SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
cellulose
products
manufacturing
operation
were
proposed
on
August
28,
2000
(
65
FR
52166),
and
promulgated
on
June
11,
2002
(
67
FR
40043).
These
standards
apply
to
each
operation
that
is
a
major
source
of
hazardous
air
pollutant
(
HAP),
that
emits
or
has
the
potential
to
emit
any
single
HAP
at
a
rate
of
9.1
megagrams
per
year
[
10
tons
per
year
(
tpy)]
or
more,
or
any
combination
of
HAP
at
a
rate
of
23
megagrams
per
year
(
25
tpy)
or
more,
which
includes
both
the
miscellaneous
viscose
processes
source
category
and
the
cellulose
ethers
productions
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.

Respondents
must
choose
one
of
the
compliance
options
that
is
described
in
the
rule
or
install
and
monitor
a
specific
air
pollution
control
system
that
reduces
HAP
emissions
to
the
compliance
level.
Respondents
are
also
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
of
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.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners
or
operators
of
the
affected
facilities.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
2
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
In
addition
to
the
requirements
of
subpart
A,
cellulose
ether
respondents
are
required
to
comply
with
the
applicable
reporting
and
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.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Based
on
our
consultations
with
industry
representatives,
there
is
an
average
of
one
affected
facility
at
each
plant
site
and
that
each
plant
site
has
only
one
respondent
(
i.
e.,
the
owner/
operator
of
the
plant
site).

Approximately
thirteen
respondents
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
Out
of
the
thirteen
existing
sources
in
the
cellulose
products
manufacturing
industry,
four
are
cellulose
ether
facilities,
four
are
cellulosic
sponge
facilities,
three
are
cellulose
food
casing,
one
rayon,
and
one
cellophane
operation.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
section
114(
a)
states
that
the
Administrator
may
require
any
owner/
operator
subject
to
any
requirement
of
this
Act
to:

(
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
3
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.

In
the
Administrator's
judgment,
HAP
emissions
from
cellulose
products
manufacturing
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63
subpart
UUUU.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standards
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.
Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standards.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standards
at
all
times.
During
the
performance
test
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standards
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
ensure
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
the
standards
are
being
met.
The
performance
test
may
also
be
observed.

The
required
semiannual
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
UUUU.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
4
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
69
FR
69909)
on
December
1,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
consulted
with
the
preparer
of
the
active
ICR,
and
used
several
different
resources
to
obtain
the
most
recent
data
available
including
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
also
reviewed
information
available
from
the
United
States
Census
Bureau,
and
other
websites
covering
cellulose
products
manufacturing,
and
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
record's
retention
requirement
is
consistent
the
part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.
5
3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
cellulose
products
manufacturing.
States
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standards,
which
correspond
to
the
North
American
Industry
Classification
System
(
NAICS)
codes,
are
listed
below
for
source
category
description.

Standard
(
40
CFR
Part
63,
Subpart
UUUU)
SIC
Codes
NAICS
Codes
All
Other
Plastics
Product
Manufacturing
3089
326199
Unlaminated
Plastics
Profile
Shape
Manufacturing
3089
326121
Plastics
Material
and
Resin
Manufacturing
2821
325211
Cellulosic
Organic
Fiber
Manufacturing
2823
325221
All
other
Basic
Inorganic
Chemical
Manufacturing
2819
325188
All
Other
Basic
Organic
Chemical
Manufacturing
2869
325199
4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal).
6
A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Initial
notification
63.5575
and
63.9(
b)(
1)­(
5)

Notification
of
performance
tests
63.5575,
3.7(
b)
and
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),
63.9(
j),
63.10(
d)(
2)
and
63.10(
e)(
2)

Notification
of
equipment
leaks
63.5575,
63.182(
a)(
1),
63.182(
2)(
b)
and
63.182(
c)(
1)­(
3)
or
63.1039(
a)

Notification
of
wastewater
63.5575,
63.146(
a)(
1),
63.146(
a)(
2),
63.146(
b),
63.151,
63.152(
a)(
1)­(
3)
and
63.152(
b)(
1)­(
5)

Reports
Semiannual
report
of
deviations/
out­
of­
control
operation
63.5580
and
63.10(
e)(
3)

Semiannual
report
of
startup,
shutdown,
and
malfunction
63.5580
and
63.10(
d)(
5)

Semiannual
report
of
equipment
leaks
63.5580,
63.182(
a)(
3),
63.182(
a)(
6)
and
63.182(
d)(
2)­(
4)
or
63.1039(
b)

Semiannual
report
of
wastewater
63.5580,
63.146(
c)­(
e),
63.152(
a)(
4),
63.152(
a)(
5)
and
63.152(
c)­(
e)

Semiannual
report
of
changes
in
information
63.5580
and
63.9(
j)

Semiannual
report
of
closed­
vent
system
63.5580
and
63.148(
j)(
1)

Semiannual
report
of
bypass
lines
63.5580,
63.148(
j)(
2)
and
63.148(
j)(
3)

Semiannual
report
of
heat
exchanger
systems
63.5580
and
63.104(
f)(
2)(
i)­(
iv)

Semiannual
report
of
storage
vessel
control
device
maintenance
66.5580
7
A
source
must
keep
the
following
records:

Recordkeeping
Record
retention
63.5590
and
63.10(
b)(
1)

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

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

Records
of
startup,
shutdown,
and
malfunction
(
SSM)
plan
63.5515,
635585,
63.6(
e)(
3)
and
63.10(
b)(
2)(
i)­(
v)

Records
of
site­
specific
monitoring
plan
63.5545,
63.5585
and
63.8(
d)(
2)

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

Records
of
each
continuous
parameter
monitoring
system
63.5585,
63.10(
b)(
2)(
vi)­(
xi)
and
63.10(
c)

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
of
extended
cookout
63.5585
Records
of
equipment
leaks
63.5585
and
63.181,
or
63.1038
Records
of
wastewater
63.5585,
63.105,
63.147,
63.152(
f)
and
63.152(
g)

Records
of
closed­
vent
systems
63.5585
and
63.148(
j)

Records
of
bypass
lines
63.5585
Records
of
heat
exchanger
systems
63.5585
and
63.104(
f)(
1)
8
Recordkeeping
Records
of
storage
vessel
control
device
maintenance
63.5585
Records
of
safety
devices
63.5585
Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
temperature,
pressure
drop,
liquid
flow
rate,
etc.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
20
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
control
device.

Perform
initial
performance
test,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.
9
Respondent
Activities
Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
sources
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.
10
The
records
required
by
this
regulation
must
be
retained
by
the
owner/
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
12,088
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
11
This
ICR
uses
the
following
labor
rates:

Managerial
$
96.41
($
45.91
+
110%)
Technical
$
82.74
($
39.40
+
110%)
Clerical
$
42.25
($
20.12
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Continuous
parameter
monitoring
system
N/
A
N/
A
$
0
$
78
13
$
1,014
$
0
$
1,014
The
total
capital/
startup
costs
for
this
ICR
are
zero.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
1,014.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).
12
The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
1,000
(
rounded).
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
14,919.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
for
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
thirteen
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
13
Number
of
Respondents
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
13
0
0
13
2
0
13
0
0
13
3
0
13
0
0
13
Average
13
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
13.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
each
of
the
three
years
covered
by
this
ICR.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Semiannual
report
of
no
deviation
10
2
N/
A
20
Semiannual
report
of
deviation
3
2
N/
A
6
Semiannual
report
of
SSM
13
2
N/
A
26
Semiannual
report
on
equipment
leaks
4
2
N/
A
8
Semiannual
report
on
all
other
13
2
N/
A
26
Total
86
The
number
of
Total
Annual
Responses
is
86.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
14
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
964,081.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal).

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
964,081.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU).
(
Renewal).
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
141
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
1,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
368
labor
hours
at
a
cost
of
$
14,919.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Cellulose
Products
Manufacturing
(
40
CFR
part
63,
subpart
UUUU)
(
Renewal),
attached.

6(
f)
Reasons
for
Change
in
Burden
There
is
no
change
in
the
number
of
respondents
identified
in
the
active
ICR,
however
there
is
an
increase
of
10,652
hours
in
the
estimated
burden
as
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.
The
increase
is
attributed
primarily
to
the
fact
that
all
thirteen
sources
are
in
compliance
with
the
standard,
and
must
now
monitor
data
and
submit
semiannual
reports.

Because
there
are
no
new
sources
with
reporting
requirements,
no
capital/
startup
costs
are
incurred.
The
only
cost
that
is
incurred
is
for
the
operation
and
maintenance
(
O&
M)
of
the
monitoring
equipment.
15
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
141
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0030,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0030
and
OMB
Control
Number
2060­
0488
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Cellulose
Products
Manufacturing
(
CFR
part
63,
subpart
UUUU)

(
Renewal)
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
1.
Applications
N/
A
2.
Survey
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
report
on
no
deviations
c
8
2
16
10
160
8
16
$
14,009.68
Semiannual
report
on
deviations
d
16
2
32
3
96
4.8
9.6
$
8,811.41
Semiannual
report
of
startup,
shutdown,

malfunction
(
SSM)
e
8
2
16
13
208
10.4
20.8
$
19,091.38
Semiannual
report
on
equipment
leaks
f
303
2
606
4
2,424
121.2
242.4
$
222,488.05
Semiannual
report
on
wastewater
Included
in
4E
Semiannual
report
on
all
other
reports
g
8
2
16
13
208
10.4
20.8
$
19,091.38
4.
Recordkeeping
Requirements
17
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
A.
Read
instructions
N/
A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
SSM
h
1.5
52
78
13
1,014
50.7
101.4
$
93,070.50
Records
of
continuous
parameter
monitoring
system
(
CPMS)
data
Record
continuous
monitor
parameters
i
1
365
365
13
4,745
237.25
474.5
$
435,522.20
Compile
data
j
24
2
48
13
624
31.2
62.4
$
57,274.15
Enter
and
verify
information
for
semiannual
report
j
16
2
32
13
416
20.8
41.6
$
38,182.77
Records
of
closed­
loop
systems
k
2
2
4
1
4
0.2
0.4
$
367.14
Records
of
nitrogen
systems
l
2
2
4
9
36
1.8
3.6
$
3,304.28
Records
of
material
balances
m
8
2
16
9
144
7.2
14.4
$
13,217.11
Records
of
supporting
calculations
n
8
2
16
13
208
10.4
20.8
$
19,091.38
Records
for
extended
cookout
o
8
2
16
1
16
0.8
1.6
$
1,468.57
Records
for
equipment
leaks
Included
in
3E
All
other
records
Included
in
3E
18
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
F.
Time
for
refresher
training
of
personnel
p
16
1
16
13
208
10.4
20.8
$
19,091.38
G.
Time
for
audits
N/
A
Subtotal
Labor
Burden
10,511
525.55
1,051.1
$
964,081.38
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
12,088
$
964,081
Assumptions:

a
There
are
thirteen
existing
major
cellulose
products
manufacturing
sources,
which
includes
four
cellulose
ether
facilities,
four
cellulosic
sponge
facilities,
three
cellulose
food
casing,
one
rayon
and
one
cellophane.

b
This
ICR
uses
the
following
labor
rates:
$
96.41
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
82.74
per
hour
for
Technical
labor,
and
$
42.25
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2004,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
We
have
assumed
that
80
percent
of
respondents
will
report
no
deviation.

d
We
have
assumed
that
20
percent
of
respondents
will
report
deviation.

e
We
have
assumed
that
all
of
the
existing
respondents
will
be
required
to
submit
a
SSM
report
f
We
have
assumed
that
it
will
take
303
hours
on
a
semiannual
basis
to
write
reports
for
4
cellulose
ether
facilities
subject
to
leak
detection
and
repair
(
LDAR)

requirements..

g
All
other
reports
includes
changes
of
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance
will
be
reported
on
twice
a
year.

h
We
have
assumed
that
SSM
records
will
be
recorded
on
a
weekly
basis.

i
Information
is
recorded
daily
on
process
vent,
storage
tank
and
wastewater
monitoring
and
inspections.

j
Information
is
compiled,
entered,
and
verified
for
semiannual
report.

k
We
have
assumed
that
it
will
take
two
hours
to
enter
information
on
one
cellulose
ether
facility
with
a
closed­
loop
system.

l
We
have
assumed
that
it
will
take
two
hours
to
enter
information
on
nine
viscose
process
facilities
with
CS2,
unloading
and
storage
operations.

m
We
have
assumed
that
it
will
take
eight
hours
to
enter
information
on
nine
viscose
process
facilities
using
material
balances.

n
We
have
assumed
that
it
will
take
eight
hours
to
enter
information
on
all
thirteen
respondents.
19
o
We
have
assumed
that
it
will
take
eight
hours
to
enter
information
on
one
cellulose
ether
facility
that
uses
extended
cookout.

p
We
have
assumed
that
it
will
take
two
days
(
16
hours)
to
provide
refresher
training
to
personnel.

Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Cellulose
Products
Manufacturing
(
CFR
part
63,
subpart
UUUU)
(
Renewal)

Burden
item
(
A)
Technical
Person
Hours
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost,

Per
Yearb
Initial
performance
test
N/
A
Repeat
performance
test
N/
A
Excess
Emissions
Enforcement
Activities
120
1
120
0
0
0
0
$
0
Review
reports
20
Burden
item
(
A)
Technical
Person
Hours
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost,

Per
Yearb
Review
semiannual
compliance
report
Report
of
no
deviations
c
2
2
4
10
40
2
4
$
1,864.84
Report
of
deviations
d
8
2
16
3
48
2.4
4.8
$
2,237.81
Report
of
SSM
e
2
2
4
13
52
2.6
5.2
$
2,424.29
Reports
of
equipment
leaks
f
8
2
16
4
64
3.2
6.4
$
2,983.74
Report
on
wastewater
g
8
2
16
4
64
3.2
6.4
$
2,983.74
Report
on
al
other
reports
h
2
2
4
13
52
2.6
5.2
$
2,424.29
Subtotals
Labor
Burden
and
Cost
320
16
32
$
14,918.71
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
368
$
14,919
Assumptions:

a
There
are
thirteen
existing
major
cellulose
products
manufacturing
sources,
which
includes
four
cellulose
ether
facilities,
four
cellulosic
sponge
facilities,
three
cellulose
food
casing,
one
rayon
and
one
cellophane.

b
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
56.02
for
Managerial
(
GS­
13,
Step
5,
$
35.01
x
1.6),
$
41.57
for
Technical
(
GS­
12,
Step
1,
$
25.98
x
1.6)
and
$
22.50
Clerical
(
GS­
6,
Step
3,
$
14.06
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

c
We
have
assumed
that
80
percent
of
respondents
will
report
no
deviation.

d
We
have
assumed
that
20
percent
of
respondents
will
report
deviation.

e
We
have
assumed
that
all
of
the
existing
respondents
will
be
required
to
submit
a
SSM
report.

f
It
is
assumed
that
four
cellulose
ether
facilities
will
review
their
report
on
equipment
leaks
two
twice
a
year.

g
We
have
assumed
that
it
will
take
eight
hours
to
review
reports
of
four
cellulose
ether
facilities
subject
to
LDAR
and
wastewater
requirements.

h
All
other
reports
includes
changes
of
information,
closed­
vent
systems,
bypass
lines,
heat
exchanger
systems,
and
storage
vessel
control
device
maintenance
will
be
reported
on
twice
a
year.
