Burden Calculation Tables

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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
1. Applications	N/A								Tech	$122.66
2. Surveys and studies	N/A								Mgmt	$149.84
3. Reporting requirements									Cler	$60.88
A. Familiarization with the regulatory requirements c	1	1	1	104	104	5.2	10.4	$14,168.96
B. Required activities d
Prepare for initial/periodic performance test	24	1	24	25	600	30	60	$71,559
Attend initial/periodic performance test	24	2	48	25	1,200	60	120	$163,488.00
Prepare for retest	24	1	24	5	120	6	12	$16,348.80
Attend retest	24	2	48	5	240	12	24	$32,697.60
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports									Hours per Response
Notifications e, f, g									117000	# hours
Notification of construction/reconstruction	2	1	2	1	2	0.10	0.20	$272.48	338	# responses
Notification of actual startup	2	1	2	1	2	0.10	0.20	$272.48	346	hr/resp
Notification of applicability of standard	2	1	2	1	2	0.10	0.20	$272.48
Notification of compliance status	80	1	80	1	80	4.00	8.00	$10,899.20
Notification of performance test/retest	2	1	2	42	84	4.2	8.4	$11,444.16
Notification of performance evaluation	2	1	2	42	84	4.2	8.4	$11,444.16
Report of performance test/retest (through CEDRI using ERT) h	8	1	8	42	336	16.8	33.6	$45,776.64
Excess emissions report (through CEDRI) i
Semiannual reports of monitoring exceedances and periods of noncompliance	16	2	32	5	160	8	16	$21,798.40
Semiannual reports of no exceedances	8	2	16	99	1,584	79.2	158.4	$215,804.16
Subtotal for Reporting Requirements					5,288			$616,247
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	40	2	4.00	$5,449.60
E. Time to enter information
Records and documentation of supporting calculations for compliance determinations k	8	1	8	42	336	17	33.6	$45,806.61
Record of compliant monitoring parameter ranges	2	1	2	42	84	4.3	8.4	$11,459.14
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	$267.98
Records demonstrating compliance with requirement to maintain proper operation of ESP’s AVC m	8	2	16	178	2,848	146	284.8	$388,550.94
Records of failures to meet standards n	2	12	24	5	120	6	12	$16,348.80
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	$1,105,238.82
Records of lime production for lime kilns p	1.5	52	78	95	7,410	382	741	$1,011,261.56
Records of CMS data q	0.5	1,050	525	104	54,600	2,809	5460	$7,450,541.36
F. Time to train personnel
Initial training r	40	1	40	1	40	2	4.00	$5,449.60
Refresher training s	16	1	16	104	1,664	86	166.4	$227,122.91
G. Time to adjust existing ways to comply with previously applicable requirements t	17.8	1	17.8	0	0	144	0	$21,576.96
H. Time to transmit or disclose information
Compile data for semiannual periods u	96	2	192	104	19,968	1,027	1996.8	$2,724,725.74
Enter/verify information for semiannual reports v	8	2	16	104	1,664	86	166.40	$227,122.91
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					111,694			$13,240,923
TOTAL LABOR BURDEN AND COSTS (rounded) w					117,000			$13,900,000
TOTAL CAPITAL AND O&M COST (rounded) w								$788,000
GRAND TOTAL (rounded) w								$14,700,000
a We estimate that the number of existing sources subject to the rule is 104 pulp mills. 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 104 pulp mills per year and new source requirements for an average of 1 pulp mills per year.
b This ICR uses the following labor rates: $149.84 per hour for Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, 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 will need to conduct a test (the rest of the 104 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 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).
h We estimate that 5% of respondents (5% x 104 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 104 respondents = 99) will each take 8 hours two times per year to write reports of no exceedances and submit them through the EPA's CEDRI.
i We estimate that it will take one respondent 40 hours to develop a record system to comply with monitoring requirements.
j 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 42 mills (see footnote g) will enter this information (includes initial test and retest, for mills required to retest).
k We estimate that 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 (2 mills/3 years= 0.67, or 1, rounded). 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.
l 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 178 recovery furnace and lime kiln ESPs.									<--Note for EPA: Adjusting number of existing ESPs downwards based on decrease in sources (183 ESPs/107 sources * 104 = 178)
m We estimate that 5% of respondents (5% x 104 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.
n 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.
o We estimate 95 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.									<--Note for EPA: Adjusting to 95 based on GHGRP data (see "Count of Respondents" tab).
p 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 104 mills.
q We estimate that it will take the respondent 40 hours (1 week) once per year for initial training of personnel with new sources (3 new respondents/3 years) = 1).
r We estimate that it will take each respondent 16 hours to provide refresher training each year for personnel at all 104 existing mills.
s 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 January 1, 2022 through December 31, 2024, and assumes that existing sources are no longer performing this one-time implementation activity.
t We estimate that each respondent will take 96 hours per semiannual period to compile data for all 104 mills.
u We estimate that each respondent will take 8 hours two times per year to verify information for reports for all 104 mills.
v 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
1. Attend initial/periodic performance test c	24	1	24	3.5	84	4.2	8.4	$4,826.22
2. Attend retest c,d	24	1	24	0.7	16.8	0.84	1.68	$965.24		Tech	$51.23
3. Report review										Mgmt	$69.04
Notification of construction/reconstruction e	2	1	2	1	2.00	0.10	0.20	$114.91		Cler	$27.73
Notification of actual startup e	2	1	2	1	2.00	0.10	0.20	$114.91
Notification of applicability of standard e	2	1	2	1	2.00	0.10	0.20	$114.91
Notification of initial/periodic performance test f	2	1	2	42	84	4.2	8.4	$4,826.22
Notification of performance evaluation f	2	1	2	42	84	4.2	8.4	$4,826.22
Review of notification of compliance status e	4	1	4	1	4.00	0.20	0.40	$229.82
Review of excess emissions report
Semiannual reports of monitoring exceedances and periods of noncompliance g	8	2	16	5	80	4	8	$4,596.40
Semiannual reports of no exceedances h	2	2	4	99	396	19.8	39.6	$22,752.18
Subtotal for Burden and Cost - Salary					868			$43,367
Travel Expenses for Tests Attended i								$1,890
TOTAL ANNUAL BURDEN AND COST j								$45,300
a We estimate that the number of existing sources subject to the rule is 104 pulp mills. 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 104 pulp mills per year and new source requirements for an average of 1 pulp mills per year.
b This cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 Managerial rate (GS-13, Step 5, $43.15 x 1.6), $51.23 Technical rate (GS-12, Step 1, $32.02 x 1.6), and $27.73 Clerical rate (GS-6, Step 3, $17.33 x 1.6). These rates are from the Office of Personnel Management (OPM) 2021 General Schedule which excludes locality rates of pay.
c Assume EPA will attend tests at 3.5 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 104/3 years = 3.5), assuming 104 existing plants 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 104/3 years = 0.7), assuming 104 existing plants 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 (3 mills with new process units/3 years = 1).
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 42 mills will submit notifications of initial/periodic performance test/retest and performance evaluation over the 3-year ICR period (test: 104 existing respondents/3 years = 35; retest: 20% x 35 = 7; total: 35 + 7 = 42).
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 104 = 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 104 = 99).
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 (3.5 tests + 0.7 retests = 4.2)(see footnotes c and d), the annual cost for travel expenses is $1,890 (4.2 tests/retests*($400+$50) = $1,890).
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	254	$619,482
Method 25A for THC	$3,414	5	$17,072
Method 308 for methanol	$3,414	6	$20,487
Retests a			$131,408
Total annualized capital/startup cost b			$788,000
a We estimate that 20% of respondents will repeat the performance test due to failure. Estimate assumes 104 existing facilities with 254 sources, 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
				E=(BxC)+D
Notification of construction/ reconstruction	1	1	0	1
Notification of actual startup	1	1	0	1
Notification of applicability of standard	1	1	0	1
Notification of performance test/ retest	42	1	0	42
Notification of performance evaluation	42	1	0	42
Notification of compliance status	1	1	0	1
Report of performance test/retest	42	1	0	42
Semiannual report of monitoring exceedances and periods of noncompliance	5	2	0	10
Semiannual report of no exceedances	99	2	0	198
			Total	338

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Sheet 5: Count of Respondents

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	104	0	1	104
2	1	104	0	1	104
3	1	104	0	1	104
Average	1	104	0	1	104
Count of Existing Pulp Mills
Mill Type	Count of Existing Pulp Mills
Kraft	62
Kraft, Mechanical	4
Kraft, Mechanical, Secondary	2
Kraft, Secondary	17
Kraft, Secondary, SemiChem	5
Kraft, SemiChem	3
Kraft, Sulfite-Na	1
Soda	1	95	kraft/soda
Secondary, Semichem	4
SemiChem	2	6	semichem
Sulfite-Mg	1
Sulfite-NH3	2	3	sulfite
Grand Total	104	104