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 ICR 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 apply 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-only notifications including: notification of any physical or operational change to an 

existing facility which may increase 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 system is inoperative. Monitoring 

requirements specific to 40 CFR part 63, subpart JJ provide information on compliance with the 

rule. Semiannual reports are required for all sources. Some 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 the 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 sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United States 

Environmental Protection Agency (EPA) regional office.
2

Approximately 750 sources are currently subject to the standard, based on information 

provided by the American Furniture Manufacturers Association. Of these sources, approximately 

300 are major sources and 450 are incidental/area sources. It is anticipated that no new facilities 

will come on-line over 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 currently active Information 

Collection Request (ICR) with the following “Terms of Clearance.”

The 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 Statistics, 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 privately owned and operated. None of the 750 facilities in the United States are 

owned by 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 entirely to work performed by Federal 

employees or government contractors. This burden may be found in Table 2: Average Annual 

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 establish 

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 reduction. In addition, section 114(a) 

states that the Administrator may require any owner or operator subject to any requirement of this 

Act to:

(A) Establish and maintain such records; (B) make such reports; (C) 

install, use, and maintain such monitoring equipment, and use such 

audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 
3

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); and 

(G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, 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 properly 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 by 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 

properly installed and functioning properly. The required quarterly/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 ICR is used by the Agency to ensure that facilities affected by the NESHAP 

continue to operate the control equipment in compliance with the regulation. Adequate 

monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable 

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, Consultations, 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 EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted their own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 
4

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in 

the Federal Register (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 ICR, consultations concerning the industry growth rate 

over the next three years 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 representatives indicated that no net growth in the industry was expected over 

the next three years. They cited 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 regulatory-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. They did not mention any specific 

problems with the rule burden 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 recordkeeping 

are useful techniques to ensure that good operation and maintenance practices are applied and 

emission limitations are met. If the information required by these standards was collected less 

frequently, the likelihood of detecting poor operation and 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. This is consistent with the General Provisions as applied to the 

standards. EPA believes that the five-year records retention requirement is consistent with the Part 
5

70 permit program and the five-year statute of limitations on which the permit program is based. 

Also, the retention of records for five years would allow EPA to establish the compliance history

of a source and any pattern of compliance 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 

violators 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 which a claim of confidentiality is made will be 

safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B -

Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are wood furniture 

manufacturers. The United States Standard Industrial Classification (SIC) and the North 

American Industry Classification System (NAICS) codes for the respondents affected by 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 Requested
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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 ICR that is recorded and/or reported is required by 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

Notification 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 physical or operational change 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)

Notification of compliance status. 63.807(b), 63.9(h)

Reports

Semiannual reports 63.807(c)

Quarterly 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 action 

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 system data 63.806(b)(2), 63.10(c), 63.6(e) 

CMS quality control plan 63.807(a)

Startup, shutdown and malfunction plans. 63.807(a), 63.6(e)(3), 

63.10(d)(5)
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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 calculations 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 provides parameter data in an 

automated way, e.g., internal feed. Although personnel at the source still need to evaluate the data, 

this type of monitoring equipment has significantly reduced the burden associated with monitoring 

and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting 

systems to allow sources to report electronically which is reducing the reporting burden. 

However, electronic reporting systems 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, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Adjust existing ways to comply with any previously applicable instructions and requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way. Although personnel at the source still need to evaluate the data, this type of 

monitoring equipment has significantly reduced the burden associated with monitoring and 

recordkeeping.
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5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, 

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports, 

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to 

determine whether the pollution control devices are properly installed and operational. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply 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.

Information 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 local and state regulatory agencies, EPA regional offices and EPA 

headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or operator for five 

years.

5(c) Small Entity Flexibility

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 by the standards. The second source could be major and 

subject to the requirements of the standards. Information available 
9

to the Agency shows that the second source is able to achieve the 

control levels of the NESHAP using existing equipment. The 

testing, monitoring, recordkeeping and reporting requirements are 

essentially identical to the current requirements and, thus, should 

cause little or no change in these burdens.

This ICR conservatively 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). However, the impact on small entities 

was taken into consideration during the development of the regulation. Due to technical 

considerations involving the process operations and the type of control equipment employed, the 

recordkeeping and reporting requirements are the same for both small and large entities. The 

Agency considers these requirements the minimum needed to ensure compliance and, therefore, 

cannot reduce them further for small entities.

5(d) Collection Schedule

The specific frequency for each information collection activity within 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 applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 47,189 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 
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 Occupational and Industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry costs associated with the information collection activities in the 

subject standards are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M 

(G)

Total O&M,

(E X F)

Several 

options 

available

0 0 $0 $600 30 $18,000

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 years of the ICR is estimated to be $18,000.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. The EPA compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information.

This cost is based on the average hourly 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 have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, there are approximately 750 existing sources currently 

subject to the standard. It is estimated that no additional sources per year will become subject to 

the regulation in the next three years.

Number of respondents is calculated using the following table which addresses the three 

years covered by this ICR.

Number of Respondents

Year

(A)

Number of 

New

Respondents

(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 above, the average 

Number of Respondents over the three-year period of this ICR is 750.

The total number of annual responses per year is calculated using the following table:

Respondent Universe and Number of Responses Per Year

Regulation 

Citation

(A)

Average 

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 2.011450 1,053

1 Weighted average of semiannual and quarterly reports (See Table 1. Annual Respondent Burden and Cost, NESHAP for 
12

Wood Furniture Manufacturing Operations, 40 CFR part 63, subpart JJ) for details

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 Burden and Cost - NESHAP for Wood Furniture Manufacturing 

Operations (40 CFR part 63, subpart JJ), below.

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below.

6(f) Reasons for Change in Burden

There are no changes in the respondent labor hours in this ICR compared to the previous 

ICR. This is due to two considerations: 1) the regulations have not changed over the past three 

years and are not anticipated to change over the next three years; and 2) the growth rate for the 

respondents is very low, negative or non-existent. Therefore, the labor hours in the previous ICR 

reflect the current burden to the respondents and are reiterated (with a correction for rounding) in 

this ICR. It should be noted that there is an apparent decrease of one hour in the total labor hours 

for this ICR. Total labor hours for this ICR are 47,189 rather than 47,190 as in the previous ICR. 

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 from labor rate 

increases from 2003 to 2009. In addition, 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 

estimated 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 instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA’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 suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-OECA-2009-0380, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, N.W., Washington, D.C. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

Enforcement and Compliance Docket and Information Center Docket is (202) 566-1752. An 

electronic version of the public docket is available online at 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 system, select “search,” then key in the Docket ID Number identified above. Also, you can 

send comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-OECA-2009-0380 and OMB Control Number 

2060-0324 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture 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 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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

 Notification of construction/reconstruction d2 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 f4 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 requirements
15

 A. Read instructions See 3A

 B. Plan activities N/A

 C. Implement activities N/A

 D. Time to enter information 

 Record of operators completing training 

courses

1 2 2 300 600 30 60 $64,893 

 Records of CMS parameters i1.5 52 78 30 2,340 117 234 $253,082 

 Records of types and quantities of 

materials used, including VHAP and solids 

common data

See 3D

 E. Records for incidental and area sources j1 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 audits 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 

Assumptions:

a

 We assume 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 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 Occupational and Industry group.” Workers by 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 employed by private industry.

c

 We have assumed that there will be 39 respondents (30 modified + 9 reconstructed) that will apply for construction, reconstruction 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 comply by using control devices, but only 95 percent are assumed to be in compliance at any given time and would 

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 quarterly 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)

Management 

person-hours 

per year 

(Cx0.05)

Clerical 

person-hours 

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 excess 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 

Assumptions:

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 Department of Labor, Bureau of Labor 

Statistics, March 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” Workers by 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 

employed by private industry.

c

 It is assumed 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 approach 

(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 would 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)].