SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
40
CFR
PART
63,
SUBPART
JJ
­
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS;
FINAL
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANT
EMISSIONS
FROM
WOOD
FURNITURE
MANUFACTURING
OPERATIONS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
40
CFR
Part
63,
Subpart
JJ
­
National
Emission
Standards
for
Hazardous
Air
Pollutants;
Final
Standards
for
Hazardous
Air
Pollutants
From
Wood
Furniture
Manufacturing
Operations.

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,
1996.
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
40
CFR
Part
63,
Subpart
JJ.

Owners
or
operators
of
the
affected
facilities
described
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
63,
Subpart
JJ,
provide
information
on
compliance
with
the
rule.
Semiannual
reports
of
excess
emissions
are
required.
These
notifications,
reports
and
records
are
required,
in
general,
of
all
sources
subject
to
40
CFR
Part
63.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
sources
subject
to
general
provisions
of
Part
63
are
required
to
retain
records
for
five
years
[
40
CFR
63.10(
b)(
1)].

Approximately
750
sources
are
currently
subject
to
the
standard,
and
based
on
information
provided
by
the
American
Furniture
Manufacturers
Association,
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
2
affected
facility
per
plant.
The
estimated
recordkeeping
and
reporting
costs
of
this
ICR
will
be
$
4,999,151.

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
EPA
Regional
Office.

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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
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
manufactures
to
control
air
emissions
using
maximum
achievable
control
technology
(
MACT)
was
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
JJ.

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
hazardous
air
pollutants
(
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.
3
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
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63,
Subpart
JJ.
If
the
rule
has
not
been
delegated
to
a
State
Agency,
the
information
is
sent
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
regulation
to
implement
this
rule,
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
Standard.
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
on
August
17,
2000
(
FR
50196).

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
USEPA
Office
of
Air
Quality
Planning
and
Standards.
The
contacts
were:
1)
The
American
Furniture
Manufacturing
Association,
Mr.
Larry
Runyan,
(
336)
884­
5000,
2)
The
Kitchen
Cabinet
Manufacturers
Association,
Mr.
Richard
Titus,
(
703)
264­
1690,
3)
The
Business
and
Institutional
Furniture
Manufacturing
Association,
Mr.
Brad
Miller,
(
616)
285­
3963,
and
4)
the
Office
of
Air
Quality
and
Planning
(
EPA),
Mr.
Paul
Almodovar,
(
919)
541­
0283.
4
The
industry
representatives
indicated
that
no
net
growth
in
the
industry
was
expected
over
the
next
three
years.
They
cited
foreign
competition
as
the
main
cause.

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
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
main
consequence
would
be
that
the
chances
of
detecting
poor
operation
and
maintenance
of
control
equipment
would
decrease
and
some
manufacturers
would
use
noncompliant
coatings
or
high
HAP
coatings.
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
63
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
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
contained
in
40
CFR
Part
63
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.
5
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
wood
furniture
manufacturers
under
the
following
SIC
codes:

2434
­
Wood
Kitchen
Cabinets
2511
­
Wood
Household
Furniture,
Except
Upholstered
2512
­
Wood
Household
Furniture,
Upholstered
2517
­
Wood
Television,
Radio,
Photograph,
and
Sewing
Machine
Cabinets
2519
­
Household
Furniture,
Not
Elsewhere
Classified
2521
­
Wood
Office
Furniture
2531
­
Public
Building
and
Related
Furniture
2541
­
Wood
Office
and
Store
Fixtures,
Partitions,
Shelving,
and
Lockers
2599
­
Furniture
and
Fixtures,
Not
Elsewhere
Classified
5712
­
Furniture
Stores
All
affected
facilities
are
located
at
plant
sites
that
are
major
sources
as
defined
in
40
CFR
63.2.

4(
b)
INFORMATION
REQUESTED
All
the
recordkeeping
and
reporting
requirements
in
this
ICR
are
required
by
40
CFR
Part
63,
Subpart
JJ.
There
have
been
no
changes
in
regulatory
requirements
since
the
last
ICR.

It
should
be
noted
that
this
rule
requires
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
5
years.
This
is
consistent
with
the
General
Provision
to
the
rule.
Furthermore,
EPA
believes
that
the
5
year
records
retention
requirement
is
consistent
the
Part
70
permit
program
and
the
5
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
5
years
would
allow
EPA
to
establish
a
source's
history
and
patterns
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
5
year
statute
of
limitations.
Therefore,
EPA
should
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
less
than
5
years
of
records
were
kept.

Recordkeeping
­
5
year
retention
of
records
[
63.806(
j),
63.10(
b)(
1)]
­
Records
of
startup,
shutdown,
or
malfunction
and
corrective
actions
[
63.806(
a),
63.6(
e)
and
63.10(
b)(
2)]
­
Records
required
as
part
of
work
practice
standards
implementation
plan
[
63.806(
e),
63.10(
b)(
2)]
6
­
Records
of
CMS
data
[
63.806(
a),
63.10(
b)(
2),
63.10(
c),
63.6(
e)]
­
CMS
quality
control
program
[
63.807(
a),
63.8(
d)]
­
Records
of
types
&
quantities
of
finishing
and
cleaning
materials
and
adhesives
used,
including
VHAP
and
solids
content
data
[
63.806(
b),
63.10(
b)(
2)]
­
Records
of
monthly
weighted­
average
emission
calculations
[
63.806(
c),
63.10(
b)(
2)]
­
Records
of
applicability
determination/
area
source
status
[
63.806(
a),
63.10(
b)(
3)]
­
Records
of
performance
tests
and
CMS
performance
evaluations
[
63.806(
a),
63.10(
b)(
2)]

Reports
­
Application
for
approval
of
construction/
reconstruction
[
63.807(
a),
63.5(
d)]
­
Notification
of
start­
up,
construction,
reconstruction,
or
modification
[
63.807(
a),
63.5(
b)(
4)
and
63.9(
b)]
­
Start­
up,
shutdown,
and
malfunction
plan
and
reports
[
63.807(
a),
63.6(
e)(
3)
and
63.10(
d)(
5)]
­
Notification
of
physical/
operational
changes
[
63.807(
a),
63.5(
b)(
6)]
­
Site
specific
performance
test
and
CMS
performance
evaluation
test
plans
[
63.807(
a)
63.7(
c)
and
63.8(
e)]
­
Notification
and
report
of
performance
tests
and
results
[
63.807(
a),
63.7(
b)
and
(
g),
63.9(
e),
and
63.10(
d)(
2)]
­
Notification
and
report
of
CMS
performance
evaluation
and
results
[
63.807(
a)
63.8(
e)(
2),
63.9(
g),
and
63.10(
e)(
2)]
­
Semiannual
compliance
report
[
63.807(
c),
overrides
63.10(
e)]
­
Work
practice
standards
implementation
plan
[
63.806(
e),
63.10(
d)(
1)]
­
Notification
of
applicability
[
63.807(
a),
63.9(
b)]
­
Notification
and
report
of
compliance
status
[
63.807(
b),
63.9(
h)]

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
sources
subject
to
general
provisions
of
Part
63
are
required
to
retain
records
for
five
years
[
40
CFR
63.10(
b)(
1)].

Respondent's
Activities
­
Read
instructions
­
Install,
calibrate,
maintain,
and
operate
CMS
­
Perform
initial
performance
test,
Reference
Methods
24
and
311,
and
repeat
performance
tests,
as
necessary.
­
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.
7
­
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
existing
internal
procedures
to
comply
with
any
applicable
instructions
and
requirements
­
Train
personnel
to
collect
information
­
Transmit,
or
otherwise
disclose
the
required
information
None
of
respondent
activities
listed
above
are
considered
"
customary
and
usual
business
practices."

Various
automated,
mechanical
or
other
technical
collection
techniques
would
typically
be
used
to
collect
information
at
the
plant
site
by
the
respondent
to
provide
information
to
the
Agency.
The
respondents
would
then
mail
various
reports
to
the
Agency.
Reporting
by
the
respondent
is
not
frequent
enough
to
warrant
development
of
special
direct
transmission
techniques
(
i.
e.,
electronic
information
exchange)
between
the
respondent
and
the
Agency.
The
Agency
currently
has
no
plans
to
develop
such
a
system.
All
of
the
costs
associated
with
the
transmission
of
reports
to
the
Agency
have
been
include
in
the
cost
figures
developed
in
Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
40
CFR.
63,
Subpart
JJ.

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
information
required
under
40
CFR
Part
63,
Subpart
JJ:

­
Observes
initial
and
repeat
performance
tests
­
Reviews
notifications
and
reports,
including
excess
emissions
reports,
required
to
be
submitted
by
industry.
­
Audits
facility
records
­
Compiles
data
in
the
AIRS
database
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
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
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
obtained
8
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.
The
semiannual
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
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
AFS
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.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Offices
and
Headquarters.
EPA
can
edit,
store,
retrieve
and
analyze
the
data
via
PC
terminals.

The
records
required
by
this
rule
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
employee
less
than
500
people;
however,
only
about
7
percent
(
750)
of
the
existing
11,000
wood
furniture
facilities
are
expected
to
be
major
sources
and
thus
subject
to
the
rule.
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
3
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.
9
Another
provision
of
the
rule
that
has
been
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
any
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
compliance
date
for
existing
affected
sources
that
emit
less
than
50
tons
of
HAP
in
1996,
was
December
7,
1998.
The
compliance
date
for
existing
affected
sources
that
emit
50
tons
or
more
of
HAP
in
1996
was
November
21,
1997.
New
wood
furniture
manufacturing
operations
will
have
to
comply
immediately
upon
startup.
The
standards
require
semiannual
reporting.
A
more
detailed
schedule
for
the
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
and
recordkeeping
are
triggered
by
action
of
the
respondent.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
40
CFR.
63,
Subpart
JJ,
documents
the
computation
of
burden
for
each
recordkeeping
and
reporting
requirement
applicable
to
the
industry.
Each
burden
is
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
methods
of
information
collection
for
this
rule
are
consistent
and
compatible,
to
the
maximum
extent
practicable,
with
the
respondents
existing
reporting
or
recordkeeping
practices.
Responses
to
this
information
collection
are
mandatory
under
40
CFR
Part
63,
Subpart
JJ.

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
at
80,062
technical
person­
hours
per
year;
4,003
managerial
person­
hours
per
year;
8,006
clerical
person­
hours
per
year.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
and
test
methods,
Agency
knowledge
and
experience
with
the
rule,
the
previously
approved
ICR,
and
any
comments
received
about
the
costs
to
conduct
recordkeeping
and
prepare
reports.
10
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
listed
below.
These
labor
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.
.
­
Managerial:
$
78.10
($
37.19
per
hour
+
110%
overhead)
­
Technical:
$
54.92
($
26.15
per
hour
+
110%
overhead)
­
Clerical:
$
36.16
($
17.22
per
hour
+
110%
overhead)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
required
by
this
rule
are
continuing
O&
M
[(
i.
e.,
operation
and
maintenance
of
continuous
monitoring
systems
(
CMS)]
activities.
There
are
no
capital
CMS
start­
up
costs
for
this
ICR
renewal
because
no
new
sources
are
expected
to
come
on­
line
during
the
next
three
years
(
source:
American
Furniture
Manufacturers
Association).
Since
CMS
are
required
only
for
sources
selecting
the
control
device
compliance
option,
an
estimated
10%
of
the
sources
will
be
using
CMS.
The
O&
M
cost
for
each
CMS
is
estimated
to
be
$
540
per
year
as
reported
by
the
Office
of
Air
Quality
Planning
and
Standards,
US
EPA.
Therefore,
the
annual
O&
M
costs
are
$
40,500
per
year
(
750
x
10%
x
$
540).

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
No
new
sources
are
expected
to
come
on­
line
during
the
next
three
years;
therefore,
the
capital/
start­
up
costs
are
zero
and
the
annual
operating
and
maintenance
costs
are
same
as
above,
$
40,500.

(
iv)
Annualized
Capital/
Start­
up
Costs
No
new
sources
are
expected
to
come
on­
line
during
the
next
three
years;
therefore,
the
annualized
capital/
start­
up
costs
are
zero.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards.
Examination
of
records
to
be
maintained
by
the
11
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
annual
Federal
Government
costs
during
the
next
three
years
is
estimated
to
be
$
368,599
year.
Agency
costs
for
managerial,
technical
and
clerical
person­
hours
are
computed
as
follows:

­
Managerial:
GS
13,
Step
1,
$
45.71
($
28.57
per
hour
x
1.6
benefits
multiplication
factor)
­
Technical:
GS
10,
Step
3,
$
29.18
($
18.24
per
hour
x
1.6
benefits
multiplication
factor)
­
Clerical:
GS
6,
Step
1,
$
19.50
($
12.19
per
hour
x
1.6
benefits
multiplication
factor)

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Table
1,
Annual
Burden
and
Cost
for
the
Federal
Government
to
Implement
Reporting
and
Recordkeeping
Requirements
for
40
CFR
63,
Subpart
JJ;
and
Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
40
CFR
63,
Subpart
JJ
may
be
found
at
the
end
of
this
document.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
(
i)
Respondent
Tally
The
number
of
existing
sources
subject
to
40
CFR
Part
63,
Subpart
JJ
is
750.
As
noted
above,
no
new
sources
are
expected
to
come
on­
line
during
the
next
three
years.
The
total
annual
labor
costs
over
the
next
three
years
are
92,071
person­
hours
per
year,
and
the
total
annual
capital
and
O&
M
costs
are
estimated
to
be
$
40,500.
Details
upon
which
this
estimate
is
based
appear
in
Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
40
CFR
63,
Subpart
JJ,
and
the
discussion
above
under
items
6(
b)(
ii)
and
6(
b)(
iii)
.

(
ii)
The
Agency
Tally
The
annualized
burden
the
Federal
government
is
9,664
person­
hours
and
$
280,824
per
year
as
shown
on
Table
1,
Annual
Burden
and
Cost
for
the
Federal
Government
to
Implement
Reporting
and
Recordkeeping
Requirements
for
40
CFR
63,
Subpart
JJ.

(
iii)
Variations
In
The
Annual
Bottom
Line
No
significant
(
i.
e,
over
25%)
variations
in
the
annual
bottom
line
are
expected
over
the
next
three
years.
12
6(
f)
Reasons
for
Change
in
Burden
A
small
decrease
in
burden
to
the
Federal
government
and
a
small
increase
in
burden
to
the
industry
occurs
in
this
ICR
compared
to
the
previous
ICR
primarily
because
of
an
changes
in
the
overall
labor
rates
for
both
the
Federal
government
and
industry.
It
should
be
noted
that
all
initial
one­
time­
only
activities
to
achieve
initial
compliance
were
completed
during
the
previous
ICR
approval
period;
therefore,
no
initial
one­
time­
only
activities
do
not
appear
in
this
ICR.

Table
1,
Annual
Burden
and
Cost
for
the
Federal
Government
to
Implement
Reporting
and
Recordkeeping
Requirements
for
40
CFR
Part
63,
Subpart
JJ,
shows
a
decrease
in
the
overall
cost.
This
due
to
a
reduction
in
the
overhead
rate
from
110%
in
the
previous
ICR
to
60%
(
i.
e.,
the
1.6
benefits
multiplication
factor)
in
this
ICR.
The
1.6
factor
reflects
the
true
cost
to
the
Federal
government
to
employ
a
Federal
worker.
The
new
labor
rate
for
each
of
the
three
person­
hour
categories
is
as
follows:
managerial
at
$
45.71
vs.
$
52.67
per
hour,
technical
at
$
29.18
vs.
$
35.87
per
hour,
and
clerical
at
$
19.50
vs.
$
22.47
per
hour.

Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
40
CFR
63,
Subpart
JJ,
shows
a
small
increase
in
the
overall
cost.
This
primarily
due
to
an
increase
in
the
labor
rates
for
each
of
the
three
person­
hour
categories
(
i.
e.,
managerial
at
$
78.10
vs.
$
50.48
per
hour,
technical
at
$
54.92
vs.
$
35.89
per
hour,
and
clerical
at
$
36.16
vs.
$
23.07
per
hour).
An
Increase
in
estimated
annual
burden
hours
was
because
of
10
additional
respondents
per
year,
thus
increasing
the
total
from
88
to
98.

6(
g)
Burden
Statement
The
total
annual
burden
for
recordkeeping
and
reporting
requirements
under
this
rule
is
92,071
hours.
The
total
number
of
annual
responses
is
47,800.
The
average
annual
burden
per
response
is
therefore
1.92
hours.
The
estimated
cost
to
the
respondents
is
$
40,500
based
on
an
estimated
750
respondents.

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.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
13
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
