SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)
1. Identification of the Information Collection 1(a) Title of the Information Collection NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal) EPA I CR 1716.06, OMB Control Number 2060

- 0324 1(b) Short Characterization/Abstract The final National Emission Standards for Hazardous Air Pollutants (NESHAP) from Wood Furniture Manufacturing Operations were proposed on December 6, 1994, and promulgated on December 7, 1995. These standards appl y to both existing wood furniture manufacturing operations and to new wood furniture manufacturing operations commencing construction, modification or reconstruction after the date of proposal that are major sources of hazardous air pollutants (HAPs). This information is being collected to assure compliance with the standard promulgated at 40 CFR part 63, subpart JJ. Owners or operators of the affected facilities that are major sources must make one - time

- onl y notifications including: notification of any ph ys ical or operational change to an existing facility

which may

i ncrease the regulated pollutant emission rate; notification of the initial performance test, including information necessary to determine the conditions of the performance test, performance test measurements and results; and notification of demonstration of the continuous monitoring system (CMS). Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any

period during which the monitoring s ys tem is inoperative. Monitoring requirements specific to 40 CFR part 63, subpart JJ provide information on compliance with the rule. S emiannual reports are required for all sources. S ome sources having excess emissions must submit quarterly

reports. In general, these notifications, reports and records are required of all sources subject to 40 CFR part 63. Owners or operators of the affected facilities that are incidental wood furniture manufacturers or area sources (incidental/area sources) must keep records to demonstrate that they are not major sources as defined in th e standard. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are s ent 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.2

Approximately

750 sources are currently subje ct to the standard, based on information provided by the American Furniture Manufacturers Association. Of these sources, approximatel y 300 are major sources and 450 are incidental/area sources. It is anticipated that no new facilities will come on

- line o ver the next three years. It is assumed that there is an average of one affected facility per source. The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request (I CR) with the following “Terms of Clearance.”

T he assumptions underlying estimates of industry and agency burden and costs of the collection should be updated in the next renewal. The industry

and cost burden have been updated using rates from the United States Department of Labor, Bureau of Labor St atistics, March 2009, “Table 2. Civilian Workers, by Occupational and Industry group” and the Office of Personnel Management (OPM), 2010 General Schedule. The wood furniture manufacturing operations consists of 750 facilities in the United States, which are all privatel y owned and operated. None of the 750 facilities in the United States are owned b y either state, local, tribal or the Federal government. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost

- NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ). The burden to the “Federal government” is attributed entirel y to work performed by Federal employees or government contractors. This burden may be found in Table 2: Average Annu al EPA Burden

- NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ).
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 est ablish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants (HAPs). These standards are applicable to new or existing sources of HAPs and shall require the maximum degree of emission reduc tion. In addition, section 114(a) states that the Administrator may require any o wner 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 eq uipment, 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 reco rds on control3 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 reasonabl y require. In the Administrator's judgment, hazardous emissions from wood furniture manufacturers cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subpart JJ. 2(b) Practical Utility/Users of the Data The control of emissions from hazardous air pollutant emissions from wood furniture manufacturing operations require the installation of properl y designed equipment and the operation and maintenance of that equipment. Emissions of HAPs from wood furniture manufacturers are the result of operation of the affected facilities. This standard relies on the reduction of hazardous air pollutants b y the use of compliant or low HAP content coatings, or the use of control devices, or some combination of these three control technologies. The notifications required in the applicable regulations are used to inform the Agency or delegated authority

when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y i nstalled and functioning properl y. The required quarterl y/ semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/ maintenance procedures and for compliance determinations. The information generated by the monitoring, recordkeeping and reporting requirement described in this I CR is used by the Agency

to ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the app licable regulations, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court. 3. Nonduplication, Consu ltations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 63, subpart JJ. 3(a) Nonduplication If the subject standards have not been delegated, the information is sent directly to the appropriate E PA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication4

exists. 3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this IC R was published in the Federal Register (74 FR 34583) on July 8, 2009. No comments were received on the burden published in the Federal Register

. 3(c) Consultations During a previous renewal of this I CR, consultations concerning the industry growth rate over the next three ye ars and the burden costs of recordkeeping and reporting under the rule were conducted with the leading trade associations representing the industry, and the EPA Office of Air Quality Planning and Standards. The contacts were: 1) The American Furniture Manufacturing Association, Mr. David Purvis, (336) 884

- 5000; 2) The Business and Institutional Furniture Manufacturing Association, Mr. Tom Reardon, (616) 285

- 3963; and 3) the Office of Air Quality Planning and Standards. The industry

r epresentatives indicated that no net growth in the industry w as expected over the next three ye ars. T hey c ited foreign competition as having a negative effect on industry growth and modestly increasing residential/business demand for furniture as having a positive effect with a projected net growth rate of zero. In addition, any industry growth over the next three years could likely

be absorbed by

existing plants without any new source construction. This rule was developed using the regulat ory- negotiation process. The industry participated in the rulemaking process and agreed to comply with the final rule, so they have a good understanding of the recordkeeping and reporting burden. T hey did not mention an y s pecific problems with the rule b urden during the consultations. 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 record keeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the likelihood of detecting poor operation an d maintenance of control equipment and noncompliance would decrease. 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 affected facilities to maintain all records, including reports and notifications for at least five years. T his is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the Part5

70 permit program and the five

- ye ar statute of limitations on which the permit program is based. Also, the retention of records for five ye ars would allow EPA to establish the compliance history of a source and an y pattern of comp liance for purposes of determining the appropriate level of enforcement action. Historically , EPA has found that the most flagrant violators frequently have violations extending beyond the five years. EPA would be prevented from pursuing the worst violat ors due to the destruction or nonexistence of records if records were retained for less than five years. 3(f) Confidentiality The required information has been determined not to be confidential. However, any information submitted to the Agency for whic h 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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40 000, 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) Re spondents/SIC Codes The respondents to the recordkeeping and reporting requirements are wood furniture manufacturers. The United States Standard Industrial Classification (SI C) and the North American Industry

Classification Sy stem (NAICS) codes for the r espondents affected b y the standards are shown below.

Standard SIC Codes NAICS Codes

40 CFR part 63, subpart JJ 2434 33711 2511 337215 2512 337121 2517 337129 2519 337125 2521 337211 2531 33636, 337127, 339942 2541 337127, 337212, 337215 2599 339111, 337127 5712 337122 4(b) Information Requested6

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 All data in this I CR that is reco rded and/or reported is required b y National Emission Standards for Hazardous Air Pollutants for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ). A source must make the following reports:

Reports for 40 CFR part 63, subpart JJ Notif ication of applicability

. 63.807(a), 63.9(h) Notification and application of construction or reconstruction. 63.807(a), 63.5(d) Notification of anticipated date of initial startup. 63.807(a), 63.5(b), 63.9(b) Notification of ph ys ical or operational chan ge which may increase the emission rate. 63.807(a), 63.5(b)(6) Notification of performance tests. 63.807(a), 63l7(b), (c), and (g), 63.8, 63.9(c), 63.10(d)(2) Notification performance test results. 63.807(a), 63.8(e)(2), 63.9(g), 63.10(e)(2) Notificatio n of compliance status. 63.807(b), 63.9(h) Reports Semiannual reports 63.807(c) Quarterl y reports 63.807(d) A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart JJ Startup, shutdown or malfunctions and corrective acti on records. 63.806(a), 63.6(e), 63.10(b)(2) Work practice standards implementation plan 63.806(e), 63.10(d)(1) Work practice standards records 63.806(e), 63.10(b)(2) Records of compliance monitoring sy stem data 63.806(b)(2), 63.10(c), 63.6(e) CMS qual ity

control plan 63.807(a) Startup, shutdown and malfunction plans. 63.807(a), 63.6(e)(3), 63.10(d)(5)7 Recordkeeping for 40 CFR part 63, subpart JJ Records of the types and quantities of finishing/cleaning/adhesive materials 63.806(b), 63.10(b)(2) Records monthly

weighted

- average emission calculat ions 63.806(a), 63.10(b)(3) Records of applicability

determination/area source status 63.806(a), 63.10(b)(3) Records of performance test/evaluations 63.806(a), 63.10(b)(2) Electronic Reporting Currently , sources are using monitoring equipment that pro vides parameter data in an automated way , e.g., internal feed. A lthough personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. In addit ion, some regulatory agencies are setting up electronic reporting sy stems to allow sources to report electronicall y which is reducing the reporting burden. However, electronic reporting s ys tems are still not widely used by the regulatory

agencies. It is estimated that approximately 10 percent of the respondents use electronic reporting. (ii) Respondent Activities

Respondent Activities Read instructions. Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device. Perform initial performance test and repeat, if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, a nd utilizing technology

and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust existing way s to comply with an y 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 . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping.8

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities
EPA conducts the following activities in conn ection with the acquisition, analy sis, 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 rep orts, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Air Facility Sy stem (AFS). 5(b) Collection Methodology and Management Following notification of startup, the review ing authority might inspect the source to determine whether the pollution control devices are properl y i nstalled and operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard , and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification , as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection , maintenance, and retrieval of compliance and annual emission inventory data for more than 100,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by l ocal and state regulatory a gencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. 5(c) Small Entity Flexibility According to the Final Rule (64 FR 31358): The Agency

has found that two of the twenty- one firms that potentially

could be subject to the standards are small firms. Of the two, data indicate that one is an area source which would not be covered b y the standards. The second source could be major and subject to the requirements of the standards. Information available9 to the Agency

shows that the second source is able to achieve the control levels of the NESHAP using existing equipment. The testing, mon itoring, recordkeeping and reporting requirements are essentially

identical to the current requirements and, thus, should cause little or no change in these burdens. This I CR conservativel y assumes that two of twenty

- one ownership firms are small, and extrapolates this fraction to the affected facilities, assuming that approximately 91⁄2 percent, or 71 affected facilities, are small entities (e.g., small businesses). H owever, the impact on small entities was taken into consideration during the development o f the regulation. Due to technical considerations involving the process operations and the ty pe of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these require ments the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities. 5(d) Collection Schedule The specific frequency

f or each information collection activity w ithin this request is shown in Table 1: Annual Industry Burden for NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ). 6. Estimating the Burden and Cost of the Collection Table 1 document the computation of individual burdens for the recordkeeping and reporting requirements app licable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks an d major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it 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 47,189 (Total Labor Hours from Table 1). These hours are based on Agenc y studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and an y comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs
Th is I CR uses the following labor rates:10 Managerial $114.77 ($54.65 + 110%) Technical $97.59 ($46.47 + 110%) Clerical $48.26 ($22.98 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by O ccupational and Industry group.” T he rates are from column 1, “Total compensation.” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The ty pes of industry

costs associated with the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with co ntinuous 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)
Several options available 0 0 $0 $600 30 $18,000
The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $18,000. 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 ye ars of the I CR is estimated to be $18,000. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with anal ys is of the reported information. 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. This cost is based on the average hourl y labor rate as follows:11 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), 2010 General Schedule, which excludes locality

rates of pay . The rates hav e been increased b y 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our r esearch for this I CR, there are approximately 750 existing sources currentl y subject to the standard. It is estimated that no additional sources per ye ar will become subject to the regulation in the next three ye ars. Number of respondents is calculated using the following table which addresses the three ye ars covered b y this ICR. Number of Respondents

Year (A)

Number of New Respondents (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 0 300 450 0 750 2 0 300 450 0 750 3 0 300 450 0 750 Average 0 300 450 0 750
To avoid double

- counting respondents, column D is subtracted. As shown a bove, the average Number of Respondents over the three

- ye ar period of this I CR is 750. The total number of annual responses per ye ar is calculated using the following table:

Respondent Universe and Number of Responses Per Year

Regulation Citation (A)

Av erage Number of New Respondents per Year (B)

Number of Reports for New Sources (C)

Number of Existing Respondents (D)

Number of Reports for Existing Sources (F)

Number of Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses = (AxB)+(CxD) +F

40 CFR part 63, subpart JJ 0 0 300 2.01 1 450 1,053

1 Weighted average of semiannual and quarterly reports (See Table 1. Annual Respondent Burden and Cost, NESHAP for12

Wood Furniture Manufacturing Operations, 40 CFR part 63, subpart JJ) for d etails The number of total respondents is 750. The number of Total Annual Responses is 1,053. This is the number in column E of the Respondent Universe and Number of Responses per Year table above. The total annual labor costs are $4,438,012. Details regarding these estimates may be found in Table 1: Annual Industry B urden and Cost

- NESHAP for Wood Furniture Manufacturin g Operations (40 CFR part 63, subpart JJ), below. 6(e) Bottom Line Burden Hours Burden Hours and Cost Tables The detailed bottom l ine burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. 6(f) Reasons for Change in Burden There are no changes in the respondent labor hours in this I CR compared to the p revious ICR. This is due to two considerations: 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years; and 2) the growth rate for the respondents is very

low, negative or non

- existent. T herefore, the labor hours in the previous ICR reflect the current burden to the respondents and are reiterated (with a correction for rounding) in this I CR. It should be noted that there is an apparent decrease of one hour in the total labor hours for thi s I CR. Total labor hours for this I CR are 47,189 rather than 47,190 as in the previous I CR. The previous ICR did not carryout decimal places for the calculations in Table 1. There is an increase in both respondent and Agency labor costs resulting fro m labor rate increases from 2003 to 2009. Ina ddition, Tables 1 and 2 were expanded to include managerial and clerical labor rates. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimat ed to average 45 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 ins tructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to co mply with an y previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.13

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 2009

- 0380, which is available for online viewing at www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket and In formation 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the t elephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1752. An electronic version of the public docket is available online at www.regulations.gov. T his site can be used to submit or view public comments, acc ess the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronicall y. When in the system , select “search,” then key in the Docket ID Number identified above. Also, you can send c omments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. P lease include the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0380 and OMB Control Number 2060

- 0324 in an y correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.14 Table 1: Annual Respondent Burden and Cost

– NESHAP for Wood Furni ture Manufacturing Operations (40 CFR Part 63, Subpart JJ)

Burden item (A) (B) (C) (D) (E) (F) (G) (H) Person
- hours per occurrence No. of

occurrences per respondent per year Person
- hours

per respondent per year Respondents

per year a Technical

person hours per year Managem ent

person - hours per year Clerical

person hours per year Cost, $ b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1) 1. Applications for construction, reconstruction and modification a, d, e 4 1 4 39 156 7.8 15.6 $16,872
2. Survey and studies N/A 3. Reporting Requirements A. Read instructions c 1 1 1 300 300 15 30 $32,446 B. Create information See 3D C. Gather existing information See 3D D. Write reports No tification of construction/reconstruction d 2 1 2 9 18 0.9 1.8 $1,947

Notification of modifications e (physical/operational changes) 8 1 8 30 240 12 24 $25,957
Notification of anticipated startup (including reconstruction and modification) 2 1 2 39 78 3.9 7.8 $8,436 Notification of actual startup 2 1 2 39 78 3.9 7.8 $8,436 Semiannual compliance status reports f 4 2 8 270 2,160 108 216 $233,614 Semiannual excess emissions reports g 4 2 8 29 232 11.6 23.2 $25,092 Quarterly excess emissions reports h 4 4 16 2 32 1.6 3.2 $3,461 List of types and quantities of materials used, including VHAP and solids content data 1.5 52 78 300 23,400 1,170 2340 $2,530,815

Subtotal Reporting 30,698 $2,887,076 4. Recordkeeping requirements15

A. Read instructions See 3A B. Plan activities N/A C. Implement activities N/A D. Time to enter inf

ormation Record of operators completing training courses 1 2 2 300 600 30 60 $64,893 Records of CMS parameters i 1.5 52 78 30 2,340 117 234 $253,082 Records of types and quantities of m aterials used, including VHAP and solids common data See 3D

E. Records for incidental and area sources j 1 12 12 450 5,400 270 540 $584,034 F. Annual personnel refresher course k 8 1 8 750 6,000 300 600 $648,927 G. Time for aud its N/A Subtotal Recordkeeping 16,491 $1,550,936 Subtotals Labor Burden and cost 41,034 2,052 4,103 $4,438,012 TOTAL LABOR BURDEN AND COST (rounded) 47,189 $4,438,012

Assu mptions: a We assume that the average number of respondents that will be subject to the rule will be 750. O f these sources, approximately 300 are major so urces and 450 are incidental/area sources. There will be no additional ne w sources that will become subject to the rule over the three

- year period of this ICR. b We assume a technical labor rate of $97.59, managerial rate $114.77, and clerical rate of $48.26 from the United States Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by Occupation al and Industry group.” Workers by Occupational and Industry Group. The rates are from column 1: Total compensation. The wa ge rate obtained from the table has been increased by 110 percent to account for the benefit packages available to those em ployed b y private industry.

c We have assumed that there will be 39 respondents (30 modified + 9 reconstructed) that will apply for construction, reconstru ction and modification. d It is assumed that approximately 3 percent of the total number of major sources will apply for reconstruction of their facility (300x3=9).

e It is assumed that 10 percent of the total number of major sources will apply for modification of their facility (300x10=30). f We have assumed that 90 percent of the affected sources will comply by using compliant coatings or by using the HAP averaging approach (300x90%=270). g We have assumed that 10 percent of the affected facilities will com ply b y u sing control devices, but only 95 percent are assumed to be in compliance at any g iven time and wo uld be required to submit semiannual rather than quarterly reports; therefore, the number of affected facilities submitting semiannual report is 29 [300x10%x95%=29 (rounded)]. h We have assumed that the number of sources submitting quart erly reports is 2 [300x10%x5%=2 (rounded)]. i It is assumed that 10 percent of affected facilities will use control devices to comply (300x10%=30).16

J We have assumed that 450 incidental/area sources affected facilities will record information once per month. k It is assumed that all of the affected sources will participate in the annual personnel refresher source once per year.17

Table 2: Average Annual EPA Burden
- NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ)

Activity (A) (B) (C) (D) (E) (F) EPA person - hours per occurrence No. of

occurrences per plant per year Technical

person - hours per year (C=AxB) Managem ent

person - hours per year (Cx0.05) Clerical

person - ho urs per year (Cx0.1) Cost, $ b

1. Excess emissions enforcement activities 2. Report Review A. Review notification of construction/reconstruction c 2 9 18 0.9 1.8 $1,947 B. Review notification of modifications (physical/operational changes) d 2 30 60 3 6 $6,489 C. Review semiannual compliance status reports and certifications e 8 270 2,160 108 216 $233,614
D. Review

semiannual excess emission reports f 8 29 232 11.6 23.2 $25,092 E. Review

quarterly exces s emission reports g 16 2 32 1.6 3.2 $3,461 Subtotals Labor Burden and cost 2,502 125 250 $270,603 TOTAL ANNUAL BURDEN AND COST (rounded) 2,877 $270,603

Assu mptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 750. Of these sources, approximately 300 are major sources and 450 are incidental/area sources. There will be no additional new sources that will become subject to the rule over the three

- year period of this ICR.

b Assume a technical labor rate of $97.59, managerial rate $114.77, and clerical rate of $48.26 from the United States Departme nt of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” Workers b y Occupational and Industry Group. The rates are from column 1: Total compensation. The wage rate obtained from the table has been increased by 110 percent to account for the benefit packages available to those em ployed by private industry.

c It is ass umed that approximately 3 percent of the total number of major sources will apply for reconstruction of their facility (300x3 =9). d It is assumed that 10 percent of the total number of major sources will apply for modification of their facility (300x10= 30).18

e We have assumed that 90 percent of the affected sources will comply by using compliant coatings or by using HAP averaging app roach (300x90%=270). f We have assumed that 10 percent of the affected facilities will comply by using control devices, but only 95 percent are assumed to be in compliance at any given time and wo uld be required to submit semiannual rather than quarterly reports; therefore, the number of affected facilities submitting semiannual report is 29 [300x10%x95%=29 (rounded)]. g We have assumed that the number of sources submitting quarterly reports is 2 [(300x10%x5%=2 (rounded)].