SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
part
63,
subpart
JJ)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
part
63,
subpart
JJ)

1(
b)
Short
Characterization/
Abstract
The
final
standards
for
Hazardous
Air
Pollutants
from
Wood
Furniture
Manufacturing
Operations
were
proposed
on
December
6,
1994,
and
promulgated
on
December
7,
1995.
These
standards
apply
to
both
existing
wood
furniture
manufacturing
operations
and
to
new
wood
furniture
manufacturing
operations
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal
that
are
major
sources
of
hazardous
air
pollutants
(
HAPs).
This
information
is
being
collected
to
assure
compliance
with
the
standard
promulgated
at
40
CFR
part
63,
subpart
JJ.

Owners
or
operators
of
the
affected
facilities
that
are
major
sources
must
make
one­
time­
only
notifications
including:
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate,
notification
of
the
initial
performance
test;
including
information
necessary
to
determine
the
conditions
of
the
performance
test,
and
performance
test
measurements
and
results;
notification
of
demonstration
of
the
continuous
monitoring
system
(
CMS).
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Monitoring
requirements
specific
to
40
CFR
part
63,
subpart
JJ,
provide
information
on
compliance
with
the
rule.
Semiannual
reports
are
required
for
all
sources.
Some
sources
having
excess
emissions
must
submit
quarterly
reports.
These
notifications,
reports
and
records
are
required,
in
general,
of
all
sources
subject
to
40
CFR
part
63.

Owners
or
operators
of
the
affected
facilities
that
are
incidental
wood
furniture
manufacturers
or
area
sources
(
incidental/
area
sources)
must
keep
records
to
demonstrate
that
they
are
not
major
sources
as
defined
in
the
standard.

Owners
or
operators
subject
to
the
provisions
of
this
standard
maintain
a
file
of
certain
measurements,
and
retain
the
file
for
at
least
five
years
following
the
creation
of
such
measurements,
maintenance
reports,
and
records.
In
general,
all
sources
subject
to
general
provisions
of
part
63
are
required
to
retain
records
for
five
years.
2
Approximately
750
sources
are
currently
subject
to
the
standard,
based
on
information
provided
by
the
American
Furniture
Manufacturers
Association.
Of
these
approximately
300
are
major
sources
and
450
are
incidental/
area
sources.
It
is
anticipated
that
no
new
facilities
will
come
on­
line
over
the
next
three
years.
It
is
assumed
that
there
is
an
average
of
one
affected
facility
per
source.

All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
Environmental
Protection
Agency
(
EPA)
regional
office.

The
previous
Information
Collection
Request
(
ICR)
was
approved
by
the
Office
of
Management
and
Budget
(
OMB)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
emissions
from
wood
furniture
manufacturers
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
a
rule
requiring
wood
furniture
manufacturers
to
control
air
emissions
using
maximum
achievable
control
technology
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
JJ.
3
2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
hazardous
air
pollutant
emissions
from
wood
furniture
manufacturing
operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAPs
from
wood
furniture
manufacturers
are
the
result
of
the
operation
of
the
affected
facilities.
These
standards
rely
on
the
reduction
of
hazardous
air
pollutants
by
either
the
use
of
compliant
or
low
HAP
content
coatings,
use
of
control
devices
or
some
combination
of
these
three
control
technologies.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
compliant
or
low
HAP
coatings
are
actually
being
used
and
whether
any
pollution
control
devices
installed
are
functioning
properly.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
this
rule
continue
to
achieve
continuous
compliance
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
63,
subpart
JJ.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
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
(
FR
68
27059)
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
4
3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

Additional
consultations
concerning
the
industry
growth
rate
over
the
next
three
years,
and
the
burden
costs
of
recordkeeping
and
reporting
under
the
rule
were
conducted
with
the
leading
trade
associations
representing
the
industry,
and
the
EPA
Office
of
Air
Quality
Planning
and
Standards.
The
contacts
were:
1)
The
American
Furniture
Manufacturing
Association,
Mr.
David
Purvis,
(
336)
884­
5000;
2)
The
Business
and
Institutional
Furniture
Manufacturing
Association,
Mr.
Tom
Reardon,
(
616)
285­
3963;
and
3)
the
Office
of
Air
Quality
Planning
and
Standards.

The
industry
representatives
indicated
that
no
net
growth
in
the
industry
was
expected
over
the
next
three
years.
They
cited
foreign
competition
as
having
a
negative
effect
on
industry
growth
and
modestly
increasing
residential/
business
demand
for
furniture
as
having
a
positive
effect
with
a
projected
net
growth
rate
of
zero.
In
addition,
any
industry
growth
over
the
next
three
years
could
likely
be
absorbed
by
existing
plants
without
any
new
source
construction.

This
rule
was
developed
using
the
regulatory­
negotiation
process.
The
industry
participated
in
the
rulemaking
process
and
agreed
to
comply
with
the
final
rule,
so
they
have
a
good
understanding
of
the
recordkeeping
and
reporting
burden.
They
did
not
mention
any
specific
problems
with
the
rule
burden
during
the
consultations.

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
to
the
standard.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
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
5
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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
and
NAIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
wood
furniture
manufacturers.
The
SIC
(
United
States
Standard
Industrial
Classification)
and
NAICS
(
The
North
American
Industry
Classification
System)
codes
for
the
respondents
affected
by
the
standards
are
shown
below.

Standard
SIC
Codes
NAICS
Codes
40
CFR
part
63,
subpart
JJ
2434
33711
2511
337215
2512
337121
2517
337129
2519
337125
2521
337211
2531
33636,
337127,
339942
2541
337127,
337212,
337215
2599
339111,
337127
5712
337122
6
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
standard
(
40
CFR
part
63,
subpart
JJ).

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
applicability.
63.807(
a),
63.9(
h)

Notification
and
application
of
construction
or
reconstruction.
63.807(
a),
63.5(
d)

Notification
of
anticipated
date
of
initial
startup.
63.807(
a),
63.5(
b),
63.9(
b)

Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate.
63.807(
a),
63.5(
b)(
6)

Notification
of
performance
tests.
63.807(
a),
63.7(
b),
(
c)
and
(
g),
63.8,
63.9(
c),
63.10(
d)(
2)

Notification
performance
test
results.
63.807(
a),
63.8(
e)(
2),
63.9(
g),
63.10(
e)(
2)

Notification
of
compliance
status.
63.807(
b),
63.9(
h)

Reports
Semiannual
reports.
63.807(
c)

Quarterly
reports.
63.807(
d)

A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdown
or
malfunctions
and
corrective
action
records.
63.806(
a),
63.6(
e),
63.10(
b)(
2)

Work
practice
standards
implementation
plan.
63.806(
e),
63.10(
d)(
1)
7
Recordkeeping
Work
practice
standards
records.
63.806(
e),
63.10(
b)(
2)

Records
of
Compliance
Monitoring
System
(
CMS)
data.
63.806(
b)(
2),
63.10(
c),
63.6(
e)

CMS
quality
control
plan.
63.807(
a)

Startup,
shutdown
and
malfunction
plans.
63.807(
a),
63.6(
e)(
3),
63.10(
d)(
5)

Records
of
the
types
and
quantities
of
finishing/
cleaning/
adhesive
materials.
63.806(
b),
63.10(
b)(
2)

Records
monthly
weighted­
average
emission
calculations.
63.806(
c),
63.10(
b)(
3)

Records
of
applicability
determination/
area
source
status.
63.806(
a),
63.10(
b)(
3)

Records
of
performance
tests/
evaluations.
63.806(
a),
63.10(
b)(
20
Electronic
Reporting
Presently,
some
sources
are
using
monitoring
equipment
that
provides
parameter
data
via
an
automated
internal
feed.
Personnel
at
the
source
still
need
to
evaluate
the
data.
This
type
of
internal
monitoring
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically,
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10%
of
the
respondents
use
electronic
reporting
to
regulatory
agencies.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
control
device.

Perform
initial
performance
test
and
repeat,
if
necessary.
8
Respondent
Activities
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,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard
and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
9
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
and
quarterly
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
Because
of
the
large
number
of
small
businesses
in
the
wood
furniture
industry,
some
of
which
will
be
impacted
by
the
regulation,
the
impacts
of
the
reporting
and
recordkeeping
requirements
on
small
businesses
were
considered
carefully.
The
Small
Business
Administration
(
SBA)
definition
of
a
small
business
wood
furniture
manufacturing
facility
is
500
or
fewer
employees.
The
majority
of
the
approximately
11,000
wood
furniture
manufacturing
facilities
are
expected
to
employ
less
than
500
people;
however,
only
about
300
of
the
existing
11,000
wood
furniture
facilities
are
major
sources.
Approximately
450
are
incidental
sources
and
are
only
required
to
maintain
purchase
or
usage
records.

The
rule
for
wood
furniture
manufacturing
operations
was
developed
using
a
regulatory
negotiation
approach.
Small
businesses
were
represented
on
the
regulatory
negotiation
committee
by
the
Architectural
Woodwork
Institute,
a
trade
association
consisting
primarily
of
small
businesses,
and
by
Pridgen
Cabinet
Works
and
Stylecraft
Corporation,
two
small
wood
furniture
manufacturers.
In
addition,
a
small
business
Work
Group
was
formed
to
specifically
address
issues
relevant
to
small
businesses.

One
objective
of
the
regulatory
negotiation
committee
regarding
reporting
and
recordkeeping
requirements
was
to
ensure
that
the
proposed
requirements
were
not
beyond
the
resources
of
small
businesses.
For
example,
to
decrease
the
burden
on
small
businesses,
semiannual
rather
than
quarterly
reporting
is
required.
In
addition,
the
regulation
allows
an
additional
year
for
smaller
facilities
that
emit
less
than
50
tons
per
year
of
HAP
to
comply
with
the
standard.
The
compliance
date
for
these
smaller
facilities
is
three
years
after
promulgation.
Other
reporting
requirements
also
have
been
critically
reviewed
and
determined
to
be
the
minimum
necessary
for
enforcement
agencies
to
ascertain
compliance
with
the
standards.
An
economic
analysis
also
has
been
performed;
the
results
of
the
analysis
show
that
small
business
impacts
are
minimal.
10
Another
provision,
added
to
decrease
the
burden
on
small
businesses,
addresses
applicability
of
the
standard.
The
rule
is
not
applicable
to
sources
that
commit
to
using
less
than
or
equal
to
250
gallons
per
month
of
coating,
gluing,
cleaning,
and
washoff
materials,
including
materials
used
for
source
categories
other
than
wood
furniture.
Owners
or
operators
of
these
facilities
would
be
required
to
maintain
records
of
the
total
gallons
of
coating,
gluing,
cleaning,
and
washoff
materials
used
each
month
but
would
not
be
subject
to
other
provisions
of
the
rule.
Sources
with
actual
emissions
no
more
than
5
tons
of
one
HAP
per
year
or
12.5
tons
of
a
combination
of
HAP
are
also
exempt
from
the
standard.
These
exemptions
are
built
into
the
rule
and
serve
to
minimize
the
number
of
small
businesses
subject
to
the
rule.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
part
63,
subpart
JJ).

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
subject
to
the
standard.
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.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
47,190
hours
per
year.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
standard,
the
previously
approved
ICR,
and
any
comments
received.
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
11
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
associated
with
the
information
collection
activity
required
by
this
standard
are
for
continuing
operation
and
maintenance
(
i.
e.,
O&
M
)
of
the
continuous
monitoring
systems
(
CMSs)
associated
with
data
collection
under
the
standard.
There
are
no
capital
CMS
startup
costs
for
this
ICR
renewal
because
no
new
sources
are
expected
to
come
on­
line
during
the
next
three
years.
CMS
are
required
only
for
sources
selecting
the
control
device
compliance
option.
An
estimated
10%
of
the
major
sources
will
be
using
CMS.
The
O&
M
cost
for
each
CMS
is
estimated
to
be
$
600
per
year
on
average
as
reported
by
the
Office
of
Air
Quality
Planning
and
Standards,
EPA.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
costs
associated
with
the
information
collection
activity
required
by
this
standard
are
for
continuing
operation
and
maintenance
(
i.
e.,
O&
M
)
of
the
continuous
monitoring
systems
(
CMSs)
associated
with
data
collection
under
the
standard.
There
are
no
capital
CMS
startup
costs
for
this
ICR
renewal
because
no
new
sources
are
expected
to
come
on­
line
during
the
next
three
years.
CMS
are
required
only
for
sources
selecting
the
control
device
compliance
option.
An
estimated
10%
of
the
major
sources
will
be
using
CMS.
The
O&
M
cost
for
each
CMS
is
estimated
to
be
$
600
per
year
on
average
as
reported
by
the
Office
of
Air
Quality
Planning
and
Standards,
EPA.

Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Several
Options
Available
0
0
0
$
600
30
$
18,000
The
total
capital/
startup
costs
for
this
ICR
are
zero.
This
is
the
total
of
column
D
in
the
above
table.
This
figure
is
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.
12
The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
18,000.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
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
the
ICR
is
estimated
to
be
$
18,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
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
$
112,228.
This
cost
is
based
on
the
following
hourly
labor
rates:

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.
Cost
estimate
details
appear
in
Table
2:
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
part
63,
subpart
JJ).
The
rates
are
increased
by
60%
so
that
the
value
of
the
typical
government
employee
benefit
package
is
included.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
750
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
13
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
300
450
0
750
2
0
300
450
0
750
3
0
300
450
0
750
Average
0
300
450
0
750
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
750.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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
(
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
300
2.011
450
1,053
1
Weighted
average
of
semiannual
and
quarterly
reports
(
See
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Wood
Furniture
Manufacturing
Operations,
40
CFR
part
63,
subpart
JJ)
for
details.

The
number
of
Total
Annual
Responses
is
1,053.
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
shown
in
the
previous
ICR
reflected
the
number
of
individual
records
created
(
i.
e.,
47,800)
by
the
respondents
rather
than
the
number
of
reports
submitted
to
the
Agency
added
to
the
number
of
number
of
respondents
that
kept
records
but
did
not
submit
reports.
In
this
ICR,
correct
number
of
responses
(
i.
e.,
1,053)
is
shown
in
block
13(
b)
of
the
OMB
83­
I
form.
14
6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
respondents
and
the
Agency
appear
in
Tables
1
and
2
(
attached).

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
the
reporting
and
recordkeeping
hour
and
cost
burdens
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
previous
ICR
showed
750
major
sources.
The
best
data
now
available
indicates
that
there
are
approximately
300
major
sources
and
450
incidental
sources.
The
standard
places
greater
recordkeeping
and
reporting
burdens
on
major
sources
than
on
incidental
sources.
Consequently,
the
overall
burden
for
this
standard
is
less
than
in
the
previous
ICR
due
to
a
recharacterization
of
the
source
universe.

It
should
be
noted
that
the
labor
rates
have
increased
from
the
previous
ICR,
but
due
to
the
recharacterization
the
overall
labor
cost
is
less.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
45
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
Docket
ID
Number
OECA­
2003­
0032,
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
Docket
is
15
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
to
view
public
comments,
to
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
0032
and
OMB
Control
Number
2060­
0324
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Attachment
Table
1.
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
Part
63,
Subpart
JJ)

Activity
(
A)
Person­

Hours
per
Occurrenc
e
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hours
Per
Respondent
Per
Year,

C=
AxB
(
D)
Respondents
Per
Year
(
E)
Technical
Person­

Hours
Per
Year,

E=
CxD
(
F)
Management
Person­
Hours
Per
Year,

F=
Ex5%
(
G)
Clerical
Person­

Hours
Per
Year,

G=
Ex10%
(
H)
Cost
in
Dollars
Per
Year
1.
Applications
for
construction,

reconstruction
&
modification
4
1
4
39
a
156
8
16
$
11,349
2.
Surveys
and
studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
300
300
15
30
$
21,824
B.
Create
Information
See
3.
D.

C.
Gather
existing
information
See
3.
D.

D.
Write
Report
i.
Notification
of
construction
and
reconstruction
2
1
2
9
b
18
1
2
$
1,309
ii.
Notification
of
modifications
(
physical/

operational
changes)
8
1
8
30
c
240
12
24
$
17,459
iii.
Notification
of
anticipated
startup
(
including
reconstruction
and
modification)
2
1
2
39
a
78
4
8
$
5,674
17
Table
1.
Continued,
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
Part
63,
Subpart
JJ)

Activity
(
A)
Person­

Hours
per
Occurrenc
e
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hours
Per
Respondent
Per
Year,

C=
AxB
(
D)
Respondents
Per
Year
(
E)
Technical
Person­

Hours
Per
Year,

E=
CxD
(
F)
Management
Person­
Hours
Per
Year,

F=
Ex5%
(
G)
Clerical
Person­

Hours
Per
Year,

G=
Ex10%
$
9
iv.
Notification
of
actual
startup
2
1
2
39
a
78
4
8
$
5,674
v.
Semiannual
compliance
status
reports
4
2
8
270
d
2,160
108
216
$
157,134
vi.
Semiannual
excess
emissions
reports
4
2
8
29
232
12
23
$
16,877
vii.
Quarterly
excess
emissions
reports
4
4
16
2
f
32
2
3
$
2,328
viii.
List
of
types
and
quantities
of
materials
used,
including
VHAP
and
solids
content
data
1.5
52
78
300
23,400
1,170
2,340
$
1,702,280
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3.
A.

B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
18
Table
1.
Continued,
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
Part
63,
Subpart
JJ)

Activity
(
A)
Person­

Hours
per
Occurrenc
e
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hours
Per
Respondent
Per
Year,

C=
AxB
(
D)
Respondents
Per
Year
(
E)
Technical
Person­

Hours
Per
Year,

E=
CxD
(
F)
Management
Person­
Hours
Per
Year,

F=
Ex5%
(
G)
Clerical
Person­

Hours
Per
Year,

G=
Ex10%
(
H)
Cost
in
Dollars
Per
Year
D.
Time
to
enter
information
i.
Records
of
operators
completing
training
courses
1
2
2
300
600
30
60
$
43,648
ii.
Records
of
CMS
parameters
1.5
52
78
30
g
2,340
117
234
$
170,228
iii.
Records
of
types
and
quantities
of
materials
used,

including
VHAP
and
solids
content
data
See
3.
D.

E.
Records
for
incidental
and
area
sources
1
12
12
450
5,400
270
540
$
392,834
F.
Annual
Personnel
refresher
course
8
1
8
750
6,000
300
600
$
436,482
G.
Time
for
audits
N/
A
5.
Burden
Subtotals
and
Cost
Per
Year
41,034
2,052
4,104
$
2,985,109
Total
Burden
Per
Year
47,190
Footnotes:

a
30
(
modification)
+
9
(
reconstruction)
=
39
total.
See
footnotes
b
and
c
below.

b
It
is
assumed
that
approximately
3%
of
the
total
number
of
sources
will
apply
for
reconstruction
(
300x3%=
9).
19
c
An
estimated
10%
of
the
sources
will
apply
for
modification
of
the
facility
(
300x10%=
30).

d
An
estimated
90%
of
the
affected
facilities
sources
will
comply
by
using
compliant
coatings
or
by
using
the
HAP
averaging
approach
(
300x90%=
270).

e
An
estimated
10%
of
the
affected
facilities
will
comply
by
using
control
devices,
but
only
95%
are
assumed
to
be
in
compliance
at
any
given
time
and
would
be
required
to
submit
semiannual
rather
than
quarterly
reports;
therefore,
the
number
of
affected
facilities
submitting
semi­
annual
reports
is
[(
300x10%
x
95%=
29(
rounded)].

f
The
number
submitting
quarterly
reports
is
[(
300x10%
x5%=
2
(
rounded)].

g
An
estimated
10%
of
the
affected
facilities
will
use
control
devices
to
comply
(
300x10%
=
30).
20
Table
2.
Annual
Agency
Burden
and
Cost:
NESHAP
for
Wood
Furniture
Manufacturing
Operations
(
40
CFR
Part
63,
Subpart
JJ)

Activity
(
A)
EPA
Hours
per
Facility
per
Year
(
B)
Number
of
Facilities
(
C)
Technical
Person­
Hours
Per
Year,

C=
AxB
(
D)
Management
Person­
Hours
Per
Year,

D=
Cx5%
(
E)
Clerical
Person­
Hours
Per
Year,

E=
Cx10%
(
F)
Cost
in
Dollars
Per
Year
1.
Excess
Emissions
Enforcement
Activities
32
1
32
2
3
$
1,417
2.
Report
Review
A.
Review
notification
of
construction/
reconstruction
2
9
a
18
1
2
$
797
B.
Review
notification
of
modifications
(
physical/

operational
changes)
2
30
b
60
3
6
$
2,657
C.
Review
semiannual
compliance
status
reports
&
certifications
8
270
c
2,160
108
216
$
95,664
D.
Review
semiannual
excess
emission
reports
8
29d
232
12
23
$
10,275
E.
Review
quarterly
excess
emission
reports
16
2
f
32
2
3
$
1,417
3.
Total
Cost
Burden
Per
Year
2,534
127
253
$
112,228
Footnotes:

a
It
is
assumed
that
approximately
3%
of
the
total
number
of
sources
will
reconstruction
some
portion
of
their
affected
facility
each
year
(
300x3%=
9).

b
An
estimated
10%
of
the
sources
will
modify
the
operations
affected
by
this
rule
(
300x10%=
30).

c
An
estimated
90%
of
the
affected
facilities
sources
will
comply
by
using
compliant
coatings
or
by
using
the
HAP
averaging
approach
(
300x90%=
270).
21
22
d
An
estimated
10%
of
the
affected
facilities
will
comply
by
using
control
devices,
but
only
95%
are
assumed
to
be
in
compliance
at
any
given
time
and
would
be
required
to
submit
semiannual
rather
than
quarterly
reports;
therefore,
the
number
of
affected
facilities
submitting
semiannual
reports
is
[
300x10%
x95%=
29
(
rounded)].

f
The
number
submitting
quarterly
reports
is
[
300x10%
x5%=
2
(
rounded)].
