1657t(2)06

Table 2.			Annual Agency Burden and Cost
of the NESHAP for the Pulp and Paper Production Source Category -- Process Operations			NESHAP for Pulp and Paper Production
			(40 CFR Part 63, Subpart S)	(A)		(B)	(C)	(D)	(E)	(F)
			(Renewal)	Number of		EPA	Tech	Management	Clerical	EPA
				Respondents		Hours	Hours	Hours	Hours	Cost
				Per Year (a)		Per	Per Year	Per Year	Per Year	Per Year
						Respondent	@ $40.56	@ $54.66	@ $21.95
Burden Item							(C=AxB)	(D=Cx0.05)	(E=Cx0.1)
1.	Applications
2.	Surveys and Studies
3.	Reporting Requirements
	A.	Read and Understand Rule Requirements		7	b	6	42	2	4	$1,910
	B.	Required Activities
		Initial performance tests:
		1.1) Pulping processes (Non-Sulfite) - Choice of:
		a) Review Documentation that vent streams are introduced to		4	b,c	8	32	2	3	$1,456
		the flame zone of a boiler, lime kiln, or recovery furnace, or
		b) Review documentation that the control incinerator is operating		1	b,d	8	8	0	1	$364
		at a level of at least 1600 F and 0.75 sec residence time, or
		c) Review performance test of control device		1	b,d	8	8	0	1	$364
		1.2) Pulping Processes (Sulfite)		0	b,e	8	0	0	0	$0
		-Revew performance test of control device
		2.1) Bleaching process vent scrubber (MACT I Mills) - Choice of
		a) Review documentation of scrubber operating parameters		4	b,g	8	32	2	3	$1,456
		b) Review performance test of control device		0	b,f	8	0	0	0	$0
		2.2) Bleaching process vent scrubber (MACT III Mills) - Choice of
		a) Review documentation of scrubber operating parameters		0	b,g	8	0	0	0	$0
		b) Review performance test of control device		0	b,f	8	0	1	0	$55
		3.1) Pulping wastewater treatment system (Non-Sulfite) - Choice of:
		a) Review performance test of condensate segregation and		4	b,g	8	32	2	3	$1,456
		control device, or
		b) Review performance test of biotreatment unit		2	b,g	8	16	1	2	$728
		3.2) Pulping wastewater treatment (Sulfite)
		-Review performance test of control device		0	b,g,h	8	0	0	0	$0
		Review repeat performance tests
		1) test method 308 - pulping		0	b,i	4	0	0	0	$0
		2) test method 26A - bleaching		0	b,i	4	0	1	1	$77
		3) test method 305 - kraft pulping wastewater		1	b,i	4	4	0	0	$182
		4) test method 304 - kraft pulping wastewater		0	b,i	4	0	0	0	$0
		5) test method 305 - sulfite pulping wastewater		0	b,i	4	0	1	0	$55
		Initial/Annual inspection (enclosures, closed vent,		87	j	0	0	0	0	$0
		wastewater conveyance system) - test method 21
		Monthly visual inspection of enclosures, closed		130	k	0	0	0	0	$0
		vent system, and wastewater conveyance system.
	C.	Create Information
	D.	Gather Information
	E.	Report Preparation
		Review Initial Notification Report		0	b,k	4	0	0	0	$0
		Review Notification of compliance status		0	b,k	4	0	0	0	$0
		Review initial compliance strategy report		0	b,l	4	0	0	0	$0
		Review compliance strategy report update		27	l	4	108	5	11	$4,913
		Review Semi-annual summary report		137	k	2	274	14	27	$12,464
		Review Continuous monitoring/Exceedance reports		21	m	8	168	8	17	$7,642
		Review Notification of performance test		24	b,n	8	192	10	19	$8,734
		Review Notification of construction/reconstruction		21	b,o	4	84	4	8	$3,821
		Review Notification of actual startup		21	b,o	4	84	1	1	$3,484
4.	Recordkeeping Requirements
	A.	Read Instructions
	B.	Plan Activities
	C.	Implement Activities
	D.	Develop Record System		0	b,k	0	0	0	0	$0
	E.	Record information
		Records of monitoring parameters		137	k	0	0	0	0	$0
		Records of periodic inspections (monthly
		visual inspections and annual method 21)
		Record startups, shutdowns, and malfunctions		137	k	0	0	0	0	$0
	F.	Personnel Training		137	k	0	0	0	0	$0
	G.	Time for audits		137	k	0	0	0	0	$0
			Total:				1084	54	102	$49,158
			TOTAL FEDERAL GOVERNMENT BURDEN SUMMARY:
			Total hours per year	1,240
			Annual costs in dollars	$49,158
Footnotes
a Values are rounded to simplify calculations.
b One-time activity. After initial compliance date, assume that 5% of mills affected as a result of unexplained exceedances.
c Estimated that 66.7% of mills will use a recovery boiler, power boiler, or lime kiln for pulping lines. There are 122 non-sulfite pulping mills. (66.7% of 122 = 81).
d Estimated that 33.3% of mills will use incineration for pulping lines (16.7% will provide accepatble design specs (14), and 16.7% will conduct performance tests (14) ).
e Assume that all of the 8 sulfite pulping mills will conduct performance tests.
f 94 MACT I category mills have bleaching lines. 90% will provide acceptable performance specs (85), 10% will conduct performance tests (9).
Assume 2 percent of stand-alone MACT III category mills have bleaching lines (2% of 338=7). 90% will provide performance specs of previous test results (6).
10% will conduct performance tests (1).
g Estimated that each kraft mill has one pulping wastewater control device. Of the 108 kraft mills, 28 already have steam strippers in use,
and of the 28, all are assumed to conduct condensate segregation and performance tests. Of the 80 mills without control, 35 will use biotreatment control, and 45 will install steam strippers.
Facilities installing new biotreatment control will perform initial performance tests.
h Estimated that each kraft mill has one pulping wastewater control device. Assumed 33% will use biotreatment. (33% of 108 = 36).
i Assumed that 15% of performance tests are failed and need to be repeated.
j Initial and annual activity by all affected mills. Assumed that EPA is notified each year of the testing. Assumed 2/3 of all MACT I mills have positive pressure points in their vent systems.
k Performed by all affected mills. (137)
l Performed by all kraft mills. (108)
m Assumed that 15% of all mills during any one quarter will be required to submit an exceedance report in addition to the summary report. (15% of 137 = 21)
n EPA must be notified of all tests including repeat performance tests. (130 x .05 = 7) (7 x 1.15 x 3 = 24)
o Assumed 15% of mills conduct construction or reconstruction per year. (15% of 130 = 21)