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 1974.07, OMB Control Number 2060-0488. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Cellulose 

Products Manufacturing were proposed on August 28, 2000, promulgated on June 11, 2002, and 

most-recently amended on February 27, 2014. The 2014 amendment promulgated technical and 

editorial corrections on emission testing provisions. These regulations apply to both the 

miscellaneous viscose processes source category and the cellulose ethers productions source 

category that are major sources of hazardous air pollutant (HAP), that emit or have 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. 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. New facilities include 

those that commenced construction or reconstruction after the date of proposal. This information 

is being collected to assure compliance with 40 CFR Part 63, Subpart UUUU.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/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. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall 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 U.S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 13 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Of the 

thirteen existing sources: 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 
2

operation.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

In the United States, there are approximately 13 cellulose products manufacturing plants. 

None of these thirteen facilities are owned by either state, local, tribal, or the Federal 

government. They are owned and operated by privately-owned, for-profit businesses. The 

“burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and 

Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) 

(Renewal). The Federal Government “burden” is attributed entirely to work performed by either 

Federal employees or government contractors and may be found below in Table 2: Average 

Annual EPA Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 

63, Subpart UUUU) (Renewal). 

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 

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

either cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health and/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
3

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 check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and 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. 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 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 Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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 (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations
4

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 EPA's Office of Compliance. OTIS is EPA’s 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 standards as they were being developed and the 

standard has been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted both the American Association of 

Pharmaceutical Scientists, at (703) 243-2800, and the National Center for Biotechnology

Information, at (888) 346-3656.

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. In this 

case, no comments were received.

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

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 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 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 
5

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (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

The reporting or recordkeeping requirements in the standard do not include 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) code for the 

respondents affected by the standards and the corresponding North American Industry

Classification System (NAICS) codes are listed in the table below. 

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 325220

All Other Basic Inorganic Chemical 

Manufacturing

2819 325180

All Other Basic Organic Chemical Manufacturing 2869 325199

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU). 

A source must make the following reports:

Notifications

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

Notification of performance tests 63.5575, 3.7(b), 
6

Notifications

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(ce), 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)
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Reports

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
8

Recordkeeping

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 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.

(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, Reference Method 1 or 1A; 2, 2A, 2C, 2D, 2F, or 2G; 3, 3A, 

or 3B; 4; 15; 18 or 320; 25; 25A; 22; and 624 tests, 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.

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 monitoring and reporting equipment that provide 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

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 could 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 (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. 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 OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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 (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 below 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. 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 hours (Total Labor Hours from Table 1

below). 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 $128.02 ($60.98 + 110%) 
11

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2014, “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 13 $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 for this ICR 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. 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 
12

$16,749. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 below in Table 2: Average Annual EPA Burden and Cost – 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, approximately 13 existing respondents will be subject 

to the standards on average over the next three years. It is estimated that no additional 

respondents 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 that addresses the three 

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

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. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 13. 
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 $1,183,412. Details regarding these estimates may be 

found below 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 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 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 12,088 hours. Details regarding these estimates may be 

found below 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 $1,014. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.
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(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 $16,749. See below Table 2: Average Annual EPA 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 labor hours in this ICR compared to the previous ICR. However, 

there is a small adjustment decrease in the respondent and Agency labor costs to correct 

mathematical and rounding errors. 

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 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-2014-0080. An electronic version of the public docket is 

available at 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 

contents of the 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 

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), WJC West, 

Room 3334, 1301 Constitution Ave., 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 docket center 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, NW, 
15

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0080 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 (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 

personhours 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 $18,014.08

 Semiannual report on 

deviations d 16 2 32 3 96 4.8 9.6 $10,808.45

 Semiannual report of startup, 

shutdown, malfunction (SSM) e 8 2 16 13 208 10.4 20.8 $23,418.30

 Semiannual report on 

equipment leaks f 303 2 606 4 2,424 121.2 242.4 $272,913.31

 Semiannual report on 

wastewater See 4E

 Semiannual report on all other 

reports g 8 2 16 13 208 10.4 20.8 $23,418.30

Subtotal for Reporting Requirements 3,560.4 $348,572.45

4. Recordkeeping requirements

 A. Read instructions N/A

 B. Plan activities N/A
17

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 

personhours 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

 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 $114,164.23

 Records of continuous 

parameters monitoring system 

(CPMS) data

 Record continuous monitor 

parameters i 1 365 365 13 4,745 237.25 474.5 $534,230.06

 Compile data j

24 2 48 13 624 31.2 62.4 $70,254.91

 Enter and verify information 

for semiannual report j 16 2 32 13 416 20.8 41.6 $46,836.61

 Records of closed-loop systems 

k 2 2 4 1 4 0.2 0.4 $450.35

 Records of nitrogen systems l

2 2 4 9 36 1.8 3.6 $4,053.17

 Records of material balances m

8 2 16 9 144 7.2 14.4 $16,212.67

 Records of supporting 

calculations n 8 2 16 13 208 10.4 20.8 $23,418.30

 Records for extended cookout o

8 2 16 1 16 0.8 1.6 $1,801.41

 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 $23,418.30

 G. Time for audits N/A

Subtotal for Recordkeeping Requirements 8,527.3 $834,840.02

TOTAL LABOR BURDEN AND COST (rounded) 12,088 $1,183,412
18

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 threeyear period of this ICR.

 b

 This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and 

$51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, 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.
19

Table 2: Average Annual EPA Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart 

UUUU) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours per 

plant per 

year (AxB)

(D) 

Plants 

per year 

a

 

(E) 

Technical 

personhours per 

year (CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 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 $0.00

Review reports

 Review semiannual compliance 

report 

 Report of no deviations c 2 2 4 10 40 2 4 $2,093.60

 Report of deviations d 8 2 16 3 48 2.4 4.8 $2,512.32

 Report of SSM e 2 2 4 13 52 2.6 5.2 $2,721.68

 Reports of equipment leaks f

8 2 16 4 64 3.2 6.4

$3,349.76

 Report on wastewater g 8 2 16 4 64 3.2 6.4 $3,349.76

 Report on all other reports h 2 2 4 13 52 2.6 5.2 $2,721.68

TOTAL ANNUAL BURDEN AND COST

368 $16,749 

(rounded) 

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: $62.90 for 

Managerial (GS-13, Step 5, $39.31 x 1.6), $46.67 for Technical (GS-12, Step 1, $29.17 x 1.6) and $25.25 Clerical (GS-6, Step 3, $15.78 x 1.6). These rates are 
20

from the Office of Personnel Management (OPM) 2014 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.