STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
1952.02
INFORMATION
COLLECTION
REQUEST
FOR
THE
METAL
FURNITURE
SURFACE
COATING
OPERATIONS
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
January,
2003
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection.

A
supporting
statement
was
prepared
for
"
Recordkeeping
and
Reporting
Requirements
for
the
Information
Collection
Request
(
ICR)
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Metal
Furniture
Surface
Coating
Operations
Source
Category."
This
is
a
new
information
collection
request
and
the
tracking
number
is
EPA
ICR
No.
1952.02.

1(
b)
Short
Characterization.

This
ICR
was
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
rulemaking
amends
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
subpart
RRRR
­­
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP):
Metal
Furniture
Surface
Coating
Operations
(
hereafter,
this
subpart
is
referred
to
as
the
"
metal
furniture
NESHAP").
The
metal
furniture
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAPs).

Respondents
are
owners
or
operators
of
source
category
affected
sources
regulated
under
the
metal
furniture
NESHAP.

This
ICR
is
for
HAP
emission
sources
in
the
metal
furniture
surface
coating
operations
source
category
subject
to
the
monitoring,
recordkeeping,
and
reporting
(
MRR)
requirements
of
the
metal
furniture
NESHAP.
The
metal
furniture
surface
coating
operations
source
category
consists
of
an
estimated
3,002
existing
nationwide
facilities.
Six
hundred
fifty­
five
of
these
facilities
were
considered
to
be
potential
major
sources
and
may
be
subject
to
the
major
source
provisions
specified
under
the
metal
furniture
NESHAP.
An
estimated
2,347
facilities
are
not
major
sources
and
will
not
be
subject
to
the
major
source
provisions
specified
under
the
metal
furniture
NESHAP.
Of
the
655
potential
major
sources,
12
percent
(
79
facilities)
are
expected
to
become
synthetic
minor
sources
based
on
information
obtained
from
industry
survey
responses.

Thus,
the
number
of
existing
major
sources
used
for
estimating
MRR
costs
was
576.

All
new
sources
are
expected
to
reduce
emissions
to
below
major
source
levels.
As
such,

these
new
sources
will
be
area
sources
which
will
not
be
subject
to
the
rule.
No
costs
will
be
2
incurred
by
new
facilities
for
compliance
activities,
although
a
small
cost
has
been
assigned
for
each
new
source
to
initially
read
the
rule.

All
existing
major
sources
must
be
in
compliance
with
the
requirements
of
the
metal
furniture
NESHAP
within
three
years
of
the
effective
date
(
promulgation
date)
of
the
standard.

The
ICR
was
developed
on
the
basis
that
large
facilities
(
estimated
to
be
132
facilities)
will
begin
preparations
for
complying
with
the
NESHAP
in
the
second
year
after
promulgation.
These
activities
will
continue
in
the
third
year
after
promulgation.
Small
and
medium
facilities
(
estimated
to
be
444
facilities)
will
all
begin
preparations
for
compliance
in
the
third
year
after
promulgation.
All
facilities
will
begin
compliance
activities
(
e.
g.,
recordkeeping,
monthly
compliance
calculations,
and
semiannual
reports)
at
the
beginning
of
the
fourth
year
after
compliance.
The
costs
for
the
first
three­
year
period
after
promulgation
of
the
NESHAP
are
detailed
in
Attachment
1
and
discussed
throughout
this
document.
The
costs
for
the
second
three­
year
period
after
promulgation
are
detailed
in
Attachment
2
for
informational
purposes,
but
are
not
discussed
further
in
this
document.

All
new
sources
must
be
in
compliance
with
the
requirements
of
the
metal
furniture
NESHAP
no
later
than
the
effective
date
if
startup
of
your
affected
source
is
before
the
effective
date
of
this
subpart.
If
startup
of
your
affected
source
is
after
the
effective
date
of
this
subpart,

you
must
be
in
compliance
with
the
requirements
of
the
metal
furniture
NESHAP
upon
initial
startup
of
your
affected
source.

This
ICR
included
576
existing
metal
furniture
surface
coating
facilities
that
we
anticipate
will
conduct
all
MRR
requirements,
including
testing
activities.
MRR
costs
per
facility
to
conduct
all
MRR
activities
were
estimated
to
be
$
15,130
over
the
three­
year
period
following
promulgation
of
the
rule.
This
gives
an
annual
average
MRR
cost
per
facility
to
conduct
all
MRR
activities
of
$
5,043.
The
nationwide
average
MRR
cost
per
year
over
the
three
year
implementation
period
for
the
576
existing
major
sources
was
estimated
to
be
$
2,904,969.
The
2,426
facilities
that
are
not
major
sources
and
will
not
be
subject
to
the
major
source
provisions
would
only
read
the
rule.
The
estimated
costs
for
this
one
activity
was
$
293
per
facility.
The
total
estimated
costs
for
non­
major
sources
to
read
the
rule
was
$
709,809.
This
gives
total
MRR
3
costs
of
$
8,714,907
for
existing
sources
under
the
metal
furniture
surface
coating
source
category
during
the
first
three
years
after
promulgation
of
a
NESHAP
for
this
source
category.

This
ICR
assumed
no
new
metal
furniture
surface
coating
facilities
that
will
be
major
sources
subject
to
the
rule
will
be
constructed
during
the
three­
year
period
following
promulgation
of
the
rule.
New
sources
must
conduct
all
MRR
requirements,
including
testing
activities,
recordkeeping,
monthly
compliance
calculations,
and
semiannual
reporting,
upon
startup.
MRR
costs
per
facility
to
conduct
all
MRR
activities
were
estimated
to
be
$
0
over
the
three­
year
period
following
promulgation
of
the
rule.
This
gives
total
MRR
costs
of
$
0
for
new
sources
under
the
metal
furniture
surface
coating
source
category
during
the
first
three
years
after
promulgation
of
a
NESHAP
for
this
source
category.
See
section
6
for
more
details.

2.
Need
For
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection.

We
have
been
directed
by
section
112
of
the
CAA
to
regulate
the
emission
of
HAPs
from
stationary
sources.
The
metal
furniture
surface
coating
source
category
contains
major
sources
of
HAP
emissions
and
is
included
on
our
list
of
categories
scheduled
for
regulation.

Section
114
of
the
CAA
gives
us
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
(
1)
identify
existing
and
new
sources
subject
to
the
metal
furniture
NESHAP
and
(
2)
ensure
that
the
requirements
specified
for
an
affected
source
subject
to
the
metal
furniture
NESHAP,
which
are
based
on
MACT,
are
being
achieved.

2(
b)
Use/
Users
of
the
Data.

The
information
will
be
used
by
our
enforcement
personnel
to
(
1)
identify
existing
and
new
affected
sources
subject
to
the
metal
furniture
NESHAP,
(
2)
identify
the
emission
control
devices
and
methodologies
(
i.
e.,
add­
on
control
devices,
product
substitution
and/
or
reformulation)
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Records
and
reports
are
necessary
to
enable
us
to
identify
facilities
subject
to
the
metal
furniture
NESHAP
that
may
not
be
in
compliance.
Based
on
reported
information,
we
can
decide
whether
to
inspect
a
facility
and
which
records
or
processes
to
inspect.
The
records
that
facilities
4
maintain
must
indicate
to
us
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
methodologies
properly.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication.

A
search
of
our
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts
with
the
exception
of
the
New
Source
Performance
Standards
(
NSPS)
for
the
Surface
Coating
of
Metal
Furniture
(
40
CFR
part
60,
subpart
EE).
The
NSPS
and
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standard
(
e.
g.,
records
of
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
in
lieu
of,
or
as
a
part
of,
the
report
required
by
the
standards.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.

Since
this
is
a
rule­
related
ICR,
it
is
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
ICR
to
OMB.
However,
a
public
review
and
comment
period
occurred
after
proposal
of
the
metal
furniture
NESHAP
in
the
Federal
Register.

3(
c)
Consultations.

The
ICR
handbook
states
that
OMB
regulations
require
periodic
consultation
with
respondents
and
data
users
such
as
members
of
industry
and
State
and
local
governments.

Consultations
with
numerous
representatives
of
companies
and
government
agencies
involved
with
metal
furniture
surface
coating
operations
were
conducted
throughout
the
NESHAP
development
process.
Table
1
presents
a
list
of
the
names,
affiliations,
and
telephone
numbers
of
persons
that
were
consulted
during
the
rule
development.

TABLE
1.
METAL
FURNITURE
SURFACE
COATING
OPERATIONS
CONSULTATIONS
NAME
AFFILIATION
TELEPHONE
NUMBER
Gary
Woodward
A&
J
Manufacturing
Company
(
714)
773­
0823
NAME
AFFILIATION
TELEPHONE
NUMBER
5
Christy
Myers
Alabama
DEM
­
Air
Division
(
334)
271­
7861
Ken
Barrett
Alabama
DEM
­
Air
Division
(
334)
271­
7870
Jeffery
Masi
Allsteel,
Inc.
(
901)
686­
4116
Andy
Counts
American
Furniture
Manufacturers
Association
(
336)
884­
5000
Michael
McMullen
American
Seating
Company
(
616)
732­
6650
Jeff
Lisenbe
Arco
Bell
(
254)
773­
1776
Herbert
Ueno
Atlas
Spring
Manufacturing
Corporation
(
310)
660­
0150
Walt
Hammond
Bassett
Furniture
(
910)
476­
2263
Dan
Belik
Bay
Area
AQMD
(
415)
749­
4786
Brad
Miller
BIFMA
International
(
616)
285­
3963
Terry
Knight
B­
Line
Systems
(
618)
654­
2184
Jo
Spiceland
Charleston
Forge
(
828)
264­
0100
Thomas
Ashley
Charleston
Forge
(
828)
264­
0100
Bob
Colby
Chattanooga/
Hamilton
County
Air
Pollution
Control
Bureau
(
423)
867­
4321
Chuck
Millisor
Collier­
Keyworth,
Incorporated
(
336)
622­
0120
Charles
Wagner
Cramer
Incorporated
(
913)
621­
6700
Steven
Varon
Crown
Metal
Manufacturing
Company
(
630)
279­
9800
Steve
Byrne
Cytec
(
973)
425­
8406
Andy
Stickler
Darling
Store
Fixtures
(
870)
239­
9564
Doug
Kuzmicki
Davies
Office
Refurbishing,
Inc.
(
518)
449­
2040
Barry
Pinchcofsky
Dehler
Manufacturing
Company,
Inc.
(
773)
637­
1666
Mitchel
Thompson
Dental
Ez
Group
(
334)
937­
6781
Romell
Jackson
Duro
Metal
Manufacturing
(
214)
391­
3181
David
Haas
Est
Division
of
Leggett
Partners,
L.
P.
(
414)
377­
3270
Venkata
Panchakarla
Florida
Department
of
Environmental
Protection
(
850)
488­
0114
Jimmy
Johnson
Georgia
Department
of
Natural
Resources,
Air
Protection
Branch
(
404)
363­
7127
Dennis
Kane
Harris
Hub,
A
Division
of
Dresher
Inc.
(
717)
843­
6288
Fred
Gordon
Herman
Miller,
Inc.
(
616)
654­
3604
David
McNeil
Hickory
Springs
Manufacturing
Co.
(
828)
328­
2201,
ext.
4669
Albert
Kula
High
Point
Sleeper
(
336)
889­
4998
Scott
Lesnet
HON
Industries
(
319)
262­
7865
Hank
Naour
Illinois
EPA,
Bureau
of
Air
(
217)
785­
1716
Doug
Wagner
Indiana
DEM,
Office
of
Air
Management
(
317)
232­
0286
Somnath
Dasgupta
Iowa
Waste
Reduction
Center
NAME
AFFILIATION
TELEPHONE
NUMBER
6
Steve
Foster
Johnston
Casuals
(
336)
838­
5178
John
Ramsey
Kansas
Department
of
Health
and
Environment
(
913)
296­
1593
Stanley
Schmitt
Kimball
INT­
FTSG
(
812)
634­
3274
Keith
Masterson
Kimball
International
(
812)
634­
3234
Bob
Wood
Lexington
Furniture
Industries
(
336)
249­
5316
Theresa
Block
Leggett
&
Platt,
Incorporated
(
417)
358­
8131
Ronald
Westgate
Lightolier
Fall
River
(
508)
646­
3341
Sherry
Stookey
Lilly
Industries
(
336)
802­
4305
William
Mather
Lithonia
Lighting;
National
Services
Industries,
Inc.
(
770)
922­
9000,
ext.
2842
Michael
Jones
Lozier
Corporation
(
402)
457­
8497
Greg
Olsen
Lozier
Corporation
(
402)
457­
8433
Richard
Mathis
Metal
Creations
(
336)
889­
2083
Cindy
Eisfelder
Michigan
DEQ
­
Air
Quality
Division
(
517)
241­
7461
Sidney
Lefkovitz
Mid­
West
Chandelier
Co.
(
913)
281­
1100
Richard
Wales
Mojave
Desert
­
Antelope
Valley
AQMD
(
760)
245­
1661
Frank
St.
Clair
Mojave
Desert
AQMD
(
760)
245­
1661,
ext.
6101
Karen
Doodeman
National
Association
of
Store
Fixture
Manufacturers
(
954)
424­
1443
Clyde
Blaco
National
Association
of
Store
Fixture
Manufacturers
(
954)
893­
7300,
ext.
27
Wayne
Vangness
National
Metal
Industries
(
413)
785­
5861
Robert
Nelson
National
Paint
and
Coatings
Association
(
202)
462­
6272
Robert
Nevin
Nevin
Laboratories,
Inc.
(
773)
624­
4330
Robert
Hodanbosi
Ohio
EPA,
Division
of
Air
Pollution
Control
(
614)
644­
2270
Bernard
Zysman
Oxychem
(
716)
278­
7894
Edwin
Brennan
PENCO
Products,
Inc.;
Vesper
Corporation
(
610)
666­
0500
Susan
Hoyle
Pennsylvania
Bureau
of
Air
Quality
(
717)
787­
9257
Todd
Nishikawa
Placer
County
APCD
(
530)
386­
7027
Dave
Mazzocco
PPG
Industries,
Inc.
(
412)
492­
5476
Viji
Sadasivan
Professional
Refinishing
Organization
(
949)
756­
3160
Bob
Eshbach
Republic
Storage
Systems
Company,
Inc.
(
330)
438­
5800,
ext.
2409
Quentin
Baker
Royal
Development
Company
(
336)
889­
2569
Terry
Cole
Royal
Development
Company
(
336)
889­
2569
Jorge
Deguzman
Sacramento
Metropolitan
APCD
(
916)
386­
7027
Lee
Huo
San
Joaquin
Valley
Unified
APCD
(
209)
497­
1075
Diane
Luo
Siemens
Medical
System,
Inc.;
Pelton
and
Crane
Group
(
704)
587­
7294
John
Pawlow
Small
Business
Association
(
202)
205­
6951
NAME
AFFILIATION
TELEPHONE
NUMBER
7
Fred
Lettice
South
Coast
AQMD
(
909)
396­
2576
Mick
Durham
Stanley
Environmental,
Incorporated
(
319)
264­
6342
Darrin
Sculley
Steelcase,
Incorporated
(
616)
247­
2050
John
Patten
Tennessee
Department
of
Environmental
Conservation
(
615)
532­
0554
Ken
Gabele
The
Sherwin­
Williams
Company
(
216)
566­
3316
Stan
Cowen
Ventura
County
Air
Pollution
Control
District
(
805)
645­
1408
Arthur
Kaplan
Venture
Lighting
International,
Inc.
(
440)
248­
0600
Ferrell
Van
Raalten
Virco
Manufacturing
Corporation
(
310)
533­
0474,
ext.
315
Bob
Maindelle
Wilsonart
International
Jon
Heinrich
Wisconsin
DNR,
Bureau
of
Air
Management
(
608)
267­
7547
3(
d)
Effects
of
Less
Frequent
Collection.

If
the
requirement
to
submit
compliance
demonstrations
of
relevant
information
were
collected
less
frequently,
we
would
not
be
reasonably
assured
that
a
source
is
in
compliance
with
the
NESHAP.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.

Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
we
and
the
regulated
community
benefit
from
preservation
of
our
administrative
powers.

3(
e)
General
Guidelines.

The
metal
furniture
NESHAP
requires
owners
or
operators
of
an
affected
source
to
retain
records
for
five
years,
which
exceeds
the
three­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
five­
year
retention
period
is
consistent
with
the
provisions
of
the
General
Provisions
of
40
CFR
part
63,
subpart
A,
and
the
retention
requirement
in
the
operating
permit
program
under
title
V
of
the
CAA.
All
subsequent
general
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.
8
3(
f)
Confidentiality.

All
information
submitted
to
us
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
our
policies
set
forth
in
title
40,
chapter
1,
part
2,
subpart
B,

Confidentiality
of
Business
Information.
See
41
FR
36902,
September
1,
1976;
amended
by
43
FR
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,

March
23,
1979.
Even
where
we
have
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
part
2,
subpart
B,
we
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
7414
(
C);

40
CFR
2.301
(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
(
OMB)
Circular
108.

3(
g)
Sensitive
Questions.

Information
that
will
be
reported
consists
of
emissions
data
and
other
information
that
are
not
expected
to
be
of
a
sensitive
nature.
Therefore,
this
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes.

Respondents
are
owners
or
operators
of
all
existing
and
new
HAP­
emitting
affected
sources
in
the
metal
furniture
surface
coating
source
category.
The
source
category
and
affected
sources
regulated
by
the
metal
furniture
NESHAP
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
codes
for
metal
furniture
manufacturing
and
the
North
American
Industrial
Classification
System
(
NAICS)
codes
for
metal
furniture
manufacturing
listed
in
Table
2
below.

TABLE
2.
METAL
FURNITURE
PRODUCT
DESCRIPTIONS
AND
CORRESPONDING
SIC
AND
NAICS
CODES
9
Product
Description
1987
SIC
Code
Equivalent
1997
NAICS
Code(
s)
Equivalent
1997
NAICS
Product
Description
Metal
Household
Furniture
2514
337124
Metal
Household
Furniture
Manufacturing
Office
Furniture,
Except
Wood
2522
337214
Nonwood
Office
Furniture
Manufacturing
Public
Building
and
Related
Furniture
2531
337127
Institutional
Furniture
Manufacturing
Office
and
Store
Fixtures,
Partitions,
Shelving,
and
Lockers,
Except
Wood
2542
337215
Showcase,
Partition,
Shelving,
and
Locker
Manufacturing
Furniture
and
Fixtures,
Not
Elsewhere
Classified
2599
337127
Institutional
Furniture
Manufacturing
Hardware,
Not
Elsewhere
Classified
3429
332951
Hardware
Manufacturing
Metal
Stampings,
Not
Elsewhere
Classified
3469
332116
Metal
Stamping
Wire
Springs
3495
332612
Wire
Spring
Manufacturing
Fabricated
Metal
Products,
Not
Elsewhere
Classified
3499
337215
Showcase,
Partition,
Shelving,
and
Locker
Manufacturing
Residential
Electric
Lighting
Fixtures
3645
335121
Residential
Electric
Lighting
Fixture
Manufacturing
Commercial,
Industrial,
and
Institutional
Electric
Lighting
Fixtures
3646
335122
Commercial,
Industrial,
and
Institutional
Electric
Lighting
Fixture
Manufacturing
Laboratory
Apparatus
and
Furniture
3821
339111
Laboratory
Furniture
Manufacturing
Dental
Equipment
and
Supplies
3843
339114
Dental
Equipment
Manufacturing
Manufacturing
Industries,
Not
Elsewhere
Classified
3999
337127
Institutional
Furniture
Manufacturing
Product
Description
1987
SIC
Code
Equivalent
1997
NAICS
Code(
s)
Equivalent
1997
NAICS
Product
Description
10
Reupholstery
and
Furniture
Repair
7641
81142
Reupholstery
and
Furniture
Repair
4(
b)
Information
Requested.

The
metal
furniture
NESHAP
allows
the
use
of
product
substitution
and
reformulation
as
well
as
add­
on
control
devices
to
comply
with
the
standards.
Based
on
information
obtained
from
the
industry,
we
expect
that
nearly
all
existing
facilities
will
use
product
substitution
and
reformulation
to
comply
with
the
standards.
Consequently,
the
burden
and
cost
estimates
presented
below
were
based
on
all
facilities
using
product
substitution
and
reformulation.
No
burden
or
cost
was
estimated
for
the
use
of
add­
on
control
devices
for
existing
sources.

4(
b)(
i)
Data
items,
including
recordkeeping
requirements.

Respondents
will
be
required
to
submit
one­
time
reports
for
the
(
1)
initial
notification,
(
2)

initial
compliance
demonstration,
(
3)
start
of
construction
for
new
facilities,
(
4)
anticipated
and
actual
start­
up
dates
for
new
facilities,
and
(
5)
physical
or
operational
changes
to
existing
facilities.

An
affected
source
with
an
initial
startup
date
before
the
effective
date
of
the
standards
must
submit
a
one­
time
initial
notification.
This
initial
notification
would
have
to
be
submitted
within
120
days
after
the
promulgation
date
of
the
standards.
An
affected
source
with
an
initial
startup
date
on
or
after
the
promulgation
date
of
the
standards
will
have
to
submit
the
initial
notification
within
120
days
after
becoming
subject
to
the
standards.

If
you
are
required
to
conduct
a
performance
test,
the
notification
of
compliance
status
must
be
submitted
60
calendar
days
following
completion
by
the
source
of
the
performance
test
specified
in
the
rule.
For
each
initial
compliance
demonstration
that
does
not
include
a
performance
test,
the
notification
of
compliance
status
must
be
submitted
30
calendar
days
following
completion
of
the
initial
compliance
demonstration.

Affected
facilities
using
add­
on
controls
must
conduct
an
initial
performance
test
and
report
results
back
to
EPA.
Performance
test
results
(
as
applicable)
must
be
included
as
part
of
11
the
initial
compliance
status
report.
These
facilities
must
also
submit
a
startup,
shutdown,
and
malfunction
(
SSM)
plan
for
their
capture
and
control
systems.

For
sources
constructed
or
reconstructed
after
the
effective
date
of
the
relevant
standard,

the
General
Provisions
of
40
CFR
part
63
require
that
the
source
submit
an
application
for
approval
of
construction
or
reconstruction.
The
application
is
required
to
contain
information
on
the
air
pollution
control
system
(
equipment
or
method)
that
will
be
used
for
each
potential
HAP
emission
point.

The
information
in
the
initial
notification
and
the
application
for
construction
or
reconstruction
will
enable
enforcement
personnel
to
identify
the
number
of
sources
subject
to,
or
are
already
in
compliance
with,
the
standards.

Affected
sources
subject
to
standards
under
the
metal
furniture
NESHAP
must
submit
a
semiannual
notification
of
compliance
status.
Each
subsequent
compliance
report
must
cover
the
semiannual
reporting
period
from
January
1
through
June
30
or
the
semiannual
reporting
period
from
July
1
through
December
31.
This
notification
must
be
signed
by
a
responsible
company
official
who
certifies
its
accuracy
and
that
the
affected
source
has
complied
with
the
relevant
standards.
The
notification
of
compliance
status
must
be
submitted
no
later
than
the
end
of
the
next
month
following
the
semiannual
reporting
period.

In
addition,
affected
sources
subject
to
the
metal
furniture
NESHAP
are
required
to
maintain
records
of
the
following
for
each
monthly
compliance
period
(
including
all
data,

calculations,
test
results,
and
other
supporting
information),
as
appropriate:
1)
name,

manufacturer
or
supplier,
volume
used,
mass
fraction
of
organic
HAP,
and
density
for
each
coating,
thinner,
and
cleaning
material,
2)
volume
fraction
solids
for
each
coating,
3)
total
mass
of
organic
HAPs
in
all
coatings,
thinners,
and
cleaning
materials
used,
4)
total
volume
solids
used
for
each
coating,
5)
total
mass
organic
HAPs
in
waste
material
shipped
off
site
for
treatment
or
disposal
(
only
when
a
facility
seeks
to
reduce
its
emissions
by
taking
credit
for
organic
HAP
in
the
waste
material),
6)
each
monthly
calculation
for
the
affected­
source
wide
emission
rate,
and
7)
all
parameter
monitoring
data
for
capture
and
control
systems.
Any
deviations
must
be
reported
in
the
semiannual
compliance
report.
12
The
General
Provisions
require
owners
or
operators
of
affected
sources
to
develop
SSM
plans,
which
document
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
SSM
reports
detailing
the
actions
taken
by
an
owner
or
operator
in
the
event
of
a
SSM
are
required
to
be
submitted.
Reports
are
required
semiannually
when
actions
taken
are
consistent
with
the
plan.

Immediate
reports
are
required
when
actions
taken
are
inconsistent
with
the
plan.

4(
b)(
ii)
Respondent
activities.

The
respondent
activities
that
are
required
by
the
metal
furniture
NESHAP
in
the
first
three
years
after
promulgation
for
existing
major
sources
are
presented
in
Tables
3a
through
3c.

The
respondent
activities
that
are
required
by
the
metal
furniture
NESHAP
for
new
major
sources
during
this
period
are
presented
in
Tables
3d
through
3f.
The
annual
burden
estimate
for
new
major
sources
is
based
on
the
assumption
that
there
will
be
no
new
sources
that
are
major
sources
subject
to
the
metal
furniture
NESHAP
in
the
first
three
years
after
promulgation.

The
labor
hours
associated
with
and
costs
of
MRR
activities
for
existing
and
new
sources
are
summarized
in
Table
4.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities.

A
list
of
our
activities
is
provided
in
Tables
5a
through
5f.
Table
6
summarizes
the
estimated
labor
hours
and
costs
for
us.
These
tables
are
introduced
in
Section
6(
c)
of
this
ICR.

5(
b)
Collection
Methodology
and
Information
Management.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
our
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

5(
c)
Small
Entity
Flexibility.

Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
our
part.
We
have
reduced
the
recordkeeping
and
reporting
requirement
respondent
13
burden
to
include
only
the
information
needed
by
us
to
determine
compliance
with
the
metal
furniture
NESHAP.
The
metal
furniture
NESHAP
is
applicable
to
only
major
sources.

By
definition,
a
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
For
the
SIC
codes
that
define
the
metal
furniture
surface
coating
operations
category,
the
small
business
threshold
ranged
from
100
to
1,000
employees,
or
less
than
$
3.5
million
in
annual
sales.

Based
on
available
information
from
industry
survey
respondents,
10
companies
(
42
percent
of
the
total
number
of
respondents
for
which
complete
information
was
available)
were
identified
as
small
businesses
for
the
metal
furniture
surface
coating
category,
the
remaining
14
being
large
(
58
percent).
In
addition,
based
on
the
available
information
on
the
operations
of
the
facilities
managed
by
these
small
businesses
and
estimated
HAP
emissions,
we
anticipate
that
some
of
the
facilities
that
are
operated
by
these
small
businesses
are
likely
to
be
major
sources
with
respect
to
total
facility
HAP
emissions.

5(
d)
Collection
Schedule.

The
metal
furniture
NESHAP
is
scheduled
for
promulgation
in
the
Federal
Register
in
February
2003.
Collection
of
data
will
begin
after
promulgation
of
the
standards.
The
schedule
for
reports
that
will
be
required
by
the
metal
furniture
NESHAP
is
summarized
below.

Major
sources
using
add­
on
control
devices
would
be
required
to
submit
periodic
excess
emissions
summary
reports
with
their
semiannual
compliance
report.
Major
sources
would
have
to
submit
SSM
reports
semiannually
when
actions
taken
in
the
event
of
a
SSM
are
consistent
with
the
source's
SSM
plan.
If
actions
taken
are
not
consistent
with
the
source's
plan,
an
immediate
report
would
have
to
be
submitted.

6.
Estimating
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden.

The
existing
major
source
annual
burden
estimates
for
recordkeeping
and
reporting
for
the
first
three
years
after
promulgation
are
presented
in
Tables
3a
through
3c
for
metal
furniture
surface
coating
operations.
The
new
major
source
annual
burden
estimates
for
recordkeeping
and
reporting
for
this
period
are
presented
in
Tables
3d
through
3f.
14
The
estimates
of
annual
total
technical
labor
hours
per
source
and
the
annual
number
of
activities
per
respondent
listed
in
each
table
are
based
upon
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts
and
the
number
of
emission
points
in
each
source.
Activities
that
are
one­
time
only
activities
are
noted
in
the
tables.

6(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
first
three
years
for
existing
and
new
affected
sources
subject
to
the
Metal
Furniture
NESHAP
are
presented
in
Tables
3a
through
3f.
The
costs
of
these
activities
were
based
on
data
from
U.
S.
Bureau
of
Labor
Statistics
(
BLS)
Internet
web
site
(
http://
www.
bls.
gov/
news.
release/
ecec.
toc.
htm
Table
12)
accessed
November
11,
2002.
BLS
labor
rates
were
increased
by
a
factor
of
1.67
to
more
accurately
reflect
the
actual
labor
rates
of
the
industry.
Labor
costs
were
divided
into
the
following
three
categories
(
1)
technical,

(
2)
managerial,
and
(
3)
clerical.
Managerial
and
clerical
labor
hours
were
calculated
as
5
and
10
percent,
respectively,
of
each
technical
labor
hour
requirement.
We
estimated
the
cost
of
labor
to
be
$
67
per
hour
for
technical
labor,
$
70/
hr
for
managerial
labor,
and
$
28/
hr
for
clerical
labor.

These
estimates
included
fringe
benefits.
All
costs
are
in
Second
Quarter
2002
dollars.

Facilities
achieving
compliance
through
the
use
of
add­
on
control
devices
will
be
required
to
perform
parametric
monitoring.
The
devices
required
for
parametric
monitoring
(
e.
g.,

temperature
monitors)
are
included
with
the
capital
costs
of
the
control
device
and
are
therefore
not
associated
the
MRR
activities
required
to
comply
with
the
metal
furniture
NESHAP.
In
addition,
the
rule
does
not
require
continuous
emissions
monitoring,
nor
electronic
data
submittal.

For
these
reasons,
no
capital
costs
are
associated
with
MRR
activities.

6(
c)
Estimating
the
EPA's
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
metal
furniture
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.

Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
AFS
operated
and
15
maintained
by
our
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
affected
sources.
Periodic
inspections
are
part
of
our
overall
compliance
and
enforcement
program.
Therefore,
these
examinations
are
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information.
Labor
rates
and
associated
costs
were
based
on
the
1999
General
Schedule
(
GS)
base
annual
salary
data
from
the
office
of
Personnel
Management
Internet
web
site
(
http://
www.
opm.
gov/
oca/
02tables/
gs.
htm),
accessed
November
11,
2002.
We
used
an
hourly
labor
cost
of
$
71
for
managerial
staff
(
GS
15,
step
3),
$
41
for
technical
staff
(
GS
12
step
3),
and
$
22
for
administrative/
clerical
staff
(
GS
6
step
3).
To
derive
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080
which
is
the
average
number
of
hours
worked
during
the
Federal
calendar
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
to
account
for
overhead
expenses.

6(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables.

6(
d)(
i)
The
simple
collection.

The
bottom
line
respondent
burden
hours
and
costs
were
calculated
by
adding
total
person­
hours
and
costs.
The
estimated
nationwide
burden
for
regulated
major
sources
in
the
first
three
years
after
promulgation
of
the
metal
furniture
NESHAP
is
summarized
in
Table
4.

The
annual
average
nationwide
burden
for
regulated
major
sources
in
the
first
three
years
after
promulgation
of
the
metal
furniture
NESHAP
is
estimated
to
be
45,672
total
labor
hours
per
year
at
a
cost
of
$
2,904,969
per
year
for
existing
major
sources
and
0
total
labor
hours
per
year
at
a
cost
of
$
0
per
year
for
new
major
sources.
The
annual
average
nationwide
burden
for
all
major
sources
in
this
three­
year
period
is
estimated
to
be
45,672
labor
hours
at
a
cost
of
$
2,904,969.

The
total
annualized
capital
and
startup
cost
reflects
the
estimated
capital
costs
for
equipment
required
to
comply
with
MRR
activities
associated
with
the
major
source
provisions
of
the
proposed
standards.
For
the
metal
furniture
NESHAP,
there
are
three
types
of
control
costs
that
may
be
incurred
by
a
facility
in
the
course
of
complying
with
this
rule:
capital,
direct,
and
indirect.
Capital
costs
represent
the
one­
time
purchase
of
equipment.
Because
the
compliance
16
option
expected
to
be
used
by
most
facilities
to
comply
with
the
standard
utilizes
reformulated
raw
materials
rather
than
a
different
coating
technology
or
add­
on
control
devices,
we
assumed
no
capital
costs
would
be
incurred.

Direct
costs
are
incurred
on
a
continuing
basis
for
materials
consumed
in
the
manufacturing
process,
primarily
coatings
and
solvents.
Utilities
are
also
included
in
the
direct
costs,
but
are
expected
to
be
unchanged
since
there
will
be
no
change
in
equipment.
Indirect
costs
include
overhead,
taxes,
insurance,
and
administrative
costs,
as
well
as
capital
recovery
costs.
Since
we
have
no
capital
costs,
we
assumed
that
overhead,
taxes,
insurance,
and
administrative
costs
would
be
unchanged
as
a
result
of
converting
to
lower
organic
HAP
content
coatings.
All
of
the
activities
and
costs
listed
above
are
usual
and
customary
for
the
metal
furniture
industry;
therefore,
no
additional
cost
are
incurred
for
the
purpose
of
collecting
information
as
required
by
the
metal
furniture
NESHAP.

Although
no
equipment
is
required
to
comply
with
the
metal
furniture
NESHAP
MRR
requirements,
there
are
MRR
labor
costs
for
compliance
(
as
described
in
section
1(
b)
and
provided
in
Tables
3a
through
3f).
Included
with
the
MRR
costs
are
the
training
costs
presented
in
Tables
3a
through
3f.
For
the
three
years
after
promulgation,
there
are
no
training
costs
for
new
or
existing
sources.

The
total
annual
estimated
operating
and
maintenance
costs
were
calculated
based
on
(
1)
the
estimated
storage,
filing,
photocopying,
and
postage
costs
for
the
24
estimated
total
annual
responses
associated
with
the
provisions
of
the
metal
furniture
NESHAP
and
(
2)
the
O&
M
costs
for
the
equipment
required
for
compliance
with
this
standard.
Storage,
filing,
and
photocopying
costs
per
response
were
estimated
as
0.5
hour
of
administrative
labor
at
a
rate
of
$
28/
hr.
First
class
postage
was
estimated
as
$
7.78
per
response
for
mailing
of
a
one­
pound
package
and
two
half­
pound
packages
to
regulatory
agencies.
The
postage
rates
were
based
on
data
from
U.
S.
Postal
Services
Internet
web
site
(
http://
www.
usps.
com/),
accessed
November
11,
2002.
The
total
storage,
filing,
photocopying,
and
postage
cost
per
response
was
$
21.78.

Because
there
are
no
sources
submitting
any
reports
during
the
three
years
after
promulgation,
the
estimated
total
annual
cost
for
the
0
estimated
total
annual
responses
is
$
0.

6(
d)(
ii)
The
EPA
tally.
17
The
bottom
line
Federal
government
burden
hours
and
costs
that
would
result
from
this
ICR
are
presented
in
Tables
5a
through
5c
for
existing
major
sources
and
Tables
5d
through
5f
for
new
major
sources.
These
estimates
were
calculated
by
adding
total
person­
hours
and
costs
from
each
of
the
tables.
Table
6
summarizes
the
Federal
government
burden
hours
and
costs
for
the
metal
furniture
NESHAP.

The
estimated
average
annual
labor
hours
and
costs
in
the
first
three
years
after
promulgation
for
the
metal
furniture
NESHAP
for
existing
major
sources
in
the
metal
furniture
surface
coating
source
category
were
1,766
labor
hours
per
year
at
a
cost
of
$
71,808
per
year.

The
estimated
average
annual
labor
hours
and
costs
for
the
first
three
years
after
promulgation
for
the
metal
furniture
NESHAP
for
new
major
sources
was
0
labor
hours
per
year
at
a
cost
of
$
0
per
year.
The
average
annual
bottom
line
Federal
government
burden
for
the
metal
furniture
NESHAP
was
1,766
labor
hours
per
year
at
a
cost
of
$
71,808
per
year
for
the
three­
year
period
following
promulgation
of
the
rule.

6(
d)(
iii)
The
complex
collection.

This
collection
is
a
simple
collection,
therefore,
this
section
does
not
apply.

6(
d)(
iv)
Variations
in
the
annual
bottom
line.

Variation
in
the
annual
bottom
line
for
this
regulation
may
occur
due
to
the
fact
that
certain
one­
time
activities
may
occur
any
time
during
the
three­
year
period
following
promulgation
of
the
rule.
Additionally,
some
sources
may
choose
to
achieve
compliance
before
the
end
of
the
three­
year
period,
incurring
costs
for
activities
such
as
recordkeeping,
monthly
compliance
calculations,
and
semiannual
reports.

6(
e)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
collection.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
79
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
18
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2002­
0048,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,

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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
0AR­
2002­
0048).
19
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
and
operators
of
facilities
subject
to
the
metal
furniture
NESHAP
are
required
to
collect
information.
ATTACHMENT
1
ATTACHMENT
2
