1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
Subpart
QQQQ
Coating
of
Wood
Building
Products
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.
"
Recordkeeping
and
Reporting
Requirements
for
the
Wood
Building
Products
(
Surface
Coating)
National
Emission
Standard
for
Hazardous
Air
Pollutants."
This
is
a
new
information
collection
request
(
ICR)
and
the
tracking
number
is
EPA
ICR
No.
[
2034.02].

(
b)
Short
Characterization.
This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
rulemaking
amends
Title
40,
Chapter
I,
Part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
Subpart
QQQQ­­
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Surface
Coating
of
Wood
Building
Products.
Hereafter,
this
subpart
is
referred
to
as
the
"
wood
building
products
NESHAP."
The
wood
building
products
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions
that
use
at
least
4,170
liters
(
1,100
gallons)
of
coatings
annually.
Respondents
are
owners
or
operators
of
commercial
facilities
that
perform
surface
coating
operations
on
wood
building
products.
Wood
building
products
include
any
finished
or
laminated
wood
product
containing
at
least
50
percent
wood
or
wood
fiber
(
excluding
the
weight
of
glass)
that
is
used
in
the
construction
of
any
residential,
commercial,
or
institutional
building.
The
definition
does
not
include
wood
furniture,
wood
furniture
components,
processes
that
are
subject
to
the
plywood
and
composite
wood
products
NESHAP,
prefabricated
housing,
or
mobile/
modular
homes.
It
also
does
not
include
facilities
that
coat
wood
building
products
but
are
not
considered
commercial
manufacturers.

It
is
estimated
that
215
major
source
facilities
are
subject
to
the
provisions
of
this
NESHAP
in
the
United
States
and
must
be
in
compliance
with
the
requirements
of
the
wood
building
products
NESHAP
within
3
years
of
the
effective
date
(
promulgation
date)
of
the
rule.
No
new
growth
is
expected
in
the
wood
building
products
surface
coating
industry.

Respondents
to
this
ICR
are
required
to
submit
a
detailed
listing
of
coatings
and
solvents
used
during
coating,
thinning,
and
cleaning
operations.
This
report
should
include
the
amount
of
material
used
(
in
units
of
gallons
or
liters),
the
amount
of
solids
content
in
the
2
material
as
a
volume
percentage,
a
breakdown
of
HAP
contained
in
each
material
(
in
units
of
pounds
or
grams),
and
an
annual
organic
HAP
emission
rate
expressed
in
units
of
weight
of
organic
HAP
per
volume
of
solids.
This
information
should
be
collected
on
a
monthly
basis
and
submitted
on
a
semiannual
basis,
with
the
requirement
that
the
rolling
12­
month
emission
rate
not
exceed
the
limit
set
forth
by
this
NESHAP.
All
records
should
be
maintained
for
a
period
of
5
years
and
should
be
maintained
at
the
source
for
a
period
of
at
least
2
years.

The
wood
building
products
NESHAP
also
requires
new
or
reconstructed
and
existing
affected
sources
to
submit
a
one­
time
Initial
Notification.
This
Initial
Notification
must
be
submitted
no
later
than
120
calendar
days
after
the
promulgation
date
of
the
subpart
for
existing
sources.
For
new
or
reconstructed
sources
the
Initial
Notification
must
be
submitted
no
later
than
120
calendar
days
after
the
promulgation
date
or
no
later
than
120
calendar
days
after
the
startup
date,
whichever
is
later.

Owners
and
operators
of
affected
sources
are
subject
to
the
requirements
of
40
CFR
Part
63,
Subpart
A,
the
General
Provisions,
unless
the
regulation
specifies
otherwise.

The
wood
building
products
NESHAP
also
requires
affected
sources
to
submit
a
Notification
of
Compliance
Status.
This
notification
must
be
signed
by
a
responsible
company
official
who
certifies
its
accuracy
and
certifies
that
the
source
has
complied
with
the
standards.
In
addition,
the
affected
sources
using
add­
on
control
devices
to
meet
the
requirements
of
the
standard
are
required
by
the
Administrator
to
conduct
a
performance
test
of
the
add­
on
control
device.
The
results
of
the
performance
test
must
be
submitted
to
the
EPA
in
the
Notification
of
Compliance
Status.

For
new
or
reconstructed
and
existing
sources,
the
Notification
of
Compliance
Status
must
be
submitted
1
year
and
30
days
following
the
compliance
date,
and
must
include
the
results
of
the
performance
test
(
if
performance
testing
is
required).

Periodic
reports
documenting
deviations
are
also
required
to
be
submitted
to
the
EPA
semiannually
to
demonstrate
compliance.
The
periodic
reports
must
also
contain
documentation
of
inspections
and
a
statement
that
no
deviations
occurred
during
the
reporting
period,
if
appropriate.

The
wood
building
products
NESHAP
requires
owners
or
operators
using
capture
and
control
systems
to
develop
a
startup,
shutdown,
and
malfunction
plan
(
SSMP),
documenting
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
Startup,
shutdown,
and
malfunction
reports
also
are
required
to
be
submitted
that
demonstrate
that
the
actions
taken
by
an
owner
or
operator
during
a
startup,
shutdown,
or
malfunction
event
comply
with
the
SSMP.
When
actions
taken
are
consistent
with
the
plan,
reports
are
required
semiannually.
When
actions
taken
are
inconsistent
with
the
plan,
immediate
reports
are
required.
3
Each
facility
is
required
to
submit
all
necessary
reports
to
the
respondent's
Regional,
State,
local,
or
tribal
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.
The
EPA
is
charged
under
Section
112(
d)
of
the
CAA
to
establish
standards
to
limit
HAP
emissions
from
stationary
sources.
In
the
Administrator's
judgment,
the
wood
building
products
surface
coating
industry
causes
or
contributes
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Wood
building
products
surface
coating
operations
are
listed
as
an
affected
source
category
in
a
Federal
Register
revision
dated
November
18,
1999
(
64
FR
63025.)

Section
114
of
the
CAA
gives
EPA
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
Section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to:
(
1)
identify
new
or
reconstructed
and
existing
sources
subject
to
the
wood
building
products
NESHAP,
and
(
2)
ensure
that
the
wood
building
products
NESHAP,
based
on
maximum
achievable
control
technology
(
MACT)
for
major
sources,
is
being
achieved.

(
b)
Use/
Users
of
the
Data.
The
EPA's
enforcement
personnel
will
use
the
emissions
data
collected
by
each
wood
building
products
surface
coating
facility
to
(
1)
identify
new
or
reconstructed
and
existing
organic
HAP
emission
sources
subject
to
the
wood
building
products
NESHAP,
(
2)
identify
the
emission
control
devices
and
control
methodologies
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
control
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

The
records
and
reports
will
also
be
useful
in
identifying
facilities
that
are
out
of
compliance
with
the
terms
of
the
wood
building
products
NESHAP.
Based
on
the
reported
information,
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
indicates
to
EPA
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
control
methodologies
properly.
4
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.
A
search
of
EPA's
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
wood
building
products
NESHAP.
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
wood
building
products
NESHAP.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
Because
this
is
a
final
rule­
related
ICR,
it
is
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
ICR
to
OMB.

(
c)
Consultations.
Consultations
were
conducted
with
various
representatives
of
industry,
coating
suppliers,
and
trade
associations
during
the
development
of
the
wood
building
products
NESHAP.
The
following
persons
provided
input
during
development
of
the
rule:

Name
Affiliation
Telephone
Jim
Berry
Berry
Environmental
(
919)
785­
9631
Kurt
Bigbee
APA­
The
Engineered
Wood
Association
(
253)
565­
6600
Timothy
Boerst
ABTco
Inc
(
419)
535­
5921
John
Bradfield
Composite
Panel
Association
(
CPA)
(
301)
670­
0604
Jack
Burgess
AWI
(
910)
642­
7175
Erich
Burke
ABTco
Inc
(
800)
334­
3551
Allen
Campbell
National
Wood
Window
and
Door
Association
(
NWWDA)
(
847)
299­
5200
George
Carter
Laminating
Materials
Association
(
LMA)
(
201)
664­
2700
Mark
Collatz
Adhesives
and
Sealants
Council
(
202)
452­
1500
Maggie
Corbin
Puget
Sound
APCA
(
206)
869­
4057
Mary
Ellen
Roddy
NPCA
(
202)
462­
6272
Barbara
Francis
Chemical
Manufacturers
Association
(
CMA)
(
703)
741­
5609
Gary
Gramp
Hardwood
Plywood
and
Veneer
Association
(
HPVA)
(
703)
435­
2900
Madelyn
Harding
Sherwin­
Williams
(
216)
566­
2630
Gerald
Hoerber
Stimson
Lumber
Co
(
503)
357­
2131
Tim
Hunt
American
Forest
and
Paper
Association
(
AF&
PA)
(
202)
463­
2588
Allen
Irish
National
Paint
and
Coatings
Association
(
NPCA)
(
202)
462­
6272
Jim
Jaderholm
Woodgrain
Millwork
(
208)
452­
3801
Edward
Korczak
National
Wood
Flooring
Association
(
314)
391­
5161
Name
Affiliation
Telephone
5
Bob
Matejka
Akzo
Nobel
Coatings
Inc.
(
336)
801­
0872
David
Mazzocco
PPG
(
412)
492­
5476
Mickey
Moore
National
Oak
Flooring
Association
(
901)
526­
5016
Bob
Nelson
NPCA
(
202)
462­
6272
Carol
Niemi
CMA
Solvents
Council
(
517)
631­
4923
Jim
Rabe
Masonite
(
312)
634­
2690
Susan
Rasor
Kitchen
Cabinet
Manufacturers
Association
(
KCMA)
(
919)
484­
1619
Gary
Raven
Triangle
Pacific
(
800)
526­
0308
David
Ritchey
Architectural
Woodworking
Institute
(
AWI)
(
703)
733­
0600
Sherry
Stookey
Lilly
Industries
(
336)
802­
4305
Mike
Taylor
States
Industries
(
541)
461­
0877
Paul
Vasquez
Georgia
Pacific
Corporation
(
404)
652­
7327
Louis
Wagner
American
Hardboard
Association
(
AHA)
(
847)
934­
8800
Dave
Walters
Chesapeake
Hardwood
Products
(
757)
543­
1601
Robert
Weiglein
Wood
Molding
and
Millwork
Producers
Association
(
530)
661­
9591
Tammy
Wyles
Georgia
Pacific
Corporation
(
404)
652­
7281
(
d)
Effects
of
Less
Frequent
Collection.
If
results
were
collected
less
frequently,
there
would
be
little
assurance
that
each
source
was
in
compliance
during
the
previous
12­
month
period,
as
the
rule
requires.
Also,
EPA's
authority
to
take
administrative
action
would
be
reduced.

(
e)
General
Guidelines.
None
of
the
recordkeeping
or
reporting
requirements
contained
in
40
CFR
Part
63,
Subpart
QQQQ
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

(
f)
Confidentiality
Confidential
business
information
will
be
handled
using
EPA
guidelines
on
confidentiality,
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

(
g)
Sensitive
Questions.
Information
to
be
reported
consists
of
emission
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.
6
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes.
Respondents
are
owners
or
operators
of
facilities
that
surface
coat
wood
building
products.
The
following
is
a
list
of
Standard
Industrial
Classification
(
SIC)
and
newly
established
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
the
wood
building
products
industry.
Respondents
in
these
SIC/
NAICS
codes
are
only
affected
if
surface
coating
operations
are
performed
on
site.

The
SIC
codes
for
the
respondents
affected
by
this
standard
include:
2421
­
Sawmills
and
Planing
Mills,
General
2426
­
Hardwood
Dimension
and
Flooring
Mills
2431
­
Millwork
2435
­
Hardwood
Veneer
and
Plywood
2436
­
Softwood
Veneer
and
Plywood
2439
­
Structural
Wood
Member,
Not
Elsewhere
Classified
2493
­
Reconstituted
Wood
Products
2499
­
Wood
Products,
Not
Elsewhere
Classified
The
government
is
in
the
process
of
transitioning
to
the
NAICS
codes.
The
affected
NAICS
codes
include:
321211
­
Hardwood
Veneer
and
Plywood
Manufacturing
321212
­
Softwood
Veneer
and
Plywood
Manufacturing
321213
­
Engineered
Wood
Member
(
Except
Truss)
Manufacturing
321214
­
Truss
Manufacturing
321219
­
Reconstituted
Wood
Product
Manufacturing
321911
­
Wood
Window
and
Door
Manufacturing
321918
­
Other
Millwork
(
including
Flooring)
321999
­
All
other
Miscellaneous
Wood
Product
Manufacturing
This
list
is
not
meant
to
be
exhaustive;
other
SIC/
NAICS
Codes
could
be
included
if
the
facility
fulfills
the
definition
of
a
wood
building
product
and
performs
surface
coating.

(
b)
Information
Requested.
(
i)
Data
items,
including
recordkeeping
requirements
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63,
Subpart
QQQQ.
All
major
sources
must
fulfill
these
requirements.
7
Notifications
Initial
Notification
63.4710(
b),
63.5(
d),
63.9(
b)

Notification
of
Compliance
Status
63.4710
(
c),
63.9(
h)

Notification
of
Intent
to
Conduct
Performance
Test
63.7(
b)(
1),
63.8(
e)(
2),
63.9(
e)

Performance
test
and
evaluation
63.4710
(
c)(
9)(
ii),
63.7(
a),
63.7(
c),
63.7(
d),
63.7(
e),
63.7(
g),
63.8(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Notification
of
alternative
monitoring
method
63.8(
f)(
4)

Waiver
of
recordkeeping
or
reporting
requirements
63.10(
f)

Additional
notifications
63.9(
c),
63.9(
d),
63.9(
g)(
1),
63.9(
g)(
2),
63.9(
j)

Reports
Startup,
shutdown,
malfunction
reports
63.4720
(
c),
63.6(
e)(
3),
63.10(
d)(
5)(
i),
63.10(
d)(
5)(
i)

Semiannual
compliance
report
63.4720
(
a),
63.10(
e)

Deviation
and
CMS
performance
reports
63.10(
a)

Performance
test
reports
63.4720(
b),
63.10(
d)(
2),
63.10(
e)

Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

Emission
test
results
and
other
data
needed
to
determine
emissions,
operating
parameters,
etc.
63.4730(
b),
63.4730
(
c),
63.4730
(
d),
63.4730(
e),
63.4730(
f),
63.4730
(
g),
63.4730
(
h),
63.4730
(
k)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
b),
63.10(
c)

Records
of
maintenance
63.10(
b)(
2)

Startup,
shutdown,
and
malfunction
records
63.10(
b)(
2)(
i)
­
(
iv)

Records
for
initial
notification
and
notification
of
compliance
status
63.10(
b)(
2)(
xiv)

Records
are
required
to
be
retained
for
5
years.
All
MACT
standards
require
5
years
of
record
retention.
The
first
2
years
of
records
must
be
kept
onsite.
8
(
ii)
Respondent
Activities
Read
regulation.

Apply
for
waiver,
if
applicable.

Technical
activities.

Set­
up
and
maintain
coating
data
spreadsheet
for
regulation
compliance.

Train
coating­
related
personnel.

Write
Initial
Notification.

Write
Notification
of
Intent
to
Conduct
Performance
Test.

Write
Performance
Test
Report.

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

Attend
add­
on
control
device
performance
testing.

Repeat
performance
test.

A.
Retesting
preparation.

B.
Attend
retesting.

Reporting
requirements.

A.
Review
regulation.

B.
Review
waivers.

C.
Review
Initial
Notification.

D.
Review
performance
test
report.

(
b)
Collection
Methodology
and
Management.

Information
contained
in
the
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
The
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
5
years
and
maintained
at
the
site
for
2
years.
9
(
c)
Small
Entity
Flexibility.

This
industry,
including
small
businesses,
should
already
track
the
amount
of
coatings,
thinners,
and
cleaning
materials
used
for
costing
purposes,
via
purchase
orders
or
receipts.
These
methods
of
tracking
usages
will
be
sufficient
to
meet
the
recordkeeping
and
reporting
requirements
of
this
rule.
The
requirements
are
viewed
by
the
EPA
as
the
minimum
needed
to
ensure
compliance
and
cannot
reduce
them
further
for
small
entities.

(
d)
Collection
Schedule.

Collection
of
data
will
begin
after
the
promulgation
date
of
the
wood
building
products
NESHAP,
tentatively
scheduled
for
February
2003.
The
schedule
for
reports
required
by
the
wood
building
products
NESHAP
and
the
General
Provisions
is
detailed
below.

The
Initial
Notification
is
due
not
later
than
120
calendar
days
after
the
promulgation
date
of
the
subpart
for
all
existing
affected
sources.

The
Notification
of
Compliance
Status
must
be
submitted
1
year
and
30
days
following
the
compliance
date.
The
Notification
of
Compliance
Status
includes
performance
test
results
and
deviation
reports,
if
applicable.

Major
sources
are
required
to
submit
periodic
reports
on
a
semiannual
basis.
Major
sources
using
add­
on
control
devices
to
comply
with
the
NESHAP
must
submit
startup,
shutdown,
and
malfunction
reports
semiannually
when
actions
taken
in
the
event
of
a
startup,
shutdown,
or
malfunction
are
consistent
with
the
source's
SSMP.
If
actions
taken
are
not
consistent
with
the
source's
plan,
an
immediate
deviation
report
must
be
submitted.

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

The
existing
major
source
annual
burden
estimates
for
recordkeeping
and
reporting
are
presented
in
Tables
1
through
3.
These
costs
are
incurred
during
the
first,
second,
and
third
year
following
the
promulgation
date,
respectively.
The
annual
burden
estimates
are
based
on
an
estimated
215
major
affected
sources
in
the
wood
building
products
surface
coating
industry.
All
assumptions
made
in
the
labor
estimates
are
included
as
footnotes
to
the
tables.
Table
4
summarizes
these
costs
and
calculates
the
average
annual
respondent
burden.
10
As
shown
in
Table
4,
overall
labor
for
the
first
three
years
is
estimated
to
be
6,527
hours
and
$
315,004
for
all
215
major
source
facilities.
The
overall
capital
equipment
cost
is
$
64,700
for
all
215
major
source
facilities.
The
annual
average
burden
is
2,176
hours
and
$
127,235.

(
b)
Estimating
Respondent
Costs.

(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
calculated
for
the
affected
SIC
codes
listed
in
4(
a)
of
this
supporting
statement.
The
labor
rates
for
technical,
management,
clerical,
and
coating
operations
staff
were
calculated
using
Bureau
of
Labor
Statistics
data
for
SIC
codes
242,
243,
and
249.
For
each
staff
level,
a
weighted
average
was
calculated
for
the
affected
SIC
codes
of
2421,
2426,
2431,
2435,
2436,
2439,
2493,
and
2494.
The
fully
burdened
labor
rate,
which
includes
overhead,
profit,
and
all
employee
benefits,
was
found
by
summing
the
base
labor
rate
and
110
percent
of
the
base
labor
rate,
per
guidance
from
EPA's
Regulatory
Information
Department
(
RID).
The
hourly
rates
used
for
technical,
managerial,
clerical,
and
coating
operator
were
$
50.33,
$
59.75,
$
21.80,
and
$
20.65,
respectively.
These
labor
rates
were
then
applied
to
the
activities
required
in
4(
b)(
ii).
The
total
labor
required
for
the
entire
industry
of
215
major
sources
is
estimated
to
be
$
315,004.

(
ii)
Estimating
Capital
Costs
(
computer
equipment)

Recordkeeping
and
reporting
costs
assume
the
use
of
a
computer
and
software
for
tracking
the
coating
usages
for
each
facility.
Assumptions
were
made
concerning
the
cost
of
computer
equipment
and
the
number
of
respondents
required
to
buy
the
equipment.
A
cost
of
$
2000
for
the
equipment
was
estimated,
including
spreadsheet
software.
Facilities
using
more
than
100,000
gallons
per
year
were
excluded
because
of
the
assumption
that
computer
equipment
is
readily
available.
Of
the
estimated
industry
of
215
major
sources,
an
estimated
133
facilities
will
require
computer
equipment.
Assuming
that
a
new
computer
will
be
bought
every
5
years
and
the
interest
rate
is
7
percent,
the
capital
recovery
factor
is
0.2439.
Multiplying
the
capital
investment
cost
of
$
2000
by
the
capital
recovery
factor
yields
an
annualized
computer
equipment
cost
of
$
488
per
facility,
bringing
the
total
industry
cost
for
computer
equipment
to
approximately
$
64,700.

It
was
assumed
that
the
computer
equipment
will
be
purchased
in
year
three,
so
that
the
computer
system
will
be
functional
before
the
compliance
date.
Therefore,
the
capital
costs
are
shown
in
Table
3.
11
(
c)
Estimating
Agency
Burden
and
Cost.

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

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

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
shown
in
5(
a).
Labor
rates
and
associated
costs
are
based
on
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
These
hourly
rates
include
a
factor
of
1.6
to
account
for
employee
benefits.

The
activities
shown
in
5(
a)
are
divided
among
years
one,
two,
and
three
after
promulgation.
The
costs
and
related
assumptions
are
shown
in
Tables
5
through
7,
respectively.
The
total
agency
burden
for
the
first
three
years
following
promulgation
of
subpart
QQQQ
is
1,819
hours
and
$
76,317.
The
annual
agency
average
is
606
hours
and
$
25,439.
These
burden
estimates
are
shown
in
Table
8.

(
d)
Estimating
Respondent
Universe
and
Total
Burden
Cost.

The
number
of
existing
major
sources
subject
to
MACT
Subpart
QQQQ
is
215.
No
growth
is
expected
in
this
industry.
The
total
average
annual
labor
cost
for
the
industry
is
estimated
to
be
2,176
hours
and
$
127,235
for
the
215
major
sources.
This
cost
includes
labor
and
capital
equipment
costs.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

Please
refer
to
Table
4
and
Table
8.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
collection.
12
(
g)
Burden
Statement:

The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
5.06
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;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0002
,
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
2003­
0002).
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
Subpart
QQQQ
Coating
of
Wood
Building
Products
PART
B
OF
THE
SUPPORTING
STATEMENT
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
14
TABLE
1.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
4
1
4
215b
860
43
86
47,728
B.
Apply
for
waiver
6c
1
6
2d
12
1
1
666
C.
Required
activities
D.
Create
information
Incl.
in
3B
0
E.
Gather
existing
information
Incl.
in
3B
0
F.
Write
reports/
notifications
Write
initial
notification
2
1
2
215
426
21
43
23,642
TOTAL
ONE­
TIME
BURDEN
AND
COST
1,298
65
130
72,036
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
6
0
1
335
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
50.33,
management
at
$
59.75,
and
clerical
at
$
21.80.
The
composite
hourly
labor
rate
is
$
55.50/
hr
(
50.33
+
0.05
x
59.75
+
0.1
x
21.80
=
55.50).

b
Assumes
all
215
major
source
facilities
will
read
the
regulation.

c
From
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping."

d
Assumes
1%
of
215
major
source
facilities
will
apply
for
a
waiver.
15
TABLE
2.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
B.
Apply
for
waiver
C.
Required
activities
Technical
Set­
up
and
maintain
coating
data
spreadsheet
for
regulation
compliance
4
1
4
215
860
43
86
47,728
D.
Create
information
Incl.
in
3B
0
E.
Gather
existing
information
Incl.
in
3B
0
F.
Write
reports/
notifications
Write
notification
of
intent
to
conduct
performance
test
2
1
2
15b
30
2
3
1,665
TOTAL
ONE­
TIME
BURDEN
AND
COST
890
45
89
49,393
TOTAL
CAPITAL
EQUIPMENT
COSTS
(
COMPUTER
COSTS)
c
67,600
890
45
89
116,993
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
4
0
0
544
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
50.33,
management
at
$
59.75,
and
clerical
at
$
21.80.
The
composite
hourly
labor
rate
is
$
55.50/
hr
(
50.33
+
0.05
x
59.75
+
0.1
x
21.80
=
55.50).

b
Assumes
3
of
every
42
(
15
of
215)
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
the
NESHAP.

c
Assumes
133
of
the
215
major
source
facilities
will
have
to
purchase
computer
equipment:
$
2000
capital
investment
per
facility
every
5
years
($
488
per
facility
annualized).
See
Section
6(
b)(
ii)
of
Part
A
for
documented
assumptions.
16
17
TABLE
3.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
B.
Apply
for
waiver
C.
Required
activities
Technical
Training
of
coating­
related
personnel
each
year
4
4b
16
215
3,440
172
344
190,911
D.
Create
information
Incl.
in
3B
0
E.
Gather
existing
information
Incl.
in
3B
0
F.
Write
reports/
notifications
Write
performance
test
report
16
0.20c
3
15d
45
2
4
2,664
TOTAL
ONE­
TIME
(
LABOR)
BURDEN
AND
COST
3,488
174
349
193,575
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
16
1
2
900
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
50.33,
management
at
$
59.75,
and
clerical
at
$
21.80.
The
composite
hourly
labor
rate
is
$
55.50/
hr
(
50.33
+
0.05
x
59.75
+
0.1
x
21.80
=
55.50).

b
Assuming
an
average
of
37
coating
employees,
training
will
occur
quarterly
with
9
trainees
per
session.

c
Assumes
one
test
every
5
years
or
0.20
test
reports
per
year.

d
Assumes
3
of
every
42
(
15
of
215)
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
the
NESHAP.
18
TABLE
4.
SUMMARY
OF
INDUSTRY
BURDEN
FOR
THE
PROPOSED
STANDARDS
FOR
SURFACE
COATING
OF
WOOD
BUILDING
PRODUCTS
(
YEARS
1
THROUGH
3
AND
AVERAGE)

Year
Technical
hours
Management
hours
Clerical
hours
Total
hours
Labor
costs
Non­
labor
costs
Total
costs
Capital
costs
O&
M
costs
Year
1
1,298
65
130
1,493
$
72,036
$
0
$
0
$
72,036
Year
2
890
45
89
1,024
$
49,393
$
64,700
$
0
$
116,093
Year
3
3,488
174
349
4,011
$
193,575
$
0
$
0
$
193,575
Average
burden
2,176
$
105,001
$
21,567
$
0
$
127,235
19
TABLE
5.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
186
B.
Review
waivers
2
2
4
2b
8
0
1
372
C.
Review
reports/
notifications
Review
initial
notification
2
2
4
213
852
43
85
39,593
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
864
43
86
40,151
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
The
composite
hourly
labor
rate
is
$
46.47/
hr
(
40.80
+
0.05
x
67.44
+
0.1
x
22.99
=
46.47).
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
1%
of
215
major
source
facilities
will
apply
for
a
waiver.
20
TABLE
6.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
186
B.
Review
waivers
C.
Review
reports/
notifications
Review
notification
of
intent
to
conduct
performance
test
2
2
4
15b
60
3
6
2,788
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
64
3
6
2,974
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
The
composite
hourly
labor
rate
is
$
46.47/
hr
(
40.80
+
0.05
x
67.44
+
0.1
x
22.99
=
46.47).
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
3
of
every
42
major
sources
(
or
15
of
215)
will
use
add­
on
control
devices
to
comply
with
NESHAP.
21
TABLE
7.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
32
4.6b
147
3c
442
22
44
20,522
2.
Repeat
performance
test
A.
Retesting
preparation
12
4.6b
55
1d,
e
55
3
6
2,565
B.
Attend
retesting
32
4.6b
147
1e
147
7
15
6,841
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
186
B.
Review
waivers
C.
Review
reports/
notifications
Review
performance
test
report
2
0.2f
0
15g
6
0
1
279
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
654
33
65
30,392
ANNUAL
AVERAGE
TRAVEL
EXPENSESh
2,800
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
654
33
65
33,192
22
TABLE
7.
(
continued)

a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
The
composite
hourly
labor
rate
is
$
46.47/
hr
(
40.80
+
0.05
x
67.44
+
0.1
x
22.99
=
46.47).
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
4.6
add­
on
control
devices
per
facility.

c
Assumes
EPA
will
attend
20%
of
performance
tests
for
15
facilities
using
add­
on
control
devices.

d
Assumes
20%
of
facilities
will
fail
the
initial
performance
test
and
all
those
who
fail
will
repeat
it.

e
Assumes
EPA
will
attend
25%
of
the
retests.

f
Assumes
one
performance
test
per
facility
with
add­
on
control
devices
every
five
years
(
or
0.20
reports
per
year).

g
Assumes
3
of
every
42
major
sources
(
or
15
of
215)
will
use
add­
on
control
devices
to
comply
with
NESHAP.

h
Assumes
performance
tests
require
4
days
per
facility:
(
Travel
costs=
[(
1
person
x
(
3+
1)
facilities/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(
3+
1)

round
trips/
yr)])
23
TABLE
8.
SUMMARY
OF
AGENCY
BURDEN
HOURS
AND
COSTS
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
Total
burden
(
hours)
Total
costs
($)

First
year
following
the
effective
date
994
$
40,151
Second
year
following
the
effective
date
74
$
2,974
Third
year
following
the
effective
date
752
$
33,192
Total
1,819
$
76,317
Bottom
line
annual
burden
606
$
25,439
24
ATTACHMENT
1
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
25
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
1.
The
Information
Collected
B­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
there
are
many
one­
time
activities
that
occur
in
the
three
years
between
the
effective
date
and
the
compliance
date
of
the
regulation.
These
include
the
Initial
Notification,
the
Notification
of
Intent
to
Conduct
a
Performance
Test,
performance
test
report,
buying
computer
equipment,
setting
up
a
spreadsheet
tracking
system,
and
training
the
coating
personnel
to
accurately
track
coating
usages.

In
the
three
years
following
the
compliance
date,
there
are
recurrent
activities
that
are
required
of
the
respondents.
These
include
training,
coordinating
the
transfer
of
information
between
departments,
checking
spreadsheets
for
accuracy,
compiling
and
maintaining
records
of
coatings
data
each
week,
calculating
monthly
organic
HAP
emissions,
adjusting
process
to
comply
with
standard,
calculating
12­
month
rolling
average
organic
HAP
emissions,
entering
data
into
spreadsheet,
tracking
coating
usage
in
spreadsheet
or
log
book,
writing
semiannual
report,
writing
compliance
status
report,
writing
report
of
no
deviations,
and
writing
deviation
report
(
if
necessary).

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
the
agency
burden
include
many
one­
time
activities
during
the
three
years
between
the
effective
date
and
the
compliance
date.
These
include
reviewing
the
notifications,
and
attending
the
performance
testing
and
re­
testing,
if
needed.

During
the
three
years
following
the
compliance
date,
the
agency
burden
increases
with
recurrent
activities
such
as
responding
to
deviations
through
enforcement
activities,
reviewing
regulation,
reviewing
semiannual
reports,
reviewing
compliance
status
reports,
reviewing
reports
of
no
deviations,
and
reviewing
deviation
reports.
26
2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.

This
ICR
uses
labor
rates
calculated
for
the
affected
SIC
codes
listed
in
4(
a)
of
the
Supporting
Statement.
The
labor
rates
for
technical,
management,
clerical,
and
coating
operations
staff
were
calculated
using
Bureau
of
Labor
Statistics
data
for
SIC
codes
242,
243,
and
249.
For
each
staff
level,
a
weighted
average
was
calculated
for
the
affected
SIC
codes
of
2426,
2421,
2431,
2435,
2436,
2439,
2493,
and
2494.
The
fully
burdened
labor
rate,
which
includes
overhead,
profit,
and
all
employee
benefits,
was
found
by
summing
the
base
labor
rate
and
110%
of
the
base
labor
rate,
per
guidance
from
EPA's
Regulatory
Information
Department
(
RID).
The
hourly
rates
used
for
technical,
managerial,
clerical,
and
coating
operator
were
$
50.33,
$
59.75,
$
21.80,
and
$
20.65,
respectively.

Since
the
respondent
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
1,
along
with
all
assumptions
made.
For
these
three
years,
the
total
burden
to
the
215
major
sources
is
estimated
to
be
$
5,611,858.
The
labor
requirements
total
204,757
hours
annually.

(
ii)
Estimating
capital
costs.

There
are
no
capital
costs
estimated
for
the
three
years
following
the
compliance
date.

(
b)
Estimating
Agency
Burden
and
Costs
Labor
rates
and
associated
costs
are
based
on
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
These
hourly
rates
include
a
factor
of
1.6
to
account
for
employee
benefits.

Since
the
agency
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
2,
along
with
all
assumptions
made.
For
these
three
years,
the
total
agency
burden
is
estimated
to
be
$
82,432
annually.
The
labor
requirements
total
2,010
hours
annually.
27
TABLE
1.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
1
1
1
215b
215
11
22
11,932
B.
Required
activities
Technical
Training
of
coating­
related
personnel
each
year
4
4c
16
215
3,440
172
344
190,911
Coordinate
purchasing,

operations
and
clerical
for
information
transfer
1
12
12
215
2,580
129
258
143,184
Check
spreadsheet
for
data
entry
errors
weekly
1
50
d
50
215
10,750
538
1,075
596,598
Compile
and
maintain
records
of
coatings
data
each
week
1.5e
50d
75
215
16,125
806
1,613
894,897
Using
compiled
data,
adjust
process
to
comply
with
standard
every
quarter
2
4
8
215
1,720
86
172
95,456
Clerical
Enter
data
into
spreadsheet
to
tabulate
information
each
day
1f
250g
250
215
0
0
53,750h
1,171,750
Operations
Track
coating
usage
in
spreadsheet
or
log
book
each
shift
1i
500j
500
215
107,500
0
0
2,219,875k
D.
Create
information
Incl.
in
3B
0
E.
Gather
existing
information
Incl.
in
3B
0
F.
Write
semi­
annual
report
28
TABLE
1.
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
Write
compliance
status
report
4e
2
8
213l
1,704
85
170
94,568
Report
of
no
deviations
8e
2
16
213l
3,4408
170
341
189,135
Write
deviation
report
16e
2
32
2m
64
3
6
3,552
TOTAL
RECURRENT
BURDEN
AND
COST
147,506
2,000
55,251
5,611,858
AVERAGE
RECURRENT
BURDEN
AND
COST
PER
FACILITY:
686
9
257
26,102
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
50.33,
management
at
$
59.75,
and
clerical
at
$
21.80.
The
composite
hourly
labor
rate
is
$
55.50/
hr
(
50.33
+
0.05
x
59.75
+
0.1
x
21.80
=
55.50).

b
Assumes
all
215
major
source
facilities
will
read
the
regulation.

c
Assuming
an
average
of
37
coating
employees,
training
will
occur
quarterly
with
9
trainees
per
session.

d
Assumes
50
weeks
per
year.

e
From
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping".

f
Assumes
11
coatings
per
line
and
3
lines
per
facility
with
2
shifts,
requiring
1
minute
per
entry.

g
Assumes
50
weeks
per
year
and
5
days
per
week.

h
Assumes
clerical
instead
of
technical
labor
rate
for
data
entry.
(
G=
C
x
D)

i
Assumes
11
coatings
per
line
and
3
lines
per
facility,
requiring
2
minutes
per
entry
per
shift.

j
Assumes
2
shifts
per
day,
5
days
per
week,
and
50
weeks
per
year.

k
Cost
is
based
on
a
Coating,
Painting
and
Spraying
Machine
Operator
weighted
labor
rate
of
$
20.65.

l
Assumes
99%
of
215
major
source
facilities
will
be
in
compliance.

m
Assumes
1%
of
215
major
source
facilities
will
be
out
of
compliance.
29
TABLE
2.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
THE
AGENCY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
WOOD
BUILDING
PRODUCTS
(
SURFACE
COATING)
NESHAP
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
A.
Retesting
preparation
B.
Attend
retesting
3.
Deviations­­
enforcement
activities
16b
1
16
2c
32
2
3
1,487
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
186
B.
Review
waivers
C.
Review
semi­
annual
reports
Review
compliance
status
report
2
2
4
213d
852
41
81
39,593
Review
performance
test
report
Review
report
of
no
deviations
2
2
4
213d
852
41
81
39,593
Review
deviation
report
2
2
4
2c
8
0
1
372
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
1,668
83
167
81,232
ANNUAL
AVERAGE
TRAVEL
EXPENSESe
1,200
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
1,668
83
167
82,432
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
The
composite
hourly
labor
rate
is
$
46.47/
hr
(
40.80
+
0.05
x
67.44
+
0.1
x
22.99
=
46.47).
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
an
EPA
follow­
up
visit
of
2
days
per
deviation
report.

c
Assumes
1%
of
215
major
source
facilities
will
be
out
of
compliance.

d
Assumes
99%
of
215
major
source
facilities
will
be
in
compliance.
30
e
Assumes
performance
tests
require
4
days
per
facility
and
enforcement
visits
require
2
days
per
facility:
[
Travel
costs=
[(
1
person
x
(
3+
1)
facilities/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(
3+
1)
round
trips/
yr)]
+
[(
1
person
x
2
facilities/
yr
x
2
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
2
round
trips/
yr)]
