SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

(Renewal), EPA ICR Number 1716.09, OMB Control Number 2060-0324.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for 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 on 

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 only additional burden which 

sources will incur from the rule amendments will be that of documenting the information.

The standards apply 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 only 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 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.
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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.

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

affected facility 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 years, an average of 406 existing major sources and 450 existing 

incidental/area sources will be subject to the standard. Of these sources, 150 will use coatings 

containing formaldehyde, and will be subject to the formaldehyde documentation and reporting 

requirements. No new sources are expected to become subject to the standard over the next three 

years.

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

without any “Terms of Clearance.”

The term “Affected Public” applies to owners and operators of wood furniture 

manufacturing facilities, 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 entirely to work performed by

either Federal employees or government contractors, 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 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 
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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 furniture manufacturing 

operations either cause 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 properly 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. These standards rely 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 these standards ensure compliance with 

the applicable regulations which were 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 these standards are used to inform the Agency or delegated 

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

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

installed and functioning properly.

The required quarterly 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 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 (79 FR 30117) on 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 ICR 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 by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS), 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 ICR, 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 as 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 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
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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 with 

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 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 owners and 

operators of wood furniture manufacturing facilities. The United States Standard Industrial 

Classification (SIC) codes and corresponding North American Industry Classification System 

(NAICS) codes for respondents affected by the standard are listed in the following table:

Standard (40 CFR Part 63, Subpart 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 337211
6

Standard (40 CFR Part 63, Subpart 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 by the NESHAP for Wood 

Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ). 

A source must make the following notifications and reports:

Notifications

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 physical or operational change which may increase 

the emission rate.

63.807(a), 63.5(b)(6)

Notification of performance tests (applies only 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 comply 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)

Quarterly 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 system 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 recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities
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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) tests, 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.

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

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring systems). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

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.
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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, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS, which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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

The majority of respondents are large entities (i.e., large businesses). During rule 

development, the Agency conservatively estimated that approximately 9.5 percent of affected 

sources were small entities (i.e., small businesses). Therefore, of the total affected facilities (i.e., 

856), the Agency estimates that approximately 81 are small entities (856 x 9.5% = 81). 

Recent amendments to the rule do not result in any significant adverse impacts on small 

entities since they include minimal 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 be 
10

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.

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 Collection

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

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. 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 reporting requirements is estimated to be 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 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 $128.02 ($60.98 + 110%)

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

The types 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 costs 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 

(several options 

available)

$0 0 $0 $600 41 $24,600

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 ICR, as shown above in column D. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR is estimated to be $24,600.

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 

$366,275.

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%)
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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. 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 ICR, on average over the next three years, approximately 

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 

years. The overall average number of respondents, as shown in the table below, is 856 per year.

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

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

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 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.

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 856. 
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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

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 $6,484,619. 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. 
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(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 average 46 hours 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) ICR added the burden from the 

existing final rule (ICR No. 1716.06) and the rule amendment (ICR 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 ICR, 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 recently 

approved ICR due to the use of updated labor rates. This ICR 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 collection of information 

is estimated to average 46 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, 
15

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-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 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), WJC West, 

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

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

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

number for the 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-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.
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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

per year 

(AxB)

Respondents 

per year a

Technical 

hours

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year 

(Ex0.10)

Total cost

per year

($) b

1. Applications for construction, 

reconstruction, and 

modification 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 

modification) 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 3,602.82
17

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)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year 

(Ex0.10)

Total cost

per year

($) b

Types 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 47,538.7 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 18,696.7 1,830,456

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 66,235 6,484,619

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), $128.02 (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 are 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 rather 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)

Management 

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 

modification 

(physical/operational 

changes) c

2 1 2 41 82 4.1 8.2 4,291.88

C. Review 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 major 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 coatings 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 semiannually 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 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 recording the information.