SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for the Wood Building Products Surface Coating Industry (40 CFR Part 63, 

Subpart QQQQ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for the Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart 

QQQQ) (Renewal), EPA ICR Number 2034.06, OMB Control Number 2060-0510

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Wood 

Building Products Surface Coating Industry were proposed on June 21, 2002 and promulgated on 

May 28, 2003. These regulations apply to new and existing facilities that perform surface 

coating of wood building products where the total Hazardous Air Pollutants (HAPs) emitted are 

greater than or equal to 10 tons per year of any one HAP, or where the total HAPs emitted are 

greater than or equal to 25 tons per year of any combination of HAPs, that use at least 4,170 

liters (1,100 gallons) of coatings annually. New facilities include those that commenced 

construction, modification, or reconstruction after the date of the proposal. This information is 

being collected to assure compliance with 40 CFR Part 63, Subpart QQQQ.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They 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. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/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 U. S.

Environmental Protection Agency (EPA) regional office.

The “Affected Public” are private sector businesses that perform surface coating of wood 

building products. The burden to the “Affected Public” may be found below in Table 1: Annual 

Respondent Burden and Cost – NESHAP for the Wood Building Products Surface Coating 

Industry (40 CFR Part 63, Subpart QQQQ) (Renewal). The burden to the “Federal Government” 

is attributed entirely to work performed by federal employees or government contractors; this 

burden is found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for the 

Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal).
2

 Based on our consultations with industry representatives, there is an average of one

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 232 respondents per year will be subject to the 

standard, and no additional respondents will become subject to the standard. The industry growth 

rate is based on the Agency’s estimate from the previous renewal. It should be noted that 

consultations with industry members have indicated a potential decline in the number of 

facilities, however the specific number of closures is unknown and therefore the number of 

respondents is unchanged for this ICR. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

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. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

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

(C) install, use, and maintain such monitoring equipment, and use 

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, HAP emissions from wood building product surface 

coating facilities either cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NESHAP were promulgated for this source 

category at 40 CFR Part 63, Subpart QQQQ.

2(b) Practical Utility/Users of the Data
3

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, and leaks are being detected and repaired and the standard is being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

QQQQ.

3(a) Non-duplication

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 its 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, 

duplication does not exist.

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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 
4

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has previously been reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the Composite Panel Association, at (703) 

724-1128; 2) Alamco Wood Products, at (877) 679-9663.

We received comments from Alamco Wood Products. The company indicated that 

several facilities have closed in the past few years, but did not provide a quantitative estimate on 

number of closures. In addition, the company estimated the base managerial labor costs at 

$70.10/hr, technical labor costs at $50/hr and clerical labor costs at $30/hr. The base labor rates 

appear reasonable when compared to the labor rates referenced in this ICR; however, this ICR 

accounts for an additional overhead of 110 percent on top of base labor rates. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

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

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, section 1320.5.

These standards require the respondents 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 the 

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

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 
5

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, 

Subpart B - Confidentiality of Business Information (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

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are wood building 

products surface coating facilities. The United States Standard Industrial Classification (SIC) 

codes for the respondents affected by the standards, which corresponds to the North American 

Industry Classification System (NAICS) codes, are listed below.

Standard (40 CFR Part 63, Subpart QQQQ) SIC Codes NAICS Codes

Hardwood Veneer and Plywood Manufacturing 2421 321211

Softwood Veneer and Plywood Manufacturing 2426 321212

Engineered Wood Member (except Truss) Manufacturing 2431 321213

Truss Manufacturing 2435 321214

Reconstituted Wood Product Manufacturing 2436 321219

Wood Window and Door Manufacturing 2439 321911

Other Millwork (including Flooring) 2493 321918

All Other Miscellaneous Wood Product Manufacturing 2499 321999

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for the 

Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ). 
6

A source must make the following reports:

Notifications

Initial notification 63.4710(b), 63.5(d), 63.9(b)

Notification of compliance status 63.4710(c), 63.9(h)

Notification of construction or reconstruction 63.5

Notification of actual startup 63.9(b)

Notification of performance test 63.7(b), 63.8(e), 63.9(e)

Reports

Semiannual report 63.4720(a)

Excess emissions report 63.4720(a)(4-7)

Report of performance test 63.4720(b)

Startup, shutdown, malfunction report 63.4720(c)

A source must keep the following records:

Recordkeeping

Five year retention of records 63.4731(b), 63.10(b)

Material formulation data 63.4730(b)

Records of HAP content calculations 63.4730(c)

Copies of notifications and reports 63.4730(a)

Records of names of materials used 63.4730(d)

HAP fractions in each material used 63.4730(e)

Coating solids fraction in each material used 63.4730(f)

Density of materials used 63.4730(g)

Documentation of waste material shipped offsite 634730 (h) 

Startup, shutdown, and malfunction plan records 63.4730(i),(k),63.6(e)

Documentation of control device performance tests 63.4730(k),63.10(b)

Values measured by continuous monitoring systems 63.4730(k)

Monitoring system calibrations, maintenance 63.4730(k)

Periods of monitoring system failure shutdown 63.4730(j),(k)

Electronic Reporting
7

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate compliance monitoring system (CMS) for temperature, 

for gas flow, or for pressure drop for oxidizer, carbon adsorber, condenser, concentrator, or 

capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, #A, 3B, 

4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E, 204F, 311, or ASTM Method D1475-98, 

D2697-86, D6093-97 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 
8

Agency Activities

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS.

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properly installed and operated.

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

with the emission standard. 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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS 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/operator for five 

years.

5(c) Small Entity Flexibility

A majority of the respondents are small entities (i.e., small businesses). 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 types of control equipment 

employed, the recordkeeping and reporting requirements are the same for both small and large 

entities. The Agency considers these to be the minimum requirements needed to ensure 

compliance and, therefore, cannot reduce them further for small entities. To the extent that 

larger businesses can use economies of scale to reduce their burden, the overall burden will be 

reduced. According to the Industry Profile for the Proposed Wood Building Products NESHAP1, 

97 percent of the parent companies affected by proposed action were estimated to be small 

entities as defined by the Small Business Administration. The Agency assumes that 97 percent 

of the 232 facilities affected by this ICR, or 225 facilities, are small entities.

5(d) Collection Schedule

 

1

Industry Profile for the Proposed Wood Building Products, NESHAP Final Report, U.S. EPA, EPA-453/R-01-002
9

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for the Wood 

Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for 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 75,800 (Total Labor Hours from Table 1 below). 

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: 

Managerial $129.93 ($61.87+ 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

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

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 
10

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

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

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

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

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New 

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CEM $16,000 0 $0 $1,200 232 $278,400

Total $0 $278,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $278,000. 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 $278,000. These are 

recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

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

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$389,000. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,
11

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: Average Annual EPA Burden and Cost – NESHAP for the Wood 

Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 

232 existing respondents will be subject to the standard. It is estimated that no additional 

respondents will become subject. The overall average number of respondents, as shown in the 

table below is 232 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 232 0 0 232

2 0 232 0 0 232

3 0 232 0 0 232

Average 0 232 0 0 232

1 New respondent include sources with constructed, reconstructed and modified affected facilities.

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 232. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That Keep 

Records But Do Not 

Submit Reports

(E)

Total Annual 

Responses

E=(BxC)+D

Initial notification 0 1 0 0

Notification of compliance status 0 1 0 0

Notification of 

construction/reconstruction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance test 0 1.2 0 0

Report of performance test 0 1.2 0 0
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Total Annual Responses

Semiannual report 232 2 0 464

Excess emissions report 232 0.5 0 116

Startup, shutdown, malfunction report 232 0.5 0 116

Total 696

The number of Total Annual Responses is 696. 

The total annual labor costs are $7,600,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for the Wood Building 

Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 75,800 hours at a cost of $7,600,000. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP 

for the Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ)

(Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 109 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $278,000. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

8,540 labor hours at a cost of $389,000. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for the Wood Building Products Surface Coating Industry (40 CFR Part 63, 

Subpart QQQQ) (Renewal).
13

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a small adjustment increase in the respondent and Agency labor hours in this 

ICR compared to the previous ICR. There is also a decrease in the total O&M costs. This is not 

due to program changes; rather, the changes occurred because we are rounding total values in 

this ICR to three significant figures. 

In addition, there is an increase in labor costs for both the respondents and the Agency 

due to an increase in labor rates. This ICR uses updated labor rates from the Bureau of Labor 

Statistics to calculate burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 109 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 regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2011-0274. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the 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 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 
14

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 docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2011-0274 and OMB Control Number 2060-0510 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 the Wood Building Products Surface Coating Industry (40 CFR

Part 63, Subpart QQQQ) (Renewal)

Burden Item

(A)

Personhours per 

occurrence

(B)

Number of 

occurrences 

per year

(C) 

Personhrs. per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per yeara

(E)

Technical 

personhrs. per 

year 

(E=CxD)

(F) 

Management 

person-hrs. 

per year

(F=Ex0.05)

(G)

Clerical 

personhrs. per 

year 

(G=Ex0.1)

(H)

Annual costs 

($)b

1. Reporting requirements

a. Familiarize with rule 

 requirements 4 1 4 232 928 46.4 92.8 $107,040.62 

b. Process/review information 4 4 16 232 3712 185.6 371.2 $428,162.50 

c. Write reports

i. Initial notification 2 1 2 0 0 0 0 $0 

ii. Notification of compliance 

status 2 1 2 0 0 0 0 $0 

iii. Notification of 

construction/reconstruction 2 1 2 0 0 0 0 $0 

iv. Notification of actual 

startup 2 1 2 0 0 0 0 $0 

v. Notification of performance

test 2 1.2 2.4 0 0 0 0 $0 

vi. Report of performance 

test 10 1.2 12 0 0 0 0 $0 

vii. Semiannual report 6 2 12 232 2,784 139.2 278.4 $321,121.87 

viii. Excess emissions report 4 0.5 2 232 464 23.2 46.4 $53,520.31 

ix. Startup, shutdown, 

 malfunction report 4 0.5 2 232 464 23.2 46.4 $53,520.31 

Subtotal for Reporting 

Requirements 9,605 $963,366 

2. Recordkeeping requirements
17

a. Familiarize with rule 

 requirements 4 1 4 232 928 46.4 92.8 $107,040.62 

b. Plan activities 12 1 12 232 2,784 139.2 278.4 $321,121.87 

c. Implement activities 12 1 12 232 2,784 139.2 278.4 $321,121.87 

d. Maintain record system for 

 material used 20 1 20 232 4,640 232 464 $535,203.12 

e. Time to enter information

i. Material usage 0.5 260 130 232 30,160 1508 3016 $3,478,820.28 

ii. Compliance calculation 2 12 24 232 5,568 278.4 556.8 $642,243.74 

f. Time to train personnel 10 1 10 232 2,320 116 232 $267,601.56 

g. Store, file, and maintain records 2 12 24 232 5,568 278.4 556.8 $642,243.74 

h. Retrieve records/reports 1 12 12 232 2,784 139.2 278.4 $321,121.87 

Subtotal for Recordkeeping 

Requirements 66,166 $6,636,519 

TOTAL LABOR BURDEN AND 

COST (rounded) c 75,800 $7,600,000 

Capital and O&M Cost c $278,000

Grand TOTAL c $7,880,000

Assumptions:

a

 There is an average of 232 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facility will become subject to this 

regulation. 

b

 This ICR uses the following labor rates: $123.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by 

Occupational and Industry group.” The rates are from “column 1, Total Compensation. “ The rates have been increased by 110% to account for the benefit packages 

available to those employed by private industry.

c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for the Wood Building Products Surface Coating Industry

(40 CFR Part 63, Subpart QQQQ) (Renewal)

 

Burden Item

(A)

EPA 

Personhours 

per 

activity

(B) 

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(D=Cx0.05)

(G)

Clerical 

personhours per 

year 

(E=Cx0.1)

(H)

Annual 

costs ($)b

1. Initial performance test 24 0 0 0 0 0 0 $0 

2. Repeat performance test 24 0 0 0 0 0 0 $0 

3. Report review 

a) Initial notification 8 0 0 0 0 0 0 $0 

b) Notification of performance test 8 0 0 0 0 0 0 $0 

c) Notification of compliance status 8 0 0 0 0 0 0 $0 

d) Notification of 

 construction/reconstruction 8 0 0 0 0 0 0 $0 

e) Notification of actual startup 8 0 0 0 0 0 0 $0 

f) Notification of performance test 8 0 0 0 0 0 0 $0 

g) Report of performance test 8 0 0 0 0 0 0 $0 

h) Semiannual report 12 2 24 232 5,568 278.4 556.8 $291,429 

i) Excess emissions report 8 0.5 4 232 928 46.4 92.8 $48,572 

j) Startup, shutdown, malfunction report 8 0.5 4 232 928 46.4 92.8 $48,572 

Total Burden Hours and Costs c 8,540 $389,000 

Assumptions:

a

 There is an average of 232 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facility will become subject to 
19

this regulation.

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.90(GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78

x 1.6). These rates are from the Office of Personnel Management (OPM) 2014 General Schedule which excludes locality rates of pay.

c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.