**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal) , EPA I CR Number 1716.09, OMB Control Number 2060

- 0324. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) f or Wood Furniture Manufacturing Operations ( 40 CFR Part 63, Subpart JJ ) were proposed on December 6, 1994 , and promulgated on December 7, 1995. Amendments to the rule were proposed o n December 21, 2010 and promulgated on November 21, 2011

. The amendments added a requirement for respondents to document the formaldehyde content of their coatings on a monthly basis , and to report those emissions annually

. Reporting of formaldehyde content will coincide with existing reporting requirements; therefore, the onl y additional burden which sources will incur from the rule amendments will be that of documenting the information.
The standard s appl y to both existing and new wood furniture manufacturing operations that are major sources of hazardous air pollutants (HAPs). A “major source” is a stationary source or group of stationary sources that emit or have the potential to emit 10 tons per year (tpy) or more of a HAP or 25 tpy or more of a combination of HAPs. New facilities include those that commenced construction, modification , or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63 , Subpart JJ

. The standard also applies to existing and new incidental and area sources. These sources are onl y required to maintain purchase or usage records demonstrating that they meet the definition for incidental or area sources. Incidental and area sources are not subject to any other provisions of the standard. An “incidental source,” as defined in the standard, is a major source that is primarily

engaged in the manufacture of products other than wood furniture or wood furniture components, and that uses no more than 100 gallons per month of finishing material or adhesives in the manufacture of wood furniture or wood furniture components. An “area source” is any stationary

source that is not a major source.” In general, all NESHAP standards require initi al 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 affecte d facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.2

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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with i ndustry representatives, there is an average of one affected fac ility at each plant site , and each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of 406 existing major sources and 4 50 existing incidental/area sources will be subject to the standard. Of these sources, 1 50 will use coatings containing formaldehyd e, and will be subject to the formaldehyd e documentation and reporting requirements. No new sources are expected to become subject to the standard over the next three ye ars. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

“Terms of Clearance.” The term “Affected Public” applies to owners and operators of wood furniture manufacturing f

acilities, and may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. The “burden ” to the Federal Government is attributed entirel y to work performed b y either F ederal emplo yees or government contractor s , and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. **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 st andards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement o f 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 data3 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 Admini strator may reasonabl y require. In the Administrator's judgment , HAP emissions from wood furniture manufacturing operations either c ause or contribute to air pollution that may reasonably

be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR Part 63 , Subpart JJ. **2(b) Practical Utility/Users of the Data** The control of HAP emissions from wood furniture manufacturing operations require the installation of properl y designed equipment and the operation and maintenance of that equipment. HAP emissions from wood furniture manufacturers are the result of operation of the affected facilities. Th e s e standard s rel y on the reduction of HAPs by the use of compliant or low HAP content coatings, the use of control devices, or some combination of these control technologies. The recordkeeping and reporting requirements in the se standard s ensure compliance with the applicable regulations which w ere 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. The notifications required in the se standard s are use d to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and functioning properly

. The required quarterl y and 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 JJ.4

**3(a) Non** 
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 79 FR 30117 ) o n May 27, 2014

. The Agency

received one public comment in the docket; the commenter opposed any new regulation or rule changes to the NESHAP. This I CR renewal will not result in any regulatory

changes. **3(c) Consultations** Industry experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) , which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or to improve the language in the standard to make it easier to comply

. In developing this I CR, we contacted both the Kitchen Cabinets Manufacturers Association , at 703

- 264

- 1690 , and the American Home Furnishings Alliance , at 336

- 884

- 5000

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal a s well as those submitted in response to the first Federal Register notice. The comment received and our responses may be found in Section 3(b) above. **3(d) Effects of Less Frequent Collection** Less

- frequent information collection would decrease the marg in 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**5

These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 ye ars. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The 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 appropriate level of enforcement acti on. 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 nonexistence of essential records

. **3(f) Confidentiality** Any infor mation 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 owners and operators of wood furniture manufacturing facilities . The United States Standard Industrial Classifi cation (SI C) codes and corresponding North American Industry Classification Sy stem (NAICS) codes for respondents affected b y the standard are listed in the following table : **Standard ( 40 CFR**  **P art 6**  **3 ,**  **S ubpart JJ** **) SIC Codes**  **NAICS Codes** Wood Kitchen Cabinet and Countertop Manufacturing 2434 337110

Household and Institutional Furniture Manufacturing 2511, 2519, and 2599 33712
Wood Office Furniture Manufacturing 2521 3372116

**Standard ( 40 CFR**  **P art 6**  **3 ,**  **S ubpart JJ** **) SIC Codes**  **NAICS Codes** Custom Architectural Woodwork and Millwork Manufacturing 2541 337212

Other Furniture Related Products Manufacturing 2515 337910

All Other Furniture Related Products Manufacturing 2499 321999

**4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ)

. A source must make the following notifications and reports:
**Notification s**  Notification of applicability

. 63. 807(a), 63.9(b ) Notification and application of construction or reconstruction. 63. 807(a), 63.5(d) Notification of anticipated date of initial startup. 63. 807(a), 63.5(b), 63.9(b) Notification of phys ical or operational change which may increase the emission rate. 63.807(a), 63.5(b)(6)
No tification o f performance test s (applies onl y to affected sources using a control device to comply with the rule). 63.807(a), 63

. 7(b) , (c), and (g), 63 .8 (e) , 63.9( e ), 63.10(d)(2) Notification performance test results (applies only to affected sources using a control device to compl y with the rule)

. 63. 807(a), 63.8(e)( 5 ), 63.9(g), 63.10(e)(2) Notification of compliance status. 63.807(b), 63.9(h) Notification of increase of annual VHAP usage. 63.807(e), 63.803(l)(4)
**Reports** Semiannual reports

. 63.807(c) Reports of excess emissions

. 63.807(c)(3) ,7 **Reports** 63.807(d), and 63.10(e) Quarterl y reports

. 63.807(d) A source must keep the following records: **Recordkeeping** Startup, shutdown or malfunctions and corrective action records. 63.806(a), 63.10(b)(2) Work practice standards implementation plan. 63.806(e), 63.10(d)(1) Work practice standards records. 63.806(e), 63.10(b)(2) Records of monitoring s ystem compliance data

. 63. 10 (b)(2), 63.10(c) Startup, shutdown , and malfunction plans and any corrective actions

. 63.806(k)
Records of the types and quantities of finishing material, thinner, contact adhesive, and strippable spray booth coatings and VHAP, VOC, and formaldehyde content. 63.806(b), 63.806(c), 63.806( d), and 63.10(b)(2) Records of monthly

average emission calculations. 63.806( c ), 63.10(b)(3) Records of control efficiency calculations, operating parameters, and semiannual reports. 63.806(f) and (g) Records of compliance certifications and compliance status and semiannual reports. 63.806(h

- j ) Records of applicability

determination/area source status. 63.806(a), 63.10(b)(3) Records of performance test/evaluations

. 63.806(a), 63.10(b)(2) Electronic Reporting 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**8 **Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for the control device. Perform initial performance test, Reference Method 18 (HAP concentration of gaseous air streams); 1 or 1A (sample and velocity traverses); 2, 2A, 2C, or 2D (velocity and volumetric flow rates); 3 (exhaust gases); and 4 (stack gas moisture) test s , 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 sy stems for the purpose of collecting, validating, and veri fying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem s) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equip ment has significantl y reduced the burden associated with monitoring and recordkeeping. **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.9 **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard , and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S , which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** 
The majority

of respondents are large entities (i.e., large businesses)

. During rule development, the Agency conservativel y estimated that approximately 9.5 percent of affected sources were small entities (i.e., small businesses)

. Th erefore, o f the total affected facilities (i.e., 856) , the Agency estimates that approximately 81 are small entities ( 856 x 9.5 % = 8 1)

. Recent amendments to the rule do not result in any significant adverse impacts on small entities since they

include m inimal reporting and recordkeeping requirements related to formaldehyde emissions. The impact on small entities was also 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 be10

the minimum requirements needed to ensure compliance and, therefore, cannot reduce th em 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. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. **6. Estimating the Burden and Cost of the Collec tion**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where 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 rep orting requirement s is estimated to b e 66,235 hours ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with th e NESHAP program , the previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%) Technical $ 10 1

. 05 ($4 8

. 12 + 110%) Clerical $ 5 1

. 37 ($2 4

. 46 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014 , “ Table 2. Civilian w orkers, b y occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increase d by 110 percent to account for the benefit packages available to those employed by private industry

.11 **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe s of industry

costs associated with the information collection activities in the 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 c osts when a facility becomes subject to the regulation. The annual operation and maintenance (O&M) 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)

Control device (s everal options available ) $0 0 $0 $600 41 $ 24,6 00

1 EPA assumes 10% of affected sources will use control devices to comply with the standard (406 x 0.1 = 41, after rounding). There are no total capital/startup costs for this I CR , as shown above in column D. The total operation and maintenance ( O&M) costs for this I CR are $24,600

. 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 IC R is estimated to be $24,600

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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 b e $ 366,275

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )12

These rates are from the Office of Personnel Management (OPM) , 20 1 4 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximatel y 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new sources are expected to become subject to the standard over the next three ye ars. The overall average number of respondents, as shown in the table below, i s 856 per ye ar. The number of respondents is calculated us ing the following table that addresses the three ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports 2 (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 406 450 0 856 2 0 406 450 0 856 3 0 406 450 0 856 Average 0 406 450 0 856 1 New respondents include sources with constructed, reconstructed , and modified affected facilities. 2 Incidental/area sources are only required to maintain purchase or usage records demonstrating that they meet the definition for incidental or area sources. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR i s 856

.13

The total number of annual responses per year is calcul ated 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

Application for construction, reconstruction, and modification 53 1 0 53

Notification of construction/ reconstruction 12 1 0 12

Notification of modification 41 1 0 41 Notification of anticipated startup 53 1 0 53 Notification of actual startup 53 1 0 53 Semiannual compliance status reports 365 2 0 730

Semiannual excess emissions reports 39 2 0 78
Quarterly excess emissions reports 2 4 0 8
Types and quantities of materials used, including VHAP and solids content data 406 1 0 406

Total 1,434 The number of Total Annual Responses is 1,434

. The total annual labor costs are $ 6,484,61 9

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (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 below , respectively , and summarized below.14 **(i) Respondent Tally** The total annual labor hours are 66,235 hours

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to averag e 46 h ours per response . The total annual capital/startup and O&M costs to the regulated entity are $24,600

. 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 8,048 labor hours at a cost of $ 366,275 . See below Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)

. **6(f ) Reasons for Change in Burden**  There is an increase in the total estimated respondent burden as currently identified in the OMB Inventory

of Approved Burdens. The active (previous) IC R added the burden from the existing final rule (ICR No. 1716.06) and the rule amendment (I CR No. 1716.08) , but did not update the number of affected major sources subject to the existing rule to reflect the most recent information received at the time by the Agency

. In this I CR, we have addressed this inconsistency

by updating the burden calculations to reflect the appropriate number of major sources . This correction resulted in the observed increase in respondent burden. There is an increase in the O&M cost as compared to the active (previous) ICR. This increase also is the result of updating calculations to reflect the appropriate number of major sources. There is an increase in respondent and Agency burden costs from the most recentl y approved ICR due to the use of updated labor rates. This I CR references labor rates from the Bureau of Labor Statistics to calculate respondent burden costs and references labor rates from OPM to calculate Agency burden costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this co llection of information is estimated to average 46 hours per response. 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 Federal agency. This includes the time needed to review instructions; develop,15

acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing informati on; adjust the existing way s to compl y 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, EP A has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2014

- 0057 . 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 sy stem , 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), WJC West, Room 3334 , 1301 Constitution Av e., 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket c enter i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 2014

- 0057 and OMB Control Number 2060

- 0324 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.16

**Table 1 : Annual Respondent Burden and Cost** 

**– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63,**  **Subpart JJ) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H**
**Technical person**  **- hours**  **per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per respondent**  **p er year**  **(AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **b** 1. Applications for construction, reconstruction, and mo dification c 4 1 4 53 212 10.6 21.2 23,868.66 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 5 1 5 406 2,030 101.5 203 228,553.64 B. Create information d 2 12 24 150 3,600 180 360 405,316.8 C. Gather existing information See 3D D. Write reports Notification of construction/ reconstruction c 2 1 2 12 24 1.2 2.4 2,702.11 Notification of modification (physical/operational changes)
c 8 1 8 41 328 16.4 32.8 36,928.86 Notification of anticipated startup (including reconstruction and mo dification) c 2 1 2 53 106 5.3 10.6 11,934.33 Notification of actual startup c 2 1 2 53 106 5.3 10.6 11,934.33 Semiannual compliance status reports e 4 2 8 365 2,920 146 292 328,756.96 Semiannual excess emissions reports f 4 2 8 39 312 15.6 31.2 35,127.46 Quarterly excess emissions reports g 4 4 16 2 32 1.6 3.2 3,602.8217

**Burden Item A**  **B C**  **D E**  **F G**  **H**
**Technical person**  **- hours**  **per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per respondent**  **p er year**  **(AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **b** Ty pes and quantities of materials used, including VHAP and solids content data 1.5 52 78 406 31,668 1,583.4 3,166.8 3,565,436.78 **Subtotal for Reporting Requirements 47,53**  **8.7 4,654,163**  4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities N/A C. Implement activities N/A D. Time to enter information Records of operators completing training courses 1 2 2 406 812 40.6 81.2 91,421.46 Records of CMS parameters h 1.5 52 78 41 3,198 159.9 319.8 360,056.42 Records of types and quantities of materials used, including VHAP and solids content data See 3D Records of formaldehyde content See 3B E. Records for incidental and area sources i 1 12 12 450 5,400 270 540 607,975.2 F. Annual personnel refresher course j 8 1 8 856 6,848 342.4 684.8 771,002.62 G. Audits N/A **Subtotal for Recordkeeping Requirements 18,69**  **6.7 1,830,456**  **TOTAL ANNUAL BURDEN AND COST (ROUNDED) 66,235**  **6,484,61 9** 

a EPA estimates 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new major or area sources will become subject over the next 3 years. b This ICR uses the following labor rates: $101.05 (technical), $128.0 2 (managerial), and $51.37 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2. Civilian workers, by occupational and industry group.” The rates ar e from column 1, “Total compensation.” They

have been increased by 110 percent to account for the benefit packages available to those employed by private industry.18

c EPA assumes 3% of sources will apply for reconstruction (406 x 0.03 = 12, after rounding) and 10% will apply for modification (406 x 0.1 = 41, after rounding). d EPA estimates 150 major sources will use coatings containing formaldehyde. These sources will be required to record the formaldehyde content of their coatings on a monthly basis. Reporting of formaldehyde content will occur on an annual basis and will coincide with existing reporting requirements. Therefore, the only burden incurred by sources will be that of documenting the information.
e EPA assumes 90% of sources will comply by using compliant coatings or by using the HAP averaging approach (406 x 0.9 = 365, after rounding ). f EPA assumes 10% of sources will comply by using control devices. However, only 95% are assumed to be in compliance at any given time, and would be required to submit reports semiannually r ather than quarterly. Therefore, the number of affected sources submitting semiannual reports is 39 (406 x 0.1 x 0.95 = 39, after rounding). g EPA assumes 2 sources will submit quarterly reports (406 x 0.1 x (1

- 0.095) = 2, after rounding). h EPA assumes 10% of affected sources will use control devices to comply with the standard (406 x 0.1 = 41, after rounding). i EPA assumes 450 affected incidental/area sources per year will record information once per month. j EPA assumes all affected sources will participate in the annual personnel refresher course once per year.19

**Table 2 : Average Annual EPA Burden and Cost** 

**– NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63,**  **Subpart JJ) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total**  **cost**

**per year ($)**  **b**
1. Excess emissions enforcement activities N/A 2. Report review A. Review notification of construction/ reconstruction c 2 1 2 12 24 1.2 2.4 1,256.16 B. Review notification of mo dification (physical/operational changes) c 2 1 2 41 82 4.1 8.2 4,291.88
C. Revie w semiannual compliance status reports and certifications d 8 2 16 365 5,840 292 584 305,665.6 D. Review semiannual excess emission reports e 8 2 16 39 624 31.2 62.4 32,660.16 E. Review quarterly excess emission reports f 16 4 64 2 128 6.4 12.8 6,699.52 F. Review annual records of formaldehyde content g 2 1 2 150 300 15 30 15,702 **TOTAL ANNUAL BURDEN AND COST (ROUNDED) 8,048**  **366,275**

a EPA estimates 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new ma jor or area sources will become subject over the next 3 years. b This ICR uses the following labor rates: $46.67 (technical), $62. 90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. c EPA assumes 3% of sources will apply for reconstruction (406 x 0.03 = 12, after rounding) and 10% will apply for modification (406 x 0.1 = 41, after rounding).20

d EPA assumes 90% of sources will comply by using compliant coating s or by using the HAP averaging approach (406 x 0.9 = 365, after rounding ). e EPA assumes 10% of sources will comply by using control devices. However, only 95% are assumed to be in compliance at any given time, and would be required to submit reports s emiannually rather than quarterly. Therefore, the number of affected sources submitting semiannual reports is 39 (406 x 0.1 x 0.95 = 39, after rounding). f EPA assumes 2 sources will submit quarterly reports (406 x 0.1 x (1

- 0.095) = 2, after rounding). g EPA estimates 150 major sources will use coatings containing formaldehyde. These sources will be required to record the f ormaldehyde content of their coatings on a monthly basis. Reporting of formaldehyde content will occur on an annual basis and wil l coincide with existing reporting requirements. Therefore, the only burden incurred by sources will be that of recording the information.