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Effluent Guidelines

Pulp and Paper Rulemaking Actions

Information Collection Request Supporting Statement for Best Management Practices for the Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of the Pulp, Paper, and Paperboard Point Source Category *40 CFR Part 430)

December 1, 1998

U.S. Environmental Protection Agency
Office of Water
Engineering and Analysis Division
401 M Street, S.W.
Washington, D.C. 20460

TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

2. NEED FOR AND USE OF THE COLLECTION

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

LIST OF TABLES

Table 1. Summary of Mill Status

Table 2. Consultant Burden and Costs for Development, Review and Certification of BMP Plan

Table 3. Mill Burden and Costs for Development, Review and Certification of BMP Plan

Table 4. Initial Mill Respondent Burden and Costs

Table 5. Mill Labor for Amendment and Review of BMP Plan, Reporting, Monitoring, Recordkeeping and Training

Table 6. Mill Costs for Amendment and Review of BMP Plan, Reporting, Monitoring, Recordkeeping and Training

Table 7. Recurring Respondent Burden and Costs

Table 8. Summary of Burden and Costs to Respondents and Government

Table 9. Bottom Line Initial Burden and Costs Based in 1998 Dollars

Table 10. Bottom Line Recurring Burden and Costs Based in 1998 Dollars

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1. IDENTIFICATION OF THE INFORMATION COLLECTION

ICR: Best Management Practices for the Bleached Papergrade Kraft and Soda Subcategory and the Papergrade Sulfite Subcategory of the Pulp, Paper, and Paperboard Point Source Category (EPA ICR No. 1829.01).

This Information Collection Request (ICR) presents estimates of the burden and costs to the regulated community (approximately 95 bleached papergrade kraft, soda and sulfite mills) and NPDES permit and pretreatment control authorities for data collection and recordkeeping associated with implementation of the Best Management Practices requirements of the Pulp and Paper Effluent Limitations Guidelines and Standards (40 CFR Part 430.03). This is a new ICR.

The Clean Water Act (CWA) authorizes the Environmental Protection Agency (EPA) to include Best Management Practices (BMPs) in effluent limitations guidelines and standards regulations. EPA's legal authority to promulgate BMPs is found in Section 304(e), Section 307(b) and (c), Section 308(a), Section 402(a)(1)(B) and Section 501(a) of the Clean Water Act, 33 U.S.C. §1251, et. seq. EPA also relies on 40 CFR 122.44(k). The BMP regulation is consistent with the Pollution Prevention Act of 1990, 42 U.S.C. § 13101, et. seq.

The objectives of the BMPs are to prevent leaks and spills of spent pulping liquors, soap and turpentine for mils in bleached papergrade kraft and soda (Subpart B) and papergrade sulfite (Subpart E) subcategories; and, to contain, collect and recover at the immediate process area, or otherwise control, those leaks, spills and intentional diversions of spent pulping liquor that do occur. EPA has emphasized control of spent pulping liquors, intentional liquor diversions, soap and turpentine for the following reasons: (1) losses of spent pulping liquor contribute significant portions of untreated wastewater loadings and discharge loadings of color, oxygen-demanding substances, and non-chlorinated toxic compounds from chemical pulp mills; (2) spent pulping liquor spills and intentional liquor diversions are a principal cause of upsets and loss of efficiency of biological treatment systems that are used for treatment of Subpart B and E mill wastewaters, thus contributing to increased effluent discharges of toxic, conventional and nonconventional pollutants; (3) soap and turpentine are substances that are highly toxic to biological treatment systems; and (4) control of spent pulping liquors is a form of pollution prevention that can result in cost savings, less demand for make-up pulping chemicals, increased energy efficiency, more effective wastewater treatment and incidental reductions in atmospheric emissions of total reduced sulfur (TRS) compounds from kraft mills and volatile hazardous air pollutants from Subpart B and E mills.

The regulation requires that owners or operators of Subpart B and E mills prepare and implement site-specific BMPs for management of spent pulping liquors and prevent and control losses of soap and turpentine. In addition, the regulation requires mills to monitor the effectiveness of BMP implementation on a continuing basis by tracking the influent-to-treatment wastewater loading. EPA has structured the BMP regulation to provide maximum flexibility to the regulated community and to minimize administrative burdens on NPDES permit and pretreatment control authorities that regulate Subpart B and E mills. In fact, the final BMP regulation provides flexibility for mill owners or operators to select any reasonable measure of organic loading and/or spent pulping liquor losses to monitor the effectiveness of BMPs. Also, the final regulation is less prescriptive than the proposed rule with regard to inspection, repair and log-keeping requirements. EPA determined that the final rule language allows mills to use existing maintenance and repair tracking systems to fulfill the aforementioned requirements thereby reducing burden to the industry. By promulgating a national regulation for BMPs, EPA has effectively removed substantial administrative and technical burdens on NPDES and pretreatment control authorities to devise and implement these requirements on a case-by-case basis through their permit programs.

In summary, implementation of effective BMPs has been shown to provide a potential significant payback to a mill. In one incident at an indirect-discharging kraft mill in the southeastern U.S. in July 1993, a process upset caused a release of excess spent pulping liquor to the POTW, which then caused a fish kill. The resulting costs for cleanup and mill shutdown were approximately equal to the cost of full implementation of BMPs at the mill.

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2. NEED FOR AND USE OF THE COLLECTION

In the BMP regulation, EPA is requiring mills with pulp production Subpart B and E Subcategories to develop and implement BMPs to prevent or otherwise contain leaks and spills and to control intentional diversions of spent pulping liquor, soap and turpentine. These BMPs apply to direct and indirect discharging mills within these subcategories and are intended to reduce wastewater loadings of color, oxygen-demanding substances, and non-chlorinated toxic compounds and hazardous substances in mill wastewater, with incidental reductions in conventional water pollutants and certain air pollutants.

EPA's legal authority to promulgate this BMP regulation is found in Section 304(e), Section 307(b) and (c), Section 308(a), Section 402(a)(1)(B), Section 402(a)(2) and Section 501(a) of the Clean Water Act, 33 U.S.C. § 1251, et seq. EPA also relies on 40 CFR § 122.44(k). This BMP regulation is also consistent with the Pollution Prevention Act of 1990, 42 U.S.C. § 13101, et seq. For further discussion of EPA's legal authority to require mills to develop and implement BMPs, including the information collection requirements discussed in this document, see the BMP Technical Support Document (BMP TSD, DCN 14489).

The primary users of the information generated through BMP Plans will be the owners and operators of the Subpart B and E pulp and paper mills. EPA intends that the data collected (in the form of BMP monitoring reports) will be used by mill operators to track the effectiveness and progress of BMP implementation through comparisons with action levels established by the mill. Under the regulation, whenever monitoring results exceed action levels for particular periods, the mill must complete an investigation or corrective action, as appropriate.

EPA also expects that the monitoring reports required by the BMP regulations will be used by NPDES and pretreatment control authorities to determine compliance with the regulation. EPA anticipates that state and local control authorities will conduct detailed technical reviews of BMP Plans only in the event the monitoring reports indicate noncompliance with BMP conditions contained in the mill's NPDES permit or pretreatment control mechanism.

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3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

EPA has examined all other reporting requirements contained in the Clean Water Act and 40 CFR Parts 122, 123, 124, 125, 501, and 503. The Agency also has consulted the following sources of information to determine if similar or duplicative information is available elsewhere:

Examination of these databases revealed no duplicative reporting requirements.

EPA has examined a similar reporting requirement for notice of spills under the Resource Conservation and Recovery Act (RCRA) for duplication of the requirements of this regulation. The requirements for reporting of pollutant releases under RCRA is different than reporting of spills or losses of spent pulping liquor, soap or turpentine outside the immediate process areas under this regulation. EPA has concluded that there is no other way to obtain the compliance assessment information addressed in this ICR.

EPA solicited comments on this ICR prior formal submission to OMB. EPA published a notice in the Federal Register on April 15, 1998 (63 FR 18399-18401). EPA received no comments.

EPA had extensive discussions with the regulated community and selected federal and state NPDES permitting authorities regarding development of this regulation and the attendant recordkeeping and reporting requirements. As mentioned above, EPA received no comments on the ICR.

The regulation requires collection of daily influent-to-treatment data. Most mill operators collect such data independent of this requirement for purposes of monitoring and optimizing wastewater treatment plant operations. Because spill, leaks and losses of spent pulping liquors can and do occur frequently and at any time, less frequent monitoring would not provide the timely information to mill operators to identify and respond to a spill, leak or loss event.

This information collection is consistent with OMB guidelines contained in 5 CFR 1320.6 and 1320.12.

EPA does not expect that confidential business information or trade secrets will be required from mill operators as part of this ICR. In the event that the information submitted in conjunction with this ICR is claimed to be confidential business information (CBI) by the mill owner or operator, the information would then be handled pursuant to 40 CFR Part 2 when EPA is the permitting authority and applicable state and local government rules and regulations governing CBI when states or local governments are the permitting or pretreatment control authorities. Any mills that may consider asserting CBI claims should do so carefully as they may be asked to support any such claims at a later date.

The reporting requirements addressed in this ICR do not include sensitive questions.

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4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents for this ICR will be approximately 95 direct and indirect discharging Subpart B and E pulp mills in the Pulp, Paper and Paperboard Manufacturing Category (SIC 2611, 2631). Government respondents are estimated to be 35 State and local authorities (approximately 26 State governments for direct discharging mills and 9 local governments for indirect discharging mills) for preparation of new NPDES permits and pretreatment conditions for implementing the BMP regulation and conducting detailed technical reviews of BMP Plans in the event the monitoring reports indicate noncompliance with BMP conditions contained in the mill's NPDES permit or pretreatment control mechanism.

The BMP regulations at 40 CFR 430.03 include the following major components:

(1) development, review and certification of a BMP plan; (2) amendment and periodic review of the BMP plan; (3) reporting of spills; (4) additional monitoring and reporting; and (5) additional recordkeeping. See 40 CFR 430.03(c) through (i) and the BMP TSD for more detailed information on the requirements.

Central to the BMP regulation is the development of a BMP plan. This plan is intended to be the initial and ongoing BMP planning and implementation tool for mills. The BMP plan must, at a minimum, include programs: (a) to identify and repair leaking equipment; (b) to track equipment repairs; (c) to train personnel; (d) to report and evaluate spills; (e) to review planned mill modifications; and (f) to establish wastewater treatment system influent action levels (including an initial six-month monitoring program)

Also, as part of the BMP plan development, each mill must conduct a detailed engineering review of the pulping and chemical recovery areas to determine the magnitude and routing of potential leaks, spills, and intentional diversions of spent pulping liquors, soap and turpentine and to determine the adequacy of containment and collection facilities (see 40 CFR 430.03 (d) (3) for additional details). The BMP plan and any amendments require review by the senior technical manager and certification by the mill manager.

Owners or operators must amend their BMP Plans whenever there is a change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, soap or turpentine from the immediate process areas. Notwithstanding this requirement, owners or operators must complete a review and evaluation of their BMP Plans at least once every five years and amend the plan within three months of such review, if warranted. As mentioned above, any BMP plan amendments require review by the senior technical manager and certification by the mill manager.

Owners or operators are required to prepare brief reports of spills of spent pulping liquor, soap or turpentine not contained in the immediate process area (e.g., a failure of the management practices and control systems identified by the owner or operator in the BMP Plan). The report must list the equipment items involved, the circumstances leading to the incident, the effectiveness of corrective actions taken and plans to implement future changes. These reports must be maintained by the mill owner or operator for three years and they need only be submitted to the NPDES permit or pretreatment control authority upon request.

Mills are required to operate continuous, automatic monitoring systems that the mill determines are necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine. See 40 CFR 430.03(c)(3). As part of this requirement, all mills (with the exception of new sources) are required to perform two six-month monitoring programs in order to determine the characteristics (or action levels) of their wastewater treatment system influent. See 40 CFR 430.03(h). (New sources are required to perform only one six-month monitoring program for this purpose. See 40 CFR 430.03(h)(5).) All mills are also required to perform additional monitoring to revise those action levels after any change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills or spent pulping liquor, soap, or turpentine from the immediate process area. See 40 CFR 430.03(h)(6). The regulation also requires all mills to conduct daily monitoring of wastewater treatment system influent for the purpose of detecting leaks and spills, tracking the effectiveness of the BMPs, and detecting trends in spent pulping liquor losses. See 40 CFR 430.03(i).

Mill operators are required to provide their NPDES permit or pretreatment control authorities reports of the monitoring required by the BMP regulation. See 40 CFR 430.03(i)(4). The reports must include a summary of the monitoring results, the number and dates of exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to respond to such exceedances. Submission of such reports shall be at the frequency established by the NPDES permit or pretreatment control authority, but in no case less than once per year.

The regulation requires that certain equipment repair records, records of employee training, reports of spills outside the immediate process area, and records of monitoring conducted as part of the BMP program be maintained for three years.

Mill respondent activities include the following:

State permitting and local pretreatment control authority activities include the following:

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5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

Upon approval of this ICR, permittees must maintain records as described above in Section 4(c) and at least annually, must submit to the NPDES or pretreatment control authority a report summarzing the results of daily monitoring, the number and dates of any exceedances of action levels and corrective actions taken when action levels are exceeded. The permitting authority can be either an approved NPDES State or one of EPA's regional offices. The permitting authority or pretreatment control authority is authorized to conduct compliance audits of facility records, review the data, and where necessary, conduct follow-up actions. Follow-up activities may include informal contact with the permittee (by telephone or letter) to discuss the cause of any exceedances of action levels and responses taken to correct the exceedences. Because the requirements to implement the BMPs and maintain records will be incorporated in a mill's NPDES permit or pretreatment control mechanism as enforeceable conditions, the permitting authority will be responsible for assessing whether the mill is properly maintaining records (including the BMP Plan) and thus, performing equipment repairs, employee training and responding to any exceedance events in a timely manner. Review of monitoring records may also be helpful to the permit writers in the development of future NPDES permit conditions.

The extent to which EPA reviews data will depend on available resources and the specific reviewing procedures of the permitting authority (State or EPA region). In NPDES States, State environmental agencies generally review permittee data. EPA regions may also review data from major permittees in NPDES States while performing program oversight functions, particularly since the assessment of compliance is subjective.

As with the minimum effluent monitoring requirements associated with the Cluster Rule, mill owners and operators are required to maintain information for in-mill use to assess BMP effectiveness and for preparation of the summary report of daily monitoring. The regulation provides a framework for compliance, but mill owner and operators can develop the necessary data collection and management protocols to achieve an effective BMP program. EPA expects that mill owners and operators will most likely use existing in-mill and effluent monitoring capabilities to perform the daily monitoring and existing computer capabilities to develop and maintain records.

EPA has certified that the Cluster Rules, including the BMP requirements will not have a significant economic impact on a substantial number of small entities. Only four mills are considered "a small business concern" as defined by SBA regulations. EPA does not believe this is a substantial number of small entities as that term is used in the RFA (see Section X.C. of the Preamble to the final Cluster Rules published in the Federal Register on April 15,1998 (see 63 FR 18611).

The majority of information collection activities included in this ICR are anticipated to coincide with existing monitoring, recordkeeping, and reporting requirements (e.g., Discharge Monitoring Reports), although some recordkeeping may be non-routine, such as spill reporting. For all Subpart B and E mills except new sources, the timeframes for preparing the BMP Plan and associated BMP records are outlined below. It should be noted that no burden was estimated for new sources or in this case, new mills, as EPA does not expect any new Subpart B or E mills to emerge. If a deadline outlined below has passed at the time an existing direct discharging mill receives its NPDES permiting containing the corresponding BMP requirement, the NPDES permit must require immediate compliance with the BMP requirement. Thus, depending upon the timing of NPDES permit issuance, the deadline for complying with some of these provisions might actually be later than the dates specified below.

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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 4 and 7 present estimates of the initial and recurring mill respondent burdens (respectively) for labor hours and costs associated with this ICR. The assumptions made are listed in each Table. A summary of the mill respondents' burden hours and costs is presented in Table 8. A brief description of the basis for the burden estimates is presented below.

Development of a site-specific BMP plan is a one-time initial burden. Plan preparation costs will vary based upon mill complexity, see Table 1. EPA anticipates that mills will use outside consultants under direction of mill personnel to prepare the site-specific BMP plan, including the detailed engineering review, and establish a training program for technical personnel. Labor costs for preparing the BMP Plan and establishing a training program are estimated to be 2100 for simple mills, 2,800 for moderately complex mills, and 3,500 hours for complex mills. Seventy-five perent of these estimated hours are anticipated to be performed by consulting engineers (at $65 per hour), with the remaining 25 percent to be performed by consulting management (at $100 per hour). EPA anticipates mill labor burden of 40, 60, and 80 hours (at $65 per hour for process engineering time) for direction and oversight of the consultant effort for simple, moderately complex, and complex mills, respectively. Review of the initial plan by the senior technical manager and certification by the mill manager is expected to take one day of effort (at $100 per hour for senior management time). These one-time burden estimates associated with the BMP plan are summarized in Tables 2 and 3.

As part of the BMP plan development, mills must establish a training program for technical personnel. This training program must include both an initial training effort and refresher training, which at a minimum, must be performed annually. The burden for initial training is included in the above consultant effort for preparing the site-specific BMP plan and detailed engineering review. The refresher training is based on bi-annual effort of four hours each, including nine operators and one consultant acting as trainer. The total burden for refresher training per mill is estimated to be 72 hours of operator effort and eight hours of consultant effort.

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Tables

Table 1. Summary of Mill Status

CATEGORY Simple Moderately Complex Complex Total
Kraft & Soda 41 30 13 84
Sulfite 11 0 0 11
Total Mills 52 30 13 95

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Table 2. Consultant Burden and Costs for Development, Review and Certification of BMP Plan

Subcategory

Labor Hours

Labor Costs
Engineering Management Total Engineering Management Total
Kraft & Soda
Simple 64,575 21,525 86,100 $4,100,000 $2,050,000 $6,150,000
Moderately Complex 63,000 21,000 84,000 $3,900,000 $2,100,000 $6,000,000
Complex 34,125 11,375 45,500 $2,210,000 $1,040,000 $3,250,000
Total Kraft & Soda 161,700 53,900 215,600 $10,210,000 $5,190,000 $15,400,000
Sulfite
Simple 17,325 5,775 23,100 $1,100,000 $550,000 $1,650,000
Total Sulfite 17,325 5,775 23,100 $1,100,000 $550,000 $1,650,000
TOTAL MILLS 179,025 59,675 238,700 $11,310,000 $5,740,000 $17,050,000

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Table 3. Mill Burden and Costs for Development, Review and Certification of BMP Plan1

Subcategory

Labor Hours

Labor Costs
Engineering Management Total Engineering Management Total
Kraft & Soda
Simple 1,640 328 1,968 $106,600 $32,800 $139,400
Moderately Complex 1,800 240 2,040 $117,000 $24,000 $141,000
Complex 1,040 104 1,144 $67,600 $10,400 $78,000
Total Kraft & Soda 4,480 672 5,152 $291,200 $67,200 $358,400
Sulfite
Simple 440 88 528 $28,600 $8,800 $37,400
Total Sulfite 440 88 528 $28,600 $8,800 $37,400
TOTAL MILLS 4,920 760 5,680 $319,800 $76,000 $395,800

1EPA assumes that mills will use outside consultants to prepare the BMP plan and that burden presented here includes oversight of the consultant, review and certification of the plan.

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Table 4. Initial Mill Respondent Burden and Costs

Subcategory Labor Hoursa Labor Costsa Capital Costsb Total Initial Costs
Kraft & Soda
Simple 88,068 $6,289,400 $6,150,000 $ 12,439,400
Moderately Complex 86,040 $6,141,000 $7,500,000 $ 13,641,000
Complex 46,644 $3,328,000 $4,550,000 $ 7,878,000
Total Kraft & Soda 220,752 $15,758,400 $18,200,000 $ 33,958,400
Sulfite
Simple 23,628 $1,687,400 $1,650,000 $ 3,337,400
Total Sulfite 23,628 $1,687,400 $1,650,000 $ 3,337,400
TOTAL MILLS 244,380 $17,445,800 $19,850,000 $ 37,295,800

a includes consultant hours and costs outlined in Table 2 and mill hours and costs outlined in Table 3.

b see section (4) below.

(2) Amendment and periodic review of a BMP Plan:

EPA anticipates less than 50 hours of mill labor per amendment and has based the ICR burden on an assumption that each mill would need to amend its BMP plan twice every five years for an annual burden of 20 hours, estimating 18 hours of process engineering time and two hours of senior management time, which is included in the annual estimates presented in Tables 5 and 6.

(3) Reporting of spills:

EPA anticipates that the burden of preparing a spill report is approximately four hours and can be conducted by a mill engineer at $65 per hour. ICR burden is calculated on an annual basis using an assumption of one spill per mill per month and is included in the annual estimates presented in Table 5 and 6.

(4) Additional monitoring and reporting:

Mills are required to operate continuous, automatic monitoring systems that the mills determine are necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine. The burden for designing, testing, and operating the monitoring system, expressed in the form of costs, is included in the compliance cost estimates developed for the regulation (see Table 9.2 of the BMP TSD, DCN 14489).

In addition, all mills with the exception of new sources are required to perform two six-month monitoring programs in order to determine the characteristics (or action levels) of their wastewater treatment system effluent. See 40 CFR 430.03(h). (New sources are required to perform only one six-month monitoring program for this purpose.) All mills are also required to perform additional monitoring to revise those action levels after any change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills or spent pulping liquor, soap, or turpentine from the immediate process area. The effort required to implement the initial monitoring program and perform the associated statistical analysis to establish the action levels is included in the compliance cost estimates developed for the regulation, and the burden to perform monitoring to revise those action levels is included in the incremental monitoring burden discussed below.

The regulation also requires all mills to conduct daily monitoring of wastewater treatment system influent for the purpose of detecting leaks and spills, tracking the effectiveness of the BMPs, and detecting trends in spent pulping liquor losses. EPA estimates the burden associated with this monitoring to be an increment of one additional hour per day (at $20 per hour of operator time) over existing burden imposed by minimum monitoring; this increment is included in the annual estimates shown in Tables 5 and 6. Costs for monitoring equipment are included as capital costs and are estimated to be $150,000, $250,000 and $350,000 for simple, moderately complex and complex mills, respectively. These capital costs for Sewer Conductivity Monitoring Equipment and Storage Tank Alarms are reflected in Table 4.

Mill operators are required to provide their NPDES permit or pretreatment control authorities reports of the monitoring required by the BMP regulation. Submission of such reports shall be at the frequency established by the NPDES permit or pretreatment control authority, but in no case less than once per year. EPA has based the burden estimates on a semi-annual reporting frequency and estimates that each report will take 16 hours to complete, based on 14 hours of engineer effort and two hours of senior technical manager effort (also included in estimates presented in Tables 5 and 6).

(5) Recordkeeping requirements:

Burden estimates for recordkeeping are based on an incremental level of effort to comply with BMP requirements consisting of two to four hours per month for the operators/shift supervisors over current shift log recordkeeping (at $20 per hour), two to four hours per months for mill engineers (at $65 per hour), and two hours per month for clerical support (at $15 per hour). These burden estimates are also included in the annual estimates presented in Tables 5 and 6 .

(6) NPDES permit provisions, pretreatment conditions and periodic review

EPA estimates the initial burden to state NPDES permitting and pretreatment control authorities at ten hours per facility for preparation of NPDES permit provisions and pretreatment conditions for implementing the BMP regulation and an incremental ten hours per year per facility for reviewing periodic (e.g., annual or semi-annual) monitoring reports and conducting compliance reviews.

To estimate associated costs, EPA used labor rates were based on the U.S. Labor Department figures, whereby the average annual salary for state and local employees is $41,185; this is equivalent to the salary of a GS-9, Step 10 Federal employee. At 2,080 available labor hours per year, the hourly rate is $19.80. Overhead costs for state and local employees are estimated by EPA to be 60 percent (EPA ICR Handbook), or $11.88 per hour, which results in a total hourly rate of $31.68 ($19.80 + $11.88). Using this hourly rate, the initial cost to state permitting and pretreatment control authorities is about $317 per facility for a total of $30,100 for 95 mills; total recurring costs to these authorities are estimated at $30,100 (see Table 8 for a summary of burden and costs).

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Table 5. Mill Labor for Amendment and Review of BMP Plan, Reporting, Monitoring, Recordkeeping and Training (hours)

Item

 Kraft & Soda Sulfite TOTAL

HOURS

Simple

 Moderately

Complex

 Complex Total Simple Total
Amendment and Review of BMP Plan 820 600 260 1,680 220 220 1,900
Reporting of Spills 1,968 1,440 624 4,032 528 528 4,560
Additional Monitoring and Reporting 16,277 11,910 5,161 33,348 4,367 4,367 37,715
Recordkeeping 2,952 2,880 1,560 7,392 792 792 8,184
Refresher Training 3,280 2,400 1,040 6,720 880 880 7,600
TOTAL 59,959


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Table 6. Mill Costs for Amendment and Review of BMP Plan, Reporting, Monitoring, Recordkeeping and Training

Item

 Kraft & Soda Sulfite

TOTAL

COSTS
Simple Moderately

Complex

 Complex Total Simple Total
Amendment and Review of BMP Plan $56,170 $41,100 $17,810 $115,080 $15,070 $15,070 $130,150
Reporting of Spills $127,920 $93,600 $40,560 $262,080 $34,320 $34,320 $296,400
Additional Monitoring and Reporting $390,320 $285,600 $123,760 $799,680 $104,720 $104,720 $904,400
Recordkeeping $98,400 $108,000 $57,720 $264,120 $26,400 $26,400 $290,520
Refresher Training $80,360 $58,800 $25,480 $164,640 $21,560 $21,560 $186,200
TOTAL $1,807,670


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Table 7. Recurring Mill Respondent Burden and Costs

Status Total Labor Hours Total Recurring Costs
Kraft & Soda
Simple 25,297 $ 753,170
Moderately Complex 19,230 $ 587,100
Complex 8,645 $ 265,330
Total Kraft & Soda 53,172 $ 1,605,600
Sulfite
Simple 6,787 $ 202,070
Total Sulfite 6,787 $ 202,070
TOTAL MILLS 59,959 $ 1,807,670

6(b) Estimating Agency Burden

EPA estimates its initial burden to be one hour per facility for a total of 95 hours and an incremental labor burden of approximately eight hours per facility for a total of 760 hours annually for the BMP regulation. This burden accounts for anticipated support of state and local authority efforts described in Section 6(a). Using the hourly labor rate of $31.68 developed in see Section 6(a)(6), initial and recurring Agency costs are estimated at $3,000 and $24,100, respectively. A summary of the Agency burden hours and costs is presented in Table 8.

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Table 8. Summary of Burden and Costs to Respondents and EPA

Category

Total Labor Hours

Total Costs
Respondents - Initial Burden

Kraft & Soda Mills

Sulfite Mills

Total

Respondents - Annual Burden

Kraft & Soda Mills

Sulfite Mills

Total

Respondents - Capital Costs1

Kraft & Soda Mills

Sulfite Mills

Total

220,752

23,628

244,380

53,172

6,787

59,959

-----------

-----------

-----------

$ 15,758,400

$ 1,687,400

$ 17,445,800

$ 1,605,600

$ 202,070

$ 1,807,670

$ 18,200,000

$ 1,650,000

$ 19,850,000
Respondents - State & Local Governments

Initial Burden

Annual Burden

950

950

$ 30,100

$ 30,100
EPA

Initial Burden

Annual Burden

95

760

$ 3,000

$ 24,100


1Assumes installation of capital equipment and infrastructure within three years of publication of the Cluster Rules or April 16, 2001 as specified in 40 CFR 430.03(j)(1)(v).

6(c) Bottom Line Burden and Costs Tables

The bottom line burden hours and cost tables for respondents are the summaries of all the hours and costs incurred for all activities.

(1) Respondent Tally

The bottom line respondent (mills, state permitting and local pretreatment authorities) tally is presented in Table 9. The estimates for total hours and costs per year represent on the initial respondent burden and cost plus the sum of the twice the annual burden cost, respectively, divided over a three-year period. Total annualized capital costs for mills was estimated using the formula for Annualized Net Present Value with a discount rate of 4.75%. EPA does not expect state and local authorities to incur capital and O&M costs for this effort.



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Table 9. Total Estimated Respondent Burden and Cost Summary (1998 Dollars)
Category Number of Respondents

 Total Hours Per Year Total Labor Cost Per Year Total Annualized Capital Costs Total Annual O & M Costs
Respondents - Subpart B

and E mills

 95 121,433 $7,020,400 $7,255,000 $0
Respondents - State and local authorities

 35 950 $ 30,100 $0 $0
Total Respondents 130 122,383 $7,050,500 $7,255,000 $0

(2) Agency Tally

The bottom line Agency tally is presented in Table 10.

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Table 10. Total Estimated Agency Burden and Cost Summary (1998 Dollars)
Category Total Hours Per Year Total Labor Cost Per Year Total Annualized Capital Costs Total Annual O & M Costs
Agency 538 $17,000 $0 $0




6(d) Reasons for Changes in Burden

As this is a new information collection, there is no change in burden for this collection.

6(e) Burden Statement

The initial burden for a mill to prepare and certify an initial BMP plan and establish a training program for technical personnel is estimated to be 2,100, 2,800 and 3,500 hours of consultant effort and approximately 48, 68 and 88 hours of mill engineer oversight and senior management effort per respondent for simple, moderately complex and complex mills, respectively. This is a one-time burden. The recurring burden for a mill to periodically review and amend the BMP plan, prepare spill reports, perform additional monitoring, hold refresher training, and conduct recordkeeping and reporting is estimated to be 617, 641 and 665 hours annually per mill for simple, moderately complex and complex mills, respectively.

The initial burden to state NPDES and pretreatment control authorities is estimated at ten hours per mill for preparation of new NPDES permit and pretreatment conditions implementing the BMP regulation and an incremental ten hours per year per facility for reviewing periodic (e.g., annual or semi-annual) monitoring reports and conducting compliance reviews.

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 currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, OP Regulatory Information Division, U.S. Environmental Protection Agency (2137), 401 M. St. S.W., Washington, D.C. 20460; and 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. Include the EPA ICR number (1829.01) in any correspondence.

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316(b) | UNDS | NPDES

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