2452ss01

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S)
(Proposed Amendments)

1. Identification of the Information Collection
1(a) Title of the Information Collection
NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) (Proposed Amendments),
EPA ICR Number 2452.01, OMB Control Number 2060-NEW
1(b) Short Characterization/Abstract
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Pulp and
Paper Production were proposed on December 17, 1993, and promulgated on April 15, 1998.
Amendments to the Pulp and Paper Production NESHAP are being proposed as a result of the
residual risk and technology review (RTR) required under by the Clean Air Act (as discussed
further below). The Pulp and Paper Production NESHAP applies to facilities that produce pulp,
paper, or paperboard by employing kraft, soda, sulfite, semi-chemical, or mechanical pulping
processes using wood; or any process using secondary or non-wood fiber and that emits 10 tons
per year or more of any hazardous air pollutant or 25 tons per year or more of any combination
of hazardous air pollutants. Affected sources are all the hazardous air pollutant (HAP) emission
points or the HAP emission points in the pulping and bleaching system for mechanical pulping
processes using wood and any process using secondary or non-wood fiber. This information is
being collected to assure compliance with 40 CFR Part 63, subpart S.
In general, all NESHAP require initial notifications, performance tests, and periodic
reports. Owners or operators are also required to maintain records of the occurrence and
duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any
period during which the monitoring system is inoperative. These notifications, reports, and
records are essential in determining compliance, and are required of all sources subject to
NESHAP.
Any owner or operator subject to the provisions of this part shall maintain a file of these
measurements, and retain the file onsite for at least two years following the date of such
measurements, maintenance reports, and records. All reports are sent to the delegated state or
local authority. In the event that there is no such delegated authority, the reports are sent
directly to the United States Environmental Protection Agency (EPA) regional office.
The amendments to the rule eliminate the startup, shutdown, and malfunction exemption,
remove the SSM plan requirement, add provisions to provide an affirmative defense against civil
penalties for exceedances of emission standards caused by malfunctions, and a requirement for
electronic submittal of performance test data, and correct editorial errors. The remaining

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portions of the NESHAP remain unchanged.
Of 171 major source mills, approximately 114 mills have equipment subject to the
standard, and it is estimated that no new major sources will become subject to the standard in the
next three years. These assumptions are based on the research conducted by EPA during the
subpart S rule making, consultation with the industry, and an information collection request
(ICR) conducted by EPA’s Office of Air Quality Planning and Standards (OAQPS) in 2011.
EPA is also aware that this industry is undergoing widespread consolidation and corporate
restructuring, and that no new major source facilities are being built, though approximately 15
percent of the affected facilities will rebuild one or more process units in a given year.
The Office of Management and Budget (OMB) approved the currently active Information
Collection Request (ICR) without any “Terms of Clearance."
2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for major
sources of HAP that are listed for regulation under CAA section 112(c). A major source is a
stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any
single HAP or more than 25 tpy of any combination of HAP. For major sources, these
technology-based standards must reflect the maximum degree of emission reductions of HAP
achievable (after considering cost, energy requirements, and non-air quality health and
environmental impacts) and are commonly referred to as maximum achievable control
technology (MACT) standards. In the Administrator's judgment, HAPs from pulp and paper
plants cause or contribute to air pollution that may reasonably be anticipated to endanger public
health or welfare. Therefore, the NESHAP for this source category were promulgated at 40 CFR
part 63, subpart S.
Section 112(d)(6) of the CAA requires EPA to review the technology-based MACT
standards and revise them “as necessary (taking into account developments in practices,
processes, and control technologies)” no less frequently than every 8 years. In addition, section
112(f) of the CAA requires EPA to determine whether the MACT emissions limitations provide
an ample margin of safety to protect public health. For MACT standards for HAP “classified as
a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer
risks to the individual most exposed to emissions from a source in the category or subcategory to
less than 1-in-1 million,” EPA must promulgate residual risk standards for the source category
(or subcategory) as necessary to provide an ample margin of safety to protect public health. In
doing so, EPA may adopt standards equal to existing MACT standards, if EPA determines that
the existing standards are sufficiently protective. EPA must also adopt more stringent standards,
if necessary, to prevent an adverse environmental effect, but must consider cost, energy, safety,
and other relevant factors in doing so.
Certain records and reports are necessary for the Administrator to confirm the compliance
status of sources subject to NESHAP, identify any new or reconstructed sources subject to the

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standards, and confirm that the standards are being achieved on a continuous basis. These
recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean
Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions (40 CFR part
63, subpart A). CAA Section 114(a) states that the Administrator may require any owner or
operator subject to any requirement of this Act to:
(A) Establish and maintain such records; (B) make such reports;
(C) install, use, and maintain such monitoring equipment, and use
such audit procedures, or methods; (D) sample such emissions (in
accordance with such procedures or methods, at such locations, at
such intervals, during such periods, and in such manner as the
Administrator shall prescribe); (E) keep records on control
equipment parameters, production variables or other indirect data
when direct monitoring of emissions is impractical; (F) submit
compliance certifications in accordance with Section 114(a)(3);
and (G) provide such other information as the Administrator may
reasonably require.
2(b) Practical Utility/Users of the Data
The control of emissions of HAP from pulp and paper plants requires not only the
installation of properly designed equipment, but also the operation and maintenance of that
equipment. Emissions of HAP from pulp and paper plants are the result of operation of the
affected facilities. These standards rely on the collection of HAP emissions in enclosed and
closed vent collection. Then, the collected HAPs are incinerated in a boiler, recovery furnace,
lime kiln, or thermal incinerator. HAPs associated with kraft pulping condensates are either
treated with steam stripping (or equivalent technology) or in a wastewater treatment system.
HAPs captured from bleaching systems are controlled with a chlorine gas scrubber. Equipment
inspection, performance tests, and leak detection and repair procedures are critical components
of the standards. The required notifications are used to inform the Agency or delegated authority
when a source becomes subject to the standard. Then, the reviewing authority may inspect the
source to ensure that the pollution control system is properly installed and operated, that leaks
are being detected and repaired, and that the standard is being met. Performance test reports are
needed as these are the Agency's record of a source's initial capability to comply with the
emission standard, and serve as a record of the operating conditions under which compliance was
achieved. Repeat performance tests (at 5-year intervals) are needed to ensure ongoing
compliance. The semiannual reports are used for problem identification, as a check on source
operation and maintenance, and for compliance determinations. The information generated by
the monitoring, recordkeeping and reporting requirements described in this ICR is used by the
Agency to ensure that facilities affected by the NESHAP continue to operate their control
equipment and achieve continuous compliance with the regulation. Adequate monitoring,
recordkeeping, and reporting are necessary to ensure compliance with these standards, as
required by the Clean Air Act. The information collected from recordkeeping and reporting
requirements is also used for targeting inspections, and is of sufficient quality to be used as
evidence in court.

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3. Nonduplication, Consultations, and Other Collection Criteria
The recordkeeping and reporting requested is required under 40 CFR part 63, subpart S.
3(a) Nonduplication
If the subject standards have not been delegated, the information is sent directly to the
appropriate EPA regional office. Otherwise, the information is sent directly to the delegated
state or local agency. If a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the state or local agency can
be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no
duplication exists.
Some of the facilities subject to this NESHAP will also be subject to requirements under
the New Source Performance Standard (NSPS) for Kraft Pulp Mills, 40 CFR 60 subpart BB.
The burden requested for this NESHAP does not duplicate any of the burden accounted for under
NSPS subpart BB.
3(b) Public Notice Required Prior to ICR Submission to OMB
The preamble to the proposed RTR will provide public notice of this ICR.
3(c) Consultations and Stakeholder Outreach
The proposed amendments were developed in consultation with the Nez Perce, Forest
County Potowatomi and Leech Lake Band of Ojibewa.
Stakeholder outreach occurred with industry groups including American Forest and Paper
Association (AF&PA), National Council for Air and Stream Improvement (NCASI) and member
companies of these organizations. Stakeholder meetings were also held with Sierra Club, Earth
Justice, and with organizations that participated in EPA Environmental Justice outreach efforts.
Further stakeholder and public input is expected through public comment and follow-up
meetings with interested stakeholders.
In addition, EPA/OAQPS conducted a three-part ICR to gather data from the pulp and
paper industry. The results from Part I of this ICR were used in updating the burden estimates
contained in this supporting statement.
3(d) Effects of Less Frequent Collection
Less frequent information collection would decrease the margin of assurance that
facilities are continuing to meet the required standards. Requirements for information gathering
and recordkeeping are useful techniques to ensure that good operation and maintenance practices
are applied and emission limitations are met. If the information required by these standards was
collected less frequently, the likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

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3(e) General Guidelines
None of these reporting or recordkeeping requirements violate any of the regulations
established by OMB in 5 CFR 1320.5.
3(f) Confidentiality
Any information submitted to the Agency for which a claim of confidentiality is made
will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, part 2,
subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,
1978; 44 FR 17674, March 23, 1979).
3(g) Sensitive Questions
None of the reporting or recordkeeping requirements contain sensitive questions.
4. The Respondents and the Information Requested
4(a) Respondents/NAICS Codes
Respondents included in the subpart S source category are owners/operators of mills that
are “major sources” of HAP emissions and produce pulp, perform bleaching, or manufacture
paper or paperboard products.1 According to results of EPA’s 2011 pulp and paper ICR, there
are a total of 171 major source mills in the U.S. including:
 111 major source mills that carry out chemical wood pulping (kraft [97], sulfite [5], soda
[1], or semi-chemical [8]),
 33 major source mills that carry out mechanical, groundwood, secondary fiber, and nonwood pulping, and
 27 major source mills that produce paper or paperboard (but do not produce pulp)
Some mills perform multiple operations (e.g., chemical pulping, bleaching, and
papermaking; pulping and unbleached papermaking; etc.). For example, 72 of the major source
mills listed above bleach with chlorinated compounds, and 156 major source mills manufacture
paper or paperboard products (including both integrated and non-integrated paper mills). Mills
that only purchase pre-consumer paper or paperboard stock products and convert them into other
products (i.e., converting operations) are not part of the Subpart S source category and are not
affected by Subpart S. The North American Industry Classification System (NAICS) codes for
respondents affected by the information collection include 32211 for pulp mills, 32212 for paper
1

As defined in 40 CFR Part 63, subpart A, “Major source” means any stationary source or group of stationary
sources located within a contiguous area and under common control that emits or has the potential to emit
considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or
more of any combination of hazardous air pollutants, unless the Administrator establishes a lesser quantity, or in the
case of radionuclides, different criteria from those specified in this sentence.

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mills, and 32213 for paperboard mills.
Of the 171 major sources, 114 are estimated to be affected by the Subpart S standards
(including 111 chemical pulp mills, and 3 non-integrated paper mills that bleach with chlorinated
compounds. Some major source mills (e.g., stand-alone mechanical pulp mills, non-integrated
paper mills) are not affected because they do not have any emission sources with requirements
under Subpart S.
4(b) Information Requested
(i) Data Items
All data in this ICR that is recorded and/or reported is required by 40 CFR part 63,
subpart S. Subpart S references 40 CFR part 63, subpart A for several general reporting and
recordkeeping requirements that apply for all NESHAP.
A source must make the following reports:
Notification Reports
Requirement
Construction/reconstruction
Construction or modification application
Initial notifications
Anticipated startup
Actual startup
Performance test results
Performance tests
Rescheduled initial performance test
Demonstration of continuous monitoring system
Compliance status
Physical or operational change
Periodic malfunction reports
Source status report
Semiannual Control Strategy Update (thru 2006)
Reports of malfunctions that result in an exceedances of the standard for the
purpose of affirmative defense

Regulation Reference
(40 CFR part 63)
63.5
63.455(d)
63.9(b)(2)
63.9(b)
63.9(b)(4)(v)
63.10(d)(2), 63.455(h)
63.7(b), 63.9(e)
63.7(b)(2)
63.9(g)
63.9(h)
63.5(b)(4)
63.455(g)
63.10(e)(3)
63.455(b)
63.456

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A source must maintain the following records:
Recordkeeping
Requirement
Periods where the continuous monitoring system is inoperative
Records of malfunctions
Emission test results and other data needed to determine emissions
All reports and notifications
Record of applicability
Records for sources with continuous monitoring systems
Records are required to be retained for five years. Records must be kept
onsite for the first two years, for the remaining three years records can be
kept in a readily accessible off-site location.
Site Specific Inspection Plans for closed vent systems
Records of paper machine new substance reviews

Regulation Reference
(40 CFR part 63)
63.10(b)(2)
63.454(g)
63.454(a)
63.10(b)
63.10(b)(3)
63.10(c)
63.454

63.454(b)
63.454(h)

Electronic Reporting
Currently, sources are using monitoring equipment that provides automated parameter data in an
automated way, e.g., inlet and outlet concentrations when determining percent efficiency.
Although personnel at the source still need to evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with monitoring and recordkeeping.
Modern pulp and paper facilities employ distributive controls on their manufacturing process and
have integrated many of the compliance record keeping and reporting requirements into their
systems. In addition, some regulatory agencies are setting up electronic reporting systems to
allow sources to report electronically which is reducing the reporting burden. However,
electronic reporting systems are still not widely used by the regulatory agencies. It is estimated
that approximately 10 percent of the respondents currently use electronic reporting. As part of
the RTR amendments, respondents would be required to report test results using EPA’s
Electronic Reporting Tool (ERT) for test methods supported by the ERT.2

2

As of 2011, Method 26A is the only test method referenced in subpart S that is included in the ERT.

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(ii) Respondent Activities
Respondent activities are as follows:
Respondent Activities
Read instructions.
Install, calibrate, certify, maintain, and operate Continuous Monitoring Systems (CMS) for each of the
following affected units:
1.1 Non-Sulfite Pulping Process choice of:
a. provide documentation that vent streams are introduced to the flame zone of a boiler, lime
kiln, or recovery furnace, or
b. provide documentation that the control incinerator is operating at a minimum level of
1600 F and 0.75 second residence time, or
c. Performance test of control device using Method 308.
1.2. Sulfite Pulping Process - performance test of control device using test method 308.
2.1. Bleaching Process Vent Scrubber - performance test of scrubber or control device using test
Method 26A.
3.1 Non-Sulfite Pulping Wastewater Treatment
a. performance test of condensate segregation and control device using test method 305 or
b. performance test of biotreatment unit using test Method 304.
3.2 Sulfite Pulping Process
a. performance test of control device using test Method 305.
Conduct performance tests using appropriate Reference Test Methods 26A, 304, 305, 308, and repeat
performance tests if necessary.
Conduct initial and annual inspections of enclosures, closed vent and wastewater conveyance systems
using test Method 21.
Write the notifications and reports for: initial notification; compliance status; initial compliance
strategy report; compliance strategy report update; semiannual summary report; continuous
monitoring/exceedance reports; notifications of performance tests, construction/ reconstruction, and
actual startup.
Enter information required to be recorded for continuous monitoring for operating parameters, periodic
inspections (monthly visual and annual Method 21), malfunctions, personnel training and time for
audits.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for
the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and
maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of 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.
Transmit, or otherwise disclose the information.

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In addition to the respondent activities listed above, EPA is including an estimate of the burden
associated with performing an affirmative defense. EPA is providing this as an illustrative
example of the potential additional administrative burden a source may incur to assert in an
Affirmative Defense in response to an action to enforce the standards set forth in the applicable
subpart. See section 6(b)(iv) of this ICR for details.
5. The Information Collected -- Agency Activities, Collection Methodology, and
Information Management
5(a) Agency Activities
EPA conducts the following activities in connection with the acquisition, analysis,
storage, and distribution of the required information.
Agency Activities
Observe initial and repeat performance tests.
Review notifications and reports, including performance test reports, and excess emissions reports,
required to be submitted by industry.
Audit facility records.
Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management
Following notification of startup, the reviewing authority might inspect the source to
determine whether the pollution control devices are properly installed and operated.
Performance test reports are used by the Agency to discern a source’s initial and ongoing
capability to comply with the emission standard, and note the operating conditions, such as,
control device fire box temperature, gas and liquid flow rates, production volume, wood species,
under which compliance was achieved. Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. The semiannual
reports are used for problem identification, as a check on source operation and maintenance, and
for compliance determinations.
The records required by this regulation must be retained by the owner or operator for
five years.
5(c) Small Entity Flexibility
Approximately 5 percent of the affected HAP major source facilities are considered small
business entities, defined as being independently owned and operated and not dominant in their
field of operations. Due to technical considerations involving the process operations and the
types of control equipment employed, the recordkeeping and reporting requirements are the same
for both small and large entities. The Agency considers these requirements the minimum needed
to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent
that larger businesses can use economies of scale to reduce their burden, the overall burden will
be reduced.

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The recordkeeping and reporting requirements were selected within the context of this
specific subpart and the specific process equipment and pollutants. The impact on small
businesses was accounted for in the regulation development. The requirements reflect the
burden on small businesses. Even though, the recordkeeping and reporting requirements are the
same for small and larger businesses. To the extent that larger businesses can use economies of
scale to reduce their burden, the overall burden will be reduced. The Agency considers these
requirements the minimum needed to ensure compliance and cannot reduce them further for
small businesses.
5(d) Collection Schedule
The specific frequency for each information collection activity within this request is
shown in Table 1: Annual Respondent Burden and Cost, NESHAP for Pulp and Paper
Production (40 CFR Part 63, Subpart S), (Proposed Amendments).
6. Estimating the Burden and Cost of the Collection
Table 1 documents the computation of individual burdens for the recordkeeping and
reporting requirements applicable to the industry for each of the subparts included in this ICR.
The individual burdens are expressed under standardized headings believed to be consistent with
the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks
and major assumptions have been identified. Responses to this information collection are
mandatory.
The 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.
6(a) Estimating Respondent Burden
The average annual burden to industry over the next three years from these recordkeeping
and reporting requirements is estimated to be 52,304 (Total Labor Hours from Table 1). These
hours are based on Agency studies and background documents from the development of the
standards or test methods, Agency knowledge and experience with the NESHAP program, the
previously approved ICR and any comments received. No burden estimates are provided for
new sources because no new facilities are expected to become affected sources during the 3-year
period of this ICR.
6(b) Estimating Respondent Costs
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial
Technical

$118.92 ($56.63 + 110%)
$97.78 ($46.56 + 110%)

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Clerical

$48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics (BLS),
December 2010, “Table 2. Civilian Workers, by occupational and industry group,” available at
www.bls.gov/news.release/ecec.t02.htm. The rates are from column 1, “Total compensation.”
The rates have been increased by 110 percent to account for the benefit packages available to
those employed by private industry.
(ii) Estimating Capital and Operation and Maintenance Costs
Since no new continuous emission or parameter monitors beyond those that may already
be in place are used to comply with this rule, the only type of industry costs associated with the
information collection activity in the standards are labor costs and emission testing costs
described below.
(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
Since this rule does not require any new continuous emission monitoring or electronic
monitoring data submittal, total capital costs are zero. Continuous monitoring requirements are
for parametric monitoring and these systems are already in place; therefore, no new equipment
would be required by the recordkeeping and reporting requirements. It is assumed that all mills
will contract a testing company to provide sampling and analytical services for air and water
tests.
Based on EPA’s experience the testing methods required for this rule, the purchase of
service for each method is estimated below. These estimates include labor, materials, and
analytical costs. The number of mills assumed to contract testing companies for compliance is
presented in Table 1. For the entire industry, the number of tests required annually for
demonstrating compliance and the associated cost are estimated as follows:
Method
Method 308
Method 26A
Method 304
Method 305
Method 21

Count
9
38
3
5
74

Cost, $
$14,000
$10,000
$11,000
$16,000
$ 3,000
TOTAL

Total, $
$126,000
$380,000
$ 33,000
$ 80,000
$222,000
$841,000

Based on these estimates for testing costs and the number of mills assumed to perform
compliance tests, the total annual cost to the industry is $841,000.

(iv) Affirmative Defense, Root Cause Analysis, and Malfunction Costs
EPA’s estimate for a affirmative defense and root cause analysis is based on general
experience to calculate the time and effort required of a source to review relevant data, interview

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plant employees, and reconstruct the events prior to a malfunction in order to determine primary
and contributing causes. The level of effort also includes time to produce and retain the report in
document form so that the source will have it available should EPA or state enforcement
agencies ever request to review it.
To provide the public with an estimate of the relative magnitude of the burden associated
with an assertion of the affirmative defense position adopted by a source, EPA provides an
administrative adjustment to this ICR that estimates the costs of the notification, recordkeeping
and reporting requirements associated with the assertion of the affirmative defense. EPA’s
estimate for the required notification, reports and records, including the root cause analysis,
associated with a single incident totals approximately $3,258 and is based on the time and effort
required of a source to review relevant data, interview plant employees, and document the events
surrounding a malfunction that has caused an exceedance of an emission limit. The estimate also
includes time to produce and retain the records and reports for submission to EPA. EPA
provides this illustrative estimate of this burden because these costs are only incurred if there has
been a violation and a source chooses to take advantage of the affirmative defense.
Of the number of excess emission events reported by source operators, only a small
number would be expected to result from a malfunction, and only a subset of excess emissions
caused by malfunctions would result in the source choosing to assert the affirmative defense.
Thus we believe the number of instances in which source operators might be expected to avail
themselves of the affirmative defense will be extremely small. For this reason, we estimate no
more than 2 or 3 such occurrences for all sources within a given category over the 3-year period
covered by this ICR. For the purpose of this estimate, we are adding two (2) instances of
affirmative defense. We expect to gather information on such events in the future and will revise
this estimate as better information becomes available.
6(c) Estimating Agency Burden and Cost
The only costs to the Agency are those costs associated with analysis of the reported
information. EPA's overall compliance and enforcement program includes activities such as the
examination of records maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected information.
The average annual Agency cost during the three years of the ICR is estimated to be
$310,058, see Table 2 in Section 6(e).

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This cost is based on the average hourly labor rate as follows:
Managerial
Technical
Clerical

$62.27 (GS-13, Step 5, $38.92 x 1.6)
$46.21 (GS-12, Step 1, $28.88 x 1.6)
$25.01 (GS-6, Step 3, $15.63 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2011 General Schedule”
(http://www.opm.gov/oca/11tables/pdf/gs_h.pdf) which excludes locality rates of pay. These
rates were increased by 60 percent to include fringe benefits and overhead. Details upon which
this estimate is based appear in Table 2: Annual Agency Burden and Cost. The only costs to the
Agency are those costs associated with analysis of the reported information. EPA's overall
compliance and enforcement program includes activities such as the examination of records and
reports maintained by the respondents, periodic evaluation of sources of emissions, and the
analysis, publication and distribution of collected information. The only Federal costs are user
costs associated with analysis of the reported information. Publication and distribution of the
information are part of the AFS program. Examination of records to be maintained by the
respondents will occur as part of the periodic inspection of sources, which is part of EPA's
overall compliance and enforcement program.
6(d) Estimating the Respondent Universe and Total Burden and Costs
Based on our research for this ICR, there are approximately 114 existing sources
currently subject to the standard, all of which will keep records and submit reports. It is
estimated that no additional sources will become subject to the regulation in the next three years.
The average number of respondents over the three-year period of this ICR is 114. The number of
total annual responses (calculated based on section 3.E in Table 1) is 522.
6(e) Bottom Line Burden Hours And Cost Tables
The detailed bottom line burden hours and cost calculations for the respondents and the
Agency are shown in Tables 1 and 2, respectively, and summarized below.
(i) Respondent Tally
The total annual labor costs are $4,939,270. Details regarding these estimates may be
found in Table 1. Annual Respondent Burden and Cost, NESHAP for Pulp and Paper Production
(40 CFR Part 63, Subpart S) attached. Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to average 100 hours per
response.
The total annual capital/startup and O&M costs to the regulated entity are $841,000.
The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and
Maintenance (O&M) Costs.

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(ii) The Agency Tally
The average annual Agency burden and cost over next three years is estimated to be
6,874 labor hours at a cost of $310,058. See Table 2. Annual Agency Burden and Cost,
NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) attached.
6(f) Reasons for Change in Burden
This ICR is prepared for amendments to the Pulp and Paper Production NESAHP (40
CFR, Part 63, Subpart S). These amendments: (1) adjusted references to the Part 63 General
Provisions (40 CFR, Part 63, Subpart A) to remove the startup, shutdown, and malfunction
exemption; (2) added affirmative defense reporting to subpart S; (3) added repeat (5-year) air
emissions testing requirements for selected equipment; and (4) increased the stringency of the
kraft condensates standards. Adjustments for these amendments are reflected in Tables 1 and 2
of this ICR.
The number of affected mills changed because of: (1) continued consolidation and
closures within the pulp and paper industry which reduced the number of mills previously
affected by Subpart S; and (2) updates to the number of affected major source mills based on
EPA’s 2011 pulp and paper sector survey. Further, the percentages of mills using various
compliance options were refined based on the results of EPA’s 2011 pulp and paper sector
survey.
Costs per labor hour increased due to increases in labor rates. In addition, some rows in
the former Table 1 were consolidated to eliminate obsolete references to “MACT I” versus
“MACT III” since subpart S covers MACT I and MACT III processes. This consolidation
eliminates redundancy and the potential for double counting mills with both types of processes.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 100 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 valid OMB Control Number. The OMB Control
Numbers for EPA’s regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

15
To comment on the Agency’s need for this information the accuracy of the provided
burden estimates, and any suggestions for minimizing respondent burden, including through the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. EPA-HQ-OAR-2007-0544, which is available for online viewing at
http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and
Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 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
Air Docket is (202) 566-1927. An electronic version of the public docket is available at
http://www.regulations.gov. This site can be used 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. When 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 Officer for EPA. Please include Docket ID Number EPA-HQ-OAR2007-0544 and OMB Control Number 2060-NEW in any correspondence.
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.

Table 1. Annual Respondent Burden and Cost - NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) - Proposed Amendments
(A)
(B)
(C)
(D)
Person-hours
per
Emissions
Number of
Person-hours Number of Testing Cost respondent
respondents per
per year
Per
occurrences
per
year (a)
Note
(C=AxB)
Occurrence
per year
occurrence
Burden Item
1. Applications
Not applicable
2. Surveys and Studies
Not applicable
3. Reporting Requirements
A. Read and Understand Rule Requirements
30
1
$0
30
171
b,d
B. Required Activities
1.1) Pulping processes (Non-Sulfite)
a. Provide documentation that vent streams are
introduced to the flame zone of a boiler, lime kiln, or
24
1
$0
24
5
c,e
b. Provide documentation that the control incinerator is
operating at a minimum level of 1600 F and 0.75 sec
residence time, or
60
1
$0
60
1
c,f
c. Performance test of control device - test method 308
24
1
$14,000
24
1 c,f,g,n
1.2) Pulping Processes (Sulfite)
24
1
$14,000
24
1 c,g,i,n
Performance test of control device - test method 308
2.1) Bleaching process vent scrubber
Performance test of scrubber or control device - test
method 26A
24
1
$10,000
24
5 c,g,j,n
3.1) Pulping wastewater treatment (Non-Sulfite)
a. Performance test of condensate segregation and
control device (test method 305), or
24
1
$16,000
24
4 c,h,k,n
b. Performance test of biotreatment unit - test method 304
24
1
$11,000
24
3 c,h,l,n
3.2) Pulping wastewater treatment (Sulfite)
Performance test of control device - test method 305
24
1
$16,000
24
1 c,h,m,n
4.1) Repeat of performance test (5-yr intervals)
a. Test method 308 - pulping
24
1
$14,000
24
7 g,n,t
b. Test method 26A - bleaching
24
1
$10,000
24
33 g,n,t
4.2) Inspection of enclosures, closed vent, wastewater
conveyance system
a. Initial/Annual inspection - test method 21
8
1
$3,000
8
74
o
b. Monthly visual inspection
4
12
$0
48
111
o
C. Create Information
Included in 3.B
D. Gather Information
Included in 3.B
E. Report Preparation
1) Initial Notification Report (<45 days after promulgation)
16
1
$0
16
0
c,d
2) Notification of compliance status
16
1
$0
16
0
c,d
3) Initial Compliance Strategy Report
40
1
$0
40
0
c,p
4) Compliance Strategy Report Update
16
1
$0
16
0
p
5) Semi-annual summary report
16
2
$0
32
114
d
6) Continuous monitoring/Exceedance reports
24
2
$0
48
17
q
7) Notification of performance test (>75 days before test)
4
1
$0
4
129
c,r
8) Notification of construction/reconstruction (>180 days
beforehand)
4
1
$0
4
17
c,s
9) Notification of actual startup (<150 days after startup)
4
1
$0
4
17
c,s
10) Affirmative defense
30
1
$0
30
228
u
4. Recordkeeping Requirements
A. Read Instructions
Included in 3.A
B. Plan Activities
Included in 3.B
C. Implement Activities
Included in 3.B
D. Develop Record System
40
1
$0
40
114 c,d,v
E. Record information
Records of continuous monitoring for operating parameters
2
52
$0
104
114
d

(E)
(F)
(G)
Clerical
Technical
person- Management personhours per person-hours hours per
year
per year
year
(E=CxD) (F=Ex0.05) (G=Ex0.1)

(H)

Total cost
per year

5,130

257

513

$557,110

120

6

12

$13,032

60
24
24

3
1
1

6
2
2

$6,516
$2,606
$2,606

120

6

12

$13,032

96
72

5
4

10
7

$10,425
$7,819

24

1

2

$2,606

168
792

8
40

17
79

$18,245
$86,010

592
5,328

30
266

59
533

$64,290
$578,612

0
0
0
0
3,648
816
516

0
0
0
0
182
41
26

0
0
0
0
365
82
52

$0
$0
$0
$0
$396,167
$88,616
$56,037

68
68
6,840

3
3
342

7
7
684

$7,385
$7,385
$742,813

4,560

228

456

$495,208

11,856

593

1,186

$1,287,542
Table 1, Page 1 of 2

(A)

Burden Item
Records of periodic inspections (monthly visual inspections
and annual method 21)
Record of malfunctions
F. Personnel Training
G. Time for audits
TOTAL INDUSTRY BURDEN SUMMARY:
Total annual responses (based on 3.E)
Total annual labor hours
Average hours per response
Annual costs in dollars

(C)
(D)
Person-hours
per
Emissions
Number of
Person-hours Number of Testing Cost respondent
respondents per
per year
Per
occurrences
per
year (a)
Note
(C=AxB)
Occurrence
per year
occurrence
Included in 3.B
2
Not applicable
8
Total:

(B)

(E)
(F)
(G)
Clerical
Technical
person- Management personhours per person-hours hours per
year
per year
year
(E=CxD) (F=Ex0.05) (G=Ex0.1)

(H)

Total cost
per year

12

$0

24

114

d

2,736

137

274

$297,125

2

$0

16

114

d

1,824
45,482

91
2,274

182
4,548

$198,083
$4,939,270

522
52,304
100
$4,939,270

Footnotes
a Values are rounded up to the nearest whole number.
b MACT I Mills include kraft, sulfite, soda, and semi-chemical operations. MACT III Mills include mechanical, non-wood, and secondary fiber operations; along with papermaking at all types of mills.
Only major sources are subject to Subpart S.
c One-time activity. In out years, after initial compliance date, assume that 5% of mills affected as a result of unexplained exceedances.
d Performed by all major source mills. (111 major MACT I Category Mills, 60 major stand-alone MACT III category mills)
All MACT I category mills are affected by this rule. The only MACT III category mills affected by this rule are those bleaching with chlorinated compounds (3 mills).
Total number of mills affected by this rule is 111 + 3 = 114
e Approximately 85% of mills use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non-sulfite pulping mills. (85% of 106 = 90)
f Approximately 15% of mills use incineration for pulping lines (assuming half of these provide acceptable design specs (8), and half conduct performance tests (8))
g Estimate includes test plan, test report, and parametric monitoring setup. Method 308 tests for pulping lines and method 26A tests for bleaching lines.
h Estimate includes test plan, test report, and parametric monitoring setup. Method 304 and 305 are for wastewater streams.
i Assume that all 5 sulfite pulping mills will conduct performance tests.
j 69 MACT I and 3 MACT III category mills have bleaching lines that use chlorinated compounds.
k Estimated that each kraft mill has one pulping wastewater control device, with 60% of mills using stream strippers (60% of 97 = 58). Per footnote "c," 5% of 58= 3.
Facilities with steam strippers are assumed to perform initial condensate segregation and performance tests.
l Approximately 40% of kraft mills use biotreatment. (40% of 97 = 39) Per footnote "c," 5% of 39 = 2.
Facilities with biotreatment control will perform initial performance tests.
m Assume sulfite mills will monitor gas scrubber parameters and use Water-9 Model for emission estimates.
n Assumed that 15% of performance tests are failed and need to be repeated.
o Initial and annual activity. 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
and will have to test using method 21 (2/3 x 111 = 74). Monthly visual inspections are to be conducted by chemical pulp mills (111).
p The requirement for a compliance strategy report is now obsolete (required before 2006 only).
q Assumed that 15% of all affected mills during any one quarter will be required to submit an exceedance report in addition to the summary report. (15% of 115 = 17)
r EPA must be notified of all tests including out-year repeat performance tests and tests conducted at 5-year intervals.
s Assumed 15% of all affected mills conduct construction or reconstruction per year. (15% of 114 = 17)
t Kraft/soda/semichemical mills using compliance options requiring testing (8 mills) are likely to have 3 emission points that would require 5-year repeat testing (LVHC, HVLC, and stripper off gases).
Sulfite mills (5) are likely to have 1 emission point to be tested. Total no. M308 tests = [(8 mills x 3 points) + (5 mills x 1 point)] x 1.15 = 33. Annual no. of 5-year repeat M308 tests = 33/5 = 7 tests.
Mills bleaching with chlorinated compounds (72 mills) are likely to have two emission points requiring M26A testing. Total no. of M26A tests = (72 x 2) x 1.15 = 166. Annual no. of 5-yr
repeat M26A tests = 166/5=33 tests.
u Assumes all affected mills (114) will have 2 malfunctions per year requiring affirmative defense review.
v For this amendment ICR, includes time for reevaluating previously developed SSM-record system at 114 mills according to rule changes. T
[ his time may be eliminated in future 3-year ICR renewals.]

Table 1, Page 2 of 2

Table 2. Annual Agency Burden and Cost of the NESHAP for Pulp and Paper Production (40 CFR Part 63, Subpart S) - Proposed Amedments
(A)
(B)
(C)
(D)
(E)
Number of
EPA Hours Tech Hours Management Clerical Hours
Respondents
Per
Per Year Hours Per Year
Per Year
Burden Item
Per Year (a)
Note
Respondent
(CxB)
(D=Cx0.05)
(E=Cx0.1)
1. Applications
Not applicable
2. Surveys and Studies
Not applicable
3. Reporting Requirements
A. Read and Understand Rule Requirements
171
a
6
1026
51
103
B. Required Activities
Initial performance tests:
1.1) Pulping processes (Non-Sulfite) - Choice of:
a. Review Documentation that vent streams are introduced to the
flame zone of a boiler, lime kiln, or recovery furnace, or
5
b,c
8
40
2
4
b. Review documentation that the control incinerator is operating
at a level of at least 1600 F and 0.75 sec residence time, or
1
b,d
8
8
0
1
c. Review performance test of control device
1
b,d,i
8
8
0
1
1.2) Pulping Processes (Sulfite)
1
b,e,i
8
8
0
1
-Revew performance test of control device
2.1) Bleaching process vent scrubber
-Review performance test of control device
5
b,f,i
8
40
2
4
3.1) Pulping wastewater treatment system (Non-Sulfite) - Choice of:
a. Review performance test of condensate segregation and
control device, or
4
b,g,i
8
32
2
3
b. Review performance test of biotreatment unit
3
b,h,i
8
24
1
2
3.2) Pulping wastewater treatment (Sulfite)
-Review performance test of control device
1
b,e,i
8
8
0
1
4.1) Review repeat performance tests (5-yr intervals)
a. Test method 308 - pulping
7
i,q
8
56
3
6
b. Test method 26A - bleaching
33
i,q
8
264
1
1
4.2) Inspection of enclosures, closed vent, wastewater conveyance
system
a. Initial/Annual inspection - test method 21
74
j
0
0
0
0
b. Monthly visual inspection
111
j
0
0
0
0
C. Create Information
Included in 3.B
D. Gather Information
Included in 3.B
E. Report Preparation
Review Initial Notification Report
0
b
4
0
0
0
Review Notification of compliance status
0
b
4
0
0
0
Review initial compliance strategy report
0
b,p
4
0
0
0
Review compliance strategy report update
0
b,p
4
0
0
0
Review Semi-annual summary report
114
k
2
228
11
23
Review Continuous monitoring/Exceedance reports
17
m
8
136
7
14
Review Notification of performance test
129
b,n
8
1032
52
103
Review Notification of construction/reconstruction
17
b,o
4
68
3
7
Review Notification of actual startup
17
b,o
4
68
3
7
Review Affirmative Defense
228
r
8
1824
91
182
4. Recordkeeping Requirements
A. Read Instructions
Included in 3.A
B. Plan Activities
Included in 3.B
C. Implement Activities
Included in 3.B
D. Develop Record System
114
b,k
0
0
0
0
E. Record information
Review records of monitoring parameters
114
k
1
114
6
11

(F)
EPA Cost Per
Year

$53,170

$2,073
$415
$415
$415

$2,073

$1,658
$1,244
$415
$2,902
$12,286

$0
$0

$0
$0
$0
$0
$11,816
$7,048
$53,481
$3,524
$3,524
$94,524

$0
$5,908
Table 2, Page 1 of 2

Burden Item
Review records of periodic inspections (monthly visual inspections
and annual method 21)
Review records of malfunctions
F. Personnel Training
G. Time for audits

(A)
Number of
Respondents
Per Year (a)
Included in 3.B
114
Not applicable
114
Total:

Note

(B)
EPA Hours
Per
Respondent

(C)
(D)
(E)
Tech Hours Management Clerical Hours
Per Year Hours Per Year
Per Year
(CxB)
(D=Cx0.05)
(E=Cx0.1)

(F)
EPA Cost Per
Year

k

1

114

6

11

$5,908

k

8

912
6010

46
288

91
576

$47,262
$310,058

TOTAL FEDERAL GOVERNMENT BURDEN SUMMARY:
Total hours per year
6,874
Annual costs in dollars
$310,058
Footnotes
a Values are rounded up to nearest whole number. There are 171 majour source mills (111 MACT mills producing chemical pulp, and 60 stand-alone MACT III category mills).
All MACT I category mills are afftected by this rule. The only MACT III category mills affected by this rule are those bleaching with chlorinated compounds (3 mills).
Total number of mills affected by this rule is 111 + 3 = 114
b One-time activity. After initial compliance date, assume that 5% of mills affected as a result of unexplained exceedances.
c Approximately 85% of mills use a recovery boiler, power boiler, or lime kiln for control of pulping vents. There are 106 non-sulfite pulping mills. (85% of 106 = 90)
d Approximately 15% of mills use incineration for pulping lines (assuming half of these provide acceptable design specs (8), and half conduct performance tests (8))
e Assume that all 5 sulfite pulping mills will conduct performance tests.
f 69 MACT I and 3 MACT III category mills have bleaching lines that use chlorinated compounds.
g Estimated that each kraft mill has one pulping wastewater control device, with 60% of mills using stream strippers (60% of 97 = 58).
Facilities installing new biotreatment control will perform initial performance tests.
h Approximately 40% of kraft mills use biotreatment. (40% of 97 = 39)
i Assumed that 15% of performance tests are failed and need to be repeated.
j Initial and annual activity. 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
and will have to test using method 21 (2/3 x 111 = 74). Monthly visual inspections are to be conducted by chemical pulp mills (111).
k Performed for all affected mills. (114)
l Performed for all kraft mills. (97)
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 114 = 17)
n EPA must be notified of all tests including out-year repeat performance tests and tests conducted at 5-year intervals.
o Assumed 15% of mills conduct construction or reconstruction per year. (15% of 114 = 17)
p The requirement for a compliance strategy report is now obsolete (required before 2006 only).
q Kraft/soda/semichemical mills using compliance options requiring testing (8 mills) are likely to have 3 emission points that would require 5-year repeat testing (LVHC, HVLC, and stripper off gases).
Sulfite mills (5) are likely to have 1 emission point to be tested. Total no. M308 tests = [(8 mills x 3 points) + (5 mills x 1 point)] x 1.15 = 33. Annual no. of 5-year repeat M308 tests = 33/5 = 7 tests.
Mills bleaching with chlorinated compounds (72 mills) are likely to have two emission points requiring M26A testing. Total no. of M26A tests = (72 x 2) x 1.15 = 166. Annual no. of 5-yr
repeat M26A tests = 166/5=33 tests.
r Assumes all affected mills (114) will have 2 malfunctions per year requiring affirmative defense review.

Table 2, Page 2 of 2