 3 years after the effective date. Assumes 5 percent of the CPMS/ COMS performance evaluations must be repeated due to the failure of the first performance evaluation.

fAssumes the seven new kraft combustion units will be required to submit notifications of initial performance test each year over the first 3 years after the effective date. Also, assumes the new semichemical combustion unit will be required to submit a notification of initial performance test only the first year after the effective date.

gAssumes 1 week ( 40 hours) to develop a record system for recording parameter monitoring information.

hAssumes 1 person would take 2 weeks ( 80 hours) to draft the startup, shutdown, and malfunction plan and then another 20 hours of review/ revisions, for a total of 100 hours.

iAssumes 4 existing kraft and soda pulp mills will install new recovery furnaces each year over the 3 year review period. Based on current industry trends, these new furnaces are expected to be NDCE recovery furnaces equipped with a dry ESP system. 32 TABLE 1c. ( continued)

jAssumes 1 week ( 40 hours) to train personnel.

kThe one time burden and cost in the second year are equal to the totals added down each column. 33 TABLE 1d. RECURRENT RESPONDENT BURDEN AND COST TO INDUSTRY OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions N/ A B. Required activities N/ A C. Create information N/ A D. Gather existing information N/ A E. Write report ° Excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 16c 4 64 1d, e 64 3.2 6.4 74 3,276 Semiannual report of no exceedances 8f 2 16 14d, e 224 11 22 258 11,467 4. Recordkeeping Requirements A. Read instructions N/ A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Time to enter information ° Records of startup, shutdown, and malfunction 1.5 52 78 15d 1,170 59 117 1,346 59,893 ° Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units 1.5 52 78 9d 702 35 70 807 35,936 ° Records of lime production rates for lime kilns 1.5 52 78 6d 468 23 23 538 23,957 34 TABLE 1d. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b ° Records of CPMS/ COMS data Record continuously monitored parameters ( per shift) 0.5 1,050 525 15d 7,875 394 788 9,056 403,125 Compile monthly data 16 12 192 15d 2,880 144 288 3,312 147,429 Enter/ verify information for quarterly/ semiannual reports 8 2 16 15d 240 12 24 276 12,286 F. Time to train personnel N/ A G. Time for refresher training for personnel 16g 1 16 8 d 128 6.4 13 147 6,552 H. Time for audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: h 13,751 688 1,375 15,814 703,921 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes 16 person hours per report per affected facility per pollutant for an exceedances report.

dAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these recurrent requirements was estimated to be 15 for the second year after the effective date ( 8 mills in the first year + 7 mills in the second year).

eAssumes 5 percent of respondents ( 0.05 * 15 = 1) report monitoring exceedances and 95 percent of respondents ( 0.95 * 15 = 14) report no exceedances..

fAssumes 8 person hours per report per affected facility per pollutant for a report of no exceedances.

gAssumes 2 days ( 16 hours) to provide refresher training for personnel.

hThe recurrent burden and cost in the second year are equal to the totals added down each column. 35 TABLE 1e. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS   THIRD YEAR FOLLOWING THE EFFECTIVE DATEa Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions 2 1 2 7c 14 0.7 1.4 16 717 B. Required activities B. Required activities ° Performance evaluation CPMS 10d 1 10 4c, e 39 2.0 3.9 45 2,000 COMS 27d 1 27 7c, e 191 9.6 19 220 9,800 ° Repeat performance evaluation CPMS 10d 1 10 0c, e 0 0 0 0 0 COMS 27d 1 27 0c, e 0 0 0 0 0 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report ° Notification of construction/

reconstruction 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of anticipated startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of actual startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of applicability of the standard 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of initial performance test 2 1 2 7f 14 0.7 1.4 16 717 ° Notification of performance evaluation 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of compliance status 80 1 80 7c 560 28 56 644 28,667 4. Recordkeeping Requirements A. Read instructions Included in 3A 36 TABLE 1e. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b B. Plan activities N/ A C. Implement activities N/ A D. Develop record system 40g 1 40 7 c 280 14 28 322 14,333 E. Develop startup, shutdown, and malfunction plan 100h 1 100 7c 700 35 70 805 35,833 F. Time to enter information ° Records and documentation of supporting calculations for compliance determinations 8 1 8 7 c 56 2.8 5.6 64 2,867 ° Records of compliant monitoring parameter ranges 2 1 2 7 c 14 0.7 1.4 16 717 ° Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces 2 1 2 4 i 8 0.4 0.8 9.2 410 G. Time to train personnel 40j 1 40 7 c 280 14 28 322 14,333 H. Time for audits N/ A ONE TIME BURDEN AND COST ( SALARY)

NATIONWIDE: k 2,227 111 223 2,560 113,976 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these one time requirements was estimated to be eight for the first year after the effective date and seven for the second and third years.

dPerson hours per occurrence are based on the cost of the performance evaluation divided by the composite hourly labor rate. The performance evaluation costs are $ 500 for each CPMS and $ 1,400 for each COMS.

eAssumes three new SDT's will be required to conduct a CPMS performance evaluation each year over the first 3 years after the effective date; also assumes one new semichemical combustion unit will be required to conduct a CPMS performance evaluation the first year after the effective date. Assumes four new recovery furnaces and three new lime kilns will be required to conduct a COMS performance evaluation each year over the first 3 years after the effective date. Assumes 5 percent of the CPMS/ COMS performance evaluations must be repeated due to the failure of the first performance evaluation.

fAssumes the seven new kraft combustion units will be required to submit notifications of initial performance test each year over the first 3 years after the effective date. Also, assumes the new semichemical combustion unit will be required to submit a notification of initial performance test only the first year after the effective date.

gAssumes 1 week ( 40 hours) to develop a record system for recording parameter monitoring information. 37 TABLE 1e. ( continued)

hAssumes 1 person would take 2 weeks ( 80 hours) to draft the startup, shutdown, and malfunction plan and then another 20 hours of review/ revisions, for a total of 100 hours.

iAssumes 4 existing kraft and soda pulp mills will install new recovery furnaces each year over the 3 year review period. Based on current industry trends, these new furnaces are expected to be NDCE recovery furnaces equipped with a dry ESP system.

jAssumes 1 week ( 40 hours) to train personnel.

kThe one time burden and cost in the third year are equal to the totals added down each column. 38 TABLE 1f. RECURRENT RESPONDENT BURDEN AND COST TO INDUSTRY OF REPORTING AND RECORDKEEPING REQUIREMENTS   THIRD YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions N/ A B. Required activities N/ A C. Create information N/ A D. Gather existing information N/ A E. Write report ° Excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 16c 4 64 1d, e 64 3.2 6.4 74 3,276 Semiannual report of no exceedances 8f 2 16 21d, e 336 17 34 386 17,200 4. Recordkeeping Requirements A. Read instructions N/ A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Time to enter information ° Records of startup, shutdown, and malfunction 1.5 52 78 22d 1,716 86 172 1,973 87,843 ° Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units 1.5 52 78 13d 1,014 51 101 1,166 51,907 ° Records of lime production rates for lime kilns 1.5 52 78 9d 702 35 70 807 35,936 39 TABLE 1f. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b ° Records of CPMS/ COMS data Record continuously monitored parameters ( per shift) 0.5 1,050 525 22d 11,550 577 1,155 13,283 591,250 Compile monthly data 16 12 192 22d 4,224 211 422 4,858 216,229 Enter/ verify information for quarterly/ semiannual reports 8 2 16 22d 352 18 35 405 18,019 F. Time to train personnel N/ A G. Time for refresher training for personnel 16g 1 16 15 d 240 12 24 276 12,286 H. Time for audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: h 20,198 1,010 2,020 23,228 1,033,946 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes 16 person hours per report per affected facility per pollutant for an exceedances report.

dAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these recurrent requirements was estimated to be 22 for the third year after the effective date ( 8 mills in the first year + 7 mills in the second year + 7 mills in the third year). eAssumes 5 percent of respondents ( 0.05 * 22 = 1) report monitoring exceedances and 95 percent of respondents ( 0.95 * 22 = 21) report no exceedances..

fAssumes 8 person hours per report per affected facility per pollutant for a report of no exceedances.

gAssumes 2 days ( 16 hours) to provide refresher training for personnel.

hThe recurrent burden and cost in the third year are equal to the totals added down each column. 40 TABLE 2a. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a 1. Attend initial performance test 40 1 40 1b 40 2.0 4.0 46 2,048 2. Attend repeat performance test A. Retesting preparation 8 1 8 1c 8.0 0.4 0.8 9.2 410 B. Attend retesting 40 1 40 0d 0 0 0 0 0 3. Litigation 2,080 1 2,080 0e, f 0 0 0 0 0 4. Excess emissions enforcement activities 48 1 48 0b, g 0 0 0 0 0 5. Report review ° Review of notification of construction/

reconstruction 2 1 2 8 f 16 0.8 1.6 18 819 ° Review of notification of anticipated startup 2 1 2 8f 16 0.8 1.6 18 819 ° Review of notification of actual startup 2 1 2 8f 16 0.8 1.6 18 819 ° Review of notification of applicability 2 1 2 136h 272 14 27 313 13,924 ° Review of notification of initial performance test 2 1 2 8b, f 16 0.8 1.6 18 819 ° Review of notification of performance evaluation 2 1 2 8 f 16 0.8 1.6 18 819 ° Review of notification of compliance status 4 1 4 8f 32 1.6 3.2 37 1,638 ° Review of excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 8 4 32 0f, i 0 0 0 0 0 Semiannual report of no exceedances 2 2 4 8f, i 32 1.6 3.2 37 1,638 41 TABLE 2a. ( continued)

Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a TOTAL BURDEN AND COST ( SALARY) j 464 23 46 534 23,752 TRAVEL EXPENSES FOR TESTS ATTENDEDk = ( 1 person * 1 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 1 round trip/ yr) 500 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES 24,252 aCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 + 0.1 * $ 28.14 = $ 51.19).

bAn estimated 4 new recovery furnaces, 4 new SDT's, 3 new lime kilns, and 1 new semichemical combustion unit will be required to conduct an initial performance test in the first year. Assumes EPA personnel attend 8 percent of the tests ( 0.08 * 12 combustion units = 1 test attended).

cOf the 5 percent that are assumed to fail the initial performance test, assume all repeat the performance test ( 0.05 * 12 combustion units = 1 retest).

dAssumes 10 percent of the retests are attended by EPA personnel ( 0.1 * 1 retest = 0 retests attended).

eAssumes 1 percent of the affected facilities will be involved in litigation ( 0.01 * 8 mills = 0 mills).

fAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT, and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills subject to these requirements was estimated to be eight for the first year after the effective date. gAssumes 5 percent of the affected facilities are required to retest as a result of excess emissions, and that EPA personnel attend 10 percent of these tests ( 0.05 * 12 new combustion units * 0.1 = 0 units).

hThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 semichemical mills. No new major source pulp mills are projected to be built within the next 5 years.

iAssumes 5 percent of respondents ( 0.05 * 8 = 0) report monitoring exceedances and 95 percent of respondents ( 0.95 * 8 = 8) report no exceedances..

jThe burden and cost in the first year are equal to the totals added down each column.

kTests attended = 1 ( initial tests) + 0 ( repeat tests) + 0 ( excess emissions enforcement tests) = 1 test. 42 TABLE 2b. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a 1. Attend initial performance test 40 1 40 1b 40 2.0 4.0 46 2,048 2. Attend repeat performance test A. Retesting preparation 8 1 8 1c 8.0 0.4 0.8 9.2 410 B. Attend retesting 40 1 40 0d 0 0 0 0 0 3. Litigation 2,080 1 2,080 0e, f 0 0 0 0 0 4. Excess emissions enforcement activities 48 1 48 0b, g 0 0 0 0 0 5. Report review ° Review of notification of construction/

reconstruction 2 1 2 7 f 14 0.7 1.4 16 717 ° Review of notification of anticipated startup 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of actual startup 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of applicability 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of initial performance test 2 1 2 7b, f 14 0.7 1.4 16 717 ° Review of notification of performance evaluation 2 1 2 7 f 14 0.7 1.4 16 717 ° Review of notification of compliance status 4 1 4 7f 28 1.4 2.8 32 1,433 ° Review of excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 8 4 32 1f, h 32 1.6 3.2 38 1,638 Semiannual report of no exceedances 2 2 4 14f, h 56 2.8 5.6 64 2,867 43 TABLE 2b. ( continued)

Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a TOTAL BURDEN AND COST ( SALARY) i 248 12.0 25 285 12,695 TRAVEL EXPENSES FOR TESTS ATTENDEDj = ( 1 person * 1 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 1 round trip/ yr) 500 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES 13,195 aCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 + 0.1 * $ 28.14 = $ 51.19).

bAn estimated 4 new recovery furnaces, 4 new SDT's, and 3 new lime kilns will be required to conduct an initial performance test in the second year. Assumes EPA personnel attend 8 percent of the tests ( 0.08 * 11 combustion units = 1 test attended).

cOf the 5 percent that are assumed to fail the initial performance test, assume all repeat the performance test ( 0.05 * 11 combustion units = 1 retest).

dAssumes 10 percent of the retests are attended by EPA personnel ( 0.1 * 1 retest = 0 retests attended).

eAssumes 1 percent of the affected facilities will be involved in litigation ( 0.01 * 7 mills = 0 mills).

fAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT, and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills for the second year after the effective date was estimated to be 7 for one time requirements and 15 for recurrent requirements ( 8 mills in the first year + 7 mills in the second year).

gAssumes 5 percent of the affected facilities are required to retest as a result of excess emissions, and that EPA personnel attend 10 percent of these tests ( 0.05 * 11 new combustion units * 0.1 = 0 units).

hAssumes 5 percent of respondents ( 0.05 * 15 = 1) report monitoring exceedances and 95 percent of respondents ( 0.95 * 15 = 14) report no exceedances..

iThe burden and cost in the second year are equal to the totals added down each column.

jTests attended = 1 ( initial tests) + 0 ( repeat tests) + 0 ( excess emissions enforcement tests) = 1 test. 44 TABLE 2c. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS   THIRD YEAR FOLLOWING THE EFFECTIVE DATE Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a 1. Attend initial performance test 40 1 40 1b 40 2.0 4.0 46 2,048 2. Attend repeat performance test A. Retesting preparation 8 1 8 1c 8.0 0.4 0.8 9.2 410 B. Attend retesting 40 1 40 0d 0 0 0 0 0 3. Litigation 2,080 1 2,080 0e, f 0 0 0 0 0 4. Excess emissions enforcement activities 48 1 48 0b, g 0 0 0 0 0 5. Report review ° Review of notification of construction/

reconstruction 2 1 2 7 f 14 0.7 1.4 16 717 ° Review of notification of anticipated startup 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of actual startup 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of applicability 2 1 2 7f 14 0.7 1.4 16 717 ° Review of notification of initial performance test 2 1 2 7b, f 0 0 0 0 0 ° Review of notification of performance evaluation 2 1 2 7 f 14 0.7 1.4 16 717 ° Review of notification of compliance status 4 1 4 7f 28 1.4 2.8 32 1,433 ° Review of excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 8 4 32 1f, h 32 1.6 3.2 38 1,638 Semiannual report of no exceedances 2 2 4 21f, h 84 4.2 8.4 97 4,300 45 TABLE 2c. ( continued)

Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a TOTAL BURDEN AND COST ( SALARY) i 276 14 28 317 14,129 TRAVEL EXPENSES FOR TESTS ATTENDEDj = ( 1 person * 1 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 1 round trip/ yr) 500 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES 14,629 aCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 + 0.1 * $ 28.14 = $ 51.19).

bAn estimated 4 new recovery furnaces, 4 new SDT's, and 3 new lime kilns will be required to conduct an initial performance test in the third year. Assumes EPA personnel attend 8 percent of the tests ( 0.08 * 11 combustion units = 1 test attended).

cOf the 5 percent that are assumed to fail the initial performance test, assume all repeat the performance test ( 0.05 * 11 combustion units = 1 retest).

dAssumes 10 percent of the retests are attended by EPA personnel ( 0.1 * 1 retest = 0 retests attended).

eAssumes 1 percent of the affected facilities will be involved in litigation ( 0.01 * 7 mills = 0 mills).

fAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT, and three existing kraft pulp mills will each install one new lime kiln each year over the 3 year review period after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills for the third year after the effective date was estimated to be 7 for one time requirements and 22 for recurrent requirements ( 8 mills in the first year + 7 mills in the second year + 7 mills in the third year).

gAssumes 5 percent of the affected facilities are required to retest as a result of excess emissions, and that EPA personnel attend 10 percent of these tests ( 0.05 * 11 new combustion units * 0.1 = 0 units).

hAssumes 5 percent of respondents ( 0.05 * 22 = 1) report monitoring exceedances and 95 percent of respondents ( 0.95 * 22 = 21) report no exceedances..

iThe burden and cost in the third year are equal to the totals added down each column.

jTests attended = 1 ( initial tests) + 0 ( repeat tests) + 0 ( excess emissions enforcement tests) = 1 test. PART B OF THE SUPPORTING STATEMENT This section is not applicable because statistical methods are not used in the data collection associated with this rule.

3 attachments ATTACHMENT 1 Source Data and Information Requirements Attachment 1 SUMMARY OF RECORDKEEPING REQUIREMENTS Requirements Regulation reference Record retention 63.10( b)( 1)

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

Records of startup, shutdown, and malfunction 63.6( e)( 3)( iii)( iv) and 63.10( b)( 2)( i)( v)

Records of performance tests 63.10( b)( 2)( viii)

Documentation supporting initial notifications and notifications of compliance status 63.10( b)( 2)( xiv)

Records of exceedances requiring corrective action and violations 63.866( b)

Black liquor solids firing rates for all recovery furnaces and semichemical combustion units 63.866( c)( 1)

Lime production rates for all lime kilns 63.866( c)( 2)

All parameter monitoring data required in 63.864 63.866( c)( 3)

Supporting calculations for compliance determinations made under 63.865( a) through ( e) 63.866( c)( 4)

Compliant monitoring parameter ranges established for each affected source 63.866( c)( 5)

Certification that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard in 63.862( c)( 1) 63.866( c)( 6)

SUMMARY OF REPORTING REQUIREMENTS Requirement Regulation Reference Initial notifications ( including construction/ reconstruction) 63.5 and 63.9( b)

Notification of performance test 63.7( b) and 63.9( e)

Notification of initial CMS/ COMS demonstration 63.9( g)

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

Reporting results of performance test 63.10( d)( 2)

Startup, shutdown, and malfunction reports 63.10( d)( 5)

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

Excess emissions reports 63.10( e)( 3) and 63.867( c) ATTACHMENT 2 Description of Respondent Activities Attachment 2 DESCRIPTION OF RESPONDENT ACTIVITIES ( 1) Read Instructions represents the activities, less training, which involve comprehending the provisions in the standard and understanding how they apply to the respective combustion sources at a pulp mill.

( 2) Plan Activities represents such burdens as design, redesign, scheduling as well as drafting the implementation plan, and selecting methods of compliance. The costs for planning and selection are included in the capital costs for the performance test, as explained in item ( 4) below.

( 3) Train Personnel represents activities involved in communicating specific definitions, compliance limits, and other requirements, such as recordkeeping, monitoring, and reporting. An average mill may elect to provide classroom instructions for all workers directly impacted by the requirements. However, the rule does not require specific training itself.

( 4) Create Information represents the activities involving testing, retesting, establishing operating range parameters, and analyzing point by point applicability. Monitor related refit, calibration, and maintenance activities are also included under this heading. Because respondents are expected to hire outside contractors to conduct the performance tests, these costs are not included in the burden tables. Instead, the costs associated with the performance test are included as capital costs and are discussed in the text.

( 5) Gather Existing Information represents the activities involving physical inspections of equipment, collection of monitored data, and other related activities.

( 6) Complete Reports represents the activities normally associated with filling out forms. Since the rule requires no standard forms, these activities relate to the preparation of formal reports and cover letters, as appropriate.

( 7) Enter Information represents the activities that involve analysis of the information collected for accuracy, compliance, and appropriate reports and records required as a result; software translation, duplication, or archival proceses normally associated with data management and storage; and the management life cycle of records, from the time they are filed and boxed up to the time at which they are disposed. ATTACHMENT 3 Burden and Cost of Reporting and Recordkeeping Requirements for the Fourth, Fifth, and Sixth Years Following the Effective Date 1 Attachment 3 BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE FOURTH, FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE 1. The Information Collected   Respondent and Agency Activities ( a) Respondent Activities As shown in the Supporting Statement, in the 3 years between the effective date of the rule and the compliance date for existing sources, both existing and new sources must determine their applicability and notify EPA that the facility is subject to the rule. New sources are also required to submit notifications of construction/ reconstruction and notifications of anticipated and actual startup, as well as semiannual compliance reports.

In the 3 years following the compliance date for existing sources, existing sources must submit other one time notifications and reports, and ongoing recordkeeping and reporting begins. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), existing facilities must notify EPA of upcoming performance tests and COMS/ CPMS performance evaluations, conduct the tests and evaluations, and submit the notification of compliance status, which includes the results.

Existing facilities also must develop their startup, shutdown,

and malfunction plans and begin ongoing monitoring and recordkeeping for opacity and various operating parameters.

Existing facilities will begin to submit semiannual compliance reports.

The respondent activities required by the rule in the fourth, fifth, and sixth years following the effective date of the rule are listed in the first columns of Tables 1a through 1d of this attachment. One time and recurrent respondent activities are presented in Tables 1a and 1b for the fourth year and Tables 2 1c and 1d for the fifth and sixth years. ( Separate tables were not prepared for the fifth and sixth years after the effective date because the estimated recordkeeping and reporting burden for those 2 years is identical.)

( b) Agency Activities As shown in the Supporting Statement, over the 3 years between the effective date of the rule and the compliance date for existing sources, EPA will review the notifications of applicability submitted by both new and existing sources and review the notifications of construction/ reconstruction,

notifications of anticipated and actual startup, and semiannual compliance reports submitted by new sources.

In the 3 years following the compliance date for existing sources, EPA will continue to review the notifications and semiannual compliance reports submitted by new sources. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), EPA will also review notifications and reports submitted by existing sources, including the notifications of performance tests,

notifications of COMS/ CPMS performance evaluations, notifications of compliance status, and semiannual compliance reports. The EPA will review the ongoing semiannual compliance reports for existing sources in the fifth and sixth years following the effective date of the rule. Agency activities are listed in the first columns of Table 2a for the fourth year following the effective date and Table 2b for the fifth and sixth years.

( Separate tables were not prepared for the fifth and sixth years after the effective date because the estimated recordkeeping and reporting burden for those 2 years is identical.) 3 2. Estimating the Burden and Cost of the Collection ( a) Estimating Respondent Burden and Costs ( i) Estimating respondent burden and labor costs. Tables 1a through 1d of this attachment present the annual respondent burden estimates and labor costs for reporting and recordkeeping activities for the fourth, fifth, and sixth years following the effective date of the rule. The one time and recurrent burden and cost estimates are presented in Tables 1a and 1b for the fourth year and Tables 1c and 1d for the fifth and sixth years.

The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts.

The costs of the reporting and recordkeeping activities in each table were estimated based on data from the U. S. Bureau of Labor Statistics. Labor costs are divided into the following three categories: ( 1) technical, ( 2) management, and ( 3)

clerical. The cost of technical labor was estimated at $ 45.04/ hr, the cost of management labor at $ 66.73/ hr, and the cost of clerical labor at $ 28.14/ hr. These estimates include fringe benefits, overhead, and profit rate.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities: capital costs and O& M costs. One time capital costs usually include any produced physical good, such as computers,

machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest rate.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs 4 ( planning and selection), and a data acquisition system ( data logger, computer, logging and reporting software, and printer).

The capital costs for the monitoring equipment were estimated based on the following assumptions: ( 1) COMS for monitoring opacity will be required for an estimated 137 existing kraft and soda recovery furnaces and 73 existing kraft and soda lime kilns not already subject to the Kraft Pulp Mills NSPS; ( 2) the capital costs for COMS were determined based on a cost of $ 34,800 per COMS, escalated to current dollars; the annualized capital costs were determined based on a cost of $ 1,400 per COMS, also escalated to current dollars; ( 3) CPMS for monitoring scrubber liquid flow rate and scrubber pressure drop will be required for an estimated 147 existing kraft and soda smelt dissolving tanks and 53 existing kraft and soda lime kilns not already subject to the Kraft Pulp Mills NSPS; ( 4) the capital costs for CPMS were determined based on a cost of $ 13,800 per CPMS; ( 5) scrubbers used to control emissions from sulfite combustion units are already equipped with devices for monitoring scrubber flow rate and pressure drop, so no additional monitoring costs are necessary for sulfite combustion units; and ( 6) because thermocouples and strip chart recorders are included in the cost of the RTO's used to control emissions from semichemical combustion units, no additional costs are necessary for those units.

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file cabinet). The annualized capital cost per file cabinet is $ 35.

An estimated 114 existing mills will purchase file cabinets in the fourth year after the effective date. ( The number of mills was determined based on 22 existing mills, which installed new combustion units during the first 3 years after the effective date, having already purchased file cabinets, leaving the 5 remaining 114 mills to purchase the file cabinets in the fourth year). No mills are expected to purchase file cabinets after the fourth year.

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. The capital costs associated with performance testing include the costs for Method 5 PM performance tests for kraft and soda recovery furnaces, SDT's,

and lime kilns and sulfite combustion units and Method 25A THC performance tests for semichemical combustion units. Only the PM test costs for combustion units not subject to the Kraft Pulp Mills NSPS are included. The PM test costs for kraft combustion units already subject to the NSPS are not included because those costs are assumed to be existing costs for complying with existing State permits or other State/ local programs.

No initial costs were estimated for Method 308 methanol performance tests for kraft and soda recovery furnaces. Only new recovery furnaces are subject to the gaseous organic HAP standard for kraft and soda recovery furnaces, and new recovery furnaces are expected to be NDCE recovery furnaces equipped with dry ESP systems, which are exempted from testing requirements.

Performance test costs were estimated based on the following assumptions: ( 1) capital costs are $ 8,500 per Method 5 test and $ 9,500 per Method 25A test; ( 2) an estimated 418 existing combustion units will be required to conduct initial PM performance tests during the fourth year after the effective date; ( 3) the existing combustion units include 137 kraft and soda recovery furnaces, 147 kraft and soda SDT's, 126 kraft and soda lime kilns, and 8 sulfite combustion units ( one source was assumed per sulfite mill based on the fact that sulfite mills typically route emissions from multiple combustion units to the same stack); ( 4) an estimated 13 existing semichemical combustion units and 1 new semichemical combustion unit will be required to 6 conduct initial THC performance tests during the fourth year after the effective date; ( 5) an estimated 5 percent of the initial performance tests must be repeated due to failure of the first test; and ( 6) test costs will be annualized for 15 tests,

which include the tests for the 13 existing semichemical combustion units and the 2 new semichemical combustion units installed during the first and fourth years after the effective date.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. Operation and maintenance costs were determined for the estimated 137 existing recovery furnaces and 73 existing lime kilns not already subject to the Kraft Pulp Mills NSPS that are expected to install COMS. ( No O& M costs were determined for new sources because they would be subject to the Kraft Pulp Mills NSPS.) The O& M costs for COMS were estimated based on a cost of $ 7,000 per source, escalated to current dollars. The scrubbers used to control emissions from sulfite combustion units are already equipped with devices for monitoring scrubber flow rate and pressure drop, so no additional monitoring O& M costs are necessary for sulfite combustion units. Because thermocouples and strip chart recorders are included in the cost of the RTO's used to control emissions from semichemical combustion units, no additional O& M costs are necessary for those units.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. The O& M costs for rules that require respondents to submit notifications and reports to EPA and maintain records are estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 7 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs were applied to the 672 responses submitted during the fourth year and the 281 responses submitted during each of the fifth and sixth years.

( The number of responses was determined by adding the number of reports submitted to EPA by respondents during the fourth, fifth,

and sixth years after the effective date, as shown in Tables 1a through 1f of this attachment.)

( b) Estimating Agency Burden and Costs Tables 2a and 2b of this attachment present the estimated annual burden to the Federal Government during the fourth, fifth,

and sixth years following the effective date of the rule. The only burden and costs that the Federal Government will incur as a result of the information collection requirements are associated with the analysis of the information reported by facilities in one time notifications and semiannual compliance reports ( unless the compliance report indicates a violation, thereby triggering an enforcement action). Labor costs were estimated based on estimated wage rates of $ 45.04/ hr for technical labor, $ 66.73/ hr for management labor, and $ 28.14/ hr for clerical labor.

( c) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 1a and 1b to the total personhours and costs from Tables 1c and 1d multiplied by 2, and then dividing the sum by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date). The total annual respondent burden hours and costs are summarized as follows: 8 Total burden, hours Total costs, $

Tables 1a + 1b ( fourth year) 235,146 10,467,169 Tables 1c + 1d ( fifth and sixth years) 134,535 5,988,624 Total 504,216 22,444,417 Bottom line annual burden 168,072 7,481,472 The bottom line annual burden, averaged over the fourth,

fifth, and sixth years after the effective date, is 168,072 labor hours, at a cost of $ 7,481,472. The average annual burden per respondent, based on 136 respondents, is 1,236 labor hours, at a cost of $ 55,011.

On average, there are an estimated 411 total annual responses for the fourth, fifth, and sixth years after the effective date. Of the 411 total annual responses, approximately 50 percent are assumed to be collected electronically. The total annual responses are an average of the one time and recurrent notifications and reports submitted during the fourth, fifth, and sixth years after the effective date. An estimated 672 one time and recurrent notifications and reports will be submitted during the fourth year and 281 during each of the fifth and sixth years.

The total nationwide capital costs associated with monitoring equipment were estimated to be $ 10.6 million. The average annualized capital cost for the monitoring equipment is $ 314,600 for the fourth, fifth, and sixth years following the effective date.

The total nationwide capital costs associated with file cabinets were estimated to be $ 26,800. The average annualized capital cost for the file cabinets is $ 4,800 for the fourth,

fifth, and sixth years following the effective date.

The total nationwide capital costs for performance tests were estimated to be $ 3.69 million. The average annualized 9 capital cost for the performance tests is $ 405,600 for the fourth, fifth, and sixth years following the effective date.

Annual O& M costs, which include O& M costs for monitoring equipment as well as photocopying and postage costs, average $ 1.58 million for the fourth, fifth, and sixth years following the effective date of the rule.

Combining the annualized capital costs for the monitoring equipment, file cabinets, and performance tests results in a total annualized capital cost of $ 725,000 for the fourth, fifth,

and sixth years following the effective date. Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 2.31 million for the fourth, fifth, and sixth years following the effective date.

( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours and costs from Table 2a to the total person hours and costs from Table 2b multiplied by 2 and then dividing the sum by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date). The total annual Agency burden hours and costs are summarized as follows:

Total burden, hours Total costs, $

Table 2a ( fourth year) 6,431 305,757 Table 2b ( fifth and sixth years) 883 39,814 Total 8,197 385,386 Bottom line annual burden 2,732 128,462 The bottom line annual burden, averaged over the fourth,

fifth, and sixth years, is 2,732 labor hours, at a cost of $ 128,462. 10 ( d) Burden Statement ( i) The total annual reporting and recordkeeping burden and cost for this collection averaged over the fourth, fifth, and sixth years after the effective date of the rule were estimated to be 168,072 labor hours and $ 7,481,472. The average burden and cost, per respondent, are 1,236 labor hours and $ 55,011.

During these 3 years, new facilities are required to submit notifications of construction/ reconstruction and notifications of anticipated and actual startup. Both new and existing facilities are required to submit notifications of performance tests,

notifications of performance evaluations, and notifications of compliance status, as well as semiannual compliance reports to indicate their ongoing compliance status. Each respondent also must keep necessary records of data to determine compliance with the rule. The collection requirements are applicable to an estimated 136 respondents.

( ii) The total capital cost for monitoring equipment, file cabinets, and performance tests is $ 14.3 million. The annualized capital cost and average annual O& M cost for the fourth, fifth,

and sixth years after the effective date are $ 725,000 and $ 1.58 million, respectively. Combining the annualized capital cost with the annual O& M cost gives a total annualized cost of $ 2.31 million for the fourth, fifth, and sixth years after the effective date. 11 11 TABLE 1a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions 2 1 2 8c 16 0.8 1.6 18 819 B. Required activities ° Performance evaluation CPMS 10d 1 10 226e 2,207 110 221 2,539 113,000 COMS 27d 1 27 217e 5,935 297 593 6,825 303,800 ° Repeat performance evaluation CPMS 10d 1 10 11 e 107 5.4 11 124 $ 5,500 COMS 27d 1 27 11 e 301 15 30 346 $ 15,400 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report ° Notification of construction/

reconstruction 2 1 2 8 c 16 0.8 1.6 18 819 ° Notification of anticipated startup 2 1 2 8c 16 0.8 1.6 18 819 ° Notification of actual startup 2 1 2 8c 16 0.8 1.6 18 819 ° Notification of applicability of the standard 2 1 2 8 c 16 0.8 1.6 18 819 ° Notification of initial performance test 2 1 2 136f 272 14 27 313 13,924 ° Notification of performance evaluation 2 1 2 136f 272 14 27 313 13,924 ° Notification of compliance status 80 1 80 136f 10,880 544 1,088 12,512 556,953 12 TABLE 1a. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 12 4. Recordkeeping Requirements A. Read instructions Included in 3A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system 40g 1 40 136 f 5,440 272 544 6,256 278,476 E. Develop startup, shutdown, and malfunction plan 100h 1 100 136f 13,600 680 1360 15,640 696,191 F. Time to enter information ° Records and documentation of supporting calculations for compliance determinations 8 1 8 136 f 1,088 54 109 1,251 55,695 ° Records of compliant monitoring parameter ranges 2 1 2 136 f 272 14 27 313 13,924 ° Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces 2 1 2 4 i 8 0.4 0.8 9.2 410 G. Time to train personnel 40j 1 40 136 f 5,440 272 544 6,256 278,476 H. Time for audits N/ A ONE TIME BURDEN AND COST ( SALARY)

NATIONWIDE: k 45,902 2,295 4,590 52,788 2,349,768 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year for the fourth, fifth, and sixth years after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the fourth year after the effective date. Therefore,

the total number of existing mills subject to these one time requirements for new sources was estimated to be eight for the fourth year after the effective date and seven for the fifth and sixth years. 13 TABLE 1a. ( continued)

13 dPerson hours per occurrence are based on the cost of the performance evaluation divided by the composite hourly labor rate. The performance evaluation costs are $ 500 for each CPMS and $ 1,400 for each COMS.

eAssumes 147 existing SDT's, 53 existing lime kilns, 8 existing sulfite combustion units, 13 existing semichemical combustion units, and 1 new semichemical combustion unit will be required to conduct a CPMS performance evaluation during the fourth year after the effective date; also assumes 4 new SDT's will be required to conduct a CPMS performance evaluation each year over the fourth,

fifth, and sixth years after the effective date. Assumes 137 existing recovery furnaces and 73 existing lime kilns will be required to conduct a COMS performance evaluation during the fourth year after the effective date; also assumes 4 new recovery furnaces and 3 new lime kilns will be required to conduct a COMS performance evaluation each year over the fourth, fifth, and sixth years after the effective date. Assumes 5 percent of the CPMS/ COMS performance evaluations must be repeated due to the failure of the first performance evaluation.

fThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 stand alone semichemical pulp mills. No new major source pulp mills are projected to be built within the next 5 years.

gAssumes 1 week ( 40 hours) to develop a record system for recording parameter monitoring information.

hAssumes 1 person would take 2 weeks ( 80 hours) to draft the startup, shutdown, and malfunction plan and then another 20 hours of review/ revisions, for a total of 100 hours.

iAssumes 4 existing kraft and soda pulp mills will install new recovery furnaces each year over the fourth, fifth, and sixth years after the effective date. Based on current industry trends, these new furnaces are expected to be NDCE recovery furnaces equipped with a dry ESP system.

jAssumes 1 week ( 40 hours) to train personnel.

kThe one time burden and cost in the fourth year are equal to the totals added down each column. 14 14 TABLE 1b. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH YEAR FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions N/ A B. Required activities N/ A C. Create information N/ A D. Gather existing information N/ A E. Write report ° Excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 16c 4 64 6d, e 384 19 38 442 19,657 Semiannual report of no exceedances 8f 2 16 104d, e 1,664 83 166 1,914 85,181 4. Recordkeeping Requirements A. Read instructions N/ A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Time to enter information ° Records of startup, shutdown, and malfunction 1.5 52 78 136d 10,608 530 1,061 12,199 543,029 15 TABLE 1b. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 15 ° Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units 1.5 52 78 128d 9,984 499 998 11,482 511,086 ° Records of lime production rates for lime kilns 1.5 52 78 116d 9,048 452 905 10,405 463,172 ° Records of CPMS/ COMS data Record continuously monitored parameters ( per shift) 0.5 1,050 525 110d, e 57,750 2,888 5,775 66,413 2,956,251 Compile monthly data 16 12 192 110d, e 21,120 1,056 2,112 24,288 1,081,143 Enter/ verify information for quarterly/ semiannual reports 8 2 16 110d, e 1,760 88 176 2,024 90,095 F. Time to train personnel N/ A G. Time for refresher training for personnel 16g 1 16 22 h 352 18 35 405 18,019 H. Time for audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: i 112,670 5,634 11,267 129,571 5,767,634 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes 16 person hours per report per affected facility per pollutant for an exceedances report.

dThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 stand alone semichemical pulp mills. No new major source pulp mills are projected to be built within the next 5 years.

eAssumes a 75 percent reduction in the recordkeeping and reporting burden for an estimated 35 mills with at least half of their combustion sources currently subject to the NSPS. Therefore, the equivalent recordkeeping and reporting burden = calculated number of respondents: 136  ( 35 * 0.75) = 110. Also assumes 5 percent of respondents ( 0.05 * 110 = 6) report monitoring exceedances and 95 percent of respondents ( 0.95 * 110 = 104) report no exceedances..

fAssumes 8 person hours per report per affected facility per pollutant for a report of no exceedances.

gAssumes 2 days ( 16 hours) to provide refresher training for personnel.

hAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the first year after the effective date. Therefore, the total number of existing mills with refresher training in the fourth year after the effective date is 22 ( 8 in the fourth year + 7 in the fifth year + 7 in the sixth year). 16 TABLE 1b. ( continued)

16 iThe recurrent burden and cost in the fourth year are equal to the totals added down each column. 17 17 TABLE 1c. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS   FIFTH AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATEa Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions 2 1 2 7e 14 0.7 1.4 16 717 B. Required activities CPMS 10d 1 10 4c, e 39 2.0 3.9 45 2,000 COMS 27d 1 27 7c, e 191 9.6 19 220 9,800 ° Repeat performance evaluation CPMS 10d 1 10 0c, e 0 0 0 0 0 COMS 27d 1 27 0c, e 0 0 0 0 0 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report ° Notification of construction/

reconstruction 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of anticipated startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of actual startup 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of applicability of the standard 2 1 2 7 c 14 0.7 1.4 16 717 ° Notification of initial performance test 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of performance evaluation 2 1 2 7c 14 0.7 1.4 16 717 ° Notification of compliance status 80 1 80 7c 560 28 56 644 28,667 4. Recordkeeping Requirements 18 TABLE 1c. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C) Technical person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I)

Cost, $ b 18 A. Read instructions Included in 3A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Develop startup, shutdown, and malfunction plan N/ A F. Time to enter information ° Records and documentation of supporting calculations for compliance determinations 8 1 8 7 c 56 2.8 5.6 64 2,867 ° Records of compliant monitoring parameter ranges 2 1 2 7 c 14 0.7 1.4 16 717 ° Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces 2 1 2 4 f 8 0.4 0.8 9.2 410 G. Time to train personnel 40g 1 40 7 c 280 14 28 322 14,333 H. Time for audits N/ A ONE TIME BURDEN AND COST ( SALARY)

NATIONWIDE: h 1,247 62 125 1,433 63,810 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes four existing kraft pulp mills will each install one new recovery furnace and SDT and three existing kraft pulp mills will each install one new lime kiln each year over the fourth, fifth, and sixth years after the effective date. Also assumes one existing stand alone semichemical pulp mill will install one semichemical combustion unit during the fourth year after the effective date.

Therefore, the total number of existing mills subject to these one time requirements for new sources was estimated to be eight for the fourth year after the effective date and seven for the fifth and sixth years. 19 TABLE 1c. ( continued)

19 dPerson hours per occurrence are based on the cost of the performance evaluation divided by the composite hourly labor rate. The performance evaluation costs are $ 500 for each CPMS and $ 1,400 for each COMS.

eAssumes four new SDT's will be required to conduct a CPMS performance evaluation each year over the fourth, fifth, and sixth years after the effective date; also assumes one new semichemical combustion unit will be required to conduct a CPMS performance evaluation the fourth year after the effective date. Assumes four new recovery furnaces and three new lime kilns will be required to conduct a COMS performance evaluation each year over the fourth, fifth, and sixth years after the effective date. Assumes 5 percent of the CPMS/ COMS performance evaluations must be repeated due to the failure of the first performance evaluation.

fAssumes 4 existing kraft and soda pulp mills will install new recovery furnaces each year over the fourth, fifth, and sixth years after the effective date. Based on current industry trends, these new furnaces are expected to be NDCE recovery furnaces equipped with a dry ESP system.

gAssumes 1 week ( 40 hours) to train personnel.

hThe one time burden and cost in the fifth and sixth years are equal to the totals added down each column. 20 20 TABLE 1d. RECURRENT RESPONDENT BURDEN AND COST TO INDUSTRY OF REPORTING AND RECORDKEEPING REQUIREMENTS   FIFTH AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read instructions N/ A B. Required activities N/ A C. Create information N/ A D. Gather existing information N/ A E. Write report ° Excess emissions report Quarterly report of monitoring exceedances and periods of noncompliance 16c 4 64 6d, e 384 19 38 442 19,657 Semiannual report of no exceedances 8f 2 16 104d, e 1,664 83 166 1,914 85,181 4. Recordkeeping Requirements A. Read instructions N/ A B. Plan activities N/ A C. Implement activities N/ A D. Develop record system N/ A E. Time to enter information ° Records of startup, shutdown, and malfunction 1.5 52 78 136d 10,608 530 1,061 12,199 543,029 21 TABLE 1d. ( continued)

Burden itema ( A)

Person hours per occurrence ( B) Number of occurrences per year ( C)

Person hours per respondent per year ( C= A* B) ( D) Respondents per year ( E) Technical person hours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical person hours per year ( G= E* 0.1) ( H) Respondent person hours per year ( H= E+ F+ G) ( I) Cost,

$ b 21 ° Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units 1.5 52 78 128d 9,984 499 998 11,482 511,086 ° Records of lime production rates for lime kilns 1.5 52 78 116d 9,048 452 905 10,405 463,172 ° Records of CPMS/ COMS data Record continuously monitored parameters ( per shift) 0.5 1,050 525 110d, e 57,750 2,888 5,775 66,413 2956,251 Compile monthly data 16 12 192 110d, e 21,120 1,056 2,112 24,288 1,081,143 Enter/ verify information for quarterly/ semiannual reports 8 2 16 110d, e 1,760 88 176 2,024 90,095 F. Time to train personnel N/ A G. Time for refresher training for personnel 16g 1 16 136h 2,176 109 218 2,502 111,391 H. Time for audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: i 114,494 5,725 11,449 131,668 5,861,005 aSee Attachment 2 for a further explanation of respondent activities.

bCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 +

0.1 * $ 28.14 = $ 51.19).

cAssumes 16 person hours per report per affected facility per pollutant for an exceedances report.

dThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 stand alone semichemical pulp mills. No new major source pulp mills are projected to be built within the next 5 years.

eAssumes a 75 percent reduction in the recordkeeping and reporting burden for an estimated 35 mills with at least half of their combustion sources currently subject to the NSPS. Therefore, the equivalent recordkeeping and reporting burden = calculated number of respondents: 136  ( 35 * 0.75) = 110. Also assumes 5 percent of respondents ( 0.05 * 110 = 6) report monitoring exceedances and 95 percent of respondents ( 0.95 * 110 = 104) report no exceedances..

fAssumes 8 person hours per report per affected facility per pollutant for a report of no exceedances.

gAssumes 2 days ( 16 hours) to provide refresher training for personnel.

hThe total number of existing mills with refresher training in the fifth and sixth years after the effective date is 136.

iThe recurrent burden and cost in the fifth and sixth years are equal to the totals added down each column. 22 22 TABLE 2a. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH YEAR FOLLOWING THE EFFECTIVE DATE Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a 1. Attend initial performance test 40 1 40 35b 1,400 70 140 1,610 71667 2. Attend repeat performance test A. Retesting preparation 8 1 8 22c 176 8.8 18 202 9,010 B. Attend retesting 40 1 40 2d 80 4.0 8.0 92 4,095 3. Litigation 2,080 1 2,080 1e, f 2,080 104 208 2,392 106,476 4. Excess emissions enforcement activities 48 1 48 2b, g 96 4.8 9.6 110 4,914 5. Report review ° Review of notification of construction/

reconstruction 2 1 2 8 h 16 0.8 1.6 18 819 ° Review of notification of anticipated startup 2 1 2 8h 16 0.8 1.6 18 819 ° Review of notification of actual startup 2 1 2 8h 16 0.8 1.6 18 819 ° Review of notification of applicability 2 1 2 8h 16 0.8 1.6 18 819 ° Review of notification of initial performance test 2 1 2 136e 272 14 27 313 13,924 ° Review of notification of performance evaluation 2 1 2 136e 272 14 27 313 13,924 ° Review of notification of compliance status 4 1 4 136e 544 27 54 626 27,848 ° Review of excess emissions report 23 TABLE 2a. ( continued)

Activity ( A)

EPAhours per operation ( B) Number of operations per year ( C)

EPA hours per facility per year ( C= A* B) ( D) Facilities per year ( E) Technical personhours per year ( E= C* D) ( F) Management person hours per year ( F= E* 0.05) ( G) Clerical personhours per year ( G= E* 0.1) ( H) Total personhours per year ( H= E+ F+ G) ( I) Cost,

$ a 23 Quarterly report of monitoring exceedances and periods of noncompliance 8 4 32 6e, i 192 9.6 19 221 9,829 Semiannual report of no exceedances 2 2 4 104e, i 416 21 42 478 21,295 TOTAL BURDEN AND COST ( SALARY) j 5,592 280 559 6,431 286,257 TRAVEL EXPENSES FOR TESTS ATTENDEDk = ( 1 person * 39 facilities/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 39 round trips/ yr) 19,500 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES 305,757 aCosts assume a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor. The composite hourly labor rate is $ 51.19/ hour ($ 45.04 + 0.05 *$ 66.73 + 0.1 * $ 28.14 = $ 51.19).

bAn estimated 137 existing recovery furnaces, 126 existing lime kilns, 147 existing SDT's, 8 existing sulfite combustion units, 13 existing semichemical combustion units,

and 1 new semichemical combustion unit will be required to conduct an initial performance test in the fourth year after the effective date. Also, an estimated 4 new recovery furnaces, 4 new SDT's, and 3 new lime kilns will be required to conduct an initial performance test each year over the fourth, fifth, and sixth years after the effective date.

Assumes EPA personnel attend 8 percent of the tests ( 0.08 * 443 combustion units = 35 tests attended).

cOf the 5 percent that are assumed to fail the initial performance test, assume all repeat the performance test ( 0.05 * 443 combustion units = 22 retests).

dAssumes 10 percent of the retests are attended by EPA personnel ( 0.1 * 22 retest = 2 retests attended).

eThere are an estimated 136 existing major source pulp mills, which include 114 kraft, 2 soda, 8 sulfite, and 12 semichemical mills. No new major source pulp mills are projected to be built within the next 5 years.

fAssumes 1 percent of the affected facilities will be involved in litigation ( 0.01 * 136 mills = 1 mills).

gAssumes 5 percent of the affected facilities are required to retest as a result of excess emissions, and that EPA personnel attend 10 percent of these tests ( 0.05 * 443 existing and new combustion units * 0.1 = 2 units).