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), EPA ICR Number 1974.05, OMB Control Number 2060-0488  

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 pollutants (HAP), that emit or has the potential to emit
any single HAP at a rate of 9.1 megagrams per year (10 tons per year) or
more, or any combination of HAP at a rate of 23 megagrams per year (25
tons per year) 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 are 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 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.

Approximately 13 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,
and three are cellulose food casing, one is rayon, and one cellophane
operation. 

There are approximately 13 cellulose products manufacturing plants in
the United States, which are owned and operated by the cellulose
products manufacturing industry.  None of the thirteen facilities in the
United States are owned by state, local, tribal or the Federal
Government.  They are owned and operated by privately owned for-profit
businesses.  You can find the burden to the “Affected Public” listed
below in Table 1: Annual Industry Burden and Cost - NESHAP for Cellulose
Products Manufacturing (40 CFR Part 63, Subpart UUUU).  The Federal
government burden does not include work performed by Federal employees. 
The burden refers only to work performed by contractors, which could be
found listed below in Table 2: Average Annual EPA Burden - NESHAP for
Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU).

The Office of Management and Budget (OMB) approved the currently active
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 (HAP). 
These standards are applicable to new or existing sources of HAP and
shall require the maximum degree of emission reduction.  In addition,
section 114(a) states that the Administrator may require any owner or
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 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 was 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 standard ensure
compliance with the applicable regulations which where 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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, 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 standard 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.

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart UUUU.

3(a)  Non-duplication

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 their 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 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 (72 FR 10736) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts. 
Approximately 13 respondents will be subject to the standard over the
three-year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed, and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

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 records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance, and to determine the appropriate level of
enforcement action.   EPA has found that the most flagrant violators
have violations extending beyond the five years.    In addition, EPA
would be prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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.  The United 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 each 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

In this ICR, all the data recorded or reported is required by the
National Emission Standards for Hazardous Air Pollutants for Cellulose
Products Manufacturing (40 CFR Part 63, Subpart UUUU).

A source must make the following reports:

Notifications

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



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(c) and 63.10(b)(2)(vi)-(xi)

Records of each continuous parameter monitoring system	63.5585, 63.10(c)

63.10(b)(2)(vi)-(xi) and 

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)

Records of storage vessel control device maintenance	63.5585

Records of safety devices	63.5585



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a 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.

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.

Transmit, or otherwise disclose the information.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g. continuous parameter monitoring
system.  Although personnel at the source 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,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note 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.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA delegated Authorities can
edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or
operator for five years.

5(c)  Small Entity Flexibility

The majority of the respondents are large entities (i.e., 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 to be the minimum
requirements 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
Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU)
(Renewal), below.

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.  Wherever 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 

	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 10: Private industry, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
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/Startup Cost for One Respondent	(C)

Number of New Respondents 	(D)

Total Capital/Startup 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.

The total operation and maintenance (O&M) costs consists of
photocopying, and postage are $1,014.  This is the total of column G.

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 $1,014.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 + 60%)

Technical	$41.57   (GS-12, Step 1, $25.98 + 60%)

Clerical	$22.50   (GS-6, Step 3, $14.06 + 60%)

These rates are from the Office of Personnel Management (OPM) “2004
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP for Cellulose
Products Manufacturing (Renewal), (40 CFR Part 63, Subpart UUUU)
(Renewal), below.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Based on our research for this ICR, on average over the next three
years, approximately 13 respondents will be subject to the standard.  It
is estimated that no additional sources per year will become subject. 
The overall average number of respondents, as shown in the table below
is 13 per year. 

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

Number of Respondents

Year	(A)

Number of New Respondents 1	(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	0	13	0	0	13

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 13.

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	3	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.

The total annual labor costs are $964,081.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Cellulose Products Manufacturing (Renewal), (40 CFR Part 63,
Subpart UUUU) (Renewal), below.

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,
and summarized below. 

(i)  Respondent Tally

The total annual labor costs are $964,081.  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), below.  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 $1,014.

(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 (Renewal), (40 CFR Part 63, Subpart UUUU) (Renewal),
below.

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR compared to
the previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is very low, negative or non-existent, so there is
no significant change in the overall burden.  It should be noted that
the previous ICR rounded the burden cost down to the nearest one
thousand.  In this ICR, the exact cost figure is reported which results
in an apparent increase in the cost when, in fact, no increase has
occurred.

Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR, and there is no change in burden to
industry.

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 either disclose or provide
information to either 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
either 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
EPA-HQ-OECA-2007-0062.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
http://www.regulations.gov/  which may be used to obtain a copy of the
draft collection of information, submit or view public comments, access
the index listing of the content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than key in the docket ID number
identified in this document.  The documents are also available for
public viewing at the Enforcement and Compliance Docket       and
Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, N.W., 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 Docket is (202) 566-1927.           Also, you can
send comments to the Office of Information and Regulatory Affairs,
Office of Management and Budget, 725 17th Street, N.W., Washington, DC
20503, Attention: Desk Officer for EPA.  Please include the EPA Docket
ID Number EPA-HQ-OECA-2007-0062 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.

Table 1:  Annual Respondent Burden and Cost – NESHAP for Cellulose
Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal)

Burden item	(A)

Person hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours 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	See 3E







	     D.  Gather existing information	See 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	See 4E







	           Semiannual report on all other reports g	8	2	16	13	208	10.4
20.8	$19,091.38

4.  Recordkeeping requirements









     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 parameters 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	See 3E







	          All other records	See 3E







	     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







	Subtotals Labor Burden and cost  



	10,511	525.55	1,051.1	$964,081.38

TOTAL LABOR BURDEN AND COST (rounded)





12,088

$964,081



Assumptions:

a  We have assumed that there are approximately thirteen  sources that
are subject to the standard, 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 percent 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 sources will be required to
submit an SSM report.

f  We have assumed that it will take each respondent 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 include changes of information, closed-vent
systems, bypass lines, heat exchanger systems, and storage vessel
control device maintenance will be reported on twice per 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 each respondent two hours to enter
information on one cellulose ether facility with a closed-loop system.

l   We have assumed that it will take each respondent 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.

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 (40 CFR Part 63, Subpart UUUU) (Renewal)

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant per year	(C)

EPA person- hours per plant per year

(C=AxB)	(D)

Plants per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person-hours per year

(Ex0.05)

	(G)

Clerical person-hours per year

(Ex0.1)	(H)

Cost, $ b

Activity









Initial performance test 	N/A







	Repeat performance test 	N/A







	Excess emissions enforcement activities 	120	1	120	0	0	0	0	$0

Review reports









     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 all 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 ANNUAL BURDEN AND COST (rounded)	

	

	

	

	368	$14,919



 	Assumptions:

    a  We have assumed that there are approximately thirteen sources
that are subject to the standard, 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), $44.57
for Technical (GS-12, Step 1, $25.98 x 1.6) and $22.50 Clerical (GS-6,
Step 3, $14.06x 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 an SSM report.

f  It is assumed that four cellulose ether facilities will review their
report on equipment leaks two times per 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 include changes of information, closed-vent
systems, bypass lines, heat exchanger systems, and storage vessel
control device maintenance will be reported on twice a year.

 PAGE   

 PAGE   2 

 PAGE   

