SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standard
(
NSPS)
was
proposed
on
February
18,
1987,
and
promulgated
on
February
26,
1988.
These
standards
apply
to
each
wood
heater
manufactured
on
or
after
July
1,
1988,
or
sold
at
retail
on
or
after
July
1,
1990.
Wood
heaters
manufactured
on
or
after
July
1,
1990,
or
sold
at
retail
on
or
after
July
1,
1992,
must
meet
more
stringent
emission
standards.
Approximately
54
manufacturers,
875
retailers,
and
5
certification
laboratories
are
currently
subject
to
the
regulations.
No
increase
is
expected
in
those
estimates
over
the
next
three
years.
Particulate
matter
(
PM)
is
the
pollutant
regulated
under
the
standards.

Two
features
of
this
rulemaking
which
are
unique
to
the
NSPS
program
require
emphasis
at
the
outset.
First,
these
standards
were
negotiated
by
representatives
of
groups
affected
by
the
NSPS,
including
those
groups
which
are
burdened
by
the
information
collection
activities.
None
of
these
activities
were
judged
to
be
unreasonable
by
these
representatives.
Some
of
these
provisions
were
recommended
by
the
affected
groups
as
a
means
of
promoting
an
efficient
and
smooth­
running
certification
and
enforcement
program.
Second,
these
regulations
established
a
certification
program
instead
of
the
usual
NSPS
requirement
that
each
affected
facility
demonstrates
compliance
through
New
Source
Review
and
testing.
Under
this
certification
program
a
single
wood
heater
is
tested
to
demonstrate
compliance
for
an
entire
model
line,
which
could
consist
of
thousands
of
stoves.
The
certification
approach
significantly
reduces
the
compliance
burden,
including
information
collection
for
the
manufacturers
of
wood
heaters.
Because
of
the
potential
risks
to
the
environment
from
the
intentional
or
accidental
misuse
of
the
certification
approach,
there
were,
however,
several
safeguards
included,
some
of
which
entail
reporting
and
recordkeeping.

Under
this
regulation,
wood
heater
manufacturers,
testing
laboratories,
and
retailers
are
required
to
submit
reports
to
the
Environmental
Protection
Agency
(
EPA)
and/
or
to
maintain
records
for
demonstrating
compliance
with
the
NSPS.

The
information
supplied
by
the
manufacturer
to
the
Agency
is
used:
(
1)
to
ensure
that
best
demonstrated
technology
is
being
applied
to
reduce
emissions
from
wood
heaters;
(
2)
to
ensure
that
the
wood
heater
tested
for
certification
purposes
is
in
compliance
with
the
applicable
emission
standards;
(
3)
to
provide
assurance
that
nontested
production
model
heaters
have
emission
performance
characteristics
similar
to
tested
models;
and
(
4)
to
provide
an
indicator
of
2
continued
compliance.

Information
supplied
to
the
Agency
by
testing
laboratories
is
used
to
grant
or
deny
laboratory
accreditation,
and
to
assist
in
enforcement
and
compliance
activities.
Information
requested
by
the
Agency
from
manufacturers
is
used
to
determine
compliance
with
requirements
that
are
based
upon
volume
of
production.

The
previous
Information
Collection
Request
(
ICR)
had
the
following
Terms
of
Clearance
(
TOC):

When
EPA
submits
this
ICR
for
renewal,
it
must
evaluate,
after
consulting
with
respondents,
the
burden
estimates
for
reporting
and
recordkeeping
requirements.
As
part
of
its
submission,
EPA
should
also
verify
that
the
wage
rates
referenced
in
Section
6(
b)
of
the
supporting
statement
have
been
properly
loaded
to
include
overhead,
consistent
with
current
EPA
and
OMB
guidelines.
Furthermore,
EPA
should
update
its
labor
estimates,
distinguishing
between
management
and
technical
staff
hours
and
wages.

EPA
has
addressed
each
item
of
concern
in
the
TOC.
The
wage
rates
referenced
in
Section
6(
b)
of
the
supporting
statement
have
been
properly
loaded
to
include
overhead
consistent
with
current
EPA
and
OMB
guidelines.
The
supporting
statement
also
contains
updated
labor
estimates,
distinguishing
between
management
and
technical
staff
hours
and
wages
as
required
by
the
TOC.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.
Section
111(
a)(
l).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.
3
In
the
Administrator's
judgment,
pollutant
emissions
from
wood
heaters
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
was
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
AAA.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
pollution
from
new
residential
wood
heaters
(
i.
e.,
wood
stoves)
relies
on
the
reduction
of
particulate
matter
emissions
by
proper
wood
heater
design.
A
representative
unit
for
each
certified
model
line
is
tested
for
particulate
emissions.
The
manufacturer
also
conducts
periodic
quality
assurance
inspections
and
emissions
tests
to
ensure
that
wood
heaters
manufactured
subsequent
to
the
initial
certification
test
continue
to
comply
with
the
NSPS.
Manufacturers
must
recertify
their
wood
heater
model
lines
every
five
years.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
new
model
line
is
expected
to
be
tested.
The
reviewing
authority
may
then
observe
the
testing
operation,
if
necessary.
Emission
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
model
line's
initial
capability
to
comply
with
the
emission
standard,
and
to
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.

Adequate
recordkeeping
and
reporting
are
necessary
to
ensure
compliance
with
these
standards
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subpart
AAA.

3(
a)
Nonduplication
The
NSPS
has
not
been
delegated
to
state
agencies
or
EPA
regional
offices.
All
reports
are
sent
directly
to
the
EPA
headquarters.
Therefore,
no
duplication
in
reporting
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
68
FR
27059)
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
The
EPA
concludes
that
the
average
cost
wood
heater
manufacturers
pay
to
laboratories
4
to
conduct
certification
testing
increased
from
$
7,500
per
test
to
$
10,000
per
test
since
the
last
ICR
was
published.
This
increase
is
based
on
information
received
from
Richard
Sparwassar
from
Omni
Environmental
Services,
an
EPA­
accredited
wood
heater
testing
laboratory.
His
phone
number
is:
(
503)
643­
3788.

Additionally,
the
number
of
respondents
increased
from
50
to
54.
These
figures
are
based
on
consultations
with
John
Crouch
from
the
Hearth,
Patio
and
Barbecue
Association
(
HPBA).
His
phone
number
is:
(
916)
536­
2390.
Industry
statistical
information
received
from
HPBA
was
also
used
to
determine
the
number
of
respondents.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
Section
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications,
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
The
retention
of
records
for
five
years
allows
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
5
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
and
NAICS
Codes
The
United
States
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standards
are
3433,
3631,
and
8734
which
correspond
to
the
North
American
Industry
Classification
System
(
NAICS)
codes
333414,
335221,
and
541380
for
source
category
description.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
NSPS
for
New
Residential
Wood
Heaters
40
CFR
part
60,
subpart
AAA.

Manufacturers,
testing
laboratories
and
retailers/
distributors
of
new
residential
wood
heaters
must
make
the
following
reports:

Reports
for
NSPS
subpart
AAA
The
reporting
requirements
for
NSPS
subpart
AAA
were
uniquely
designed
for
the
manufacturers,
testing
laboratories
and
retailers/
distributors
of
new
residential
wood
heaters.
A
special
table
is
attached
that
describes
the
requirements
in
detail.
See
Table
A.
Respondent
Reporting
and
Recordkeeping,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).
See
Table
A
Recordkeeping
for
NSPS
subpart
AAA
The
recordkeeping
requirements
for
NSPS
subpart
AAA
were
uniquely
designed
for
the
manufacturers,
testing
laboratories
and
retailers/
distributors
of
new
residential
wood
heaters.
A
special
table
is
attached
that
describes
the
requirements
in
detail.
See
Table
A.
Respondent
Reporting
and
Recordkeeping,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).
See
Table
A
Electronic
Reporting
No
special
automated,
mechanical,
or
technical
collection
techniques
are
used
to
6
collect
information.

The
reports
that
are
submitted
by
the
manufacturer
to
EPA
either
are
very
voluminous
(
e.
g.,
the
application
for
model
line
certificate)
or
performed
infrequently.
Therefore,
the
electronic
submission
of
such
reports
is
not
considered
economically
viable.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Manufacturers
must
obtain
a
certificate
of
compliance
for
each
model
line
of
wood
heater
to
be
manufactured/
sold
and
conduct
quality
assurance
activities.

Laboratories
must
install,
calibrate,
maintain,
and
operate
the
appropriate
equipment
and
demonstrate
their
proficiency
at
performing
the
required
tests
(
emission,
burn
rate
and
air­
to­
fuel
ratio).

Retailers/
distributors
must
maintain
sale
records
of
used
wood
heaters.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

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

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

Transmit,
or
otherwise
disclose
the
information.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
7
and
distribution
of
the
required
information.

Agency
Activities
The
Agency
activities
for
NSPS
subpart
AAA
are
in
response
to
a
uniquely
designed
rule.
A
special
table
is
attached
that
describes
the
requirements
in
detail.
See
Table
B.
Agency
Activities,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).
See
Table
B
5(
b)
Collection
Methodology
and
Management
All
reports
are
sent
directly
to
the
Agency.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.

Information
contained
in
the
reports
is
systematically
filed
at
EPA
headquarters.
Portions
of
the
data
are
entered
into
a
special
database
program
maintained
exclusively
by
the
Agency
for
later
retrieval,
study
and
essential
reports.

Public
access
to
the
wood
heater
database
can
be
obtained
by
writing
to
the
Agency.
Reports
of
wood
heaters
currently
certified
are
commonly
requested
by
retailers
and
the
general
public.

Records
required
by
this
NSPS
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
Virtually
all
of
the
manufacturers,
laboratories,
and
commercial
owners
affected
by
this
proposed
regulation
are
considered
small
businesses
based
on
the
definition
used
by
the
Small
Business
Administration.
Special
efforts
taken
by
the
Agency
to
minimize
burden
to
these
respondents
are
summarized
elsewhere
in
this
supporting
statement.

Since
this
rule
was
developed
through
the
regulatory­
negotiation
process,
industry
representatives
directly
participated
in
the
writing
of
the
rule
and
agreed
to
make
all
of
the
required
reports
and
keep
the
appropriate
records
as
specified
in
the
rule.

Additional
efforts
were
taken
by
the
Agency
to
reduce
the
burden
imposed
on
the
smallest
businesses
affected
by
this
regulation.
Provisions
were
included
which
allow
delayed
compliance
of
up
to
one
year
for
those
manufacturers
producing
fewer
than
2,000
wood
heaters
per
year.
In
addition,
less
frequent
quality
assurance
emission
audits
were
required
for
those
manufacturers
that
produce
fewer
than
2,500
wood
heaters
within
a
model
line.
The
wood
heater
standards
also
allow
small
manufacturers
to
purchase
a
certified
design
from
another
manufacturer.
In
this
case,
8
no
certification
testing
is
required.
This
provision
has
significantly
reduced
the
burden
associated
with
certification
process
for
small
manufacturers
of
wood
heaters.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.

The
information
collection
under
this
rule
is
consistent
and
compatible,
to
the
maximum
extent
practicable,
with
the
respondents
existing
reporting
or
recordkeeping
practices.
Since
the
last
ICR,
there
are
no
new
rule
requirements
that
would
require
the
respondent
to
adjust
their
existing
recordkeeping
or
reporting
from
previously
applicable
instructions.
Responses
to
this
information
collection
are
mandatory.

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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
9,728
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
wood
heater
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
64.13
per
hour,
a
Managerial
Labor
Rate
of
$
93.04
and
a
Clerical
Labor
rate
of
$
39.65.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rate
is
from
column
1,
"
Total
compensation."
These
rates
have
been
9
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
93.04
($
44.33
+
110%)
Technical
$
64.13
($
64.13
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Data
Collection
Device
(
B)
Capital/
Startup
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost
(
B
X
D)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondent
s
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Sampling
Trains
$
6,500
0
0
$
500
5
$
2,500
Certification
Test
a
$
10,000
72
$
720,000
0
0
0
Cost
of
Permanent
Label
b
$
2
162,000
$
324,000
0
0
0
Removable
Label
Purchase/
Printing
Cost
c
$
0.75
162,000
$
121,500
0
0
0
QA
Emissions
Test
d
$
7,500
24
$
180,000
0
0
0
Totals
$
1,345,500
$
5
$
2,500
a
Each
of
the
54
manufacturers
is
assumed
to
pay
$
10,000
per
certification
test
for
four
tests
over
three
years
(
1.33
tests
per
year).
1.33
x
54
=
72.
This
cost
is
assumed
to
include
the
cost
incurred
by
the
laboratory
to
seal
the
certified
stove.
There
are
essentially
no
burden
hours
associated
with
this
cost.
b
Total
costs
of
permanent
labeling
are
estimated
at
$
2.00
per
stove.
There
are
essentially
no
burden
hours
associated
with
this
cost.
There
are
an
expected
3,000
new
woodstoves
produced
annually
per
manufacturer
(
3,000
x
54
=
162,000).
c
Removable
labels
estimated
to
cost
$
0.75
per
label.
There
are
an
expected
3,000
new
woodstoves
produces
annually
per
manufacturer
(
3,000
x
54
=
162,000).
d
Assumes
an
emissions
test
is
performed
once
every
5,000
units
and
since
750
units
are
produced
each
year
for
each
model,
0.15
emission
tests
are
performed
annually
per
manufacturer
per
model.
Each
manufacturer
has
three
models,
therefore
.45
emissions
tests
per
manufacturer
will
be
conducted
(
0.15
x
3
=
0.45).
There
are
54
manufacturers
(.
45
x
54
=
24).
10
The
total
capital/
startup
costs
for
this
ICR
are
$
1,345,500
(
column
D).
The
number
of
new
respondents
above
includes
the
number
of
new
residential
wood
heaters
manufactured
per
year.
This
is
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
2,500.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
(
i.
e.,
$
1,349,000)
have
been
calculated
as
the
addition
of
the
capital/
startup
costs
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
Total
annualized
costs
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
258,177.
This
cost
is
based
on
the
average
hourly
labor
rates
in
the
table
below.
The
labor
rates
incorporate
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses.

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
934
respondents
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
11
Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
59
875
0
934
2
0
59
875
0
934
3
0
59
875
0
934
Average
0
59
875
0
934
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
934.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
respondents
has
increased
from
54
in
the
previous
ICR
to
934
in
this
ICR
due
to
the
inclusion
of
875
respondents
that
keep
records
but
do
not
submit
reports.

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

Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Respondents
(
C)
Number
of
Existing
Respondents
1
(
D)
Number
of
Reports
for
Existing
Respondents
(
F)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
0
0
59
3.2
0
189
1
Does
not
include
respondents
that
do
not
submit
reports.

The
number
of
Total
Annual
Responses
is
189.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

It
should
be
noted
that
the
number
of
responses
in
the
previous
ICR
(
i.
e.,
3,093)
is
significantly
different
from
the
number
of
responses
in
this
ICR
(
i.
e.,
189).
The
previous
ICR
counted
each
data
point
collected
as
a
response
instead
of
the
number
of
reports
submitted
plus
the
number
of
respondents
that
do
not
keep
records.
In
this
ICR,
the
correct
number
of
responses
is
shown.
12
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
615,367.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
1,349,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached
as
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA).
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
51
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
burden
has
increased
because
the
number
of
accredited
laboratories
increased
from
4
to
5
and
the
number
of
manufacturers
increased
from
50
to
54.
In
addition,
the
inclusion
of
managerial
and
clerical
labor
costs
that
were
not
included
in
the
previous
ICR
also
increased
the
labor
cost
burden.
There
were
also
mathematical
adjustments.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
51
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
13
Docket
ID
Number
OECA
2003­
0021,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
DOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
DOCKET
to
submit
or
to
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.
When
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
Number
OECA­
2003­
0021
and
OMB
Control
Number
2060­
0161
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
14
Table
A
Respondent
Reporting
and
Recordkeeping
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Regulatory
Reference
Regulated
Reporting/
Recordkeeping
Frequency/
Other
Title
40,
Part
60
Entity
Requirement
Comments
60.533(
f)(
l)
Manufacturer
Report:
Notification
of
Once
per
model.

certification
testing
at
least
30
days
prior
to
test.

60.533(
b)
Manufacturer
Report:
Application
for
certification
Once
for
each
model
line
for
each
Includes
indentifying
characterization
phase
of
the
standard
(
unless
wood
date,
complete
certification
test
heater
qualifies
for
Phase
II
results,
and
various
affirmations
of
standard).
Must
reapply
every
5
compliance.
years.

60.537(
f)
Manufacturer
Report:
To
EPA
certifying
that
model
Every
2
years.

line
is
unchanged.

60.536(
a)
Manufacturer
Report:
Produce
and
apply
permanent
One
per
unit
produced.

label.

60.536(
i)
Manufacturer
Produce
and
apply
removable
label.
One
per
unit
produced.

60.536(
l)
Manufacturer
Develop
and
publish
owners
manual.
One
per
unit
produced.
15
Table
A,
Continued
Respondent
Reporting
and
Recordkeeping
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Regulatory
Reference
Regulated
Reporting/
Recordkeeping
Frequency/
Other
Title
40,
Part
60
Enity
Requirement
Comments
60.533(
o)(
3)
Manufacturer
Report:
Notify
EPA
that
a
Q.
A.
Once
for
each
Q.
A.
emission
test.

emissions
test
will
be
conducted
w/
in
one
week
of
the
mailing
of
the
notice.

Submit
test
report
for
accelerated
Q.
A.

[(
o)(
3)(
iii)]*

60.537(
a)(
2)
Manufacturer
Maintain
records
of
all
certification
data.
Once
per
model.

60.533(
o)
Manufacturer
Recordkeeping
of
results,
remedial
Parameter
inspections
every
150
&
measures
taken
pursuant
to
quality
units.
Emission
tests
vary
according
60.537(
a)(
3),
assurance
program.
to
manufacturer
size
and
(
a)(
4)
certification
results.

60.537(
a)(
5)
Manufacturer
Maintain
records
of
the
number
of
wood
Continuously
through
production
heaters
sold
each
year.
year.

60.537(
g)
Manufacturer
Recordkeeping
for
all
models
and
units
Variable
unpredictable.

exempted
under
R
and
D
provision.

60.537(
c)
Manufacturer
Retain
sealed
wood
heater
for
the
life
of
One
for
each
certified
model.

the
model.
16
Table
A,
Continued
Respondent
Reporting
and
Recordkeeping
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Regulatory
Reference
Regulated
Reporting/
Recordkeeping
Frequency/
Other
Title
40,
Part
60
Enity
Requirement
Comments
60.533(
i)*
Manufacturer
Report:
Request
for
waiver
of
testing
Once
per
model,
if
at
all.

requirement
for
certification
testing.

60.533(
h)(
3)**
Manufacturer
Report:
Application
for
alternative
Once
per
model,
if
at
all.

certification.

60.533(
k)(
l)
Manufacturer
Report:
Request
for
waiver
of
the
Variable.

requirement
that
a
model
line
be
recertified
when
changes
exceed
specified
tolerances.

60.533(
p)(
5)**
Manufacturer
Development
of
documentation
to
rebut
Variable,
but
no
more
than
one
for
presumption
of
audit
failure.
every
four
certified
models.

60.535(
a)(
1)
Laboratory
Report:
Application
for
accreditation.
One
per
lab.

60.535(
b)(
5)
Laboratory
Report:
Proficiency
test
and
all
test
At
time
of
application
and
annually.

documentation.

60.535(
b)(
3)
Laboratory
Keep
records
of
audit
tests.
Once
for
each
five
certification
tests.
17
Table
A,
Continued
Respondent
Reporting
and
Recordkeeping
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Regulatory
Reference
Regulated
Reporting/
Recordkeeping
Frequency/
Other
Title
40,
Part
60
Enity
Requirement
Comments
60.534(
e)(
1)(
3)
Laboratory
Report:
To
EPA
changes
in
testing
Once
per
test.

schedule
or
interruptions
in
testing.

60.537(
b)(
1)
Laboratory
Maintain
records
of
certification
Once
per
certified
model.

test
data.

60.535(
g)
Laboratory
Recordkeeping.
Seal
each
Once
per
model
certified.

certified
woodheater.

60.533(
h)(
4)**
Laboratory
Report:
Submission
of
preliminary
Once
per
model,
if
at
all.

test
reports
from
laboratory
to
EPA
and
manufacturer
for
wood
heaters
which
exceed
emission
limits.
Report
is
submitted
within
10
days
of
test
completion.
(
This
provision
for
wood
heaters
which
have
been
granted
alternative
certification,
only.)

60.537(
h)
Commercial
Name
and
address
of
previous
owner
of
Variable.
18
Owner
(
e.
g.,
a
used
stove
that
he
has
purchased
or
retailer)
obtained
as
a
trade
in.
19
Table
A,
Continued
Respondent
Reporting
and
Recordkeeping
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

*
This
is
associated
with
an
exemption
or
waiver
(
which
would
eliminate
other
reporting
and
recordkeeping
burdens)
and,

therefore,
is
not
counted
as
a
burden
in
the
calculation.

**
This
is
not
a
routine
report.
It
is
a
provision
for
an
extraordinary
circumstance
and,
therefore,
is
not
included
in
the
calculations
because
it
is
very
unlikely
to
occur
during
the
next
3
years.
20
Table
B
Agency
Activities
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Regulatory
Reference
Title
40,
Part
60
Agency
Reporting/
Recordkeeping
Frequency/
Other
Comments
60.533(
1)(
2)*
EPA
Report:
Notice
of
revocation
Once
per
model,
if
at
all.

of
certification.

60.533(
p)(
5)(
B)*
EPA
Issue
notification
of
audit
Variable,
but
no
more
than
one
test
failure
and
certificate
for
every
four
certified
suspension
or
revocation.
models.

60.535(
b)
EPA
Evaluate
laboratory
Annually
proficiency
tests.

60.535(
e)*
EPA
Notice
of
intention
to
Variable
and
infrequent.

revoke
laboratory
accredition
with
justification
and
basis.

60.539*
Manufacturer
Various
requests,
submittals,

EPA
motions,
filings,
etc.
under
hearing
and
appeal
procedures.

*
This
is
not
a
routine
report.
It
is
a
provision
for
an
extraordinary
circumstance
and,
therefore,
is
not
included
in
the
calculations
because
it
is
very
unlikely
to
occur
during
the
next
3
years.
21
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters,

(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Burden
Items
Wood
Heater
Regulation
Citation
(
A)
a
(
B)
(
C)
a
(
D)
(
E)
a
(
F)
(
G)
(
H)

Person
Hours
Per
Occurrence
Number
Of
Occurrences
Per
Respondent
Per
Year
Technical
Person
Hours
Per
Respondent
Per
Year
(
C=
AxB)
Respondents
Per
Year
Technical
Person
Hours
Per
Year
(
E=
CxD)

E=
CxD
Management
Person
Hours
Per
Year
=
Ex5%
Clerical
Person
Hours
Per
Year
=
Ex10%
Cost
Dollars
Per
Year
Manufacturers
­

Reporting
Requirements
1)
Certification
Test
Notification
b
60.533(
f)(
1)

&
60.534(
e)
2
1.33
2.66
54
143.6
7.2
14.4
$
10,449.38
2)
Application
For
Certification
c
60.533(
b)
8
1.33
10.64
54
574.6
28.7
57.6
$
41,801.64
3)
Biennial
Reporting
For
Certified
Models
d
60.537(
f)
2
0.50
1.00
54
54.0
2.7
5.4
$
3,928.34
4)
Labeling
Labor
Cost
Removable
Label
e
60.536(
i)
0.0083
3000
24.9000
54
1,344.60
67.2
134.5
$
97,815.62
5)
Owner's
Manual
f
60.536(
l)
20
1.00
20.00
54
1,080.00
54
108
$
78,566.76
6)
Q.
A.
Emission
Test
Notification
g
60.533(
o)(
3)
2
0.80
1.60
54
86.4
4.3
8.6
$
6,285.34
Manufacturers
­
Recordkeeping
Requirements
60.537(
a)

1)
Test
Documentation
h
60.537(
a)(
1,2)
1
1.33
1.33
54
71.8
3.6
7.2
$
5,224.69
2)
Q.
A.
Parameter
Inspections
i
60.537(
a)(
3)
2
20.00
40.00
54
2,160.0
108
216
$
157,133.52
3)
Sales
Data
j
60.537(
g)
0
0.00
0.00
0
0
0
4)
R&
D
Stoves
Report
k
60.537(
g)
2
1.00
2.00
54
108
5.4
10.8
$
7,856.68
5)
Retained
Stoves
l
60.537(
c)
8
1.33
10.64
54
575
28.7
57.5
$
41,797.52
Subtotals
For
Manufacturing
Burden
6,198
310
620
$
450,859
22
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters,

(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Burden
Items
Wood
Heater
Regulation
Citation
(
A)
a
(
B)
(
C)
a
(
D)
(
E)
a
(
F)
(
G)
(
H)

Person
Hours
Per
Occurrence
Number
Of
Occurrences
Per
Respondent
Per
Year
Technical
Person
Hours
Per
Respondent
Per
Year
(
C=
AxB)
Respondents
Per
Year
Technical
Person
Hours
Per
Year
(
E=
CxD)

E=
CxD
Management
Person
Hours
Per
Year
=
Ex5%
Clerical
Person
Hours
Per
Year
=
Ex10%
Cost
Dollars
Per
Year
Laboratories
­

Reporting
Requirements
m
1)
Application
For
Accreditation
60.535(
a)(
1)
40
1.00
40.00
1
40
2
4
$
2,909.88
2)
Proficiency
Test­

Accreditation
60.535(
b)(
5)
135
1.00
135.00
1
135
7
13.5
$
9,820.85
3)
Notice
of
Proficiency
Test
n
60.535(
b)(
5)
1
2.00
1.00
1
1
0
0.1
$
72.75
4)
Annual
Proficiency
Test
o
60.535(
b)(
7)
135
1.00
135.00
5
675
33.8
67.5
$
49,104.23
5)
Rescheduling
Of
Proficiency
Test
p
60.534(
e)(
1)
2
2.00
4.00
5
20
1
2
$
1,454.94
1)
Certification
Test
Runs
q
60.537(
b)(
1)
4
52
208.00
5
1,040
52
104
$
75,656.88
Subtotals
For
Laboratory
Burden
1,911
96
191
$
139,019.52
Retailers
­
Recordkeeping
1)
Used
Stoves
r
60.537(
h)
0.1
4.00
0.40
875
350
18
35
$
25,461.45
Totals
for
hourly
labor
rates
8,459.0
423.0
845.9
$
615,366.87
Totals
For
All
Manufacturing,
Laboratory
and
Retailer
Burden
Items
9,728
Hours
$
615,367
(
rounded)
23
24
NOTES
FOR
TABLE
1
aPlease
note:
numbers
shown
in
columns
(
A),
(
C),
and
(
E)
are
in
person­
hours.
It
was
necessary
to
make
several
general
assumptions
regarding
1)
how
wood
heater
manufacturers
would
respond
to
the
various
alternatives
for
compliance
and
2)
the
large
variety
of
wood
heater
manufacturer
size
and
marketing
approaches.
Using
data
from
EPA's
Section
114
survey
of
manufacturers,
the
following
assumptions
were
developed
for
this
burden
calculation:

1)
54
woodstove
manufacturers
2)
200
woodstove
models
3)
4
woodstove
models
per
manufacturer
4)
750
woodstoves
produced
annually
for
each
model
by
each
manufacturer
5)
3,000
woodstoves
produced
annually
by
each
manufacturer
6)
150,000
woodstoves
produced
each
year
by
all
manufacturers
bAssumes
that
during
the
next
three
years
of
the
woodstoves
NSPS,
the
typical
manufacturer
will
require
four
Phase
II
certification
tests
over
the
three
year
period.
Thus,
four
notices
in
three
years
equals
1.33
notices
per
year.

cSee
footnote
b.

dBiennial
reporting
equals
0.50
occurrences/
year.

eRemovable
labels
estimated
to
require
30
seconds
to
apply
per
wood
heater.

fTwenty
hours
required
to
include
requisite
information
in
owner's
manual.

gAssumes
an
emissions
test
is
performed
once
every
5,000
units
and
since
750
units
are
produced
each
year
for
each
model,
0.15
emission
tests
are
performed
annually
per
manufacturer
per
model.
Since
each
manufacturer
has
three
models,
0.8
emissions
tests
per
year,
per
manufacturer
will
be
conducted
(
0.15
*
3
=
0.45).

hSee
footnote
b.

iAssumes
that
750
units
per
model
year
are
produced
and
that
one
out
of
every
150
units
undergoes
a
parameter
inspection.
Thus,
a
parameter
inspection
will
occur
approximately
five
times
per
year
per
manufacturer
per
model.
Since
each
manufacturer
has
four
models,
20
parameter
inspections
will
be
conducted
annually
for
each
manufacturer.

jNo
additional
burden
because
manufacturers
already
keep
track
of
sales
data
for
marketing
purposes
and
payment
of
income
taxes.

kAssumes
one
report
filed
by
each
manufacturer
annually.
25
lSee
footnote
b.

mAssumes
that
one
new
lab
will
apply
for
accreditation
each
year.

nAn
average
of
two
notifications
per
proficiency
test
is
assumed
due
to
test
cancellation
and
rescheduling.

oAnnual
proficiency
tests.
It
is
assumed
that
for
each
laboratory
applying
for
accreditation,
another
laboratory
will
not
renew
their
accreditation;
therefore,
there
is
no
net
increase
in
the
number
of
laboratories
from
year
to
year
and
the
number
of
respondents
remains
constant
at
four.

pEach
laboratory
is
required
to
report
to
EPA
changes
in
the
testing
schedule
or
interruptions
in
testing
that
last
more
than
24
hours.
It
is
assumed
that
two
of
these
events
will
occur
for
each
test.

qLaboratories
are
expected
to
spend
4
hours
per
week
to
update
and
maintain
records
on
certification
tests.

rOne­
tenth
of
the
estimated
8,751
wood
heater
retailers
are
assumed
to
buy
and
sell
used
wood
stoves.
These
875
retailers
are
each
assumed
to
purchase
four
used
stoves
per
year
and
to
spend
six
minutes
per
purchase
maintaining
records
of
each
used
wood
heater
purchase.
26
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Report
Type
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Person
Hours
Per
Occurrenc
e
Number
Of
Occurrences
Per
Respondent
Per
Year
Technical
Person
Hours
Per
Respondent
Per
Year
(
C=
AxB)
Respondents
Per
Year
Technical
Person
Hours
Per
Year
(
E=
CxD)

($
39.49)
Management
Person
Hours
Per
Year
(
Ex5%)

($
53.22)
Clerical
Person
Hours
Per
Year
(
Ex10%)

($
21.38)
Cost
in
Dollars
in
Per
Year
Response
To
Applicability
Determination
b
4
1.00
4.00
5
20.0
1.0
2.0
$
885.78
Manufacture
Certification
Notification
&
Changes
c
60.533(
f)(
1)

&
60.534(
e)
2
2.67
5.34
54
288.4
14.4
28.8
$
12,771.18
Certification
Test
d
60.533(
n)
40
0.13
5.20
54
280.8
14.0
28.1
$
12,436.35
Apply
For
Certification
of
Model
Line
e
60.533(
b)
60
1.33
79.80
54
4,309.2
215.5
430.9
$
190,850.16
Biennial
Reporting
For
Certified
Models
f
60.537(
f)
2
0.50
1.00
54
54
2.7
5.4
$
2,391.61
Laboratory
Application
For
Accreditation
g
60.535(
a)(
1)
40
1.00
40.00
1
40
2
4
$
1,771.56
Laboratory
Proficiency
Test
Notice
­
Accreditation
h
60.535(
b)(
5)
2
1.00
2.00
1
2
0.1
0.2
$
88.58
Laboratory
Proficiency
Test
Notice
­
New
Lab
Accreditation
i
60.535(
b)(
5)
25
1.00
25.00
1
25.0
1.3
2.5
$
1,107.23
Laboratory
Proficiency
Test
Report
­
Annual
j
60.535(
b)(
7)

a)
Test
Design
and
Implementation
80
1.00
80.00
1
80.0
4.0
8.0
$
3,543.12
b)
Test
Observation
40
0.25
10.00
5
50.0
2.5
5.0
$
2,214.45
27
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
New
Residential
Wood
Heaters
(
40
CFR
part
60,
subpart
AAA)
(
Renewal)

Report
Type
(
A)
(
B)
(
C)
(
D)
(
E)
(
F)
(
G)
(
H)

Person
Hours
Per
Occurrenc
e
Number
Of
Occurrences
Per
Respondent
Per
Year
Technical
Person
Hours
Per
Respondent
Per
Year
(
C=
AxB)
Respondents
Per
Year
Technical
Person
Hours
Per
Year
(
E=
CxD)

($
39.49)
Management
Person
Hours
Per
Year
(
Ex5%)

($
53.22)
Clerical
Person
Hours
Per
Year
(
Ex10%)

($
21.38)
Cost
in
Dollars
in
Per
Year
c)
Review
of
Test
Reports
20
1.00
20.00
5
100.0
5.0
10.0
$
4,428.90
d)
Analysis/

Conclusions
40
1.00
40.00
1
40.0
2.0
4.0
$
1,771.56
Parameter
Inspections
k
40
0.25
10.00
54
540.0
27.0
54.0
$
23,916.06
Totals
For
All
Burden
Items
(
sum)
5,829.4
291.5
582.9
$
258,176.53
Total
hours
6704
28
NOTES
FOR
TABLE
2
aIt
was
necessary
to
make
several
simplifying
assumptions
regarding
1)
how
wood
heater
manufacturers
would
respond
to
the
various
alternatives
for
compliance
and
2)
the
large
variety
of
wood
heater
manufacturer
size
and
marketing
approaches.
The
following
assumptions
were
developed
for
renewal
of
this
ICR:

1)
54
wood
heater
manufacturers
2)
200
wood
heater
models
3)
4
wood
heater
models
per
manufacturer
4)
750
wood
heaters
produced
annually
for
each
model
by
each
manufacturer
5)
3,000
wood
heaters
produced
annually
by
each
manufacturer
6)
150,000
wood
heaters
produced
each
year
by
all
manufacturers
bTen
percent
of
the
wood
heater
manufacturers
will
request
a
determination
of
applicability
once
per
year.

cEach
manufacturer
will
require
four
EPA
certification
tests
over
the
next
three
years
for
an
average
of
1.33
certification
tests
per
manufacturer
per
year.
Each
certification
test
is
assumed
to
result
in
two
schedule
changes
requiring
notification.
This
doubles
the
occurrences
per
respondent
from
1.33
to
2.67.

dAssumes
that
there
will
be
1.33
certifications
per
manufacturer
per
year
(
see
footnote
c)
and
that
EPA
will
send
an
observer
to
one
out
of
every
ten
certification
tests.

eSee
footnote
c.

fBiennial
reporting
equals
0.50
occurrences/
year.

gAssumes
that
one
new
lab
will
apply
for
accreditation
each
year.

hTo
receive
accreditation,
each
laboratory
will
be
required
to
perform
a
proficiency
test
one
time
during
each
year.

iSee
footnote
g.

jLab
proficiency
test
reports
will
consist
of
four
parts.
The
first
part,
test
design
and
implementation,
is
assumed
to
required
80
hours
once
per
year
to
evaluate.
The
second
part,
test
observation,
assumes
that
EPA
will
send
an
observer
to
one­
fourth
of
all
tests.
The
third
part,
review
of
test
reports,
assumes
that
each
laboratory
will
submit
a
report
and
that
each
report
will
require
20
hours
to
review.
The
fourth
part,
analysis
and
conclusions,
is
assumed
to
take
40
hours
once
per
year.

kRandom
compliance
audits
to
inspect
wood
heater
parameters
are
expected
to
be
conducted
on
one­
quarter
of
each
manufacturer's
model
lines
per
year.
