1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Cellulose
Products
Manufacturing."
This
is
a
new
information
collection
request
(
ICR),
and
a
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
has
not
been
assigned.

(
b)
Short
Characterization
(
i)
Applicability.
Respondents
are
owners
and
operators
of
new
and
existing
sources
in
the
cellulose
products
manufacturing
industry.
The
cellulose
products
manufacturing
industry
includes
the
Miscellaneous
Viscose
Processes
source
category
and
Cellulose
Ethers
Production
source
category.
The
Miscellaneous
Viscose
Processes
source
category
includes
the
cellulose
food
casing,

rayon,
cellophane,
and
cellulosic
sponge
industry
sectors,
and
the
Cellulose
Ethers
Production
source
category
includes
the
carboxymethyl
cellulose,
hydroxyethyl
cellulose,
hydroxypropyl
cellulose,
hydroxypropyl
methyl
cellulose,
and
methyl
cellulose
industry
sectors.

The
cellulose
products
manufacturing
NESHAP
includes
emission
limits,
operating
limits,
and
work
practice
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).
Thirteen
existing
sources
in
the
cellulose
products
manufacturing
industry
(
three
cellulose
food
casing,
one
rayon,
one
cellophane,
four
cellulosic
sponge
facilities,
and
four
cellulose
ether
facilities)
are
major
sources
of
HAP
and,
therefore,
will
be
subject
to
the
major
source
provisions.
The
three
remaining
existing
sources
in
the
cellulose
products
manufacturing
industry
(
three
cellulose
ether
facilities)
are
not
major
sources
and
will
2
not
be
subject
to
the
major
source
provisions.
No
new
major
source
cellulose
products
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

(
ii)
Cellulose
products
manufacturing
facilities.

Respondents
must
choose
one
of
the
compliance
options
described
in
the
rule
or
install
and
monitor
a
specific
air
pollution
control
system
that
reduces
HAP
emissions
to
the
compliance
level.
Respondents
also
are
required
to
install,
operate,
and
maintain
a
continuous
parameter
monitoring
system
(
CPMS)
for
each
facility
to
demonstrate
compliance
with
the
operating
limits
in
the
rule.
Respondents
are
required
to
record
the
values
of
operating
parameters
and
maintain
the
averages
of
those
values
within
the
limits
established
during
the
performance
test
or
other
initial
compliance
demonstration.
Respondents
are
given
the
option
to
use
a
continuous
emissions
monitoring
system
(
CEMS)

as
an
alternative
to
a
CPMS.
Viscose
process
respondents
are
required
to
prepare
and
maintain
a
material
balance,
which
would
be
used
to
calculate
the
percent
reduction
in
emissions
and
demonstrate
compliance
with
the
process
vent
emission
limits
in
the
rule.
Cellulose
ether
respondents
are
required
to
comply
with
the
monitoring
requirements
of
40
CFR
part
63,
subparts
F
and
G
for
wastewater
systems
and
40
CFR
part
63,
subpart
H
or
UU
for
equipment
leaks
to
demonstrate
compliance
with
the
wastewater
and
equipment
leak
standards
in
the
rule.

Respondents
are
subject
to
the
reporting
and
recordkeeping
requirements
described
in
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include
the
notification
that
the
facility
is
subject
to
the
rule;
the
notification
of
performance
test;
the
notification
of
compliance
status
(
including
results
of
performance
tests
and
other
initial
compliance
demonstrations);

and
semiannual
compliance
reports.
In
addition
to
the
requirements
of
subpart
A,
cellulose
ether
respondents
are
required
to
comply
with
the
applicable
reporting
and
3
recordkeeping
requirements
of
40
CFR
part
63,
subparts
F
and
G
for
wastewater
systems,
and
40
CFR
part
63,
subpart
H
or
UU
for
equipment
leaks.

Respondents
are
to
submit
all
reports
to
their
State
or
local
agency
or
to
the
EPA
Regional
Office,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
rule
are
achieving
the
emission
limits,
operating
limits,
and
work
practice
standards
in
the
rule.

(
iii)
Deviations
from
the
standard.
If
respondents
identify
any
deviation
resulting
from
a
known
cause
for
which
no
Federally
approved
or
promulgated
exemption
from
an
emission
limit,
operating
limit,
or
work
practice
standard
applies,
the
compliance
report
must
also
include
all
records
that
the
facility
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
action
taken
to
minimize
each
deviation
and
action
taken
to
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
monitoring
protocol.

(
iv)
Record
retention.
Respondents
must
maintain
a
copy
of
all
operating
parameter
values
that
demonstrate
compliance
with
the
operating
limits
in
the
rule,
as
well
as
maintain
records
of
performance
tests;
startup,
shutdown,
and
malfunction
(
SSM);

monitoring
systems;
supporting
calculations
for
compliance
determinations;
and
any
other
information
necessary
to
demonstrate
compliance
with
the
emission
limits,
operating
limits,
and
work
practice
standards
in
the
rule.
Respondents
must
maintain
those
records
for
a
minimum
of
5
years.
At
a
minimum,
respondents
must
maintain
the
most
recent
2
years
of
data
onsite.
Respondents
may
retain
the
remaining
3
years
of
data
offsite.
4
2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
emission
standards
for
each
category
or
subcategory
of
major
and
area
sources
of
HAP
listed
for
regulation
in
section
112(
b).
These
standards
are
applicable
to
new
or
existing
sources
of
HAP
and
shall
require
the
maximum
degree
of
emission
reduction.
The
predominant
HAP
emitted
from
the
Miscellaneous
Viscose
Processes
source
category
include
carbon
disulfide,
carbonyl
sulfide,
and
toluene.
The
predominant
HAP
emitted
from
the
Cellulose
Ethers
Production
source
category
include
ethylene
oxide,
methanol,
methyl
chloride,
and
propylene
oxide.

In
the
Administrator's
judgment,
the
pollutants
emitted
from
the
Miscellaneous
Viscose
Processes
source
category
and
the
Cellulose
Ethers
Production
source
category
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
these
source
categories
are
listed
for
regulation
under
section
112.
(
Note:
The
original
source
category
list
included
separate
categories
for
Cellulose
Food
Casing,
Rayon,
Cellophane,
Methyl
Cellulose,

Carboxymethyl
Cellulose,
and
Cellulose
Ethers.
The
Cellulose
Food
Casing,
Rayon,
and
Cellophane
source
categories
have
been
grouped
together
with
Cellulosic
Sponge
[
a
source
category
not
on
the
original
source
category
list]
to
create
a
new
"
Miscellaneous
Viscose
Processes"
source
category.
The
Methyl
Cellulose,

Carboxymethyl
Cellulose,
and
Cellulose
Ethers
source
categories
have
also
been
grouped
together
to
create
a
new
"
Cellulose
Ethers
Production"
source
category.)

Section
114(
a)
of
the
CAA
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
the
CAA
to:
5
...(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables,
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

The
required
notifications
are
used
to
inform
EPA
or
delegated
authority
when
a
source
becomes
subject
to
the
cellulose
products
manufacturing
NESHAP.
The
reviewing
authority
may
then
inspect
the
source
to
determine
if
the
air
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
emission
limits,
operating
limits,
and
work
practice
standards
in
the
rule
are
being
met.

Performance
test
reports
are
necessary
because
they
are
EPA's
record
of
a
source's
initial
capability
to
comply
with
the
emission
limits
and
work
practice
standards,
and
they
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
facilities
subject
to
the
cellulose
products
manufacturing
NESHAP
and
to
ensure
that
the
emission
limits
and
work
practice
standards,
which
are
based
on
maximum
achievable
control
technology
(
MACT)
for
viscose
process
facilities
and
cellulose
ether
facilities,
are
being
achieved.

After
their
compliance
date,
all
respondents
must
submit
semiannual
(
every
6
months)
compliance
reports
that
contain
the
information
requested
in
§
63.5580
of
the
rule.
The
semiannual
compliance
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance
(
O&
M),
and
for
compliance
determinations.
These
records
and
reports
are
required
under
the
cellulose
products
manufacturing
NESHAP
and
the
General
Provisions
of
40
CFR
part
63,
subpart
A
(
as
6
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
CAA
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,
7412,
7414,
7416,

7601]).

(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
EPA
enforcement
personnel
to
(
1)
identify
new,
modified,
reconstructed,
and
existing
sources
subject
to
the
rule;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
air
pollution
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
EPA
to
identify
facilities
subject
to
the
cellulose
products
manufacturing
NESHAP
that
are
not
in
compliance
with
the
emission
limits,
operating
limits,
and
work
practice
standards
in
the
rule.
Based
on
reported
information,
EPA
can
decide
which
cellulose
products
manufacturing
facilities
should
be
inspected
and
which
records
or
processes
should
be
inspected
at
those
facilities.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
the
facility
personnel
are
in
compliance
with
the
emission
limits,
operating
limits,
and
work
practice
standards.

Much
of
the
information
EPA
needs
to
determine
compliance
would
be
recorded
on
a
continuous,
hourly,
or
daily
basis.
Other
information
would
be
recorded
on
a
monthly,
semiannual,
or
other
basis.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
need
to
be
reported
on
a
semiannual
basis.
7
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
cellulose
products
manufacturing
NESHAP
(
e.
g.,
reports
of
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

A
search
of
existing
rules
revealed
some
duplication
of
information­
gathering
efforts
in
those
cases
where
facilities
are
subject
to
other
rules
in
addition
to
the
cellulose
products
manufacturing
NESHAP.
In
each
case
that
has
been
identified,
an
effort
has
been
made
to
eliminate
this
duplication.
Two
examples
of
these
efforts
are
provided
below.

The
cellulose
products
manufacturing
NESHAP
allows
facilities
that
are
also
subject
to
the
provisions
of
40
CFR
parts
264
and/
or
265
to
comply
with
those
provisions
(
which
constitutes
compliance
with
the
requirements
of
the
rule)
or
with
the
provisions
of
the
rule.
If
facilities
comply
with
the
provisions
of
40
CFR
parts
264
and/
or
265,
then
they
must
report
the
information
required
under
§
63.5580
of
the
rule
and
identify
in
the
notification
of
compliance
status
required
by
§
63.5575
the
recordkeeping
and
reporting
authority
under
which
they
will
comply.

Also
noted
in
the
cellulose
products
manufacturing
NESHAP,

facilities
with
an
affected
wastewater
stream
that
is
also
subject
to
the
provisions
of
40
CFR
parts
260
through
272
may
determine
whether
the
NESHAP
or
40
CFR
parts
260
through
272
contain
the
more
stringent
requirements.
Compliance
with
provisions
of
40
CFR
parts
260
through
272
that
are
determined
to
be
more
stringent
than
the
requirements
of
the
NESHAP
constitutes
compliance
with
the
NESHAP.
In
the
notification
of
compliance
8
status
required
by
§
63.5575,
the
facilities
must
identify
the
more
stringent
provisions
of
40
CFR
parts
260
through
272
with
which
they
will
comply,
as
well
as
provide
the
information
and
procedures
that
they
used
to
make
any
stringency
determinations.

(
b)
Consultations
The
EPA
published
a
list
of
categories
of
major
and
area
sources
of
HAP
on
July
16,
1992
(
57
FR
21592),
under
authority
of
section
112(
c);
this
notice
listed
most
of
the
various
source
categories
comprising
the
Miscellaneous
Viscose
Processes
and
Cellulose
Ethers
Production
source
categories
as
categories
of
major
sources
of
HAP.
(
As
noted
above,
the
Cellulose
Food
Casing,
Rayon,
and
Cellophane
source
categories
have
been
grouped
together
with
Cellulosic
Sponge
[
a
source
category
not
on
the
original
source
category
list]
to
create
a
new
"
Miscellaneous
Viscose
Processes"
source
category.
The
Methyl
Cellulose,

Carboxymethyl
Cellulose,
and
Cellulose
Ethers
source
categories
have
also
been
grouped
together
to
create
a
new
"
Cellulose
Ethers
Production"
source
category.)

Representatives
of
the
affected
companies,
their
consultants,
air
pollution
control
device
vendors,
State
environmental
agencies,
and
a
Federal
government
agency
were
consulted
during
the
development
of
the
rule,
and
14
meetings
were
held
with
them
during
this
time.
Table
1
presents
a
list
of
the
names,
affiliations,
and
telephone
numbers
of
persons
that
provided
input
during
development
of
the
rule.
(
The
list
includes
the
latest
contact
names
and
telephone
numbers
and
excludes
those
no
longer
pertinent
to
the
development
of
the
rule.)
During
the
meetings,
the
representatives
were
given
opportunities
to
comment
on
the
regulatory
approach.
The
major
topics
of
these
discussions
included
the
applicability,
MACT
floor
approach,
regulatory
strategies,
and
cost
and
environmental
9
impacts
of
the
rule.
No
specific
information
was
provided
to
the
representatives
with
respect
to
burden
estimates.

TABLE
1.
CELLULOSE
PRODUCTS
MANUFACTURING
CONSULTATIONS
Name
Affiliation
Telephone
number
Penny
Lassiter
U.
S.
Environmental
Protection
Agency
(
919)
541­
5396
William
Schrock
U.
S.
Environmental
Protection
Agency
(
919)
541­
5032
Val
Schaeffer
U.
S.
Occupational
Safety
and
Health
Administration
(
202)
693­
2092
Sherri
Clark
American
Chemistry
Council
 
Carbon
Disulfide
Panel
(
703)
741­
5000
Lynn
Bergeson
Bergeson
&
Campbell
P.
C.
(
202)
962­
8577
Jack
Webster
Devro­
Teepak,
Inc.
(
217)
446­
6460,
ext.
5312
David
Gustafson
Dow
Chemical
Co.
(
517)
636­
2953
Bruce
Alexius
Dow
Chemical
Co.
(
225)
353­
8844
William
Fucich
Envirogen,
Inc.
(
609)
936­
9300
Glennis
Kanour
Hercules
Inc.
(
804)
541­
4300
Dave
Van
Derveer
Hercules
Inc.
(
908)
254­
1234,
ext.
215
William
South
Lenzing
Fibers
Corp.
(
423)
585­
4805
Stuart
Andrews
MAK
Chemical
Corp.
(
765)
288­
4464
Joseph
Enneking
NUCON
International,
Inc.
(
614)
846­
5710
Dominique
Alibeckoff
Nylonge
Corp.
(
216)
323­
6161
David
Savage
Penn
Carbose,
Inc.
(
814)
443­
1611,
ext.
11
Sunil
Kapoor
Program
Management
Co.
(
703)
748­
3433
Kathryn
Larkins
Shook,
Hardy,
&
Bacon
L.
L.
P.
(
913)
663­
8913
Robert
Beuerlein
Spontex,
Inc.
(
931)
540­
2151
Gregory
Stubbs
3M
Corp.
(
716)
871­
6281
Charlie
Connell
3M
Corp.
(
608)
326­
2466,
ext.
3321
Michelle
Probasco
UCB
Films,
Inc.
(
785)
379­
0571
Robert
Odewald
Viskase
Corp.
(
630)
455­
4485
Hank
Naour
Illinois
Environmental
Protection
Agency
(
217)
782­
2113
Jackie
Surles
Louisiana
Department
of
Environmental
Quality
(
225)
765­
0219
Nick
Zabrodsky
Michigan
Department
of
Environmental
Quality
(
517)
373­
4921
Alfred
Azevedo
West
Virginia
Department
of
Environmental
Protection
(
304)
926­
3727,
ext.
316
10
(
c)
Effects
of
Less
Frequent
Collection
In
the
3
years
after
the
effective
date
of
the
rule,

existing
sources
will
submit
only
one­
time
notifications
to
EPA.

In
this
instance,
less
frequent
reporting
would
not
be
practical
because
EPA
needs
the
information
provided
in
these
one­
time
notifications.
In
addition
to
these
one­
time
notifications,

existing
sources
will
also
submit
semiannual
compliance
reports
in
the
years
after
their
compliance
date.
If
the
relevant
information
were
collected
less
frequently,
the
EPA
would
not
be
reasonably
assured
that
the
sources
are
applying
good
O&
M
practices
and
meeting
the
emission
limits,
operating
limits,
and
work
practice
standards
in
the
rule.
Less
frequent
collection
could
decrease
the
likelihood
of
detecting
poor
O&
M
of
control
equipment
and
long­
term
deviations
from
the
applicable
emission
limits,
operating
limits,
and
work
practice
standards.

In
addition,
EPA's
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
that
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Because
administrative
proceedings
are
less
costly
and
require
fewer
resources
than
judicial
proceedings,
both
EPA
and
the
regulated
community
benefit
from
preservation
of
EPA's
administrative
powers.

Also,
the
reporting
frequency
in
the
NESHAP
is
consistent
with
the
requirements
of
title
V
permit
programs.
Consequently,

less
frequent
reports
would
not
result
in
a
lower
burden.

(
d)
General
Guidelines
The
cellulose
products
manufacturing
NESHAP
requires
owners
or
operators
of
a
facility
to
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
general
information
collection
guidelines
in
5
CFR
1320.6(
f)

of
the
Office
of
Management
and
Budget
(
OMB)
regulations
11
implementing
the
Paperwork
Reduction
Act.
However,
the
5­
year
retention
period
is
consistent
with
the
retention
requirement
in
the
General
Provisions
to
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
40
CFR
part
70.

All
of
the
facilities
subject
to
the
rule
would
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71.
Thus,
the
5­
year
record
retention
requirement
of
the
rule
would
add
no
additional
burden.

At
a
minimum,
respondents
would
be
required
to
retain
on
site
the
most
recent
2
years
of
data.
Respondents
could
retain
the
remaining
3
years
of
data
at
a
readily
accessible
onsite
or
offsite
storage
facility.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
e)
Confidentiality
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
 
­

Confidentiality
of
Business
Information.
(
See
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,

1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,

1979.)

(
f)
Sensitive
Questions
The
information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.

Therefore,
this
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.
12
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAICS
Codes
Respondents
are
owners
or
operators
of
cellulose
food
casing,
rayon,
cellophane,
cellulosic
sponge,
and
cellulose
ether
facilities
that
are
classified
as
major
sources
under
section
112
of
the
CAA.
The
following
table
lists
the
North
American
Industrial
Classification
System
(
NAICS)
codes
used
to
classify
the
respondents
affected
by
the
cellulose
products
manufacturing
NESHAP.
Not
all
processes
classified
in
the
NAICS
codes
in
the
table
below
will
be
regulated
by
the
cellulose
products
manufacturing
NESHAP
(
i.
e.,
they
will
not
be
regulated
if
they
are
already
subject
to
another
NESHAP).

Regulated
entity
NAICS
code
and
description
Cellulose
food
casing
facilities
326121
­
Unsupported
Plastics
Profile
Shape
Manufacturing
Cellophane
facilities
326199
­
All
Other
Plastics
Product
Manufacturing
Cellulosic
sponge
facilities
326199
­
All
Other
Plastics
Product
Manufacturing
325211
­
Plastics
Material
and
Resin
Manufacturing
Rayon
facilities
325221
­
Cellulosic
Organic
Fiber
Manufacturing
Cellulose
ether
facilities
325199
­
All
Other
Basic
Organic
Chemical
Manufacturing
13
(
b)
Information
Requested
(
i)
Data
items,
including
recordkeeping
requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
reporting
and
recordkeeping
requirements.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
rule
for
existing
major
sources
for
the
first
and
third
years
after
the
effective
date
of
the
rule
are
listed
in
Tables
2a
and
2b,
respectively,
and
are
presented
in
section
6(
a).
The
EPA
does
not
expect
any
respondent
activities
for
existing
major
sources
for
the
second
year
after
the
effective
date
of
the
rule.
The
respondent
activities
are
described
in
more
detail
in
Attachment
2,
Description
of
Respondent
Activities.
No
new
major
source
cellulose
products
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.
14
TABLE
2a.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
FIRST
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*
0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
instructions
4
1
4
13
52
3
5
60
$
2,829
B.
Required
activities
N/
A
C.
Create
information
Included
in
3E
D.
Gather
existing
information
Included
in
3E
E.
Write
report
°
Notification
of
applicability
2
1
2
13
26
1
3
30
$
1,414
4.
Recordkeeping
requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
N/
A
F.
Time
to
train
personnel
N/
A
G.
Time
for
audits
N/
A
Total
burden
and
cost
nationwide
(
salary)
c
78
4
8
90
$
4,243
Average
cost
per
facility
d
13
$
326
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

bCosts
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.

dThe
average
cost
per
facility
is
calculated
by
dividing
the
total
cost
by
the
number
of
facilities
(
13)
subject
to
the
standards.
15
TABLE
2b.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­

THIRD
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*
0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
Included
in
3E
D.
Gather
existing
information
Included
in
3E
E.
Write
report
°
Notification
of
initial
performance
test
c
2
1
2
14
28
1
3
32
$
1,523
4.
Recordkeeping
requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
d
40
1
40
13
520
26
52
598
$
28,286
°
Develop
SSM
plan
e
100
1
100
13
1,300
65
130
1,495
$
70,716
°
Develop
site­
specific
monitoring
plan
f
100
1
100
13
1,300
65
130
1,495
$
70,716
E.
Time
to
enter
information
N/
A
F.
Time
to
train
personnel
g
40
1
40
13
520
26
52
598
$
28,286
G.
Time
for
audits
N/
A
Total
burden
and
cost
nationwide
(
salary)
h
3,668
183
367
4,218
$
199,528
Average
cost
per
facility
i
13
$
15,348
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

bCosts
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.
16
TABLE
2b.
(
continued)

cRespondents
per
year
are
based
on
6
viscose
process
facilities
conducting
a
performance
test
for
their
process
vents
and
4
cellulose
ether
facilities
conducting
separate
performance
tests
for
their
process
vents
and
wastewater
systems,
with
the
facilities
submitting
a
separate
notification
of
performance
test
for
each
performance
test
conducted
at
the
facility.

dHours
per
occurrence
assume
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

eHours
per
occurrence
assume
one
person
would
take
2
weeks
(
80
hours)
to
draft
the
SSM
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

f
Hours
per
occurrence
assume
one
person
would
take
2
weeks
(
80
hours)
to
draft
the
site­
specific
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

gAssume
40
hours
to
train
personnel.

hThe
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.

i
The
average
cost
per
facility
is
calculated
by
dividing
the
total
cost
by
the
number
of
facilities
(
13)
subject
to
the
standards.
17
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
The
Agency
activities
for
the
first
and
third
years
after
the
effective
date
of
the
rule
are
listed
in
Tables
3a
and
3b,

respectively,
and
are
presented
in
section
6(
c).
The
EPA
does
not
expect
any
Agency
activities
for
the
second
year
after
the
effective
date
of
the
rule.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time­
only
notifications
will
be
entered
in
the
National
Emissions
Trends
(
NET)
database
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
The
NET
database
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
industrial
and
government­
owned
facilities.
The
EPA
uses
the
NET
database
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
agencies
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
NET
database
can
be
publicly
accessed
via
the
Internet
from
Envirofacts
at
http://
www.
epa.
gov/
enviro/

index_
java.
html
or
through
a
Freedom
of
Information
Act
request
to
EPA.
Data
obtained
during
periodic
visits
by
EPA
personnel,

from
records
maintained
by
the
respondents,
and
from
information
provided
in
semiannual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.
18
TABLE
3a.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­
FIRST
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
(
C)

Hours
per
facility
per
year
(
C
=
A
*
B)
(
D)
Facilities
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*
0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Agency
hours
per
year
(
H
=
E
+
F
+

G)
(
I)

Labor
cost
per
year,
$
b
1.
Attend
initial
performance
test
N/
A
2.
Attend
repeat
performance
test
N/
A
3.
Litigation
N/
A
4.
Excess
emissions
 
enforcement
activities
N/
A
5.
Report
review
A.
Review
notification
of
applicability
2
1
2
13
26
1
3
30
$
1,414
Total
burden
and
cost
(
salary)
c
26
1
3
30
$
1,414
Travel
expenses
for
tests
attended
$
0
Total
annual
cost
=
total
cost
(
salary)
+
travel
expenses
$
1,414
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,

and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.
19
TABLE
3b.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­
THIRD
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
(
C)

Hours
per
facility
per
year
(
C
=
A
*
B)
(
D)
Facilities
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*
0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Agency
hours
per
year
(
H
=
E
+
F
+

G)
(
I)

Labor
cost
per
year,
$
b
1.
Attend
initial
performance
test
N/
A
2.
Attend
repeat
performance
test
N/
A
3.
Litigation
N/
A
4.
Excess
emissions
 
enforcement
activities
N/
A
5.
Report
review
A.
Review
notification
of
initial
performance
test
c
2
1
2
14
28
1
3
32
$
1,523
Total
burden
and
cost
(
salary)
d
28
1
3
32
$
1,523
Travel
expenses
for
tests
attended
$
0
Total
annual
cost
=
total
cost
(
salary)
+
travel
expenses
$
1,523
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,

and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
Facilities
per
year
are
based
on
6
viscose
process
facilities
conducting
a
performance
test
for
their
process
vents
and
4
cellulose
ether
facilities
conducting
separate
performance
tests
for
their
process
vents
and
wastewater
systems,
with
the
facilities
submitting
a
separate
notification
of
performance
test
for
each
performance
test
conducted
at
the
facility.

d
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.
20
The
cellulose
products
manufacturing
NESHAP
does
not
require
the
use
of
automated,
electronic,
mechanical,
or
other
technological
data
collection
techniques
or
other
forms
of
information
technology.
Although
many
of
the
large
companies
may
have
elaborate
collection
methods,
automated
systems
are
not
expected
to
reduce
the
burden.

(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
by
EPA.
The
EPA
has
reduced
the
reporting
and
recordkeeping
burden
for
respondents
to
include
only
the
information
that
EPA
needs
to
determine
compliance
with
the
cellulose
products
manufacturing
NESHAP.

Nine
companies
own
the
13
major
source
facilities
in
the
cellulose
products
manufacturing
industry.
Only
one
of
these
companies
meets
the
applicable
definition
of
a
small
business
(
i.
e.,
fewer
than
500
employees
for
NAICS
code
326199).
The
EPA
does
not
expect
that
this
company
will
experience
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

(
d)
Collection
Schedule
Collection
of
data
will
begin
after
the
effective
date
of
the
cellulose
products
manufacturing
NESHAP.
The
schedule
for
reports
required
by
the
NESHAP
is
summarized
below.

For
all
existing
sources,
the
initial
notification
stating
that
the
source
is
subject
to
the
rule
must
be
submitted
no
later
than
4
months
(
120
days)
after
the
effective
date
of
the
rule.

New
or
reconstructed
sources
for
which
startup
occurs
on
or
after
the
effective
date
of
the
rule
must
submit
the
initial
notification
no
later
than
120
days
after
the
source
becomes
subject
to
the
rule.
New
or
reconstructed
sources
must
comply
immediately
upon
the
effective
date
of
the
rule
if
their
startup
21
date
is
before
the
effective
date
of
the
rule
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date
of
the
rule.

Sources
required
to
conduct
a
performance
test
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.
The
sources
must
conduct
the
performance
test
or
other
initial
compliance
demonstration
no
later
than
180
days
after
their
compliance
date.
The
sources
must
submit
the
notification
of
compliance
status,
containing
the
results
of
the
performance
test
or
other
initial
compliance
demonstration,
no
later
than
240
days
after
their
compliance
date.

Following
their
compliance
date,
sources
must
compile
on
a
daily
basis
those
records
necessary
to
demonstrate
compliance,

and
they
must
submit
compliance
reports
on
a
semiannual
basis
to
the
Administrator,
as
discussed
in
section
1(
b).
22
6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
for
existing
major
sources
for
the
first
and
third
years
after
the
effective
date
of
the
rule
are
presented
in
Tables
2a
and
2b,
respectively.
The
EPA
does
not
expect
any
respondent
burden
for
existing
major
sources
for
the
second
year
after
the
effective
date
of
the
rule.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standard
development
efforts.

(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs.
The
annual
labor
costs
for
reporting
and
recordkeeping
activities
for
existing
major
sources
for
the
first
and
third
years
after
the
effective
date
of
the
rule
are
also
presented
in
Tables
2a
and
2b,
respectively.
The
costs
of
these
activities
are
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.
Labor
costs
are
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
management,
and
(
3)
clerical.
The
cost
of
technical
labor
is
estimated
at
$
47.75
per
hour
($
47.75/
hr),
the
cost
of
management
labor
at
$
72.58/
hr,
and
the
cost
of
clerical
labor
at
$
30.18/
hr.
These
estimates
include
fringe
benefits,
overhead,
and
profit
rate.

The
labor
costs
are
in
March
2000
dollars.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor­
related
costs
associated
with
information
collection
activities­­
capital
costs
and
O&
M
costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
ICR
are
presented
in
Attachment
3,
Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
23
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
discount
rate.
For
this
ICR,
capital
costs
were
annualized
using
an
interest
rate
of
7
percent.
In
most
cases,
administrative
charges,
insurance,
and
property
taxes
were
also
included
with
the
annualized
capital
costs,
estimated
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
data
acquisition
system,

computer,
logging
and
reporting
software,
printer,
and
ancillary
costs,
such
as
planning,
selecting
the
equipment,
providing
support
facilities,
installing
and
checking
the
equipment,

establishing
operating
parameters,
and
preparing
a
QA/
QC
plan.

Capital
and
annualized
capital
costs
associated
with
monitoring
equipment
are
expected
to
be
incurred
in
the
third
year
after
the
effective
date
of
the
rule
as
existing
facilities
purchase,

install,
and
verify
their
monitoring
equipment
prior
to
their
compliance
date.

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
average
annualized
capital
cost
per
facility
for
file
cabinets
is
$
35.
Capital
and
annualized
capital
costs
associated
with
file
cabinets
are
expected
to
be
incurred
in
the
third
year
after
the
effective
date
of
the
rule
as
existing
facilities
develop
their
record
systems
prior
to
their
compliance
date.

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
However,
no
performance
tests
24
are
expected
to
be
conducted
in
the
first
3
years
after
the
effective
date
of
the
rule.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
Those
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
recordkeeping
and
reporting,
and
overhead
for
the
monitoring
equipment.
Because
existing
facilities
are
expected
to
be
purchasing,
installing,

and
checking
out
their
monitoring
equipment
in
the
third
year
after
the
effective
date
of
the
rule,
no
monitoring
O&
M
costs
are
expected
to
be
incurred
until
the
following
year.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
a
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
maintain
records
and
submit
reports
to
EPA
should
be
estimated
as
costs
for
file
storage,

photocopying,
and
postage.
File
storage
and
photocopying
costs
per
response
are
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
30.18/
hr.
First
class
postage
is
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
File
storage,
photocopying
and
postage
costs
will
be
applied
to
the
13
responses
(
notifications
of
applicability)
submitted
during
the
first
year
after
the
effective
date
of
the
rule
and
the
14
responses
(
notifications
of
performance
test)
submitted
during
the
third
year.
The
EPA
does
not
expect
any
responses
to
be
submitted
during
the
second
year
after
the
effective
date
of
the
rule.
(
The
number
of
responses
was
determined
based
on
the
number
of
notifications
submitted
to
EPA
by
respondents,
as
shown
in
Tables
2a
and
2b.)
25
(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
are
developed
as
an
incidental
part
of
the
cellulose
products
manufacturing
NESHAP,
no
costs
can
be
attributed
to
the
development
of
these
requirements.

In
addition,
the
Federal
Government
will
incur
no
operational
costs
because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA.
Publication
and
distribution
of
the
information
are
part
of
the
NET
database,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
facilities.
Periodic
inspections
are
part
of
EPA's
overall
compliance
and
enforcement
program.
Therefore,
this
examination
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
by
the
respondents
in
one­
time
notifications
and
semiannual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).

Tables
3a
and
3b
present
the
estimated
annual
burden
to
the
Agency
for
the
first
and
third
years,
respectively,
after
the
effective
date
of
the
rule.
The
EPA
does
not
expect
any
Agency
burden
for
the
second
year
after
the
effective
date
of
the
rule.

Labor
costs
are
based
on
estimated
wage
rates
of
$
47.75/
hr
for
technical
labor,
$
72.58/
hr
for
management
labor,
and
$
30.18/
hr
for
clerical
labor.
The
labor
costs
are
in
March
2000
dollars.
26
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Once
the
burden
and
costs
per
activity
have
been
established
on
a
per
respondent
basis,
the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
the
Agency.
To
calculate
the
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.

The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."
The
respondent
universe
varies
among
the
activities
listed
because
not
all
respondents
must
complete
each
activity.

In
calculating
respondent
burden,
EPA
estimates
that
13
major
source
cellulose
products
manufacturing
facilities
will
be
required
to
submit
notifications
of
applicability,
10
facilities
will
be
required
to
submit
notifications
of
their
process
vent
performance
tests,
and
4
facilities
will
be
required
to
submit
notifications
of
their
wastewater
performance
tests.
In
calculating
Agency
burden,
EPA
estimates
that
EPA
personnel
will
conduct
reviews
of
13
notifications
of
applicability
and
14
notifications
of
performance
tests.

To
determine
the
burden
for
each
activity
for
technical
staff,
the
number
of
hours
per
respondent
is
multiplied
by
the
number
of
respondents.
Management
and
clerical
labor
hours
are
calculated
at
5
percent
and
10
percent
of
technical
labor
hours,

respectively.
The
total
burden
is
determined
by
summing
the
technical,
management,
and
clerical
burden
estimates.
To
determine
the
total
labor
cost,
the
burden
estimates
for
technical,
management,
and
clerical
labor
are
multiplied
by
their
respective
labor
rates
and
then
summed.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
27
(
i)
Respondent
tally.
The
annual
bottom
line
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
hours
and
costs
from
Tables
2a
and
2b
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
burden
hours
and
costs
are
summarized
as
follows:

Burden
table
Total
burden,
hours
Total
cost,
$

Table
2a
(
first
year)
90
$
4,243
Table
2b
(
third
year)
4,218
$
199,528
Total
4,308
$
203,771
Bottom
line
annual
burden
1,436
$
67,924
The
bottom
line
annual
burden,
averaged
over
the
3­
year
review
period,
is
1,436
labor
hours,
at
a
cost
of
$
67,924.
The
bottom
line
annual
burden
is
presented
in
Box
13c
of
OMB
83­
I.

The
average
annual
burden
per
respondent,
based
on
13
respondents
nationwide,
is
110
labor
hours,
at
a
cost
of
$
5,225.
The
average
number
of
respondents
is
presented
in
Box
13a
of
OMB
83­
I.

There
are
an
estimated
9
total
annual
responses
for
the
first
3
years
after
the
effective
date
of
the
rule.
The
total
annual
responses
are
based
on
an
estimated
13
one­
time
notifications
of
applicability
submitted
during
the
first
year,

no
notifications
submitted
during
the
second
year,
and
14
onetime
notifications
of
performance
test
submitted
during
the
third
year.
It
is
assumed
that
20
percent
of
all
notifications
and
reports
will
be
collected
electronically.
The
total
annual
responses
and
the
percent
of
responses
collected
electronically
are
presented
in
Boxes
13b
and
13b.
1
of
OMB
83­
I.

The
total
capital
cost
for
the
3
years
after
the
effective
date
of
the
rule
is
estimated
to
be
$
596,671
for
the
monitoring
equipment
and
$
3,055
for
the
file
cabinets
used
to
store
collected
data
and
reports.
Summing
the
capital
costs
for
the
monitoring
equipment
and
file
cabinets
results
in
a
total
capital
28
cost
of
$
599,726
for
the
3
years
after
the
effective
date
of
the
rule.

The
average
annualized
capital
cost
for
the
3
years
after
the
effective
date
of
the
rule
is
$
56,465
for
the
monitoring
equipment
and
$
152
for
the
file
cabinets.
Summing
the
average
annualized
capital
costs
for
the
monitoring
equipment
and
file
cabinets
results
in
a
total
annualized
capital
cost
of
$
56,616
for
the
3
years
after
the
effective
date
of
the
rule.
The
annual
O&
M
cost,
which
includes
file
storage,
photocopying,
and
postage
for
the
responses,
averages
$
204
for
the
3
years
after
the
effective
date
of
the
rule.
Summing
the
total
annualized
capital
cost
with
the
annual
O&
M
cost
results
in
a
total
annualized
cost
of
$
56,821
for
the
3
years
after
the
effective
date
of
the
rule.

The
total
annualized
capital
cost,
annual
O&
M
cost,
and
total
annualized
cost
are
presented
in
Boxes
14a,
14b,
and
14c,

respectively,
of
OMB
83­
I.

A
discussion
of
the
respondent
burden
and
costs
in
later
years
is
provided
in
Attachment
4,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
After
the
Effective
Date.

(
ii)
The
Agency
tally.
The
annual
bottom
line
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
hours
and
costs
from
Tables
3a
and
3b
and
then
dividing
by
the
3­
year
review
period.
The
annual
burden
hours
and
costs
are
summarized
as
follows:

Burden
table
Total
burden,
hours
Total
cost,
$

Table
3a
(
first
year)
30
$
1,414
Table
3b
(
third
year)
32
$
1,523
Total
62
$
2,937
Bottom
line
annual
burden
21
$
979
29
The
bottom
line
annual
burden,
averaged
over
the
3­
year
review
period,
is
21
labor
hours,
at
a
cost
of
$
979.
A
discussion
of
the
Agency
burden
and
costs
in
later
years
is
provided
in
Attachment
4,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
After
the
Effective
Date.

(
iii)
The
complex
collection.
This
section
does
not
apply
because
this
collection
is
a
simple
collection.

(
iv)
Variations
in
the
annual
bottom
line.
The
annual
burden
hours
and
costs
vary
over
the
course
of
the
3­
year
review
period
because
existing
sources
are
subject
to
different
requirements
in
each
year
as
follows:
(
1)
in
the
first
year,

determining
applicability,
notifying
EPA
that
the
facility
is
subject
to
the
rule,
and
reading
instructions;
(
2)
no
requirements
in
the
second
year;
and
(
3)
in
the
third
year,

notifying
EPA
of
upcoming
performance
tests,
training
personnel,

and
developing
record
systems,
SSM
plans,
and
site­
specific
monitoring
plans.
The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
they
will
be
reviewing
the
following
notifications
from
existing
sources:
(
1)
the
notifications
of
applicability
of
the
rule
in
the
first
year;

(
2)
no
review
in
the
second
year;
and
(
3)
the
notifications
of
performance
tests
in
the
third
year.

(
f)
Reasons
for
Change
in
Burden
This
section
does
not
apply
because
this
collection
is
a
new
collection.

(
g)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
CAA
to
regulate
emissions
of
HAP
listed
in
section
112(
b).
30
(
ii)
The
respondents
would
be
subject
to
applicable
recordkeeping,
reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10
of
the
General
Provisions
for
the
part
63
rules.

(
iii)
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
(
1)
review
instructions;
(
2)
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;
(
3)
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;

(
4)
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
5)
search
data
sources;
(
6)
complete
and
review
the
collection
of
information;
and
(
7)
transmit
or
otherwise
disclose
the
information.

(
iv)
The
information
is
needed
as
part
of
the
overall
compliance
and
enforcement
program.
The
information
in
the
initial,
one­
time­
only
reports
will
be
stored
in
EPA's
NET
database
and
will
be
available
to
stakeholders.

(
v)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection,
averaged
over
the
first
3
years
after
the
effective
date
of
the
rule,
are
estimated
to
be
1,436
labor
hours
and
$
67,924.
The
average
burden
and
cost,
per
respondent,

are
110
labor
hours
and
$
5,225.
These
burden
and
cost
estimates
include
submitting
one­
time
notifications
of
applicability
and
performance
test,
reading
instructions,
training
personnel,
and
developing
a
record
system,
SSM
plan,
and
site­
specific
monitoring
plan.

(
vi)
The
total
capital
cost
for
monitoring
equipment
and
file
cabinets
for
the
3
years
after
the
effective
date
of
the
rule
is
$
599,726.
The
annualized
capital
cost,
averaged
over
the
3
years
after
the
effective
date
of
the
rule,
is
$
56,616.
The
31
annual
O&
M
cost
for
file
storage,
photocopying,
and
postage,

averaged
over
the
3
years
after
the
effective
date
of
the
rule,

is
$
204.
Summing
the
annualized
capital
cost
with
the
annual
O&
M
cost
results
in
a
total
annualized
cost
of
$
56,821
for
the
3
years
after
the
effective
date
of
the
rule.

(
vii)
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
a
table
in
40
CFR
part
9.
The
EPA
will
amend
part
9
when
the
ICR
is
approved.

(
viii)
Send
comments
on
EPA's
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,
Office
of
Environmental
Information,
Collection
Strategies
Division
(
2822),
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue
NW,
Washington,
DC
20460,
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street
NW,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

(
ix)
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,

Subpart
B­­
Confidentiality
of
Information
(
see
40
CFR
part
2;

41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).
32
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
does
not
apply
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
regulation.

4
attachments
ATTACHMENT
1
Source
Data
and
Information
Requirements
Attachment
1
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions/
other
regulation
citation
NOTIFICATIONS
Initial
notifications
63.5575
63.9(
b)(
1)­(
5)

Notification
of
performance
test
63.5575
63.7(
b),
63.9(
e)

Notification
of
compliance
status
(
including
results
of
performance
test,
CEMS
performance
evaluation,
or
other
initial
compliance
demonstration)
63.5575
63.9(
h)(
1)­(
6)
and
(
j),
63.10(
d)(
2)
and
(
e)(
2)

Notifications
for
equipment
leaks
63.5575
63.182(
a)(
1)
and
(
2),
(
b),
and
(
c)(
1)­(
3),
or
§
63.1039(
a)

Notifications
for
wastewater
63.5575
63.146(
a)(
1)
and
(
2)
and
(
b),
63.151,
63.152(
a)(
1)­(
3)
and
(
b)(
1)­(
5)

REPORTS
Semiannual
compliance
reports
Deviations/
out­
of­
control
operation
Startup,
shutdown,
and
malfunction
Changes
in
information
Equipment
leaks
Wastewater
Closed­
vent
system
Bypass
lines
Heat
exchanger
systems
Storage
vessel
control
device
maintenance
63.5580
63.10(
e)(
3)
63.10(
d)(
5)
63.9(
j)
63.182(
a)(
3)
and
(
6)
and
(
d)(
2)­(
4),
or
63.1039(
b)
63.146(
c)­(
e),
63.152(
a)(
4)
and
(
5)
and
(
c)­(
e)
63.148(
j)(
1)
63.148(
j)(
2)
and
(
3)
63.104(
f)(
2)(
i)­(
iv)

RECORDS
Record
retention
63.5590
63.10(
b)(
1)

Documentation
supporting
initial
notification
and
notification
of
compliance
status
63.5585
63.10(
b)(
2)(
xiv)

Records
of
performance
tests,
CEMS
performance
evaluations,
and
other
initial
compliance
demonstrations
63.5585
63.10(
b)(
2)(
viii)

Records
of
startup,
shutdown,
and
malfunction
(
including
startup,
shutdown,
and
malfunction
plan)
63.5515,
63.5585
63.6(
e)(
3),
63.10(
b)(
2)(
i)­(
v)

Site­
specific
monitoring
plan
63.5545,
63.5585
63.8(
d)(
2)

Records
for
each
continuous
emissions
monitoring
system
63.5585
63.8(
d)(
3),
63.8(
f)(
6)(
i),
63.10(
b)(
2)(
vi)­(
xi),
63.10(
c)

Records
for
each
continuous
parameter
monitoring
system
63.5585
63.10(
b)(
2)(
vi)­(
xi),
63.10(
c)
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
(
continued)
Attachment
1
Requirement
Regulation
citation
General
Provisions/
other
regulation
citation
2
Records
of
closed­
loop
systems
63.5585
Records
of
nitrogen
systems
63.5585
Records
of
material
balances
63.5585
Records
of
calculations
63.5585
Records
for
extended
cookout
63.5585
Records
for
equipment
leaks
63.5585
63.181
or
63.1038
Records
for
wastewater
63.5585
63.105,
63.147,
63.152(
f)
and
(
g)

Records
for
closed­
vent
systems
63.5585
63.148(
i)

Records
for
bypass
lines
63.5585
Records
for
heat
exchanger
systems
63.5585
63.104(
f)(
1)

Records
for
storage
vessel
control
device
maintenance
63.5585
Records
for
safety
devices
63.5585
ATTACHMENT
2
Description
of
Respondent
Activities
Attachment
2
1
DESCRIPTION
OF
RESPONDENT
ACTIVITIES
(
1)
Read
Instructions
represents
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standards
and
understanding
how
they
apply
to
the
respective
emission
points
at
a
cellulose
products
manufacturing
facility.

(
2)
Create
Information
represents
the
activities
involving
testing,
retesting,
establishing
operating
parameter
limits,
and
analyzing
point­
by­
point
applicability.
Monitor­
related
refit,
calibration,
and
maintenance
activities
are
also
included
under
this
heading.
Because
respondents
are
expected
to
hire
outside
contractors
to
conduct
the
performance
tests,
these
activities
are
not
included
in
the
burden
tables.
Instead,
the
costs
associated
with
the
performance
test
are
included
as
capital
costs
and
are
discussed
in
the
text.

(
3)
Gather
Existing
Information
represents
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data,
and
other
related
activities.
These
activities
do
not
include
the
monitoring
of
equipment
leak
components,
which
is
included
as
part
of
the
leak
detection
and
repair
program.

(
4)
Write
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
rule
requires
no
standard
forms,
these
activities
relate
to
the
preparation
of
formal
reports
and
cover
letters,
as
appropriate.

(
5)
Plan
Activities
represents
such
burdens
as
design,
redesign,
and
scheduling,
as
well
as
drafting
the
implementation
plan,
and
selecting
methods
of
compliance.
The
costs
for
planning
and
selection
are
included
in
the
capital
costs
for
the
performance
test,
as
explained
in
item
(
2)
above.

(
6)
Enter
Information
represents
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance,
and
appropriate
reports
and
records
required
as
a
result.

(
7)
Train
Personnel
represents
the
activities
involved
in
communicating
specific
definitions,
compliance
options,
and
other
requirements,
such
as
recordkeeping,
monitoring,
and
reporting.
An
average
cellulose
products
manufacturing
facility
may
elect
to
provide
classroom
instructions
for
all
workers
directly
impacted
by
the
requirements;
however,
the
rule
does
not
require
specific
training
itself.
ATTACHMENT
3
Methods
Used
in
Cost
Estimates
Attachment
3
1
METHODS
USED
IN
COST
ESTIMATES
(
a)
Costs
for
Monitoring
Equipment
The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
methods
and
assumptions
presented
in
the
memorandum
"
Revised
Costs
and
Environmental
Impacts
of
Control
Technology
Options
for
the
Cellulose
Products
Manufacturing
Industry."
(
See
docket
no.
A­
99­
39,
item
no.
IV­
B­
09.)

Facilities
were
assumed
to
choose
to
monitor
control
device
operating
parameters
instead
of
operating
CEMS.
Table
1
presents
the
capital
costs
for
monitoring
equipment
estimated
for
each
facility
in
the
cellulose
products
manufacturing
industry.

The
annualized
capital
costs
for
monitoring
equipment
were
calculated
as
a
sum
of
the
capital
recovery
cost,
administrative
charges,
insurance,
and
property
taxes.
The
capital
recovery
cost
was
determined
as
a
product
of
a
capital
recovery
factor
and
the
total
capital
cost.
The
capital
recovery
factor
was
estimated
to
be
0.2439,
based
on
a
5­
year
equipment
life
and
7
percent
interest
rate.
The
administrative
charges,
insurance,

and
property
taxes
were
calculated
as
4
percent
of
the
capital
cost.
Table
1
presents
the
annualized
capital
costs
for
monitoring
equipment
estimated
for
each
facility
in
the
cellulose
products
manufacturing
industry.

Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
monitoring
equipment
for
the
first
6
years
after
the
effective
date
of
the
rule
were
estimated
as
shown
in
Table
3.

(
b)
Costs
for
File
Cabinets
The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility.
A
capital
cost
of
$
235
was
assumed
per
file
cabinet.
The
annualized
capital
costs
Attachment
3
2
for
monitoring
equipment
were
calculated
as
a
sum
of
the
capital
recovery
cost,
administrative
charges,
insurance,
and
property
taxes.
The
capital
recovery
cost
was
determined
as
a
product
of
a
capital
recovery
factor
and
the
total
capital
cost.
The
capital
recovery
factor
was
estimated
to
be
0.1098,
based
on
a
15­
year
equipment
life
and
7
percent
interest
rate.
The
administrative
charges,
insurance,
and
property
taxes
were
calculated
as
4
percent
of
the
capital
cost.
The
average
annualized
capital
cost
per
facility
for
file
cabinets
was
estimated
to
be
$
35.
By
applying
these
unit
costs
to
the
13
facilities
subject
to
the
cellulose
products
manufacturing
NESHAP,
the
capital
costs
for
file
cabinets
were
estimated
to
be
$
3,055,
and
the
annualized
capital
costs
were
estimated
to
be
$
455.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
file
cabinets
for
the
first
6
years
after
the
effective
date
of
the
rule
were
estimated
as
shown
in
Table
3.

(
c)
Costs
for
Performance
Tests
The
capital
costs
associated
with
performance
testing
include
the
costs
for
organic
HAP
performance
tests
for
process
vents
and
wastewater
systems
at
cellulose
ether
facilities
and
the
costs
for
total
sulfide
performance
tests
for
process
vents
at
viscose
process
facilities.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:

1.
The
capital
cost
per
test
is
$
10,000;
for
process
vents,

this
cost
includes
the
cost
for
testing
both
the
inlet
and
outlet
of
the
control
device.

2.
One
performance
test
will
be
performed
for
each
process
vent
control
device
and
each
wastewater
system,
as
applicable.

3.
Ten
facilities
(
four
cellulose
ether
facilities
and
six
viscose
process
facilities)
will
be
required
to
conduct
an
initial
performance
test
for
their
process
vents.

4.
Four
cellulose
ether
facilities
will
be
required
to
conduct
an
initial
performance
test
for
their
wastewater
systems.
Attachment
3
3
5.
No
performance
test
is
required
for
three
viscose
process
facilities,
which
are
using
recovery
devices
to
meet
the
process
vent
emission
limit;
these
three
facilities
will
be
required
to
conduct
an
initial
compliance
demonstration
based
on
the
material
balance
for
their
process;
the
cost
for
the
initial
compliance
demonstration
is
included
in
the
notification
of
compliance
status
labor
cost
in
Table
1a
of
Attachment
4.

6.
The
facilities
required
to
conduct
an
initial
performance
test
will
conduct
the
test
during
the
fourth
year
after
the
effective
date
of
the
rule
(
i.
e.,
the
first
year
after
their
compliance
date).

7.
Based
on
the
assumptions
that
5
percent
of
the
10
testing
facilities
will
fail
the
first
test
and
50
percent
of
the
failing
facilities
will
conduct
a
retest,
no
facilities
are
expected
to
have
to
retest.

To
determine
the
total
capital
cost
for
performance
tests,

the
unit
cost
($
10,000)
was
applied
to
the
process
vent
control
devices
at
each
of
the
10
cellulose
products
manufacturing
facilities
and
to
the
wastewater
system
at
each
of
the
4
cellulose
ether
facilities
as
shown
in
Table
2.
Using
a
capital
recovery
factor
of
0.1098,
the
average
annualized
capital
cost
per
facility
for
performance
tests
was
estimated.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,
or
property
taxes
were
estimated
for
performance
testing.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
performance
testing
for
the
first
6
years
after
the
effective
date
of
the
rule
were
estimated
as
shown
in
Table
3.

(
d)
Costs
for
Operation
and
Maintenance
Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
recordkeeping
and
Attachment
3
4
reporting,
and
overhead
for
the
monitoring
equipment.
The
monitoring
O&
M
costs
were
estimated
based
on
methods
and
assumptions
presented
in
the
memorandum
"
Revised
Costs
and
Environmental
Impacts
of
Control
Technology
Options
for
the
Cellulose
Products
Manufacturing
Industry."
(
See
docket
no.

A­
99­
39,
item
no.
IV­
B­
09.)
Table
4
presents
the
annual
monitoring
O&
M
costs
estimated
for
each
facility
in
the
cellulose
products
manufacturing
industry.
Using
these
estimated
costs,

the
monitoring
O&
M
costs
for
the
first
6
years
after
the
effective
date
of
the
rule
were
estimated
as
shown
in
Table
6.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
file
storage,
photocopying,
and
postage.

File
storage
and
photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
30.18/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Table
5
presents
the
annual
file
storage,

photocopy,
and
postage
O&
M
costs
for
the
cellulose
products
manufacturing
industry.
Using
these
estimated
costs,
the
file
storage,
photocopying,
and
postage
O&
M
costs
for
the
first
6
years
after
the
effective
date
of
the
rule
were
estimated
as
shown
in
Table
6.
Attachment
3
5
TABLE
1.
MONITORING
EQUIPMENT
COSTS
Industry
Facility
Facility
location
Capital
cost
Annualized
capital
cost
a
Cellulose
food
casing
Devro­
Teepak,
Inc.
Danville,
IL
$
90,383
$
25,659
Viskase
Corp.
Loudon,
TN
$
38,457
$
10,918
Viskase
Corp.
Osceola,
AR
$
31,523
$
8,950
Rayon
Lenzing
Fibers
Corp.
Lowland,
TN
$
36,306
$
10,307
Cellulosic
sponge
Nylonge
Corp.
Elyria,
IL
$
168,791
$
47,920
Spontex,
Inc.
Columbia,
TN
$
21,198
$
6,018
3M
Corp.
Prairie
du
Chien,
WI
$
21,198
$
6,018
3M
Corp.
Tonawanda,
NY
$
25,367
$
7,202
Cellophane
UCB
Films,
Inc.
Tecumseh,
KS
$
40,746
$
11,568
Cellulose
ether
Dow
Chemical
Co.
Institute,
WV
$
18,866
$
5,356
Dow
Chemical
Co.
Midland,
MI
$
36,167
$
10,268
Dow
Chemical
Co.
Plaquemine,
LA
$
36,794
$
10,446
Hercules
Inc.
Hopewell,
VA
$
30,875
$
8,765
Total
$
596,672
$
169,394
a
Annualized
capital
cost
for
monitoring
equipment
=
0.2839
*
capital
cost.
Attachment
3
6
TABLE
2.
PERFORMANCE
TEST
COSTSa
Industry
Facility
Facility
location
Process
vent
control
devices
to
test
Wastewater
systems
to
test
Capital
costb
Annualized
capital
costc
Cellulose
food
casing
Devro­
Teepak,
Inc.
Danville,
IL
11
­­
$
110,000
$
12,078
Viskase
Corp.
Loudon,
TN
4
­­
$
40,000
$
4,392
Viskase
Corp.
Osceola,
AR
3
­­
$
30,000
$
3,294
Cellulosic
sponge
Nylonge
Corp.
Elyria,
IL
2
­­
$
20,000
$
2,196
Spontex,
Inc.
Columbia,
TN
2
­­
$
20,000
$
2,196
3M
Corp.
Prairie
du
Chien,
WI
2
­­
$
20,000
$
2,196
Cellulose
ether
Dow
Chemical
Co.
Institute,
WV
4
1
$
50,000
$
5,490
Dow
Chemical
Co.
Midland,
MI
5
1
$
60,000
$
6,588
Dow
Chemical
Co.
Plaquemine,
LA
6
1
$
70,000
$
7,686
Hercules
Inc.
Hopewell,
VA
16
1
$
170,000
$
18,666
Total
$
590,000
$
64,782
a
No
performance
test
will
be
required
for
Lenzing
Fibers
Corp.,
3M
Corp.
(
Tonawanda,
NY),
and
UCB
Films,
Inc.
because
these
three
facilities
are
using
recovery
devices
to
meet
the
emission
limit;
these
three
facilities
will
only
be
required
to
conduct
an
initial
compliance
demonstration
based
on
the
material
balance
for
their
process.
b
Unit
capital
cost
of
performance
test
is
$
10,000.
c
Annualized
capital
cost
for
performance
tests
=
0.1098
*
capital
cost.
Attachment
3
7
TABLE
3.
CAPITAL
AND
ANNUALIZED
CAPITAL
COSTS
FOR
THE
FIRST
6
YEARS
AFTER
THE
EFFECTIVE
DATE
Capital
cost
Monitoring
equipment
File
cabinets
Performance
tests
Total
capital
cost
Year
1
$
0
$
0
$
0
$
0
Year
2
$
0
$
0
$
0
$
0
Year
3
$
596,671
$
3,055
$
0
$
599,726
TOTAL
(
Years
1­
3)
$
596,671
$
3,055
$
0
$
599,726
Year
4
$
0
$
0
$
590,000
$
590,000
Year
5
$
0
$
0
$
0
$
0
Year
6
$
0
$
0
$
0
$
0
TOTAL
(
Years
4­
6)
$
0
$
0
$
590,000
$
590,000
Annualized
capital
cost
Monitoring
equipment
File
cabinets
Performance
tests
Total
annualized
capital
cost
Year
1
$
0
$
0
$
0
$
0
Year
2
$
0
$
0
$
0
$
0
Year
3
$
169,394
$
455
$
0
$
169,849
AVERAGE
(
Years
1­
3)
$
56,465
$
152
$
0
$
56,616
Year
4
$
169,394
$
455
$
64,782
$
234,631
Year
5
$
169,394
$
455
$
64,782
$
234,631
Year
6
$
169,394
$
455
$
64,782
$
234,631
AVERAGE
(
Years
4­
6)
$
169,394
$
455
$
64,782
$
234,631
Attachment
3
8
TABLE
4.
MONITORING
O&
M
COSTS
Industry
Facility
Facility
location
O&
M
costa
Cellulose
food
casing
Devro­
Teepak,
Inc.
Danville,
IL
$
40,315
Viskase
Corp.
Loudon,
TN
$
14,639
Viskase
Corp.
Osceola,
AR
$
11,106
Rayon
Lenzing
Fibers
Corp.
Lowland,
TN
$
3,671
Cellulosic
sponge
Nylonge
Corp.
Elyria,
IL
$
89,181
Spontex,
Inc.
Columbia,
TN
$
6,448
3M
Corp.
Prairie
du
Chien,
WI
$
5,936
3M
Corp.
Tonawanda,
NY
$
9,205
Cellophane
UCB
Films,
Inc.
Tecumseh,
KS
$
13,159
Cellulose
ether
Dow
Chemical
Co.
Institute,
WV
$
1,986
Dow
Chemical
Co.
Midland,
MI
$
12,218
Dow
Chemical
Co.
Plaquemine,
LA
$
12,302
Hercules
Inc.
Hopewell,
VA
$
3,390
Total
$
223,556
a
Monitoring
O&
M
cost
includes
costs
for
operating
labor,
maintenance
labor,
maintenance
materials
and
supplies,
recordkeeping
and
reporting,
and
overhead.
9
Attachment
3
TABLE
5.
FILE
STORAGE,
PHOTOCOPY,
AND
POSTAGE
O&
M
COSTS
Cost
item
File
storage
and
photocopy
cost/

responsea
Postage
cost/
response
Responses/

respondent
Respondents/

year
Responses/

year
File
storage
and
photocopy
cost
Postage
cost
Total
costb
Notification
of
applicability
$
15.09
$
7.63
1
13
13
$
196
$
99
$
295
Notification
of
performance
test
$
15.09
$
7.63
1
14
14
$
211
$
107
$
318
Notification
of
compliance
status
$
15.09
$
7.63
1
13
13
$
196
$
99
$
295
Semiannual
compliance
report
$
15.09
$
7.63
2
13
26
$
392
$
198
$
591
a
File
storage
and
photocopy
cost/
response
=
0.5
hr/
response
*
$
30.18/
hr
=
$
15.09/
response.

b
Numbers
may
not
add
exactly
due
to
rounding.
10
Attachment
3
TABLE
6.
O&
M
COSTS
FOR
THE
FIRST
6
YEARS
AFTER
THE
EFFECTIVE
DATE
Monitoring
O&
M
cost
File
storage,
photocopy,
and
postage
O&
M
cost
Total
O&
M
cost
Notification
of
applicability
Notification
of
performance
test
Notification
of
compliance
status
Semiannual
compliance
report
Total
Year
1
$
0
$
295
$
0
$
0
$
0
$
295
$
295
Year
2
$
0
$
0
$
0
$
0
$
0
$
0
$
0
Year
3
$
0
$
0
$
318
$
0
$
0
$
318
$
318
AVERAGE
(
Years
1­
3)
$
0
$
98
$
106
$
0
$
0
$
204
$
204
Year
4
$
223,556
$
0
$
0
$
295
$
591
$
886
$
224,442
Year
5
$
223,556
$
0
$
0
$
0
$
591
$
591
$
224,147
Year
6
$
223,556
$
0
$
0
$
0
$
591
$
591
$
224,147
AVERAGE
(
Years
4­
6)
$
223,556
$
0
$
0
$
98
$
591
$
689
$
224,245
ATTACHMENT
4
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
after
the
Effective
Date
Attachment
4
1
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
AFTER
THE
EFFECTIVE
DATE
1.
The
Information
Collected
 
­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
Part
A
of
the
Supporting
Statement,
there
are
two
one­
time
notifications
that
existing
sources
must
complete
in
the
3
years
between
the
effective
date
of
the
rule
and
the
compliance
date
for
existing
sources.
These
notifications
include:
(
1)
determining
applicability
and
notifying
EPA
that
the
facility
is
subject
to
the
rule
and
(
2)
notifying
EPA
of
upcoming
performance
tests.

In
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
(
i.
e.,
the
3
years
after
the
existing
source
compliance
date),
existing
sources
must
submit
other
one­
time
notifications
and
reports,
and
ongoing
recordkeeping
and
reporting
begins.
In
the
fourth
year
after
the
effective
date
of
the
rule,
existing
sources
will
conduct
their
performance
tests
or
other
initial
compliance
demonstrations
and
submit
their
initial
notifications
of
compliance
status.
Existing
sources
also
will
begin
ongoing
monitoring
and
recordkeeping
for
various
operating
parameters,
equipment
leaks,
etc.
The
sources
will
begin
to
submit
semiannual
reports
that
include
information
about
deviations,
periods
of
SSM,
wastewater,
equipment
leaks,
etc.

The
respondent
activities
required
by
the
rule
for
existing
major
sources
in
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
are
listed
in
Tables
1a
and
1b
of
this
attachment.
Table
1a
presents
the
respondent
activities
for
the
fourth
year
after
the
effective
date
of
the
rule,
and
Table
1b
presents
the
respondent
activities
for
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.
The
EPA
does
not
expect
Attachment
4
2
any
difference
in
respondent
activities
for
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.
The
respondent
activities
are
described
in
more
detail
in
Attachment
2,

Description
of
Respondent
Activities.
No
new
major
source
cellulose
products
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.
3
Attachment
4
TABLE
1a.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­

FOURTH
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
instructions
N/
A
B.
Required
activities
°
Initial
compliance
demonstration
Included
in
3E
C.
Create
information
Included
in
3E
D.
Gather
existing
information
Included
in
3E
E.
Write
report
°
Notification
of
compliance
status
With
performance
test
c
80
1
80
14
1,120
56
112
1,288
$
60,925
Without
performance
test
d
160
1
160
9
1,440
72
144
1,656
$
78,332
°
Semiannual
compliance
report
No
deviations
e
8
2
16
10
160
8
16
184
$
8,704
Deviations
e
16
2
48
3
96
5
10
110
$
5,222
SSM
f
8
2
16
13
208
10
21
239
$
11,315
Equipment
leaks
g
303
2
606
4
2,424
121
242
2,788
$
131,858
Wastewater
Included
in
4E
Other
h
8
2
16
13
208
10
21
239
$
11,315
4.
Recordkeeping
requirements
A.
Read
instructions
N/
A
4
Attachment
4
TABLE
1a.
(
continued)

Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
N/
A
°
Records
of
SSM
i
1.5
52
78
13
1,014
51
101
1,166
$
55,159
°
Records
of
CPMS
data
j
Record
continuously
monitored
parameters
1
365
365
13
4,745
237
475
5,457
$
258,114
Compile
data
24
2
48
13
624
31
62
718
$
33,944
Enter/
verify
information
for
semiannual
report
16
2
32
13
416
21
42
478
$
22,629
°
Records
of
closed­
loop
systems
k
2
2
4
1
2
0.1
0.2
2
$
109
°
Records
of
nitrogen
systems
l
2
2
4
9
18
0.9
2
21
$
979
°
Records
of
material
balances
m
8
2
16
9
144
7
14
166
$
7,833
°
Records
of
supporting
calculations
n
8
2
16
13
208
10
21
239
$
11,315
°
Records
for
extended
cookout
o
8
2
16
1
16
0.8
2
18
$
870
°
Records
for
equipment
leaks
Included
in
3E
°
Other
records
Included
in
3E
F.
Time
for
refresher
training
for
personnel
p
16
1
16
13
208
10
21
239
$
11,315
G.
Time
for
audits
N/
A
5
Attachment
4
TABLE
1a.
(
continued)

Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
Total
burden
and
cost
nationwide
(
salary)
q
13,051
653
1,305
15,009
$
709,935
Average
cost
per
facility
r
13
$
54,610
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities).
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
Respondents
per
year
are
based
on
6
viscose
process
facilities
conducting
a
performance
test
for
their
process
vents
and
4
cellulose
ether
facilities
conducting
separate
performance
tests
for
their
process
vents
and
wastewater
systems,
with
the
facilities
submitting
one
notification
of
compliance
status
for
all
performance
tests
conducted
at
the
facility.
The
notification
of
compliance
status
includes
the
reports
of
all
of
these
performance
tests.

d
Respondents
per
year
are
based
on
9
viscose
process
facilities
conducting
an
initial
compliance
demonstration
for
their
process
vents
based
on
the
material
balance
for
their
facility.
The
notification
of
compliance
status
includes
the
material
balance
calculations
conducted
at
the
facility.

e
Occurrences
per
respondent
are
based
on
having
semiannual
report
submitted
twice
each
year.
Respondents
per
year
assume
that
20
percent
of
the
respondents
will
have
deviations
from
the
standard,
and
80
percent
will
have
no
deviations.

f
Hours
per
occurrence
assume
that
the
hours
for
SSM
report
are
the
same
as
for
semiannual
report
of
no
deviations.
Occurrences
per
respondent
are
based
on
having
it
submitted
with
semiannual
report
twice
each
year.
Respondents
per
year
are
based
on
every
facility
submitting
an
SSM
report.

g
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
costs
for
the
LDAR
program
are
estimated
to
be
40
percent
of
monitoring
and
repair
labor
(
40%
*
$
165,037
=
$
66,015
total
and
$
16,504
per
facility).
Hours
per
occurrence
are
based
on
this
cost
divided
by
the
composite
hourly
labor
rate
($
47.75
+
0.05
*
$
72.58
+
0.1
*
$
30.18
=
$
54.40).
Respondents
per
year
are
based
on
the
4
cellulose
ether
facilities
subject
to
LDAR
requirements.

h
Other
reports
include
reports
on
changes
in
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance.
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
assumed
to
include
all
13
respondents.

i
Occurrences
per
respondent
are
based
on
weekly
records
of
SSM.

j
Includes
process
vent,
storage
tank,
and
wastewater
monitoring
and
inspections.
Occurrences
per
respondent
are
based
on
daily
records
of
parameters
and
compiling,
entering,
and
verifying
data
for
semiannual
report.

k
Hours
per
occurrence
are
assumed
to
be
2
hours,
and
respondents
per
year
are
based
on
the
1
cellulose
ether
facility
with
a
closed­
loop
system.

l
Hours
per
occurrence
are
assumed
to
be
2
hours,
and
respondents
per
year
are
based
on
the
9
viscose
process
facilities
with
CS2
unloading
and
storage
operations.

m
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
based
on
the
9
viscose
process
facilities
complying
by
using
material
balances.

n
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
assumed
to
include
all
13
respondents.

o
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
based
on
the
1
cellulose
ether
facility
that
uses
extended
cookout.

p
Hours
per
occurrence
assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.
6
Attachment
4
TABLE
1a.
(
continued)

q
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.

r
The
average
cost
per
facility
is
calculated
by
dividing
the
total
cost
by
the
number
of
facilities
(
13)
subject
to
the
standards.
7
Attachment
4
TABLE
1b.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­

FIFTH
AND
SIXTH
YEARS
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A
.
Read
instructions
N/
A
B.
Required
activities
N/
A
C.
Create
information
Included
in
3E
D
.
Gather
existing
information
Included
in
3E
E.
Write
report
°
Semiannual
compliance
report
No
deviations
c
8
2
16
10
160
8
16
184
$
8,704
Deviations
c
16
2
48
3
96
5
10
110
$
5,222
SSM
d
8
2
16
13
208
10
21
239
$
11,315
Equipment
leaks
e
303
2
606
4
2,424
121
242
2,788
$
131,858
Wastewater
Included
in
4E
Other
f
8
2
16
13
208
10
21
239
$
11,315
4.
Recordkeeping
requirements
A
.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D
.
Develop
record
system
N/
A
8
Attachment
4
TABLE
1b.
(
continued)

Burden
item
(
A)
Technical
hours
per
occurrence
(
B)
Occurrences
per
respondent
per
year
(
C)
Technical
hours
per
respondent
per
year
(
C
=
A
*
B)
(
D)
Respondents
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Respondent
hours
per
year
(
H
=
E
+
F
+

G)
(
I)
Labor
cost,
$
b
E.
Time
to
enter
information
°
Records
of
SSM
g
1.5
52
78
13
1,014
51
101
1,166
$
55,159
°
Records
of
CPMS
data
h
Record
continuously
monitored
parameters
1
365
365
13
4,745
237
475
5,457
$
258,114
Compile
data
24
2
48
13
624
31
62
718
$
33,944
Enter/
verify
information
for
semiannual
report
16
2
32
13
416
21
42
478
$
22,629
°
Records
of
closed­
loop
systems
i
2
2
4
1
2
0.1
0.2
2
$
109
°
Records
of
nitrogen
systems
j
2
2
4
9
18
0.9
2
21
$
979
°
Records
of
material
balances
k
8
2
16
9
144
7
14
166
$
7,833
°
Records
of
supporting
calculations
l
8
2
16
13
208
10
21
239
$
11,315
°
Records
for
extended
cookout
m
8
2
16
1
16
0.8
2
18
$
870
°
Records
for
equipment
leaks
Included
in
3E
°
Other
records
Included
in
3E
F.
Time
for
refresher
training
for
personnel
n
16
1
16
13
208
10
21
239
$
11,315
G
.
Time
for
audits
N/
A
Total
burden
and
cost
nationwide
(
salary)
o
10,491
525
1,049
12,065
$
570,679
Average
cost
per
facility
p
13
$
43,898
9
Attachment
4
TABLE
1b.
(
continued)

a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
Occurrences
per
respondent
are
based
on
having
semiannual
report
submitted
twice
each
year.
Respondents
per
year
assume
that
20
percent
of
the
respondents
will
have
deviations
from
the
standard,
and
80
percent
will
have
no
deviations.

d
Hours
per
occurrence
assume
that
the
hours
for
SSM
report
are
the
same
as
for
semiannual
report
of
no
deviations.
Occurrences
per
respondent
are
based
on
having
it
submitted
with
semiannual
report
twice
each
year.
Respondents
per
year
are
based
on
every
facility
submitting
an
SSM
report.

e
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
costs
for
the
LDAR
program
are
estimated
to
be
40
percent
of
monitoring
and
repair
labor
(
40%
*
$
165,037
=
$
66,015
total
and
$
16,504
per
facility).
Hours
per
occurrence
are
based
on
this
cost
divided
by
the
composite
hourly
labor
rate
($
47.75
+
0.05
*
$
72.58
+
0.1
*
$
30.18
=
$
54.40).
Respondents
per
year
are
based
on
the
4
cellulose
ether
facilities
subject
to
LDAR
requirements.

f
Other
reports
include
reports
on
changes
in
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance.
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
assumed
to
include
all
13
respondents.

g
Occurrences
per
respondent
are
based
on
weekly
records
of
SSM.

h
Includes
process
vent,
storage
tank,
and
wastewater
monitoring
and
inspections.
Occurrences
per
respondent
are
based
on
daily
records
of
parameters
and
compiling,
entering,
and
verifying
data
for
semiannual
report.

i
Hours
per
occurrence
are
assumed
to
be
2
hours,
and
respondents
per
year
are
based
on
the
1
cellulose
ether
facility
with
a
closed­
loop
system.

j
Hours
per
occurrence
are
assumed
to
be
2
hours,
and
respondents
per
year
are
based
on
the
9
viscose
process
facilities
with
CS2
unloading
and
storage
operations.

k
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
based
on
the
9
viscose
process
facilities
complying
by
using
material
balances.

l
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
assumed
to
include
all
13
respondents.

m
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
respondents
per
year
are
based
on
the
1
cellulose
ether
facility
that
uses
extended
cookout.

n
Hours
per
occurrence
assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

o
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.

p
The
average
cost
per
facility
is
calculated
by
dividing
the
total
cost
by
the
number
of
facilities
(
13)
subject
to
the
standards.
Attachment
4
10
(
b)
Agency
Activities
As
shown
in
Part
A
of
the
Supporting
Statement,
in
the
3
years
between
the
effective
date
of
the
rule
and
compliance
date
for
existing
sources,
EPA
will
review
the
notifications
of
applicability
and
the
notifications
of
performance
tests
submitted
by
existing
sources.

In
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
(
i.
e.,
the
3
years
after
the
existing
source
compliance
date),
EPA
will
review
other
notifications
and
reports
submitted
by
existing
sources.
In
the
fourth
year
after
the
effective
date
of
the
rule,
EPA
will
review
the
notifications
of
compliance
status
and
semiannual
compliance
reports
for
existing
sources.
The
EPA
will
continue
to
review
the
semiannual
compliance
reports
in
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.

The
Agency
activities
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
are
listed
in
Tables
2a
and
2b
of
this
attachment.
Table
2a
presents
the
Agency
activities
for
the
fourth
year
after
the
effective
date
of
the
rule.

Table
2b
presents
the
Agency
activities
for
the
fifth
and
sixth
year
after
the
effective
date
of
the
rule.
The
EPA
does
not
expect
any
difference
in
Agency
activities
for
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.
11
Attachment
4
TABLE
2a.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­

FOURTH
YEAR
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
(
C)

Hours
per
facility
per
year
(
C
=
A
*
B)
(
D)
Facilities
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*
0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Agency
hours
per
year
(
H
=
E
+
F
+

G)
(
I)

Labor
cost
per
year,
$
b
1.
Attend
initial
performance
test
c
40
1
40
1
40
2
4
46
$
2,176
2.
Attend
repeat
performance
test
d
40
1
40
0
0
0
0
0
$
0
3.
Litigation
e
2,080
1
2,080
0
0
0
0
0
$
0
4.
Excess
emissions­­

enforcement
activities
f
120
1
120
0
0
0
0
0
$
0
5.
Report
review
A.
Review
notification
of
compliance
status
°
With
performance
test
g
40
1
40
14
560
28
56
644
$
30,462
°
Without
performance
test
h
40
1
40
9
360
18
36
414
$
19,583
B.
Review
semiannual
compliance
report
°
No
deviations
i
2
2
4
10
40
2
4
46
$
2,176
°
Deviations
i
8
2
16
3
48
2
5
55
$
2,611
°
SSM
j
2
2
4
13
52
3
5
60
$
2,829
°
Equipment
leaks
k
8
2
16
4
64
3
6
74
$
3,481
°
Wastewater
k
8
2
16
4
64
3
6
74
$
3,481
°
Other
l
2
2
4
13
52
3
5
60
$
2,829
Total
burden
and
cost
(
salary)
m
1,280
64
128
1,472
$
69,628
Travel
expenses
for
tests
attended
n
$
500
Total
cost
=
total
cost
(
salary)
+
travel
expenses
$
70,128
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
Facilities
per
year
assumes
EPA
personnel
will
attend
8
percent
of
initial
performance
tests
(
0.08
*
13
facilities
=
1
facility).
12
Attachment
4
TABLE
2a.
(
continued)

d
Facilities
per
year
assumes
that
5
percent
of
facilities
will
fail
the
first
performance
test
and
50
percent
of
these
facilities
will
repeat
the
test,
and
EPA
personnel
will
attend
10
percent
of
the
retests
(
0.05
*
0.5
*
0.1
*
10
facilities
=
0
facilities).

e
Facilities
per
year
assume
that
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
13
facilities
=
0
facilities).

f
Facilities
per
year
assumed
that
10
percent
of
the
affected
facilities
will
be
required
to
retest
as
a
result
of
deviations,
and
EPA
personnel
will
attend
10
percent
of
these
tests
(
0.1
*
0.1
*
13
facilities
=
0
facilities).

g
Facilities
per
year
are
based
on
6
viscose
process
facilities
conducting
a
performance
test
for
their
process
vents
and
4
cellulose
ether
facilities
conducting
separate
performance
tests
for
their
process
vents
and
wastewater
systems,
with
the
facilities
submitting
one
notification
of
compliance
status
for
all
performance
tests
conducted
at
the
facility.
The
notification
of
compliance
status
includes
the
reports
of
all
of
these
performance
tests.

h
Facilities
per
year
are
based
on
9
viscose
process
facilities
conducting
an
initial
compliance
demonstration
based
on
the
material
balance
for
their
facility.

The
notification
of
compliance
status
includes
the
material
balance
calculations.

i
Occurrences
per
respondent
are
based
on
having
semiannual
report
submitted
twice
each
year.
Facilities
per
year
assume
that
20
percent
of
the
facilities
will
have
deviations
from
the
standard,
and
80
percent
will
have
no
deviations.

j
Hours
per
occurrence
assume
that
the
hours
to
review
SSM
report
are
the
same
as
for
semiannual
report
of
no
deviations.
Occurrences
per
respondent
are
based
on
having
it
submitted
with
semiannual
report
twice
each
year.
Facilities
per
year
are
based
on
every
facility
submitting
an
SSM
report.

k
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
facilities
per
year
are
based
on
the
4
cellulose
ether
facilities
subject
to
LDAR
and
wastewater
requirements.

l
Other
reports
include
reports
on
changes
in
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance.
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
facilities
per
year
are
assumed
to
include
all
13
respondents.

m
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.

n
Tests
attended
=
1
initial
test
+
0
repeat
tests
+
0
excess
emissions
enforcement
tests
=
1
test.
Travel
expenses
for
tests
attended
=
(
one
person
*
1
test/
yr
*

2
days/
test
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trips/
yr)
=
$
500.
13
Attachment
4
TABLE
2b.
ANNUAL
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
­

FIFTH
AND
SIXTH
YEARS
AFTER
THE
EFFECTIVE
DATE
Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
(
C)

Hours
per
facility
per
year
(
C
=
A
*
B)
(
D)
Facilities
per
year
a
(
E)
Technical
hours
per
year
(
E
=
C
*
D)
(
F)
Management
hours
per
year
(
F
=
E
*

0.05)
(
G)
Clerical
hours
per
year
(
G
=
E
*
0.1)
(
H)
Agency
hours
per
year
(
H
=
E
+
F
+

G)
(
I)

Labor
cost
per
year,
$
b
1.
Attend
initial
performance
test
N/
A
2.
Attend
repeat
performance
test
N/
A
3.
Litigation
c
2,080
1
2,080
0
0
0
0
0
$
0
4.
Excess
emissions­­

enforcement
activities
d
120
1
120
0
0
0
0
0
$
0
5.
Report
review
A.
Review
semiannual
compliance
report
°
No
deviations
e
2
2
4
10
40
2
4
46
$
2,176
°
Deviations
e
8
2
16
3
48
2
5
55
$
2,611
°
SSM
f
2
2
4
13
52
3
5
60
$
2,829
°
Equipment
leaks
g
8
2
16
4
64
3
6
74
$
3,481
°
Wastewater
g
8
2
16
4
64
3
6
74
$
3,481
°
Other
h
2
2
4
13
52
3
5
60
$
2,829
Total
burden
and
cost
(
salary)
i
320
16
32
368
$
17,407
Travel
expenses
for
tests
attended
$
0
Total
cost
=
total
cost
(
salary)
+
travel
expenses
$
17,407
a
There
are
13
existing
major
source
cellulose
products
manufacturing
facilities,
which
include
3
cellulose
food
casing,
1
rayon,
1
cellophane,
4
cellulosic
sponge,
and
4
cellulose
ether
facilities.
No
new
major
source
cellulose
manufacturing
facilities
are
projected
to
be
built
within
the
next
5
years.

b
Costs
assume
a
rate
of
$
47.75/
hour
for
technical
labor,
$
72.58/
hour
for
management
labor,
and
$
30.18/
hour
for
clerical
labor.

c
Facilities
per
year
assume
that
1
percent
of
the
affected
facilities
will
be
involved
in
litigation
(
0.01
*
13
facilities
=
0
facilities).

d
Facilities
per
year
assumed
that
10
percent
of
the
affected
facilities
will
be
required
to
retest
as
a
result
of
deviations,
and
EPA
personnel
will
attend
10
percent
of
these
tests
(
0.1
*
0.1
*
13
facilities
=
0
facilities).

e
Occurrences
per
respondent
are
based
on
having
semiannual
report
submitted
twice
each
year.
Facilities
per
year
assume
that
20
percent
of
the
facilities
will
have
deviations
from
the
standard,
and
80
percent
will
have
no
deviations.

f
Hours
per
occurrence
assume
that
the
hours
to
review
SSM
report
are
the
same
as
for
semiannual
report
of
no
deviations.
Occurrences
per
respondent
are
based
on
having
it
submitted
with
semiannual
report
twice
each
year.
Facilities
per
year
are
based
on
every
facility
submitting
an
SSM
report.
14
Attachment
4
TABLE
2b.
(
continued)

g
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
facilities
per
year
are
based
on
the
4
cellulose
ether
facilities
subject
to
LDAR
and
wastewater
requirements.

h
Other
reports
include
reports
on
changes
in
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance.
Hours
per
occurrence
are
assumed
to
be
8
hours,
and
facilities
per
year
are
assumed
to
include
all
13
respondents.

i
The
annual
burden
and
cost
are
equal
to
the
hours
added
down
each
column
for
technical,
management,
and
clerical
labor
and
the
sum
of
the
cost
column.
Attachment
4
15
2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.

Tables
1a
and
1b
of
this
attachment
present
the
annual
burden
estimates
and
costs
for
reporting
and
recordkeeping
activities
for
existing
major
sources
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
Table
1a
presents
the
estimated
burden
and
costs
to
the
industry
during
the
fourth
year
after
the
effective
date
of
the
rule.
Table
1b
presents
the
estimated
burden
and
costs
to
the
industry
during
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standard
development
efforts.

The
costs
of
the
reporting
and
recordkeeping
activities
are
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.
Labor
costs
are
divided
into
the
following
three
categories:

(
1)
technical,
(
2)
management,
and
(
3)
clerical.
The
cost
of
technical
labor
is
estimated
at
$
47.75/
hr,
the
cost
of
management
labor
at
$
72.58/
hr,
and
the
cost
of
clerical
labor
at
$
30.18/
hr.

These
estimates
include
fringe
benefits,
overhead,
and
profit
rate.
The
labor
costs
are
in
March
2000
dollars.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor­
related
costs
associated
with
information
collection
activities­­
capital
costs
and
O&
M
costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
ICR
are
presented
in
Attachment
3,
Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
Attachment
4
16
years
by
annualizing
the
cost
using
an
OMB­
approved
discount
rate.
For
this
ICR,
capital
costs
were
annualized
using
an
interest
rate
of
7
percent.
In
most
cases,
administrative
charges,
insurance,
and
property
taxes
were
also
included
with
the
annualized
capital
costs,
estimated
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
data
acquisition
system,

computer,
logging
and
reporting
software,
printer,
and
ancillary
costs,
such
as
planning,
selecting
the
equipment,
providing
support
facilities,
installing
and
checking
the
equipment,

establishing
operating
parameters,
and
preparing
a
QA/
QC
plan.

Capital
and
annualized
capital
costs
associated
with
monitoring
equipment
are
expected
to
be
incurred
in
the
third
year
after
the
effective
date
of
the
rule
as
existing
facilities
purchase,

install,
and
check
out
their
monitoring
equipment
prior
to
their
compliance
date.
Annualized
capital
costs
associated
with
monitoring
equipment
also
are
expected
to
be
incurred
during
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
(
i.
e.,
the
3
years
after
the
existing
source
compliance
date).

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
average
annualized
capital
cost
per
facility
for
file
cabinets
is
$
35.
Capital
and
annualized
capital
costs
associated
with
file
cabinets
are
expected
to
be
incurred
in
the
third
year
after
the
effective
date
of
the
rule
as
existing
facilities
develop
their
record
systems
prior
to
their
compliance
date.
Annualized
capital
costs
associated
with
file
cabinets
also
are
expected
to
be
incurred
during
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
(
i.
e.,
the
3
years
after
the
existing
source
compliance
date).
Attachment
4
17
Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
organic
HAP
performance
tests
for
process
vents
and
wastewater
systems
at
cellulose
ether
facilities
and
the
costs
for
total
sulfide
performance
tests
for
process
vents
at
viscose
process
facilities.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:
(
1)
the
capital
cost
per
test
is
$
10,000;

for
process
vents,
this
cost
includes
the
cost
for
testing
both
the
inlet
and
outlet
of
the
control
device;
(
2)
one
performance
test
will
be
performed
for
each
wastewater
system
and
each
process
vent
control
device;
(
3)
10
facilities
(
4
cellulose
ether
facilities
and
6
viscose
process
facilities)
will
be
required
to
conduct
an
initial
performance
test
for
their
process
vents;

(
4)
4
cellulose
ether
facilities
will
be
required
to
conduct
an
initial
performance
test
for
their
wastewater
systems;
(
5)
no
performance
test
is
required
for
three
viscose
process
facilities,
which
are
using
recovery
devices
to
meet
the
emission
limit;
these
three
facilities
will
be
required
to
conduct
an
initial
compliance
demonstration
based
on
the
material
balance
for
their
process;
the
cost
for
the
initial
compliance
demonstration
is
included
in
the
notification
of
compliance
status
labor
cost
in
Table
1a
of
this
attachment;
(
6)
the
facilities
required
to
conduct
an
initial
performance
test
will
conduct
the
test
during
the
fourth
year
after
the
effective
date
of
the
rule
(
i.
e.,
the
first
year
after
their
compliance
date);

and
(
7)
based
on
the
assumptions
that
5
percent
of
these
facilities
will
fail
the
first
test
and
50
percent
of
the
failing
facilities
will
conduct
a
retest,
no
facilities
are
expected
to
have
to
retest.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
as
well
as
those
costs
associated
with
a
paperwork
requirement
incurred
Attachment
4
18
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
the
Agency
and
maintain
records
should
be
estimated
as
costs
for
file
storage,
photocopying,
and
postage.
File
storage
and
photocopying
costs
per
response
are
estimated
at
0.5
hour
of
clerical
labor
at
a
rate
of
$
30.18/
hr.
First
class
postage
is
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
Those
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
recordkeeping
and
reporting,
and
overhead
for
the
monitoring
equipment.
Monitoring
O&
M
costs
are
expected
to
be
incurred
during
the
fourth,
fifth,

and
sixth
years
after
the
effective
date
of
the
rule
(
i.
e.,
the
3
years
after
the
existing
source
compliance
date).

Operation
and
maintenance
costs
also
include
the
costs
associated
with
a
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
should
be
estimated
as
costs
for
file
storage,

photocopying,
and
postage.
File
storage
and
photocopying
costs
per
response
are
estimated
at
0.5
hour
of
clerical
labor
at
a
rate
of
$
30.18/
hr.
First
class
postage
is
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
File
storage,

photocopying,
and
postage
costs
will
be
applied
to
the
39
responses
submitted
during
the
fourth
year
after
the
effective
date
of
the
rule
and
the
26
responses
submitted
during
each
of
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.

(
The
number
of
responses
was
determined
based
on
the
number
of
notifications
and
reports
submitted
to
EPA
by
respondents,
as
shown
in
Tables
1a
and
1b
of
this
attachment.)
Attachment
4
19
(
b)
Estimating
Agency
Burden
and
Costs
Tables
2a
and
2b
of
this
attachment
present
the
estimated
annual
Agency
burden
estimates
and
costs
for
the
fourth,
fifth,

and
sixth
years
after
the
effective
date
of
the
rule.
Table
2a
presents
the
estimated
burden
and
costs
to
the
Agency
during
the
fourth
year
after
the
effective
date
of
the
rule.
Table
2b
presents
the
estimated
burden
and
costs
to
the
Agency
during
the
fifth
and
sixth
years
after
the
effective
date
of
the
rule.
The
only
burden
and
costs
that
the
Federal
Government
will
incur
as
a
result
of
the
information
collection
requirements
are
associated
with
the
analysis
of
the
information
reported
by
respondents
in
one­
time
notifications
of
compliance
status
and
semiannual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).
Labor
costs
are
based
on
estimated
wage
rates
of
$
47.75/
hr
for
technical
labor,
$
72.58/
hr
for
management
labor,
and
$
30.18/
hr
for
clerical
labor.
The
labor
costs
are
in
March
2000
dollars.

(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Once
the
burden
and
costs
per
activity
have
been
established
on
a
per
respondent
basis,
the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
the
Agency.
To
calculate
the
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.

The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."
The
respondent
universe
varies
among
the
activities
listed
because
not
all
respondents
must
complete
each
activity.

In
estimating
respondent
burden,
EPA
estimates
that
13
major
source
cellulose
products
manufacturing
facilities
will
be
required
to
submit
notifications
of
compliance
status
and
semiannual
compliance
reports,
provide
refresher
training
for
personnel,
and
maintain
records.
In
calculating
Agency
burden,
Attachment
4
20
EPA
estimates
that
EPA
personnel
will
conduct
reviews
of
13
notifications
of
compliance
status
in
the
fourth
year
after
the
effective
date
of
the
rule
and
13
semiannual
compliance
reports
during
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.

To
determine
the
burden
for
each
activity
for
technical
staff,
the
number
of
hours
per
respondent
is
multiplied
by
the
number
of
respondents.
Management
and
clerical
labor
hours
are
calculated
at
5
percent
and
10
percent
of
technical
labor
hours,

respectively.
The
total
burden
is
determined
by
summing
the
technical,
management,
and
clerical
burden
estimates.
To
determine
the
total
labor
cost,
the
burden
estimates
for
technical,
management,
and
clerical
labor
are
multiplied
by
their
respective
labor
rates
and
then
summed.

(
d)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
are
calculated
by
adding
the
total
hours
and
costs
from
Table
1a
to
the
total
hours
and
costs
from
Table
1b
multiplied
by
two,
and
then
dividing
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule).
The
total
annual
burden
hours
and
costs
are
summarized
as
follows:

Burden
table
Total
burden,
hours
Total
cost,
$

Table
1a
(
fourth
year)
15,009
$
709,935
Table
1b
x
2
(
fifth
and
sixth
years)
24,129
$
570,679
Total
39,138
$
1,280,614
Bottom
line
annual
burden
13,046
$
426,871
The
bottom
line
annual
burden,
averaged
over
the
3­
year
period,
is
13,046
labor
hours,
at
a
cost
of
$
426,871.
The
Attachment
4
21
average
annual
burden
per
respondent,
based
on
13
respondents
over
the
3­
year
period,
is
1,004
labor
hours,
at
a
cost
of
$
32,836.

There
are
an
estimated
30
total
annual
responses
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
The
total
annual
responses
are
based
on
an
estimated
13
one­
time
notifications
of
compliance
status
and
26
semiannual
compliance
reports
submitted
during
the
fourth
year
and
an
estimated
26
semiannual
compliance
reports
submitted
during
each
of
the
fifth
and
sixth
years.
Of
these
30
responses,
it
is
assumed
that
approximately
20
percent
will
be
collected
electronically.

The
total
capital
cost
for
the
performance
tests
is
estimated
to
be
$
590,000
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
performance
tests
is
$
64,782
for
the
fourth,

fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
costs
for
monitoring
equipment
and
file
cabinets
(
purchased
in
the
third
year
after
the
effective
date
of
the
rule)
are
$
169,394
and
$
455,
respectively,
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
Summing
the
annualized
capital
costs
for
the
performance
tests,
monitoring
equipment,
and
file
cabinets
results
in
a
total
annualized
capital
cost
of
$
234,631
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.

The
average
annual
O&
M
costs
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
are
$
223,556
for
monitoring
and
$
689
for
file
storage,
photocopying,
and
postage.

Summing
these
two
O&
M
costs
results
in
a
total
annual
O&
M
cost
of
$
224,245
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.

Summing
the
total
annualized
capital
cost
with
the
total
annual
O&
M
cost
results
in
a
total
annualized
cost
of
$
458,876
Attachment
4
22
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.

(
ii)
The
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
are
calculated
by
adding
the
total
hours
and
costs
from
Table
2a
to
the
total
hours
and
costs
from
Table
2b
multiplied
by
two,
and
then
dividing
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule).
The
annual
burden
hours
and
costs
are
summarized
as
follows:

Burden
table
Total
burden,
hours
Total
cost,
$

Table
2a
(
fourth
year)
1,472
$
70,128
Table
2b
x
2
(
fifth
and
sixth
years)
736
$
34,814
Total
2,208
$
104,942
Bottom
line
annual
burden
736
$
34,981
The
bottom
line
annual
burden,
averaged
over
the
3­
year
period,
is
736
labor
hours,
at
a
cost
of
$
34,981.

(
e)
Burden
Statement
(
i)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection,
averaged
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule,
are
estimated
to
be
13,046
labor
hours
and
$
426,871.
The
average
burden
and
cost,
per
respondent,
are
1,004
labor
hours
and
$
32,836.
These
burden
and
cost
estimates
include
submitting
one­
time
notifications
of
compliance
status,
submitting
semiannual
compliance
reports,
and
recordkeeping.

(
ii)
The
total
capital
cost
for
performance
tests
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
is
$
590,000.
The
annualized
capital
cost
for
performance
tests,
monitoring
equipment,
and
file
cabinets,
averaged
over
the
Attachment
4
23
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule,
is
$
234,631.
The
annual
O&
M
cost
for
monitoring,
file
storage,
photocopying,
and
postage,
averaged
over
the
fourth,

fifth,
and
sixth
years
after
the
effective
date
of
the
rule,
is
$
224,245.
Summing
the
annualized
capital
cost
with
the
annual
O&
M
cost
results
in
a
total
annualized
cost
of
$
458,876
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
