SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

S ubpart 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 2034.0 6 , 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

co ating 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 as sure compliance with 40 CFR P art 63, S ubpart 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 t he 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 complianc e, and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this P art 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 Surfa ce 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 facilit y at eac h 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 subjec t 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 t o:

(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 loca tions, 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) s ubmit 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 P art 63, S ubpart QQQQ

.

2(b) Practical Utility/Users of the Dat a3

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 evidenc e 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. Durin g 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 det ected 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 P art 63, S ubpart
QQQQ

.

3(a) Non

- duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regi onal office. Otherwise, the information is sent directly to the de legated 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 no t 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 Fed eral Register

.

3(c) Consultations

The Agency has consulted i ndustry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source4

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.

I ndustry 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, t he company estimate d 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

account s 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 f irst Federal Register n otice.

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 en sure 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

T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR P art 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. T he retention of records for five years allow s EPA to establish the compliance history of

a source

, any pattern of non

- compliance and to determine the appropriat e leve l of enforcement

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

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or5

nonexistence of essential records

.

3(f) Confi dentiality

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, C hapter 1, P art 2,

S ubpart B

- Confidentiality of Business Information (CBI) (see 4 0 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

T he 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 32121 4

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

I n 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 P art 63, S ubpart QQQQ )

.6

A source must make the following reports:

Notification s

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 63.47 30(e)

Coating solids fraction in each material used 63.4730(f)

Density of materials used 63.4730(g )

Documentation of waste material shipped offsite 6347 30 (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 Reporting7

Some of the r espondents 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 recordke eping 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 emissions8

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 require d 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). T he 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 a re 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 NESHAP 1

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

entities as defi ned 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

- 0029

The specific frequency for each information collection activity wi thin 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 S ubpart 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 i dentified. 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 r eporting requirement s is estimated to be 75, 800 ( T otal Labor Hours from Table 1 below ).

T hese hours are based on Agency studies and background documen ts from the development of

the regulation, Agency knowledge and experience with the NESHAP program, the p reviously 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 the10

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

associat ed with continuous monitoring. Th e 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, 4 00

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 o f column D in the

above table.

The total operation and maintenance (O&M) costs for this ICR are $ 278,0 00

. 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 $ 278,0 00

. 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 responden ts, periodic inspection of sources of emissions, and the publication and distribution of collec ted 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 $6 2.90 (GS

- 13, Step 5, $3 9

. 31 + 60%)

Technical $4 6

. 67 (GS

- 1 2, Step 1, $2 9

. 17 + 60%)

Clerical $2 5.25 (GS

- 6, Step 3, $15. 78 + 60%)

These rates are from the Office of Personnel Management (OPM)

, 201 4 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 estimat ed 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 thi s 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.

. C olumn 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 0 012

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 t o 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 $ 278,0 00

. 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 requi red 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, t her e 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 reportin g 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 c ollection 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

Num bers for EPA regulations are listed at 40 CFR P art 9 and 48 CFR C hapter 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 t his 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 al so 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 Public14

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 i s (202) 566

- 17 52

. Also, you can send comments to the Office of

Information a nd 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

- 20 11

- 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.16

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)

Person

hours per

occurrence (B)

Number of

occurrences

per year (C)

Person

hrs. per

respon dent

per year (C=AxB) (D)

Respondents

per year a (E)

Technical

person

hrs. per

year (E=CxD) (F)

Management

person

- hrs.

per year (F=Ex0.05) (G)

Clerical

person

hrs. 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 requirements17

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, Bure au 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

Person

hours

per activity (B)

No. of

occur r ences per plant

per year (C)

EPA

person

hours per plant per

year (C=AxB) (D)

Plants

per

year a (E)

Technical

person

hours per

year (E=CxD) (F)

Management

person

- hours

per year (D=Cx0.05) (G)

Clerical

person

hours 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 to19

this regulation.

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for govern ment 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) 201 4 General Schedule which exclud es locality rates of pay.

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