January 2015



### 1 **SUPPORTING STATEMENT NSPS for New Residential**  **Hydronic Heaters and Forced -**  **Air Furnaces**

**(40 CFR Part 60, Subpart QQQQ**  **) PART A**  **1.0 Identification of the**  **Information Collection** (a ) Title of the Information Collection. The title of the Information Collection Request (ICR) is NSPS for New Residential Hydronic Heaters and Forced - Air Furnaces (40 CFR Part 60, Subpart QQQQ ) ( Final Rule) . This is a new ICR , and the U.S. Environmental Protection A gency (EPA) tracking number i s 2442.0 2 , Office of Management and Budget ( OMB ) Control Number 2060 - 0693 . (b ) Short Characterization. This I CR covers information collection requirements in the final rule, New Source Performance Standards (NSPS) for new residential hydronic heaters and forced - air furnaces (40 CFR part 6 0 , subpart QQQQ (subpart QQQQ) ) . The information collected will be used by the EPA and delegated state and local agencies to determine the co mpliance status of sources subject to the rule. A residential hydronic heater is defined as a fuel burning device designed to burn wood or wood pellet fuel for the purpose of heating building space and/or water through the distribution, ty

pically through p ipes, of a fluid heated in the device, typically water or a water and antifreeze mixture. A residential forced - air furnace is defined as a fuel burning device designed to burn wood or wood pellet fuel that warms spaces other than the space where the furnac e is located, b y the distribution of air heated by the furnace through ducts. The residential hydronic heater and forced - air furnace NSPS is based on similar design principles as the NSPS for new residential wood heaters (40 CFR part 60, subpart AAA). The se NSPS es tablish a certification program instead of the usual NSPS requirement that each affected facility demonstrate compliance with emission limits through performance testing . Under this certification program, a single wood - heating appliance is tested to demonstrate compliance with particulate matter (PM) emission limits for an entire model line which could consist of thousands of stoves. The use of a certification approach significantly reduces the compliance burden, including information col lection , for the manufacturers of hydronic heaters and forced - air furnace s . In order to minimize risks to the environment from intentional or accidental misuse ofJanuary 2015



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the certification approach, subpart QQQQ also includes several safeguards, some of which entail reporting and recordkeeping. There are approximately

30 hydronic heater manufacturers, 7 forced - air furnace manufacturers and 4 laboratories (inclusive of both test labs and third -party certifiers) that would be subject to the final rule . Un der subpart QQQQ , hydronic heater and forced - air furnace manufacturers, testing laboratorie s, and third -party certifier s are required to submit reports to the EPA and to maintain records for demonstrating compliance with the NSPS. The information supplied by

the manufacturer to the EPA is used: (1) to ensure that the best sy stem of emission reduction is being applied to reduce emissions from hydronic heaters and forced - air furnaces ; (2) to ensure that the appliance tested for certif ication purposes is in compliance with the applicable emission standards; (3) to provide assurance that non - tested production model appliances have emission performance characteristics similar to tested models; and (4) to provide an indicator of continued compliance. In formation supplied to the EPA by testing laboratories and third -party certifiers is used to grant or deny laboratory

accreditation and to assist in enforcement and compliance activities. In formation supplied to the EPA by testing laboratories and certifying bodies/entities is used to grant or deny laboratory accreditation, assure continued test lab proficiency and to assist in enforcement and compliance activities . Subpart QQQQ does not require any reporting or recordkeeping requirements on hydronic heater or forced - air furnace owners or operators. However, the final rule specifies a list of prohibited fuel types and prohibited operations, as well as good operating and good burning practices (which are required to be included in the owner’s manual for certified models) that owners and operators are directed to follow when installing and operating their heating appliances. The phased implementation schedule of the final rule along with the two - step PM emission standards approach (with phased compliance dates) result s in differing recordkeeping and reporting impacts. For purposes of the supporting statement, we refer to these steps as Step 1 and Step 2. The compliance date f or meeting Step 1 emission standard s provided in the rule occurs in 2015 , and the compliance date f or meeting Step 2 emission standard s provided in the rule occurs in 2020. The recordkeeping and reporting burden cost estimate s as a result of the subpart QQQQ final rule for years 2018 to 2020 are presented in a memo to the docket. 1 

### The

1 Memorandum to Docket ID Number EPA - HQ - OAR - 2009 - 0734 from EC/R, Inc. 40 CFR Part 60, Subparts AAAJanuary 2015



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recordkeeping and reporting burden estimates included in this supporting statement are for ye ars 2015 to 2017 and the burden estimates outlined in the memo for ye ars 2018 to 2020 are both included in cost impacts estimates included in a memo in the docket for the final rule. 1 

### The estimated burden to the “Affected Public” is listed in Table 1 , “Three - Year and Annual Respondent Burden and Cost of Reporting and Recordkeeping Re quirements of th e Final Rule . ” The f

ederal government burden associated with the review of reports submitted by respondent s is shown in Table 2 , “Three - Year and Annual Burden and Cost to the Federal Government of the Final Rule . ” (Tables 1 and 2 are located at the end of this supporting statement.) We do not anticipate any reporting or recordkeeping burden for state, local or tribal entities because we have only delegate d ability to enforce the standards for residential hydronic heaters and forced - air furnaces sol d or operated in their region . Under subpart QQQQ, p artial delegations shall not include: (1) Decisions on certification; (2) Revocation of certification; (3) Standards; (4) Test methods; (5) Laboratory

and third - party

certifier approvals and revocations; (6) Enforcing provisions governing content of owner’s manuals; and (7) Hearings and appeals procedures. The information collection requirements for n ew sources subject to the NSPS for Residential Hydronic Heaters and Forced - A ir Furnaces are listed in Attachment 1 . **2. Need For and Use of the Collection**  (a ) Need/Authority for the Collection . The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect: “ **. . .** application of the best sy stem of emission reduction which (taking into consideration the cost of achieving such reduction and any non - air quality health and environmental impact and energy requirements) the Administrator determines has been adequatel y de monstrated. Section 111(a)(l). The a gency refers to this charge as selecting the “best sy stem of emission reduction . ” Section 111 also and QQQQ Estimated Three - Year and Annual Respondent Burden Cost of Reporting and Recordkeeping Requirements (Years 2018 to 2020) . January 2015 . 1 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts . January 2015.January 2015



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requires that the Administrator review and, if appropriate, revise such standards every 8 years. W ood burning hydronic he aters and forced - air furnaces are part of the residential wood heating source category , pollutant emissions from which cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare , in the Administrator's judgment . As part of the review process , the EPA has decided to expand the ty pes of appliances regulated under the residential wood heating source category to include hydronic heaters and forced - air furnaces. Therefore, the NSPS was promulgated for th ese appli ances at 40 CFR part 60, subpart QQQQ . The records and reports required under subpart QQQQ are nec essary for the Administrator to confir

m the compliance status of new residential hydronic heaters and forced air furnaces sold in the United States . These recordkeeping and reporting requirements are specificall y authorized by CAA section 114 . (b ) Practical Utility/

/Users of the Data. The control of pollution from new residential hydronic heaters and forced - air furnaces relies on the reduction of particulate matter emissions by proper appliance design. A representative unit for each model line is subjected to a certifi cation test for particulate matter emissions for a range of operating conditions . The manufacturer also contracts with a third -party certifier , which reviews the te st reports and quality assurance (QA) plan, and con ducts periodic QA audits to ensure that hydronic heaters and forced - air furnaces manufactured subsequent to the initial certification test continue to comply with the NSPS. Manufacturers must renew or recertify their model lines every 5 ye ars or when they make changes to the model line that would exceed specified parameters . The requir ed certification test notification is used to inform the EPA when a new model line is expected to be tested. The EPA may th en observe the testing, if desired . Emission test reports are needed as these are the EPA ’s record of a model line’s initial capabili ty to comply with the emission standard, and serve as a record of the operating conditions under which compliance was achieved. The EPA compliance audit tests and QA annual audit reports are necessary to ensure continued compliance with the emission standards. Adequate recordkeeping and reporting are necessary to ensure compliance with these standards as required b y the CAA . The information collected from recordkeeping and reportingJanuary 2015



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requirements is also used for targeting inspections and is of sufficient quality to be used as evidence in court. **3. Non**  **- duplication, Consultations, and Other Collection Criteria**  (a ) Non - duplication. A computer search of the EPA ’ s ongoing ICRs revealed no duplication of information gathering efforts. Similar requirements to this NSPS are found in the requirements to 40 CFR part 60, subpart AAA, the NSPS for Residential Wood Heaters. Subpart AAA has a separate ICR undergoing OMB review. Although the requirements are similar, they are not duplicative because they

appl y to separate groups of appliances and the ir associated manufacturers. In the case of test laboratories and third -party certifiers , similar accreditation requirements are found in both subparts (40 CFR part 60, subparts AAA and QQQQ) , but each has different test methods. Therefore, the requirements under each of these subparts are not duplicative because separate accreditation is required for each test method. (b ) Public Notice Required Prior to ICR Submission to OMB. The preamble to the p roposed r ule (79 FR 6330, February 3, 2014) provide d public notice of the proposed ICR . The EPA considered comments (see Docket ID N o. EPA - HQ - OAR - 2009 - 0734) when preparing this revised ICR. The preamble to the final rule provide s public notice on this revised I CR. (c) Consultations. The final rule w as developed using information obtained during extensive consultation with individual companies , trade associations and s tate agencies . Several of the key non - EPA persons consulted on the information collection activitie s are identified in Table 3 . Additional meetings and contacts are documented in the project docket for this final rule , Docket No. EPA HQ - OAR - 20 09 - 0734 .January 2015



### 6 **TABLE 3. PERSONS CONSULTED ON THE INFORMATION**

**COLLECTION ACTIVITIES Contact**  **Organization Telephone**  **Number** Dennis Brazier Central Boiler John Crouch Hearth, Patio, Barbecue Association (HPBA) 916.536.2390 Rick Curkeet Intertek Testing Services 608.836.4400 Alice Edwards Alaska Dept. Of Environmental Conservation 907.465.5105 Chuck Gagnor Northwest Manufacturing Stephen Hartsfield National Tribal Air Association 505.242.2175 Frank Moore Hardy Manufacturing 601.656.5866 Ben M yr en My ren Consulting, Inc. 509.684.1154 Scott Nichols Tarm Biomass Lisa Rector Northeast States for Coordinated Air Use

Measurement (NESCAUM) 617.259.2095 Rod Tinnemore Washington State Department of Ecology 360.407.6978 ( d) Effects of Less Frequent Collection. Less frequent information collection would decrease the margin of assurance that manufacturers are produc ing residential hydronic heaters and forced - air furnaces that (1) pass the initial certification test , and (2) continue to be manufactured in a way that ensures continuous compliance with the emission standards. If the information required b y these standards w ere collected less frequentl y, the likelihood of detecting violations would be reduced . (e) General Guidelines . None of the guidelines in 5 CFR 1320.6 is being exceeded , with the exception of the requirement to retain records for 5 ye ars (which exceeds the guideline requirement that records not be required to be retained for more than 3 ye ars) . The basis for the 5 - ye ar record retention is due to required emission standard model certifications being valid for 5 years prior to the need for renewal or recertification . During this time, the EPA need s to require the retention of model certification test s and QA compliance documentation to support initial and continued compliance with model certification s (e.g., certification tests, QA emissions tests, QA audit reports, biennial reports). (f ) Confidentiality. All information submitted to the agency for which a claim of confidentiality is made will be safeguarded according to the EPA regulations set forth in 40 CFR 2.201 et seq ., Cha pter 1, Part 2, Subpart B

—Confidentiality of Business Information.January 2015



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(g ) Sensitive Questions. This section is not applicable because this ICR does not involve matters of a sensitive nature. **4. The Respondents and the Information Requested**  (a ) Respondents/NAIC

S Codes . Potential respondents under s ubpart QQQQ are manufacturers of new residential hydronic heaters and forced - air furnaces . The North American Industry Classification System (NAICS) code for residential hydronic heating manufacturing facilities is 33 3414, Heating Equipment (Except for Warm Air Furnace Manufacturing). The NAI CS code for forced - air furnaces is 333415 , Air- Conditioning and Warm Air Heating Equipment and Commercial and Industrial Refrigeration Equipment Manufacturing . S ubp art QQQQ als o applies to laboratories that conduct or plan to conduct hydronic heater and forced - air furnace certification tests (referred herein as testing labs) and laboratories that plan to become third-party certifiers (referred herein as third -party c ertifiers) for manufacturers. The NAI CS code for testing laboratories is 541380 . (b ) Information Requested. (i ) Data Items, Including Recordkeeping Requirements. Inthis ICR, all the data recorded or reported is required b y the NSPS for New Residential Hydronic Heaters and Forced - air Furnaces (40 CF R Part 60, s ubpart QQQQ ). The reporting requirements for NSPS subpart QQQQ were uniquely designed for the manufacturers , third -party certifiers and testing laboratories. The records required by this regulatio n must be retained b y the manufacturer, third party certifier and/or test laboratory for 5 years. A special table is attached that describes the reporting and recordkeeping requirements . See Attachment 1. (ii) Respondent Activities. The respondent activities that will be required b y the final rule are identified in Table 1 (located at the end of this supporting statement) and introduced in section 6(a). **5. The Information Collected** **– Agency Activities, Collection Methodology and**  **Inform ation Management**  (a ) Agency Activities. Attachment 2 is a summary of the reporting and recordkeeping requirements for the f ederal government. The agency activities associated with the final rule are provided in Table 2 (located at the end of this supporting statement) and are introduced in section 6(c).January 2015



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(b ) Collection Methodology and Management . All reports are sent directly to the EPA electronically . Dat a obtained from reports submitted and records maintained b y the respondents will be use d in compliance and enforcement programs. Portions of the data obtained will be entered into a special database program maintained exclusively by the EPA and some of the data will be made available to the public on an EPA website. The EPA provide s public access to the l ist of certified appliances and their emissions ratings on line at http://www.epa.gov/compliance/resources/publications/monitoring/caa/woodstoves/certifiedwoo d.pdf . (c) Small Entity Flexibility. Most of the manufacturers, laboratories and commercial owners affected b y th e final r ule are considered small businesses based on the definition used by the Small Business Administration . Additional efforts were taken b y the EPA to reduce the burden imposed on the small businesses affected by this regulation. For instance, we have included provisions that allow models with existing certifications th at meet Step 1 emission standards that meet specified (conditional) criteria to be automaticall y certified until the Step 2 emission standards effective date (2020). We believe that allowing this automatic conditional certification approval and including phased compliance dates in the final rule allow s additional time for sources to come into compliance and help s to reduce the burden on small businesses by spreading out research and development (R&D) costs over several ye ars . The final rule also includes QA program requirements that align with existing safety QA procedures, thus avoiding duplicative procedures. Additionally , the final rule allows currently EPA - accredited testing laboratories to be allowed to test as approved testing labs for subpart QQQQ for three ye ars after the effective date of the rule. F or forced - air furnaces, w e have also deferred implementation of the requirement that third -party certifiers be accredited under subpart QQQQ until 6 months after the effective date of the final rule . (d ) Collection Schedule . The specific frequency

for each information collection activity within this request is shown in Table 1 for new residential hydronic h eater s and f orced - air f

urnace s , which is located at the end of this supporting statement .January 2015



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**6. Estimating the Burden and**  **Cost of the Collection** (a ) Estimating Respondent Burden. The annual recordkeeping and reporting respondent burden estimates for subpart QQQQ are shown in Table 1 , located at the end of this section . These numbers were derived from estimates based on EPA’s experience with implementing existing subpart AAA rule and other rule s , and the EPA voluntary hydronic heater program . (b ) Estimating Respondent Costs. (i) Estimating Labor Costs . Lo aded l abor rates have been calculated for 20 1 3 . We used May 20 13 labor rates from the Bureau of Labor Statistics for the Ventilation, Heating, AirConditioning and Commercial Refrigeration Equipment Manufacturing (NAI CS 33 34 00) . 1 

### Loading factors (i.e., fringe benefits and overhead rates) were calculated using methodolo gies referenced in promulgated regulations and their accompanying I CRs, particularly those used in New Source Review regulations. Fringe benefits are calculated as 29 percent of hourl y earnings, and overhead is calculated using a standard 110 percent above hourl y earnings. Table 4 presents the labor rates used in the cost anal ys is. **Table 4**  **. 20 1**  **3 L**  **OADED LABOR RATES Labor Category**  **Hourly**

**earnings [$20**  **13 ]**  **Fringe Overhead**  **Loaded 201 3**  **Hourly Earnings ($)**  Professional specialty and technical 31.53 1.29 2.1 $ 85 . 41 Executive, admin, managerial 5 4 . 89 1.29 2.1 $14 8 . 70 Admin support 1 8 . 22 1.29 2.1 $4 9 . 36 

### (ii) Estimating Capital and Operations and Maintenance (O& M) Costs . In this section we provide estimated capital costs and one - time start - up costs associated with complying with the NSPS over the 3 - ye ar I CR clearance period. These costs are summarized in Table 5 at the end of this section . Estimated capital costs included in Table 5 include fixed capital cost estimates provided b y an anal ys is prepared by Fergus on, Andors & Company for the Hearth,

1 May 2013 National Industry- Specific Occupational Employment and Wage Estimates . Located http://www.bls.gov/oes/current/naics4_333400.htm .January 2015



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Patio and Barbecue Association. 1 

### See the manufacturer costs impacts memo 2 

### and the unit cost memo 3 

### for more information on assumptions used in this section. As discussed in the manufacturer costs impacts memo , we estimate that there are currentl y 50 model lines of forced - air furnaces produced b y 7 manufacturers and 120 model lines of hydronic heaters (about 10 percent of which are indoor hydronic heaters) produced b y 30 manufacturers. We assume that of these 170 existing model lines, 47 models (approximately 5 forced air furnace models and 42 hydronic heater models) will meet EPA criteria as meeting Step 1 emission standard s and will qualify for conditional certification approval until 2020 and will not have to undergo certification testing during the three - ye ar IC R period (2015 - 2017). We assume that a like number of models to replace existing models that currently do not meet the Step 1 emission standards ( approximately 115 models (45 forced air fur nace models and 70 hydronic heater models )) will be developed/tested and will apply to certify to meet Step 1 emission standards or Step 2 emission standards and would be required by the NSPS to arrange for certifi cation testing during the three - ye ar ICR p eriod (2015 - 2017) at a cost of $55,000 per test (assumes EPA testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs) . 4 

### The final rule require s a permanent label on each hydronic heater and forced - air furnace model , just as required under subpart AAA. To estimate the costs of permanent labels, we assumed the capital costs to be $1,250 per model certif ied (including those with conditional certification) and that all new models produced b y manufacturers (170 ; 120 outdoor hydronic heater models, 50 forced - air furnace models ) produced by all manufacturers will have a permanent label affixed. These costs are consistent with cost estimates provided in Ferguson’s anal ys is. 5

1 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental C ost Effectiveness Analyses , Appendix A: Woodstove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643). 2 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts . January 201 5 . 3 Memorandum to USEPA from EC/R, Inc. Unit Cost Estimates of Residential Wood Heating Appliances . January 2015 . 4 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Hydronic Heater Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 7, Table 6. Fixed Costs per Model - Certification). May 2014. 5 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Hydronic Heat er Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); PageJanuary 2015



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The final NSPS requires that each hydronic heater and forced - air furnace offered for sale by a commercial owner be accompanied b y an owner’s manual that contains specified installation and operation and maintenance information required to be followed to minimize emissions. We have assum ed an average fixe d cost of $3,7 50 for owner's manual (revised or new, possibly

bilingual) per m odel, assuming 170 model owner's manuals will need to be develope d/revised to include subpart QQQQ requirements. These costs are consistent with cost estimates provided in Fergus on’s anal ys is. 1 

### The final rule includes the requirement for a QA program whereb y the manufacturer contracts with a third -party certifier to conduct QA audits. The third -party certifier will be required to conduct regular (at least annual), unannounced audits (and prepare a report for submission to the EPA) of each certified model line to ensure that the manufacturer’s QA plan is implemented properl y. For purposes of this ICR, w e assume that the contracted third -party certifier will require one QA perfor mance test and two QA audits for each o f the hydronic heater and forced - air furnace manufacturers (37 manufacturers) under the Q A program between 2015 and 2017. Another category

of capital costs includes costs that would be incurred if the EPA requests a compliance audit, which would be infrequent and sporadic . Under the final rule, we anticipate EPA conducting one audit test for one m odel that would affect one manufacturer during the period covered by this ICR (2015 - 2017) . Costs assume the c ost of one app liance (based on the average cost of three appliances: 1 outdoor ($11,571) and 1 indoor ($11,543) hydronic heater and 1 forced - air furnace ($2,579)) , plus $55,0 00 for one test (assumes EPA testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs) . The last category

of capital costs relates to IS O accreditation costs for test labs and third party certifiers seeking accreditation (at a cost of $75,000 /accreditation) .

7, Table 6. Fixed Costs per Model - Certification). May 2014. 1 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Hydronic Heater Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 7, Table 6. Fixed Costs per Model - Certification). May 2014.January 2015



### 12 **T ABLE**  **5 . E**  **STIMATED CAPITAL /START**  **- UP**  **COSTS FOR 3 -**  **YEAR**

**CLEARANCE PERIOD**  **(201 5**  **- 201**  **7 )**  **(A) (B)**  **(C) (D)**  **Data Collection Device**  **Capital/Start -**  **U p for** 

**One Respondent/Unit Number of New**  **Respondents/ Models/** **Units Total**  **Capital/Start -**  **Up Cost**  **(B X C)** Certification Test a 

### $ 55,000 per respondent 115 model s $ 6,325 ,000 Cost of Permanent Label **b** 

### $ 1, 2 50 per model 170 model s $ 212,5 00 QA Performance Test **c** 

### $ 55 ,000 per respondent 37 respondents $ 2,035,000 EPA Compliance Audit Test d 

### $63,564 per respondent 1 respondent $ 63,564 Owner’s Manual e 

### $3,750 per model 170 models $637,5 00 ISO Accreditation

– Test Laboratories f 

### $75,000 per respondent 2 respondents $150,000 ISO Accreditation

– Third - Party Certifiers g 

### $75,000 per respondent 2 respondents $150,000 **Total** $ 9,573,564 **Annual Average** $ 3,191,188 a Models certified by testing per manufa cturer: Assumes that 42 % of exis ting hydronic heater models (.42 X 120 mo dels = 50) and 10% of existing forced air furnace models (.10 X 50 models= 5) will not need to test to certify to meet limits during the three - year ICR period (2015 - 2017) . We assume that manufacturers will test ( at a cost of $55,000 per test ( includes EPA testing ($30,000), confirmation safety testing or full safety testing ($22,500), and shipping of prototype(s)($2,500) costs)) and apply to meet either Step 1 emission standards or Step 2 emission standard for 115 mo dels ( 70 hydronic heater and 45 forced - air furnace mo dels) during the three year ICR period (2015 - 2017) in order to replace old models that will not meet the 2015 and 2016/2017 (for forced - air furnaces) compliance emission standards. b Total costs of permanent labels are estimated to be $1,250 per model (170 mo dels) (2015 - 2017). c Assumes each of the manufacturers (37 manufacturers ) will be required to test one of their mo del s under the ir Q A program during the period covered by this ICR ( 2015 - 2017) at $55,000 per test ( includes EPA testing ($30,000), confirmation safety testing or full safety testing ($22,500), and shipping of prototype(s)($2,500) costs). d Assumes one mo del line will be audited by EPA during the three - year ICR period (2015

– 2017 ) . Costs assume the cost of one appliance (based on the average cost of three appliances: 1 outdoor ($11,571) and 1 indoor ($11,543) hydronic heater and 1 forced - air furnace ($2,579)) plus the cost of testing at $55,000 (assumes EPA testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs).January 2015



### 13 e Assumes an average fixed cost of $3,750 for ow ner's manual (revised or new , possibly bilingual) per model certified (assumes 170 mo del lines from 37 manufacturers). f Assumes all test labs will be ISO accredited (that are going to choose be accredited) before 2018, a total of four labs between 2015 and 2017 and 0 occurr ences between 2018 and 2020. We assume an average cost to obtain ISO accreditatio n is $75,000 based on cost estimates provided by manufacturers. g Assumes all third -party certifiers will be ISO accredited (that are going to choose be accredited) before 2018, a total of four labs between 2015 and 2017 and 0 occurr ences between 2018 and 2020. We assume an average cost to obtain ISO accreditatio n is $75,000 based on cost estimate s provided by manufacturers. 

### (i ii ) Annualizing Capital Costs . The total annual capital/start - up costs are estimated to average $ 3,191,188 over the period of this I CR (201 5 - 201 7 ) . (c) Estimating Agency Burden and Cost . The major costs to the EPA are those costs associated with reviewing applications for model certification s, testing lab and third -party certifier accreditations, and ongoing compliance verification QA functions. This is consistent with the overall EPA compliance and enforcement program , which includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emission s and the publication and distribution of collected information. The average annual agency cost during the 3 ye ars of the I CR is estimated to be $28,630 . See Table 2, located at the end of this supporting statement. The agency labor rates are from the Office of Personnel Management 20 1 4 General Schedule which excludes locality rates of pay . These rates can be obtained from Salary Table 20 1 4 - GS available on the OPM website, http://www.opm.gov/policy- data - oversight/payleave/salaries - wages/salary- tables/pdf/2014/salhrl.pdf . The government employee labor rates are $1 5 . 78 /hour for clerical (GS - 6, Step 3), $2 9.17 for te chnical (GS - 12, Step 1) and $3 9.31 /hr for management (GS - 13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully- burdened wage rates used to represent agency labor costs are: clerical at $ 2 5 . 25 ; technical at $ 4 6 . 67 and management at $ 62. 90 . (d ) Estimating the Respondent Universe and Total Burden and Costs . Subpart QQQQ requires hydronic heater and forced - air furnace manufacturers , test laboratories and third -party certifiers to submit reports to the EPA and/or to maintain records for demonstrating and documenting compliance with the NSPS. A third -party certification process is required under subpart QQQQ . Under this process , for all heaters/stoves subject to subpartJanuary 2015



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QQQQ, after testing is complete d by an approved test laboratory , a certifi cation of conformity with the particulate matter emissions standard s mus t be issued by a third -party

certifier with whom the manufacturer has entered into contract for certification services. To avoid the potential for manufacturer model certification delays (and the potential for lost revenues), we are allowing automatic conditional certification for hydronic heaters and forced - air furnaces that meet Step 1 emission standard s until the Step 2 emission standard s compliance date (2020). The third -party certifier is an independent third -party that is ISO accredited to perform certifications, inspections and audits by an accr editation body . The third -party certifier can certify conformity

if the em ission tests have been conducted per the appropriate guidelines; the test report is complete and accurate; the instrumentation used for the test was properl y calibrated; the test report shows that the rep resentative hydronic heater or forced - air furnace me ets the applicable emiss ion standard s ; and the QA plan prepared by the manufacturer is adequate to ensure that units within the model line will be similar in all material respects that would affect emissions to the wood heater submitted for certification testing. The third -party certifier is also required to conduct regular (at least annu al) unannounced audits to ensure that the manufacturer’s QA plan is being implemented and must prepare a report for each audit that fully documents the results of the audit. The manufacturer must include in its contract with the third party certifier the a

uthorization and requirement to submit all such reports to the Administrator . The I SO accreditation and approval to be third -party certifiers will be required on the effective date for hydronic heaters and 6 months after the effective date of the rule for forced - air furnaces. We have assumed that two laboratories will be ISO - accredited and will apply to be third -party certifiers and two will seek to obtain accreditation and will apply to be third -party certifiers during the three - ye ar ICR period (2015 - 2017) . Test laboratories that want to become approved test laboratories to conduct NSPS certification testing will need to appl y for IS O accreditation as a test laboratory , conduct proficiency

testing and report th e results of all such testing. A ccredited appro ved test laboratories must maintain records of all certification tests, proficiency tests and compliance audit test data. Approved test laboratories must be approved for hydronic heater and forced air furnace certification under subpart QQQQ or must be an independent third -party test laboratory that is accredited b y a nationally recognized accrediting entity to perform testing using the test methods specified in subpart QQQQ . The final rule allows a three - ye ar extension of current EPAJanuary 2015



### 15

accreditations of labs (as approved test laboratories). Laboratories not currently EPA - accredited will be required (as of the date 6 months after the effective date of the final rule) to register their credentials with the EPA and be approved b y the EPA prior to conducting any certification testing or related work used as a basis for compliance with subpart QQQQ . Of the 4 labs, we assume that 2 will have ISO accreditation as test laboratories b y the effective date of the final rule and 2 will obtain I SO accreditation as test lab oratories during the three - year period covered by this ICR (2015 - 2017). This I CR assumes that there is an overlap of laboratories that will obtain accreditation and approval as approved testing laboratories and as third -party certifiers under subpart QQQQ. The only subpart QQQQ final rule testing laboratory and third -party

certifier recordkeeping and reporting burden costs not passed on to the manufacturer would be the burden associated with obtaining ISO accreditation, proficiency testing and reporting req uired for approved test laboratories to maintain accreditation and approval as test labs, and specified recordkeeping requirements (e.g., certification tests, proficiency tests, QA program inspections, audit test results). There are an estimated 37 existing manufacturers that will be subject to the Residential Hydronic Heater and Forced - Air Furnace NSPS . We recognize that this value may be high. We obtained information on the number of existing manufacturers b y appliance ty pe, which may double count manufa cturers that make more than one ty pe of appliance. Also, there seems to be a certain amount of consolidation in the industry . However, the number of new manufacturers, particularl y outside of the United States, is unknown. Therefore, we consider the total of 37 manufacturers to be a reasonable estimate of the number of new and existing manufacturers. M anufacturers of new hydronic heaters and forced - air devices are required to submit applications for certification of model lines, to submit results of emissi ons tests conducted to demonstrate that the model lines woul d comply with the emission standard s and produce certified unit s according to a QA plan approved b y an independent third -party certifier . For hydronic heaters, compliance dates with Step 1 and Step 2 emission limits are 2015 and 2020, respectivel y. For forced - air furnaces, compliance with work practice/operational standards is required in 2015, and compliance with Step 1 emission limits for small (<65,000 BTU/hr models) and larg e furnaces ( > 65, 000 BTU/hr models) is required in 2016 and 2017, respectivel y. The final rule allows hydronic heater/forced - air heater model s that meet specifiedJanuary 2015



### 16

EPA criteria that show compliance with the Step 1 emission standard s to be automaticall y deemed as certified to meet the Step 1 emission standard s under this final rule until the Step 2 emission standards compliance date (2020) . Manufacturers must submit a notification of the initial test and biennial reports that each certified model line remains unchanged. They must also maintain records of all certification data, maintain results of QA program inspections and emissions test data, and seal and store the tested appliance. M anufacturers are also required to apply permanent labels on each applicable unit prior to s ale. These labels provide important compliance information to enforcement officials and important information to consumers for purchasing appliances. For subpart QQQQ , the components of the total annual responses attributable to this ICR are test notifications, applications for certification, biennial reporting for certified models, applications for accreditation , test report submittals , QA audit reports and test lab proficiency reporting for the 4 1 re spondents (37 manufacturers and 4 testing laboratories (including both approved test laboratories and third -party certifiers ) ) that will be subject to the rule. The number of total annual responses for subpart QQQQ is estimated at 199 . (e) Bottom Line Burden Hours and Cost Tables. (i ) Respondent T

ally. The bottom line respondent burden hours and costs for the 3 years (2015 - 2017 ) covered b y this I CR are presented in Table 1 (located at the end of this supporting statement) . The average annual burden for the recordkeeping and reporting requirements in subpart QQQQ for the estimated 37 manufacturers and 4 laboratories (consisting of both thirdparty certifiers and test laboratories) that will be subject to subpart QQQQ is 2,337 person - hours , with an annual labor average labor cost of $ 191,904 (approximately $140,000 for manufacturers, $15,000 for third -party

certifiers and $36,000 for test laboratories) and annualized capital/start up costs of $ 3,191,188 . (ii) The Agency T

ally. The average annual Federal Go vernment cost is $ 28,630 for 629 hours for subpart QQQQ . The bottom line agency burden hours and costs for the 3 ye ars covered b y this ICR are presented in Table 2 (located at the end of this supporting statement) . (iii) Variations in the A nnual B ottom L ine. This section does not appl y since no significant variation is anticipated.January 2015



### 17

(f ) Reasons for Change in Burden. We are requesting a burden of an estimated 2,337 hours and annualized capi tal/startup costs of $3, 191,188 due to implementation of this new regulation. (g ) Burden Statement The average annual respondent burden for the New Residential Hydronic Heaters and Forced - Air Furnaces NSPS is approximately 57 hours with an average annual burden per response of 12 hours. Burden means the total time, ef fort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 currently valid OMB control number. The OMB control numbers for EPA ’ s regulations in 40 CFR part 6 0 are listed in 40 CFR part 9. To comment on the agency ’s need for this information the accuracy of the provided burden estimates, and any suggestions for minimizing respondent burden, including through the use of automated collection techniques, the EPA has established a public docket for this ICR under Docket ID No. EPA - HQ - OAR - 2009 - 0734 , which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and In formation Center in the EPA Docket Center (EPA/DC), EP A WJC West Building , 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) 5 66 - 1744, and the telephone number for the EPA Docket is (202) 566 - 1742 . An e lectronic version of the public do cket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search,” then key in o ne ofJanuary 2015



### 18

the Docket ID Number s identified above. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17 th 

### Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the re levant Docket ID Number ( EPA - HQ - OAR - 2009 - 0734 ) and OMB Control Number (2060 -NEW) in any c orrespondence. **PART B** This section is not applicable because statistical methods are not used in data collection associated with the final rule.January 2015



### 19 (A ) (B) (C) (D) (E) (F) (G ) (H) (I) (J) (K) Pers on- No. of Pers on-hours Res pondents Technical Ma nagem ent Clerical Cos t,$ b Total Avg . a nnual Avg . a nnual hours per occurrences per res pondent 2015-2017 pers on-hours pers on-hours a pers on-hours a 2015-2017 pers on-hours pers on-hours cos ts occurrence per res pondent 2015-2017 2015-2017 2015-2017 2015-2017 2015-2017 **Ac tiv** **it y**  2015-2017 (C=A xB ) (E=CxD) (F=Ex 0.05) (G=Ex

0.1) (I=E+F+G) (J=I/3 ) (K=H/3) **Re por**  **ti ng Re**  **quir emen**  **ts Manufa**  **cturers** 1. Ce rt if ic ation tes t n ot if

ic ation c 2.00 3. 1 6. 2 37 230. 0 11. 5 23. 0 22, 491 $ 264. 5 88. 2 7,497 $ 2. A pplicat ion for cert if

ic ation d 8.00 3. 1 24. 9 37 920. 0 46. 0 92. 0 89, 963 $ 1, 058. 0 352. 7 29, 988 $ 3. Bie nnial report ing e 2.00 4. 6 9. 2 37 340. 0 17. 0 34. 0 33, 247 $ 391. 0 130. 3 11, 082 $ 4. EPA com pliance audit

te st ing f 8.00 1. 0 8. 0 1 8. 0 0.4 0.8 782 $ 9. 2 3.1 261 $ 5. QA p erform ance tes t res ults g 2.00 1. 0 2. 0 37 74. 0 3.7 7.4 7, 236 $ 85. 1 28. 4 2,412 $ 6. QA a nnual audit

report h 20. 00 37. 0 740. 0 2 1,480. 0 74. 0 148. 0 127, 898 $ 1, 702. 0 567. 3 42, 633 $ 7. Re vi ew annual QA

audit report

i 4.00 2. 0 8. 0 37 296. 0 14. 8 29. 6 26, 767 $ 340. 4 113. 5 8,922 $ **Te st La**  **bor ato**  **ri es**  1. A pplicat ion for tes t l ab approv al j a. A lready has IS O a ccreditat ion 20. 00 1. 0 20. 0 2 40. 0 2.0 4.0 4, 901 $ 46. 0 15. 3 1,634 $ b. N eeds to obtain ISO a ccreditation 80. 00 1. 0 80. 0 2 160. 0 8.0 16. 0 15, 646 $ 184. 0 61. 3 5,215 $ 2. Bie nnial prof

ic iency te st ing and report

dev elopm ent

k 150. 00 1. 0 150. 0 4 600. 0 30. 0 60. 0 58, 671 $ 690. 0 230. 0 19, 557 $ **Thir d-**  **Party**

**C ertifi**  **ers** 1. A pplicat ion fo r approv

al as a th ird-body

ce rt if ier l a. A lready has IS O a ccreditat ion 20. 00 1. 0 20. 0 2 40. 0 2.0 4.0 3, 417 $ 46. 0 15. 3 1,139 $ b. N eeds to obtain ISO a ccreditation 80. 00 1. 0 80. 0 2 160. 0 8.0 16. 0 13, 666 $ 184. 0 61. 3 4,555 $ Subtotal fo r Report ing Requirem ents 4,348. 0 217. 4 434. 8 404, 685 $ 5, 000. 2 1, 666. 7 134, 895 $ **Re co**  **rd keep**  **ing Re quir**  **emen ts**  **Manufa cturers**  1. Te st d ocum entat ion m 1.00 4. 6 4. 6 37 170. 0 8.5 17. 0 16, 624 $ 195. 5 65. 2 5,541 $ 2. QA p aram eter ins pections n 2.00 12. 0 24. 0 37 888. 0 44. 4 88. 8 86, 833 $ 1, 021. 2 340. 4 28, 944 $ 3. Re ta ined (s ealed) stov es o 1.00 3. 1 3. 1 37 115. 0 5.8 11. 5 11, 245 $ 132. 3 44. 1 3,748 $ **Te st La**  **bor ato**  **ri es**  1. Ce rt if ic ation tes t, p roficiency te st , a nd audit

te st re su ltsp 2.00 36. 0 72. 0 4 288. 0 14. 4 28. 8 28, 162 $ 331. 2 110. 4 9,387 $ **Thir d-**  **Party**

**C ertifi**  **ers** 1. Ce rt if ic ation tes t, QA

program i ns pect ion and audit te sts q 2.00 36. 0 72. 0 4 288. 0 14. 4 28. 8 28, 162 $ 331. 2 110. 4 9,387 $ Subtotal fo r Recordkeeping Requirem ents 1,749. 0 87. 5 174. 9 171, 027 $ 2, 011. 4 670. 5 57, 009 $ TOTA L BURDEN A

ND CO ST (SA

LARY ) 6,097. 0 304. 9 609. 7 575, 712 $ 7, 011. 6 2, 337. 2 191, 904 $ TOTA L NUM BER OF R ESPON SES 2015-2017 598 An nual av g. 199 a M anagem ent

p ers on-hours a nd clerical pers on-hours a re as su me d to be 5 percent and 10 percent of tech nical pers on-hours , re sp ectiv ely. b C os ts a re bas ed on th e fo llowing hourly rates : te chnical at

$88.41, m anagem ent at $ 148. 70 and clerical at $49.36.

d Mo del applicat ions p er m anuf acturers : 1 15 mo del lines from 3 7 m anuf acturers projected from 2 015-2017.

f As su me s that

one of th e 37 ma nuf

acturers w ill be required to undergo an EPA co mp liance audit

te st fo r one of the ir m odels during t he th ree-y ear ICR period (2015-2017). TA BLE 1. THRE E-YEAR AN D AN NUA L RE SPON DE NT BU RDE N AN D COS T OF RE PORTING AN D RE CORDK EEPI NG RE QUI RE MEN TS O F T HE FI NA L RULE ( 2015-2017)

c Mo dels ce rt if

ied by te st ing per m anuf

acturer: A

ssu me s 10% of force d air f urnaces ( .1 X

5 0 m odels = 5 ) and 42% of hy dronic heater (.42 X 120 mo dels = 5 0) m odel lines w ill not n eed to te st

to c ertify to m eet em is si on standards during th e th ree-y

ear period (2015-2017). We a ssu me th at m anuf acturers wi ll tes t a nd apply to m eet e missio n standards fo r 115 m odels ( 45 forced air furnace m odels a nd 70 hy dronic heater m odels ) during t he th ree y ear I CR period (2015-2017) in order to replace old mo dels th at wi ll not m eet th e 2015 (f

or hy dronic heaters ) and 2016/2017 (for fo rced-air f urnaces ) com pliance em issio n standards .

h, i A ssu me s there will be two QA a udits by

th e thi rd-part

y cert if ier f or each of the 3 7 m anuf acturers ov

er th e three-y

ear ICR period (2015-2017) and th at e ach of the se a udit

reports will be reviewed by th e m anuf

acturer (in all cas es ) and ma y require preparing a res pons e to th e audit ( in cas es where def

ic iencies a re identified). It i s as su me d that th e th ird-party

certifier will audit

m ult iple ma nuf

acturer mo dels w hen th ey co nduct th eir audits (t hereby

reducing the ti me n eeded to a udit

m anuf acturers and t heir as so ci ated mo dels ). e Fo r purpos es o f th is IC R, we as su me th at 170 m odels wi ll eit her te st a nd apply

to cert if y to m eet

Step 1 em is sio n standards /Step 2 e missio n standards or w ill obtain a condit ional approv al as m eet ing lim its. We h av e as su me d 2 hours p er report, and that 1 bi ennial report will be required for al l 170 mo dels (37 ma nuf actures ) during th e th ree-y ear I CR period (2015-2017). g As su me s th at th ere will be one QA a udit p erform ance tes t p er ma nuf acturer (37 ma nuf

acturers ) under th e QA program during the period cov ered by th is IC R (2015-2017). We a ssu me th at e ach of the ma nuf acturers w ill be required to te st o ne mo del and report res ults to th e EPA under t heir QA

program b etween 2015 and 2017.January 2015



### 20 k As su me s that

each of th e 4 te st

l aboratories w ill conduct one biennial prof

ic iency te st a nd prepare one report during the th ree-y ear I CR period (2015-2017).

o As su me s one unit

s ealed for each original cert if ic ation tes t (fo r 115 mo dels ) required of the 37 ma nuf acturers . p We e xp ect the required recordkeeping to b e highly a utom ated and hav

e as su me d th at tes t l aboratories wi ll sp end 2 hours p er m ont h fo r the 3-y ear period of

th is IC R (2015-2017) to m aintain th e required records . q We e xp ect the required recordkeeping to b e highly a utom ated and hav

e as su me d th at thi rd-party certi fi ers w ill sp end 2 hours per mo nt h for th e 3-y ear period of thi s ICR (2015-2017) to m aintain the required records . n Param eter ins pections a re part of the e xi st ing sa fety

i ns pect ion program . We hav e as su me d th at a ll ma nuf act urers ( 37 ma nuf

acturers ) wi ll sp end an addit ional 2 hours per quarter for th e 3-y ear period of thi s ICR to docum ent res ults. j As su me s th at 4 te st

l aboratories wi ll su bm it a pplicat ions fo r a pprov al as te st

l aboratories d uring the th ree-y ear ICR period (2015-2017). Tw o of th os e laboratories w ill be ISO-accre dited and two will need to obtain I SO-accreditat ion. l A ssu me s that

al l 4 tes t l aboratories w ill su bm it applicat ions for ap prov al as th ird party

certifiers bet

ween 2015 and 2017. Tw o of th os e laboratories are as su me d to be I SO-accredited and two are as su me d to need to obtain ISOaccreditat ion. m As su me s th at m anuf act urers w ill sp end 1 hour per certification tes t (a ssu mi ng cert if ic ations fo r 170 m odels ) to ke ep the required records .A - 1

TA BL E 2. T HRE E-YEAR AN D A NNUA L BU RDE N AN D COS T TO THE F ED ER ALG OVER NM EN T OF T HE FI NA L RULE (A ) (B ) (C) (D) (E ) (F ) (G ) (H) (I) (J) (K ) EPA p ers on- No. of EPA pe rs on- Res pondents Te ch ni ca l Management Cl eric al Cos t,$ b To ta l Av g. a nnual Av

g. annual hours p er oc cu rrenc es hours per 2015-2017 pers on-hours pers on-hours a pers on-hours a pers on-hours pers on-hours co sts oc cu rrenc e per res pondent res pondent 2015-2017 2015-2017 2015-2017 2015-2017

2015-2017 2015-2017 Activ ity (C= AxB) (E =CxD ) (F= Ex0 .0 5) (G= Ex0.1 ) (I= E+F+G ) (J= I/ 3) (K =H /3 ) 1. C ertif ica tion test n ot if

ica tion c 0. 5 3. 1 1. 6 37 57. 5 2. 9 5. 8 3, 010 $ 66. 1 22.0 1, 003 $ 2. C ertif ica tion test d 20. 0 3. 1 62. 2 6 373. 0 18. 6 37. 3 19, 522 $ 428. 9 143. 0 6, 507 $ 3. App lica tio n fo r ce rt if ica tio n of model line e 8. 0 3. 1 24. 9 37 920. 0 46. 0 92. 0 48, 154 $ 1058. 0 352. 7 16, 051 $ 4. Bie nnial re port ing for ce rt if ie d models f 1. 0 4. 6 4. 6 21 96. 5 4. 8 9. 6 5, 050 $ 111. 0 37.0 1, 683 $ 5. Rev iew and approv

al of te st labcr

edent ials g 4. 0 1. 0 4. 0 4 16. 0 0. 8 1. 6 837 $ 18. 4 6.1 279 $ 6. Rev iew te st labb iennial profic ienc y te st r eport s h 10. 0 1. 0 10. 0 4 40. 0 2. 0 4. 0 2, 094 $ 46. 0 15.3 698 $ 7. Rev iew QA p erform anc e test res ul ts i 2. 0 1. 0 2. 0 37 74. 0 3. 7 7. 4 3, 873 $ 85. 1 28.4 1, 291 $ 8. Rev iew QA a udi t r

eport j 2. 0 2. 0 4. 0 2 8. 0 0. 4 0. 8 419 $ 9. 2 3.1 140 $ 9. EPA co mp lianc e audit k 40. 0 1. 0 40. 0 1 40. 0 2. 0 4. 0 2, 094 $ 46. 0 15.3 698 $ 10. Rev iew and approv

al of th ir d-part y ce rt if

ie r credent ials l 8. 0 1. 0 8. 0 2 16. 0 0. 8 1. 6 837 $ 18. 4 6.1 279 $ TO TA L BU RDE N AN D COST ( SALARY) 1641. 0 82. 0 164. 1 85, 890 $ 1887. 1 629. 0 28, 630 $ a Ma nagement pers on-hours a nd cle ric al pers on-hours a re as su med to b e 5 perc ent a nd 10 perc ent of tech ni ca l p ers on-hours , r es pec tiv el y. b C os ts a re b as ed on th e f ol lowi ng hourly r

at es : tech ni ca l a t $ 46. 67, ma nagement at $62.90, and clerical at $25.24. c Mo dels ce rt if

ie d by te sti ng per manuf ac tu re r: 1 15 model lines f rom 37 manufac tu re rs p rojec te d tob e teste d during t he th ree-y ear ICR period (2015-2017). d Assu mes th at ove r th e long te rm EPA w ill observ e 5 perc ent of ce rt if

ica tio n te sts, w hic h is r ounded to6 tests o bs erv ed during th e peri od of th is I CR. e EPA mu st r

ev iew and approv

e ce rt if icatio n appl ica tio ns : 11 5 model lines f rom 37 manufac tu rers p rojec te d tob e ce rt if ied from 2015-2017. f During th e 3-y ear ICR period, EPA mu st r ev iew 1 bi ennial re port f

or eac h ce rt if

ie d model line (170 models /3 7 manuf ac turers ). g Assu mes th at 4 test la borat ories w ill su bmit a pplic at ions f or s ubpart QQQQ te sting lab approv al ( 2 that already h av

e IS O ac credi ta tio n and 2 th at do not ) bet ween 2015 and 2017. h Assu mes th at th ere wi ll b e one bi enni al la borat ory p rofic ie nc y te st p er laborat ory (4 labor at ories ) during the th ree-y ear ICR period (2 015-2017).

k Assu mes th at o ne model line for one of th e 37 manuf ac tu rers w ill be audited by the EPA during the I CR th re e-y ear period (2 015-2017). l EPA a pprov

al of th ird-part y ce rt if

ier s f or th is rule: Wea ssu me that two labs w ill s ubmit applications f or approv al to theEPA a s th ird-party ce rt if iers d uring t he th ree-y ear ICR period (2015-2017). I Assu mes th at th ere wi ll b e 37 perform anc e te st r es ults su bmitte d under th e QA program and re vi ewed by th e EPA du ring the peri od co ve red by th is I CR (2015-2017). Wea ssu me th at e ac h of the hy dronic h eat er a nd forc ed-air fu rnac e ma nufac tu res w ill b e required to test o ne model and report r es ul ts to theEPA un der th ei r QAp ro gram between 2015 and 2017. j Assu mes th ere wi ll be two QA a udi ts by th e third-part y ce rt if ie r rev iewed by th e EPA f

or eac h of the 37 manuf ac tu rers o ve r th e th ree-y ear IC R period (2015-2017).A - 2 

### Attachment 1 **Respondent Reporting and Recordkeeping Requirements NSPS for New Residential Hydronic Heaters and Forced**  **- Air Furnaces (40 CFR part 60, subpart QQQQ)**  **Regulatory Reference Title 40, Part 60**  **Regulated Entity Reporting/Recordkeeping Requirement**  **Frequency/Other Comments** 60.5475(b), 60.5475(f)(1) Manufacturer Report : Application for a certificate of compliance. Include results of certification test, model identification information, engineering drawings and component specifications (for components that may affect emissions), identification of any CBI (as neces sary), warranty information, owner’s manual, documentation of contracts with an approved test laboratory and third party certifier, quality assurance (QA) program and various affirmations of compliance. Once for each model line.

60.5475(g)* Manufacturer Report : Request for waiver from submitting certification test results. Once per model, if at all. 60.5475(i) Manufacturer Report : Renewal of certification. Renewal of certificate allowed by

reapplying or by affirming in writing that the wood heater has b een subject to no changes that would im pact emissions and requesting a waiver from certification testing. Must renew or apply for recertification every 5 years. 60.5475(k)** Manufacturer Report : Recertification required w henever a change is heater design exceeds specified parameters. May request a waiver with adequate rationale that changes may not reasonably be anticipated to cause wood heaters in the mo del line to exceed the applicable emission limits. Variable. 60.5475(m) Manufacturer Report : Develop a QA program and submit with application for a certificate of compliance. Report : Review third -party certifier QA audit report and submit corrective actions for any identified deficiencies. Once per model line. Variable. 60.5475(n)** Manufacture r Report : EPA compliance audit test results. EPA may select a hydronic heater or forced - air furnace for compliance audit testing. EPA may test or direct the manufacturer to test a selected model line; at manufacturer’s expense. Variable and infrequent.

60 .5476(f) Manufacturer Report : Notification in advance of compliance certification test. Once per model line, at least 30 days before the start of testing. 60.5478(a) - (d) Manufacturer Produce and apply permanent label. One per unit produced.A - 3

**Regulatory Reference Title 40, Part 60**  **Regulated Entity Reporting/Recordkeeping Requirement**  **Frequency/Other Comments** 60.5478(e) *** Manufacturer Optional requirement . Produce and apply temporary label. Variable/optional.

- Each model that meets 2020 emission limits prior to the 2020 compliance date may display a tem

porary label indicating that the model meets the 2020 emission limits .

- Each model certified to meet the 2020 cord wood alternative means of emissions limitation compliance option may display that the model meets the 2020 cord wood alternative compliance option . 60.5478(f) Manufacturer Develop and publish owner’s manual. One owner’s manual developed per model line; a copy accompanies each unit produced. 60.5479(a) Manufacturer Maintain records of all certification test data, results of QA program inspections, emission test data. Once per model for certification and test data. Periodically for all QA inspections and tests. 60.5479(c) Manufacturer Retain sealed wood heater for 3 years after the certification test of the model. One for each certified model. 60.5479(d) Manufacturer Report : Certification that model line is unchanged and sales for each model by state. Every 2 years following issuance of a certificate of compliance for each model line. 60.5479(f) Manufacturer Report : Performance test data submitted electronically. Within 60 days after completion of each performance test. 60.5479(g) Manufacturer For each certified model line, post the non - CBI certification test report to the manufacturer’s website. Once for each model lint, within 30 days of receiving the certificate of compliance. 60.5481** Manufacturer Various requests, submittals, motions, filings, etc., under hearing and appeal procedures. Variable and infrequent, if at all. 60.5477(a) Test Laboratory Report : After being accredited by a nationally recognized accrediting entity, application for EPA approval as a test lab. Once (unless not rene wed every 5 years by the EPA). 60.5477(a) , 60.5479(b) Test Laboratory Report : Proficiency test and documentation. Approved test labs must participate in a biennial proficiency testing program conducted by a nationally recognized accrediting entity. Each approved test laboratory must submit all proficiency test results to the EPA. Biennially. 60.5479(b) Test Laboratory Keep records of documentation pertaining to certification tests, QA audit tests, including the full test report and raw

data sheets, technician notes, calculations and test results for all test runs. Once for each certification test, QA audit test. 60. 539** Test Laboratory Various requests, submittals, motions, filings, etc., under hearing and appeal procedures. Variable and infrequent, if at all. 60.5475(m), 60.5477(e)(2) Third - Party Certifier Report : Submit report of unannounced QA program audits to EPA and the manufacturer. At least annually.A - 4

**Regulatory Reference Title 40, Part 60**  **Regulated Entity Reporting/Recordkeeping Requirement**  **Frequency/Other Comments** 60.5477(e) Third - Party Certifier Report : After being accredited by a nationally recognized accrediting entity, application for EPA approval as a third -party certifier. Once, to be renewed every 5 years. 60.5479(b) Third - Party Certifier Keep records of documentation pertaining to certification tests, QA inspections and audit tests, including the full test report and raw data sheets, technician notes, calculations and test results for all test runs. Once fo r each certification test, QA inspection and audit test. 60.5479(b) Third - Party Certifier Each certifier must submit each certification test, QA inspection report and ISO IEC accreditation credentials to the EPA. Once for each certification test, QA inspection and audit test. 60.539** Third - Party Certifier Various requests, submittals, motions, filings, etc., under hearing and appeal procedures. Variable and infrequent, if at all. * This is associated with an exemption or waiver (which would eliminate other reporting and recordkeeping burdens) and therefore not counted as a burden in the calculation. ** This is not a routine report or is a provision for an extraordinary circumstance and, therefore, is not included in the calculations because it is very unlikely to occur during the next 3 years. *** This is an optional requirement and, therefore, is not included in the calculated burden estimates.A - 5 

### Attachment 2 **Federal Reporting and Recordkeeping Requirements NSPS for New Hydronic Heaters and Force**  **d -** **Air Furnaces (40 CFR part 60, subpart QQQQ) Regulatory Reference**  **Title 40, Part 60 Agency**  **Reporting/Recordkeeping Frequency/Other Comments**  60.5475(c)(1) or (2), 60.5475(f)(2) or (3) EPA Report : Review application for a certificate of compliance and issue the certificate or a notice of denial. Once per model. 60.5475(i)(2) or (3) EPA Report : Renewal or denial of certificate of compliance. Every 5 years. 60.5475(l)(2)* EPA Report : Notice of revocation of certification. Variable and infrequent, if at all. 60.5475(n)(1)(ii) EPA Report : Notice to manufacturer that a model has been selected for an EPA compliance audit test. Variable and infrequent. 60.5475(n)(3)* EPA Report : Issue notification of suspension or revocation of a model’s certification. Variable and infrequent, if at all. 60.5477(a) EPA Report : Review test laboratory application and provide the test laboratory with a certificate of approval if approval criteria are met. If approval not granted, provide w

ritten notice with rationale. Test lab approval (unless revoked sooner) is valid for 5 years from the date of issuance. 60.5477(b)* EPA Report : Notice of revocation of test laboratory approval with basis for re vocation and notice of opportunity for a hearing. Variable and infrequent, if at all. 60.5477(e) EPA Report : Review of third -party certifier application and provide a certificate of approval if approval criteria met. If approval not granted, provide a written notice with rationale. Third -party certifier approval expires 5 years after being issued unless renewed. 60.5477(f)* EPA Report : Notice of revocation of third -party certifier approval with basis for revocation and notice of opportunity for a heari ng. Variable and infrequent, if at all. 60.5479(b) EPA Evaluation of laboratory proficiency tests submitted by test laboratories. Biennially. 60.5481* EPA Various requests, submittals, motions, filings, etc., under hearing and appeal procedures. Variable and infrequent, if at all. * This is not a routine occurrence. It is a provision for an extraordinary circumstance and, therefore, is not included in th e calculations because it is very unlikely to occur during the next 3 years.