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["Table 1. Annual Respondent Burden and Cost"]
[null,null,null,"  NESHAP for Pulp and Paper Production"]
[323,"=","# pulping lines","  (40 CFR Part 63, Subpart S)","(A)","(B)",null,"(C)","(D)",null,"(E)","(F)","(G)","(H)"]
[185,"=","# bleaching lines","(Renewal)","Hours Per","Number of","Emissions","Hours","  Number of",null,"Technical","Management","Clerical","Total"]
[161,"=","# mills total",null,"Occurrence","Occurrences","Testing Cost","Per","Respondents",null,"Hours","Hours","Hours","Cost"]
[105,"=","# mills with bleaching lines",null,"(Technical","Per","Per","Respondent","   Per Year (a)",null,"Per Year","Per Year","Per Year","Per Year"]
[{"$nulls":4},"hours)","Respondent","Occurrence","Per Year",null,null,"@$64.60","@$95.32","@$40.09"]
["                  Burden Item",{"$nulls":4},"Per Year",null,"(C=AxB)",null,null,"(CxD)","(Ex0.05)","(Ex0.1)"]
["1.","Applications",null,null,"Not applicable",null,null,0,{"$nulls":5},0]
["2.","Surveys and Studies",null,null,"Not applicable",null,null,0,null,null,0,0,0,0," "]
["3.","Reporting Requirements",{"$nulls":5},0,null,null,0,0,0,0]
[null,"A.","Read and Understand Rule Requirements (MACT I Mills) (b)",null,40,1,0,40,7,"c,d",280,14,28,20545]
[1,"B.","Read and Understand Rule Requirements (MACT III Mills) (b)",null,20,1,0,20,0,"c,d",0,0,0,0]
[null,"B.","Required Activities",{"$nulls":7},0,0,0]
[1,null,"1.1)  Pulping processes (Non-Sulfite) "]
[null,0.9,"   a)  Provide documentation that vent streams are introduced to ",null,24,1,0,24,4,"c,e",96,4.800000000000001,9.600000000000001,7044]
[null,null,"        the flame zone of a boiler, lime kiln, or recovery furnace, or"]
[null,null,"   b)  Provide documentation that the control incinerator is operating",null,60,1,0,60,1,"c,f",60,3,6,4402.499999999999]
[null,null,"         at a minimum level of 1600 F and 0.75 sec residence time, or"]
[null,0.1,"   c)  Performance test of control device - test method 308",null,24,1,14000,24,1,"c,f,g",24,1.2000000000000002,2.4000000000000004,1761]
[null,null,"1.2)  Pulping Processes (Sulfite) ",null,24,1,14000,24,0,"c,g,i",0,0,0,0]
[null,null,null,"    Performance test of control device - test method 308"]
[1,null,"2.1)  Bleaching process vent scrubber (MACT I Mills) - Choice of"]
[null,null,"    a)  Provide documentation of scrubber operating parameters",null,60,1,0,60,4,"c,j",240,12,24,17609.999999999996]
[null,null,"         or previous performance tests results, or"]
[null,null,"    b)  Performance test of scrubber or control device ",null,24,1,10000,24,0,"c,g,j",0,0,0,0]
[null,null,"          - test method 26A",null," "]
[1,null,"2.2)  Bleaching process vent scrubber (MACT III Mills) - Choice of"]
[null,null,"    a)  Provide documentation of scrubber operating parameters,",null,60,1,0,60,0,"c,j",0,0,0,0]
[null,null,"         or previous performance test results, or"]
[null,null,"    b)  Performance test of scrubber or control device ",null,24,1,10000,24,0,"c,g,j",0,0,0,0]
[null,null,"          - test method 26A"]
[1,null,"3.1)  Pulping wastewater treatment (Non-Sulfite)"]
[null,0.7,"  a)  Performance test of condensate segregation and ",null,24,1,16000,24,4,"c,h,k",96,4.800000000000001,9.600000000000001,7044]
[null,null,"        control device (test method 305), or"]
[null,0.1,"  b)  Performance test of biotreatment unit - test method 304",null,24,1,11000,24,2,"c,h,l",48,2.4000000000000004,4.800000000000001,3522]
[null,null,"3.2)  Pulping wastewater treatment (Sulfite)",{"$nulls":4}," "," "]
[null,null,"        Performance test of control device - test method 305",null,24,1,16000,24,0,"c,h,m",0,0,0,0]
[0.15,null,"Repeat of performance test"]
[null,null,"   1)  test method 308 - pulping",null,24,1,14000,24,0,"c,g,n",0,0,0,0]
[null,null,"   2)  test method 26A - bleaching",null,24,1,10000,24,0,"c,g,n",0,0,0,0]
[null,null,"   3)  test method 305 - kraft pulping ww",null,24,1,16000,24,1,"c,h,n",24,1.2000000000000002,2.4000000000000004,1761]
[null,null,"   4)  test method 304 - kraft pulping ww",null,24,1,11000,24,0,"c,h,n",0,0,0,0]
[null,null,"   5)  test method 305 - sulfite pulping ww",null,24,1,16000,24,0,"c,h,n",0,0,0,0]
[1,null,"Initial/Annual inspection  (enclosures, closed vent,",null,8,1,3000,8,87,"o",696,34.800000000000004,69.60000000000001,51069]
[null,null,"wastewater conveyance system)- test method 21"]
[1,null,"Monthly visual inspection of enclosures, closed",null,4,12,0,48,130,"d",6240,312,624,457860]
[null,null,"vent system, and wastewater conveyance system."]
[null,"C.","Create Information",null,"Included in 3.B",null,null,0,null,null,0,0,0]
[null,"D.","Gather Information",null,"Included in 3.B",null,null,0,null,null,0,0,0]
[null,"E.","Report Preparation",{"$nulls":4},0,null,null,0,0,0]
[1,null,"  Initial Notification Report",null,16,1,0,16,0,"c,d,t",0,0,0,0]
[1,null,"  Notification of compliance status",null,16,1,0,16,0,"c,d",0,0,0,0]
[null,null,"  Initial Compliance Strategy Report",null,40,1,0,40,0,"c,p",0,0,0,0]
[null,null,"  Compliance Strategy Report Update",null,16,1,0,16,27,"p",432,21.6,43.2,31697.999999999996]
[1,null,"  Semi-annual summary report",null,16,2,0,32,137,"d",4384,219.20000000000002,438.40000000000003,321676]
[0.1,null,"  Continuous monitoring/Exceedance reports",null,24,2,0,48,21,"q",1008,50.400000000000006,100.80000000000001,73962]
[1,null,"  Notification of performance test",null,4,1,0,4,24,"c,r,u",96,4.800000000000001,9.600000000000001,7044]
[0.01,null,"  Notification of construction/reconstruction",null,4,1,0,4,21,"c,s,v",84,4.2,8.4,6163.5]
[0.01,null,"  Notification of actual startup",null,4,1,0,4,21,"c,s,w",84,4.2,8.4,6163.5]
["4.","Recordkeeping Requirements",{"$nulls":5},0,null,null,0,0,0,0]
[1,"A.","Read Instructions",null,"Included in 3.A",null,null,0,null,null,0,0,0,0]
[1,"B.","Plan Activities",null,"Included in 3.B",null,null,0,null,null,0,0,0,0]
[1,"C.","Implement Activities",null,"Included in 3.B",null,null,0,null,null,0,0,0,0]
[1,"D.","Develop Record System",null,40,1,0,40,0,"c,d",0,0,0,0]
[null,"E.","Record information",{"$nulls":4},0,null,null,0,0,0,0]
[1,null,"  Records of continuous monitoring for operating parameters",null,2,52,0,104,137,"d",14248,712.4000000000001,1424.8000000000002,1045446.9999999999]
[1,null,"  Records of periodic inspections (monthly",null,"Included in 3.B"]
[null,null,"    visual inspections and annual method 21)",{"$nulls":7},0,0,0,0]
[1,null,"  Record startups, shutdowns, and malfunctions",null,4,12,0,48,137,"d",6576,328.8,657.6,482514]
[null,"F.","Personnel Training",null,"Not applicable"]
[null,"G.","Time for audits",null,8,2,0,16,137,"d",2192,109.60000000000001,219.20000000000002,160838]
[null,null,null,"Total:",{"$nulls":6},36908,1845.3999999999999,3690.7999999999997,2708124.5," "]
[]
[null,null,null,"TOTAL INDUSTRY BURDEN SUMMARY: "]
[null,null,null,"Total annual labor hours",42444.200000000004]
[null,null,null,"Annual costs in dollars",2708124.5]
[]
["Footnotes"]
["a  Values are rounded "]
["b  MACT I Mills include kraft, sulfite, soda, and semi-chemical operations.  MACT III Mills include mechanical, non-wood, and secondary fiber operations."]
["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 mills. (130 MACT I Category Mills,  338 Stand-alone MACT III category mills)"]
["    Assume all MACT I category mills will be afftected by this rule.  Assume the only MACT III category mills that will be affected by this rule are the stand-alone mills with chlorine bleaching"]
["    (Available information estimates that only 2% of stand-alone MACT III category mills have chlorine bleaching processes (2% of 338 = 7, After initial compliance assessment 331 mills are not impacted.) )"]
["    Total number of mills affected by this rule is 130 + 7 = 137"]
["e  Estimated that 66.7% of mills will use a recovery boiler, power boiler, or lime kiln for control of pulping vents.  There are 122 non-sulfite pulping mills. (66.7% of 122 = 81)"]
["f   Estimated that 33.3% of mills will use incineration for pulping lines (16.7% will provide acceptable design specs (14), and 16.7% will conduct performance tests (14) )"]
["g  Estimate includes test plan, test report, and parametric montioring 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 8 sulfite pulping mills will conduct performance tests."]
["j   94 MACT I category mills have bleaching lines. 90% will provide acceptable performance specs or previous test results (85), 10% will conduct performance tests (9)"]
["    Assume 2 percent of stand-alone MACT III category mills have bleaching lines (2% of 338=7).   90% will provide acceptable performance specs or previous test results (6) "]
["   10% will conduct performance tests (1)."]
["k  Estimated that each kraft mill has one pulping wastewater control device.  Of the 108 kraft mills, 28 already have steam strippers in use,"]
["    and of the 28, all are assumed to conduct condensate segregation and performance tests.  Of the 80 mills without control, 35 will use biotreatment control"]
["    and, 45 will install steam strippers.  Facilities installing new steam strippers are assumed to perform initial condenstate segregation and performance tests."]
["    Facilites installing new biotreatment control will perform initial performance tests."]
["l   Estimated that each kraft mill has one pulping wastewater control device.  Assumed 33% will use biotreatment.  (33% of 108 = 36)  Per footnote \"c,\"  5 % of 36= 2."]
["m Assume sulfite mills will monitor gas scrubber parameters and use Water-8 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 130 = 87)."]
["p  Assume that 25% of all kraft mills are still required to submit compliance strategy reports (25% of 108 kraft mills = 27 affected kraft mills) in order to comply by 2006."]
["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 162 = 24)"]
["r   EPA must be notified of all tests including repeat performance tests. ((130 x .05 =7)  7 x 1.15 x 3 = 24) (see footnotes c and q)"]
["s  Assumed 15% of all affected mills conduct construction or reconstruction per year.  (15% of 137 = 21)"]
["t","<45","days","after promulgation"]
["u",">75","days","before test"]
["v",">180","days","beforehand"]
["w","<150","days","after startup"]
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