SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) 

(Renewal), EPA ICR Number 1984.05, OMB Control Number 2060-0552

1(b) Short Characterization/Abstract

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

and Composite Products were proposed on January 9, 2003, promulgated on July 30, 2004, and 

was last amended on October 29, 2007. These regulations apply to both new and existing 

plywood and to composite wood products (PCWP) facilities. Plywood and/or composite 

products are manufactured by bonding wood material (fibers, particles, strands, veneers, etc.) 

or agricultural fiber with resin, generally under head and pressure, to form a structural panel or 

engineered wood product. Plywood and composite products include, but are not limited to: 

plywood; veneer; particleboard; oriented strand board; hardboard; fiberboard; medium density

fiberboard; laminated strand lumber; laminated veneer lumber; wood I-joists; kiln-dried lumber; 

and glue-laminated beams. A PCWP manufacturing facility is a major source of hazardous air 

pollutant (HAP) emissions either in and of itself, or because it is located with other major 

sources of HAP. New facilities include those that commenced construction or reconstruction 

after the date of proposal. This information is being collected to assure compliance with 40 CFR 

part 63, subpart DDDD.

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 in any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

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

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

owner/operator of the plant site).
2

Over the next three years, an average of 228 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these standards. 

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

without any “Terms of Clearance.”

All of the plywood and composite products facilities in the United States are owned and 

operated by the plywood and composite industry (the “Affected Public”). None of the facilities 

in the United States are owned by state, local, tribal or the Federal government. They are all 

privately-owned, for-profit businesses. The “burden” to the “Affected Public” may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Plywood and Composite 

Products (40 CFR Part 63, Subpart DDDD) (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 Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) (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 

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 PCWP manufacturing facilities

which include acetaldehyde, acrolein, formaldehyde, methanol, phenol, and propionaldehyde 

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 DDDD.

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

The recordkeeping and reporting requirements in the standard ensure compliance with 

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

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

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

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

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

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

determine compliance in place of a continuous emission monitor.

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

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

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

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

The performance test may also be observed.

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

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

DDDD.

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 (78 FR 33409) on June 4, 2013. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s 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. 
4

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 EPA's Office of Compliance. OTIS is EPA’s database for 

the collection, maintenance, and retrieval of all compliance data. The growth rate for the 

industry is based on our consultations with the Agency’s internal industry experts. 

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

comment on the burden associated with the standards as they were being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the American Wood Preservers 

Association (AWPA), at (205) 733-4077; and 2) the Hardwood Plywood and Veneer Association 

(HPVA), at (703) 435-2900.

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. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with

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, 
5

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 PCWP facilities. 

The United States Standard Industrial Classification (SIC) code for the respondents affected by 

the standards and the corresponding North American Industry Classification System (NAICS) 

codes are listed in the table below.

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

All Other Miscellaneous Wood Product 

Manufacturing

2421, 2429, 2499, 

3131, 3999 321999

Hardwood Veneer and Plywood Manufacturing 2435 321211

Softwood Veneer and Plywood Manufacturing 2436 321212

Reconstituted Wood Product Manufacturing 2493 321219

Engineered Wood Member (except truss) 

Manufacturing 2439 321213

 

4(b) Information Requested

(i) Data Items

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

Plywood and Composite Products (40 CFR Part 63, Subpart DDDD). 

A source must make the following reports:

Notifications

Initial notification for existing sources 63.9(b)(2), 

63.2280(b)

Notification of performance test 63.7(b)(1), 

63.2280(c)
6

Notifications

Notification of compliance status 63.9(h)(2)(ii), 

63.2280(d)

Request for routine control device maintenance exemption 63.2280(e)

Emissions averaging plan 63.2280(f)

Notification of change of control system, processing unit in your 

emissions averaging plan, monitoring parameter, or value of a 

monitoring parameter

63.2280(g)

Reports

Semiannual compliance report 63.2281(b)

Start-up, shutdown, and malfunction plan 63.10(d)(5)(2)

A source must keep the following records:

Recordkeeping

Documentation supporting any initial notification or notification of 

compliance status

63.10(b)(2)(xiv), 

63.2282(a)(1)

Startup, shutdown, malfunction plan 63.6(e)(3)(iii)-(v), 

63.2282(a)(2) 

Records relating to control device maintenance and documentation of 

routine control device maintenance exemption 63.2282(a)(3)

Records of performance test and performance evaluations 63.10(b)(2)(viii), 

63.2282(a)(4)

Records for each CEMS for emission limitations and records related to 

the work practice requirements

63.10(b)(2)(vi)-(xi),

63.8(d)(3), 

63.8(f)(6)(i),

63.2282(b)-(c)

Records of all information required to calculate emission debits and 

credits 63.2282(d)

Maintain records for 5 years 63.10(b)(1), 

63.2283(d)

Electronic Reporting
7

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site. 

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 20 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Methods 308, 316, 320 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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). 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
8

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

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

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 
9

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 Plywood and 

Composite Products (40 CFR Part 63, Subpart DDDDD) (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. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 11,687 hours (Total Labor Hours from Table 1

shown below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

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

September 2012, “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
10

The type 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 costs are the 

ongoing costs to maintain the monitor(s) 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)

Continuous 

monitoring 

system

$1,880 0 $0 $70 228 $15,960

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

above table. 

The total operation and maintenance (O&M) costs for this ICR are $15,960. 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 $15,960. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions, and the publication and distribution of collected information. 

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

$35,552. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 
11

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 Plywood 

and Composite Products (40 CFR Part 63, Subpart DDDD) (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

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

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 228 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

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1

0 228 0 0 228

2

0 228 0 0 228

3

0 228 0 0 228

Average 0 228 0 0 228

1

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

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

average Number of Respondents over the three year period of this ICR is 228. 

The total number of annual responses per year is calculated using the following table: 
12

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

Notification of 

construction/reconstruction 0 1 0 0

Notification of anticipated 

startup 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of applicability of 

standard 0 1 0 0

Emissions averaging plan 0 1 0 0

Request for routing control 

system maintenance 

exemption

0 1 0 0

Notification of initial 

performance test 0 1 0 0

Notification of compliance 

status with performance test 0 1 0 0

Notification of compliance 

status without performance 

test

0 1 0 0

Initial compliance report with 

no deviations 0 1 0 0

Initial compliance report with 

deviations 0 1 0 0

Initial compliance startup, 

shutdown, malfunction report 0 1 0 0

Initial compliance emissions 

averaging report 0 1 0 0

Semiannual report with no 

deviations 205 2 0 410

Semiannual report with 

deviations 23 2 0 46

Semiannual startup, shutdown, 

malfunction report 23 2 0 46

Semiannual control system 

maintenance report 23 2 0 46

Semiannual emissions 

averaging report 0 0 0 0

Total Number of Annual 

Responses Total 548
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The number of Total Annual Responses is 548.

The total annual labor costs are $1,143,152. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Plywood and 

Composite Products (40 CFR Part 63, Subpart DDDD) (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 11,687 hours at a cost of $1,143,152. Details regarding 

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

NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) (Renewal). 

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

information is estimated to average 21 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. The total 

Operation and Maintenance (O&M) costs to the regulated entity are $15,960. 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 capital/startup costs for this Agency burden and cost over next three 

years is estimated to be 789 labor hours at a cost of $35,552. See below Table 2: Average 

Annual EPA Burden and Cost – NESHAP for Plywood and Composite Products (40 CFR Part 

63, Subpart DDDD) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden from the most recently

approved ICR. This is not due to any program changes. The adjustment increase is the result of 

a labor rate increase and a rounding correction. The previous ICR rounded the number of hours 

required to record continuous parameter information. This ICR uses a more accurate estimate in 

calculating this burden. 

6(g) Burden Statement

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

is estimated to average 21 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 
14

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

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

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

Docket ID Number EPA-HQ-OECA-2013-0341. An electronic version of the public docket is 

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

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

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

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

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

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

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-2013-0341 and OMB Control Number 2060-0552 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart

 DDDD) (Renewal)

Burden Item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person hours 

per year 

(Ex0.1)

(H) 

Total Cost per 

year b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c1 1 1 0 0 0 0 $0 

 B. Required activities N/A

 C. Create information See 3E

 D. Gather existing information See 3E

 E. Write report

 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 

 Notification of anticipated startup 2 1 2 0 0 0 0 $0 

 Notification of actual startup 2 1 2 0 0 0 0 $0 

 Notification of applicability of standard 2 1 2 0 0 0 0 $0 

 Emissions averaging plan d120 1 120 0 0 0 0 $0 

 Request for routine control system maintenance 

exemption e 2 1 2 0

0 0 0 $0 

 Notification of initial performance test f2 1 2 0 0 0 0 $0 

 Notification of compliance status

 With performance test f80 1 80 0 0 0 0 $0 

 Without performance test g120 1 120 0 0 0 0 $0 

 Initial compliance report h

 No deviations i2 1 2 0 0 0 0 $0 

 Deviations i24 1 24 0 0 0 0 $0 

 Startup, shutdown, malfunction report j8 1 8 0 0 0 0 $0 

 Control system maintenance report k 8 1 8 0 0 0 0 $0 

 Emissions averaging report l8 1 8 0 0 0 0 $0 

 Semiannual compliance report h

 No deviations i8 2 16 205 3,280 164 328 $368,949.16 
16

Burden Item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person hours 

per year 

(Ex0.1)

(H) 

Total Cost per 

year b

 Deviation i24 2 48 23 1,104 55.2 110.4 $124,182.89 

 Startup, shutdown, malfunction report i, j 8 2 16 23 368 18.4 36.8 $41,394.30 

 Control system maintenance report k8 2 16 23 368 18.4 36.8 $41,394.30 

 Emissions averaging report l20 1 20 0 0 0 0 $0 

Subtotal for Reporting Requirements 5,888 $575,920.65

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities N/A

 C. Implement activities N/A

 D. Develop record system m40 1 40 0 0 0 0 $0 

 E. Develop startup, shutdown, malfunction plan n100 1 100 0 0 0 0 $0 

 F. Time to enter information

 Records of startup, shutdown, and malfunction 1.5 52 78 0 0 0 0 $0 

 Records of continuous compliance o

 Record parameters/information 0.25 365 91.25 23 2,098.75 104.94 209.88 $236,076.84 

 Compile data 24 2 48 23 1,104 55.2 110.4 $124,182.89 

 Enter/verify information for semiannual reports 16 2 32 23 736 36.8 73.6 $82,788.59 

 Records of control system maintenance See 3E

 Records of emissions averaging credit/debts See 3E

 G. Calibration of CMS p16 1 16 23 368 18.4 36.8 $41,394.30 

 H. Time to train personnel q40 1 40 0 0 0 0 $0 

 I. Time to refresher training for personnel r16 1 16 46 736 36.8 73.6 $82,788.59 

 J. Time for audits N/A

Subtotal for Recordkeeping Requirements 5,799 $567,231.21 

TOTAL LABOR BURDEN AND COST (rounded) 11,687 $1,143,152

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 228. There will be no new additional sources during the next 
17

three years of this ICR.

b

 This ICR uses the following labor rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour for Technical labor, and 

$50.80 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, 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.

c

 We have assumed that there will be no new or reconstructed facilities during the next three years of this ICR.

d

 We have assumed that no existing facilities will choose to use the emission averaging plan because all facilities we assume will install control systems and new 

facilities are not allowed to use emissions averaging.

e

 We have assumed that each respondent will submit a request for routine control device maintenance exemption..

f

 We have assumed that each new facility will comply by conducting performance test(s). The notification of compliance status includes the report of the 

performance test(s).

g We have assumed that only one new facility with softwood veneer dryers will take 120 hours to submit a notification of compliance status without performance 

test(s).

h

 We have assumed that the respondents’ compliance date is in the first half of the year, so respondents will submit one compliance report the first year that they 

start complying with the rule and two compliance reports the following year.

i

 We have assumed that 90 percent of facilities will have no deviation, and 10 percent will have deviation.

j

 We have assumed that 10 percent of respondents will report an action taken during startup, shutdown, malfunction that are not consistent with the SSMP.

k

 We have assumed that 10 percent of the facilities will submit control device maintenance report.

l

 We have assumed that no existing facilities will choose to use the emissions averaging option, and since new facilities are not allowed to use emissions 

averaging, there will be no need to obtain emissions averaging report.

m

 We have assumed that it will take each new respondent 40 hours to develop a record system for recording parameter monitoring information.

n

 We have assumed that it will take 80 hours to draft the startup, shutdown, malfunction plan, and another 20 hours to review/revisions, for a total of 100 hours.

o

 Records of continuous compliance includes, records of CMS data for emission limitations and various records for work practice standards.

p

 We have assumed that calibration of the CMS will require eight hours per year for each monitor, assuming two CMS per facility for a total of 16 hours per year.

q

 We have assumed that it will take 40 hours for each new personnel to be trained.

r

 We have assumed that it will take 16 hours for personnel to complete refresher training and that 20 percent of the personnel will participate (20%x226=46).
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart

DDDD) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(AxB)

(D) 

Plants per 

year 

a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.1)

(H) 

Cost, $ b

1. Report review

 A. Notification of construction/reconstruction c

2 1 2 0 0 0 0

$0 

 B. Notification of anticipated startup c

2 1 2 0 0 0 0

$0 

 C. Notification of actual startup c

2 1 2 0 0 0 0

$0 

 D. Notification of applicability of standard c

2 1 2 0 0 0 0

$0 

 E. Review of emissions averaging plan d

40 1 40 0 0 0 0

$0 

 F. Review of request for routine control system 2 1 2 0 0 0 0$0 

 maintenance exemption e

 G. Notification of initial performance test f

2 1 2 0 0 0 0

$0 

 H. Notification of compliance status

 With performance test g

40 1 40 0 0 0 0

$0 

 Without performance test h

40 1 40 0 0 0 0

$0 

 I. Review of initial compliance report i

 No deviations j

2 1 2 0 0 0 0

$0 

 Deviations j

8 1 8 0 0 0 0

$0 

 Startup, shutdown, malfunction report k

2 2 4 0 0 0 0

$0 

 Control system maintenance report l

2 1 2 0 0 0 0

$0 

 Emissions averaging report d

8 1 8 0 0 0 0

$0 

 J. Review of semiannual compliance report

 No deviations j

2 1 2 205 410 20.5 41 $21,248.05 
19

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(AxB)

(D) 

Plants per 

year 

a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.1)

(H) 

Cost, $ b

 Deviations j

8 1 8 23 184 9.2 18.4 $9,535.71 

 Startup, shutdown, and malfunction reports k

2 1 2 23 46 2.3 4.6 $2,383.93 

 Control system maintenance report l

2 1 2 23 46 2.3 4.6 $2,383.93 

 Emissions averaging report d

8 1 8 0 0 0 0

$0 

TOTAL ANNUAL BURDEN AND COST(rounded) 789 $35,552 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 228. There will be no new additional sources during the next 

three years of this ICR.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 

Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These 

rates are from the Office of Personnel Management (OPM) 2012 General Schedule which excludes locality rates of pay.

c

 We have assumed that there will be no new or reconstructed facilities during the next three years of this ICR.

d

 We have assumed that no existing facilities will choose to use the emission averaging plan because we assume that all facilities will install control systems, and 

new facilities are not allowed to use emissions averaging..

e

 We have assumed that all new facilities will have submitted a request for routine control system maintenance exemption.

f

 We have assumed that it will take each new respondent two hours to review the notification of initial performance test.

g

 We have assumed that all new facilities will conduct an initial performance test(s) and submit a notification of compliance status that includes the report of the 

performance test(s).

h

 We have assumed that one new facility per year with softwood veneer dryers will submit a notification of compliance status without performance test.

i

 We have assumed that the facilities compliance date is in the first half of the year, so facilities will submit one compliance report the first year that they start 

complying with the rule and two compliance reports the years that follow.

j

 We have assumed that 90 percent of facilities will have no deviations, and 10 percent will have deviations

k

 We have assumed that each respondent will report any action taken during a startup, shutdown, or malfunction that are consistent with the SSMP.