Burden Calculations

---

Overview

Table 1
Table 2
O&M

---

Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013 (40 CFR Part 60, Subpart BBa) (Renewal)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total cost per year b
1. Applications	N/A									Labor Rates
2. Survey and studies	N/A									Management	$141.06
3. Reporting requirements										Technical	$120.27
A. Familiarize with regulatory requirements c	30	1	30	14	420	21	42	$55,939.80		Clerical	$58.67
B. Required activities
Initial performance tests d	80	1	80	2	160	8	16	$21,310.40
5-year repeat performance tests d, e	80	1	80	2	160	8	16	$21,310.40
Repeated performance tests due to failure d, f	80	0.2	16	0.8	13	0.6	1.3	$1,704.83
C. Gather existing information	See 3B
D. Write report
Notification of construction/reconstruction	2	1	2	2	4	0.2	0.4	$532.76
Notification of performance test f	2	1.2	2.4	4.8	12	0.6	1.2	$1,534.35
Notification of actual startup	2	1	2	2	4	0.2	0.4	$532.76
Notification of CMS demonstration	2	1	2	2	4	0.2	0.4	$532.76
Notification of physical or operational changes	2	1	2	2	4	0.2	0.4	$532.76
Notification of opacity observations	2	1	2	2	4	0.2	0.4	$532.76
Report of performance test (including submittal through EPA's ERT) f, g	4	1.2	4.8	4.8	23	1.2	2.3	$3,068.70
Semiannual report h, i	8	2	16	14	224	11	22	$29,834.56
Excess emissions/monitoring systems report i, j	20	2	40	14	560	28	56	$74,586.40
Malfunction report (affirmative defense) k	30	2	60	0	0	0	0	$0
Subtotal for Reporting Requirements					1,830			$211,953
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system l	40	1	40	2	80	4	8	$10,655.20
E. Time to enter and transmit information
Records of monitoring data m	0.5	365	182.5	14	2,555	128	256	$340,300.45
Records of malfunctions	2	12	24	14	336	17	34	$44,751.84
Subtotal for Recordkeeping Requirements					3,417			$395,707
TOTAL LABOR BURDEN AND COST (rounded) n					5,250			$608,000		69	hrs/response
TOTAL CAPITAL AND O&M COST (rounded) n								$976,000
GRAND TOTAL (rounded) n								$1,580,000
Assumptions:
a We assume an average of 12 existing mills per year will be subject to the rule and that an average of 2 existing mills (that were previously subject to 40 CFR Part 60, Subpart BB) per year will replace aging emission units with new emission units subject to Subpart BBa.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “Table 2. Civilian Workers, by occupational and industry group.” 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.
c We assume that each respondent will have to familiarize with the regulatory requirements each year.
d We assume it will take 80 hours for each respondent to coordinate the performance tests for PM, CPM, opacity and TRS. Testing contractor costs are included in the capital/startup and O&M costs.
e Repeat performance tests are required in 5-year intervals. We assume 2 respondents per year will be required to conduct repeat performance tests.
f We assume that 20 percent of respondents would repeat a performance test due to failure.
g Hard copy report of performance test is included in 3B. Submittal of performance test data through EPA's ERT is estimated to require 4 hours per test.
h Assumes that it will take each respondent 8 hours to complete the semiannual report.
i Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods.
j We assume each respondent will take 20 hours two times per year to review monitoring data (e.g., to document compliance with allowances) and complete the excess emissions report.
k Not applicable.
l Includes time to adjust existing data acquisition systems at modified sources to include startup and shutdown periods and comply with revised monitoring allowances; this is a one-time activity.
m We assume that it will take each respondent 30 minutes per day to document monitoring data (e.g., operating parameters, opacity and TRS monitoring data, CMS performance evaluations, and startup/shutdown).
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013 (40 CFR Part 60, Subpart BBa) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=A×B)	Plants per year a	Technical person- hours per year (E=C×D)	Management person-hours per year (F=E×0.05)	Clerical person-hours per year (G=E×0.1)	Cost b
1. Attend initial performance test c	24	1	24	2	48	2.4	4.8	$2,661.41		Labor Rates
2. Attend 5-year repeat performance test c, d	24	1	24	2	48	2.4	4.8	$2,661.41		Management	$66.62
3. Attend repeat performance test due to failure c, e	24	0.2	4.8	0.8	3.84	0.192	0.384	$212.91		Technical	$49.44
4. Report review										Clerical	$26.75
Review notification of construction/reconstruction	2	1	2	2	4	0.2	0.4	$221.78
Review notification of performance test e	0.5	1.2	0.6	4.8	2.88	0.144	0.288	$159.68
Review notification of actual startup	0.5	1	0.5	2	1	0.05	0.1	$55.45
Review notification of CMS demonstration	0.5	1	0.5	2	1	0.05	0.1	$55.45
Review notification of physical/operational changes	0.5	1	0.5	2	1	0.05	0.1	$55.45
Review notification of opacity observations	0.5	1	0.5	2	1	0.05	0.1	$55.45
Review performance test reports e	8	1.2	9.6	4.8	46	2.3	4.6	$2,554.95
Review semiannual report f, g	4	2	8	14	112	5.6	11	$6,209.95
Review excess emissions/monitoring systems report f, g	8	2	16	14	224	11	22	$12,419.90
TOTAL (rounded)h					567			$27,300
Assumptions:
a We assume an average of 12 existing mills per year will be subject to the rule and that an average of 2 existing mills (that were previously subject to 40 CFR Part 60, Subpart BB) per year will replace aging emission units with new emission units subject to Subpart BBa.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We assume that it will take EPA personnel 24 hours to attend each performance test.
d Repeat performance tests are required in 5-year intervals. We assume 2 respondents per year will be required to conduct repeat performance tests.
e We assume that 20 percent of respondents would repeat a performance test due to failure.
f We assume that it will take EPA personnel 4 hours to review each semiannual report and 8 hours to review each excess emissions report and malfunction report.
g Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods.
h Totals have been rounded to 3 significant figures.

---

Sheet 3: O&M

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	2	1	0	2
Notification of performance test a	4	1.2	0	4.8
Notification of actual startup	2	1	0	2
Notification of CMS demonstration	2	1	0	2
Notification of physical or operational changes	2	1	0	2
Notification of opacity observations	2	1	0	2
Report of performance test (including submittal through EPA's ERT) a	4	1.2	0	4.8
Semiannual report	14	2	0	28
Excess emissions/monitoring systems report	14	2	0	28
			Total	76
a We assume that there are 2 new respondents each year and that 2 existing respondents will have to complete the 5-year repeat performance tests for a total of 4 respondents subject to performance testing per year. We also assume that 20% of respondents will have to repeat a performance test due to failure.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	2	10	0	0	12
2	2	12	0	0	14
3	2	14	0	0	16
Average	2	12	0	0	14
a New respondents include sources with constructed, reconstructed and modified affected facilities.
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/ Startup Cost for One Respondent	Number of New Respondents	Total Capital/ Startup Cost (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M (E X F)
Opacity monitor	$40,000	2	$80,000	$8,600	14	$120,400
TRS monitor	$108,000	2	$216,000	$23,000	14	$322,000
ESP voltage and current monitors	$31,000	2	$62,000	$4,200	14	$58,800
Scrubber pressure drop monitor a	$350	2	$700	$70	14	$980
Scrubber liquid flow rate monitor a	$15,500	2	$31,000	$3,100	14	$43,400
Performance tests:
Initial Method 9 for opacity	$1,000	2	$2,000
Initial Method 5 and 202 for PM and condensable PM (CPM)	$6,800	2	$13,600
Initial Method 16, 16A, 16B or 16C for TRS	$3,000	2	$6,000
Repeat Method 5 and 202 for PM and CPM (every 5 years) b	N/A			$6,800	2	$13,600
Repeat Method 16, 16A, 16B or 16C for TRS (every 5 years) b	N/A			$3,000	2	$6,000
Total c			$411,000			$565,000
a Scrubber monitor O&M costs were estimated as 20 percent of the initial monitor cost.
b Repeat tests are required in 5-year intervals. We assume that 2 respondents per year will be required to conduct repeat performance tests.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.