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 1974.06, 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.  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.  In addition,
respondents are required to install, operate, and maintain a continuous
parameter monitoring system (CPMS) for each facility in order 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 is used to calculate the percent of reduction in emissions and to
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 in order 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.  Also, they are 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.  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 facilities; one is a rayon operation;
and one is a cellophane operation. 

In the United States, there are approximately 13 cellulose products
manufacturing plants that are owned and operated by the cellulose
products manufacturing industry.  None of these thirteen facilities 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 Respondent 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).

In the development of the Information Collection Request (ICR), we
addressed the Office of Management and Budget (OMB) “Terms of
Clearance (TOC)” on the active ICR.  The TOC are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, response number, labor rates, and capital costs and ensure
these estimates have been updated.

EPA addressed each item of concern in the TOC.  The respondent burden,
universe, response number, labor rates, and capital cost have been
thoroughly checked, and all estimates updated.

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 for this source category was promulgated 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.

The information generated by the monitoring, recordkeeping, and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.

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 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 (76 FR 26900) on May 9, 2011.  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.  

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.  In developing this ICR, we contacted the
Cellulose Insulation Manufacturers Association (CIMA) at (937) 222-2462,
and the North American Insulation Manufacturers Association (NAIMA) at
(703) 684-0084

After a thorough review of comments, it is our policy to respond to
those received since the last ICR renewal, as well as to 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 that 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 notification 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 corresponds 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

Unlimited 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 National
Emission Standards for Hazardous Air Pollutants for Cellulose Products
Manufacturing (40 CFR Part 63, Subpart UUUU).

A source must make the following reports:

Notification Reports

Initial notification	63.5575, 63.9(b)(1-5)

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

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

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



Reports

Semiannual report of deviations/out-of-control operation	63.5580,
63.10(e)(3)

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

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

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

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

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

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

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

Semiannual report of storage vessel control device maintenance	66.5580



A source must keep the following records:

Recordkeeping

Startup, shutdown, malfunctions, periods where the continuous monitoring
system is inoperative	63.10(b)(2)

Record retention	63.5590,  63.10(b)(1)

Records of 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 SSM plan	63.5515, 63.5585, 63.6(e)(3), 63.10(b)(2)(i-v)

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

Records of each CEMS	63.5585, 63.8(d)(3), 63.8(f)(6)(i), 63.10(c),
63.10(b)(2)(vi-xi)

Records of each CPMS	63.5585, 63.10(c)

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

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, 63.181, 63.1038

Records of wastewater	63.5585, 63.105, 63.147, 63.152(f-g) 

Records of closed-vent systems	63.5585,  63.148(j)

Records of bypass lines	63.5585

Records of heat exchanger systems	63.5585, 63.104(f)(1)

Records of storage vessel control device maintenance	63.5585



Electronic Reporting

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

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,
and 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 Respondent Burden and Cost,
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.  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

This ICR uses the following labor rates:

Managerial	$119.36 ($56.84 + 110%)   

Technical	$99.18 ($47.23 + 110%)

Clerical	$49.35 ($23.50 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2011, "Table 2. Civilian Workers, 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	11	$1,014



	$0

	$1,014



The total capital/startup costs for this ICR are $0.  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 $21,358.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011
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 (40 CFR Part 63, Subpart UUUU) (Renewal).

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 new sources will become subject to the
rule.  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 respondent 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	2	N/A	26

Semiannual report on equipment leaks	4	2	N/A	8

Semiannual report on all others	13	2	N/A	26



	Total	86



The number of Total Annual Responses is 86.

The total annual labor costs are $1,157,042.  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,
and summarized below. 

(i)  Respondent Tally

The total annual labor hours are 12,088.  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 operation and maintenance (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 $21,358.  See Table 2.
Annual Agency Burden and Cost: NESHAP for Cellulose Products
Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  This is due to two considerations: 1) the regulations
have not changed over the past three years and are not anticipated to
change over the next three years; and 2) the growth rate according to
the industry sources is very low, negative or non-existent, so there is
no significant change in the overall burden.  There are no new
facilities expected to be constructed over the next three years of this
ICR. 

	However, there is an increase in the estimated burden cost as currently
identified in the OMB Inventory of Approved Burdens.  The increase is
not due to any program changes.  The change in burden is due to the use
of the most updated labor rates.

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 the EPA 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-2011-0216.  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, D.C.  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) 566-1752. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, N.W.,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0216 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
$17,613.28

           Semiannual report on deviations d	16	2	32	3	96	4.8	9.6
$10,567.97

           Semiannual report of startup, shutdown,

           malfunction (SSM) e	8	2	16	13	208	10.4	20.8	$22,897.26

           Semiannual report on equipment leaks f	303	2	606	4	2,424
121.2	242.4	$266,841.19

           Semiannual report on wastewater	See 4E







	           Semiannual report on all other reports g	8	2	16	13	208	10.4
20.8	$22,897.26

Subtotal for Reporting Requirements









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	$111,624.16

          Records of continuous parameters 

          monitoring system (CPMS) data









               Record continuous monitor parameters i	1	365	365	13	4,745
237.25	474.5	$622,303.25

               Compile data j	24	2	48	13	624	31.2	62.4	$68,691.79

               Enter and verify information for

               semiannual report j	16	2	32	13	416	20.8	41.6	$45,794.53

          Records of closed-loop systems k	2	2	4	1	4	0.2	0.4	$440.33

          Records of nitrogen systems l	2	2	4	9	36	1.8	3.6	$3,962.99

          Records of material balances m	8	2	16	9	144	7.2	14.4
$15,851.95

          Records of supporting calculations n	8	2	16	13	208	10.4	20.8
$22,897.26

          Records for extended cookout o	8	2	16	1	16	0.8	1.6	$1,761.33

          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	$22,897.26

    G.  Time for audits	N/A







	Subtotal for Recordkeeping Requirements









Subtotals Labor Burden and cost  



	10,511	525.55	1,051.1	$1,157,041.81

TOTAL LABOR BURDEN AND COST (rounded)





12,087.65

12,088 (rounded)

$1,157.042



 Assumptions:

 a  We have assumed that there are approximately thirteen sources
subject to the standard which includes the following facilities: four
cellulose ether; four cellulosic sponge; three cellulose food casing;
one rayon; and one cellophane.  There will be no additional new sources
per year that will become subject to the rule over the three-year period
of this ICR.

   b  This ICR uses the following labor rates:  $119.36 per hour for
Executive, Administrative, and Managerial labor; $99.18 per hour for
Technical labor, and $49.35 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 2011, Table 2. Civilian Workers, by Occupational and
Industry groups.  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 a
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, including changes of information, closed-vent
systems, bypass lines, heat exchanger systems, and storage vessel
control device maintenance, will be reported twice per year.

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

i  We have assumed that it will take each respondent one hour to record
information on a daily basis on process vent, storage tank and
wastewater monitoring and inspections.

j  We have assumed that each respondent will enter and verify
information for the semiannual report twice per year.

k  We have assumed that it will take 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 of the nine 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 each of the nine respondent eight
hours to enter information on nine viscose process facilities using
material balances.

n  We have assumed that it will take eight hours for each respondent to
enter information on supporting calculations twice per year.

o  We have assumed that it will take respondent eight hours to enter
information on one cellulose ether facility that uses extended cookout.

p  We have assumed that it will take each of the thirteen respondent 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	$2,072.98

         Report of deviations d	8	2	16	3	48	2.4	4.8	$2,487.58

         Report of SSM e	2	2	4	13	52	2.6	5.2	$2,694.87

         Reports of equipment leaks f	8	2	16	4	64	3.2	6.4	$3,316.76

         Report on wastewater g 	8	2	16	4	64	3.2	6.4	$3,316.76

         Report on all other reports h	2	2	4	13	52	2.6	5.2	$4,151.99

Subtotals Labor Burden and cost



	320	16	32	$21,357.70

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	368	$21,358



 	Assumptions:

    a  We have assumed that there are approximately thirteen sources
that are subject to the standard which includes the following
facilities: four cellulose ether; four cellulosic sponge; 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: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21
for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6,
Step 3, $15.63 1.6).  These rates are from the Office of Personnel
Management (OPM) (2011 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  We have assumed that each of the four respondents for cellulose ether
facilities will review their report on equipment leaks two times per
year.

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

h  We have assumed that all other reports, including changes of
information, closed-vent systems, bypass lines, heat exchanger systems,
and storage vessel control device maintenance, will be reported twice a
year.

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