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 
2

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 
3

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
4

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.
5

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
6

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:
7

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.
8

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 
9

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 
10

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.
11

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
12

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).
13

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 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, 
14

Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA2011-0216 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.
15

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 c8 2 16 10 160 8 16 $17,613.28

 Semiannual report on deviations d16 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 f303 2 606 4 2,424 121.2 242.4 $266,841.19

 Semiannual report on wastewater See 4E

 Semiannual report on all other reports g8 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 h1.5 52 78 13 1,014 50.7 101.4 $111,624.16

 Records of continuous parameters 

 monitoring system (CPMS) data

 Record continuous monitor parameters i1 365 365 13 4,745 237.25 474.5 $622,303.25

 Compile data j24 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 k2 2 4 1 4 0.2 0.4 $440.33

 Records of nitrogen systems l2 2 4 9 36 1.8 3.6 $3,962.99
16

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

 Records of material balances m8 2 16 9 144 7.2 14.4 $15,851.95

 Records of supporting calculations n8 2 16 13 208 10.4 20.8 $22,897.26

 Records for extended cookout o8 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 p16 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.
17

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.
18

Table 2: Average Annual EPA Burden - 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 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

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

Review reports

 Review semiannual compliance report 

 Report of no deviations c2 2 4 10 40 2 4 $2,072.98

 Report of deviations d8 2 16 3 48 2.4 4.8 $2,487.58

 Report of SSM e2 2 4 13 52 2.6 5.2 $2,694.87

 Reports of equipment leaks f8 2 16 4 64 3.2 6.4 $3,316.76

 Report on wastewater g8 2 16 4 64 3.2 6.4 $3,316.76

 Report on all other reports h2 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) A2011 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.