1805t10

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Overview

Table 1
Table 2
CapitalStartup Costs
# Responses
Count of Respondents

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hr/yr (E=CxD)	(F) Management person hr/yr (Ex0.05)	(G) Clerical person hr/yr (Ex0.1)	(H) Total Cost Per year b	Renewal Notes
1. Applications	N/A									Tech	$117.92
2. Surveys and studies	N/A									Mgmt	$147.40
3. Reporting requirements										Cler	$57.02
A. Familiarization with the regulatory requirements c	1	1	1	107	107	5.35	10.7	$14,015.55	Reduction in burden - Was $141, 500 (30 hours in initial year - Oct 11, 2017-Oct 11, 2018) due to one-time event in first year after RTR amendments. Changed to be the lower annual on-going burden item.
B. Required activities d										Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.”)
Prepare for initial/periodic performance test	24	1	24	25	600	30	60	$71,559	Increase in burden - was 24	Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%*rate)
Attend initial/periodic performance test	24	2	48	25	1,200	60	120	$157,183.74		Mgmt.	$70.19	$147.40
Prepare for retest	24	1	24	5	120	6	12	$15,718.37		Tech.	$56.15	$117.92
Attend retest	24	2	48	5	240	12	24	$31,436.75		Cler.	$27.15	$57.02
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports										Hours per Response
Notifications e, f, g										122000	# hours
Notification of construction/reconstruction	2	1	2	1.33	3	0.13	0.27	$349.30	Increase in burden - was 1	348	# responses
Notification of actual startup	2	1	2	1.33	3	0.13	0.27	$349.30	Increase in burden - was 1	350	hr/resp
Notification of applicability of standard	2	1	2	1.33	3	0.13	0.27	$349.30	Increase in burden - was 1
Notification of compliance status	80	1	80	1.33	107	5.33	10.67	$13,971.89	Increase in burden - was 1
Notification of performance test/retest	2	1	2	43	86	4.3	8.6	$11,264.83
Notification of performance evaluation	2	1	2	43	86	4.3	8.6	$11,264.83
Report of performance test/retest (through CEDRI using ERT) h	8	1	8	43	344	17.2	34.4	$45,059.34
Excess emissions report (through CEDRI) i
Semiannual reports of monitoring exceedances and periods of noncompliance	16	2	32	5	160	8	16	$20,957.83
Semiannual reports of no exceedances	8	2	16	102	1,632	81.6	163.2	$213,769.89
Subtotal for Reporting Requirements					5,393			$607,250
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system j	40	1	40	1.33	53	2	5.33	$6,887.68	Increase in burden - was 1
E. Time to enter information
Records and documentation of supporting calculations for compliance determinations k	8	1	8	43	344	17	34.4	$45,029.86
Record of compliant monitoring parameter ranges	2	1	2	43	86	4.3	8.6	$11,264.83
Records certifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard for kraft and soda recovery furnaces l	2	1	2	1	2.0	0.07	0.2	$257.55	Increase in burden - was 0.7
Records demonstrating compliance with requirement to maintain proper operation of ESP’s AVC m	8	2	16	183.67	2,939	146	293.872	$384,794.53	Increase in burden - was 183
Records of failures to meet standards n	2	12	24	5	120	6	12	$15,718.37
Records of black liquor solids firing rates for recovery furnaces and semichemical combustion units o	1.5	52	78	104	8,112	406	811.2	$1,062,621.04
Records of lime production for lime kilns p	1.5	52	78	98	7,644	382	764.4	$1,001,230.94
Records of CMS data q	0.5	1,050	525	107.33	56,350	2,809	5635	$7,379,833.57	Increase in burden - was 107
F. Time to train personnel
Initial training r	40	1	40	1.33	53	2	5.33	$6,887.68	Increase in burden - was 1
Refresher training s	16	1	16	107	1,712	86	171.2	$224,307.76
G. Time to adjust existing ways to comply with previously applicable requirements t	17.8	1	17.8	107	1,905	144	190.46	$256,665.44	Reduction in burden - was $377,000 (80 hours over 3 years). Assume this burden was intended to be distributed over the initial 3 years following publication. For this ICR, revised to account for only Years 2 and 3 of this one-time 3-year burden. See footnote for explanation.
H. Time to transmit or disclose information
Compile data for semiannual periods u	96	2	192	107.33	20,608	1,027	2060.8	$2,698,867.61	Increase in burden - was 107
Enter/verify information for semiannual reports v	8	2	16	107.33	1,717	86	171.73	$224,967.05	Increase in burden - was 107
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					116,927			$13,319,334
TOTAL LABOR BURDEN AND COSTS (rounded) w					122,000			$13,900,000	Compared to RTR ICR, hours decreased (removed first-year burden hours associated with RTR amendments, added burden for 1 new facility - net decrease) and cost slightly increased (due to new labor rates) - was 124,000 hours and $13,400,000 (2016 rates).
TOTAL CAPITAL AND O&M COST (rounded) w								$831,000	Compared to RTR ICR, increased (due to 1 new facility) - was $809,000
GRAND TOTAL (rounded) w								$14,700,000	Compared to In RTR ICR, increased - was $14,200,000.
a We estimate that the number of existing sources subject to the rule is 107 pulp mills. We estimate 1 new pulp mill will begin operation in 2021. We also estimate that new equipment will be installed at three existing pulp mills and become subject to the rule over the 3 years of this ICR (two new recovery furnaces, two new SDTs, and one new lime kiln). Based on these estimates, over the 3 years of this ICR, there will be an average of 107.33 pulp mills per year (107 existing facilities + 1 new facility in the third year/3 years = 107.33) and new source requirements for an average of 1.33 pulp mills per year (1 modified or reconstructed facility per year + 1 new facility in the third year/3 years = 1.33 facilities).
b This ICR uses the following labor rates: $147.40 per hour for Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, Table 2. Civilian Workers, by Occupational and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c We have assumed that it will take 1 hour each year for existing respondents to refamiliarize themselves with rule requirements.
d We estimate that it will take the respondent 24 hours to prepare for initial/periodic performance test (e.g., prepare test plan) and 24 hours to attend the test. We also estimate 2 plant personnel will attend the test. We estimate that 74 mills (which includes the 1 new mill) will need to conduct a test (the rest of the 107 existing mills are already required under existing state rules to conduct tests); this will occur once during the 3-year ICR period (74 respondents/3 years = 25). In addition, we estimate that 20% of respondents (20% x 25 respondents = 5) will repeat performance test due to failure.
e With the exception of the notification of compliance status, we estimate that it will take the respondent 2 hours once per year to complete the notifications and submit selected ones through the EPA's CEDRI.
f We estimate that it will take the respondent 80 hours once in the initial year to prepare the notification of compliance status and submit it through the EPA's CEDRI.
g We estimate that the 1 new pulp mill and 3 existing pulp mills with new process units will submit initial notifications (construction/reconstruction, actual startup, applicability of standard) and a notification of compliance status, which are one-time requirements (4 new respondents/3 years = 1.33). We estimate that 43 mills will submit notifications of performance test/retest and performance evaluation over the 3-year ICR period (testing = (1 new + 107 existing respondents)/3 years = 36; retesting = 20% x 36 respondents = 7; total testing and retesting = 36 + 7 = 43).
h Hard copy report of performance test/retest is included in capital/startup costs. Submittal of performance test/retest data through the EPA's CEDRI in ERT format is estimated to require 8 hours for 43 mills (see respondent calculation in footnote g).
i We estimate that 5% of respondents (5% x 107.33 respondents = 5) will each take 16 hours two times per year to complete reports of monitoring exceedances and periods of noncompliance and submit them through the EPA's CEDRI. We estimate that 95% of respondents (95% x 107.33 respondents = 102) will each take 8 hours two times per year to write reports of no exceedances and submit them through the EPA's CEDRI.
j We estimate that it will take the respondent 40 hours to develop a record system to comply with monitoring requirements (4 new respondents/3 years = 1.33).
k We estimate that it will take the respondent 8 hours (1 day) each year to enter records and documentation of supporting calculation for compliance determinations and 2 hours to enter a record of compliant monitoring parameter ranges. We estimate that 43 mills (see footnote g) will enter this information (includes initial test and retest, for mills required to retest).
l We estimate that the 1 new pulp mill and 2 existing mills will install new recovery furnaces over 3 years, for an average of 1 mill with new recovery furnaces per year over the ICR period (3 mills/3 years=1). Based on current industry trends, the new furnaces are expected to be a non-direct contact evaporator (NDCE) recovery furnace equipped with a dry ESP system. We estimate that it will take the respondent 2 hours to record this information.
m Assume the 1 new facility has two recovery furnaces with 1 ESP for each recovery furnace. We estimate that it will take 8 hours per semiannual period each year to keep records demonstrating compliance with the requirement to maintain proper operation of the ESP AVC for 183.67 recovery furnace and lime kiln ESPs (183 existing ESPs + 2 new ESPs in the third year/3 years = 183.67).									183 count likely from Cost Memo, unlikely to have changed significantly.
n We estimate that 5% of respondents (5% x 107.33 respondents = 5) will fail to meet standards each year. We estimate that each respondent will take 2 hours 12 times per year to keep records of failures to meet the standards.
o We estimate 104 existing kraft, soda, and stand-alone semichemical pulp mills have recovery furnaces or other chemical recovery combustion units that will need to keep records of black liquor solids firing rate. We estimate that each respondent will take 1.5 hours 52 times per year to keep these records.									No newer facilites use BLO, so assuming the 1 new facility has no BLO system; 104 count likely from Cost Memo, unlikely to have changed significantly.
p We estimate 98 existing kraft and soda pulp mills have lime kilns that will need to keep records of lime production rate. We estimate that each respondent will take 1.5 hours 52 times per year to keep these records.									98 count likely from Cost Memo, unlikely to have changed significantly
q For the 1 new facility, assume each of the 2 NDCE recovery furnaces has a smelt dissolving tank (SDT) with a wet scrubber. We estimate that each respondent will take 0.5 hours 1,050 times per year to record wet scrubber and regenerative thermal oxidizer (RTO) parameters at all existing 107.33 mills (107 existing sources + 1 new source in third year/3 years=107.33).
r We estimate that it will take the respondent 40 hours (1 week) once per year for initial training of personnel with new sources (4 new respondents/3 years) = 1.33).
s We estimate that it will take each respondent 16 hours to provide refresher training each year for personnel at all 107 existing mills.
t Over the period October 11, 2017 through October 11, 2020, due to the RTR amendments published on October 11, 2017, we estimated that it would take each respondent 80 hours to make a one-time adjustment to existing data acquisition systems to include startup and shutdown periods and the revised opacity monitoring allowances, and to transition to electronic excess emissions reporting. This ICR includes the burden for the period November 1, 2018 through October 31, 2020, which equates to 2/3 of the original 80-hour estimate, or 53.3 hours. Averaged over the 3 years of this ICR, this burden equates to 17.8 hours per year for 107 respondents.
u We estimate that each respondent will take 96 hours per semiannual period to compile data for all 107.33 mills (107 existing sources + 1 new sources in third year/3 years=107.33).
v We estimate that each respondent will take 8 hours two times per year to verify information for reports for all 107.33 mills (107 existing sources + 1 new sources in third year/3 years=107.33).
w Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR Part 63, Subpart MM) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hr/yr (E=CxD)	(F) Management person hr/yr (Ex0.05)	(G) Clerical person hr/yr (Ex0.1)	(H) Cost, $ b	ERG Notes
1. Attend initial/periodic performance test c	24	1	24	3.6	86.4	4.32	8.64	$4,724.01
2. Attend retest c,d	24	1	24	0.7	16.8	0.84	1.68	$918.56		Tech	$48.75
3. Report review										Mgmt	$65.71
Notification of construction/reconstruction e	2	1	2	1.33	2.67	0.13	0.27	$145.80	was 1	Cler	$26.38
Notification of actual startup e	2	1	2	1.33	2.67	0.13	0.27	$145.80	was 1	Agency Rates Source: Office of Personnel Management (OPM), 2018 General Schedule			Note that 2017 labor rates were used in RTR amendmnets ICR supporting statement.
Notification of applicability of standard e	2	1	2	1.33	2.67	0.13	0.27	$145.80	was 1		Hourly Mean Wage	With Fringe & Overhead
Notification of initial/periodic performance test f	2	1	2	43	86	4.3	8.6	$4,702.14		(GS- 12, step 1) - Tech.	30.47	$48.75
Notification of performance evaluation f	2	1	2	43	86	4.3	8.6	$4,702.14		(GS- 13, step 5) - Mgmt.	41.07	$65.71
Review of notification of compliance status e	4	1	4	1.33	5.33	0.27	0.53	$291.61	was 1	(GS-6, step 3) - Cler.	16.49	$26.38
Review of excess emissions report
Semiannual reports of monitoring exceedances and periods of noncompliance g	8	2	16	5	80	4	8	$4,374.08
Semiannual reports of no exceedances h	2	2	4	102	408	20.4	40.8	$22,307.81
Subtotal for Burden and Cost - Salary					893			$42,458
Travel Expenses for Tests Attended i								$1,935
TOTAL ANNUAL BURDEN AND COST j								$44,400	Rounded to $43,600 with 2017 labor rates in RTR ICR; addition of 1 new facility added about $200.
a We estimate that the number of existing sources subject to the rule is 107 pulp mills. We estimate 1 new pulp mill will begin operation in 2021. We also estimate that new equipment will be installed at three existing pulp mills and become subject to the rule over the 3 years of this ICR (two new recovery furnaces, two new SDTs, and one new lime kiln). Based on these estimates, over the 3 years of this ICR, there will be an average of 107.33 pulp mills per year (107 existing facilities + 1 new facility in the third year/3 years = 107.33) and new source requirements for an average of 1.33 pulp mills per year (1 modified or reconstructed facility per year + 1 new facility in the third year/3 years = 1.33 facilities).
b This cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 Managerial rate (GS-13, Step 5,$41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule which excludes locality rates of pay.
c Assume EPA will attend tests at 3.6 plants per year. We estimate that it will take EPA personnel 24 hours once per year to attend initial and periodic performance tests at 10% of plants (0.10 x 108/3 years = 3.6), assuming 107 existing plant and 1 new plant will test.
d Assume EPA will attend retests at 0.7 plants per year. We estimate that 20% of respondents will repeat performance test due to failure and that EPA personnel will attend 10% of retests (0.20 x 0.10 x 108/3 years = 0.7), assuming 107 existing plant and 1 new plant will test.
e We estimate that it will take EPA personnel 2 hours once per year to complete review of the initial notifications (construction/reconstruction, actual startup, applicability of standard) and 4 hours once per year to review the notification of compliance status for new process units (4 mills with new process units/3 years = 1.33).
f We estimate that it will take EPA personnel 2 hours once per year to complete review of the initial and periodic notifications of performance test/retest and performance evaluation. We estimate that 43 mills will submit notifications of initial/periodic performance test/retest and performance evaluation over the 3-year ICR period (test: (1 new + 107 existing respondents)/3 years = 36; retest: 20% x 36 = 7; total: 36 + 7 = 43).
g We estimate that it will take EPA personnel 8 hours two times per year to review the monitoring exceedances and periods of noncompliance in the excess emissions report for 5% of respondents (5% x 107.33 = 5).
h We estimate that it will take EPA personnel 2 hours two times per year to review the no exceedances report for 95% of respondents (95% x 107.33 = 102).
i We estimate that it will take EPA personnel 1 day per plant plus time for travel, at $50 per diem per day, and $400 transportation expense per round trip. Assuming an average of 4.3 tests/retests each year (3.6 tests + 0.7 retests = 4.3)(see footnotes c and d), the annual cost for travel expenses is $1,935 (4.3 tests/retests*($400+$50) = $1,935).
j Sum of salary and expenses. Total has been rounded to 3 significant figures. Figure may not add exactly due to rounding.

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Sheet 3: CapitalStartup Costs

Capital/Startup Costs
(A)	(B)	(C)	(D)	ERG Notes
Cost Item	Capital/Startup Cost for One Respondent	Number of Respondents	Total Annualized Capital/ Startup Cost b		Capital recovery factor:b	0.244
			(B x C)
Performance tests:
Method 5 for PM	$2,439	263	Tracy Curtis: I updated these formulas to annualize individual tests costs so that this translates to template and going forward. $641,433	Added 2 tests for 2 furnaces for 1 new facility
Method 25A for THC	$3,414	7	$23,901	Added 2 tests for 2 furnaces for 1 new facility
Method 308 for methanol	$3,414	8	$27,316	Added 2 tests for 2 furnaces for 1 new facility
Retests a			$138,530
Total annualized capital/startup cost b			$831,000	Was $809,000; adding 1 new facility added $22,000/yr.
a We estimate that 20% of respondents will repeat the performance test due to failure. Estimate assumes 107 existing facilities with 263 sources, 1 new facility with 2 recovery furnaces, and 6 new sources at 3 existing facilities, 5 of which require THC testing.
b Annualized capital costs were estimated assuming a 5-year payment period at 7% interest for initial performance tests (with a capital recovery factor of 0.244).

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Sheet 4: # Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity a	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses	ERG Notes
				E=(BxC)+D
Notification of construction/ reconstruction	1.33	1	0	1.33
Notification of actual startup	1.33	1	0	1.33
Notification of applicability of standard	1.33	1	0	1.33
Notification of performance test/ retest	43	1	0	43
Notification of performance evaluation	43	1	0	43
Notification of compliance status	1.33	1	0	1.33
Report of performance test/retest	43	1	0	43
Semiannual report of monitoring exceedances and periods of noncompliance	5	2	0	10
Semiannual report of no exceedances	102	2	0	204
			Total	348	was 347 in RTR ICR; increased by 1.32.

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Sheet 5: Count of Respondents

Count of Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents a	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	1	107	0	1	107
2	1	107	0	1	107
3	2	107	0	1	108
Average	1.33	107	0	1	107.33
Count of Existing Pulp Mills
Mill Type	Count of Existing Pulp Mills
Kraft	65
Kraft, Mechanical	4
Kraft, Mechanical, Secondary	2
Kraft, Secondary	17
Kraft, Secondary, SemiChem	5
Kraft, SemiChem	3
Kraft, Sulfite-Na	1
Soda	1	98	kraft/soda
Secondary, Semichem	4
SemiChem	2	6	semichem
Sulfite-Mg	1
Sulfite-NH3	2	3	sulfite
Grand Total	107	107