January 2015



### 1 **SUPPORTING STATEMENT NSPS for**  **New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Revision)**  **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 Wood Heaters (40 CFR Part 60, Subpart AAA) (Revision), U.S. Environmental Protection Agency (EPA) tracking number 1176.1 2 , Office of Management and Budget (OMB) Control Number 2060 - 0161. (b ) Short Charac terization/Abstract. This I CR covers information collection requirements in the final revisions of the New Source Performance Standards (NSPS) for new residential wood heaters (40 CFR part 6 0 , subpart AAA ( subpart AAA) ) . The information collected will be used by the EPA and delegated state and local agencies to determine the compliance status of sources subject to the rule. A wood heater is defined as an enclosed, wood burning appliance capable of and intended for residential or space heating and domestic water heating. Unless other wise specified, these devices include , but are not limited to, adjustable burn rate wood heaters , single burn rate wood heater s and pellet stoves. One feature of the NSPS require s emphasis at the outset. That is, the requirements of subpart AAA establish a certification program instead of the usual NSPS requirement s where each affected facility is required to demonstrate compliance through performance testing . Under th e subpart AAA - required certification program, a single wood heater 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 signi ficantly reduces the compliance burden, including information collection, for the manufacturers of wood heating appliances. In order to minimize risks to the environment from intentional or accidental misuse of the certification approach, subpart AAA includes several safeguards, some of which entail reporting and recordkeeping . There are approximately

66 manufacturers and 6 laboratories (inclusive of both test labs and third -party certifiers) that would be subject to the final amended subpart AAA. UnderJanuary 2015



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subpart AAA , wood heater manufacturers, testing laboratories and third -party certifiers are required to su

bmit reports to the EPA and to maintain records for demonstrating compliance with the NSPS. The information supplied b y the manufacturer to the EPA is u sed to: (1) ensure that best system of emission reduction is being applied to reduce emissions from wood heaters; (2) ensure that the wood heater tested for certification purposes is in compliance with the applicable emission standards; (3) provide assuran ce that non - tested production model heaters have emission performance characteristics similar to tested models; and (4) 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 , assure continued test lab proficiency and to assist in enforcement and compliance activities. Subpart AAA do es not require any reporting or recordkeeping requirements on wood heater owners or operators. However, the final rule spe cifies a list of prohibited fuel ty pes 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 wood heater models) that owners and operators are directed to follow when installing and operating their wood stoves. 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 for meeting Step 1 emissio n standard s provided in the rule occurs in 2015 , and the compliance date for meeting Step 2 emissio n standard s provided in the rule occurs in 2020. The recordkeeping and reporting burden estimates provided during this ICR period are for ye ars 2015 to 2017. The recordkeeping and reporting burden cost estimates as a result of the subpart AAA final amendments for years 2018 to 2020 are presented in a memo to the docket . 1 

### The recordkeeping and reporting respondent burden estimates included in this supporting statement for years 2015 to 2017 and the burden estimates outlined in the memo for ye ar s 2018 to 2020 are both included in cost impacts estimates included in a memo in the docket for the final rule. 2 

### You can find the estimated burden to the “Affected Public” listed in Table 1 , Three - Year

1 Memorandum to Docket ID Number EPA - HQ - OAR - 2009 - 0734 from EC/R, Inc. 40 CFR Part 60, Subparts AAA and QQQQ Estimated Three - Year and Annual Respondent Burden Cost of Reporting and Recordkeeping Requirements (Years 2018 to 2020) . January 2015. 2 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts . January 2015.January 2015



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and Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the Final Amended Rule . The f ederal government burden associated with the review of reports submitted by

the respondent s is shown below in Table 2 , Three - Year and Annual Burden and Cost to the Federal Go vernment of the Final Amended 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 enforcement of the standards for new residenti al wood heaters sold or operated in their region . Under subpart AAA, 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 new sources subject to the NSPS for Residential Wood Heater s 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 system 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 agency refers to this charge as selecting the “best system of emission reduction.” Section 111 also requires that the Administrator review and, if appropriate, revise such standards every 8 years. In the Administrator's judgment, pollutant emissions from wood heaters cause or contribute to air pollution that may

reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart AAA. The records and reports required under the amended subpart AAA are nec essary for the Administrator to confir

m the compliance status of new residential wood heaters sold in theJanuary 2015



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United States . These recordkeeping and reportin g requirements are authorized by CAA section 114 . (b ) Practical Utility

/Users of the Data. The control of pollution from new residential wood heaters relies on the reduction of particulate matter emissions by proper wood heater design. A representative unit for each model line is subjected to a certification test for particulate matter emissions for a range of operating conditions . The manufacturer also contracts with a third -party certifier , which reviews the test reports and quality

assurance (QA) plan , and cond ucts periodic QA audits to ensure that wood heaters manufactured subsequent to the initial certification test continue to comply with the NSPS . Manufacturers must renew or recertify their wood heater model lines every 5 ye ars or when they

make changes to the model line that would exceed specified parameters . The required 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 capability to comply with the emission standard s , 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 emissions 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 reporting 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 ICR s revealed no duplication of information gathering efforts. The information - gathered under the final amended subpart AAA will replace the information gathered under subpart AAA prior to being amended. Similar requirements to this amended NSPS are found in the requirements to 40 CFR part 60, subpart QQQQ , the NSPS for New Residential Hydronic Heaters and Forced - Air Furnaces. Subpart QQQQ has a sep arate ICR undergoing OMB review. Although the requirements are similar, they are not duplicative because they app ly to separate groups of appliances and the ir associated manufacturers. In the case of test laboratories and third -partyJanuary 2015



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certifiers, similar test accreditation requirements are found in both subpart s , 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 proposed rule (79 FR 6330, February 3, 2014) provide d public notice of th e proposed ICR. The EPA considered comments (see Docket No. 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 amendments were 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 activities are identified in Tab le 3 . Additional meetings and contacts are document ed in the project docket for this final rule , Docket No. EPA - HQ - OAR- 20 09 - 0734 . **TABLE 3. PERSONS CONSULTED ON THE INFORMATION COLLECTION**  **ACTIVITIES Contact**  **Organization Telephone Number**  John Crouch Hearth, Patio, Barbe cue Association (HPBA) 916.536.2390 Rick Curkeet Intertek Testing Services 608.836.4400 Alice Edwards Alaska Dept. Of Environmental Conservation 907.465.5105 Bob Ferguson Ferguson, Andors & Company 802.763.2339 Stephen Hartsfield National Tribal Air Association 505.242.2175 Mike Haefner American Energy S ys tems 320 . 587 . 6565 Dan Henry Hearth & Home Technologies 509 . 685 . 8904 Ben M yr en My ren Consulting, Inc. 509.684.1154 Chris Neufeld Blaze King Industries 509.522.2730 Mitch Pisik Breckwell Hearth Products 817 . 652 . 9602 Lisa Rector Northeast States for Coordinated Air Use

Measurement (NESCAUM) 617.259.2095 Rod Tinnemore Washington State Department of Ecology 360.407.6978 Steve Vogelzang Vogelzang International, Inc. 616.396.1911 Paul Williams United States Stove Company 423 . 837 . 2100January 2015



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( d) Effects of Less Frequent Collection. Less frequent information collection would decrease the margin of assurance that manufacturers are produc ing residential wood heaters 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 vio lations 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 because the required emission standard model certifications are valid for 5 years prior to the need for renewal or recertification. During this time, the EPA needs to require the retention of model certification test s and QA compliance documentation to support initial and continued compliance with model certifications (e.g., certification tests, QA emissions tests, QA audit reports, biennial reports). (f ) Confidentiality. All in formation submitted to the EPA 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 . , Chapter 1, Part 2, Subpart B

—Confidentiality of Bus iness Information . (g ) Sensitive Questio ns. 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 AAA are manufacturers of new residential wood stoves and pellet heaters . The North American Industry Classification S ys tem (NAICS) code for residential wood heating manufacturing facilities is 33 3414, Heating Equipment (Except for Warm Air Furnace Manufacturing). S ubpart AAA also appl ies to laboratories that conduct or plan to conduct wood heater certification tests (referred herein as testing labs) and laboratoriesJanuary 2015



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that plan to become third -party certifiers (referred herein as third -party certifiers) for manufacturers. The NAICS 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 Wood Heaters (40 CF R p art 60, s ubpart AAA). The reporting requirements for NSPS subpart AAA were uniquely designed for the manufacturers , third -party certifiers and testing laboratories. The records required by this regulation must be retained by the manufacturer, third -party certifier and/or test labo ratory for 5 ye ars. 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 amended New Residential Wood Heater NSPS 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**  **Information Management** (a ) Agency Activities . Attachment 2 is a summary of the reporting and recordkeeping requirements for the f ederal government. The EPA activities associated with the final amended New Residential Wood Heater NSPS are provided in Table 2 (located at the end of this supporting statement) and are introduced in section 6(c). (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 .January 2015



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(c) Small Entity Flexibility. Most of the manufacturers, laboratories and commercial owners affected b y th e final amended subpart AAA are considered small b usinesses 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 smallest businesses affected b y this regulation. For heaters/stoves with EPA certification currently

in effect with Step 1 emission standards , we are giving conditional, automatic certification approval until the Step 2 emission standards effective date (2020). A llowing conditional, automatic certification of those heaters/stoves with compliant certification s and including phased compliance dates in the final rule allow s additional time for sources to come into compliance and help s reduce the burden on small businesses b y spreading out research and development (R&D) costs over several ye ars . We have also retained certification waiver provisions in the existing subpart AAA because they reduce the need for sources to re - test already certified models under qualifying conditions and reduce the burden associated with the certification process for smal l manufacturers of wood heaters. The final rule also includes changes to the QA program requirements that align better with existing safety QA procedures , thus eliminating duplicative procedures . Lastl y, w e have also deferred the requirement for (1) EPA - accredited test labs to be accredited under subpart AAA fo r three ye ars after the effective date of the rule and (2) non EPA - accredited test labs to be accredited under subpart AAA for six months after the effective date of the rule. (d ) Collection Schedule . The specific frequency

for each information collection activity within this request is shown in Table 1 for the residential w ood h eater s ource c atego ry , which is located at the end of this supporting statement . **6. Estimating the Burden and Cost**  **of the Collection** (a ) Estimating Respondent Burden. The annual recordkeeping and reporting respondent burden estimates for the New Residential Wood Heater NSPS final amended rule are shown in Table 1 , located at the end of this section . These numbers were derived from estimates based on the EPA’s experience with implementing existing subpart AAA and other standards.January 2015



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(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) . 3 

### Loading factors (i.e., fringe benefits and overhead rates) were calculated using methodologies referenced in promulgated regulations and their accompanying I CRs, particularly those used in New Source Review (NSR) regulations. Fringe benefits are calculate d as 29 percent of hourl y earnings, and overhead is calculated using a standard 110 percent above hourly earnings. Table 4 presents the labor rates used in the cost anal ys is. **T ABLE**  **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 three - ye ar ICR clearance period. These costs are summarized in Table 5 at the end of this section . Estimated capital co sts included in Table 5 include fixed capital cost estimates provided b y an anal ys is prepared by Ferguson, Andors & Company for the Hearth, Patio and Barbecue Association. 4 

### See the manufacturer costs impacts memo 5 

### and the unit cost memo 6 

### for more informati on on assumptions used in this section. Not e that these cost impacts differ from I CR 1176.11 based on new information on the structure of the industry and the final

3 May 2013 National Industry- Specific Occupational Employment and Wage Estimates . Located http://www.bls.gov/oes/current/naics4_333400.htm . 4 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: W oodstove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643). 5 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts . January 2015 . 6 Memorandum to USEPA from EC/R, Inc. Unit Cost Estimates of Residential Wood Heating Appliances . January 2015 .January 2015



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amendments made to subpart AAA that would result in additional expenses during the three - ye ar ICR clearance period in order for all models to comply with the final standards. As discussed in the manufacturer cost impacts memo, we estimate that there are currently 125 model lines of adjustable burn rate stoves produced b y 34 manufacturers , 20 model lines of single burn rate stoves produced b y 3 manufacturers and 125 model lines of pellet stoves produced b y 29 manufacturers. We assume that 90% of existing adjustable burn rate models ( 0 .9 X 125 models = 112.5)(34 manufacturers), 25% of existing pellet stove models ( 0 .25 X 125 models = 31.25)(29 manufacturers), and 0% of single burn rate stove models (0 X 20 = 0) (3 manufacturers) will meet EPA criteria as meeting Step 1 emission standards, and therefore will not need to test or appl y for certific ations during the three - year ICR 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 126 models ) will be developed/test ed and will appl y to certify to meet the Step 1 emission standards or Step 2 emis s ion standards during the three - ye ar ICR period (2015 - 2017) at a cost of $16,750 per test (includes EPA - required testing ($11,000), confirmation safety

testing or full safety testing ($5,000), and shipping of prototy pe(s)($750) costs ) . 7 

### The amended NSPS require s a permanent label on each wood heater model . To estimate the capital costs of the permanent label, we assumed the cap ital costs to be $400 per model certified (including those that receive conditional certification) and that all new models produced by all manufacturers to meet subpart AAA will have a permanent label affixed. These costs are consistent with cost estimates provided in Ferguson’s anal ys is. 8 

### The amended NSPS requires that each wood heater offered for sale b y a commercial owner be accompanied by an owner’s manual that contains specified installation and operation and maintenance information required to be followed to minimize emissions. We have assumed an average fixed cost of $2 ,250 for owner's manual (revised or new, possibly bilingual) per model, assuming 125 pellet stoves, 44 adjustable burn rate stoves and 20 single burn rate stove

7 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Wood stove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 8, Table 5. Fixed Costs per Model: Certification) . 8 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Woodstove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 8, Table 5. Fixed Costs per Model: Certification). May 2014.January 2015



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owner's manuals will need to be developed/revised to include subpart AAA requirements. These co sts are consistent with cost estimates provided in an anal ys is prepared for the Hearth, Patio & Barbecue Association (HPBA) b y Ferguson, Andors & Company . 9 

### The 1988 requirements for manufacturer QA programs are strengthened in the revised rule by requiring the manufacturer to c ontract 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 th e manufacturer’s QA plan is implemented properl y. For purposes of this I CR , w e assume that the c ontracted third -party certifier will require one QA performance t est and one QA audit for each o f the wood stove manufacturers (66 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. We assume that there would only

be one EPA compliance audit during the three - ye ar IC R period (2015 - 2017) that would affect one manufacturer. For purposes of estimating the capital costs that would be incurred b y an EPA compliance audit , we assume the cost of one appliance (based on the average of two appliances: 1 adjustable burn rate model ($848 each) and 1 pellet ($1,281 each) stove model) plus $16,750 for testing (includes EPA - required testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s) ($750) costs ) . The last category

of capital costs relates to ISO accreditation costs for test labs and third party certifiers seeking accreditati on (assuming a cost of $75,000/ accreditation) . Table 5 presents the estimated capital/start - up costs for the three - ye ar clearance period (2015 - 2017) .

9 Ferguson, Robert (Fergu son, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Woodstove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 8, Table 5. Fixed Costs per Model: Certification). May 2014.January 2015



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

**CLEARANCE PERIOD (201**  **5 -**  **201 7**  **) 10**  

### (A) **(B) (C)**  **(D) Data Collection Device**  **Capital/Start -**  **Up for One Respondent/Unit**  **Number of New Respondents/** **Models/ Units**  **Total Capital/Start -**  **Up Cost**  **(B X C)** Certification Test a 

### $ 16,750 per respondent 126 models $ 2,110,500 Cost of Permanent Label **b** 

### $ 400 per model 270 models $ 108,000 QA Performance Test **c** 

### $1 6 , 750 per respondent 66 respondents $1,105,500 EPA Compliance Audit Test d 

### $1 7 , 815 per respondent 1 respondent $ 1 7 ,815 Owners Manual e 

### $2,250 per model 270 models $607, 5 0 0 ISO Accreditation - Test Laboratories f 

### $75,000 per respondent 4 respondents $300,000 ISO Accreditation - Third Party Certifiers g 

### $75,000 per respondent 2 respondents $150,000 **Total s**  $ 4,399,315 **Annual average** $1,466,438 a Models certifie d by

testing per manufacturer: Assumes that 90% of existing adjustable burn rate models (.9 X 125 models = 112.5)(34 manufacturers), 25% of existing pellet stove models (.25 X 125 models=31.25)(29 manufacturers), and 0% of single burn rate stove models (0 X 20 = 0) (3 manufacturers) will not need to tes t and apply to certify to meet emission standards during the three - year ICR period (2015 - 2017) . We assume that manufactu rers will test (at a cost of $16,750 per test (includes EPA testing ($11,000), confirmation safety testing or full safety testing ($5,00 0), and shipping of prototype(s)($750) costs)) and apply to meet emission standards for 126 models during the three - year ICR period (2015 - 2017) in order to replace old mo dels that will not meet the Step 1 emission standard s. b Total costs of permanent labe ls are estimated to b e $400 per model. We e stimate that there will be 270 certified models produced by all manufacturers (66 manufacturers) during the period covered by this ICR (2015 - 2017) that would be subject to permanent labeling requirements. c Assumes th at there will be 66 QA performance tests (at a cost of $16,750 per test (includes EPA testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)($750) costs)) under the QA program during the three - year period covered by this ICR (2015 - 2017). We assume that each of the 66 manufacturers will be required to test one model under their QA program between 2015 and 2017. d Assumes that there will be EPA compliance audit testing for one model affecting one manufacturer during the period covered by this ICR (2015 - 2017). Costs for EPA compliance audit testing of one model assumes the cost of one appliance (ba sed on the average cost of two models : 1 adjustable burn rate model ($848 each) and 1 pellet ($1,281 e ach) stove model ) ) plus $16,750 for the test (includes EPA testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s) ($750) costs). e Assumes an average fixed cost of $2,250 for ow ner's manual (revised or new , possibly bilingual) per model (270 models) that 10 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses , Appendix A: Woodstove Cost Modeling. (Available at http://www.regulations. gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 8, Table 5. Fixed Costs per Model: Certification).January 2015



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will need to be developed/revised to include subpart AAA requirements. f Assumes all test labs will be ISO accredited (that are going to choose be accredited) before 2018, a total of four labs betwe en 2 015 and 2017 and 0 occurrences between 2018 and 2020. We assume an average cost to obtain ISO accreditatio n is $75,000 based costs estimates provided by manufacturers. g Assumes all third -party certifiers will be ISO accredited (that are going to choose to be accredited) before 2018, a total of two third -party certifiers between 2015 and 2017 and 0 occurrences between 2018 and 2020. We assume an average cost to obtain ISO accreditation is $75,00 0 based on cost estimates provided by manufacturers. 

### (i ii ) Annualizing Capital Costs . The total annual capital/start - up costs are estimated to average $ 1,466,438 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 complian ce and enforcement program , which includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emissions and the publication and distribution of collected information. The average annual agency cos t during the 3 ye ar s of the I CR is estimated to be $ 32,603 . See Table 2, located at the end of this supporting statement. The agency labor rates are from the Office of Personnel Management (OPM) 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 technical (GS - 12, Step 1) and $3 9.31 /hr for management (GS - 13, Step 5). These rates were increased by 60 percent to in clude fringe benefits and overhead. The fully- burdened wage rates used to represent agency labor costs are: clerical at $ 25.25 , technical at $ 46.67 and management at $ 62.90 . (d ) Estimating the Respondent Universe and Total Burden and Costs . Subpart AAA requires wood heater manufacturers , test laboratories and third -party certifiers to submit reports and/or to maintain records for demonstrating and documenting compliance with the NSPS. A third -party certification process is required under subpart AAA . Under this process , for all heaters/stoves subject to subpart AAA , after testing is complete d by an approved test laboratory , a certifi cation of conformity with the particulate matter emissions standard s must be issued by a third -party certifier with whom the manufacturer has entered into contract for certification services. In order to avoid the potential for manufacturer modelJanuary 2015



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certification delays (and the potential for lost revenues), subpart AAA allows for automatic certification for wood heaters that meet Step 1 emission standard s until the Step 2 emission standard compliance date (2020). The third -party certifier is an independent third -party that is ISO accredited to perform certifications, inspections and audits by an accreditation body . Accredited third -party certifiers under subpart AAA must maintain records of all certification tests, QA program inspections and QA audit performance tests. The third -party certifier can certify conformity if the emission tests have been conducted per the appropriate gui delines; the test report is complete and accurate; the instrumentation used for the test was properly calibrated; the test report shows that the representative affected wood heater meets the applicable emiss ion limits ; and the QA plan prepared b y 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 c onduct regular (at least annual) unannounced audits to ensure that the m anufacturer’s QA plan is being implemented and must prepare a report for ea ch audit that fully documents the results of the audit. The manufacturer must include in its contract with th e third -party certifier the authorization and requirement to submit all such reports to the Administrator . The ISO accreditation and approval to be third -party certifiers will not be required until 6 months after the effective date of the rule. We have ass umed that of the 6 labs, 2 will have ISO accreditation as third -party certifiers b y the effective date of the final amended rule and 2 will choose to obtain ISO accreditation as third -party certifiers during the period covered by this ICR (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 approved te st laboratories must maintain records of all certification tests, proficiency tests and compliance audit test data. Approved test laboratories must be approved for wood heater certification under subpart AAA or must be an independent third -party test labor atory that is accredited by a nationally

recognized accrediting entity

to perform testing using the test methods specified in subpart AAA. The final rule allows a three - ye ar extension of current EPA accreditations of labs (as approved test laboratories). W e assume that 6 laboratories will submit applications to become approved test labs between 2015 and 2017. Current EPA - accredited laboratories may retain their accreditationJanuary 2015



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and may conduct testing as approved test labs until 3 years after the effective date of this rule. Two of the labs are assumed to already be ISO - accredited and will need to apply to be approved test laboratories for subpart AAA testing and four labs are assumed to need to obtain I SO accreditation and appl y t o be approved test labs for subpart AAA testing. 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 AAA. The only final amended subpart AAA testing laboratory and third -party certifier recordkeeping and reporting burden costs not passed on to the manufacturer would be the burden associated with obtaining I SO accreditation , proficiency testing and reporting required for approved test laboratories to m aintain accreditation and approval as test labs, and specified recordkeeping requirements (e.g., certification tests, proficiency tests, QA p rogram inspections, audit test results ) . There are an estimated 66 existing manufacturers that will be subject to the New Residential Wood Heater NSPS . We recognize that this value may be high. We obtained information on the number of existing manufacturers b y appliance type, which may double count manufacturers that make more than one type of appliance. Also, there s eems 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 66 manufacturers to be a reasonable estimate of the number of new and existing manufacturers. M anufacturers of new residential wood heating devices are required to submit applications for certification of model lines, to submit results of emissions tests conducted to demonstrate that the model lines would comply with the emission limits and produce certified unit s according to a QA plan approved b y an independent third -party certifier . The final rule allows heaters/stove model s that meet specified 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 . Manufacturers must submit a notification of the initial test and biennial reports that each certified m odel 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.January 2015



### 16

M anufacturers are also required to apply permanent labels on each applicable unit prior to sale. These labels provide important compliance information to enforcement officials and important information to consumers for purchas ing appliances. The amended rule also specifies that manufacturers have the option of us ing temporary labels for the cleanest heaters in order to provide consumers the ability to select wood heaters that meet or exceed the Step 2 emission standards prior to the Step 2 emissions standards 2020 compliance date. T emporary labels may also be used to indicate wood heaters that meet Step 2 emission standards based on cord wood instead of crib wood, allowing consumers to select heaters better tuned to in - home performance. For the final amended New Residential Wood Heater NSPS , the components of the total annual responses attributable to this ICR are test notifications, applications for certification, biennial reporting for certified models, app lications for accreditation, test report submittals , QA audit reports and test lab proficiency reporting for the 72 respondents (66 manufacturers and 6 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 AAA is estimated at 246 . (e) Bottom Line Burden Hours and Cost Tables. (i ) Respondent T

ally. The bottom line respondent burden hours and costs for the 3 years (201 5 - 201 7 ) 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 AAA for the estimated 72 respondents (66 manufacturers and 6 laboratories ( including approved test labs and third -party certifiers ) ) that will be subject to the New Residential Wood Heater NSPS is estimated to be 2,947 person - hours , with an estimated average annual labor cost of $ 250,551 (approximately $179,000 for manufacturers, $16,000 for third -party certifiers and $55,000 for test laboratories) and estimated annual capital/start - up costs of $ 1,466,438 . (ii) The Agency T

ally. The average annual f ederal g o vernment cost is approximately $ 32,6 0 3 for approximately 716 hours for subpart AAA . 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 signi ficant variation is anticipated. (f ) Reasons for Change in Burden.January 2015



### 17

This I CR requests a reduction in 8,802 total annual labor hours (11,749 11



### - 2,947 ) and an assoc iated decrease in total annual respondent burden cost for reporting and recordkeeping of $898,661 ($1,149,212 12



### - $250,551 ) . This I CR requests a decrease in the total annual capital and operation and maintenance costs of $269,637 ( $ 1,736,075 13



### - $1,466,438 ) . The predominant reason for the change s in costs/ burden is the result of revisions to the NSPS (program changes) . The amendments to subpart AAA will have several major impacts. The first of these is the change in the number of affected appliances because of the inclusion of singl e burn rate stoves and all wood - burning pellet stoves. Although this change increase s the number of certification appl ications and certification tests to be processed over the clearance period for those models that do not qualify for automatic certification with the Step 1 emission standards, i t is important to note that by the final rule allowing for automatic certificatio n with the Step 1 emission standard s for those models that hold certificates that meet the EPA’s criteria as me eting the Step 1 emission standards, the number of certification tests/applications in the initial three - year ICR period focuses on o nl y those wood stove models that have not yet demonstrated that they can meet the Step 1 emission standards . The second impact results from changes in calculating estimates for permanent labels for new model s. Previously , we estimated cost s for permanent l abels based on the number of unit s shipp ed. Our new estimates calculate costs based on the number of model lines consistent with cost estimates provided in an anal ys is prepared for the Hearth, Patio & Barbecue Association (HPBA) b y Ferguson, Andors & Company . 14 

### The third impact results from changes to the QA requirements and use of a third -party certifier certification process . The focus in the three - ye ar clearance period will be for manufacturers to design and certify stoves to meet the new emission limits (where necessary) as demonstrated through certification testing and to begin to implement the new QA - related provisions. The new QA and third -party certifier certification process provisions of the revised subpart AAA are implemented in order to ensure initial and continuing compliance with the 11 NSPS for New

Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal), EPA ICR Number 1176.11, OMB Control Number 2060 - 0161. (See http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201311 - 2060 - 010 12 See Footnote 11. 13 See Footnote 11. 14 Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. Proposed Wood Heater NSPS Incremental Cost Effec tiveness Analyses , Appendix A: Woodstove Cost Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA - HQ - OAR - 2009 - 0734 - 1643 ); Page 8, Table 5. Fi xed Costs per Model: Certification). May 2014.January 2015



### 18

applicable emission limits. In the long run, the combinati on of the use of ISO third -party certifier and test laboratories should streamline the certification and accreditation process for the industry and laboratories and decrease the amount of time spent by the EPA in reviewing QA - related documents. These changes, combined with increasing automation and experience in complying with this standard result in less capital and operation and maintenance costs as well as recordkeeping and reporting burden . The fourth impact results from changes to streamline reporting and recordkeeping requirements to those that are essential for implementation and enforcement of the rule and that reflect the agency ’s experience under the current subpart. For example, we no longer use the number of units sold as the trigger for model line QA audits, so it is no longer important for retailers to track the number of units sold. These changes reduce industry burden, while simultaneou sly not affecting the agency ’s ability to enforce the standard. We have also carefull y reviewed the requirements included in this supporting statement to focus on activities that routinely occur. For example, revocation of certification and/or laboratory accreditation is extremely rare and is not reflected in this estimate of reporting and recordkeeping. Instead, we have focused on the routine activities that serve to demonstrate that sources are in compliance with the rule. The fifth impact results from changes in labor rates used. The labor rates used are greater for managerial and slightly less for technical and clerical than those used in the currently approved ICR based on May 20 13 labor rates obtained from the Bureau of L abor Statistics for the Ventilation, Heating, Air- Conditioning and Commercial Refrigeration Equipment Manufacturing (NAICS 33 34 00) . 15 

### (g ) Burden Statement The average annual respondent burden for the final Residential Wood Heating NSPS is approximately

41 hours with an approximat e average annual burden per response of 12 hours . Burden means the total time, effort or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a f ederal 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

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



### 19

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 th e 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 60 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 establis hed a public docket for this ICR under Docket ID No. EPA - HQ - OAR- 200 9 - 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), EPA 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) 566 - 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 th e Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17 th 

### Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Do cket ID Number ( EPA - HQ - OAR- 200 9 - 0734 ) and OMB Control Number (2060 - 0161) in any c orrespondence. **PART B** This section is not applicable because statistical methods are not used in data collection associated with this final rule .January 2015



### 20 (A ) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) Pers on- No. o f 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 perso n-hours pers on-hours cos ts occurrence per res pondent 2015-2017 2015-2017 2015-2017 2015-2017 2015-2017 **Ac ti**  **vi ty**  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** **ting Re quir**  **emen ts**  **Man ufactu**  **rers** 1. C ertificat ion tes t n ot if ication c 2.00 1.9 3.8 66 252. 5 12. 6 25. 3 24, 691 $ 290. 4 96. 8 8, 230 $ 2. A pplicat ion fo r cert if

ication d 8.00 1.9 15. 3 66 1,010.0 50. 5 101. 0 98, 763 $ 1, 161. 5 387. 2 32, 921 $ 3. Bi ennial report ing e 2.00 4.1 8.2 66 540. 0 27. 0 54. 0 52, 804 $ 621. 0 207. 0 17, 601 $ 4. EPA c om 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 re su lts g 2.00 1.0 2.0 66 132. 0 6.6 13. 2 12, 908 $ 151. 8 50. 6 4, 303 $ 6. QA annual audit

reports h 20. 00 16. 5 330. 0 4 1,320.0 66. 0 132. 0 129, 077 $ 1, 518. 0 506. 0 43, 026 $ 7. R eview annual QA

audit report

i 4.00 1.0 4.0 66 264. 0 13. 2 26. 4 25, 815 $ 303. 6 101. 2 8, 605 $ **Te st**  **Labor atories**  . 1. A pplicat ion fo r tes t l ab approv al j a. A lready h as ISO a ccreditat ion 20. 00 1.0 20. 0 2 40. 0 2.0 4. 0 3, 911 $ 46. 0 15. 3 1, 304 $ b. Ne eds to o btain I SO a ccreditation 80. 00 1.0 80. 0 4 320. 0 16. 0 32. 0 31, 291 $ 368. 0 122. 7 10, 430 $ 2. Bi ennial profiency

te st ing and report

dev elopm ent

k 150. 00 1.0 150. 0 6 900. 0 45. 0 90. 0 88, 007 $ 1, 035. 0 345. 0 29, 336 $ **Thir d-Party** 

**Ce rtifi**  **er** 1. A pplicat ion for approv

al as a th ird-party

certifier l a. A lready h as ISO a ccreditat ion 20. 00 1.0 20. 0 2 40. 0 2.0 4. 0 3, 911 $ 46. 0 15. 3 1, 304 $ b. Ne eds to o btain I SO a ccreditation 80. 00 1.0 80. 0 2 160. 0 8.0 16. 0 15, 646 $ 184. 0 61. 3 5, 215 $ Subtotal for Report ing Requirem ents 4,986.5 249. 3 498. 7 487, 607 $ 5, 734. 5 1, 911. 5 162, 536 $ **Re cordkeepi**  **ng Re quir**  **emen ts**  **Man ufactu**  **rers** 1. Tes t d ocum entat ion m 1.00 4.1 4.1 66 270. 0 13. 5 27. 0 26, 402 $ 310. 5 103. 5 8, 801 $ 2. QA param eter ins pections n 2.00 12. 0 24. 0 66 1,584.0 79. 2 158. 4 154, 892 $ 1, 821. 6 607. 2 51, 631 $ 3. R etained (s ealed) stov es o 1.00 1.9 1.9 66 126. 3 6.3 12. 6 12, 345 $ 145. 2 48. 4 4, 115 $ **Te st**  **Labor atories**  1. C ertificat ion tes t, p roficiency te st , a nd audit

te st res ults p 2.00 36. 0 72. 0 6 432. 0 21. 6 43. 2 42, 243 $ 496. 8 165. 6 14, 081 $ **Thir d-Party** 

**Ce rtifi**  **er** 1. Ce rt if ication tes t, QA

p rogram 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 for Recordkeeping Requirem ents 2,700.3 135. 0 270. 0 264, 045 $ 3, 105. 3 1, 035. 1 88, 015 $ TOTA L BU RDEN AN D CO ST (SA LA RY ) 7,686.8 384. 3 768. 7 751, 652 $ 8, 839. 8 2, 946. 6 250, 551 $ TOTA L NUM BER OF R ESPON SES 2015-2017 738 An nual av g. 246 a Ma nagem ent

p ers on-hours a nd clerical pers on-hours are as su me d to be 5 percent and 10 percent of te chnical pers on-hours , re sp ectiv ely. b C os ts are bas ed on th e fo llowing hourly rates : te chnical at $85. 41, m anagem ent at $ 148. 70 and clerical at $49. 36.

d Mo del applicat ions p er m anuf acturer: 126 mo del lines (s ee ta ble note "c") fro m 66 ma nuf acturers p rojected from 2 015-2017. TA BL E 1 . TH RE E-Y

EAR AN D AN NUA

L RE SPON DENT BU RDEN AN D CO ST OF R EPOR TIN G AND RECO RDKEEPING RE QU IR EM EN TS OF TH E FIN AL R ULE (2015-2017)

e Fo r purpos es o f th is IC R, w e as su me th at 2 70 mo dels w ill eit her tes t a nd apply to certify to m eet l im its or will obtain a condit ional approv al as m eet ing lim its. We hav e as su me d 2 hours per report, and t hat 1 b iennial report will be required f

or all 270 mo dels (66 ma nuf actures ) during the three-y ear IC R period (2015-2017). cMo dels c ert if

ied by te st ing per ma nuf

acturer: A

ssu me s th at 9 0% of

ex is ti ng adjus ta ble burn rate mo dels (.9 X 1 25 mo dels = 11 2.5)(34 m anuf acturers ), 2 5% of

ex is ti ng pellet

s tov e m odels ( .25 X

125 m odels = 3 1.25)(29 ma nuf acturers ), a nd 0% of s ingle burn rate s tov e m odels (0 X

20 = 0 ) (3 ma nuf

acturers ) will not

n eed to te st

a nd apply

to certify to m eet l im its during th e th ree-y ear I CR period (2015-2017) . We a ssu me th at m anuf actures w ill tes t and apply

to m eet l im its fo r 126 mo dels during t he three-y ear IC R period (2015-2017) in order to re place old mo dels th at w ill not m eet th e 2015 com pliance em is si on standards .

f As su me s that

one of the 66 ma nuf

acturers w ill be required to undergo an EPA com pliance audit

te st fo r one of their m odels d uring the three-y ear I CR period (2015-2017). g As su me s th at the re will be one QA a udit p erform ance tes t p er ma nuf acturer (66 m anuf

acturers ) under the QA program during t he period cov ered by th is IC R (2015-2017). We as su me th at each of th e 66 ma nuf

acturers w ill be required to tes t o ne mo del and report res ults to th e EPA under their QA program b etween 2015 and 2017. h, i As su me s th ere will be one QA audit by th e thi rd-part

y c ert if ier f or each of

th e 66 ma nuf

acturers ov

er the three-y

ear IC R period (2015-2017) and th at each of thes e audit

reports will be rev

iewed by th e ma nuf

acturer (in all cas es ) and ma y require preparing a res pons e to th e audit ( in ca se s where deficiencies are ident ified). It i s as su me d that th e th ird-part

y c ert if ier will audit

m ult iple ma nuf

acturer mo dels w hen they conduct their audits (thereby reducing the ti me needed to audit

m anuf acturers a nd their as so ciated mo dels ).January 2015



### 21 m We hav e as su me d that

m anuf acturers w ill sp end one hour per certification tes t (for 27 0 m odels ) to keep the required records .

q We ex pect th e required recordkeeping to be highly a utom ated and hav

e as su me d that

th ird-part

y c ert if iers (4 th ird party

certifiers ) will sp end 2 hours p er m ont h fo r the 3-y ear period of

th is IC R to m aintain th e required records . o It i s as su me d th at o ne stov e is s ealed and retained f or each cert if

icat ion tes t (as su mi ng 126 cert if ication tes ts ) required of the 6 6 m anuf acturers th at ce rt if

y to m eet

l im its (does not

i nclude mo dels th at o btain autom atic certificat ion). p We ex pect th e required recordkeeping to be highly a utom ated and hav

e as su me d that

te st l aboratories ( 6 laboratories ) will sp end 2 hours p er m ont h fo r the 3-y ear period of

th is IC R to m aintain the required records . k We as su me th ere will be one biennial prof iciency te st and report per tes ti ng lab (6 labs ) required during th e th ree-y ear I CR period (2015-2017). l We as su me th at 4 l aboratories w ill su bm it a pplicat ions fo r approv al as th ird-part

y c ert if iers b etween 2015 and 2017. Tw o of th os e laboratories w ill be ISO-accre dited and tw o will need to obtain ISO-a ccreditat ion.

n Param eter ins pections a re part of the exis ti ng sa fety

i ns pection program . We hav e as su me d each of

th e 66 wood stov

e ma nuf acturers th at

certifies m odel lines bet ween 2015-2017 will sp end an addit ional 2 hours p er quarter during the 3-y

ear period of thi s IC R (2015-2017) to d ocum ent res ults. j A ssu me s th at 6 l aboratories w ill su bm it a pplicat ions to be approv ed as te st

l aboratories fo r s ubpart A AA during th e th ree-y

ear I CR period (2015-2017). We as su me th at tw o of th os e laboratories w ill already be ISO-a ccredited as te st laboratories and f

our will need to o btain ISO-a ccreditation as te st l aboratories .January 2015



### A - 1

TA BL E 2. T HRE E-YEAR AN NUA L BU RDE N AN D COST T O T HE FED ER

ALG OVERN MEN T OF TH E 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 2015-2017 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 1. 9 1. 0 66 63. 1 3. 2 6. 3 $3, 304 72. 6 24. 2 1, 101 $ 2. C ertif ica tion test d 20. 0 1. 9 38. 3 6 229. 5 11. 5 23. 0 $12, 015 264. 0 88. 0 4, 005 $ 3. App lica tio n fo r ce rt if ica tio n of model line e 8. 0 1. 9 15. 3 66 1, 010. 0 50. 5 101. 0 $52, 865 1, 161. 5 387. 2 17, 622 $ 4. Bie nnial re port ing for ce rt if ie d models f 1. 0 4. 1 4. 1 66 270. 0 13. 5 27. 0 $14, 132 310. 5 103. 5 4, 711 $ 5. Rev iew and approv

al of te st labcr

edent ials g 4. 0 1. 0 4. 0 6 24. 0 1. 2 2. 4 $1, 256 27. 6 9. 2 419 $ 6. Rev iew te st labb iennial profic ienc y te st r eport s h 10. 0 1. 0 10. 0 6 60. 0 3. 0 6. 0 $3, 140 69. 0 23. 0 1, 047 $ 7. Rev iew QA p erform anc e test r es ul ts i 2. 0 1. 0 2. 0 66 132. 0 6. 6 13. 2 $6, 909 151. 8 50. 6 2, 303 $ 8. Rev iew QA a udi t r

eport j 2. 0 1. 0 2. 0 4 8. 0 0. 4 0. 8 $419 9. 2 3. 1 140 $ 9. EPA C omplianc 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

ier c re dentials l 8. 0 1. 0 8. 0 4 32. 0 1. 6 3. 2 $1, 675 36. 8 12. 3 558 $ TO TA L BU RDE N AN D COST ( SALARY) 1, 868. 7 93. 4 186. 9 $97, 809 2, 149. 0 716. 3 32, 603 $ 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 26 model lines f rom 66 manufac tu rers p rojec te d duri ng th e three-y ear ICR period (2015-2017). Assu mes th at it will ta ke3 0 minut es tor ev iew ce rt if ica tion test n ot if

ica tions.

e EPA mu st r

ev iew and approv

e ce rt if icatio n appl ica tio ns : 12 6 model lines f rom 66 manufac tu rers d uring th e th ree-y ear IC R period (2015-2017). f Assu mes th at th e EPA w ill rec ei veo ne bi enni al report f or 270 models ( 66 manufac tu rers ) ov er th e 3-y ear ICR period (2 015-2017. g Assu mes th at 6 test la borat ories w ill su bmit a pplic at ions f or s ubpart AAA te sting a pprov al (2 that a lready h av

e IS O ac credi ta tio n and 4 that do not) between 2015 and 2017. h Assu mes th at th ere wi ll be one biennial laborat ory p ro fi ci enc y te st p er laborat ory ( 6 laborat ori es ) duri ng th e th ree-y ear ICR peri od (2015-2017).

k Assu mes th at o ne model line for one of th e 66 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 third-par ty ce rt if iers f or this rul e: Wea ssu me th at 4 labs w ill su bmit a pplic at ions f or a pprov al toth e EPA a s th ir

d-part y ce rt if

ie rs d uri ng th e th ree-y ear ICR peri od (2015-2017). d Assu mes th at ove r th e long te rm th e EPA w ill o bs erv e 5 perc ent of ce rt if

icatio n te sts ( 126 X .0 5) c onduc te d during t he ICR report ing period, w hic h is r ounded to6te sts o bs erv ed duri ng th e period of

th is I CR (2015-2017).

i Assu mes th at th ere wi ll be 66 QA emissions test res ul ts su bmitte d under th e QA p rogram and rev iewed by th e EPA d urin g th e period cove red by this I CR (2015-2017). Wea ssu meth at e ac h of th e 66 manuf ac tu rers w ill be requi red tote sto ne model and report r es ults toth e EPA u nder their QA p rogram bet ween 2015 and 2017. j Assu mes th ere wi ll be one QA audit by theth ird-party ce rt if ier rev iewed by th e EPA f

or e ac h of th e 66 manufac tu rers ov er th e th ree-y ear ICR peri od (2015-2017).January 2015



### A - 2 **Attachment 1 Respondent Reporting and Recordkeeping**  **Requirements NSPS for New Residential Wood Heaters (40 CFR part 60, subpart AAA) (Revision)**  **Regulatory Reference Title 40, Part 60**  **Regulated Entity Reporting/Recordkeeping Requirement**  **Frequency/Other Comments** 60.533(b), 60.533(f)(1) Manufacturer Report : Application for a certificate of compliance. Report is to include results of certification test, model identification information, engineering drawings and component emissions specifications (for components that may affect emissions), identification of C BI (as necessary), warranty information, owner’s manual, documentation of contract with approved laboratory and third -party certifier, quality assurance (QA) program and various other affirmations of compliance. Once for each model line.

60.533(g)* Manufacturer Report : Waiver from submitting test results. May apply for a waiver of the requirement to submit the results of a certification test. Once per model, if at all. 60.533(i) Manufacturer Report : Renewal of certification. Renewal of certificate allowed by

reapplying or by affirming in writing that the wood heater has been 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. 60.533(k)** Manufa cturer Report : Recertification required w henever a change in 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 appli cable emission limits. Variable. 60.533(m) Manufacturer Report : Develop a QA program and submit with the 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. 60.533(n)** Manufacturer Report : EPA compliance audit test results. EPA may select a wo od heater for compliance audit testing. EPA may test or direct the manufacturer to test a selected mo del line; at manufacturer’s expense. Variable and infrequent. 60.534(g) Manufacturer Report : Notification of in advance of compliance certification test. Once for each model line, at least 30 days before the start of testing. 60.536(a) Manufacturer Produce and apply permanent label. One per unit produced.January 2015



### A - 3

60.536(f) *** 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 . 60.536 (g) Manufacturer Develop and publish owner’s manual. One owner’s manual developed per model line; a copy accompanies each unit produced. 60.537(a) Manufacturer Maintain records of all certification test data, results of QA program inspections and emission test data. Once per model for certification test data. Periodically for QA inspections and tests. 60.537(c) Manufacturer Retain sealed wood heater at facility for 5 years after certification test of model. One for each model certified. 60.537(d) Manufacturer Report : Certification that model line is unchanged and sales data for each model by state. Every 2 years following issuance of a certificate of compliance for each model line. 60.537(f) Manufacturer Report : Performance test data submitted ele ctronically Within 60 days after completion of each performance test. 60.537(g) Manufacturer For each certified model line, post the non - CBI certification test report to the manufacturer’s website Once for each model line, within 30 days of receiving the certificate of compliance. 60.539** Manufacturer Various requests, submittals, motions, filings, etc., under hearing and appeal procedures. Variable and infrequent, if at all. 60.535(a) Test Laboratory Report : After being accredited by a nationally recognized accrediting entity, application for EPA approval as a test lab. Laboratories previously accredited by the EPA may continue to be accredited and deemed EPA approved for testing under this rule until 3 years after the effective date of the rule. O nce (unless not rene wed every 5 years by the EPA). 60.535(a)(2)(i), 60.537(b) Test Laboratory Report : Proficiency test and documentation. Approved test labs must participate in a biennial proficiency testing program conducted by a nationally recognized ac crediting entity. Each approved test laboratory must submit all proficiency test results to the EPA. Biennially. 60.537(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. 60.533(m), 60.535(e)(2) Third - Party Certifier Report : Submit report of unannounced QA program At least annually.January 2015



### A - 4

* This is associated with an exemption or waiver (which would eliminate other reporting and recordkeeping burdens) and, there fore, is not counted as a burden in the calculation. ** This is not a routine report. It is a provision for an extraordinary circumstance and, therefore, is not included in the c alculations because it is very unlikely to occur during the next 3 years. *** This is an optional requirement and, therefore, is no t included in the calculated burden estimates. audits to EPA and the manufacturer 60.535(e) Third - Party Certifier Report : A fter being accredited by a nationally recognized accrediting entity, application for EPA approval as a third -party certifier. Once , to be renewed every 5 years. 60.537(b) Third - Party Certifier Keep records of documentation pertaining to certification tests, QA inspection and 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/QC inspection and audit test. 60.537(b) Third - Party Certifier Report : Each certifier must submit each certification test, QA inspection report and ISO IEC accreditation credentials to the EPA. Once for each certification test, QA/QC 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.January 2015



### A - 5 **Attachment 2 Federal Reporting and Recordkeeping Requirements**  **NSPS for New Residential Wood Heaters (40 CFR part 60, subpart AAA) (Revision) Regulatory Reference**  **Title 40, Part 60 Agency**  **Reporting/Recordkeeping Frequency/Other Comments**  60.533(c)(1) or (2), 60.533(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 line. 60.533(i)(3) or (4) EPA Report : Renewal or denial of certificate of compliance . Every 5 years. 60.533(l)(2)* EPA Report : Notice of revocation of certification. Variable and infrequent, if at all. 60.533(n)(1)(ii) EPA Report : Notice to manufacturer that a model has been selected for an EPA compliance audit test. Variable and infrequent 60.533(n) (3 ) * EPA Report : Notification of suspension or revocation of a mo del’s certification. Variable and infrequent, if at all. 60.535(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. 60.535(b)(2)* EPA N otice of intention to revoke test laboratory approval with justification and basis. Variable and infrequent, if at all. 60.535(e)(3) EPA Report : Review of third -party certifier application and provide a certificate of approval if approval criteria met. If approval not granted, provide a w ritten notice with rationale. Third -party certifier approval expires 5 years after being issued unless renewed. 60.535(f)(2)* EPA Notice of intention to revoke third -party certifier approval with justification and basis. Variable and infrequent, if at all. 60.537(b) EPA Evaluation of laboratory proficiency tests submitted by test laboratories. Biennially. 60.539* 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.