**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 I CR Number 1974. 0 7 , 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

- recentl y 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 source s 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 an y combination of HAP at a rate of 23 megagrams per year (25 tons per y ear) or more

. The miscellaneous viscose processes source category includes the cellulose food casing, rayon, cellophane, an d cellulosic sponge industry sectors. The cellulose ethers production source category includes the carboxy

methyl cellulose, hydroxy eth yl cellulose, hydroxy propyl cellulose, hydrox yp rop yl methyl cellulose, and methyl cellulose industry sectors. New facili ties 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, perfo rmance 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 an y startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem 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 deleg ated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 13 respondents per ye ar will be subject to the standard , and no additional respondents per y ear 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 faciliti es; one is a rayon operation; and one is a cellophane2

operation. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.” In the United States, there are approximately 13 cellulose products manufacturing plants. None of these thirteen facilities are owned b y either state, local, tribal, or the Federal government. They

are owned and operated b y 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 entirel y to work performed b y either F ederal emplo ye es or government contractors and m ay 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 maintai n 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, duri ng 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 certification s in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from cellulose products manufacturing either cause or contribute to air pollution th at may reasonabl y be anticipated to endanger public health and/ or welfare. Therefore, th e 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 reporti ng require ments 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 co mply

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 o perating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor

. The notifications requi red 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 properl y i nstalled 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 an d 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own simi lar standards to implement the Federal standards, a cop y 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 N otice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 79 FR 30117 ) on May 27, 2014

. No comments were received on the burden published in the Federal Reg ister

.

**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 y ears have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all complianc e 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 s as they were being developed and the standard has been reviewed previousl y to determine the minimum information needed for compliance purposes

. Indeveloping this ICR, we contacted both the American Association of Pharmaceutical Scientists , at (703) 2 43

- 2800 , and the National Center for Biotechnology In formation , 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 not ice. 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines** T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute o f 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, an y pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has fo und that the most flagrant violators have violations extending beyond five ye ars. 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 made5

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, 19 76; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** T he 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 ( SI C ) code for the respondents affected b y the standards and the corresponding North American Industry Classification Sy stem (NAI CS ) 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 b y the NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU)

. A source must make the following reports:

**Notification s**  Initial notification 63.5575, 63.9(b)(1

- 5) Notification of performance tests 63.5575, 3.7(b),6
**Notification s**  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 s ys tem 63.5580, 63.148(j)(1) Semiannual report of b yp ass lines 63.5580, 63.148(j)(2

- 3), Semiannual report of heat exchanger s ys tems 63.5580,63.104(f)( 2)(i

- iv)7 **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 sy stem 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 sy stems 63.5585 Records of nitrogen s ys tems 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 sy stems 63.5585, 63.148(j) Records of b ypass lines 63.55858 **Recordkeeping** Records of heat exchanger s ys tems 63.5585, 63.104(f)(1) Records of storage vessel control device maintenance 63.5585
Electronic Reporting Some of the r espondents 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 th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems 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 test s , 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, acquiri ng, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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 s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantl y 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, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to co mpl y with the emission standard (note the operating conditions under which compliance was ach ieved.) 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. In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,0 00 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, r etrieve and analyze the data.10

The records required b y this regulation must be retained by the owner/operator for five ye ars. **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 ty pes 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 I CR. 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 an d 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 display s 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 requirement s is estimated to be 12,088 hours ( Total Labor Hours from Table 1 below ). T hese 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 Lab**  **or Costs** This I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%)11 Technical $ 10 1

. 05 ($4 8

. 12 + 110%) Clerical $ 5 1

. 37 ($2 4

. 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 b y 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 ty pe 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 photoc opying 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 mo nitoring system N/A N/A $0 $78 1 3 $1,014

The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR 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 IC R is estimated to be $ 1,014

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA' s overall compliance and enforcement program i ncludes activities such as the examination of records maint ained 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 y ears of the ICR is estimated to be12

$ 16,749

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 I CR, approximately 13 existing respondents will be subject to the standard s on average over the next three y ears. It is estimated that no additional respondents per ye ar 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 ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 13

.13

The total number of annual responses per ye ar 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.14
**(ii) The Agency Tally** The average annual Agency burden and cost over next three y ears 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 I CR compared to the previous I CR. 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 b y persons to generate, maintain, retain, or discl ose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing an d maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 display s 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 responde nt burden, including the use of automated collection techniques, EPA has established a public docket for this I CR 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 sy stem , 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 EP A 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,15

Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 wa stewater 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/A17

**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)** 

**Managem ent**  **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

**Assu mptions:**  a We have assumed that there are approximately thirteen sources subject to the standard which includes the following facilities: f our cellulose ether; four cellulosic sponge; three cellulose food casing; one rayon; and one cellophane. There will be no additio nal 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: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per h our 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 respond ents 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 info rmation on nine viscose process facilities with CS 2 , 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 facili ties 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 exten ded co okout. p We have assumed that it will take each of the thirteen respondent two days (16 hours) to provide refresher training to person nel.19

**Table 2: Average Annual EPA Burden and Cost**

**– 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 (AxB) (D)** 

**Plants per year**  **a (E)**  **Technical person**  **** **hours per year (CxD)**  **(F)**

**Managem ent**  **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 $0.00 Revie w 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**  )
**Assu mptions:**  a We have assumed that there are approximately thirteen sources that are subject to the standard which includes the following faci lities: 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 expen ses: $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 are20

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 p ercent 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 e quipment 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 chang es of information, closed

- vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, will be reported twice a year.