SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
1984.02
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
PLYWOOD
AND
COMPOSITE
WOOD
PRODUCTS
MANUFACTURING
PLANTS
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
October
2003
2
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Plywood
and
Composite
Wood
Products
Manufacturing
Plants."
This
is
a
new
information
collection
request
(
ICR).
The
U.
S.

Environmental
Protection
Agency
(
EPA)
tracking
number
is
1984.02.

(
b)
Short
Characterization
(
i)
Applicability.
Respondents
are
owners
or
operators
of
new
and
existing
plywood
and
composite
wood
products
(
PCWP)

manufacturing
facilities.
Plywood
and/
or
composite
wood
products
are
manufactured
by
bonding
wood
material
(
fibers,
particles,

strands,
veneers,
etc.)
or
agricultural
fiber
with
resin,

generally
under
heat
and
pressure,
to
form
a
structural
panel
or
engineered
wood
product.
Plywood
and
composite
wood
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.
A
major
source
of
HAP
is
a
plant
site
that
emits,
or
has
the
potential
to
emit,
any
single
HAP
at
a
rate
of
10
tons
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
or
more
per
year.

Approximately
223
of
the
PCWP
facilities
nationwide
are
expected
to
meet
the
applicability
criteria
defined
in
the
rule.
3
However,
only
212
of
these
facilities
have
equipment
that
is
subject
to
the
control
requirements
of
the
rule.
In
addition,

there
are
approximately
34
major
source
sawmill
facilities
that
produce
kiln­
dried
lumber;
although
these
sawmill
facilities
meet
the
applicability
criteria
in
the
rule,
there
are
no
control
requirements
for
any
of
the
equipment
located
at
the
sawmills.

An
estimated
19
new
PCWP
facilities
are
expected
to
be
constructed
in
the
next
5
years.
These
19
new
facilities
are
expected
to
include
six
oriented
strand
board
facilities,
five
medium
density
fiberboard,
four
particleboard,
and
four
laminated
veneer
lumber
facilities.
(
An
increase
of
19
facilities
over
the
next
5
years
is
3.8
facilities
per
year;
rather
than
assume
3.8
facilities,
we
assumed
4
facilities
per
year
for
the
first
3
years
after
the
effective
date
in
calculating
the
burden
estimates.)

(
ii)
PCWP
manufacturing
facilities.
Owners
or
operators
of
PCWP
manufacturing
facilities
subject
to
this
rule
must
install
and
monitor
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level
or
comply
with
the
alternative
emissions
averaging
or
production­
based
compliance
option
provisions
included
in
the
rule.

Owners
or
operators
are
required
to
install,
operate,
and
maintain
a
continuous
monitoring
system
(
CMS),
either
a
continuous
parameter
monitoring
system
CPMS
or
continuous
emission
monitoring
system
CEMS
depending
on
which
monitoring
system
the
facility
chooses,
to
demonstrate
compliance
with
the
add­
on
control
system
compliance
options
in
Table
1b
of
the
rule
and
the
operating
limits
in
Table
2
of
the
rule;
they
must
also
record
the
values
of
equipment
operating
parameters
as
specified
in
Table
7
of
the
rule.
As
specified
in
Table
8
of
the
rule,

owners
or
operators
of
certain
equipment
are
required
to
record
the
values
of
the
inlet
wood
moisture
content,
dryer
inlet
4
temperature,
and
volume
percent
softwood
species
processed
to
demonstrate
compliance
with
the
work
practice
standards
in
Table
3
of
the
rule.
Certain
owners
or
operators
are
also
required
to
prepare
and
follow
a
plan
for
minimizing
fugitive
emissions
to
demonstrate
compliance
with
the
work
practice
standards.

The
respondents
are
subject
to
sections
of
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include
those
associated
with
applicability
determinations;
notifications
that
the
facilities
are
subject
to
the
rule;
notifications
of
performance
tests;
notifications
of
compliance
status,
including
the
results
of
performance
tests
and
other
initial
compliance
demonstrations
that
do
not
include
performance
tests;
startup,

shutdown,
and
malfunction
reports;
and
initial
and
semi­
annual
compliance
reports.
In
addition
to
the
requirements
of
subpart
A,
existing
facilities
that
wish
to
implement
emissions
averaging
provisions
must
submit
an
emissions
averaging
plan.
Facilities
attempting
to
use
a
wet
control
device
to
meet
the
emission
limits
of
the
rule
must
submit
a
plan
addressing
how
they
will
prevent
re­
release
to
the
atmosphere
of
HAP
in
the
wet
control
system
wastewater.
Facilities
may
also
submit
a
request
for
a
routine
control
system
maintenance
exemption
to
justify
the
need
for
routine
maintenance
on
the
control
system
and
to
show
how
the
facilities
plan
to
minimize
emissions
to
the
greatest
extent
possible
during
the
maintenance.

All
reports
are
to
be
submitted
to
the
respondent's
State
or
local
agency
or
to
the
EPA
Regional
Office,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
rule
are
achieving
the
emission
limitations
and
work
practice
standards
in
the
rule.
5
(
iii)
Deviations
from
the
standard.
If
the
owner
or
operator
identifies
any
deviation
resulting
from
a
known
cause
for
which
no
Federally­
approved
or
promulgated
exemption
from
an
emission
limitation
or
work
practice
standard
applies,
the
compliance
report
must
also
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
action
taken
to
minimize
each
deviation
and
action
taken
to
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
monitoring
protocol.

(
iv)
Record
retention.
Owners
or
operators
of
a
PCWP
manufacturing
facility
must
maintain
a
copy
of
all
monitoring
data
that
demonstrate
compliance
with
the
operating
limits
in
the
rule.
In
addition,
some
facilities
must
maintain
records
of
inlet
wood
moisture
content,
dryer
inlet
temperature,
volume
percent
softwood
species
processed,
and
their
plan
for
minimizing
fugitive
emissions
that
demonstrate
compliance
with
the
work
practice
standards
in
the
rule.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
a
source,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Those
records
must
be
maintained
for
a
minimum
of
5
years.
At
a
minimum,
the
most
recent
2
years
of
data
must
be
retained
onsite.
The
remaining
3
years
of
data
may
be
retained
offsite.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
6
The
EPA
is
charged
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
emission
standards
for
each
category
or
subcategory
of
major
and
area
sources
of
HAP
listed
for
regulation
in
section
112(
b).
These
standards
are
applicable
to
new
or
existing
sources
of
HAP
and
shall
require
the
maximum
degree
of
emission
reduction.

The
predominant
HAP
emitted
from
PCWP
manufacturing
facilities
include
acetaldehyde,
acrolein,
formaldehyde,

methanol,
phenol,
and
propionaldehyde.
In
the
Administrator's
judgment,
the
pollutants
emitted
from
PCWP
manufacturing
facilities
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.

Therefore,
the
PCWP
source
category
is
listed
for
regulation
under
section
112.
(
Note:
The
PCWP
source
category
was
originally
listed
as
the
plywood
and
particleboard
source
category
on
July
16,
1992
(
57
FR
31576).
The
name
of
the
source
category
was
changed
to
PCWP
on
November
18,
1999
(
64
FR
63025)

to
more
accurately
reflect
the
types
of
manufacturing
facilities
covered
by
the
source
category.)

Section
114(
a)
of
the
CAA
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
the
CAA
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,
as
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.
7
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
work
practice
standards
and
emission
limitations
and
to
ensure
that
the
work
practice
standards
and
emission
limitations,
which
are
based
on
maximum
achievable
control
technology
(
MACT)
for
PCWP
manufacturing
facilities,
are
being
achieved.
After
the
compliance
date,
all
respondents
must
submit
initial
and
semiannual
(
every
6
months)
compliance
reports
that
contain
the
information
requested
in
§
63.2281(
c)
through
(
e)
of
the
rule.
In
addition,
respondents
that
elect
to
use
the
emissions
averaging
provisions
in
the
rule
must
submit
an
emissions
averaging
report
(
as
specified
in
§
63.2281(
f))
as
part
of
the
semi­
annual
report.

These
records
and
reports
are
required
under
the
General
Provisions
of
40
CFR
part
63,
subpart
A
(
as
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
CAA
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,
7412,
7414,
7416,
7601]).

(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
EPA
enforcement
personnel
to:
(
1)
identify
new,
modified,
reconstructed,
and
existing
sources
subject
to
the
rule;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
systems
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
EPA
to
identify
PCWP
manufacturing
facilities
that
are
not
in
compliance
with
the
emission
limitations
and
work
practice
standards
in
the
rule.
Based
on
reported
information,
EPA
can
decide
which
PCWP
manufacturing
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
will
indicate
8
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
emission
limitations
and
work
practice
standards.

Much
of
the
information
EPA
needs
to
determine
compliance
will
be
recorded
on
a
continuous,
hourly,
operating
shift,
or
daily
basis.
Such
information
will
be
reviewed
by
enforcement
personnel
during
an
inspection
and
will
need
to
be
summarized
and
reported
on
a
semi­
annual
basis.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule
(
such
as,
reports
of
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

A
search
of
existing
rules
revealed
some
duplication
of
information­
gathering
efforts
in
those
cases
where
facilities
are
subject
to
other
rules
in
addition
to
the
PCWP
manufacturing
NESHAP.
In
each
case
that
has
been
identified,
an
effort
has
been
made
to
eliminate
this
duplication.
Some
examples
of
these
efforts
are
provided
below.

The
PCWP
manufacturing
NESHAP
includes
sources
that
use
urea
formaldehyde
resins
as
the
binder,
which
have
been
specifically
excluded
from
regulation
under
the
wood
furniture
NESHAP;

conversely,
other
emission
points
that
are
covered
under
the
wood
furniture
NESHAP
are
being
excluded
from
regulation
under
the
PCWP
manufacturing
NESHAP.

Because
the
PCWP
manufacturing
NESHAP
regulates
emissions
from
direct­
fired
dryers,
those
combustion
units
associated
with
direct­
fired
dryers
are
excluded
from
the
requirements
of
other
combustion­
related
NESHAP,
such
as
the
Industrial,
Commercial,
9
Institutional
Boilers
NESHAP
and
the
Process
Heaters
NESHAP.

However,
those
combustion
units
that
supply
heat
or
steam
to
indirect­
fired
dryers
or
presses
and
those
thermal
oil
heaters
that
supply
hot
oil
for
presses
but
which
do
not
exhaust
through
dryers
are
not
covered
under
the
PCWP
manufacturing
NESHAP;
they
will
be
subject
to
the
requirements
of
the
applicable
combustionrelated
NESHAP.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.
A
public
review
and
comment
period
occurred
following
proposal
of
the
PCWP
manufacturing
NESHAP
in
the
Federal
Register.

(
c)
Consultations
The
EPA
published
a
list
of
categories
of
major
and
area
sources
of
HAP
on
July
16,
1992
(
57
FR
31576),
under
authority
of
section
112(
c);
this
notice
listed
the
plywood
and
particleboard
manufacturing
as
a
category
of
major
sources
of
HAP.
(
As
noted
above,
the
plywood
and
particleboard
source
category
was
changed
to
the
PCWP
source
category
on
November
18,
1999
(
64
FR
63025)
to
more
accurately
reflect
the
types
of
manufacturing
facilities
covered
by
the
source
category.)

Representatives
of
the
affected
companies
and
industry
trade
associations
were
consulted
during
the
development
of
the
rule,

and
several
meetings
have
been
held
with
them
during
this
time.

The
industry
trade
associations
include
the
American
Forest
and
Paper
Association
(
AF&
PA),
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
(
NCASI),
Hardwood
Plywood
and
Veneer
Association
(
HPVA),
Composite
Panel
Association
(
CPA),

American
Hardboard
Association
(
AHA),
American
Fiberboard
Association
(
AFA),
and
APA
 
The
Engineered
Wood
Association.
10
During
these
meetings,
the
representatives
were
given
the
opportunity
to
comment
on
the
regulatory
approach.
The
major
topics
of
these
discussions
included
the
applicability,
MACT
floor
approach,
regulatory
strategies,
and
the
national
impacts
of
the
rule.
No
specific
information
was
provided
to
the
representatives
with
respect
to
burden
estimates
prior
to
proposal
of
the
rule.

The
EPA
provided
a
60­
day
public
comment
period
following
proposal
of
the
PCWP
manufacturing
NESHAP,
during
which
all
affected
parties
were
given
the
opportunity
to
comment
on
the
proposed
rule.
Comments
were
received
from
PCWP
industry
representatives,
environmental
interest
groups,
and
State
and
local
agencies.
The
EPA
considered
the
comments
received
and,
as
appropriate,
incorporated
them
into
the
final
rule.

(
d)
Effects
of
Less
Frequent
Data
Collection
In
the
3
years
following
the
effective
date
of
the
rule,

existing
sources
will
submit
only
one­
time
notifications
to
EPA.

In
this
instance,
less
frequent
reporting
would
not
be
practical
because
EPA
needs
the
information
provided
in
these
one­
time
notifications.
In
addition
to
one­
time
notifications,
new
and
reconstructed
sources
will
also
submit
initial
and
semi­
annual
compliance
reports
in
the
3
years
following
the
effective
date
of
the
rule.
If
the
relevant
information
was
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
facilities
are
applying
good
operation
and
maintenance
practices
and
meeting
the
emission
limitations
and
work
practice
standards
in
the
rule.
Less
frequent
collection
could
decrease
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
long­
term
deviations
from
the
applicable
emission
limitations
and
work
practice
standards.
11
In
addition,
EPA's
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
deviations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
fewer
resources
than
judicial
proceedings,
both
EPA
and
the
regulated
community
benefit
from
preservation
of
EPA's
administrative
powers.

Also,
the
reporting
frequency
in
the
rule
is
consistent
with
the
requirements
of
Title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

(
e)
General
Guidelines
The
PCWP
manufacturing
NESHAP
requires
that
facilities
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
specified
in
the
general
information
collection
guidelines
in
5
CFR
1320.6(
f)
of
the
Office
of
Management
and
Budget
(
OMB)
regulations
implementing
the
Paperwork
Reduction
Act.
However,
the
5­
year
retention
period
is
consistent
with
the
retention
requirement
in
the
General
Provisions
in
subpart
A
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
40
CFR
part
70.
All
sources
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,

in
accordance
with
the
provisions
of
40
CFR
part
71.
Thus,
the
5­
year
record
retention
requirement
of
the
rule
adds
no
additional
burden.
At
a
minimum,
respondents
will
be
required
to
retain
onsite
the
most
recent
2
years
of
data.
The
remaining
3
years
of
data
could
be
retained
at
a
readily
accessible
onsite
or
offsite
storage
facility.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.
12
(
f)
Confidentiality
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
title
40,
Chapter
1,
Part
2,

Subpart
B
 
Confidentiality
of
Business
Information.
(
See
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.)

(
g)
Sensitive
Questions
The
information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.

Therefore,
this
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
any
facilities
that
manufacture
plywood
and/
or
composite
wood
products
and
are
classified
as
major
sources
of
HAP
under
section
112
of
the
CAA.

Table
1
lists
the
primary
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)

codes
used
to
classify
the
respondents
affected
by
the
PCWP
manufacturing
NESHAP.
Not
all
processes
classified
in
the
SIC
or
NAICS
codes
in
Table
1
will
be
regulated
by
the
PCWP
manufacturing
NESHAP
(
i.
e.,
they
will
not
be
regulated
if
they
are
already
subject
to
another
NESHAP).
13
(
b)
Information
Requested
(
i)
Data
items.
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
reporting
and
recordkeeping
requirements.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
rule
in
the
first
3
years
following
the
effective
date
are
listed
in
the
first
columns
of
Tables
2a
through
2f
and
are
presented
in
section
6(
a).
The
respondent
activities
are
described
in
more
detail
in
Attachment
2,
Description
of
Respondent
Activities.
One­
time
and
recurrent
respondent
activities
are
presented
in
Tables
2a
and
2b
for
the
first
year,

Tables
2c
and
2d
for
the
second
year,
and
Tables
2e
and
2f
for
the
third
year.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
The
Agency
activities
in
the
first
3
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
3a
through
3c
and
are
presented
in
section
6(
c).

Tables
3a,
3b,
and
3c
present
the
Agency
activities
for
the
first,
second,
and
third
years,
respectively,
after
the
effective
date
of
the
rule.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
notifications
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
AIRS
is
EPA's
database
for
the
collection,
maintenance,

and
retrieval
of
compliance
and
annual
emission
inventory
data
14
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
agencies
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
AIRS
database
can
be
publicly
accessed
via
the
Internet
at
http://
www.
epa.
gov/
enviro/
index_
java.
html
or
through
a
Freedom
of
Information
Act
request
to
EPA.
Data
obtained
during
periodic
visits
by
EPA
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semi­
annual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

The
rule
does
not
require
the
use
of
automated,
electronic,

mechanical,
or
other
technology
data
collection
techniques
or
other
forms
of
information
technology.
Although
many
of
the
large
companies
have
elaborate
collection
methods,
automated
systems
are
not
expected
to
reduce
the
burden.

(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
by
EPA.
The
EPA
has
reduced
the
reporting
and
recordkeeping
burden
for
respondents
to
include
only
the
information
that
EPA
needs
to
determine
compliance
with
the
rule.
Few
of
the
212
existing
facilities
with
control
requirements
under
the
PCWP
manufacturing
NESHAP
are
expected
to
meet
the
applicability
criteria
for
small
businesses.

The
EPA
does
not
expect
that
small
PCWP
manufacturing
businesses
will
experience
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

(
d)
Collection
Schedule
15
Collection
of
data
will
begin
after
the
effective
date
of
the
PCWP
manufacturing
NESHAP.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

For
all
existing
PCWP
manufacturing
facilities,
the
initial
notification
stating
that
the
facility
is
subject
to
the
rule
must
be
submitted
no
later
than
120
days
after
the
effective
date
of
the
rule.
New
or
reconstructed
PCWP
manufacturing
facilities
for
which
startup
occurs
on
or
after
the
effective
date
must
submit
the
initial
notification
no
later
than
120
days
after
the
source
becomes
subject
to
the
rule.
New
or
reconstructed
facilities
must
comply
immediately
upon
the
effective
date
of
the
final
rule
if
their
startup
date
is
before
the
effective
date
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date.

Facilities
required
to
conduct
a
performance
test
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.

For
each
initial
compliance
demonstration
that
does
not
include
a
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
30
days
following
the
completion
of
the
initial
compliance
demonstration.
For
each
initial
compliance
demonstration
that
includes
a
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
60
days
following
the
completion
of
the
performance
test.
If
averaging
emissions,
existing
facilities
must
also
submit
an
emissions
averaging
plan
at
least
1
year
before
their
compliance
date.
(
The
compliance
date
for
existing
facilities
is
3
years
after
the
effective
date.)

Records
necessary
to
determine
compliance
must
be
compiled
on
a
daily
basis,
and
compliance
reports
must
be
submitted
to
the
Administrator
on
a
semi­
annual
basis,
as
discussed
in
section
1(
b).
16
6.
Estimating
The
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
for
the
first
3
years
after
the
effective
date
of
the
rule
are
presented
in
Tables
2a
through
2f.
One­
time
and
recurrent
burden
estimates
to
the
industry
are
presented
in
Tables
2a
and
2b
for
the
first
year,
Tables
2c
and
2d
for
the
second
year,
and
Tables
2e
and
2f
for
the
third
year.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.

(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs.
The
annual
labor
costs
for
reporting
and
recordkeeping
activities
are
also
presented
in
Tables
1a
through
1f.
Labor
costs
for
reporting
and
recordkeeping
activities
were
estimated
based
on
the
most
recently
available
labor
rate
data
from
the
U.
S.
Bureau
of
Labor
Statistics
(
BLS)
(
http://
www.
bls.
gov/
ncs/
ect/
home.
htm).
Labor
costs
are
divided
into
the
following
three
categories:
(
1)

technical,
(
2)
management,
and
(
3)
clerical.
The
labor
rates,

including
fringe
benefits,
reported
by
BLS
for
June
2003
(
the
most
recent
rates
available)
are
$
32.12
per
hour
($
32.12/
hr)
for
technical
personnel,
$
48.41/
hr
for
managerial
personnel,
and
$
22.29/
hr
for
clerical
personnel.
The
base
labor
rates
were
adjusted
by
an
overhead
rate
of
167
percent.
The
final
total
labor
rates
are
$
53.64
for
technical
personnel,
$
80.84
for
management,
and
$
37.22
for
clerical.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities:
capital
costs
and
operation
and
maintenance
(
O&
M)
17
costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
Supporting
Statement
are
presented
in
Attachment
3,

Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
rate.
For
this
Supporting
Statement,
capital
costs
were
annualized
over
15
years,
assuming
an
interest
rate
of
7
percent.

In
most
cases,
administrative
charges,
insurance,
and
property
taxes
were
also
included
with
the
annualized
capital
costs,

estimated
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
(
planning
and
selection),
and
a
data
acquisition
system
(
data
logger,
computer,
logging
and
reporting
software,
and
printer).

The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
the
following
assumptions:
(
1)
the
parameter
monitoring
equipment
for
thermal
oxidizers,
catalytic
oxidizers,
and
biofilters
include
thermocouples;
(
2)
facilities
that
already
have
these
control
systems
are
also
assumed
to
have
the
required
parameter
monitoring
equipment,
so
no
costs
have
been
assigned
to
these
parameter
monitoring
equipment
and
it
was
assumed
that
the
facilities
will
elect
to
monitor
parameters
rather
than
using
CEMS;
(
3)
for
those
facilities
that
would
be
required
to
install
one
of
these
control
systems
in
order
to
comply
with
the
rule,

the
control
systems
are
assumed
to
include
the
required
parameter
monitoring
equipment;
consequently,
no
cost
has
been
assigned
to
these
parameter
monitoring
equipment
and
it
was
assumed
that
the
18
facilities
will
elect
to
monitor
parameters
rather
than
using
CEMS;
(
4)
one
data
acquisition
system
will
be
required
for
each
control
system,
at
a
cost
of
$
7,300
($
3,000
for
data
logger,

$
3,000
for
computer,
$
1,000
for
logging
and
reporting
software,

and
$
300
for
printer);
and
(
5)
data
acquisition
systems
will
be
purchased
for
the
seven
control
systems
(
thermal
oxidizers)

expected
to
be
installed
during
each
of
the
first
3
years
after
the
effective
date
of
the
rule
(
based
on
an
estimated
34
new
thermal
oxidizers
installed
over
5
years).

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
annualized
capital
cost
per
file
cabinet
is
$
35.

An
estimated
four
new
facilities
will
purchase
this
equipment
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule
(
based
on
an
estimated
19
new
facilities
over
5
years).

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
Method
25A
performance
tests
for
all
control
systems.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:
(
1)
all
facilities
will
use
control
systems
and
will
choose
to
demonstrate
compliance
with
the
90
percent
THC
reduction
emission
limit
included
in
the
rule;
(
2)
capital
costs
per
performance
test
are
$
10,000,
based
on
testing
both
the
inlet
and
outlet
of
the
control
system;
(
3)
one
performance
test
will
be
conducted
for
each
control
system
at
a
facility;
(
4)
performance
tests
will
be
conducted
for
the
seven
control
systems
(
thermal
oxidizers)

expected
to
be
installed
during
each
of
the
first
3
years
after
the
effective
date
(
based
on
an
estimated
34
new
thermal
oxidizers
installed
over
5
years);
and
(
4)
no
facilities
will
19
repeat
the
performance
test
during
the
first
three
years
after
the
effective
date.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,
or
property
taxes
were
estimated
for
performance
testing.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
Because
facilities
that
already
have
control
systems
are
also
assumed
to
have
the
required
parameter
monitoring
equipment,
there
are
no
additional
O&
M
costs
associated
with
the
monitoring
equipment.
For
those
facilities
that
would
be
required
to
install
a
control
system
to
comply
with
the
rule,
it
is
assumed
that
the
control
system
already
has
the
required
parameter
monitoring
equipment.
Consequently,
there
are
also
no
additional
O&
M
costs
associated
with
this
monitoring
equipment.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
respondents
to
submit
notifications
and
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
37.22/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
will
be
applied
to
the
290
responses
submitted
during
the
first
year,
the
41
responses
submitted
during
the
second
year,
and
the
261
responses
submitted
during
the
third
year.
(
The
number
of
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents,
as
shown
in
Tables
1a
through
1f
and
in
Attachment
3.)
20
(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
standards
development,
no
costs
can
be
attributed
to
the
development
of
these
requirements.

In
addition,
no
operational
costs
will
be
incurred
by
the
Federal
Government
because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
Facility
Subsystem,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
facilities.
Periodic
inspections
are
part
of
EPA's
overall
compliance
and
enforcement
program.

Therefore,
this
examination
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
by
the
facilities
in
one­
time
notifications
and
initial
and
semi­
annual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).

Tables
3a,
3b,
and
3c
present
the
estimated
annual
burden
to
the
Federal
Government
during
the
first,
second,
and
third
years,

respectively,
after
the
effective
date
of
the
rule.
Labor
rates
for
Federal
employees
are
based
on
the
January
2002,
Office
of
Personnel
Management
labor
rates
for
General
Schedule
employees
(
http://
www.
opm.
gov/
oca/
02tables/
02gsh.
pdf).
The
base
labor
rates
are
$
27.97/
hr
for
technical
personnel
(
GS­
12,
step
5),

$
46.23
for
management
personnel
(
GS­
15,
step
5),
and
$
15.77/
hr
for
clerical
personnel
(
GS­
7,
step
5).
The
base
labor
rates
were
multiplied
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
resulting
average
hourly
labor
costs
are
$
44.75
for
technical
personnel,
$
73.97
for
management,
and
$
25.23
for
clerical.
21
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Once
the
burden
and
costs
per
activity
have
been
established
on
a
per
respondent
basis,
the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
the
Agency.
To
calculate
the
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.

The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."
The
respondent
universe
varies
among
the
activities
listed
because
not
all
respondents
must
complete
each
activity.

Burden
and
costs
were
estimated
for
an
existing
respondent
universe
of
212
PCWP
manufacturing
facilities
and
a
projected
new
respondent
universe
of
4
PCWP
manufacturing
facilities
installed
in
each
of
the
first
3
years
after
the
effective
date.
To
determine
the
burden
for
each
activity
for
technical
staff,
the
number
of
burden
hours
per
respondent
was
multiplied
by
the
number
of
respondents.
Management
and
clerical
labor
hours
were
calculated
at
5
percent
and
10
percent
of
technical
labor
hours,

respectively.
The
total
burden
was
determined
by
summing
the
technical,
management,
and
clerical
burden
hour
estimates.
To
determine
the
total
labor
cost,
the
burden
hour
estimates
for
technical,
management,
and
clerical
labor
were
multiplied
by
their
respective
wage
rates
and
then
summed.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
2a
through
2f
and
dividing
the
sums
by
the
3­
year
review
period.
The
total
annual
respondent
burden
hours
and
costs
are
summarized
in
Table
4.
The
bottom
line
annual
burden,
averaged
over
the
first
3
years
after
the
22
effective
date,
is
4,692
labor
hours,
at
a
cost
of
$
250,528.

The
average
annual
burden
per
respondent,
based
on
an
average
220
respondents
over
the
3­
year
review
period,
is
21
labor
hours,
at
a
cost
of
$
1,139.

On
average,
there
are
an
estimated
197
total
annual
responses
for
the
first
3
years
after
the
effective
date
of
the
rule.
Of
the
197
total
annual
responses,
approximately
20
percent
are
assumed
to
be
collected
electronically.
The
total
annual
responses
are
an
average
of
the
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
first,
second,
and
third
years
after
the
effective
date.
An
estimated
290
notifications
and
reports
will
be
submitted
during
the
first
year,
41
during
the
second
year,
and
261
during
the
third
year.

The
total
nationwide
capital
cost
associated
with
monitoring
equipment
was
estimated
to
be
$
51,100
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
monitoring
equipment
is
$
15,310
for
the
3
years
following
the
effective
date.

The
total
nationwide
capital
cost
associated
with
file
cabinets
for
storing
collected
data
and
reports
was
estimated
to
be
$
940
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
file
cabinets
is
$
280
for
the
3
years
following
the
effective
date.

The
total
nationwide
capital
cost
for
performance
tests
was
estimated
to
be
$
70,000
for
each
of
the
first
3
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
performance
tests
is
$
15,372
for
the
3
years
following
the
effective
date.

Annual
O&
M
costs,
which
include
photocopying
and
postage
for
the
reports,
average
$
5,178
for
the
3
years
following
the
effective
date
of
the
rule.
23
Combining
the
average
annualized
capital
costs
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
results
in
a
total
annualized
capital
cost
of
$
30,962
for
the
3
years
following
the
effective
date.
Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
36,140
for
the
3
years
following
the
effective
date.

A
discussion
of
the
respondent
burden
and
costs
in
later
years
is
provided
in
Attachment
4,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date.

(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
3a,
3b,
and
3c
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
Agency
burden
hours
and
costs
are
summarized
in
Table
5.
The
bottom
line
annual
burden,

averaged
over
the
first
3
years
after
the
effective
date,
is
732
labor
hours,
at
a
cost
of
$
32,452.
A
discussion
of
the
Agency
burden
and
costs
in
later
years
is
provided
in
Attachment
4,

Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date.

(
iii)
The
complex
collection.
This
section
does
not
apply
because
this
collection
is
a
simple
collection.

(
iv)
Variations
in
the
annual
bottom
line.
The
annual
burden
hours
and
costs
associated
with
one­
time
activities
vary
over
the
course
of
the
3­
year
review
period
because
existing
sources
are
subject
to
different
requirements
in
each
year
as
follows:
(
1)
reading
instructions
and
notifying
EPA
that
the
facility
is
subject
to
the
rule
in
the
first
year;
(
2)
no
activities
in
the
second
year;
and
(
3)
developing
and
submitting
a
request
for
routine
control
system
maintenance
exemption
in
the
third
year.
(
No
existing
sources
are
assumed
to
submit
emissions
24
averaging
plans,
which
would
also
be
submitted
in
the
third
year.)
Increasing
numbers
of
new
sources
installed
after
the
effective
date
will
also
be
subject
to
ongoing
requirements,
such
as
recordkeeping
and
submitting
initial
and
semi­
annual
compliance
reports,
over
the
3­
year
review
period.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
EPA
will
be
reviewing
the
following
notifications
and
reports
from
existing
sources:

(
1)
notifications
of
applicability
of
the
standard
in
the
first
year;
(
2)
no
notifications
or
reports
in
the
second
year;
and
(
3)
requests
for
routine
control
system
maintenance
exemption
in
the
third
year.
The
EPA
will
also
review
initial
and
semi­
annual
compliance
reports
for
increasing
numbers
of
new
sources
over
the
3­
year
review
period.

(
f)
Reasons
for
Change
In
Burden
This
section
does
not
apply
because
this
collection
is
a
new
collection.

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
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;
25
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.

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.
(
OAR­
2002­
0048)
in
any
correspondence.
26
TABLE
1.
SIC
AND
NAICS
CODES
USED
TO
CLASSIFY
PCWP
RESPONDENTS
SIC
code
NAICS
code
Description
2421
321999
Sawmills
with
lumber
kilns
2435
321211
Hardwood
plywood
and
veneer
plants
2436
321212
Softwood
plywood
and
veneer
plants
2493
321219
Reconstituted
wood
products
(
particleboard,
medium
density
fiberboard,
hardboard,
fiberboard,
agriboard,

and
oriented
strandboard
plants)

2439
321213
Structural
wood
members,
not
elsewhere
classified
(
engineered
wood
products
plants)
27
TABLE
2a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
216
216
11
22
248
$
13,263
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
261
522
26
52
600
$
32,053
°
Emissions
averaging
plane
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
initial
performance
testg
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
compliance
status
With
performance
testg
80
1
80
4
320
16
32
368
$
19,649
Without
performance
testh
120
1
120
1
120
6
12
138
$
7,368
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
4
160
8
16
184
$
9,825
28
TABLE
2a.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
4
400
20
40
460
$
24,562
F.
Time
to
Train
Personnelk
40
1
40
4
160
8
16
184
$
9,825
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDEl
1,938
97
194
2,229
$
119,001
Average
cost
per
facilitym
216
$
551
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.
Estimate
includes
45
major
source
facilities
that
need
only
to
submit
the
initial
notification
of
applicability
because
they
have
no
equipment
subject
to
the
rule
(
e.
g.,
sawmills
with
lumber
kilns,
certain
engineered
wood
facilities).

e
Assume
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
216)
subject
to
the
rule.
29
TABLE
2b.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
4
32
2
3
37
$
1,965
Deviationse
24
1
24
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
1
8
4
32
2
3
37
$
1,965
Control
system
maintenance
reportg
8
1
8
4
32
2
3
37
$
1,965
Emissions
averaging
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
0
0
0
0
0
$
0
Deviationse
24
2
48
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
2
16
0
0
0
0
0
$
0
Control
system
maintenance
reportg
8
2
16
0
0
0
0
0
$
0
Emissions
averaging
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
4
312
16
31
359
$
19,158
°
Records
of
continuous
compliancei
Record
parameters/
information
0.25
365
91
4
365
18
37
420
$
22,412
30
TABLE
2b.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Compile
data
24
2
48
4
192
10
19
221
$
11,790
Enter/
verify
information
for
semi­
annual
reports
16
2
32
4
128
6
13
147
$
7,860
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
4
64
3
6
74
$
3,930
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
0
0
0
0
0
$
0
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
1,157
58
116
1,331
$
71,044
Average
cost
per
facilitym
4
$
17,761
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
4)
complying
with
the
rule.
31
TABLE
2c.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
4
4
0.2
0.4
5
$
246
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
4
8
0.4
0.8
9
$
491
°
Emissions
averaging
plane
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
initial
performance
testg
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
compliance
status
With
performance
testg
80
1
80
4
320
16
32
368
$
19,649
Without
performance
testh
120
1
120
1
120
6
12
138
$
7,368
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
4
160
8
16
184
$
9,825
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
4
400
20
40
460
$
24,562
F.
Time
to
Train
Personnelk
40
1
40
4
160
8
16
184
$
9,825
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDEl
1,212
61
121
1,394
$
74,422
Average
cost
per
facilitym
220
$
338
32
TABLE
2c.
(
continued)

a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Assume
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
220)
subject
to
the
rule.
33
TABLE
2d.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
4
32
2
3
37
$
1,965
Deviationse
24
1
24
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
1
8
4
32
2
3
37
$
1,965
Control
system
maintenance
reportg
8
1
8
4
32
2
3
37
$
1,965
Emissions
averaging
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
4
64
3
6
74
$
3,930
Deviationse
24
2
48
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
2
16
4
64
3
6
74
$
3,930
Control
system
maintenance
reportg
8
2
16
4
64
3
6
74
$
3,930
Emissions
averaging
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
8
624
31
62
718
$
38,316
°
Records
of
continuous
compliancei
Record
parameters/
information
0.25
365
91
8
730
37
73
840
$
44,825
34
TABLE
2d.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Compile
data
24
2
48
8
384
19
38
442
$
23,579
Enter/
verify
information
for
semi­
annual
reports
16
2
32
8
256
13
26
294
$
15,719
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
8
128
6
13
147
$
7,860
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
4
64
3
6
74
$
3,930
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
2,474
124
247
2,845
$
151,913
Average
cost
per
facilitym
8
$
18,989
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
8)
complying
with
the
rule.
35
TABLE
2e.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
4
4
0.2
0.4
5
$
246
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
4
8
0.4
0.8
9
$
491
°
Emissions
averaging
plan
e
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
216
432
22
43
497
$
26,527
°
Notification
of
initial
performance
test
g
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
compliance
status
With
performance
testg
80
1
80
4
320
16
32
368
$
19,649
Without
performance
testh
120
1
120
1
120
6
12
138
$
7,368
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
4
160
8
16
184
$
9,825
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
4
400
20
40
460
$
24,562
F.
Time
to
Train
Personnelk
40
1
40
4
160
8
16
184
$
9,825
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDEl
1,636
82
164
1,881
100,457
Average
cost
per
facilitym
224
$
448
36
TABLE
2e.
(
continued)

a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Assume
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
224)
subject
to
the
rule.
37
TABLE
2f.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
 
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
4
32
2
3
37
$
1,965
Deviationse
24
1
24
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
1
8
4
32
2
3
37
$
1,965
Control
system
maintenance
reportg
8
1
8
4
32
2
3
37
$
1,965
Emissions
averaging
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
7
112
6
11
129
$
6,877
Deviationse
24
2
48
1
48
2
5
55
$
2,947
Startup,
shutdown,
and
malfunction
reportf
8
2
16
8
128
6
13
147
$
7,860
Control
system
maintenance
reportg
8
2
16
8
128
6
13
147
$
7,860
Emissions
averaging
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
12
936
47
94
1076
$
57,474
°
Records
of
continuous
compliancei
Record
parameters/
information
0.25
365
91
12
1,095
55
110
1,259
$
67,237
38
TABLE
2f.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Compile
data
24
2
48
12
576
29
58
662
$
35,369
Enter/
verify
information
for
semi­
annual
reports
16
2
32
12
384
19
38
442
$
23,579
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
12
192
10
19
221
$
11,790
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
8
128
6
13
147
$
7,860
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
3,823
191
382
4,396
$
234,747
Average
cost
per
facilitym
12
$
19,562
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
12)
complying
with
the
rule.
39
TABLE
3a.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
person­
hours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
261
522
26
52
600
$
26,607
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
4
8
0.4
0.8
9
$
408
G.
Review
of
Notification
of
Initial
Performance
Test
2
4
8
0.4
0.8
9
$
408
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
4
160
8
16
184
$
8,155
°
Without
performance
testh
40
1
40
2
4
46
$
2,039
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
4
8
0.4
0.8
9
$
408
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
4
8
0.4
0.8
9
$
408
°
Control
system
maintenance
reportl
2
4
8
0.4
0.8
9
$
408
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
0
0
0
0
0
$
0
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
0
0
0
0
0
$
0
°
Control
system
maintenance
reportl
2
0
0
0
0
0
$
0
°
Emissions
averaging
report
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
786
39
79
904
$
40,064
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
40,064
40
TABLE
3a.
(
continued)

a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
no
initial
performance
tests
and
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
41
TABLE
3b.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
person­
hours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
4
8
0.4
0.8
9
$
408
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
4
8
0.4
0.8
9
$
408
G.
Review
of
Notification
of
Initial
Performance
Test
2
4
8
0.4
0.8
9
$
408
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
4
160
8
16
184
$
8,155
°
Without
performance
testh
40
1
40
2
4
46
$
2,039
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
4
8
0.4
0.8
9
$
408
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
4
8
0.4
0.8
9
$
408
°
Control
system
maintenance
reportl
2
4
8
0.4
0.8
9
$
408
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
8
16
0.8
2
18
$
816
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
8
16
0.8
2
18
$
816
°
Control
system
maintenance
reportl
2
8
16
0.8
2
18
$
816
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
320
16
32
368
$
16,311
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
16,311
42
TABLE
3b.
(
continued)

a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
no
initial
performance
tests
and
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
43
TABLE
3c.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
personhours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
4
8
0.4
0.8
9
$
408
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
216
432
22
43
497
$
22,020
G.
Review
of
Notification
of
Initial
Performance
Test
2
4
8
0.4
0.8
9
$
408
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
4
160
8
16
184
$
8,155
°
Without
performance
testh
40
1
40
2
4
46
$
2,039
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
4
8
0.4
0.8
9
$
408
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
4
8
0.4
0.8
9
$
408
°
Control
system
maintenance
reportl
2
4
8
0.4
0.8
9
$
408
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
14
28
1
3
32
$
1,427
°
Deviationsj
8
2
16
0.8
2
18
$
816
°
Startup,
shutdown,
and
malfunction
reportk
2
16
32
2
3
37
$
1,631
°
Control
system
maintenance
reportl
2
16
32
2
3
37
$
1,631
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
804
40
80
925
$
40,981
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
40,981
44
TABLE
3c.
(
continued)

a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
test(
s),
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
no
initial
performance
tests
and
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
45
TABLE
4.
SUMMARY
OF
RESPONDENT
BURDEN
HOURS
AND
COSTS
Total
burden,

hours
Total
costs,

$

Table
2a
(
one­
time
activities
in
first
year)
2,229
$
119,001
Table
2b
(
recurrent
activities
in
first
year)
1,331
$
71,044
Table
2c
(
one­
time
activities
in
second
year)
1,394
$
74,422
Table
2d
(
recurrent
activities
in
second
year)
2,845
$
151,913
Table
2e
(
one­
time
activities
in
third
year)
1,881
$
100,457
Table
2f
(
recurrent
activities
in
third
year)
4,396
$
234,747
Total
14,076
$
751,585
Bottom
line
annual
burden
(
Total/
3)
4,692
$
250,528
46
TABLE
5.
SUMMARY
OF
AGENCY
BURDEN
HOURS
AND
COSTS
Total
burden,

hours
Total
costs,

$

Table
3a
(
first
year)
904
$
40,064
Table
3b
(
second
year)
368
$
16,311
Table
3c
(
third
year)
925
$
40,981
Total
2,197
$
97,356
Bottom
line
annual
burden
(
Total/
3)
732
$
32,452
47
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
rule.

4
attachments
ATTACHMENT
1
Source
Data
and
Information
Requirements
Attachment
1
SUMMARY
OF
RECORDKEEPING
REQUIREMENTS
Requirements
Regulation
Reference
Record
retention
63.10(
b)(
1)
and
63.2283
Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)
and
63.2282(
a)(
1)

Startup,
shutdown,
and
malfunction
plan
63.6(
e)(
3)
and
63.2250(
c)

Records
related
to
startup,
shutdown,
and
malfunction
63.6(
e)(
3)(
iii)­(
iv)
and
63.2282(
a)(
2)

Records
related
to
control
device
maintenance
and
documentation
of
routine
control
device
maintenance
exemption
63.2282(
a)(
3)

Records
of
performance
tests
63.10(
b)(
2)(
viii)
and
63.2282(
a)(
4)

Records
for
each
CMS
for
emission
limitations
and
records
related
to
the
work
practice
standards
63.8(
d)(
3),
63.8(
f)(
6)(
i),
63.8(
g),
63.10(
b)(
2)(
vi)­(
xi),
and
63.2282(
b)­(
c)

Records
of
information
required
to
calculate
emission
debits
and
credits
for
emissions
averaging
63.2282(
d)

SUMMARY
OF
REPORTING
REQUIREMENTS
Requirements
Regulation
Reference
Initial
notifications
(
including
construction/
reconstruction)
63.5,
63.9(
b),
and
63.2280(
a)­(
b)

Notification
of
performance
test
63.7(
b)­(
c),
63.9(
e),
and
63.2280(
c)

Notification
of
compliance
status
(
including
performance
test
results)
63.9(
h),
63.10(
d)(
2),
and
63.2280(
d)

Request
for
routine
control
device
maintenance
exemption
63.2280(
e)

Emissions
averaging
plan
63.2280(
f)

Notification
of
change
to
control
system,
emissions
averaging
process
unit,
monitoring
parameter,
or
monitoring
parameter
value
63.2280(
g)

Semi­
annual
compliance
report
°
Startup,
shutdown,
and
malfunction
reports
°
Control
system
maintenance
reports
°
Results
of
performance
tests
conducted
during
the
semi­
annual
reporting
period
°
No
deviations/
no
out­
of­
control
CMS
°
Deviations/
out­
of­
control
CMS
°
Emissions
averaging
reports
63.10(
e)(
3)
and
63.2281(
b)­(
f)
63.10(
d)(
5)
and
63.2281(
c)(
4)
63.2281(
c)(
5)
63.2281(
c)(
6)

63.2281(
c)(
7)­(
8)
63.2281(
d)­(
e)
63.2281(
f)
ATTACHMENT
2
Description
of
Respondent
Activities
Attachment
2
DESCRIPTION
OF
RESPONDENT
ACTIVITIES
(
1)
Read
Instructions
represents
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
rule
and
understanding
how
they
apply
to
the
respective
emission
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
scheduling,
and
selecting
methods
of
compliance.
The
costs
for
planning
and
selection
are
included
in
the
capital
costs
for
the
performance
test,
as
explained
in
item
(
4)
below.

(
3)
Train
Personnel
represents
activities
involved
in
communicating
specific
definitions,
compliance
options,
and
other
requirements,
such
as
recordkeeping,
monitoring,
and
reporting.
An
average
facility
may
elect
to
provide
classroom
instructions
for
all
workers
directly
impacted
by
the
requirements.
However,
the
rule
does
not
require
specific
training
itself.

(
4)
Create
Information
represents
the
activities
involving
testing,
retesting,
establishing
operating
parameter
limits,
and
analyzing
point­
by­
point
applicability.
Because
respondents
are
expected
to
hire
outside
contractors
to
conduct
the
performance
tests,
these
costs
are
not
included
in
the
burden
tables.
Instead,
the
costs
associated
with
the
performance
test
are
included
as
capital
costs
and
are
discussed
in
the
text.

(
5)
Gather
Existing
Information
represents
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data
and
other
related
activities.

(
6)
Write
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
rule
requires
no
standard
forms,
these
activities
relate
to
the
preparation
of
formal
reports
and
cover
letters,
as
appropriate.

(
7)
Enter
Information
represent
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance,
and
appropriate
records
required
as
a
result;
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage;
and
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
at
which
they
are
disposed.
ATTACHMENT
3
Methods
Used
in
Cost
Estimates
Attachment
3
1
METHODS
USED
IN
COST
ESTIMATES
(
a)
Costs
for
Monitoring
Equipment
The
capital
cost
for
the
monitoring
equipment
was
estimated
based
on
the
following
assumptions:

1.
Facilities
will
choose
to
monitor
control
device
operating
parameters
instead
of
operating
CEMS.

2.
The
monitoring
equipment
cost
is
$
0
because
the
equipment
(
e.
g.,
thermocouples)
are
already
being
used
by
the
facilities
or
are
included
with
the
control
system
cost.

3.
The
data
acquisition
system
cost
is
$
7,300,
which
includes
$
3,000
for
data
logger,
$
3,000
for
computer,
$
1,000
for
logging
and
reporting
software,
and
$
300
for
printer.

4.
One
data
acquisition
system
will
be
purchased
for
each
control
system.

To
determine
the
total
capital
cost
for
monitoring
equipment
for
existing
and
new
facilities,
the
unit
costs
were
applied
to
the
individual
control
systems
as
shown
in
Table
1.
The
annualized
capital
cost
for
monitoring
equipment
was
calculated
as
a
sum
of
the
capital
recovery
cost,
administrative
charges,

insurance,
and
property
taxes.
The
capital
recovery
cost
was
determined
as
a
product
of
a
capital
recovery
factor
and
the
total
capital
cost.
The
capital
recovery
factor
was
estimated
to
be
0.1098,
based
on
a
15­
year
equipment
life
and
7
percent
interest
rate.
The
administrative
charges,
insurance,
and
property
taxes
were
calculated
as
4
percent
of
the
capital
cost.

Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
monitoring
equipment
for
the
first
6
years
after
the
effective
date
were
estimated
as
shown
in
Table
2.

(
b)
Costs
for
File
Cabinets
The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility.
We
assumed
$
235
per
file
cabinet.
Using
a
capital
recovery
factor
of
0.1098
and
Attachment
3
2
estimating
administrative
charges,
insurance,
and
property
taxes
at
4
percent
of
total
capital
cost,
the
average
annualized
capital
cost
per
facility
for
file
cabinets
was
estimated
to
be
$
35.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
file
cabinets
for
the
first
6
years
after
the
effective
date
were
estimated
as
shown
in
Table
3.

(
c)
Costs
for
Performance
Tests
The
capital
costs
associated
with
performance
testing
include
the
costs
for
Method
25A
performance
tests
for
all
control
systems.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:

1.
All
facilities
will
use
control
systems
and
will
choose
to
demonstrate
compliance
with
the
90
percent
THC
reduction
emission
limit
included
in
the
rule.

2.
Capital
costs
per
performance
test
are
$
10,000,
based
on
testing
both
the
inlet
and
outlet
of
the
control
system.

3.
One
performance
test
will
be
conducted
for
each
control
system.

4.
In
the
fourth
year
after
the
effective
date,
approximately
22
repeat
tests
will
be
conducted,
assuming
5
percent
of
facilities
(
i.
e.,
11
facilities)
retest,
one
test
per
control
system,
and
two
control
systems
per
facility.

5.
In
the
sixth
year
after
the
effective
date,
facilities
with
biofilters
will
conduct
the
repeat
tests
required
every
two
years.

To
determine
the
total
capital
cost
for
initial
and
repeat
performance
tests
for
existing
and
new
facilities,
the
unit
cost
was
applied
to
the
facilities
as
shown
in
Table
4.
Using
a
capital
recovery
factor
of
0.1098,
the
average
annualized
capital
cost
per
facility
for
performance
tests
was
estimated.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,

or
property
taxes
were
estimated
for
performance
testing.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
Attachment
3
3
for
performance
testing
for
the
first
6
years
after
the
effective
date
were
estimated
as
shown
in
Table
5.

(
f)
Costs
for
Operation
and
Maintenance
Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
Because
facilities
that
already
have
control
systems
(
e.
g.,
catalytic
oxidizers,
thermal
oxidizers,

biofilters)
are
also
assumed
to
have
the
required
monitoring,

there
are
no
additional
O&
M
costs
associated
with
these
monitoring
equipment.
For
those
facilities
that
would
be
required
to
install
one
of
the
control
systems
in
order
to
comply
with
the
rule,
the
control
systems
are
already
assumed
to
have
the
required
monitoring
equipment.
Consequently,
there
are
no
additional
O&
M
costs
associated
with
these
monitoring
equipment
either.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Using
the
estimated
costs
per
response,
the
O&
M
costs
for
photocopying
and
postage
for
the
first
6
years
after
the
effective
date
were
estimated
as
shown
in
Table
6.
4
Attachment
3
TABLE
1.
MONITORING
EQUIPMENT
COSTS
FOR
EXISTING
AND
NEW
FACILITIES
Emission
point
No.
of
facilities
Unit
capital
cost
Capital
cost
Annualized
capital
cost
Existing
facilities
Catalytic
oxidizers
8
$
7,300
$
58,400
$
8,748
Biofilters
5
$
7,300
$
36,500
$
5,468
Thermal
oxidizers
302
$
7,300
$
2,204,600
$
330,249
TOTAL
$
2,299,500
$
344,465
New
facilities
Thermal
oxidizers
(
each
year)
7
$
7,300
$
51,100
$
7,655
5
Attachment
3
TABLE
2.
MONITORING
EQUIPMENT
COSTS
FOR
THE
FIRST
6
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Capital
cost
Annualized
capital
cost
New
facilities
Existing
facilities
Total
New
facilitiesa
Existing
facilities
Total
Year
1
$
51,100
$
0
$
51,100
$
7,655
$
0
$
7,655
Year
2
$
51,100
$
0
$
51,100
$
15,310
$
0
$
15,310
Year
3
$
51,100
$
0
$
51,100
$
22,964
$
0
$
22,964
AVERAGE
(
Years
1­
3)
$
51,100
$
0
$
51,100
$
15,310
$
0
$
15,310
Year
4
$
51,100
$
2,299,500
$
2,350,600
$
30,619
$
344,465
$
375,084
Year
5
$
51,100
$
0
$
51,100
$
38,274
$
344,465
$
382,739
Year
6
$
51,100
$
0
$
51,100
$
45,929
$
344,465
$
390,394
AVERAGE
(
Years
4­
6)
$
51,100
$
766,500
$
817,600
$
38,274
$
344,465
$
382,739
aWith
four
new
facilities
being
added
each
year,
the
increase
in
annualized
capital
costs
each
year
is
equal
to
the
amount
of
annualized
capital
cost
for
four
facilities.
For
example,
the
annualized
capital
cost
for
Year
1
(
four
new
facilities)
would
be
$
7,655,
while
the
annualized
capital
cost
for
Year
2
(
eight
new
facilities)
would
be
2
times
$
7,655,
or
$
15,310.
(
Note
that
the
annualized
capital
cost
for
Year
1
is
rounded
to
$
7,655
in
the
table,
so
the
annualized
capital
costs
for
subsequent
years
may
not
be
exact
multiples
of
$
7,655.)
6
Attachment
3
TABLE
3.
FILE
CABINET
COSTS
FOR
THE
FIRST
6
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Capital
cost/

respondent
Annualized
capital
cost/

respondent
Capital
cost
respondents/
yr
Annual
cost
respondents/
yr
Capital
cost
Annualized
capital
cost
Year
1
$
235
$
35
4
4
$
940
$
140
Year
2
$
235
$
35
4
8
$
940
$
280
Year
3
$
235
$
35
4
12
$
940
$
420
AVERAGE
(
Years
1­
3)
$
940
$
280
Year
4
$
235
$
35
216
228
$
50,760
$
7,980
Year
5
$
235
$
35
4
232
$
940
$
8,120
Year
6
$
235
$
35
4
236
$
940
$
8,260
AVERAGE
(
Years
4­
6)
$
17,547
$
8,120
7
Attachment
3
TABLE
4.
PERFORMANCE
TEST
COSTS
FOR
EXISTING
AND
NEW
FACILITIES
Emission
point
No.
of
control
systemsa
Unit
capital
cost
Capital
cost
Annualized
capital
cost
Existing
facilities
Catalytic
oxidizers
8
$
10,000
$
80,000
$
8,784
Biofilters
5
$
10,000
$
50,000
$
5,490
Thermal
oxidizers
302
$
10,000
$
3,020,000
$
331,596
TOTAL
$
3,150,000
$
345,870
New
facilities
Thermal
oxidizers
7
$
10,000
$
70,000
$
7,686
Repeat
performance
tests
(
year
4)
22
$
10,000
$
220,000
$
24,156
Biofilter
repeat
performance
tests
(
year
6)
5
$
10,000
$
50,000
$
5,490
a
The
number
of
control
systems
is
taken
from
the
number
used
in
the
control
cost
estimate.
Some
facilities
will
need
more
than
one
control
system.
8
Attachment
3
TABLE
5.
PERFORMANCE
TEST
COSTS
FOR
THE
FIRST
6
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Capital
cost
Annualized
capital
cost
New
facilities
Existing
facilities
Repeat
tests
Total
New
facilitiesa
Existing
facilities
Repeat
tests
Total
Year
1
$
70,000
$
0
$
0
$
70,000
$
7,686
$
0
$
0
$
7,686
Year
2
$
70,000
$
0
$
0
$
70,000
$
15,732
$
0
$
0
$
15,732
Year
3
$
70,000
$
0
$
0
$
70,000
$
23,058
$
0
$
0
$
23,058
AVERAGE
(
Years
1­
3)
$
70,000
$
0
$
0
$
70,000
$
15,732
$
0
$
0
$
15,732
Year
4
$
70,000
$
3,150,000
$
220,000
$
3,440,000
$
30,744
$
345,870
$
24,156
$
400,77,0
Year
5
$
70,000
$
0
$
0
$
70,000
$
38,430
$
345,870
$
24,156
$
408,456
Year
6
$
70,000
$
0
$
50,000b
$
120,000
$
46,116
$
345,870
$
29,646b
$
421,632
AVERAGE
(
Years
4­
6)
$
70,000
$
1,050,000
$
90,000
1,210,000
$
38,430
$
345,870
$
25,986
$
410,286
aWith
four
new
facilities
being
added
each
year,
the
increase
in
annualized
capital
costs
each
year
is
equal
to
the
amount
of
annualized
capital
cost
for
four
facilities.
For
example,
the
annualized
capital
cost
for
Year
1
(
four
new
facilities)
would
be
$
7,686,
while
the
annualized
capital
cost
for
Year
2
(
eight
new
facilities)
would
be
2
times
$
7,686,
or
$
15,732.

bIncludes
cost
of
repeat
performance
tests
required
for
biofilters
every
two
years
($
50,000
capital
cost
and
$
5,490
annualized
cost).
9
Attachment
3
TABLE
6.
O&
M
COSTS
FOR
PHOTOCOPYING
AND
POSTAGE
FOR
THE
FIRST
6
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Cost
item
Photocopy
cost/
report
Postage
cost/

report
Reports/
respondent
Respondents/

year
Reports/

year
Photocopy
cost
Postage
cost
Notification
of
construction/
reconstruction
(
Years
1­
6)
$
18.61
$
7.63
1
4
4
$
74
$
31
Notification
of
anticipated
startup
(
Years
1­
6)
$
18.61
$
7.63
1
4
4
$
74
$
31
Notification
of
actual
start­
up
(
Years
1­
6)
$
18.61
$
7.63
1
4
4
$
74
$
31
Emissions
averaging
plan
(
Years
1­
6)
$
18.61
$
7.63
1
0
0
$
0
$
0
Notification
of
applicability
of
standard
Year
1
$
18.61
$
7.63
1
261
261
$
4,857
$
1,991
Years
2­
6
$
18.61
$
7.63
1
4
4
$
74
$
31
Notification
of
initial
performance
test
Years
1­
3,
5­
6
$
18.61
$
7.63
1
4
4
$
74
$
31
Year
4
$
18.61
$
7.63
1
216
216
$
4,020
$
1,648
Notification
of
compliance
status
(
with
performance
test)

Years
1­
3,
5­
6
$
18.61
$
7.63
1
4
4
$
74
$
31
Year
4
$
18.61
$
7.63
1
216
216
$
4,020
$
1,648
Notification
of
compliance
status
(
without
performance
test)

Years
1­
3,
5­
6
$
18.61
$
7.63
1
1
1
$
19
$
8
Year
4
$
18.61
$
7.63
1
115
115
$
2,140
$
877
Request
for
routine
control
system
maintenance
exemption
Years
1­
2,
4­
6
$
18.61
$
7.63
1
4
4
$
74
$
31
10
TABLE
6.
(
continued)

Attachment
3
Cost
item
Photocopy
cost/
report
Postage
cost/

report
Reports/
respondent
Respondents/

year
Reports/

year
Photocopy
cost
Postage
cost
Year
3
$
18.61
$
7.63
1
216
216
$
4,020
$
1,648
Initial
compliance
report
Years
1­
3,
5­
6
$
18.61
$
7.63
1
4
4
$
74
$
31
Year
4
$
18.61
$
7.63
1
216
216
$
4,020
$
1,648
Semi­
annual
compliance
report
Year
1
$
18.61
$
7.63
2
0
0
$
0
$
0
Year
2
$
18.61
$
7.63
2
4
8
$
149
$
61
Year
3
$
18.61
$
7.63
2
8
16
$
298
$
122
Year
4
$
18.61
$
7.63
2
12
24
$
447
$
183
Year
5
$
18.61
$
7.63
2
228
456
$
8,486
$
3,479
Year
6
$
18.61
$
7.63
2
232
464
$
8,635
$
3,540
TOTAL
(
Year
1)
290
$
5,397
$
2,213
TOTAL
(
Year
2)
41
$
763
$
313
TOTAL
(
Year
3)
261
$
4,857
$
1,991
AVERAGE
(
Years
1­
3)
197
$
3,672
$
1,506
TOTAL
(
Year
4)
807
$
15,018
$
6,157
TOTAL
(
Year
5)
489
$
9,100
$
3,731
TOTAL
(
Year
6)
497
$
9,249
$
3,792
AVERAGE
(
Years
4­
6)
598
$
11,123
$
4,560
ATTACHMENT
4
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
Attachment
4
1
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
1.
The
Information
Collected
 
­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
there
are
several
onetime
notifications
and
reports
that
both
existing
and
new
sources
must
complete
in
the
3
years
between
the
effective
date
of
the
PCWP
manufacturing
NESHAP
and
the
compliance
date
for
existing
sources.
These
reports
include:
(
1)
determining
applicability
and
notifying
EPA
that
the
facility
is
subject
to
the
rule,

(
2)
developing
and
submitting
an
emissions
averaging
plan
(
if
appropriate),
and
(
3)
developing
and
submitting
a
routine
control
system
maintenance
exemption
request.
New
sources
are
also
required
to
submit
notifications
of
construction/
reconstruction
and
notifications
of
anticipated
and
actual
startup,
as
well
as
initial
and
semi­
annual
compliance
reports.

In
the
3
years
following
the
compliance
date
for
existing
sources,
existing
sources
must
submit
other
one­
time
notifications
and
reports,
and
ongoing
recordkeeping
and
reporting
begins.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
existing
facilities
must
notify
EPA
of
upcoming
performance
tests,
conduct
the
performance
tests,
and
submit
the
initial
notification
of
compliance
status.
Existing
facilities
also
must
develop
their
startup,
shutdown,
and
malfunction
plans
and
begin
ongoing
monitoring
and
recordkeeping
for
various
operating
parameters,
emissions
averaging
(
if
appropriate),
control
system
maintenance,
etc.
Existing
facilities
will
begin
to
submit
initial
and
semi­
annual
reports
of
deviations
and
various
other
reports
related
to
startup,
Attachment
4
2
shutdown,
and
malfunction,
emissions
averaging
(
if
appropriate),

control
system
maintenance,
etc.

The
respondent
activities
required
by
the
rule
in
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
1a
through
1f
of
this
attachment.
One­
time
and
recurrent
respondent
activities
are
presented
in
Tables
1a
and
1b
for
the
fourth
year,
Tables
1c
and
1d
for
the
fifth
year,
and
Tables
1e
and
1f
for
the
sixth
year.

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
in
the
3
years
between
the
effective
date
of
the
NESHAP
and
the
compliance
date
for
existing
sources,
EPA
will
review
the
notifications
of
applicability,
emissions
averaging
plans
(
if
appropriate),
and
routine
control
system
maintenance
exemption
requests
submitted
by
existing
and
new
sources.
The
EPA
will
also
review
the
notifications
of
construction/
reconstruction,
notifications
of
actual
and
anticipated
startup,
and
initial
and
semi­
annual
compliance
reports
submitted
by
new
sources
over
the
3
years
between
the
effective
date
of
the
NESHAP
and
the
compliance
date
for
existing
sources.

In
the
3
years
following
the
compliance
date
for
existing
sources,
EPA
will
continue
to
review
the
notifications
and
initial
and
semi­
annual
compliance
reports
submitted
by
new
sources.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
the
EPA
will
also
review
notifications
and
reports
for
existing
sources,
including
the
notifications
of
performance
tests,
notifications
of
compliance
status,
and
initial
compliance
reports.
The
EPA
will
also
review
the
ongoing
semi­
annual
compliance
reports
for
existing
sources
in
the
fifth
and
sixth
years
following
the
effective
date
of
the
rule.
Agency
activities
are
listed
in
the
first
columns
of
Tables
2a,
2b,
and
Attachment
4
3
2c
of
this
attachment
for
the
fourth,
fifth,
and
sixth
years,

respectively,
following
the
effective
date
of
the
rule.

2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.
Tables
1a
through
1f
of
this
attachment
present
the
annual
respondent
burden
estimates
and
labor
costs
for
reporting
and
recordkeeping
activities
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.
The
one­
time
and
recurrent
burden
and
cost
estimates
are
presented
in
Tables
1a
and
1b
for
the
first
year,
Tables
1c
and
1d
for
the
second
year,
and
Tables
1e
and
1f
for
the
third
year.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.

Labor
costs
for
reporting
and
recordkeeping
activities
were
estimated
based
on
the
most
recently
available
labor
rate
data
from
the
U.
S.
Bureau
of
Labor
Statistics
(
BLS)

(
http://
www.
bls.
gov/
ncs/
ect/
home.
htm).
Labor
costs
are
divided
into
the
following
three
categories:
(
1)
technical,
(
2)

management,
and
(
3)
clerical.
The
labor
rates,
including
fringe
benefits,
reported
by
BLS
for
June
2003
(
the
most
recent
rates
available)
are
$
32.12
per
hour
($
32.12/
hr)
for
technical
personnel,
$
48.41/
hr
for
managerial
personnel,
and
$
22.29/
hr
for
clerical
personnel.
The
base
labor
rates
were
adjusted
by
an
overhead
rate
of
167
percent.
The
final
total
labor
rates
are
$
53.64
for
technical
personnel,
$
80.84
for
management,
and
$
37.22
for
clerical.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities
 
capital
costs
and
O&
M
costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
attachment
to
the
Attachment
4
4
Supporting
Statement
are
presented
in
Attachment
3,
Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
rate.
For
this
attachment
to
the
Supporting
Statement,
capital
costs
were
annualized
over
15
years,
assuming
an
interest
rate
of
7
percent.
In
most
cases,
administrative
charges,
insurance,
and
property
taxes
were
also
included
with
the
annualized
capital
costs,
estimated
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
(
planning
and
selection),
and
a
data
acquisition
system
(
data
logger,
computer,
logging
and
reporting
software,
and
printer).

The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
the
following
assumptions:
(
1)
the
parameter
monitoring
equipment
for
thermal
oxidizers,
catalytic
oxidizers,
and
biofilters
include
thermocouples;
(
2)
facilities
that
already
have
these
control
systems
are
also
assumed
to
have
the
required
parameter
monitoring
equipment,
so
no
costs
have
been
assigned
to
these
monitoring
equipment
and
it
is
assumed
that
the
facilities
will
elect
to
monitor
parameters
rather
than
using
CEMS;
(
3)
for
those
facilities
that
would
be
required
to
install
one
of
these
control
systems
in
order
to
comply
with
the
rule,
the
control
systems
are
assumed
to
include
the
required
parameter
monitoring
equipment;
consequently,
no
cost
has
been
assigned
to
these
monitoring
equipment
and
it
is
assumed
that
the
facilities
will
elect
to
monitor
parameters
rather
than
using
CEMS;
(
4)
one
data
acquisition
system
will
be
required
for
each
control
system,
at
a
cost
of
$
7,300
($
3,000
for
data
logger,
$
3,000
for
computer,
Attachment
4
5
$
1,000
for
logging
and
reporting
software,
and
$
300
for
printer);

and
(
5)
data
acquisition
systems
will
be
purchased
for
the
estimated
322
control
systems
(
8
catalytic
oxidizers,
5
biofilters,
and
309
thermal
oxidizers)
at
existing
and
new
facilities
in
the
fourth
year
after
the
effective
date
of
the
rule;
data
acquisition
systems
will
be
purchased
for
the
estimated
7
control
systems
(
thermal
oxidizers)
installed
at
new
facilities
in
each
of
the
fifth
and
sixth
years
after
the
effective
date
(
based
on
an
estimated
34
new
thermal
oxidizers
expected
to
be
installed
over
5
years).

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
The
annualized
capital
cost
per
file
cabinet
is
$
35.

Approximately
216
existing
and
new
facilities
will
purchase
this
equipment
in
the
fourth
year
after
the
effective
date
of
the
rule,
and
4
new
facilities
will
purchase
this
equipment
in
each
of
the
fifth
and
sixth
years
after
the
effective
date.

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
Method
25A
performance
tests
for
all
control
systems.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:
(
1)
all
facilities
will
use
control
systems
and
will
choose
to
demonstrate
compliance
with
the
90
percent
THC
reduction
emission
limit
included
in
the
rule;
(
2)
capital
costs
per
performance
test
are
$
10,000,
based
on
testing
both
the
inlet
and
outlet
of
the
control
system;
(
3)
one
performance
test
will
be
conducted
for
each
control
system
at
a
facility;
(
4)
performance
tests
will
be
conducted
for
the
estimated
322
control
systems
(
8
catalytic
oxidizers,
5
biofilters,
and
309
thermal
oxidizers)
at
existing
and
new
facilities
during
the
fourth
year
after
the
effective
date;
performance
tests
will
be
conducted
for
the
estimated
7
Attachment
4
6
control
systems
(
thermal
oxidizers)
installed
at
new
facilities
during
each
of
the
fifth
and
sixth
years;
(
5)
in
the
fourth
year
after
the
effective
date,
approximately
22
repeat
tests
will
be
conducted,
assuming
5
percent
of
facilities
(
i.
e.,
11
facilities)

retest,
one
test
per
control
system,
and
two
control
systems
per
facility;
and
(
6)
in
the
sixth
year
after
the
effective
date,

facilities
with
biofilters
will
conduct
the
repeat
tests
required
every
two
years.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,
or
property
taxes
were
estimated
for
performance
testing.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
Because
facilities
that
already
have
control
systems
are
also
assumed
to
have
the
required
monitoring
equipment,
there
are
no
additional
O&
M
costs
associated
with
the
monitoring
equipment.
For
those
facilities
that
would
be
required
to
install
a
control
system
to
comply
with
the
rule,
it
is
assumed
that
the
control
system
already
has
the
required
monitoring
equipment.
Consequently,
there
are
no
additional
O&
M
costs
associated
with
this
monitoring
equipment.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
The
O&
M
costs
for
rules
that
require
respondents
to
submit
notifications
and
reports
to
EPA
and
maintain
records
are
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
37.22/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
will
be
applied
to
the
807
responses
submitted
during
the
fourth
year,

the
489
responses
submitted
during
the
fifth
year,
and
the
497
responses
submitted
during
the
sixth
year.
(
The
number
of
Attachment
4
7
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents,
as
shown
in
Tables
1a
through
1f
of
this
attachment
and
in
Attachment
3.)

(
b)
Estimating
Agency
Burden
and
Costs
Tables
2a,
2b,
and
2c
of
this
attachment
present
the
estimated
annual
burden
to
the
Federal
Government
during
the
fourth,
fifth,
and
sixth
years,
respectively,
following
the
effective
date
of
the
rule.
The
only
burden
and
costs
that
the
Federal
Government
will
incur
as
a
result
of
the
information
collection
requirements
are
associated
with
the
analysis
of
the
information
reported
by
facilities
in
one­
time
notifications
and
initial
and
semi­
annual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).
Labor
rates
for
Federal
employees
were
based
on
the
January
2002,
Office
of
Personnel
Management
labor
rates
for
General
Schedule
employees
(
http://
www.
opm.
gov/
oca/
02tables/
02gsh.
pdf).
The
base
labor
rates
are
$
27.97/
hr
for
technical
personnel
(
GS­
12,
step
5),

$
46.23
for
management
personnel
(
GS­
15,
step
5),
and
$
15.77/
hr
for
clerical
personnel
(
GS­
7,
step
5).
The
base
labor
rates
were
multiplied
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
resulting
average
hourly
labor
costs
are
$
44.75
for
technical
personnel,
$
73.97
for
management,
and
$
25.23
for
clerical.

(
c)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
1a
through
1f
and
dividing
the
sums
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).
The
total
annual
respondent
burden
hours
and
costs
are
summarized
in
Table
3.

The
bottom
line
annual
burden,
averaged
over
the
fourth,

fifth,
and
sixth
years
after
the
effective
date,
is
113,050
labor
Attachment
4
8
hours,
at
a
cost
of
$
6,036,300.
The
average
annual
burden
per
respondent,
based
on
an
average
232
respondents
over
the
3­
year
period,
is
487
labor
hours,
at
a
cost
of
$
26,019.

On
average,
there
are
an
estimated
598
total
annual
responses
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Of
the
598
total
annual
responses,
approximately
20
percent
are
assumed
to
be
collected
electronically.
The
total
annual
responses
are
an
average
of
the
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
An
estimated
807
one­
time
and
recurrent
notifications
and
reports
will
be
submitted
during
the
fourth
year,
489
during
the
fifth
year,
and
497
during
the
sixth
year.

The
total
nationwide
capital
costs
associated
with
monitoring
equipment
were
estimated
to
be
$
2,350,600
the
fourth
year
after
the
effective
date
of
the
rule,
and
$
51,100
in
each
of
the
fifth
and
sixth
years.
The
average
annualized
capital
cost
for
the
monitoring
equipment
is
$
382,739
for
the
fourth,
fifth,

and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
were
estimated
to
be
$
50,760
in
the
fourth
year
after
the
effective
date
of
the
rule,
and
$
940
in
each
of
the
fifth
and
sixth
years.
The
average
annualized
capital
cost
for
file
cabinets
is
$
8,120
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
for
performance
tests
were
estimated
to
be
$
3,440,000
for
the
fourth
year,
$
70,000
for
the
fifth
year,
and
$
120,000
for
the
sixth
year
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
performance
tests
is
$
410,286
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

Annual
O&
M
costs,
which
include
photocopying
and
postage
for
the
reports,
average
$
15,683
nationwide
for
the
fourth,
fifth,

and
sixth
years
following
the
effective
date
of
the
rule.
Attachment
4
9
Combining
the
annualized
capital
costs
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
results
in
an
average
total
annualized
capital
cost
of
$
801,145
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date.
Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
816,828
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
2a
through
2c
and
then
dividing
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).
The
total
annual
Agency
burden
hours
and
costs
are
summarized
in
Table
4.
The
bottom
line
annual
burden,

averaged
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date,
is
10,564
labor
hours,
at
a
cost
of
$
476,067.

(
d)
Burden
Statement
(
i)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection
averaged
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
were
estimated
to
be
113,050
labor
hours
and
$
6,036,300.
The
average
burden
and
cost,
per
respondent,
are
487
labor
hours
and
$
26,019.

During
these
3
years,
new
facilities
are
required
to
submit
notifications
of
construction/
reconstruction
and
notifications
of
anticipated
and
actual
startup,
and
existing
facilities
are
required
to
submit
notifications
of
performance
test
and
notifications
of
compliance
status.
All
facilities
are
required
to
submit
initial
and
semi­
annual
compliance
reports
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
rule.

In
the
fourth
year
after
the
effective
date,
the
collection
requirements
will
be
applicable
to
an
estimated
228
respondents
(
212
existing
facilities
as
of
the
effective
date,
16
facilities
constructed
as
of
the
fourth
year
after
the
effective
date).
An
Attachment
4
10
estimated
4
additional
facilities
will
be
subject
to
the
rule
in
each
subsequent
year.

(
ii)
The
total
capital
cost
in
the
fourth
year
after
the
effective
date
of
the
rule
is
$
5,841,360;
this
cost
includes
$
2,350,600
for
monitoring
equipment,
$
50,760
for
file
cabinets,

and
$
3,440,000
for
performance
tests.
The
total
capital
cost
in
the
fifth
year
after
the
effective
date
is
$
122,040,
which
includes
$
51,100
for
monitoring
equipment,
$
940
for
file
cabinets,
and
$
70,000
for
performance
tests.
The
total
capital
cost
in
the
sixth
year
after
the
effective
date
is
$
172,040,

which
includes
$
51,100
for
monitoring
equipment,
$
940
for
file
cabinets,
and
$
120,000
for
performance
tests.
The
average
annualized
capital
cost
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
is
$
801,145
for
the
fourth,

fifth,
and
sixth
years
after
the
effective
date.
The
average
annual
O&
M
cost,
which
includes
photocopying
and
postage
for
the
reports,
is
$
15,683
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Combining
the
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
816,828
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
11
Attachment
4
TABLE
1a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
4
4
0.2
0.4
5
$
246
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
4
8
0.4
0.8
9
$
491
°
Emissions
averaging
plane
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
initial
performance
testg
2
1
2
216
432
22
43
497
$
26,527
°
Notification
of
compliance
status
With
performance
testg
80
1
80
216
17,280
864
1,728
19,872
$
1,061,061
Without
performance
testh
120
1
120
115
13,800
690
1,380
15,870
$
847,375
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
216
8,640
432
864
9,936
$
530,531
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
216
21,600
1,080
2,160
24,840
$
1,326,326
F.
Time
to
Train
Personnelk
40
1
40
216
8,640
432
864
9,936
$
530,531
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
70,436
3,522
7,044
81,001
$
4,325,052
Average
cost
per
facilitym
228
$
18,970
12
Attachment
4
TABLE
1a.
(
continued)

a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests;
assumes
that
22
existing
facilities
with
dry
rotary
dryers,
2
existing
facilities
with
hardwood
veneer
dryers,
and
90
existing
facilities
with
softwood
veneer
dryers
will
submit
notifications
of
compliance
status
in
the
fourth
year
after
the
effective
date.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
228)
subject
to
the
rule.
13
Attachment
4
TABLE
1b.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
194
1,552
78
155
1,785
$
95,299
Deviationse
24
1
24
22
528
26
53
607
$
32,421
Startup,
shutdown,
and
malfunction
reportf
8
1
8
216
1,728
86
173
1,987
$
106,106
Control
system
maintenance
reportg
8
1
8
216
1,728
86
173
1,987
$
106,106
Emissions
averaging
plan
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
11
176
9
18
202
$
10,807
Deviationse
24
2
48
1
48
2
5
55
$
2,947
Startup,
shutdown,
and
malfunction
reportf
8
2
16
12
192
10
19
221
$
11,790
Control
system
maintenance
reportg
8
2
16
12
192
10
19
221
$
11,790
Emissions
averaging
plan
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
228
17,784
889
1,778
20,452
$
1,092,009
°
Records
of
continuous
compliancei
Record
parameters/

information
0.25
365
91
228
20,805
1,040
2,081
23,926
$
1,277,510
Compile
data
24
2
48
228
10,944
547
1,094
12,586
$
672,005
14
Attachment
4
TABLE
1b.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Enter/
verify
information
for
semi­
annual
reports
16
2
32
228
7,296
365
730
8,390
$
448,004
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
228
3,648
182
365
4,195
$
224,002
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
12
192
10
19
221
$
11,790
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
66,813
3,341
6,681
76,835
$
4,102,585
Average
cost
per
facilitym
228
$
17,994
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
a
total
of
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
228)
complying
with
the
rule.
15
Attachment
4
TABLE
1c.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIFTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
4
4
0.2
0.4
5
$
246
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
4
8
0.4
0.8
9
$
491
°
Emissions
averaging
plane
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
initial
performance
testg
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
compliance
status
With
performance
testg
80
1
80
4
320
16
32
368
$
19,649
Without
performance
testh
120
1
120
1
120
6
12
138
$
7,368
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
4
160
8
16
184
$
9,825
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
4
400
20
40
460
$
24,562
F.
Time
to
Train
Personnelk
40
1
40
4
160
8
16
184
$
9,825
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
1,212
61
121
1,394
$
74,422
Average
cost
per
facilitym
232
$
321
16
Attachment
4
TABLE
1c.
(
continued)

a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
232)
subject
to
the
rule.
17
Attachment
4
TABLE
1d.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIFTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
4
32
2
3
37
$
1,965
Deviationse
24
1
24
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
1
8
4
32
2
3
37
$
1,965
Control
system
maintenance
reportg
8
1
8
4
32
2
3
37
$
1,965
Emissions
averaging
plan
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
205
3,280
164
328
3,772
$
201,405
Deviationse
24
2
48
23
1,104
55
110
1,270
$
67,790
Startup,
shutdown,
and
malfunction
reportf
8
2
16
228
3,648
182
365
4,195
$
224,002
Control
system
maintenance
reportg
8
2
16
228
3,648
182
365
4,195
$
224,002
Emissions
averaging
plan
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
232
18,096
905
1,810
20,810
$
1,111,167
°
Records
of
continuous
compliancei
Record
parameters/

information
0.25
365
91
232
21,170
1,059
2,117
24,346
$
1,299,923
Compile
data
24
2
48
232
11,136
557
1,114
12,806
$
683,795
18
Attachment
4
TABLE
1d.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Enter/
verify
information
for
semi­
annual
reports
16
2
32
232
7,424
371
742
8,538
$
455,863
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
232
3,712
186
371
4,269
$
227,932
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
228
3,648
182
365
4,195
$
224,002
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
76,962
3,848
7,696
88,506
$
4,725,775
Average
cost
per
facilitym
232
$
20,370
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
a
total
of
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
232)
complying
with
the
rule.
19
Attachment
4
TABLE
1e.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SIXTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
4
4
0.2
0.4
5
$
246
B.
Required
Activities
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/

reconstruction
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
anticipated
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
actual
startup
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
applicability
of
standardd
2
1
2
4
8
0.4
0.8
9
$
491
°
Emissions
averaging
plane
120
1
120
0
0
0
0
0
$
0
°
Request
for
routine
control
system
maintenance
exemptionf
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
initial
performance
testg
2
1
2
4
8
0.4
0.8
9
$
491
°
Notification
of
compliance
status
With
performance
testg
80
1
80
4
320
16
32
368
$
19,649
Without
performance
testh
120
1
120
1
120
6
12
138
$
7,368
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
4
160
8
16
184
$
9,825
E.
Develop
Startup,
Shutdown,

Malfunction
Planj
100
1
100
4
400
20
40
460
$
24,562
F.
Time
to
Train
Personnelk
40
1
40
4
160
8
16
184
$
9,825
G.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
1,212
61
121
1,394
$
74,422
Average
cost
per
facilitym
236
$
315
20
Attachment
4
TABLE
1e.
(
continued)

a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
facilities
will
comply
by
conducting
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
train
personnel.

l
The
one­
time
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
236)
subject
to
the
rule.
21
Attachment
4
TABLE
1f.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SIXTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Report
°
Initial
compliance
reportd
No
deviationse
8
1
8
4
32
2
3
37
$
1,965
Deviationse
24
1
24
0
0
0
0
0
0
Startup,
shutdown,
and
malfunction
reportf
8
1
8
4
32
2
3
37
$
1,965
Control
system
maintenance
reportg
8
1
8
4
32
2
3
37
$
1,965
Emissions
averaging
plan
reporth
20
1
20
0
0
0
0
0
$
0
°
Semi­
annual
compliance
reportd
No
deviationse
8
2
16
209
3,344
167
334
3,846
$
205,335
Deviationse
24
2
48
23
1,104
55
110
1,270
$
67,790
Startup,
shutdown,
and
malfunction
reportf
8
2
16
232
3,712
186
371
4,269
$
227,932
Control
system
maintenance
reportg
8
2
16
232
3,712
186
371
4,269
$
227,932
Emissions
averaging
plan
reporth
20
2
40
0
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,
shutdown,

and
malfunction
1.5
52
78
236
18,408
920
1,841
21,169
$
1,130,325
°
Records
of
continuous
compliancei
Record
parameters/

information
0.25
365
91
236
21,535
1,077
2,154
24,765
$
1,322,335
Compile
data
24
2
48
236
11,328
566
1,133
13,027
$
695,585
22
Attachment
4
TABLE
1f.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
personhours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
Enter/
verify
information
for
semi­
annual
reports
16
2
32
236
7,552
378
755
8,685
$
463,723
°
Records
of
control
system
maintenance
Included
in
3E
°
Records
of
emissions
averaging
credits/
debits
Included
in
3E
F.
Calibration
of
CMSj
16
1
16
236
3,776
189
378
4,342
$
231,862
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
232
3,712
186
371
4,269
$
227,932
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
78,279
3,914
7,828
90,021
$
4,806,644
Average
cost
per
facilitym
236
$
20,367
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,

4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
53.64/
hour
for
technical
labor,
$
80.84/
hour
for
management
labor,
and
$
37.22/
hour
for
clerical
labor.

d
Assumes
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
years.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

g
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

h
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
records
of
CMS
data
for
emission
limitations
and
various
records
for
work
practice
standards.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
a
total
of
2
CMS
for
each
facility,
a
total
of
16
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
236)
complying
with
the
rule.
23
TABLE
2a.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
person­
hours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
22
880
44
88
1,012
$
44,855
2.
Attend
Repeat
Performance
Testd
40
1
40
2
4
46
$
2,039
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
4
8
0.4
0.8
9
$
408
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
4
8
0.4
0.8
9
$
408
G.
Review
of
Notification
of
Initial
Performance
Test
2
216
432
22
43
497
$
22,020
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
216
8,640
432
864
9,936
$
440,394
°
Without
performance
testh
40
238
9,520
476
952
10,948
$
485,249
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
194
388
19
39
446
$
19,777
°
Deviationsj
8
22
176
9
18
202
$
8,971
°
Startup,
shutdown,
and
malfunction
reportk
2
216
432
22
43
497
$
22,020
°
Control
system
maintenance
reportl
2
216
432
22
43
497
$
22,020
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
22
44
2
4
51
$
2,243
°
Deviationsj
8
2
16
0.8
2
18
$
816
°
Startup,
shutdown,
and
malfunction
reportk
2
24
48
2
5
55
$
2,447
°
Control
system
maintenance
reportl
2
24
48
2
5
55
$
2,447
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
21,136
1,057
2,114
24,306
$
1,077,334
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
23
facilities/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
23
round
trip/
yr):
$
11,500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
1,088,834
24
TABLE
2a.
(
continued)

a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.
Assumes
that
22
existing
facilities
with
dry
rotary
dryers,
2
existing
facilities
with
hardwood
veneer
dryers,
and
90
existing
facilities
with
softwood
veneer
dryers
will
submit
notifications
of
compliance
status
in
the
fourth
year
after
the
effective
date.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
22
initial
performance
tests
and
1
repeat
performance
test,
for
a
total
of
23
tests
attended.
25
TABLE
2b.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIFTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
person­
hours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
4
8
0.4
0.8
9
$
408
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
4
8
0.4
0.8
9
$
408
G.
Review
of
Notification
of
Initial
Performance
Test
2
4
8
0.4
0.8
9
$
408
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
4
160
8
16
184
$
8,155
°
Without
performance
testh
40
1
40
2
4
46
$
2,039
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
4
8
0.4
0.8
9
$
408
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
4
8
0.4
0.8
9
$
408
°
Control
system
maintenance
reportl
2
4
8
0.4
0.8
9
$
408
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
410
820
41
82
943
$
41,797
°
Deviationsj
8
46
368
18
37
423
$
18,758
°
Startup,
shutdown,
and
malfunction
reportk
2
456
912
46
91
1,049
$
46,486
°
Control
system
maintenance
reportl
2
456
912
46
91
1,049
$
46,486
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
3,284
164
328
3,777
$
167,390
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
167,390
a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
26
TABLE
2b.
(
continued)

first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
no
initial
performance
tests
and
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
27
TABLE
2c.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SIXTH
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
C
Technical
person­
hours
per
year
(
C
=
A
*
B)
D
Management
person­
hours
per
year
(
D
=
C
*
0.05)
E
Clerical
personhours
per
year
(
E
=
C
*
0.1)
F
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
1
40
2
4
46
$
2,039
3.
Litigation
N/
A
4.
Report
Review
A.
Review
of
Notification
of
Construction/
Reconstruction
2
4
8
0.4
0.8
9
$
408
B.
Review
of
Notification
of
Anticipated
Startup
2
4
8
0.4
0.8
9
$
408
C.
Review
of
Notification
of
Actual
Startup
2
4
8
0.4
0.8
9
$
408
D.
Review
of
Notification
of
Applicability
of
Standard
2
4
8
0.4
0.8
9
$
408
E.
Review
of
Emissions
Averaging
Plane
40
0
0
0
0
0
$
0
F.
Review
of
Request
for
Routine
Control
System
Maintenance
Exemptionf
2
4
8
0.4
0.8
9
$
408
G.
Review
of
Notification
of
Initial
Performance
Test
2
4
8
0.4
0.8
9
$
408
H.
Review
of
Notification
of
Compliance
Status
°
With
performance
testg
40
4
160
8
16
184
$
8,155
°
Without
performance
testh
40
1
40
2
4
46
$
2,039
I.
Review
of
Initial
Compliance
Reporti
°
No
deviationsj
2
4
8
0.4
0.8
9
$
408
°
Deviationsj
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportk
2
4
8
0.4
0.8
9
$
408
°
Control
system
maintenance
reportl
2
4
8
0.4
0.8
9
$
408
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
J.
Review
of
Semi­
Annual
Compliance
Reporti
°
No
deviationsj
2
418
836
42
84
961
$
42,612
°
Deviationsj
8
46
368
18
37
423
$
18,758
°
Startup,
shutdown,
and
malfunction
reportk
2
464
928
46
93
1,067
$
47,302
°
Control
system
maintenance
reportl
2
464
928
46
93
1,067
$
47,302
°
Emissions
averaging
reporte
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
m
3,372
169
337
3,878
$
171,876
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*
1
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
100
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
171,976
28
TABLE
2c.
(
continued)

a
Operations
per
year
are
equal
to
the
number
of
operations
per
facility
times
the
number
of
facilities.
There
are
an
estimated
212
existing
major
source
facilities
subject
to
the
NESHAP.
These
212
facilities
include
166
facilities
that
must
install
control
systems
to
comply
with
the
NESHAP
and
46
facilities
that
already
have
the
required
control
systems.
Assuming
19
new
facilities
built
over
the
first
5
years
after
the
effective
date
(
including
6
oriented
strand
board,
5
medium
density
fiberboard,
4
particleboard,
and
4
laminated
veneer
lumber
facilities),
approximately
4
new
facilities
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
44.75/
hour
for
technical
labor,
$
73.97/
hour
for
management
labor,
and
$
25.23/
hour
for
clerical
labor.

c
Assumes
all
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests.

d
Assumes
5
percent
of
facilities
will
repeat
the
performance
tests,
that
5
repeat
tests
will
be
conducted
on
existing
biofilters,
and
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.

e
Assumes
no
existing
facilities
will
choose
to
use
the
emissions
averaging
option
because
all
facilities
assumed
to
install
control
systems;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
all
facilities
will
submit
a
request
for
routine
control
device
maintenance
exemption.

g
Assumes
all
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
Assumes
1
new
facility
per
year
with
softwood
veneer
dryers
will
submit
a
notification
of
compliance
status
without
performance
tests.

i
Assumes
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
following
years.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
SSMP.

l
Assumes
all
facilities
will
submit
a
description
of
the
control
device
maintenance
performed.

m
The
burden
and
cost
are
equal
to
the
totals
added
down
each
column.

n
Tests
attended
include
no
initial
performance
tests
and
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
29
TABLE
3.
SUMMARY
OF
RESPONDENT
BURDEN
HOURS
AND
COSTS
Total
burden,

hours
Total
costs,

$

Table
1a
(
one­
time
activities
in
fourth
year)
81,001
$
4,325,052
Table
1b
(
recurrent
activities
in
fourth
year)
76,835
$
4,102,585
Table
1c
(
one­
time
activities
in
fifth
year)
1,394
$
74,422
Table
1d
(
recurrent
activities
in
fifth
year)
88,506
$
4,725,775
Table
1e
(
one­
time
activities
in
sixth
year)
1,394
$
74,422
Table
1f
(
recurrent
activities
in
sixth
year)
90,021
$
4,806,644
Total
339,151
$
18,108,899
Bottom
line
annual
burden
113,050
$
6,036,300
30
TABLE
4.
SUMMARY
OF
AGENCY
BURDEN
HOURS
AND
COSTS
Total
burden,

hours
Total
costs,

$

Table
2a
(
fourth
year)
24,306
$
1,088,834
Table
2b
(
fifth
year)
3,777
$
167,390
Table
2c
(
sixth
year)
3,878
$
171,976
Total
31,961
$
1,428,200
Bottom
line
annual
burden
10,654
$
476,067
