Appendix C

Appendix C (09142007).pdf

National Pretreatment Program (Renewal)

Appendix C

OMB: 2040-0009

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Appendix C

Information Collection Request
Supporting Statement
for
Pollution Prevention Compliance Alternative;
Transportation Equipment Cleaning (TEC) Point Source Category
(40 CFR Part 442)

EPA ICR No. 2018.02
OMB No. 2040-0235

November 3, 2004

U.S. Environmental Protection Agency
Office of Water
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460-0001

CONTENTS

IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . . . 1
1(a) Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1(b) Short Characterization/Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2(a) Need/Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2(b) Practical Utility/Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
......................................................................3
3(a) Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3(b) Public Notice Required Prior to ICR Submission to OMB . . . . . . . . . . . . . . . . . . 3
3(c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3(d) Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3(e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3(f)
Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . . . . . . . . 4
4(a) Respondents and NAICS/SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4(b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
(1)
Prepare and submit a statement of intent [40 CFR 442.15(b)(2),
442.16(b)(2), 442.25(b)(2), 442.26(b)(2)] . . . . . . . . . . . . . . . . . . . . . . . . . 5
(2)
Prepare and submit a Pollutant Management Plan [40 CFR 442.15(b)(1),
442.15(b)(3), 442.16(b)(1), 442.16(b)(3), 442.25(b)(1), 442.25(b)(3),
442.26(b)(1), and 442.26(b)(3)] . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
(3)
Collect information and maintain records [40 CFR 442.15(b)(5)(ix),
442.15(b)(5)(x), 442.16(b)(5)(ix), 442.16(b)(5)(x), 442.25(b)(5)(ix),
442.25(b)(5)(x), 442.26(b)(5)(ix), and 442.26(b)(5)(x)] . . . . . . . . . . . . . . 6
(4)
Perform operator training [40 CFR 442.15(b)(5)(x), 442.16(b)(5)(x),
442.25(b)(5)(x), and 442.26(b)(5)(x)] . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
4(c) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . . . 8
5(a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5(b) Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5(c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . . . 9
6(a) Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
(1)
Prepare and submit a statement of intent . . . . . . . . . . . . . . . . . . . . . . . . . . 9
(2)
Prepare and submit a Pollutant Management Plan . . . . . . . . . . . . . . . . . . 9
(3)
Collect information and maintain records . . . . . . . . . . . . . . . . . . . . . . . . 10
(4)
Perform operator training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
(5)
Pretreatment Control Authority Implementation . . . . . . . . . . . . . . . . . . . 11
6(b) Estimating Respondent Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
6(c) Estimating Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
6(d) Estimating the Respondent Universe and Total Burden and Costs . . . . . . . . . . . 12
6(e) Bottom Line Burden Hours and Costs Table . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
6(f)
Reasons for Changes in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
6(g) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
TABLES

1.
2.
3.

Annual Burden and Cost for Transportation Equipment Cleaning Respondents . . . . . . 15
Annual Pretreatment Control Authority Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . 16
Summary of Burden and Costs to Respondents and Pretreatment Control Authorities . 16

IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)

Title of the Information Collection

Information Collection Rule: Pollution Prevention Compliance Alternative; Transportation
Equipment Cleaning Point Source Category (40 CFR Part 442) (EPA ICR No. 2018.02 and
OMB Control Number 2040-0235).
1(b)

Short Characterization/Abstract

The U.S. Environmental Protection Agency (EPA) issued a final guideline for the
Transportation Equipment Cleaning (TEC) point source category on August 14, 2000 (at 65 FR
49666). An initial Information Collection Rule (ICR) was published on March 19, 2001. This
document serves as a renewal ICR for the Pollution Prevention Compliance Alternative.
The final TEC rule established technology-based effluent limitations guidelines, new
source performance standards, and pretreatment standards for the discharge of pollutants into
waters of the United States and into publicly owned treatment works by existing and new
facilities that perform transportation equipment cleaning operations. TEC facilities are defined
as those facilities that generate wastewater from cleaning the interior of tank trucks, closed-top
hopper trucks, rail tank cars, closed-top hopper rail cars, intermodal tank containers, tank barges,
closed-top hopper barges, and ocean/sea tankers used to transport materials or cargos that come
into direct contact with the tank or container interior. Facilities that do not engage in cleaning
the interior of tanks are outside the scope of the rule.
The final rule included a regulatory compliance option that allows certain facilities to
develop a Pollutant Management Plan (PMP) in lieu of meeting numeric standards. The PMP is
only available to indirect dischargers identified under Subparts A and B of the rule. Subpart A
covers tank trunks and intermodal tank containers, while Subpart B covers rail tank cars. EPA
estimates approximately 10 new facilities per year (9 in Subpart A and 1 in Subpart B) over the
initial rulemaking estimate of 316 facilities that transport chemical and petroleum cargos (i.e.,
326 facilities in year one, 336 facilities in year two, and 346 facilities in year three - for an
average of 336 facilities over the three year period covered by this ICR). As noted in Chapter 6,
approximately 25 percent of the existing 316 facilities (79 facilities) and all of the 20 new
facilities covered by Subparts A and B are impacted by this rule (for a total of 99 facilities) and
hence are included in this ICR supporting statement. EPA estimates that 15 of these new
facilities will only incur the initial burden of reading and understanding the regulations. EPA
believes that development and implementation of a PMP is an effective, alternative method of
reducing pollutant discharges from indirect dischargers in these subcategories. Facilities that
already have extensive treatment in place, however, may find it more cost-effective to comply
with numeric limits, whereas facilities already using good pollution prevention practices may
find the PMP compliance alternative more cost-effective.

The PMP includes requirements for record keeping and paperwork that were not
previously included in the burden estimate for the TEC industry. The initial ICR presented
estimates of the burden hours and costs to the regulated community and pretreatment control
authorities for data collection and recordkeeping associated with implementing the pollution
prevention compliance option.
The TEC rule requires facilities to address 10 components when developing a PMP.
Facilities must identify and segregate incompatible waste streams which might include heels
(i.e., tank or container residuals), pre-rinse or pre-stream wastewater, and spent cleaning
solutions from wastewater discharged to a publicly owned treatment works (POTW). The PMP
also requires provisions for recycling or reuse of incompatible waste streams and for minimizing
the use of toxic cleaning agents. Data collection and recordkeeping requirements under the
pollution prevention compliance option include preparing the PMP and maintaining records to
demonstrate compliance. Records are to be stored on site, and there are no reporting
requirements.
This ICR also estimates burden and costs for pretreatment control authorities (i.e., States
and local POTWs) responsible for incorporating these PMP requirements into discharge permits
and performing routine on-site reviews of applicable procedures and records. A total of 84
pretreatment control authorities are included.
2.

NEED FOR AND USE OF THE COLLECTION

2(a)

Need/Authority for the Collection

EPA has provided an alternative pollution prevention compliance option to reduce
pollutant loadings from indirect discharges under Subparts A and B (facilities that clean tank
trucks, intermodal tank containers, and rail tank cars transporting chemical and petroleum
cargos).
The Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards for the Transportation Equipment Cleaning Point Source Category were
promulgated under the authority of Sections 301, 304, 306, 307, 308, 402, and 501 of the Clean
Water Act, 33 U.S.C. 1311, 1314, 1316, 1317, 1318, 1342, and 1361.
2(b)

Practical Utility/Users of the Data

Subpart A and B dischargers who choose to develop PMPs as a compliance option will
be the primary users of the Plan and related data generated.
State or federal pretreatment approval authorities will likely use the PMP and related
records when making compliance determinations.

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA

3(a)

Nonduplication

EPA has examined all other reporting requirements contained in the Clean Water Act and
40 CFR Parts 122, 123, 124, 125, 501, and 503. The Agency has also consulted other sources of
information to determine if similar or duplicate information is available elsewhere. These
examinations have revealed no duplicate reporting requirements.
3(b)

Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq), EPA solicited
comments on the proposed information collection in the Federal Register prior to submitting this
renewal ICR to the Office of Management and Budget (69 FR 52883, August 30, 2004). No
comments were received.
3(c)

Consultations
EPA discussed the pollution prevention alternative with the following organizations:
•
•
•
•

3(d)

Office of Management and Budget
Small Business Administration Office of Advocacy
Association of Metropolitan Sewerage Agencies
Other industry stakeholders.

Effects of Less Frequent Collection

The frequency of data collection is site-specific and is to be articulated in each PMP.
Facilities must provide information on cleaning agents used and must maintain appropriate
records of heel management procedures, pre-rinse/pre-steam management procedures, cleaning
agent management procedures, operator training, and proper operation and maintenance of any
pretreatment system. Facilities that do not use chemical cleaning agents and do not clean tanks
or containers that last contained cargos which are likely to result in discharges of pollutants that
would be incompatible with treatment at a POTW will have minimal, if any, recurring data
collection requirements specified in their PMPs. In contrast, facilities that use toxic chemical
cleaning agents and routinely clean tanks or containers that last contained cargos which are
likely to result in discharges of pollutants that would be incompatible with treatment at a POTW
will have more significant monitoring and reporting requirements in their PMPs. For example,
they will be required to collect information on daily cleaning agent use and incompatible waste
stream management. History has shown that these facilities may generate incompatible waste
streams at any time; therefore, less frequent data collection might result in pass-through,
interference and sludge contamination at POTWs.

3(e)

General Guidelines

This information collection is consistent with Office of Management and Budget
guidelines contained in 5 CFR 1320.5, 1320.6, 1320.8, and 1320.12.
3(f)

Confidentiality

EPA does not expect that any confidential business information or trade secrets will be
required from TEC facilities as part of this ICR. If information submitted in conjunction with
this ICR were to contain confidential business information, the respondent may request that the
information be treated as such. All data so designated will be handled by EPA pursuant to 40
CFR Part 2. This information will be maintained according to procedures outlined in EPA’s
Security Manual Part III, Chapter 9, dated August 9, 1976. Pursuant to Section 308(b) of the
CWA, effluent data may not be treated as confidential.
3(g)

Sensitive Questions
The reporting requirements addressed in this ICR do not include sensitive questions.

THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)

Respondents and NAICS/SIC Codes

The regulated community includes approximately 304 Subpart A facilities (Tank Trucks
and Intermodal Tank Containers Transporting Chemical and Petroleum Cargos) and 32 Subpart
B facilities (Rail Tank Cars Transporting Chemical and Petroleum Cargos), for a total of 336
facilities. EPA assumes that all regulated facilities will evaluate the alternative pollution
prevention compliance option to determine whether it would be less costly than complying with
numerical limits. Based on discussions with industry stakeholders and pretreatment control
authorities, EPA estimates that approximately 25 percent of these facilities will select the
pollution prevention compliance option. There is no single NAIC/SIC code or set of NAIC/SIC
codes that specifically identify facilities that perform TEC operations. Examples of common
SIC codes for facilities in these Subparts include SIC 4741 (Rental of Railroad Cars) and SIC
7699 (Repair Shops and Related Services, Not Elsewhere Classified). There are no directly
correlating codes under the North American Industrial Classification System (NAICS). For the
two examples provided above, SIC 4741 has two NAICS codes (488211 and 532411) associated
with it while SIC 7699 has 20 NAICS codes associated with it.
In addition, this ICR estimates 84 pretreatment control authorities are covered, including
activities under SIC Code 4952 with a corresponding NAICS Code of 221320.
4(b)

Information Requested

The pollution prevention compliance option at 40 CFR 442.15, 442.16, 442.25, and
442.26 includes the following major action items: (1) prepare and submit a statement of intent,
(2) prepare and submit a PMP, (3) collect information and maintain records, and (4) perform
operator training.
(1)

Prepare and submit a statement of intent [40 CFR 442.15(b)(2),
442.16(b)(2), 442.25(b)(2), 442.26(b)(2)]

Prior to renewing or modifying its individual control mechanism or pretreatment
agreement, the discharger is to notify the local control authority of its intent to achieve the
pollution prevention option through implementation of a PMP by submitting a certification
statement signed by a responsible corporate officer.
(2)

Prepare and submit a Pollutant Management Plan [40 CFR 442.15(b)(1),
442.15(b)(3), 442.16(b)(1), 442.16(b)(3), 442.25(b)(1), 442.25(b)(3),
442.26(b)(1), and 442.26(b)(3)]

Central to the pollution prevention compliance option is the preparation and
implementation of a PMP. The PMP is intended to contain the procedures and provisions the
facility will implement to reduce pollutant discharges and prevent pass through, interference, and
sludge contamination at POTWs. The PMP is enforceable, meaning it shall be included in the
facility’s individual control mechanism or POTW permit. Dischargers are to maintain a copy of
the PMP on-site to demonstrate compliance.
According to 40 CFR 442, the PMP is to include the following components:
(i) procedures for identifying cargos, the cleaning of which is likely to result in
discharges of pollutants that would be incompatible with treatment at the POTW;
(ii) for cargos identified as being incompatible with treatment at the POTW,
procedures that heels be fully drained, segregated from other wastewaters, and
handled in an appropriate manner;
(iii) for cargos identified as being incompatible with treatment at the POTW,
procedures that the tank be pre-rinsed or pre-steamed as appropriate and the
wastewater segregated from wastewaters to be discharged to the POTW and
handled in an appropriate manner, where necessary, to ensure that they do not
cause or contribute to a discharge that would be incompatible with treatment at
the POTW;
(iv) procedures that all spent cleaning solutions, including interior caustic washes,
interior pre-solve washes, interior detergent washes, interior acid washes, and
exterior acid brightener washes be segregated from other wastewaters and
handled in an appropriate manner, where necessary, to ensure that they do not
5

cause or contribute to a discharge that would be incompatible with treatment at
the POTW;
(v) provisions for appropriate recycling or reuse of cleaning agents;
(vi) provisions for minimizing the use of toxic cleaning agents (solvents,
detergents, or other cleaning or brightening solutions);
(vii) provisions for appropriate recycling or reuse of segregated wastewaters
(including heels and pre-rinse/pre-steam wastes);
(viii) provisions for off-site treatment or disposal, or effective pretreatment of
segregated wastewaters (including heels, pre-rinse/pre-steam wastes, spent
cleaning solutions);
(ix) information on the volumes, content, and chemical characteristics of cleaning
agents used in cleaning or brightening operations; and
(x) provisions for maintaining appropriate records of heel management
procedures, pre-rinse/pre-steam management procedures, cleaning agent
management procedures, operator training, and proper operation and maintenance
of any pretreatment system.
(3)

Collect information and maintain records [40 CFR 442.15(b)(5)(ix),
442.15(b)(5)(x), 442.16(b)(5)(ix), 442.16(b)(5)(x), 442.25(b)(5)(ix),
442.25(b)(5)(x), 442.26(b)(5)(ix), and 442.26(b)(5)(x)]

Dischargers are to obtain information and maintain records for compliance purposes and
as stipulated under components (ix) and (x) of the PMP. As noted above, facilities may develop
and maintain logs documenting the use of cleaning agents, heel management procedures, prerinse/pre-steam management procedures, cleaning agent management procedures, operator
training, and proper operation and maintenance of any pretreatment system.

(4)

Perform operator training [40 CFR 442.15(b)(5)(x), 442.16(b)(5)(x),
442.25(b)(5)(x), and 442.26(b)(5)(x)]

Dischargers are to train operators on the data collection and recordkeeping requirements
specified in the PMP.
4(c)

Respondent Activities
Respondent activities include the following:
C

Preparing basic information. This step includes reviewing regulatory
requirements, preparing and submitting a statement of intent, preparing and
submitting a PMP, and collecting related information. These activities are
required from all new sources subject to Subparts A and B.

Maintaining records. Through the PMP, the discharger is to specify provisions
for maintaining appropriate records of heel management procedures, prerinse/pre-steam management procedures, cleaning agent management procedures,
operator training, and proper operation and maintenance of any pretreatment
system. Dischargers must also maintain records on the volumes, content, and
chemical characteristics of cleaning agents used in cleaning and brightening
operations. Records are to be maintained and stored on-site for the length of time
specified by the PMP, but for no more than three years.

Training operators. Through the PMP, the discharger is to specify provisions
for performing operator training on maintaining appropriate records of cleaning
agent use, heel management procedures, pre-rinse/pre-steam management
procedures, and cleaning agent management procedures, and wastewater
treatment operations and maintenance. These activities are required from all new
sources subject to Subparts A and B opting for the PMP alternative.

Pretreatment control authority implementation. Pretreatment control
authorities (i.e., POTWs or States) are responsible for reviewing and
incorporating the PMP into the facility’s individual control mechanism or POTW
permit and for conducting compliance reviews.

THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)

Agency Activities

Dischargers included in this ICR retain most of the information generated under the
compliance alternative option and provide only a Statement of Intent and PMP to pretreatment
control authorities; there are no additional reporting requirements. Therefore, there are no
Agency activities necessary beyond any existing oversight responsibilities as detailed in the
NPDES Compliance Assessment/Certification ICR (EPA ICR No. 1427.07, OMB Control No.
2040-0110).
5(b)

Collection Methodology and Management

The pretreatment control authority has responsibility for reviewing a discharger’s PMP,
ensuring that its implementation is consistent with Clean Water Act requirements, and
recommending additional or incremental procedures, as necessary, to prevent pass through,
interference, and sludge contamination at POTWs.
5(c)

Small Entity Flexibility

Pursuant to Section 605(b) of the Regulatory Flexibility Act, the EPA Administrator
certified as part of the rulemaking that this rule did not have a significant economic impact on a
substantial number of small entities. The number of small businesses affected by the rule is
relatively low and the impact is modest for most of the affected small businesses.
5(d)

Collection Schedule

The information collection activities included in this ICR are anticipated to occur
according to the following schedule:
C

Submit Statement of Intent to implement a PMP: Due by discharger prior to
having its individual control mechanism or POTW permit renewed or modified.

Submit a PMP: Due by discharger when applying to renew or modify its
individual control mechanism or POTW permit.

Collect information and maintain records: Performed by discharger on a
continual basis.

Perform operator training: Performed by discharger on a continual basis.

Incorporate PMP requirements into control mechanism: Performed by
pretreatment control authority on a one time basis.
8

Perform on-site records review: Performed by pretreatment control authority on a
regular basis (annually or semi-annually).

ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)

Estimating Respondent Burden

Table 1 presents estimates of burden and costs for transportation equipment cleaning
respondents associated with this ICR. Table 2 presents estimates of pretreatment control
authority burden for burden and costs associated with this ICR. A brief description of the basis
for these estimates is presented below. All estimates are based on best professional judgement.
(1)

Prepare and submit a statement of intent

As a first step, dischargers need to decide how they are going to comply with the overall
regulations for the TEC point source category. They will learn of the requirements and those of
the pollution prevention compliance option through a review of the Federal Register (65 FR
49665), EPA’s Technical Development Document (EPA-821-R-00-012, June 2000) and/or
Permit Guidance Document (EPA-821-R-01-021, March 2001).1 Those dischargers choosing the
pollution prevention compliance option will need to prepare and submit of a Statement of Intent
to implement a PMP. The statement needs to be certified by a responsible corporate officer.
EPA estimates it will require 2 hours for all new sources (20 respondents) to have a
corporate officer read the applicable portions of the regulations and supporting documents
specific to the pollution prevention compliance option. For the 25 percent of these new users (5
respondents) that select this option, an additional burden of three hours (one hour each for a
corporate officer, legal council, and a clerk) will be required to prepare and submit the Statement
of Intent.
(2)

Prepare and submit a Pollutant Management Plan

Those dischargers that choose the pollution prevention compliance option must prepare
and submit a PMP. This is an initial, one-time burden. This activity will require a manager 66.5
hours to review available cargo identification records, meet with POTW representatives to learn
about incompatible pollutants, and write the 10 components of the Plan. This estimate represents
an average facility burden of (1) dischargers who choose to operate end-of-pipe wastewater
treatment of incompatible wastes which require higher than average burden and (2) those who
choose not to operate end-of-pipe wastewater treatment of incompatible wastes which require
lower than average burden. An estimated 25 percent of these dischargers are expected to choose
to operate end-of-pipe wastewater treatment of incompatible wastes. EPA estimates that it will

These documents are available at http://www.epa.gov/waterscience/guide/teci/.
9

require a corporate officer and legal council 2 hours each to conduct an internal review of the
draft PMP, and it will require a clerk 4 hours to prepare and submit the final Plan. This results in
a initial one-time burden of 74.5 hours for each new source (5 respondents) opting to implement
the PMP alternative.
(3)

Collect information and maintain records

Components (ix), information on cleaning agents, and (x), recordkeeping, of the PMP are
to specify provisions that enable the discharger to demonstrate compliance. Recordkeeping is
assumed to include the maintenance of the following operating logs: cleaning agent use, heel
management, pre-rinse/pre-steam management, spent cleaning agent management, wastewater
treatment system operation, wastewater treatment system maintenance and repair, and
wastewater treatment system inspection.
EPA estimates that 16 hours will be required by a manager to design the format and
content of the information log sheets. This estimate is a one-time initial burden (5 respondents).
Information collection and record maintenance are recurring activities assumed to be
performed by equipment operators. EPA estimates that it will take 2 hours per month for
dischargers to collect information and maintain records for cleaning agent use, while an
estimated one-half hour per day will be required to collect information and maintain records for
heel management, pre-rinse/pre-steam management, and spent cleaning agent management.
These estimates assume that 20 percent of tanks cleaned at an average facility last contained
cargos that would cause or contribute to a discharge that would be incompatible with treatment
at the POTW. Finally, EPA estimates that one-half hour per day will be required to collect
information and maintain records for wastewater treatment for the estimated 25 percent of
dischargers who to operate end-of-pipe wastewater treatment of incompatible wastes. This
results in an annual burden of 186.5 hours for each new and existing source (79 existing
respondents and 5 new respondents) opting to implement the PMP alternative.
(4)

Perform operator training

Dischargers are to train operators on the data collection and recordkeeping requirements
specified in the PMP. EPA estimates that this task will require a manager 4 hours per year to
prepare and perform the training and an additional 2 hours per year to maintain operator training
records. EPA further estimates that operators will require 16 hours per year to attend training.
This latter estimate includes an allowance for operator staff turnover. This results in an annual
burden of 22 hours for each source (79 respondents) opting to implement the PMP alternative.
(5)

Pretreatment Control Authority Implementation

EPA estimates a burden to pretreatment control authorities of 10 hours per new source (5
respondents) to review and incorporate the PMP into the facility’s individual control mechanism
or POTW permit. This is a one-time initial burden. EPA estimates an additional pretreatment
10

control authority burden of 2 hours per year to perform periodic (e.g., annual or semi-annual)
compliance reviews for each new and existing source opting to implement the PMP alternative
(84 respondents).
6(b)

Estimating Respondent Costs

This ICR only includes labor costs associated with any respondent activities as EPA has
determined that any capital or operation and maintenance costs are negligible. Labor costs
presented in Table 1 were estimated by multiplying the estimated burden (hours) by labor rates
for the following employment categories: corporate officer, legal, manager, operator, and
clerical. In the initial ICR (2001), the labor rate for an operator was obtained from the TEC cost
model used to estimate compliance costs for the promulgated rule, after adjusting the rate to
2000 using the Chemical Engineering Plant Cost Index. Labor rates for the remaining categories
were obtained from the U.S. Bureau of Labor Statistics (BLS). Specifically, rates were based on
BLS’s average hourly earnings for private industry2 increased by 30 percent to account for
benefits and then adjusted to 2000 using BLS’s Employment Cost Index.
For the current version of the ICR, labor rates were updated to 2004 using BLS’s
Employment Cost Index.3 The BLS has changed how they organize and report occupational data
since the previous ICR. They now organize according to NAICS codes as opposed to SIC codes.
While two general SIC codes were identified as being associated with the TEC rulemaking, these
codes do not directly correspond to any NAICS codes. Some 20 NAICS codes are potentially
applicable when viewing the crosswalks between the SIC and NAICS documents. For the
purposes of this ICR, it seemed more prudent to simply escalate the rates from 2000 to 2004
using BLS’s Employment Cost Index. A summary of the revised labor rates is provided below:
C
C
C
C
C

Corporate officer - $75.46 per hour;
Legal - $66.62 per hour;
Manager - $38.40 per hour;
Operator - $30.83 per hour;
Clerical - $21.16 per hour.

National Compensation Survey: Occupational Wages in the United States, 1998, U.S.
Bureau of Labor Statistics.
3

“Table 6: Employment Cost Index (Wages & Salaries Only), Private Industry Workers
By Occupation and Industry Group (Not Seasonally Adjusted),” in Employment Cost Index:
Historical Listing, July 29, 2004, U.S. Bureau of Labor Statistics, available at
http://stats.bls.gov/web/echistry.pdf.
11

The Bureau of Labor Statistics estimates the average hourly rate for all full-time white
collar state and local employees (excluding sales personnel) to be $25.44.4 At 2,080 hours per
year, this equates to an average annual salary of $52,915. Overhead costs for state and local
employees are estimated to be 60 percent (EPA ICR Handbook), or $15.26 per hour, which
results in a total hourly rate of $40.70 per hour.
6(c)

Estimating Agency Burden and Cost
There is no Agency burden or costs related to the activities detailed in this ICR.

6(d)

Estimating the Respondent Universe and Total Burden and Costs

The potential regulated community includes approximately 304 (286 existing and 18
new) indirect discharging facilities in Subpart A and 32 (30 existing and 2 new) indirect
discharging facilities in Subpart B. EPA assumes that all new regulated facilities will evaluate
the alternative pollution prevention compliance option to determine whether it would be less
costly than complying with numerical limits. Based on discussions with industry stakeholders
and pretreatment control authorities, EPA estimates that 25 percent of these facilities will select
the pollution prevention compliance option for a total of 84 facilities (79 existing sources and 5
new sources) implementing the PMP alternative. In addition, all 20 new facilities will incur an
initial burden for reading and understanding the regulations. A comparable number of
pretreatment control authorities (i.e., 84) are also included based on the requirement to
incorporate appropriate language into individual control mechanisms (i.e., permits) and perform
routine on-site reviews of procedures and records.
Total burden and costs by activity are shown in Tables 1 and 2 for transportation
equipment cleaning respondents and pretreatment control authorities based on the assumed
respondent universe.

“Supplementary Table 3.2: State and Local Government, Selected Occupations: Mean
Hourly Earnings and Percentiles, Full-time Workers,” National Compensation Survey:
Occupational Wages in the United States, July 2003, U.S. Bureau of Labor Statistics, available
at http://stats.bls.gov/ncs/ocs/sp/ncbl0636.pdf.
12

6(e)

Bottom Line Burden Hours and Costs Table

Table 3 presents the bottom line burden hours and costs for transportation equipment
cleaning respondents and pretreatment control authorities.
6(f)

Reasons for Changes in Burden

Below is a summary of the changes in burden between the previous ICR (March 19,
2001) and this revised edition:
The overall annual burden and costs for transportation equipment cleaning respondents
decreased from 19,144 hours and $554,451 in the 2001 ICR to 17,684 hours and $551,014 in this
renewal, for a total decrease of 1,460 hours and $3,437. This decrease was due primarily to the
reduction in number of new facilities required to evaluate the PMP alternative and if appropriate,
develop a PMP. Annual burdens associated with each facility to implement the PMP (i.e.,
collect information, maintain records, and train operators) is consistent with the previous ICR.
The overall annual pretreatment control authority burden and costs increased from zero
hours in the 2001 ICR to 185 hours and $7,515 in this renewal. This increase accounts for
burden identified in the 2001 ICR as Agency burden that is actually local pretreatment control
authority respondent burden. It is these local pretreatment control authorities that are
responsible for incorporating these provisions into a control mechanism (i.e., a discharge
permit).
6(g)

Burden Statement

The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 98 hours per response. Burden means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose or provide information
to or for a Federal agency. This includes the time needed to review instructions; develop,
acquire, install, and utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of information; search data
sources; complete and review the collection of information; and transmit or otherwise disclose
the information. An agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless it displays a currently valid OMB control number. The
OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. OW-2004-0029, which is available for public viewing at the Water Docket in the
13

EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW,
Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An
electronic version of the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket. Use EDOCKET to submit or view public comments, access the
index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. Once in the system, select “search,” then key in the
docket ID number identified above. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington,
DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (OW-20040029) and OMB control number (2040-0235) in any correspondence.

Table 1
Annual Burden and Cost for Transportation Equipment Cleaning Respondents
2004 to 2007
5

Hours and Costs Per Respondent

Information Collection Activity

Corp
Officer
Legal
Manager Operator Clerical
$75.46/hr $66.62/hr $38.40/hr $30.83/hr $21.16/hr

Total Hours and Costs
Resp.
hr/yr

Labor
$/yr

Number
of
Resp.

Total
hr/yr

Total
$/yr

Prepare and submit a statement of intent
Read the regulations and supporting documents
Prepare and submit statement of intent

0.7
0.33

0.33

0.7

$52.82

$1,056

0.34

$54.08

$270

1.3

24.9

$979.44

125

$4,897

Prepare and submit a PMP
Prepare and submit a PMP

22.2

Collect information and maintain records
Develop records format and content

5.3

Collect information and maintain records

186.5

5.3

$203.52

$1,018

186.5

$5,749.80

15,666

$482,983

Perform operator training
Operator training
Subtotal

1.73

1.03

33.5

202.5

1.64

$723.68

1,848

$60,789

240.4

$7,763.34

17,684

$551,014

Many of the burden estimates reflect a one-time, initial burden that have been divided by three for purposes of the table to
provide an average burden on an annual basis over the three-year period of this ICR. Collecting information, maintaining records, and
operator training reflect actual annual burdens.
15

Table 2
Annual Pretreatment Control Authority Burden and Cost
Hours and Costs Per Respondent

Information Collection Activity

Labor
Costs
$/yr

Burden
$40.70/hr

Total Hours and Costs
Number of
Respondents

Total
hr/yr

Total
$/yr

Implement new pretreatment conditions
Annual onsite record review

3.33
2

$135.53
$81.40

5
84

16.65
168

$677.66
$6,837.60

Subtotal

5.33

$216.93

184.65

$7,515.26

Table 3. Summary of Burden and Costs to Respondents
and Pretreatment Control Authorities
Category

No. Respondents

Total Labor Hours

Total Costs

Respondents (Subpart A and B)

17,684

$551,014

Pretreatment Control Authorities

184.65

$7,515.26

Total

183

17868.65

$558,529.26

INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT
FOR
VOLUNTARY CERTIFICATION IN LIEU OF CHLOROFORM MINIMUM
MONITORING REQUIREMENTS FOR DIRECT AND INDIRECT DISCHARGING
MILLS IN THE BLEACHED PAPERGRADE KRAFT AND SODA SUBCATEGORY OF
THE PULP, PAPER AND PAPERBOARD POINT SOURCE CATEGORY (RENEWAL)
(40 CFR PART 430)
EPA ICR Number 2015.02
OMB Control Number 2040-0242

May 2005

U.S. Environmental Protection Agency
Office of Water
Engineering and Analysis Division
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page ii

TABLE OF CONTENTS

IDENTIFICATION OF THE INFORMATION COLLECTION ........................................ 1
1(a) Title of the Information Collection............................................................................. 1
1(b) Short Characterization/Abstract ................................................................................. 1

NEED FOR AND USE OF THE COLLECTION ................................................................ 2
2(a) Need/Authority for the Collection ............................................................................... 2
2(b) Practical Utility/Users of the Data............................................................................... 3

NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA ............................................................................................................................ 3
3(a) Non-duplication .......................................................................................................... 3
3(b) Public Notice Required Prior to ICR Submission ...................................................... 4
3(c) Consultations ............................................................................................................... 4
3(d) Effects of Less Frequent Data Collection.................................................................... 4
3(e) General Guidelines ..................................................................................................... 5
3(f) Confidentiality ............................................................................................................. 5
3(g) Sensitive Questions...................................................................................................... 5

THE RESPONDENTS AND THE INFORMATION REQUESTED .................................. 5
4(a) Respondents and SIC Codes........................................................................................ 5
4(b) Information Requested................................................................................................. 5

THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT .......................................... 7
5(a) Agency Activities ........................................................................................................ 7
5(b) Collection Methodology and Management ................................................................. 8
5(c) Small Entity Flexibility ............................................................................................... 8
5(d) Collection Schedule ..................................................................................................... 8

ESTIMATING THE BURDEN AND COST OF THE COLLECTION............................... 9
6(a) Estimating Respondent Burden ................................................................................... 9
6(b) Estimating Respondent Cost...................................................................................... 12
6(c) Estimating Agency Burden and Cost......................................................................... 13
6(d) Estimating the Respondent Universe and Total Burden and Costs ........................... 14
6(e) Burden Statement....................................................................................................... 14

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page iii

LIST OF TABLES
Table 6.1

Number of Eligible Mills and Lines ........................................................................... 9

Table 6.2

Recurring Burden for Activities Related to Certification
in Lieu of Chloroform Minimum Monitoring ........................................................... 10

Table 6.3

Recurring Burden Reduction from Minimum Monitoring
required by 40 CFR 430.02 ....................................................................................... 11

Table 6.4

Total Burden Reduction Resulting from Certification
in Lieu of Chloroform Minimum Monitoring .......................................................... 12

Table 6.5

Summary of Incurred and reduced Annual Respondent
Burden and Costs ...................................................................................................... 14

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 1

1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) Title of the Information Collection
Voluntary Certification in Lieu of Chloroform Minimum Monitoring Requirements for Direct
and Indirect Discharging Mills in the Bleached Papergrade Kraft and Soda Subcategory of the
Pulp, Paper, and Paperboard Point Source Category (EPA ICR No. 2015.02) (OMB Control
Number 2040-0242).
1(b)

Short Characterization/Abstract

This Information Collection Request (ICR) presents estimates of the burden and costs to
the regulated community for voluntary certification in lieu of chloroform monitoring, reporting,
and recordkeeping associated with implementation of the minimum monitoring requirements of
the Pulp, Paper and Paperboard Effluent Limitations Guidelines and Standards (Cluster Rules;
40 CFR Part 430), which were published on April 15, 1998 for mills in the Bleached Papergrade
Kraft and Soda Subcategory (Subpart B). See 63 FR 18504-18751. Certification in lieu of
chloroform minimum monitoring requirements allows direct and indirect discharging Subpart B
mills to demonstrate compliance with applicable chloroform limitations and standards under 40
CFR Part 430 in lieu of monitoring at a fiber line required by 40 CFR 430.02 by voluntarily
certifying (1) that the fiber line is not using elemental chlorine or hypochlorite as bleaching
agents and (2) that it also maintains certain process and operating conditions identified during
the initial compliance demonstration period. This is a renewal ICR.
Initial compliance demonstration consists of the time period, not less than two years,
during which 104 monitoring data measurements are collected per minimum monitoring required
by 40 CFR 430.02 (or more frequently if required by the permitting or pretreatment control
authority) for each fiber line the facility wishes to certify. During this time period, the facility
will monitor and maintain records of the range of certain process and operating conditions that
the fiber lines are operated within. The collected monitoring data will be used to demonstrate
compliance with applicable chloroform limitations and standards for each fiber line and provide
confirmation that the fiber line, if operated within the range of certain process and operating
conditions identified during the initial compliance demonstration period, continues to comply
with the chloroform limitations and standards.
Facilities that choose to certify any or all of their fiber lines with their NPDES permit or
pretreatment control authority, in lieu of chloroform minimum monitoring required by 40 CFR
Part 430, will be required to submit periodic reports certifying that the fiber line(s) are operating
within the range of certain process and operating conditions identified during the initial
compliance demonstration period. Mills that voluntarily choose to certify will be required to
maintain records of certain process and operating conditions, and also will be required to notify
their NPDES permit or pretreatment control authority if their certified fiber lines no longer
operate within the range of process and operating conditions. At the discretion of the NPDES
permit or pretreatment control authority, the facility may then be required to again monitor at
their fiber lines as required by 40 CFR 430.02.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 2

Applicable facilities that choose to certify their fiber lines in lieu of chloroform minimum
monitoring will experience a total reduction in overall monitoring, reporting, and analytical
burden and costs associated with the minimum monitoring required by 40 CFR 430.02. The
universe eligible for certification in lieu of chloroform minimum monitoring consists of 84 direct
and indirect discharging Subpart B mills.
This is a renewal ICR covering the incurred burden and costs for the estimated 80 out of
the universe of 84 direct and indirect discharging Subpart B mills that for EPA ICR No. 2015.01
were anticipated to voluntarily certify their fiber lines in lieu of chloroform minimum monitoring
and the subsequent overall reduction in burden and costs incurred by these facilities as a result of
reduced monitoring, reporting, and analytical requirements per 40 CFR 430.02. This ICR does
not cover the burden and costs for State NPDES permit and pretreatment control authorities or
EPA associated with facilities certifying their fiber lines in lieu of chloroform minimum
monitoring because it is anticipated that there will be an exact trade-off between the burden and
costs incurred from reviewing periodic certification reports for voluntarily participating fiber
lines versus reviewing periodic chloroform monitoring data for facilities complying with 40 CFR
430.02. Incurred burden and costs of certification for State NPDES permit authorities or EPA
are described in the Minimum Monitoring Requirements for Direct Discharging Mills in the
Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of the
Pulp, Paper, and Paperboard Point Source Category ICR (OMB 2040-0243) for direct
dischargers. The burden and cost of certification for pretreatment control authorities are
generically covered by National Pretreatment Program ICR (OMB 2040-0009) for indirect
dischargers. Review functions that may incur burden include actions in response to a mill
voluntarily choosing to certify in lieu of monitoring that notifies their NPDES permit or
pretreatment control authority that its participating fiber line(s) are operating outside the range of
process and operating conditions identified during the initial compliance demonstration period.
2. NEED FOR AND USE OF THE COLLECTION
2(a)

Need/Authority for the Collection

As mentioned above, EPA established minimum monitoring frequencies for chloroform
for existing and new direct and indirect discharging mills within Subpart B under authority of
Clean Water Act (CWA) Section 308 to demonstrate compliance with existing effluent
limitations and standards for chloroform (and other pollutant parameters) promulgated under 40
CFR Part 430. EPA is also allowing applicable facilities to voluntarily demonstrate compliance
with chloroform limitations and standards by certifying their fiber lines in lieu of chloroform
minimum monitoring required by 40 CFR 430.02. EPA has determined that this voluntary
certification option significantly reduces the overall compliance burden and costs associated with
meeting and demonstrating compliance with applicable chloroform limitations and standards.
EPA has also determined that an initial compliance demonstration is necessary for each
participating mill to establish the range of normal variability in process and operating parameters
that are consistent with compliance with the chloroform effluent limitations. Once this range is
established for each participating fiber line, periodic certification reports are submitted to the
NPDES permit or pretreatment control authority to confirm and certify that the fiber line
continues to comply with the chloroform effluent limitations and standards. The Agency=s

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 3

authority to provide for this voluntary certification option in lieu of minimum monitoring is
Section 402(a)(2) of the CWA which directs EPA to prescribe permit conditions to assure
compliance with requirements Aincluding conditions on data and information collection,
reporting and such other requirements as [the Administrator] deems appropriate.@
2(b)

Practical Utility/Users of the Data

The primary users of the data are the owners and operators of direct and indirect
discharging pulp and paper mills in Subparts B and NPDES permitting, pretreatment control and
enforcement authorities. Citizen groups also use this data to independently assess facility
compliance.
EPA expects that the initial compliance demonstration and periodic certification reports
will be used by NPDES and pretreatment control authorities to determine compliance with the
Cluster Rules effluent limitations and standards for chloroform, establish permit and
pretreatment control agreement conditions to include the voluntary certification option, and
revise permit requirements as may be necessary based on data from the initial compliance
demonstration, certification reports, and any additional information and data the mill may be
required to report. EPA anticipates that State and NPDES permitting and pretreatment control
authorities will only need to conduct detailed technical reviews of certification reports in the
event the reports indicate noncompliance with the NPDES permit or pretreatment control
agreement.
Mills that voluntarily choose to participate may elect to assert claims of confidential
business information (CBI), according to the provisions of 40 CFR Part 2, on any portions of the
process and operating data submitted to support a certification in lieu of minimum monitoring
for chloroform. However, CBI claims will not be appropriate for periodic reports simply
certifying that mill operations remain within the ranges of process and operating parameters
established during the initial compliance demonstration.
3.

NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA
3(a) Non-duplication

EPA has examined all other reporting requirements contained in the Clean Water Act and
40 CFR Parts 122, 123, 124, 125, 430, 501, and 503. The Agency also has consulted the
following sources of information to determine if similar or duplicate information is available
elsewhere:
$
$
$

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

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 4

Examination of these databases revealed no duplicate collection requirements. EPA has
concluded that there is no other way to obtain the initial compliance demonstration and
certification information addressed in this ICR.
3(b) Public Notice Required Prior to ICR Submission
EPA solicited comments on this ICR prior formal submission to OMB. EPA published a
formal notice in the Federal Register on August 30, 2004 (69 FR 52883-52888). EPA received
no comments.
3(c) Consultations
As mentioned above, EPA solicited public comments on the current draft ICR.
Additionally, EPA has consulted with the public, industry and States on the certification in lieu
of chloroform minimum monitoring requirements.
3(d) Effects of Less Frequent Data Collection
The certification option requires the collection of 104 measurements of chloroform data
over a period not less than two years during the initial compliance demonstration period per
minimum monitoring required by 40 CFR 430.02 (or more frequently if required by the
permitting or pretreatment control authority), documenting of process and operating conditions,
and subsequent monthly reporting and recordkeeping via periodic certification reports.
Chloroform minimum monitoring required by 40 CFR Part 430 as part of the initial compliance
demonstration is described in the Minimum Monitoring Requirements for Direct Discharging
Mills in the Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite
Subcategory of the Pulp, Paper, and Paperboard Point Source Category ICR (OMB 2040-0243)
for direct dischargers and the National Pretreatment Program ICR (OMB 2040-0009) for indirect
dischargers. Mill operators collect such data on process and operating conditions independent of
this requirement for purposes of monitoring and optimizing bleach plant, chemical recovery, and
wastewater treatment plant operations. EPA determined that the number of chloroform data
points collected during the initial compliance demonstration are necessary because there are
potentially many sources of variability in effluent discharges of unit operations in each
participating fiber line. While available information used by EPA to understand and establish
certification requirements capture the most likely sources of variability, all mill specific sources
of variability may not be accounted for. Therefore, EPA was concerned that less frequent
monitoring would not provide the information necessary to ensure that mills collect adequate
data to define ranges of process and operating parameters within which they will subsequently be
required to operate to assure compliance with the chloroform effluent limitations guidelines and
standards promulgated as part of the Cluster Rules while also successfully producing products of
acceptable quality. See 63 FR 18571-72. EPA determined that periodic certification reports are
necessary to confirm that facilities with participating fiber lines are operating within the range of
process and operating conditions identified during the initial compliance demonstration period.
The frequency of submission of periodic certification reports is the same as discharge
monitoring reports (DMRs) required for other pollutant parameters for direct dischargers by their

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 5

NPDES permits, Periodic Compliance Reports (PCRs) for other pollutant parameters for indirect
dischargers, and provides an efficient means for submitting information to the permit writer and
pretreatment control authority.
3(e) General Guidelines
This information collection is consistent with OMB guidelines contained in 5 CFR
1320.5(d)(2).
3(f)

Confidentiality

As noted in 2(b) above, mills that voluntarily choose to participate may elect to assert
claims of confidential business information (CBI), according to the provisions of 40 CFR Part 2,
on any portions of the process and operating data submitted to support a certification in lieu of
minimum monitoring for chloroform. However, CBI claims will not be appropriate for periodic
reports simply certifying that mill operations remain within the ranges of process and operating
parameters established during the initial compliance demonstration.
3(g) Sensitive Questions
The reporting requirements addressed in this ICR do not include sensitive questions.
4.

THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a)

Respondents and SIC and NAICS Codes

The respondent universe for this ICR will be: 1) approximately 84 direct and indirect
discharging chemical pulp mills included in Subpart B (Bleached Papergrade Kraft and Soda) of
the Pulp, Paper and Paperboard Manufacturing Category (SIC 2611, 2631) (NAICS 32211,
322121, 322122, 32213).
4(b)

Information Requested

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

Certification in Lieu of Chloroform Minimum Monitoring Requirements

(a)
(b)
(c)
(d)
(e)

Page 6

The pH of the first chlorine dioxide bleaching stage;
The chlorine (Cl2 ) content of chlorine dioxide (ClO2) used on the bleach line;
The kappa factor of the first chlorine dioxide bleaching stage;
The total bleach line chlorine dioxide application rate; and
The chlorine-containing compounds used for bleaching (i.e., the bleach sequence).

At many mills monitoring of process and operating parameters is accomplished electronically by
computerized distributed control systems (DCS).
When the facility has completed its initial compliance demonstration, it may request that
its permitting or pretreatment control authority modify its permit or pretreatment control
agreement to discontinue weekly chloroform monitoring of bleach plant effluent. At the time
that it makes this request, the facility must:
(a) Certify that the fiber line does not use either elemental chlorine or hypochlorite;
(b) Provide records demonstrating that, based on 104 measurements collected over a
period not less than two years, that the fiber line complies with applicable
chloroform limitations or standards; and
(c) Document the range of process and operating conditions that occurred during the
collection of samples used to demonstrate initial compliance. Specifically, the
facility must identify the chlorine-containing compounds used for bleaching (i.e., the
bleach sequence). The facility must also document the maximum values, observed
during sample collection of:
(i) The pH of the first chlorine dioxide bleaching stage;
(ii) The chlorine (Cl2) content of chlorine dioxide (ClO2) used on the bleach line;
(iii) The kappa factor of the first chlorine dioxide bleaching stage; and
(iv) The total bleach line chlorine dioxide application rate.
Thereafter, at the same frequency that the facility submits discharge monitoring reports (DMRs)
to its permitting authority or periodic compliance reports (PCRs) to its pretreatment control
authority, the facility must certify that:
(a) The pH of the first chlorine dioxide bleaching stage has not exceeded the pH range
measured during initial compliance demonstration sample collection;
(b) The chlorine (Cl2) content of chlorine dioxide (ClO2) used on the bleach line has not
exceeded the maximum Cl2 content of ClO2 used during initial compliance
demonstration sample collection;
(c) The kappa factor of the first chlorine dioxide bleaching stage has not exceeded the
maximum kappa factor employed during initial compliance demonstration sample
collection;
(d) The total bleach line chlorine dioxide application rate has not exceeded the
maximum chlorine dioxide application rate employed during initial compliance
demonstration sample collection; and
(e) The chlorine-containing compounds used for bleaching are unchanged from those
used during initial compliance demonstration sample collection.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 7

The facility also must maintain on-site records for the fiber line of these process and operating
conditions. If the facility purposely changes or unintentionally fails to maintain process and
operating conditions on the fiber line representative of those employed during initial compliance
demonstration, the facility must notify the permitting or pretreatment control authority and again
monitor for chloroform, and recertify the fiber line to continue the certification option to
demonstrate compliance in lieu of minimum monitoring.
5.

THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a) Agency Activities

Activities undertaken by EPA under this information collection primarily include
oversight of the NPDES and pretreatment control programs, and where EPA is the NPDES
permitting or pretreatment control authority, review of data and information collected during the
initial compliance demonstration period, review of periodic certification reports, and where
necessary, follow-up actions.
The extent to which EPA reviews reports and data in assessing permit and pretreatment
control agreement compliance with the certification option may vary. For example, EPA may
conduct a more extensive review of permittees that are, or have been, in violation of their
certification and permit or pretreatment control agreement requirements, than of permittees who
have been in full compliance. EPA may limit its review of data submitted by fully compliant
permittees to a simple determination of continuing compliance through certification. In most
cases, EPA will forward copies of reports to the States. EPA does not require the unauthorized
States to review data, but several States voluntarily conduct the review and use the results in
their own programs.
EPA regions may also review data from major permittees in NPDES and pretreatment
control authorized States while performing program oversight functions (e.g., during file audits
and when compiling statistical compliance summaries).
Reported data is often stored in the Permit Compliance System (PCS) for reference. EPA
and States may use this data to evaluate potential compliance problems, focus inspection efforts,
conduct spot check reviews and determine appropriate enforcement action. PCS is available for
public review at http://www.epa.gov/enviro/html/water.html#pcs.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 8

5(b) Collection Methodology and Management
Respondents typically report collected compliance data for all pollutant parameters on
Discharge Monitoring Reports (DMRs) for direct dischargers and periodic compliance reports
(PCRs) for indirect dischargers. For those facilities that choose to certify in lieu of chloroform
minimum monitoring at a fiber line, periodic certification reports may be submitted with DMRs
and PCRs. Allowing combined reporting for both the certification option (for chloroform) and
compliance (for all other pollutant parameters) is one method that EPA has used to improve its
collection methodology. EPA expects that the Cross-Media Electronic Reporting Rule
(CROMERR) will be finalized in the next few months, which will enable EPA to accept
electronic submission of data. The electronic submission of certification reports, DMR and PCR
data is voluntary and will be an alternative to the paper submissions. EPA makes use of the PCS
database to store, track and access this information.
5(c) Small Entity Flexibility
EPA considered less burdensome information collection mechanisms for small entities,
but chose not to alter the collection procedure for the following reasons:
$

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

Moreover, mills will be subject to the information collection only if they choose to
participate in the chloroform certification program.
5(d) Collection Schedule

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

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

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

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 9

ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a) Estimating Respondent Burden

This section describes the methods EPA used to estimate the burden to respondents
associated with the initial compliance demonstration and periodic compliance reports required
with the certification in lieu of chloroform minimum monitoring required by 40 CFR Part 430.
The number of facilities potentially affected by this ICR is listed in Table 6.1 below.
Table 6.1 Number of Eligible Mills and Lines
Subpart B, Bleached
Papergrade Kraft and
Soda

Number of
Facilities

Number of Bleach Lines

Direct Dischargers

120

Indirect Dischargers

Total

134

For ICR 205.01 EPA estimated that of the 75 existing direct discharging Subpart B mills
eligible for certification in lieu of chloroform minimum monitoring requirements, consisting of a
total of 120 fiber lines, 74 facilities, for a total of 118 fiber lines, would choose to certify. EPA
estimated that of the nine existing indirect discharging Subpart B mills eligible for certification
in lieu of chloroform minimum monitoring requirements, consisting of a total of 14 fiber lines,
six facilities, for a total of nine fiber lines, would choose to certify. EPA is carrying these
assumptions for this renewal ICR.
(i) Initial Compliance Demonstration
EPA does not expect any additional facilities to enroll in the voluntary certification in
lieu of chloroform monitoring, reporting, and recordkeeping associated with implementation of
the minimum monitoring requirements of the Pulp, Paper and Paperboard Effluent Limitations
Guidelines and Standards
(ii) Periodic Certification Reports and Recordkeeping
EPA estimates a recurring reporting burden of 0.5 hours monthly per facility for
submitting periodic certification reports to the permitting or pretreatment control authority to
confirm that the certified fiber lines are not using elemental chlorine or hypochlorite as bleaching
agents and are maintaining the process and operating conditions within the range documented
during the initial compliance period. This burden consists of a certification report submitted to
the permitting or pretreatment control authority and maintaining records which document and
substantiate submitted certification reports. This burden estimate is based upon monthly
submissions of DMRs for direct dischargers and PCRs for indirect dischargers, including
certification reports.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 10

The total recurring burden incurred by the 80 direct and indirect discharging mills
anticipated to certify their 127 fiber lines in lieu of chloroform minimum monitoring for
chloroform is summarized below.
Table 6.2 Recurring Burden for Activities Related to Certification in Lieu of Chloroform
Minimum Monitoring
Submission of monthly certification
reports

Number of
Affected
Facilities

Monthly
Burden
(hours)

Total Annual
Burden
(hours)

Direct

0.5

444

Indirect

0.5

Total

0.5

480

(iii) Recurring Burden Reduction from Minimum Monitoring Required by 40 CFR
430.02
Facilities that have certified their fiber lines in lieu of chloroform minimum monitoring
required by 40 CFR 430.02 will experience a reduction in recurring burden associated with
reduced monitoring and reporting, namely the discontinuance of weekly chloroform monitoring
at bleach plant effluent(s). Annual sampling burden associated with chloroform minimum
monitoring per fiber line is estimated at 156 hours. Annual reporting burden associated with
chloroform minimum monitoring per facility is estimated at two hours. Description of these
estimates can be found in Minimum Monitoring Requirements for Direct Discharging Mills in
the Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of
the Pulp, Paper, and Paperboard Point Source Category ICR (OMB 2040-0243) for direct
dischargers and the National Pretreatment Program ICR (OMB 2040-0009) for indirect
dischargers.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 11

Table 6.3 Recurring Burden Reduction from Minimum Monitoring Required by 40 CFR
430.02
Activity

Number of
Affected
Facilities

Annual
Burden
(hours)

Total Annual
Burden
(hours)

118 fiber lines

156

18,408

9 fiber lines

156

1,404

Reporting for minimum monitoring
required by 40 CFR 430.02 (Direct)

74 mills

148

Reporting for minimum monitoring
required by 40 CFR 430.02 (Indirect)

6 mills

Sampling for minimum monitoring
required by 40 CFR 430.02 (Direct)
Sampling for minimum monitoring
required by 40 CFR 430.02 (Indirect)

ANNUAL BURDEN REDUCTION

19,972

EPA does not estimate a reduction in recurring recordkeeping burden associated with
minimum monitoring requirements for those facilities that certify their fiber lines in lieu of
chloroform minimum monitoring because records are maintained for the monitoring for other
pollutant parameters, regardless of the discontinuation of minimum monitoring for chloroform.
(iv) NPDES and Pretreatment Control authorized State Respondent Burden
The burden and associated costs to NPDES and pretreatment control authorized State
authorities for reviewing reports for the initial compliance demonstration for facilities wishing to
certify their fiber lines in lieu of chloroform minimum monitoring, revising NPDES permits and
pretreatment control agreements, reviewing periodic certification reports, and conducting followup actions are estimated to exactly offset previous recurring burden for processing and analyzing
chloroform monitoring data included in the facility=s DMR or PCR and conducting follow-up
actions related to compliance. Therefore, the Agency does not estimate any addition or
reduction of recurring burden for NPDES and pretreatment control authorities with facilities
wishing to certify their fiber lines in lieu of chloroform minimum monitoring.
The additional and reduced burden for facilities wishing to certify their fiber lines in lieu
of chloroform minimum monitoring required by 40 CFR 430.02, showing an overall reduction in
total recurring burden, is summarized below.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 12

Table 6.4 Total Burden Reduction Resulting from Certification in Lieu of Chloroform
Minimum Monitoring
Activity

Total Annual
Burden (hours)

Annual burden reduction from sampling and reporting for minimum monitoring
required by 40 CFR 430.02
Annual burden for reporting for certification in lieu of chloroform minimum
monitoring
TOTAL ANNUAL BURDEN REDUCTION

6(b)

19,972
480
19,492

Estimating Respondent Cost

(i) Estimating Labor Costs (2004 Dollars)
Estimates for respondent labor costs were prepared using industry-specific labor rates
identical to those used for the EPA ICR Number 1878.01, included overhead and fringe benefits,
and adjusted to January 2004 dollars with the Employment Cost Index: To verify the validity of
the adjusted rates EPA obtained national industry-specific wage estimates for the pulp, paper,
and paperboard mills from the Labor Department 1. Noting that the Labor Department wages
were lower, EPA decided to apply the more conservative estimates from the previous ICR 2.
Technician :
Operator

$64.58 /hour
$32.81 /hour

May 2003 National Industry-Specific Occupational Employment and Wage Estimates for NAICS 322100 Pulp. Paper, and Paperboard Mills. The mean hourly wage for Architecture and Engineering Occupations (SOC
Code 17-0000) and Production Occupation (SOC Code 51-0000), including 50 percent for overhead and fringe
benefits, are 45.64 and 27.14 respectively.
2

EPA ICR # 2015.01, Voluntary Certification in Lieu of Chloroform Minimum Monitoring Requirements
for Direct and Indirect Discharging Mills in the Bleached Papergrade Kraft and Soda Subcategory of the Pulp, Paper
and Paperboard Manufacturing Category, November 2001.

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 13

Technician labor is applied to reporting and recordkeeping burdens. Operator labor is
applied to sampling burden. This ICR covers an increase in recurring reporting burden related to
periodic certification reports and a reduction in sampling and reporting burden related to the
discontinuance of chloroform minimum monitoring required by 40 CFR 430.02.
(ii) Operations and Maintenance (O&M) Costs
Facilities that choose to certify their fiber lines in lieu of minimum monitoring for
chloroform required by 40 CFR 430.02 will experience an overall reduction in O&M costs
related to the discontinuance of collecting and shipping chloroform samples to outside
laboratories for analysis. The analytical cost for chloroform performed at outside laboratories is
estimated at $320 per sample, taken from EPA ICR Number 2015.01 (originally from the BAT
cost model in the ABAT Cost Model Support Document@ [DCN 13953]) and adjusted with the
Consumer Price Index to 2004 dollars. Collection of two chloroform samples per fiber line (i.e.,
bleach plant) per week is estimated to meet minimum monitoring requirements. This estimate is
described in the Minimum Monitoring Requirements for Direct Discharging Mills in the
Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of the
Pulp, Paper, and Paperboard Point Source Category ICR (OMB OMB 2040-0243) for direct
dischargers and the National Pretreatment Program ICR (OMB 2040-0009) for indirect
dischargers.
The reduction in recurring O&M burden for facilities that choose to certify their fiber
lines in lieu of minimum monitoring for chloroform required by 40 CFR 430.02 consists of the
elimination of sample collection and shipping costs, and chloroform analytical costs.
6(c) Estimating Agency Burden and Cost
EPA burden is based on management and support activities for facilities that choose to
certify their fiber lines in lieu of chloroform minimum monitoring required by 40 CFR 430.02
located in:
C

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

States with NPDES and pretreatment control authority: EPA activities include
program support, such as review of NPDES permit and pretreatment control agreements
renewal applications and draft permits and agreements, and review of information
submitted by the facilities, including certification reports. Burden associated with these
activities are described in the Minimum Monitoring Requirements for Direct Discharging
Mills in the Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite
Subcategory of the Pulp, Paper, and Paperboard Point Source Category ICR (OMB 2040-

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 14

0243) for direct dischargers and the National Pretreatment Program ICR (OMB 20400009) for indirect dischargers and will not be impacted by the certification option.
The Agency does not estimate any addition or reduction of recurring burden for EPA
associated with facilities intending to certify their fiber lines in lieu of chloroform minimum
monitoring.
6(d) Estimating the Respondent Universe and Total Burden and Costs
Table 6.5 summarizes the total annual burden and costs incurred for facilities that choose
to certify their fiber lines in lieu of chloroform minimum monitoring and the associated overall
reduction in annual burden and costs for reduced minimum monitoring requirements.

Table 6.5 Summary of Incurred and Reduced Annual Respondent Burden and Costs
Activity

Annual
Labor
(Hours)

Annual Costs
(2004 Dollars)

Incurred Annual Burden and Costs (Certification in Lieu of
Chloroform Minimum Monitoring Requirements)
Submission of monthly certification reports

480

$30,998

Reduced Annual Burden and Costs (Minimum Monitoring Required by 40 CFR 430.02)
Sampling
Reporting
Analytical
Total

19,812
160
19,972

$650,032
$10,333
$4,226,560
$4,886,925

Total Reduction in Annual Respondent Burden and Costs

19,492

$4,855,927

6(e)

Burden Statement

The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 6 hours per respondent. Certification in lieu of chloroform minimum
monitoring eliminates all sampling burden associated with the minimum monitoring
requirements for chloroform. A total of 19,492 hours annually would be saved by the 80 direct
and indirect discharging Subpart B mills that EPA anticipated would choose to certify their 127
fiber lines. At an hourly operator rate of $32.81 per hour for sampling activities, reduction in
sampling costs associated with certifying fiber lines in lieu of minimum monitoring required by
40 CFR 430.02 for the 80 mills would be $650,032 per year ($32.81 x 19,812). In addition, the
elimination of chloroform sampling activities results in an associated reduction in analytical
costs for the outside lab analysis of chloroform samples. The total reduction in analytical costs
associated with certifying fiber lines in lieu of minimum monitoring required by 40 CFR 430.02

Certification in Lieu of Chloroform Minimum Monitoring Requirements

Page 15

for the 80 mills would be $4,226,560 per year (127 fiber lines x 2 samples per fiber line x 52
weeks x $320 per analysis). An increase in reporting burden for the 80 mills would be 320 (480
- 160) hours annually, based on the submission of periodic certification reports in lieu of
reporting chloroform compliance data in DMRs and PCRs. At an hourly technician rate of
$64.58 for reporting activities, an increase in reporting costs associated with certifying fiber lines
in lieu of minimum monitoring required by 40 CFR 430.02 for the 80 mills would be $20,666
per year ($64.58 x 320). Therefore, the overall reduction in the total burden and cost to
demonstrate compliance with minimum monitoring requirements by certifying fiber lines in lieu
of minimum monitoring required by 40 CFR 430.02 for the 80 mills would be $4,855,927 per
year ($650,032 + $4,226,560 - $20,666). This reduction in cost translates to approximately
$60,699 annually per mill.
The Agency does not estimate any change in burden for State authorized NPDES and
pretreatment control authorities or EPA from the burden associated with minimum monitoring
required by 40 CFR 430.02 for facilities ( i.e., permitees) wishing to certify their fiber lines in
lieu of chloroform minimum monitoring requirements.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to
comply with any previously applicable instructions and requirements; train personnel to be able
to respond to a collection of information; search data sources; complete and review the collection
of information; and transmit or otherwise disclose the information. An agency may not conduct
or sponsor, and a person is not required to respond to, a collection of information unless it
displays a currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. OW-2004-0028, which is available for public viewing at the Water Docket in the
EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW,
Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An
electronic version of the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket. Use EDOCKET to submit or view public comments, access the
index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. Once in the system, select “search,” then key in the
docket ID number identified above. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington,
DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (OW-20040028) and OMB control number (2040-0242) in any correspondence.

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

EPA ICR Number 1829.03
OMB Control Number 2040-0207

June 2005

U.S. Environmental Protection Agency
Office of Water
Engineering and Analysis Division
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460

Best Management Practices ICR

TABLE OF CONTENTS
1.

IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . . . 1
1(a) Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1(b) Short Characterization/Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2(a) Need/Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2(b) Practical Utility/Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(a) Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(b) Public Notice Required Prior to ICR Submission . . . . . . . . . . . . . . . . . . . . . . . . . .
3(c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(d) Effects of Less Frequent Data Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(f) Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3
3
3
3
3
4
4
4

THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . . . . . . . .
4(a) Respondents and Sic Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4(b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4(c) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4
4
4
6

THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . . .
5(a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(b) Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7
7
7
7
8

ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . . . 8
6(a) Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
6(b) Estimating Agency Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
6(c) Bottom Line Burden and Costs Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
6(d) Reasons for Change of Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
6(e) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Best Management Practices ICR

LIST OF TABLES
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.

Summary of Mill Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Mill Labor for Amendment and Review of BMP Plan, Reporting, Monitoring,
Recordkeeping and Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Mill Costs for Amendment and Review of BMP Plan, Reporting, Monitoring,
Recordkeeping and Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Recurring Respondent Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Summary of Burden and Costs to Respondents and Government . . . . . . . . . . . . . . 12
Bottom Line Initial Burden and Costs Based in 2000 Dollars . . . . . . . . . . . . . . . . 12
Bottom Line Recurring Burden and Costs Based in 2000 Dollars . . . . . . . . . . . . . 13

Best Management Practices ICR

1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a)

Title of the Information Collection

ICR: Best Management Practices for the Bleached Papergrade Kraft and Soda Subcategory and
the Papergrade Sulfite Subcategory of the Pulp, Paper and Paperboard Point Source Category
(Renewal) (EPA ICR No. 1829.03).
1(b) Short Characterization/Abstract
This Information Collection Request (ICR) presents estimates of the burden and costs to
the regulated community (approximately 94 bleached papergrade kraft, soda and sulfite mills)
and NPDES permit and pretreatment control authorities for data collection and recordkeeping
associated with implementation of the Best Management Practices requirements of the Pulp and
Paper Effluent Limitations Guidelines and Standards (40 CFR Part 430.03). This is a renewal
ICR.
The Clean Water Act (CWA) authorizes the Environmental Protection Agency (EPA) to
include Best Management Practices (BMPs) in effluent limitations guidelines and standards
regulations. EPA’s legal authority to promulgate BMPs is found in Section 304(e), Section
307(b) and (c), Section 308(a), Section 402(a)(1)(B) and Section 501(a) of the Clean Water Act,
33 U.S.C. §1251, et. seq. EPA also relies on 40 CFR 122.44(k). The BMP regulation is
consistent with the Pollution Prevention Act of 1990, 42 U.S.C. § 13101, et. seq.
The objectives of the BMPs are to prevent leaks and spills of spent pulping liquors, soap
and turpentine for mills in bleached papergrade kraft and soda (Subpart B) and papergrade
sulfite (Subpart E) subcategories; and, to contain, collect and recover at the immediate process
area, or otherwise control, those leaks, spills and intentional diversions of spent pulping liquor
that do occur. EPA has emphasized control of spent pulping liquors, intentional liquor
diversions, soap and turpentine for the following reasons: (1) losses of spent pulping liquor
contribute significant portions of untreated wastewater loadings and discharge loadings of color,
oxygen-demanding substances, and non-chlorinated toxic compounds from chemical pulp mills;
(2) spent pulping liquor spills and intentional liquor diversions are a principal cause of upsets
and loss of efficiency of biological treatment systems that are used for treatment of Subpart B
and E mill wastewaters, thus contributing to increased effluent discharges of toxic, conventional
and nonconventional pollutants; (3) soap and turpentine are substances that are highly toxic to
biological treatment systems; and (4) control of spent pulping liquors is a form of pollution
prevention that can result in cost savings, less demand for make-up pulping chemicals, increased
energy efficiency, more effective wastewater treatment and incidental reductions in atmospheric
emissions of total reduced sulfur (TRS) compounds from kraft mills and volatile hazardous air
pollutants from Subpart B and E mills.
The regulation requires that owners or operators of Subpart B and E mills prepare and
implement site-specific BMPs for management of spent pulping liquors and prevent and control
losses of soap and turpentine. In addition, the regulation requires mills to monitor the
effectiveness of BMP implementation on a continuing basis by tracking the influent-to-treatment
wastewater loading. EPA has structured the BMP regulation to provide maximum flexibility to
the regulated community and to minimize administrative burdens on NPDES permit and
1

Best Management Practices ICR

pretreatment control authorities that regulate Subpart B and E mills. In fact, the final BMP
regulation provides flexibility for mill owners or operators to select any reasonable measure of
organic loading and/or spent pulping liquor losses to monitor the effectiveness of BMPs. Also,
the final regulation is less prescriptive than the proposed rule with regard to inspection, repair
and log-keeping requirements. EPA determined that the final rule language allows mills to use
existing maintenance and repair tracking systems to fulfill the aforementioned requirements
thereby reducing burden to the industry. By promulgating a national regulation for BMPs, EPA
has effectively removed substantial administrative and technical burdens on NPDES and
pretreatment control authorities to devise and implement these requirements on a case-by-case
basis through their permit programs.
In summary, implementation of effective BMPs has been shown to provide a potential
significant payback to a mill. In one incident at an indirect-discharging kraft mill in the
southeastern U.S. in July 1993, a process upset caused a release of excess spent pulping liquor to
the POTW, which then caused a fish kill. The resulting costs for cleanup and mill shutdown
were approximately equal to the cost of full implementation of BMPs at the mill.
2. NEED FOR AND USE OF THE COLLECTION
2(a) Need/Authority for the Collection
In the BMP regulation, EPA is requiring mills with pulp production Subpart B and E
Subcategories to develop and implement BMPs to prevent or otherwise contain leaks and spills
and to control intentional diversions of spent pulping liquor, soap and turpentine. These BMPs
apply to direct and indirect discharging mills within these subcategories and are intended to
reduce wastewater loadings of color, oxygen-demanding substances, and non-chlorinated toxic
compounds and hazardous substances in mill wastewater, with incidental reductions in
conventional water pollutants and certain air pollutants.
EPA’s legal authority to promulgate this BMP regulation is found in Section 304(e),
Section 307(b) and (c), Section 308(a), Section 402(a)(1)(B), Section 402(a)(2) and Section
501(a) of the Clean Water Act, 33 U.S.C. § 1251, et seq. EPA also relies on 40 CFR §
122.44(k). This BMP regulation is also consistent with the Pollution Prevention Act of 1990, 42
U.S.C. § 13101, et seq. For further discussion of EPA's legal authority to require mills to
develop and implement BMPs, including the information collection requirements discussed in
this document, see the BMP Technical Support Document (BMP TSD, DCN 14489).
2(b) Practical Utility/Users of the Data
The primary users of the information generated through BMP Plans will be the owners
and operators of the Subpart B and E pulp and paper mills. EPA intends that the data collected
(in the form of BMP monitoring reports) will be used by mill operators to track the effectiveness
and progress of BMP implementation through comparisons with action levels established by the
mill. Under the regulation, whenever monitoring results exceed action levels for particular
periods, the mill must complete an investigation or corrective action, as appropriate.
EPA also expects that the monitoring reports required by the BMP regulations will be
used by NPDES and pretreatment control authorities to determine compliance with the
2

Best Management Practices ICR

regulation. EPA anticipates that State and local control authorities will conduct detailed
technical reviews of BMP Plans only in the event the monitoring reports indicate noncompliance
with BMP conditions contained in the mill's NPDES permit or pretreatment control mechanism.
3.
NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA
3(a)

Nonduplication

EPA has examined all other reporting requirements contained in the Clean Water Act and
40 CFR Parts 122, 123, 124, 125, 501, and 503. The Agency also has consulted the following
sources of information to determine if similar or duplicative information is available elsewhere:
•
•
•

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

Examination of these databases revealed no duplicative reporting requirements.
EPA has examined a similar reporting requirement for notice of spills under the Resource
Conservation and Recovery Act (RCRA) for duplication of the requirements of this regulation.
The requirements for reporting of pollutant releases under RCRA is different than reporting of
spills or losses of spent pulping liquor, soap or turpentine outside the immediate process areas
under this regulation. EPA has concluded that there is no other way to obtain the compliance
assessment information addressed in this ICR.
3(b)

Public Notice Required Prior to ICR Submission

EPA solicited comments on this ICR prior to formal submission to OMB. EPA published
a formal notice in the Federal Register on August 30, 2004 (69 FR 52883-52888). EPA
received no comments.
3(c)

Consultations

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

Effects of Less Frequent Data Collection

The regulation requires collection of daily influent-to-treatment data. Most mill
operators collect such data independent of this requirement for purposes of monitoring and
optimizing wastewater treatment plant operations. Because spill, leaks and losses of spent
pulping liquors can and do occur frequently and at any time, less frequent monitoring would not
provide the timely information to mill operators to identify and respond to a spill, leak or loss
event.

Best Management Practices ICR

3(e)

General Guidelines

This information collection is consistent with OMB guidelines contained in 5 CFR
1320.6 and 1320.12.
3(f) Confidentiality
EPA does not expect that confidential business information or trade secrets will be
required from mill operators as part of this ICR. In the event that the information submitted in
conjunction with this ICR is claimed to be confidential business information (CBI) by the mill
owner or operator, the information would then be handled pursuant to 40 CFR Part 2 when EPA
is the permitting authority and applicable State and local government rules and regulations
governing CBI when States or local governments are the permitting or pretreatment control
authorities. Any mills that may consider asserting CBI claims should do so carefully as they
may be asked to support any such claims at a later date.
3(g)

Sensitive Questions

The reporting requirements addressed in this ICR do not include sensitive questions.
4.

THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents and SIC Codes

The respondents for this ICR will be approximately 94 direct and indirect discharging
Subpart B and E pulp mills in the Pulp, Paper and Paperboard Manufacturing Category (SIC
2611, 2631) (NAICS 32211,322121, 322122, 32213). Government respondents are estimated to
be 34 State and local authorities (24 NPDES and pretreatment approval-authorized States and 10
local pretreatment control authorities) for preparation of new NPDES permits and pretreatment
conditions for implementing the BMP regulation and conducting detailed technical reviews of
BMP Plans in the event the monitoring reports indicate noncompliance with BMP conditions
contained in the mill's NPDES permit or pretreatment control mechanism.
4(b) Information Requested
The BMP regulations at 40 CFR 430.03 include the following major components:
(1) development, review and certification of a BMP plan; (2) amendment and periodic review of
the BMP plan; (3) reporting of spills; (4) additional monitoring and reporting; and (5) additional
recordkeeping. See 40 CFR 430.03(c) through (i) and the BMP TSD for more detailed
information on the requirements. The development, review, and certification of a BMP plan is
an initial one-time component of the BMP regulations, and the associated burden was already
accounted for in the original ICR (No. 1829.01). Therefore, that burden is not included in this
renewal ICR.
(1) Development, review and certification of a BMP plan [§430.03(d) and (f)]:
Central to the BMP regulation is the development of a BMP plan. This plan is intended
to be the initial and ongoing BMP planning and implementation tool for mills. The BMP plan
4

Best Management Practices ICR

must, at a minimum, include programs: (a) to identify and repair leaking equipment; (b) to track
equipment repairs; (c) to train personnel; (d) to report and evaluate spills; (e) to review planned
mill modifications; and (f) to establish wastewater treatment system influent action levels
(including an initial six-month monitoring program).
Also, as part of the BMP plan development, each mill must conduct a detailed
engineering review of the pulping and chemical recovery areas to determine the magnitude and
routing of potential leaks, spills, and intentional diversions of spent pulping liquors, soap and
turpentine and to determine the adequacy of containment and collection facilities (see 40 CFR
430.03 (d) (3) for additional details). The BMP plan and any amendments require review by the
senior technical manager and certification by the mill manager.
(2) Amendment and periodic review of a BMP Plan [§430.03(e)]:
Owners or operators must amend their BMP Plans whenever there is a change in mill
design, construction, operation, or maintenance that materially affects the potential for leaks or
spills of spent pulping liquor, soap or turpentine from the immediate process areas.
Notwithstanding this requirement, owners or operators must complete a review and evaluation of
their BMP Plans at least once every five years and amend the plan within three months of such
review, if warranted. As mentioned above, any BMP plan amendments require review by the
senior technical manager and certification by the mill manager.
(3) Reporting of spills [§430.03(c)(5)]:
Owners or operators are required to prepare brief reports of spills of spent pulping liquor,
soap or turpentine not contained in the immediate process area (e.g., a failure of the management
practices and control systems identified by the owner or operator in the BMP Plan). The report
must list the equipment items involved, the circumstances leading to the incident, the
effectiveness of corrective actions taken and plans to implement future changes. These reports
must be maintained by the mill owner or operator for three years and they need only be
submitted to the NPDES permit or pretreatment control authority upon request.
(4) Additional monitoring and reporting [§430.03 (c)(3), (g), (h) and (i)]:
Mills are required to operate continuous, automatic monitoring systems that the mill
determines are necessary to detect and control leaks, spills, and intentional diversions of spent
pulping liquor, soap, and turpentine. See 40 CFR 430.03(c)(3). As part of this requirement, all
mills (with the exception of new sources) are required to perform two six-month monitoring
programs in order to determine the characteristics (or action levels) of their wastewater treatment
system influent. See 40 CFR 430.03(h). (New sources are required to perform only one
six-month monitoring program for this purpose. See 40 CFR 430.03(h)(5).) All mills are also
required to perform additional monitoring to revise those action levels after any change in mill
design, construction, operation, or maintenance that materially affects the potential for leaks or
spills or spent pulping liquor, soap, or turpentine from the immediate process area. See 40 CFR
430.03(h)(6). The regulation also requires all mills to conduct daily monitoring of wastewater
treatment system influent for the purpose of detecting leaks and spills, tracking the effectiveness
of the BMPs, and detecting trends in spent pulping liquor losses. See 40 CFR 430.03(i).

Best Management Practices ICR

Mill operators are required to provide their NPDES permit or pretreatment control
authorities reports of the monitoring required by the BMP regulation. See 40 CFR 430.03(i)(4).
The reports must include a summary of the monitoring results, the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken
to respond to such exceedances. Submission of such reports shall be at the frequency established
by the NPDES permit or pretreatment control authority, but in no case less than once per year.
(5) Recordkeeping requirements [§430.03(g)]:
The regulation requires that certain equipment repair records, records of employee
training, reports of spills outside the immediate process area, and records of monitoring
conducted as part of the BMP program be maintained for three years.
4(c) Respondent Activities
Mill respondent activities include the following:
C

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

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

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

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

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

The initial one-time burden associated with mill respondents conducting initial employee
training and developing and certifying the BMP plan and State permitting and local pretreatment
control authority activities in preparing NPDES permit and pretreatment conditions was already
accounted for in the original ICR (No. 1829.01) and, therefore, is not included in this renewal
ICR.

Best Management Practices ICR

5.
THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a)

Agency Activities

Upon approval of this renewal ICR, permittees must continue to maintain records as
described above in Section 4(c) and at least annually, must submit to the NPDES or pretreatment
control authority a report summarizing the results of daily monitoring, the number and dates of
any exceedances of action levels and corrective actions taken when action levels are exceeded.
The permitting authority can be either an approved NPDES State or one of EPA’s regional
offices. The permitting authority or pretreatment control authority is authorized to conduct
compliance audits of facility records, review the data, and where necessary, conduct follow-up
actions. Follow-up activities may include informal contact with the permittee (by telephone or
letter) to discuss the cause of any exceedances of action levels and responses taken to correct the
exceedences. Because the requirements to implement the BMPs and maintain records will be
incorporated in a mill's NPDES permit or pretreatment control mechanism as enforeceable
conditions, the permitting authority will be responsible for assessing whether the mill is properly
maintaining records (including the BMP Plan) and thus, performing equipment repairs,
employee training and responding to any exceedance events in a timely manner. Review of
monitoring records may also be helpful to the permit writers in the development of future
NPDES permit conditions.
The extent to which EPA reviews data will depend on available resources and the
specific reviewing procedures of the permitting authority (State or EPA region). In NPDES
States, State environmental agencies generally review permittee data. EPA regions may also
review data from major permittees in NPDES States while performing program oversight
functions, particularly since the assessment of compliance is subjective.
5(b)

Collection Methodology and Management

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

Small Entity Flexibility

EPA has already certified that the Cluster Rules, including the BMP requirements will
not have a significant economic impact on a substantial number of small entities as that term is
used in the RFA (see Section X.C. of the Preamble to the final Cluster Rules published in the
Federal Register on April 15,1998 (see 63 FR 18611)

Best Management Practices ICR

5(d)

Collection Schedule

The majority of information collection activities included in this ICR are anticipated to
coincide with existing monitoring, recordkeeping, and reporting requirements (e.g., Discharge
Monitoring Reports), although some recordkeeping may be non-routine, such as spill reporting.
6.

ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a)

Estimating Respondent Burden and Costs

Burden and costs will vary based upon mill complexity, see Table 1. Tables 2 presents
estimates of the recurring mill respondent burdens for labor hours and costs associated with this
ICR. The assumptions made are listed in each Table. A summary of the mill respondents'
burden hours and costs is presented in Table 3. A brief description of the basis for the burden
estimates is presented below.
(1) Development, review and certification of a BMP plan:
Development of a site-specific BMP plan is a one-time initial burden. As part of the
BMP plan development, mills must also establish a training program for technical personnel.
This training program must include both an initial training effort and refresher training, which at
a minimum, must be performed annually. The burden associated with the development of the
BMP plan and initial training were already accounted for in the original ICR (No. 1829.01) and
are, therefore, not included in the burden estimates of this renewal ICR. The refresher training is
based on bi-annual effort of four hours each, including nine operators and one consultant acting
as trainer. The total burden for refresher training per mill is estimated to be 72 hours of operator
effort (at $32.81 per hour) and eight hours of consultant engineering effort (at $64.58 per hour).1
(2) Amendment and periodic review of a BMP Plan:
EPA anticipates less than 50 hours of mill labor per amendment and has based the ICR
burden on an assumption that each mill would need to amend its BMP plan twice every five
years for an annual burden of 20 hours, estimating 18 hours of mill engineer effort (at $64.58 per
hour) and two hours of management effort (at $88.49 per hour), which is included in the annual
estimates presented in Tables 2 and 3.2

Estimates for operator and engineer labor costs were prepared using industry-specific labor rates identical
to those used for the EPA ICR Number 1878.01, included overhead and fringe benefits, and adjusted to January
2004 dollars with the Employment Cost Index. To verify the validity of the adjusted rates EPA obtained national
industry-specific wage estimates for the pulp, paper, and paperboard mills from the Labor Department. Noting that
the Labor Department wages were lower, EPA decided to apply the more conservative estimates from the previous
ICR.
2

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

Best Management Practices ICR

(3) Reporting of spills:
EPA anticipates that the burden of preparing a spill report is approximately four hours
and can be conducted by a mill engineer (at $64.58 per hour). ICR burden is calculated on an
annual basis using an assumption of one spill per mill per month and is included in the annual
estimates presented in Table 2 and 3.
(4) Additional monitoring and reporting:
Mills are required to operate continuous, automatic monitoring systems that the mills
determine are necessary to detect and control leaks, spills, and intentional diversions of spent
pulping liquor, soap, and turpentine. The burden for designing, testing, and operating the
monitoring system, expressed in the form of costs, is included in the compliance cost estimates
developed for the regulation (see Table 9.2 of the BMP TSD, DCN 14489).
In addition, all mills with the exception of new sources are required to perform two
six-month monitoring programs in order to determine the characteristics (or action levels) of
their wastewater treatment system effluent. See 40 CFR 430.03(h). (New sources are required
to perform only one six-month monitoring program for this purpose.) All mills are also required
to perform additional monitoring to revise those action levels after any change in mill design,
construction, operation, or maintenance that materially affects the potential for leaks or spills or
spent pulping liquor, soap, or turpentine from the immediate process area. The effort required to
implement the initial monitoring program and perform the associated statistical analysis to
establish the action levels is included in the compliance cost estimates developed for the
regulation, and the burden to perform monitoring to revise those action levels is included in the
incremental monitoring burden discussed below.
The regulation also requires all mills to conduct daily monitoring of wastewater
treatment system influent for the purpose of detecting leaks and spills, tracking the effectiveness
of the BMPs, and detecting trends in spent pulping liquor losses. EPA estimates the burden
associated with this monitoring to be an increment of one additional hour per day of operator
time over existing burden imposed by minimum monitoring; this increment is included in the
annual estimates shown in Tables 2 and 3. Costs for monitoring equipment were included as
initial capital costs in the original ICR (No. 1829.01). Therefore, these one-time costs are not
included in the burden estimates of this renewal ICR.
Mill operators are required to provide their NPDES permit or pretreatment control
authorities reports of the monitoring required by the BMP regulation. Submission of such reports
shall be at the frequency established by the NPDES permit or pretreatment control authority, but
in no case less than once per year. EPA has based the burden estimates on a semi-annual
reporting frequency and estimates that each report will take 16 hours to complete, based on 14
hours of mill engineer effort and two hours of management effort (also included in estimates
presented in Tables 2 and 3).
(5) Recordkeeping requirements:
Burden estimates for recordkeeping are based on an incremental level of effort to comply
with BMP requirements consisting of two to four hours per month for the operators/shift
9

Best Management Practices ICR

supervisors over current shift log recordkeeping (at $32.81per hour), two to four hours per
months for mill engineers (at $64.58 per hour), and two hours per month for clerical support (at
$18.42 per hour). These burden estimates are also included in the annual estimates presented in
Tables 2 and 3 .3
(6) NPDES permit provisions, pretreatment conditions and periodic review
The initial burden to State NPDES permitting and pretreatment control authorities for
preparation of NPDES permit provisions and pretreatment conditions for implementing the BMP
regulation was already accounted for in the new ICR. Therefore, this burden is not included in
this renewal ICR. For the 82 facilities located in states with NPDES authority and the 10
facilities located in pretreatment control authorities EPA estimates an incremental ten hours per
year per facility for reviewing periodic (e.g., annual or semi-annual) monitoring reports and
conducting compliance reviews.
Estimates for Federal and State labor rates were based on the 2003 US Labor department
figures adjusted to January 2004 dollars with the Employment Cost Index, whereby the average
annual salary for Federal and State employees is $47,112; this is equivalent to the salary of a
GS-9, Step 10 Federal employee. At 2,080 available labor hours per year, the hourly rate is
$22.65. Overhead costs for Federal and State employees are estimated by EPA to be 60 percent
(EPA ICR Handbook), or $13.59 per hour, which results in a total hourly rate of $36.24 ($22.65
+ $13.59).
Estimates for local pretreatment control authority employees (i.e., POTW employees)
were based on the 2002 US Labor department figures for the wages and salaries value for State
and local government workers adjusted to January 2004 dollars with the Employment Cost Index
plus a 50 percent overhead burden; this is equivalent to an hourly rate of $33.36 ($22.24 +
$11.12).

Table 1. Summary of Mill Status
CATEGORY
Kraft & Soda
Sulfite
Total Mills

Simple
41
10
51

Moderately Complex
30
0
30

Complex
13
0
13

Total
84
10
94

Estimates for clerical labor rate from the May 2003 National Industry-Specific Occupational Employment
and Wage Estimates for NAICS 322100 - Pulp. Paper, and Paperboard Mills. The mean hourly wage for File Clerks
(SOC Code 43-4071), including 50 percent for overhead and fringe benefits and adjusted to January 2004 dollars
with the Employment Cost Index, is $18.42.

Best Management Practices ICR

Table 2. Mill Labor for Amendment and Review of BMP Plan, Reporting, Monitoring,
Recordkeeping and Training (hours)
Item
Simple
Amendment and Review of BMP
Plan
Reporting of Spills
Additional Monitoring and
Reporting
Recordkeeping
Refresher Training
TOTAL

Kraft & Soda
Moderately
Complex
Complex

Sulfite
Total

Simple

Total

TOTAL
HOURS

820

600

260

1,680

200

1880

1,968

1,440

624

4,032

480

4512

16,277

11,910

5,161

33,348

3,970

37318

2,952
3,280
25,297

2,880
2,400
19,230

1,560
1,040
8,645

7,392
6,720
53,172

720
800
6,170

8112
7520
59,342

Table 3. Mill Costs for Amendment and Review of BMP Plan, Reporting, Monitoring,
Recordkeeping and Training
Item
Simple
Amendment and
Review of BMP Plan
Reporting of Spills
Additional Monitoring
and Reporting
Recordkeeping
Refresher Training
TOTAL

$54,916

Kraft & Soda
Moderately
Complex
Complex
$40,183
$17,412

Sulfite
Total

Simple

Total

$112,511

$13,394

$127,093
$579,652

$92,995
$424,136

$40,298
$183,792

$260,387
$1,187,579

$30,998
$141,379

$113,957
$118,037
$993,655

$118,444
$86,369
$762,127

$66,518
$37,426
$345,446

$298,919
$241,833
$2,101,229

$27,794
$28,790
$242,355

TOTAL
COSTS
$125,905
$291,385
$1,328,958
$326,713
$270,623
$2,343,584

Table 4. Recurring Mill Respondent Burden and Costs
Status
Kraft & Soda
Simple
Moderately Complex
Complex
Total Kraft & Soda
Sulfite
Simple
Total Sulfite
TOTAL MILLS

6(b)

Total Labor Hours

Total Recurring Costs

25,297
19,230
8,645
53,172

$993,655
$762,127
$345,446
$2,101,229

6,170
6,170
59,342

$242,355
$242,355
$2,343,584

Estimating Agency Burden

The initial burden to EPA from non-authorized State NPDES permitting and pretreatment
control authorities for preparation of NPDES permit provisions and pretreatment conditions for
implementing the BMP regulation was already accounted for in the new ICR. Therefore, this
burden is not included in this renewal ICR. For the 2 facilities located in states without NPDES
11

Best Management Practices ICR

authority EPA estimates an incremental ten hours per year per facility for reviewing periodic
(e.g., annual or semi-annual) monitoring reports and conducting compliance reviews, for a total
of 20 hours annually.
EPA estimates an incremental labor burden of approximately eight hours per facility for a
total of 752 hours annually. This burden accounts for anticipated support of State and local
authority efforts described in Section 6(a). The estimated incremental labor burden for the BMP
regulation is 772 (752 + 20) hours. Using the hourly labor rate of $36.24 (see Section 6(a)(6)),
recurring Agency costs are estimated at $27,977. A summary of the Agency burden hours and
costs is presented in Table 5.
Table 5. Summary of Burden and Costs to Respondents and EPA
Category

Total Labor Hours

Respondents - Annual Burden
Kraft & Soda Mills
Sulfite Mills
Total

Total Costs

53,172
6,170
59,342

$2,101,229
$242,355
$2,343,584

820
100

$29,717
$3,336

772

$27,977

States & Local Governments Annual Burden
States
Local Governments (pretreatment)
EPA
Annual Burden

6(c) Bottom Line Burden and Costs Tables
The bottom line burden hours and cost tables for respondents are the summaries of all the
hours and costs incurred for all activities. There are no Operating and Maintenance costs
associated with this Information Collection Request.

(1) Respondent Tally
The bottom line respondent (mills, State permitting and local pretreatment authorities)
tally is presented in Table 6.
Table 6. Total Estimated Respondent Burden and Cost Summary (2004 Dollars)
Category

Number of
Respondents

Total Hours
Per Year

Total Labor
Cost Per Year

Respondents - Subpart B and E mills

59,342

$2,343,584

Respondents - State Athorities

820

$29,717

Respondents -Local authorities

100

$3,336

Total Respondents

128

60,262

$2,376,637

Best Management Practices ICR

(2) Agency Tally
The bottom line Agency tally is presented in Table 7.
Table 7. Total Estimated Agency Burden and Cost Summary ( 2000 Dollars)
Category

Total Hours Per Year

Total Labor Cost Per Year

772

$27,977

Agency

6(d) Reasons for Changes in Burden
As this is a renewal information collection, the change in burden for this collection
includes adjusting from 2000 to 2004 dollars and account for new NPDES authorized states.
6(e) Burden Statement
The recurring burden for a mill to periodically review and amend the BMP plan, prepare
spill reports, perform additional monitoring, hold refresher training, and conduct recordkeeping
and reporting is estimated to be 617, 641 and 665 hours annually per mill for simple, moderately
complex and complex mills, respectively. The total recurring cost for mills associated with the
BMP requirements is estimated at $2,343,811
The recurring burden to State NPDES and pretreatment control authorities is estimated at
ten hours per year per facility for reviewing periodic (e.g., annual or semi-annual) monitoring
reports and conducting compliance reviews. The total recurring costs for State NPDES and
pretreatment control authorities is estimated at $29,716 and $3,336 respectively.
The recurring burden to EPA is estimated at ten hours per year per facility in non NPDES
authorized states and eight hours per year per facility for support of State and local authority
efforts in reviewing periodic (e.g., annual or semi-annual) monitoring reports and conducting
compliance reviews. The total recurring costs for EPA is estimated at $27,977.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to
comply with any previously applicable instructions and requirements; train personnel to be able to
respond to a collection of information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information. An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control numbers for EPA's regulations are listed
in 40 CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the use
of automated collection techniques, EPA has established a public docket for this ICR under
13

Best Management Practices ICR

Docket ID No. OW-2004-0023, which is available for public viewing at the Water Docket in the
EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW,
Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An
electronic version of the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket. Use EDOCKET to submit or view public comments, access the
index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. Once in the system, select “search,” then key in the
docket ID number identified above. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington,
DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (OW-20040023) and OMB control number (2040-0207) in any correspondence.

INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT
FOR
MINIMUM MONITORING REQUIREMENTS FOR DIRECT AND INDIRECT
DISCHARGING MILLS IN THE BLEACHED PAPERGRADE KRAFT AND SODA
SUBCATEGORY AND THE PAPERGRADE SULFITE SUBCATEGORY OF THE
PULP, PAPER AND PAPERBOARD POINT SOURCE CATEGORY (RENEWAL)
(40 CFR PART 430)
EPA ICR Number 1878.02
OMB Control Number 2040-0243

May 2005

U.S. Environmental Protection Agency
Office of Water
Engineering and Analysis Division
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460

Minimum Monitoring Requirements ICR

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TABLE OF CONTENTS
1.

IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . .
1(a) Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1(b) Short Characterization/Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2(a) Need/Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2(b) Practical Utility/Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(a) Non-duplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(b) Public Notice Required Prior to ICR Submission . . . . . . . . . . . . . . . . . . . . . . . . . .
3(c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(d) Effects of Less Frequent Data Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(f) Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3(g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2
2
3
3
3
5
5
5

THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . . . . . . . .
4(a) Respondents and SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4(b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4(c) Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4(d) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6
6
6
9
9

THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . .
5(a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(b) Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5(d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

11
11
12
12
12

ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . .
6(a) Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6(b) Estimating Respondent Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6(c) Estimating Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6(d) Estimating the Respondent Universe and Total Burden and Costs . . . . . . . . . . . .
6(e) Bottom Line Burden Hours and Cost Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6(f) Reason for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6(g) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

12
12
19
22
23
23
24
24

1
1
1

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LIST OF TABLES
Table 4.1
Table 4.2

Table 4.3
Table 4.4
Table 4.5
Table 4.6
Table 6.1
Table 6.2
Table 6.3
Table 6.4
Table 6.5
Table 6.6
Table 6.7
Table 6.8
Table 6.9
Table 6.10
Table 6.11
Table 6.12
Table 6.13
Table 6.14

Minimum Monitoring: Mill Respondent Requirements . . . . . . . . . . . . . . . . . . . . . . 6
Reduced Effluent Monitoring for TCDD, TCDF, Chloroform, and the
12 Chlorinated Phenolics for Mills Participating in the Voluntary Advanced
Technology Incentives Program (VATIP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Duration of Reduced Effluent Monitoring for TCDD, TCDF, Chloroform,
and the 12 Chlorinated Phenolics for Mills Participating in the VATIP . . . . . . . . . 8
Reduced Effluent Monitoring for AOX for Mills Participating in the VATIP . . . . 8
NPDES-authorized State Requirements (As Users of Data) . . . . . . . . . . . . . . . . . 10
State and Local Pretreatment Control Authorities Requirements . . . . . . . . . . . . . 10
Regulated Pollutants and Number of Affected Mills and Lines . . . . . . . . . . . . . . . 13
Annual Sampling Burden for Subpart B Bleached Papergrade
Kraft and Soda Mills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Annual Sampling Burden for Subpart E Papergrade Sulfite Mills . . . . . . . . . . . . . 15
Annual Reporting Burden for Each Pollutant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Annual Reporting Burden for Subpart B and E Mills . . . . . . . . . . . . . . . . . . . . . . 17
Annual Recordkeeping Burden for Subpart B and E Mills . . . . . . . . . . . . . . . . . . 17
Summary of Annual Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Labor Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Analytical Sample Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Annual (O&M) Estimate of Analytical Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Summary of Annual Agency Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Summary of Annual Respondent Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . 23
Total Estimated Annual Respondent Burden and Cost Summary (2004 Dollars) . 24
Total Estimated Annual Agency Burden and Cost Summary (2004 Dollars) . . . . 24
LIST OF APPENDICES

Appendix A: Supporting Assumptions and Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

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1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a)

Title of the Information Collection

ICR: Minimum Monitoring Requirements for Direct and Indirect Discharging Mills in the
Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of the
Pulp, Paper, and Paperboard Point Source Category (EPA ICR No. 1878.02) (OMB Control
Number 2040-0243).
1(b) Short Characterization/Abstract
This Information Collection Request (ICR) presents estimates of the burden and costs to
the regulated community and to the National Pollutant Discharge Elimination System (NPDES)
permit and pretreatment approval and control authorities for monitoring, reporting,
recordkeeping, and follow-up actions associated with implementation of the minimum
monitoring requirements of the Pulp, Paper and Paperboard Effluent Limitations Guidelines and
Standards (Cluster Rules; 40 CFR Part 430), which were published on April 15, 1998 for mills in
the Bleached Papergrade Kraft and Soda Subcategory (Subpart B) and the Papergrade Sulfite
Subcategory (Subpart E). See 63 FR 18504-18751. The regulated community consists of
approximately 94 direct and indirect discharging papergrade kraft, soda and papergrade sulfite
mills. This is a renewal ICR
The Cluster Rules establish minimum monitoring requirements for certain pollutants,
namely adsorbable organic halides (AOX), 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD),
2,3,7,8-tetrachlorodibenzofuran (TCDF), chloroform and 12 chlorinated phenolics. Pursuant to
the Paperwork Reduction Act, EPA intends to add these specific monitoring requirements
contained in the Cluster Rules (see 40 CFR § 430.02) to the ICR for NPDES/Sewage Sludge
Monitoring Reports ICR (OMB 2040-0004) and the National Pretreatment Program ICR (OMB
2040-0009). The current National Pretreatment Program ICR includes burden for indirect
dischargers regulated under the Cluster Rules. This ICR serves to clarify and augment the
burden already identified in the National Pretreatment Program ICR incurred by indirect
dischargers for compliance with minimum monitoring requirements.
This ICR covers the minimum monitoring requirements for 94 direct and indirect
discharging mills as well as the alternative requirements for those Subpart B mills that choose to
enroll in the Voluntary Advanced Technology Incentives Program (VATIP), and those Subpart
B mills that demonstrate compliance with applicable chloroform limitations and standards at a
fiber line in lieu of certain monitoring requirements, until such time that these requirements are
subsumed under the NPDES/Sewage Sludge Monitoring Reports ICR (OMB 2040-0004).
2. NEED FOR AND USE OF THE COLLECTION
2(a) Need/Authority for the Collection
As mentioned above, EPA established minimum monitoring frequencies for AOX,
TCDD, TCDF, chloroform, and 12 chlorinated phenolics for existing and new direct and indirect

Minimum Monitoring Requirements ICR

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discharging mills within Subparts B and E under authority of CWA Section 308. Discharge of
these pollutants into the freshwater, estuarine and marine ecosystems may alter aquatic habitats,
affect aquatic life and adversely impact human health. Chlorinated organic compounds from
chlorine bleaching, particularly TCDD and TCDF, are human carcinogens and human system
toxicants and are extremely toxic to aquatic life. Additionally, Section 402(a)(2) of the Clean
Water Act (CWA) directs EPA to prescribe permit conditions to assure compliance with
requirements “including conditions on data and information collection, reporting and such other
requirements as [the Administrator] deems appropriate.”
2(b) Practical Utility/Users of the Data
The primary users of the data are the owners and operators of direct and indirect
discharging pulp and paper mills in Subparts B and E and NPDES permitting, pretreatment
control, and enforcement authorities. Citizen groups also use this data to independently assess
facility compliance.
EPA expects that the monitoring reports will be used by NPDES and pretreatment control
authorities to determine compliance with the Cluster Rules effluent limitations and standards.
EPA, States, and local authorities also analyze monitoring data when establishing permit and
control agreement conditions and revise permit and pretreatment control agreement requirements
based on data from monitoring reports. Furthermore, EPA and States refer to discharge
monitoring reports and facility monitoring data on toxic pollutants when developing lists of
waters not meeting applicable water quality standards. EPA anticipates that State NPDES
permitting and pretreatment control authorities will only need to conduct detailed technical
reviews of monitoring reports in the event the monitoring reports indicate noncompliance with
the NPDES permit or pretreatment control agreement conditions.
EPA anticipates that permittees will use the monitoring data to track the effectiveness
and progress of reducing pollutant discharges. For this reason, most permittees usually collect
additional data (e.g., product quality and production efficiency information) that may or may not
be included with monitoring reports. Collection and reporting of data to permitting and
pretreatment control authorities also provides permittees with an incentive to remain in
compliance with their established permit limitations and conditions.
As public information, monitoring data is used by public environmental/citizen groups
for a variety of purposes. Citizen groups review monitoring data to independently assess
discharger compliance. In some instances the data forms the basis for citizen suits that are
authorized under Section 505 of the CWA. In addition, environmental groups, academicians and
others use monitoring data to estimate pollutant loadings to streams, lakes, oceans and estuaries.
3.

NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA
3(a)

Non-duplication

EPA has examined all other reporting requirements contained in the Clean Water Act and

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40 CFR Parts 122, 123, 124, 125, 430, 501, and 503. The Agency also has consulted the
following sources of information to determine if similar or duplicate information is available
elsewhere:
•
•
•

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

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

Public Notice Required Prior to ICR Submission

EPA solicited comments on the renewal of this ICR (No. 1878.02) on August 30, 2004
(69 FR 52883-52888). EPA did not receive any comments.
3(c)

Consultations

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

Effects of Less Frequent Data Collection

EPA has determined the minimum monitoring frequencies established, at 40 CFR
§430.02(a) and (b), are necessary to demonstrate compliance with the Cluster Rules’ effluent
limitations guidelines and standards. The regulation requires collection of daily, weekly, or
monthly discharge data, depending on the pollutant. Some mill operators may collect such data
independent of this requirement for purposes of monitoring and optimizing bleach plant,
chemical recovery, and wastewater treatment plant operations. EPA determined that the
minimum required monitoring frequencies were necessary because of the degree of change that
is expected to occur to and temporal variability in pulping and bleaching processes and the
resulting variations in effluent discharges of each fiber line that can and do occur frequently and
at any time. Therefore, EPA was concerned that less frequent monitoring would not provide the
information necessary to ensure compliance with the effluent limitations guidelines and
standards promulgated as part of the Cluster Rules. See 63 Fed. Reg. at 18571-72.
In establishing the minimum monitoring frequencies for the regulated pollutants, EPA
has struck a balance between the cost of the monitoring regimen and the need to ensure that
sufficient data is consistently available to permitting and pretreatment control authorities.
Permitting and pretreatment control authorities need to have an adequate basis to verify
compliance with the effluent limitations and standards given the environmental significance of
these pollutants that are highly toxic and bioaccumulative, and the generation of which is

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variable as available data clearly demonstrate. This monitoring regimen also ensures sufficient
data are available to the mill so that the mill may quickly become aware of and react to releases
that may be harmful to the environment.
EPA selected a minimum monitoring frequency of once per month for TCDD, TCDF,
and chlorinated phenolic pollutants. These pollutants are the most toxic and bioaccumulative
among those regulated yet are also the most costly to analyze. EPA expects the 12 data points
for each pollutant per year, together with daily end-of-pipe AOX data and information on
process conditions from detailed mill logs, will yield a meaningful basis for establishing
compliance with the promulgated effluent limitations and standards.
EPA selected a minimum monitoring frequency of once per week for chloroform. This
monitoring frequency has been selected because data available indicates there can be
considerable temporal variability of this pollutant in bleach plant wastewaters. This variability is
attributable to a number of process and operational variables. Therefore, more data is required
to adequately assess compliance with the limitations and standards on both a long-term and
short-term basis. The cost of laboratory analysis of chloroform is much lower than for TCDD,
TCDF, and chlorinated phenolics. Weekly data and information on process conditions from
detailed mill logs will yield a meaningful basis for establishing long-term compliance trends in
chloroform discharge loadings and developing process control strategies to also ensure the shortterm compliance with the promulgated effluent limitations and standards.
EPA selected a minimum monitoring frequency of once daily for AOX for non-TCF
(totally chlorine free) mills. This monitoring frequency has been selected because there can be
considerable daily variability in chlorinated organic discharge loadings to receiving streams.
Discharge loadings reflect bleach plant discharge patterns and secondary biological treatment
system performance that is readily measured at reasonable cost. AOX analysis costs are
anticipated to decrease as the number of mills (in the respondent universe of this ICR) begin
compliance monitoring efforts with the Cluster Rules. Daily monitoring for AOX provides a
continuous data stream of all chlorinated organic constituents in wastewater, allowing mill
operators and permit authorities to assess and control both process technologies and end-of-pipe
biological treatment systems.
The minimum monitoring frequencies as described above will provide sufficient
information to: (1) evaluate mill compliance with the Cluster Rules limitations and standards
over the long term; and (2) allow permitting and pretreatment control authorities to judge
whether a different frequency of monitoring is warranted after the initial compulsory period of
minimum monitoring has been completed.
Additionally, EPA has offered Subpart B mills several options to reduce monitoring
burden over the course of the permit cycle. These options include:
C
C

Enrollment in the VATIP, which was established by the Cluster Rules.
Certification in lieu of monitoring for chloroform (proposed on April 15, 1998, 63
FR 18796, promulgated September 19, 2002, 67 FR 58990).

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Mills participating in the VATIP may be eligible for further reductions in monitoring
requirements. See 40 CFR 430.02(c)-(e). Mills enrolling in the VATIP are subject to more
stringent BAT limitations and NSPS than EPA could otherwise compel through its minimum
BAT and NSPS effluent limitations guidelines and standards. To encourage participation in the
incentives program, EPA has provided for reduced monitoring requirements for participating
mills. The reduced monitoring incentive applicable to AOX, TCDD, TCDF, chloroform and the
12 chlorinated phenolics is available as soon as participating mills achieve baseline BAT
limitations, and for AOX after mills achieve the ultimate VATIP limitations (see Table 4.2). See
also 63 FR 18609-18610 and 64 FR 36580-36586.
EPA has promulgated a certification mechanism for Subpart B mills that demonstrate to
the NPDES permitting authority that they have achieved the applicable limitations or standards
for chloroform for a period of two years and that certain process and operating conditions are
maintained. See 67 FR 58990-58998. Each mill voluntarily choosing to certify in lieu of
monitoring for a fiber line would be required to maintain records documenting that process and
operational conditions are maintained within the range established during the initial compliance
demonstration. Following the required two year minimum monitoring period, mills would no
longer be subject to minimum monitoring requirements for chloroform as required by 40
CFR§430.02. As a result, the total monitoring burden would be reduced.
EPA acknowledges that both the VATIP and the certification in lieu of monitoring could
substantially modify the burden reflected in this ICR. Nevertheless, these modifications are
presented as stand alone ICR and are not included in this document. See EPA ICR Numbers
1877.03 and 2015.02.
3(e)

General Guidelines

This information collection is consistent with OMB guidelines contained in 5 CFR
1320.5(d)(2).
3(f) Confidentiality
EPA does not expect that confidential business information (CBI) or trade secrets will be
required from mill operators as part of this ICR. Where information submitted in conjunction
with this ICR contains CBI, the respondent may request that this information be treated as
confidential business information. All data so designated will be handled pursuant to 40 CFR
Part 2 when EPA is the permitting or pretreatment control authority, and pursuant to applicable
state rules and regulations governing CBI when states are the permitting or pretreatment control
authorities. Pursuant to Section 308(b) of the Clean Water Act, effluent data may not be treated
as confidential.
3(g)

Sensitive Questions

The reporting requirements addressed in this ICR do not include sensitive questions.
4.

THE RESPONDENTS AND THE INFORMATION REQUESTED

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4(a) Respondents and SIC Codes
The respondent universe for this ICR will be: 1) approximately 94 direct and indirect
discharging chemical pulp mills included in Subpart B (Bleached Papergrade Kraft and Soda)
and Subpart E (Papergrade Sulfite) of the Pulp, Paper and Paperboard Manufacturing Category
(SIC 2611, 2631) (NAICS 32211,322121,322122, 32213); and 2) the 34 NPDES and
pretreatment approval-authorized States and 10 local pretreatment control authorities responsible
for ensuring compliance with NPDES and pretreatment regulations. Pretreatment approval
authorities are defined as regulatory agencies, EPA or States, that oversee programs
implemented by individual pretreatment control authorities (i.e., publically owned treatment
works (POTWs)).
4(b) Information Requested
The following sections outline the monitoring, reporting, and recordkeeping requirements
for direct and indirect discharging facilities under 40 CFR 430. Table 4.1 outlines the
information requirements for each category of respondents. The data requirements are listed by
regulation number.
Table 4.1 Minimum Monitoring: Mill Respondent Requirements
40 CFR Citation

Regulatory Description

Monitoring and/or
Reporting Frequency

Monitoring Requirements: Sample Collection and Analysis
430.02 (a)

For each non-TCF (Totally Chlorine Free) bleaching
fiber line, mills must conduct minimum monitoring at the
following frequencies:
•
AOX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
chloroform . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
each of the 12 chlorinated phenolics . . . . . . . . .

430.54 (a), 430.56 (a)

AOX limits are reserved for non-TCF bleaching lines at
direct and indirect Subpart E mills, therefore no
minimum monitoring requirements for AOX exist for
these mills.

430.02 (a)

There are no specified minimum monitoring frequencies
for fiber lines with exclusively TCF bleaching.

430.02 (b)

For direct dischargers, minimum monitoring frequencies
apply for a duration of five years commencing on the
date the applicable limitations or standards are first
included in the discharger’s NPDES permit.

Daily
Weekly
Monthly
Monthly
Monthly

None

Minimum Monitoring Requirements ICR

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Table 4.1 Minimum Monitoring: Mill Respondent Requirements
430.02(b)

For existing indirect dischargers, minimum monitoring
frequencies apply until April 17, 2006. For new indirect
dischargers, minimum monitoring frequencies apply for a
duration of five years commencing on the date the
indirect discharger commences operation.

Reporting and Recording Requirements
122.41(l)(4)

Requires direct dischargers to report all monitoring
results to the permitting authority using Discharge
Monitoring Reports (DMRs).

Permit-specific/At Least
Annually

122.44(i)(2)
403.12 (b), (d), (e), (g)

Requires indirect dischargers to report monitoring results
to the pretreatment control authority using Periodic
Compliance Reports (PCRs).

Agreement-specific/At
Least Biannually

122.41(j)(2)

Requires direct dischargers to retain ongoing monitoring
records and copies of all reports for at least 3 years from
the date of the sample.

403.12(o)(2)

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

Tables 4.2, 4.3 and 4.4 outline the reduced monitoring requirements for those mills enrolled in
the VATIP.
Table 4.2 Reduced Effluent Monitoring for TCDD, TCDF, Chloroform, and the
12 Chlorinated Phenolics for Mills Participating in the
Voluntary Advanced Technology Incentives Program (VATIP)
40 CFR Reference
430.02(c)

430.02(c)

Regulatory Description

Monitoring Frequency

Requires non-ECF1 Subpart B mills enrolled in the VATIP
to conduct minimum monitoring for these pollutants at the
following frequencies:
•
chloroform . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
each of the 12 chlorinated phenolics . . . . . . . .

Weekly
Monthly
Monthly
Monthly

Requires Advanced ECF2 Subpart B mills enrolled in the
VATIP to conduct minimum monitoring for these pollutants
at the following frequencies:
•
chloroform . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
TCDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
•
each of the 12 chlorinated phenolics . . . . . . . .

Monthly
Monthly
Monthly
Monthly

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

Notes:

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

1
2

Table 4.3 Duration of Reduced Effluent Monitoring for TCDD, TCDF, Chloroform, and the
12 Chlorinated Phenolics for Mills Participating in the VATIP
40 CFR Reference
430.02(c)

Regulatory Description

Duration

The duration of monitoring is five years, commencing after
achievement of the applicable VATIP limitations or
standards for those pollutants.

5 Years

Subpart B mills that certify that the fiber line uses Advanced
ECF bleaching processes in their NPDES permit application
or other communication to the permitting authority may
discontinue monitoring at these frequencies after one year.
The permitting authority will determine monitoring
frequency beyond that time.

1 Year

Table 4.4 Reduced Effluent Monitoring for AOX for Mills Participating in the VATIP
40 CFR Reference
430.02 (d)

430.02 (e)

Regulatory Description

Monitoring Frequency

Subpart B mills enrolled in the VATIP may reduce
monitoring frequencies for AOX for the first year after
achievement of the applicable Stage 2 or ultimate VATIP
limitations or standards for AOX, as follows:
•
Non-ECF - Tiers I, II, & III . . . . . . . . . . . . . . . . . . .
•
Advanced ECF - Tiers I, II, & III . . . . . . . . . . . . . .
•
TCF - Tiers I, II, & III . . . . . . . . . . . . . . . . . . . . . . .

Daily
Weekly
None

Subpart B mills enrolled in the VATIP may reduce
monitoring frequencies for AOX for years two through five
after achievement of the applicable Stage 2 or ultimate
VATIP limitations or standards for AOX, as follows:
•
Non-ECF - Tiers I, II, & III . . . . . . . . . . . . . . . . . .
•
Advanced ECF - Tier I . . . . . . . . . . . . . . . . . . .
•
Advanced ECF - Tier II . . . . . . . . . . . . . . . . .
•
Advanced ECF - Tier III . . . . . . . . . . . . . . . . .
•
TCF - Tiers I, II, & III . . . . . . . . . . . . . . . . . . . . . .

Daily
Monthly
Quarterly
Annually
None

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Should a facility choose to collect and analyze more samples than specified in its permit,
the permittee must include all monitoring data in the reports. See 40 CFR 122.41(j)(4)(ii). As
indicated in Table 4.1, submission of reports shall be at the frequency established by the NPDES
permit or pretreatment control authority, but in no case less than once per year for direct
dischargers and twice per year for indirect dischargers. Also, the permittee must collect and
analyze representative samples and must conduct all monitoring requirements according to
permit specific conditions and/or approved test procedures as set forth under 40 CFR Parts 136,
430, and 503. See 40 CFR 122.41(j).
4(c) Recordkeeping requirements
A sample of a pre-printed discharge monitoring form may be obtained from the
NPDES/Sewage Sludge Monitoring Reports ICR. Direct and indirect dischargers are required
to maintain monitoring records, copies of all reports required by the NPDES permit or
pretreatment control agreement and records of all data used to complete the permit application
for at least 3 years. See 40 CFR 122.41(j)(2) and 40 CFR 403.12(o)(2).
4(d) Respondent Activities
(i) Mill respondent activities include the following:
C

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

Maintaining records. All direct and indirect discharging mills in Subparts B and E must
keep records of monitoring information and spill reports as required by the regulation.
The burden for preparing spill reports and recordkeeping under 430.03(c)(5) and (g) is
included in the Best Management Practices ICR (ICR No. 1829.01; OMB No. 20400207), and thus is not accounted for in this ICR.
(ii) NPDES and pretreatment approval-authorized States and pretreatment control
authorities respondent activities include:

•
•
•

Discharge Monitoring Report (DMR) and Periodic Compliance Report (PCR) Review
Follow-up Activities
Reporting and Recordkeeping Requirements

Data review varies from State to State. Generally, the permitting and pretreatment control
authority routinely screens data to identify permit violations and conducts a more thorough
technical review and follow-up when violations are detected. Follow-up activities may include
informal contact with the permittee (by telephone or letter) requesting prompt corrective action,
technical assistance, field inspections to further substantiate violations, in the case of indirect
dischargers request assistance from the pretreatment approval authority, or a formal enforcement

Minimum Monitoring Requirements ICR

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action such as an Administrative Order or referral to the EPA regional office and/or the U.S.
Attorney (or State's Attorney General in the case of NPDES and pretreatment control-authorized
States). Table 4.5 summarizes NPDES-authorized State requirements.
Table 4.5. NPDES-authorized State Requirements (As Users of Data)
40 CFR Citation

Regulatory Description

Response Frequency

DMR data review
§123.26(a)

Requires the NPDES permitting authority to have
procedures for reviewing DMR submissions, using the
reported data to evaluate permittee compliance. The
permitting authority must also have procedures for
conducting an initial screening of compliance-related
information.

Variable/Permit-specific

§123.26(e)

When warranted, requires the permitting authority to have
procedures to follow-up the initial screening with a
substantive technical evaluation to determine permittee
compliance with permit conditions.

As Necessary

Reporting and recordkeeping requirements
§123.26(e)(4)

Requires the permitting authority to have the procedures
and ability for maintaining a management information
system that supports the compliance evaluation activities.

Ongoing

Table 4.6 summarizes State and local pretreatment control authorities requirements.
Table 4.6. State and Local Pretreatment Control Authorities Requirements (As Users of Data)
40 CFR Citation

Regulatory Description

Response Frequency

PCR data review
§403.8(f)

Requires the pretreatment control authority to have
procedures for reviewing PCR submissions, using the
reported data to evaluate permittee compliance. The
permitting authority must also have procedures for
conducting an initial screening of compliance-related
information.

Variable/Permit-specific

§403.8(f)

When warranted, requires the pretreatment control
authority to have procedures to follow-up the initial
screening with a substantive technical evaluation to
determine permittee compliance with permit conditions.

As Necessary

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Table 4.6. State and Local Pretreatment Control Authorities Requirements (As Users of Data)
Reporting and recordkeeping requirements
§403.8(f)

Requires the pretreatment control authority to have the
procedures and ability for maintaining a management
information system that supports the compliance
evaluation activities.

Ongoing

EPA anticipates that under 40 CFR §403.8(f), the pretreatment control authority may request
assistance from the pretreatment approval authority in its follow-up activities to determine an
indirect discharger’s compliance with applicable pretreatment standards.
5.

THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a)

Agency Activities

Activities undertaken by EPA under this information collection primarily include
oversight of the NPDES and pretreatment program, and where EPA is the NPDES-permitting,
pretreatment approval or control authority, review of monitoring data, and where necessary,
follow-up actions. Agency activities as the NPDES permitting or pretreatment control authority
are essentially the same for NPDES-authorized States summarized in Table 4.5 and State and
local pretreatment control authorities summarized in Table 4.6.
The extent to which EPA reviews data in assessing permit compliance may vary. For
example, EPA may conduct a more extensive review of permittees that are, or have been, in
violation of their permit requirements, than of permittees who have been in full compliance. In
cases of continued non-compliance, EPA may use monitoring report data to identify patterns of
non-compliance and/or to support Agency enforcement efforts. EPA and/or the permitting
authorities may limit its review of data submitted by fully compliant permittees to a simple
determination of continuing compliance. After the initial period of minimum monitoring is
complete, monitoring requirements may be reduced by the permitting authorities for permittees
that consistently demonstrate an ability to reduce pollutants in their discharge below their permit
limitations. EPA also expects, however, permitting authorities to consider whether poor
performance, compliance or enforcement history, or other site-specific factors indicate a need to
impose more frequent monitoring than that specified in §430.02. EPA may also review data
from minor permittees that may cause water quality problems (i.e, significant minors). EPA
may review data from other minor permittees less frequently. In most cases, EPA will forward
copies of reports to the States. EPA does not require the unauthorized States to review data, but
several States voluntarily conduct the review and use the results in their own programs.
EPA regions also may review data from major direct and indirect discharging permittees
while performing program oversight functions (e.g., during file audits and when compiling
statistical compliance summaries).

Minimum Monitoring Requirements ICR

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Reported data is often stored in the Permit Compliance System (PCS) for reference. EPA
and States may use this data to evaluate potential compliance problems, focus inspection efforts,
conduct spot check reviews and determine appropriate enforcement action. PCS is available for
public review at http://www.epa.gov/enviro/html/water.html#pcs.
5(b) Collection Methodology and Management
Respondents typically report collected compliance data on DMRs for direct dischargers
and PCRs for indirect dischargers. Use of pre-printed DMR and PCR forms is one method that
EPA has used to improve its collection methodology. EPA expects that the Cross-Media
Electronic Reporting Rule (CROMERR) will be finalized in the next few months, which will
enable EPA to accept electronic submission of data. The electronic submission of DMR/PCR
data will be voluntary and will be an alternative to the paper DMR/PCR submission. EPA
makes use of the PCS database to store, track and access this information.
5(c)

Small Entity Flexibility

EPA has already certified that the Cluster Rules, including the minimum monitoring
requirements will not have a significant economic impact on a substantial number of small
entities as that term is used in the RFA (see Section X.C. of the Preamble to the final Cluster
Rules published in the Federal Register on April 15,1998 (see 63 FR 18611)
5(d) Collection Schedule
The information collection activities included in this ICR are anticipated to coincide with
existing reporting schedules. The timeframes for submitting compliance assessment information
are outlined below:

•

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

•

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

ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a)

Estimating Respondent Burden

This section describes the methods EPA used to estimate the burden to respondents
associated with collecting, reporting and maintaining records of monitoring data. Although
Subpart B mills may qualify for reduced monitoring frequencies by enrolling in the VATIP, EPA
did not account for these possible reductions in order to estimate the full potential burden to
Subpart B mills. The assumptions made and a brief description of the basis for the burden
estimates are presented below. Further supporting calculations and assumptions may be found in

Minimum Monitoring Requirements ICR

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Appendix A. The number of affected facilities and the pollutants regulated associated with this
ICR are listed in Table 6.1 below.
Table 6.1 Regulated Pollutants and Number of Mills and Lines
Category

Number of
Affected
Direct
Discharging
Facilities

Number of
Affected
Indirect
Discharging
Facilities

Number of Bleach
Lines
Direct

Indirect

Regulated Pollutants

Subpart B, Bleached
Papergrade Kraft and Soda

120

AOX, TCDD, TCDF,
chloroform, chlorinated
phenolics

Subpart E,
Calcium/Sodium/
Magnesium Sulfite

AOX

Subpart E, Ammonium
Sulfite

TCDD, TCDF,
chlorinated phenolics

Subpart E, Specialty Grade

TCDD, TCDF,
chlorinated phenolics

Total

129

(i) Sampling Activities
All Subpart B and E direct discharging mills will be required to monitor for new BAT
and NSPS pollutants at the minimum frequency specified in 40 CFR 430.02 (see Table 4.1).
Direct discharging mills typically have one wastewater final effluent outfall with continuous
monitoring capabilities. For AOX monitoring, which must be performed daily on the mill’s final
effluent, EPA anticipates that mill personnel will take an additional 15 minutes (0.25 hour) to
prepare the AOX aliquot, labels and paperwork and to ship the sample to the laboratory for
analysis.
All Subpart B and E indirect discharging mills will be required to monitor for new PSES
and PSNS pollutants at the minimum frequency specified in 40 CFR 430.02(see Table 4.1). For
indirect dischargers, AOX monitoring must be performed daily at the point where the
wastewater containing that pollutant leaves the bleach plant. See 40 CFR 430.26(c) and
430.26(c). Some mills have a combined sewer containing both acidic and alkaline wastewaters,
but most mills have bleach lines with separate acid and alkaline sewers, thus typically, there will
be two monitoring stations per bleach line. These samples can be collected either automatically
or manually. The samples can be either grab or composite. The bleach plant sampling burden is
calculated assuming manual grab composite sampling:
Sampling Burden (hours) = Avg. Number of Samples x Avg. Hours to Collect Sample

Minimum Monitoring Requirements ICR

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When bleach acid and alkaline wastewater samples are collected separately, additional labor for
flow-proportioned composite sampling is anticipated (see Appendix A, Section I for supporting
assumptions and calculations). The labor required for daily monitoring for AOX for indirect
dischargers includes time to collect samples plus shipping of samples to the laboratory for
analysis; this burden is estimated to be 30 minutes (0.5 hour) per sample.
For bleach plant monitoring, the Cluster Rules require all Subpart B and E mills to
monitor for TCDD, TCDF, chloroform, and the 12 chlorinated phenolics at the point were the
water containing these pollutants leaves the bleach plant. See 40 CFR 430.24(e), 430.25(e),
430.54(c) and 430.55(d). Some mills have a combined sewer containing both acidic and alkaline
wastewaters, but most mills have bleach lines with separate acid and alkaline sewers, thus
typically, there will be two monitoring stations per bleach line. These samples can be collected
either automatically or manually. The samples can be either grab or composite. The bleach
plant sampling burden is calculated assuming manual grab composite sampling:
Sampling Burden (hours) = Avg. Number of Samples x Avg. Hours to Collect Sample
When bleach acid and alkaline wastewater samples are collected separately, additional
labor for flow-proportioned composite sampling is anticipated (see Appendix A, Section I for
supporting assumptions and calculations). The labor required for monthly sampling for TCDD,
TCDF and the 12 chlorinated phenolics includes time to collect samples plus shipping of
samples to the laboratory for analysis; this burden is estimated to be 30 minutes (0.5 hour) per
sample. For chloroform, however, separate samples and analyses of all bleach plant filtrates
discharged separately are required to prevent the loss of chloroform either through air stripping
as the samples are collected, measured, and composited or through chemical reaction when the
acid and alkaline samples are combined. The labor required for weekly sampling of chloroform
includes time to collect samples plus shipping of samples to the laboratory for analysis and is
estimated to be 1.5 hours per sample. For Subpart B bleached papergrade kraft and soda mills,
the annual sampling burden is summarized in Table 6.2. For Subpart E papergrade sulfite mills,
the annual sampling burden is summarized in Table 6.3 (see Appendix A, Section II for
supporting assumptions and calculations).
Table 6.2 Annual Sampling Burden for Subpart B Bleached Papergrade Kraft and Soda Mills
Pollutant

Facilities

Sampling

Labor per
sample
(hours)

Sample
frequency

Total Annual
Burden
(hours)

AOX (Direct)

75 mills

1 final effluent

0.25

daily

6,844

AOX (Indirect)

14 bleach lines

2 bleach plant

0.5

daily

5,110

AOX (Indirect)

50 percent of 14
bleach lines

flow- proportioned
composite

0.25

daily

639

chloroform (Direct
and Indirect)

134 bleach lines
(120 direct, 14
indirect)

2 bleach plant

1.5

weekly

20,904

Minimum Monitoring Requirements ICR

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Table 6.2 Annual Sampling Burden for Subpart B Bleached Papergrade Kraft and Soda Mills
TCDD, TCDF, 12
chlorinated
phenolics (Direct)

120 bleach lines

2 bleach plant

0.5

monthly

1,440

TCDD, TCDF, 12
chlorinated
phenolics
(Indirect)

14 bleach lines

2 bleach plant

0.5

monthly

168

TCDD, TCDF, 12
chlorinated
phenolics(direct)

50 percent of 120
bleach lines

flow- proportioned
composite

0.25

monthly

180

TCDD, TCDF, 12
chlorinated
phenolics(indirect)

50 percent of 14
bleach lines

flow- proportioned
composite

0.25

monthly

Total Sampling Burden for Subpart B mills (hours)

35,306

Table 6.3 Annual Sampling Burden for Subpart E Papergrade Sulfite Mills
Pollutant

Facilities

Sampling

AOX (Direct)

5 calcium, magnesium,
and sodium sulfite mills

1 final effluent

0.25

daily

456

TCDD, TCDF,
12 chlorinated
phenolics
(Direct)

2 ammonium sulfite
bleach lines

2 bleach plant

0.5

monthly

TCDD, TCDF,
12 chlorinated
phenolics
(Indirect)

1 ammonium sulfite
bleach line

2 bleach plant

0.5

monthly

TCDD, TCDF,
12 chlorinated
phenolics
(Direct)

2 specialty grade bleach
lines

2 bleach plant

0.5

monthly

TCDD, TCDF,
12 chlorinated
phenolics
(Direct)

50 percent of 4 bleach
lines (ammonium sulfite
and specialty grade)

flow-proportioned
composite

0.25

monthly

TCDD, TCDF,
12 chlorinated
phenolics
(Indirect)

50 percent of 1 bleach
line (ammonium sulfite
and specialty grade)

flow-proportioned
composite

0.25

monthly

Total Sampling Burden for Subpart E mills (hours)

Labor per
sample
(hours)

Sample
frequency

Total Annual
Burden
(hours)

524

Minimum Monitoring Requirements ICR

Page 16

(ii) Analysis of Samples
Collected samples are either analyzed on-site using the facility’s own laboratory or the
samples are sent to an outside laboratory for analysis. For the purposes of this ICR, analysis
burden is assumed to be contracted to outside laboratories for the purpose of estimating the full
potential burden of minimum monitoring on Subpart B and E mills. This respondent burden is
expressed as an “operation and maintenance” cost (see Section 6(b), particularly Table 6.9).
(iii) Reporting and Recordkeeping Requirements
Reporting of monitoring data involves compilation of data from various pollutant
analyses and calculation of average pollutant concentrations and/or loadings. The respondent
records this information on the DMR or PCR and submits this information to the NPDES
permitting or pretreatment control authority. For the purposes of this ICR, EPA assumed that
DMRs and PCRs are submitted monthly to the NPDES permit or pretreatment control authority
in order to express the full potential reporting and recordkeeping costs associated with the
minimum monitoring requirements for Subpart B and E mills. EPA estimates of the reporting
burden per pollutant for the Cluster Rule effluent minimum monitoring are summarized in Table
6.4. Total annual reporting burden for Subpart B and E mills, using annual burden estimated per
regulated pollutant as described in Table 6.4, is summarized in Table 6.5 (see Appendix A,
Section III for supporting assumptions and calculations).
Table 6.4 Annual Reporting Burden for Each Pollutant per Mill
Pollutant

Burden Assumptions

AOX

daily results are averaged for
monthly report

0.1

1.2

chloroform

weekly reports averaged for
monthly report

0.17

2.0

TCDD, TCDF, 12 chlorinated
phenolics

monthly reports at 2 minutes
for each of 14 pollutants

0.47

5.6

0.74

8.8

Total

Reporting Burden
(hours/month)

Annual Burden
(hours)

Minimum Monitoring Requirements ICR

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Table 6.5 Annual Reporting Burden for Subpart B and E Mills
Category

Regulated Pollutants

Number of
Affected
Mills

Annual
Reporting
Burden per
mill (hours)

Total Annual
Burden
(hours)

Subpart B, Bleached Papergrade
Kraft and Soda

AOX, TCDD, TCDF,
chloroform, chlorinated
phenolics

8.8

739

Subpart E,
Calcium/Sodium/Magnesium
Sulfite

AOX

1.2

Subpart E, Ammonium Sulfite

TCDD, TCDF, 12
chlorinated phenolics

5.6

Subpart E, Specialty Grade

TCDD, TCDF, 12
chlorinated phenolics

5.6

Total Annual Reporting Burden for Subpart B and E mills (hours)
Notes: 667 hours for direct dischargers; 96 hours for indirect dischargers for a total of 773

773

Facilities that are required to submit monitoring data are also required to maintain
records of that information. EPA assumes the time devoted to recordkeeping at these facilities
generally involves copying and filing DMRs or PCRs. EPA estimates this burden to be 10
minutes (0.17 hour) per DMR or PCR submitted with an extended amount of 40 minutes or 0.67
hour annually for quarterly reports for a total annual recordkeeping burden of 2.71 hours per
mill. Total annual recordkeeping burden for Subpart B and E mills is summarized in Table 6.6.
Table 6.6 Annual Recordkeeping Burden for Subpart B and E Mills
Category

Number of
Affected
Facilities

Annual
Recordkeeping
Burden per mill
(hours)

Total Annual Burden (hours)

Subpart B, Bleached Papergrade
Kraft and Soda

2.71

228

Subpart E,
Calcium/Sodium/Magnesium
Sulfite

2.71

Subpart E, Ammonium Sulfite

2.71

Subpart E, Specialty Grade

2.71

Total Annual Recordkeeping Burden for Subpart B and E mill (hours)
Notes: 228 hours for direct dischargers; 27 hours for indirect dischargers for a total of 255

255

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Page 18

(iv) NPDES-authorized State Respondent Burden
The burden and associated costs to NPDES-authorized State permitting for processing
and analyzing monitoring data are a function of: 1) the number of DMRs received by the
permitting authority; 2) the time it takes to process and analyze monitoring data (including entry
into the PCS database); and, 3) the salary and associated overhead costs of the State employees
who process DMRs. In addition to entering monitoring data into PCS, staff may need to conduct
follow-up actions in instances of non-compliance. This follow-up could be a phone conversation
or a letter to verify, clarify or substantiate the information reported.
Of the 84 direct discharging mills in Subparts B and E, the States are authorized NPDES
permit authorities for 82 mills. Compliance monitoring for the remaining 2 mills is overseen by
EPA. Recurring incremental State burden for those that are authorized NPDES permit
authorities for processing and analyzing monitoring data, including entry into the PCS database
is estimated to be an average of 30 minutes (0.5 hour) per facility per DMR (82 mills x 12
DMRs per year) for an annual incremental burden of 492 hours. In addition, staff may need to
conduct follow-up actions in instances of non-compliance. This follow-up could be a phone
conversation or a letter to verify, clarify or substantiate the information reported. EPA estimates
that 20 percent of the DMRs submitted will require follow-up action by the delegated States,
particularly due to the unique nature of the new monitoring requirements imposed by the
recently-promulgated effluent limitations guidelines. EPA estimates that recurring incremental
State burden for this follow-up action requires an average of 30 minutes (0.5 hour) per facility
per DMR or approximately 98 additional incremental hours per year for a total annual
incremental burden of 590 hours.
(iv) State and Local Pretreatment Control Authority and State Pretreatment Approval
Authority Respondent Burden
EPA estimates that the 10 indirect discharging mills in Subparts B and E are all regulated
by local pretreatment control authorities, with States acting as pretreatment approval authorities
for all ten mills. Recurring incremental burden for pretreatment control authorities for
processing and analyzing monitoring data, including entry into the PCS database is estimated to
be an average of 30 minutes (0.5 hour) per facility per PCR (10 mills x 12 PCRs per year) for an
annual incremental burden of 60 hours. In addition, staff may need to conduct follow-up actions
in instances of non-compliance. This follow-up could be a phone conversation or a letter to
verify, clarify or substantiate the information reported. EPA estimates that 20 percent of the
PCRs submitted will require follow-up action by the pretreatment control authorities with
assistance by the pretreatment approval authority, particularly due to the unique nature of the
new monitoring requirements imposed by the recently-promulgated effluent limitations
guidelines. EPA estimates that recurring incremental burden for this follow-up action requires
an average of 30 minutes (0.5 hour) per facility per PCR or approximately 12 additional
incremental hours per year for a total annual incremental burden of 72 hours.
State pretreatment approval activities include program support, such as review of
pretreatment control agreement renewal applications, and review of monitoring data (10 total
mills). To estimate State pretreatment approval authority burden support activities, EPA
assumes that approximately 20 percent of all PCRs submitted will require follow-up assistance

Minimum Monitoring Requirements ICR

Page 19

from State pretreatment approval authorities with an estimated burden of one hour per PCR for a
total annual incremental burden of 24 hours.
A summary of annual respondent burden for Subpart B and Subpart E mills and States is
presented in Table 6.7.
Table 6.7 Summary of Annual Respondent Burden
Category

Subpart B, Bleached Papergrade Kraft and
Soda

Sampling
Burden
(hours)

Reporting
Burden
(hours)

Recordkeeping Total Annual
Burden
Respondent
(hours)
Burden
(hours)

35,306

739

228

36,273

Subpart E, Calcium/Sodium/Magnesium
Sulfite

456

476

Subpart E, Ammonium Sulfite

Subpart E, Specialty Grade

35,830

773

255

36,858

NPDES-authorized States
• Processing and analyzing monitoring data.
• Follow-up actions for 20 percent of DMRs

0
0

492
98

Totals for State NPDES Authorities

590

Local Pretreatment Control Authorities
• Processing and analyzing monitoring data
• Follow-up actions for 20 percent of PCRs.

0
0

60
12

Totals for Subpart B and E mills

Totals for Local Pretreatment Control
Authorities
State Pretreatment Approval Authorities
• Follow-up actions for 20 percent of PCRs
Totals for State Pretreatment Approval
Authorities
Totals for all Respondents

37,544

6(b) Estimating Respondent Cost
EPA evaluated the total cost for each respondent activity based on the following two cost
items:
•
•

Labor Costs
Operations and Maintenance (O&M) Costs

Minimum Monitoring Requirements ICR

Page 20

Cost for monitoring equipment were included as initial capital costs in the original ICR
(No. 1878.01). Therefore, these one-time costs are not included in the burden estimates of this
renewal ICR.
(i) Estimating Labor Costs (2004 Dollars)
Estimates for respondent labor costs were prepared using industry-specific labor rates
identical to those used for the EPA ICR Number 1878.01, included overhead and fringe benefits,
and adjusted to January 2004 dollars with the Employment Cost Index: To verify the validity of
the adjusted rates EPA obtained national industry-specific wage estimates for the pulp, paper,
and paperboard mills from the Labor Department1. Noting that the Labor Department wages
were lower, EPA decided to apply the more conservative estimates from the previous ICR.
Technician
Operator

$64.58 /hour
$32.81 /hour

Technician labor is applied to reporting and recordkeeping burdens. Operator labor is applied to
sampling burden.
Estimates for Federal and State labor rates were based on the 2003 US Labor department
figures adjusted to January 2004 dollars with the Employment Cost Index, whereby the average
annual salary for Federal and State employees is $47,112; this is equivalent to the salary of a
GS-9, Step 10 Federal employee. At 2,080 available labor hours per year, the hourly rate is
$22.65. Overhead costs for Federal and State employees are estimated by EPA to be 60 percent
(EPA ICR Handbook), or $13.59 per hour, which results in a total hourly rate of $36.24 ($22.65
+ $13.59).
Estimates for local pretreatment control authority employees (i.e., POTW employees)
were based on the 2002 US Labor department figures for the wages and salaries value for State
and local government workers adjusted to January 2004 dollars with the Employment Cost Index
plus a 50 percent overhead burden; this is equivalent to an hourly rate of $33.36 ($22.24 +
$11.12).
Table 6.9 shows the labor rates (see Appendix A for supporting assumptions and calculations).
Table 6.8 Labor Rates
Technician

$64.58

Operator

$32.81

Federal and State

$36.24

Local Pretreatment Control Authority

$33.36

Minimum Monitoring Requirements ICR

Page 21

(ii) Operations and Maintenance (O&M) Costs
To estimate O&M costs associated with this ICR, EPA assumes that mills would send
their collected samples to outside laboratories for analysis. Some facilities may perform inhouse analysis for some pollutants (e.g., AOX and/or chloroform). However, for the purposes of
this ICR, EPA assumed that all analyses will be contracted to outside laboratories in order to
express the full potential analytical costs of minimum monitoring on Subpart B and E mills. In
the future, facilities may elect to conduct analysis in house, particularly AOX analyses, since the
monitoring requirement is daily.
Analytical costs performed at outside laboratories were taken from EPA ICR Number
1878.01 (originally from the BAT cost model in the “BAT Cost Model Support Document”
[DCN 13953]) and adjusted with the Consumer Price Index to 2004 dollars. These costs are as
follows:
Table 6.9 Analytical Sample Costs
Analyte

Cost/sample
(2004 dollars)

AOX

143

TCDD / TCDF

1040

chlorinated phenolics

594

chloroform

320

Table 6.10 shows the cost of sampling analysis for contracted lab work (see Appendix A for
supporting assumptions and calculations).
Table 6.10 Annual (O&M) Estimate of Analytical Costs1
Affected Category
Subpart B: bleached papergrade
kraft and soda mills

Sampling Parameter
2

AOX
TCDD/TCDF2
chlorinated phenolics2
chloroform

Analyses/year
35,040
2,412
2,412
13936

Total Analytical Costs for Subpart B mills
Subpart E: papergrade sulfite

$5,010,720
$2,508,480
$1,432,728
$4,459,520
$13,411,448

AOX (calcium only)
TCDD/TCDF2
chlorinated phenolics2

Total Analytical Costs for Subpart E mills

Cost (2004 dollars)

1825
90
90

$260,975
$93,600
$53,460
$408,035

Total Analytical Costs for Subpart B and E mills
$13,819,483
1
Costs presented assume that all analytical work is contracted to outside laboratories.
Notes:
2
Analyses/year reflect that 50 percent of bleach lines will use one flow-proportioned composite for
analysis in lieu of two separate bleach plant samples (see Appendix A)

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Page 22

6(c) Estimating Agency Burden and Cost
The estimates of EPA burden for direct dischargers are based on management and support
activities for mills located in:
C States without NPDES authority: EPA activities include analysis of monitoring data and

review of DMRs (2 total mills); this would translate to an incremental burden in addition to
current activities. Recurring incremental EPA burden for processing and analyzing
monitoring data, including entry into the PCS database (reporting and recordkeeping), is
estimated to be 30 minutes (0.5 hour) per facility per DMR. In addition, EPA assumes that
approximately 20 percent of all DMRs submitted will require follow-up action (as was
assumed in Section 6(a)(iv)), with an estimated burden of one hour per DMR.
C States with NPDES authority: EPA activities include program support, such as review of

NPDES permit renewal applications and draft permits, and review of monitoring data (82 total
mills). To estimate Agency burden support activities, EPA assumes that approximately 20
percent of all DMRs submitted will require follow-up assistance from EPA with an estimated
burden of one hour per DMR.
The estimates of EPA burden for indirect dischargers are based on management and support
activities for mills located in States acting as the pretreatment approval authority. EPA activities
include program support, such as review of pretreatment agreement renewal applications and
draft permits, and review of monitoring data (10 total mills). To estimate Agency burden
support activities, EPA assumes that approximately 20 percent of all PCRs submitted will
require follow-up assistance from EPA with an estimated burden of one hour per PCR.

Table 6.11 Summary of Annual Agency Burden and Costs
Category

Affected Subpart
B and E Mills

Activity

Annual
Labor Hours

Annual Costs
(2004 Dollars)

Agency Burden Associated with Direct Dischargers
States without NPDES
Permit Authority

States with NPDES
Permit Authority

Processing and analyzing
monitoring data

$435

Follow-up actions for 20
percent of DMRs

$181

Follow-up actions for 20
percent of DMRs

197

$7,139

$870

238

$8,625

Agency Burden Associated with Indirect Dischargers
States with Pretreatment
Approval Authority

Total Annual Agency
Burden and Costs

Follow-up actions for 20
percent of PCRs
-

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6(d) Estimating the Respondent Universe and Total Burden and Costs
Table 6.12 summarizes the total annual industry burden and costs inclusive of the sampling,
analysis, reporting and recordkeeping burden and annual burden and costs to State NPDES
permitting authorities.
Table 6.12 Summary of Annual Respondent Burden and Costs
Category
Respondents - Sampling Burden
Subpart B, Kraft & Soda Mills . . . . . . . . . . . . . . .
Subpart E, Sulfite Mills . .. . . . . . . . . . . . . . . . . . .
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Respondents - Analytical Costs
Subpart B, Kraft & Soda Mills .
Subpart E, Sulfite Mills .
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Respondents - Reporting Burden
Subpart B, Kraft & Soda Mills . . . . . . . . . . . . . . .
Subpart E, Sulfite Mills . .. . . . . . . . . . . . . . . . . . .
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Respondents - Recordkeeping Burden
Subpart B, Kraft & Soda Mills . . . . . . . . . . . . . . .
Subpart E, Sulfite Mills . .. . . . . . . . . . . . . . . . . . .
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Respondents - Subpart B and E mills

Annual Labor
Hours
35306
524
35830

Annual Costs
(2004 Dollars)
$1,158,390
$17,192
$1,175,582
$13,411,448
$408,035
$13,819,483

739
34
773

$47,725
$2,196
$49,921

228
27
255

$14,724
$1,744
$16,468

36,858

$15,061,454

Respondents - State NPDES Authorities

590

$21,382

Respondents - State Pretreatment Approval Authorities

$870

Respondents - Local Pretreatment Control Authorities

$2,402

Total Annual Respondent Burden and Cost

37,544

$15,086,107

6(e) Bottom Line Burden Hours and Cost Tables
The bottom line burden hours and cost tables for respondents are the summaries of all the hours
and costs incurred for all activities.
(i) Respondent Tally
The bottom line respondent burden (affected facilities and local and State authorities) is
presented in Table 6.13.

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Table 6.13 Total Estimated Annual Respondent Burden and Cost Summary (2004 Dollars)
Category

Number of
Respondents

Total Hours
Per Year

Total Labor
Cost Per Year

Total
Annualized
Capital Costs

Total Annual
O&M Costs
(analytical costs)

Respondents Subpart B and E
mills

36,858

$1,241,971

$13,819,483

Respondents State authorities

614

$22,251

Respondents Local authorities
(pretreatment)

$2,402

Total
Respondents

138

37,544

$1,266,624

$13,819,483

(ii) The Agency Tally
The bottom line Agency tally is presented in Table 6.14 (see supporting assumptions in Section
6(c)).
Table 6.14 Total Estimated Annual Agency Burden and Cost Summary (2004 Dollars)
Category
Agency

Total Hours Per
Year

Total Labor
Cost Per Year

Total Annualized
Capital Costs

Total Annual O & M
Costs

238

$8,625

6(f) Reasons for Changes in Burden
As this is a renewal information collection, the change in burden for this collection
includes adjusting from 2000 to 2004 dollars, to eliminate the initial burden and costs incurred
by respondents that were already accounted for in the original ICR (No. 1878.01)., and to
account for new NPDES authorized states
6(g) Burden Statement
EPA estimates that there are 94 affected mills (direct and indirect dischargers) in Subpart
B and Subpart E of the Pulp, Paper and Paperboard Point Source Category with a total of 144
bleach lines. These mills will perform the additional sample collection and pollutant analyses;
reporting and recordkeeping to permit and pretreatment authorities, as part of NPDES permit and
pretreatment control requirements, will not change significantly from existing conditions. EPA
estimates affected mills to incur a burden of 35,830 hours per year for sample collection,
corresponding to a cost of $1,175,582. Contracted laboratories are anticipated to perform all
required analyses of collected samples for minimum monitoring with an estimated O&M cost for
all mill respondents of $13,819,483. Annual reporting burden incurred by affected facilities is

Minimum Monitoring Requirements ICR

Page 25

estimated to be 773 hours for a cost of $49,921, and annual recordkeeping burden is estimated to
be 255 hours for a cost of $16,468 per year. Total mill respondent burden for the minimum
monitoring requirements is estimated to be 36,858 labor hours at a cost of $15,061,454
($1,175,582 + $13,819,483 + $49,921 + $16,468). On a per-facility basis, mills are anticipated
to incur an average of 392 hours per year for sampling, reporting and recordkeeping for monthly
DMRs or PCRs for an average annual cost of $160,228, including O&M costs.
NPDES-authorized States are estimated to incur 590 burden hours for processing and
analyzing monitoring data captured in submitted DMRs and for follow-up activities associated
with 20 percent of all DMRs submitted. This hourly burden translates to an estimated $21,382
annually for these activities.
Local pretreatment control authorities are estimated to incur 72 burden hours for
processing and analyzing monitoring data captured in submitted PCRs and for follow-up
activities associated with 20 percent of all PCRs submitted. This hourly burden translates to an
estimated $2,402 annually for these activities. State pretreatment approval authorities are
estimated to incur 24 burden hours per year for support of local follow-up activities at a cost of
$870.
EPA burden is estimated to be 238 hours per year for support of State follow-up activities
as well as acting as the NPDES permit authority for 2 mills where the States are not authorized
NPDES authorities at a cost of $8,625.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to
comply with any previously applicable instructions and requirements; train personnel to be able
to respond to a collection of information; search data sources; complete and review the
collection of information; and transmit or otherwise disclose the information. An agency may
not conduct or sponsor, and a person is not required to respond to, a collection of information
unless it displays a currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. OW-2004-0025, which is available for public viewing at the Water Docket in the
EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW,
Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An
electronic version of the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket. Use EDOCKET to submit or view public comments, access the
index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. Once in the system, select “search,” then key in the

Minimum Monitoring Requirements ICR

Page 26

docket ID number identified above. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington,
DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (OW-20040025) and OMB control number (2040-0243) in any correspondence.

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Page 27

Appendix A: Supporting Assumptions and Calculations
I.

Flow-Proportioned Composite Sampling

The Preamble to the Cluster Rules specifies “For dioxin, furan, and chlorinated phenolic
compounds, compliance with the effluent limitations and standards can be demonstrated by
collecting separate samples of the acid and alkaline discharges and preparing a
flow-proportioned composite of these samples, resulting in one sample of bleach plant effluent
for analysis”. See 63 FR 18569.
To prepare a flow-proportioned composite, the operator: 1) must know the flow in each
sampled sewer; 2) add them together to estimate total flow; and 3) calculate the proportion of the
flow attributable to each sewer. Knowing the total volume of sample required for analysis, the
operator must then: 1) calculate the volume of sample from each sewer that should make up the
total sample volume; 2) measure out each volume; and 3) combine and mix them together. This
mixture is then dispensed into the sample containers and sent to the laboratories for analysis.
It is assumed that for 50 percent of the bleach lines, flow-proportioned composites will
be prepared, requiring 15 minutes of operator labor. For these bleach lines there will be one
instead of two samples to be analyzed for AOX, TCDD, TCDF, and the 12 chlorinated phenolic
compounds.

II.

Example of Total Sampling Burden calculation:

Refer to Tables 6.2 and 6.3
Assuming a manual grab composite methodology is used for TCDD, TCDF and the 12
chlorinated phenolics, the labor requirement may be estimated as follows:
5 minutes/point/grab x 6 grabs/sample = 30 minutes/point/sample
Assuming a manual grab composite methodology is used for chloroform, the labor requirement
may be estimated as follows:
15 minutes/ point /grab x 6 grabs/sample = 90 minutes/sample
For Subpart B mills, the annual sampling burden is:
Daily AOX sampling of final effluent (direct dischargers):
75 mills x 1 final effluent discharge/mill x 0.25 hours/day x 365 day/year = 6,844 hours
Daily AOX sampling of bleach plants (indirect dischargers):
14 bleach lines x 2 sample/bleach line x 0.5 hours/day x 365 day/year = 5,110 hours
Monthly flow-proportioned composites for AOX (indirect dischargers):
50 percent of 14 bleach lines x 0.25 hours/day x 365 days/year =

639 hours

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Page 28

Weekly chloroform sampling at bleach plant:
134 bleach lines x 2 sample/bleach line x 1.5 hours/week x 52 weeks/year =
20,904 hours
Monthly TCDD, TCDF and the 12 chlorinated phenolics sampling at the bleach plant:
134 bleach lines x 2 sample/bleach line x 0.5 hours/month x 12 months/year =
1,608 hours
Monthly flow-proportioned composites for TCDD, TCDF and the 12 chlorinated phenolics:
50 percent of 134 bleach lines x 0.25 hours/month x 12 months/year =
201 hours
TOTAL ANNUAL SAMPLING BURDEN FOR SUBPART B MILLS

35,306

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

III.

524 hours

Example of Total Reporting and Recordkeeping Burden calculation:

Refer to Tables 6.5 and 6.6
For Subpart B mills, the annual reporting and recordkeeping burden is:
Annual Reporting burden:
84 mills x 8.8 hours =

739 hours

Annual Recordkeeping burden:
84 mills x 0.17 hours/DMR x 12 DMRs +
84 mills x 0.67 hours/quarterly reports =

228 hours

Minimum Monitoring Requirements ICR

TOTAL ANNUAL REPORTING AND RECORDKEEPING BURDEN
FOR SUBPART B MILLS

Page 29

967 hours

For Subpart E mills, the annual reporting and recordkeeping burden is:
Annual Reporting burden:
5 Calcium/Sodium/Magnesium Sulfite mills x 1.2 hours =
3 Ammonium Sulfite mills x 5.6 hours =
2 Specialty Grade mills x 5.6 hours =

6 hours
17 hours
11 hours

Annual Recordkeeping burden:
5 Calcium/Sodium/Magnesium Sulfite mills x 0.17 hours/DMR x 12 DMRs +
5 Calcium/Sodium/Magnesium Sulfite mills x 0.67 hours/quarterly reports =
14 hours
3 Ammonium Sulfite mills x 0.17 hours/DMR x 12 DMRs +
3 Ammonium Sulfite mills x 0.67 hours/quarterly reports =
8 hours
2 Specialty Grade mills x 0.17 hours/DMR x 12 DMRs +
2 Specialty Grade mills x 0.67 hours/quarterly reports =
5 hours
TOTAL ANNUAL REPORTING AND RECORDKEEPING BURDEN
FOR SUBPART E MILLS

IV.

61 hours

Example of TCDD, TCDF and 12 Chlorinated Phenolics Analyses per Year
calculation:

Refer to Table 6.10
For Subpart B mills, the analyses per year for TCDD, TCDF and 12 Chlorinated Phenolics is:
Flow-proportional composite (derived from 2 bleach plant samples per month per bleach line)
analysis:
50 percent of 134 bleach lines x 12 composites/year =

804 analyses

Bleach plant sampling (portion of Subpart B mills not conducting flow-proportioned composites)
analysis:
50 percent of 134 bleach lines x 2 samples/month x 12 months/year =
TOTAL TCDD, TCDF AND 12 CHLORINATED PHENOLICS
ANALYSES PER YEAR FOR SUBPART B MILLS

1,608 analyses

2,412 analyses

For Subpart E mills, the analyses per year for TCDD, TCDF and 12 Chlorinated Phenolics is:

Minimum Monitoring Requirements ICR

Page 30

Flow-proportional composite (derived from 2 bleach plant samples per month per bleach line)
analysis:
50 percent of 5 bleach lines (Ammonium Sulfite and Specialty Grade) x 12
composites/year =
30 analyses
Bleach plant sampling (portion of Subpart E mills not conducting flow-proportioned composites)
analysis:
50 percent of 5 bleach lines (Ammonium Sulfite and Specialty Grade) x 2 samples/month
x 12 months/year =
60 analyses
TOTAL TCDD, TCDF AND 12 CHLORINATED PHENOLICS
ANALYSES PER YEAR FOR SUBPART E MILLS
V.

90 analyses

Example of Labor Rate Adjustment Using the Employment Index Cost (EIC).

Technician wage in 2000 dollars (including overhead and fringe benefits): $56.91
December 1999 EIC value for the Goods-Producing Industries:
March 2000 EIC value for the Goods-Producing Industries:

139.7
141.3

January 2000 EIC estimate for the Goods-Producing Industries:
139.7+1 month*(141.3-139.7) / 3months =

140.2

December 2003 EIC value for the Goods-Producing Industries:
March 2004 EIC value for the Goods-Producing Industries:

158.7
159.9

January 2004 EIC estimate for the Goods-Producing Industries:
158.7+1 month*(159.9-158.7) / 3months =

159.1

Technician wage in 2004 dollars (including overhead and fringe benefits):
$ 56.91 * 159.1 / 140.2 =
$64.58

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