SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
FOR
NSPS
SUBPART
AAA,
NEW
RESIDENTIAL
WOOD
HEATERS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
40
CFR
60.530
thru
60.539(
b),
New
Source
Performance
Standards
for
New
Residential
Wood
Heaters
(
Subpart
AAA).

1(
b)
Short
Characterization/
Abstract
The
wood
heater
NSPS
[
40
CFR
60.530
thru
60.539(
b),
New
Source
Performance
Standards
for
New
Residential
Wood
Heaters
(
Subpart
AAA)]
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
50
manufacturers,
3,500
retailers,
and
4
certification
laboratories
are
currently
subject
to
the
regulations.
No
increase
is
expected
in
those
estimates
over
the
next
3
years.
Particulate
matter
(
PM)
is
the
pollutant
regulated
under
the
standards.

Two
features
of
this
rulemaking
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
2
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
EPA
and/
or
to
maintain
records
for
demonstrating
compliance
with
the
NSPS.

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

Information
supplied
to
the
Agency
by
testing
laboratories
is
used
to
grant
or
deny
laboratory
accreditation,
and
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
number
of
total
affected
entities
(
i.
e.,
respondents)
is
54.
The
total
number
of
annual
responses
is
3,093.
The
total
annual
labor
costs
are
7,653
person
hours.
The
total
annual
capital
and
Operation/
Maintenance
costs
are
estimated
to
be
$
1,500,573.

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,
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
nonair
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.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:
3
.
.
.
(
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,
particulate
matter
emissions
from
new
residential
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/
Utility
of
the
Data
The
control
of
pollution
from
new
residential
wood
heaters
(
i.
e.,
stoves)
relies
on
the
reduction
of
particulate
matter
emissions
by
proper
wood
heater
design.
A
representative
unit
each
certified
model
line
is
tested
for
particulate
emissions.
The
manufacturer
also
conducts
periodic
quality
assurance
inspections
to
ensure
that
only
complying
stoves
are
sold
to
the
general
public.

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
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.

Adequate
recordkeeping,
and
reporting
is
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
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60,
Subpart
AAA.
4
3(
a)
Nonduplication
Duplication
in
the
reporting
requirements
under
the
regulations
is
minimal.
Provisions
have
been
made
in
the
regulations
to
allow
emission
tests
performed
for
Oregon
certification
to
also
apply
for
national
certification.
The
only
other
federal
paperwork
burden
which
affects
wood
heaters
is
the
Consumer
Product
Safety
Commission's
(
CPSC)
requirement
(
16
CFR
1406)
that
certain
solid
fuel­
fired
heating
appliances
be
accompanied
by
safety
warnings
and
installation
instructions
on
permanent
labeling
and
in
owner's
manuals.
Although
the
standards
also
require
certain
labeling
and
owner's
manual
contents,
the
required
disclosures
and
data
can
be
combined
with
the
CPSC­
required
label
and
owner's
manual
contents.
This
provision
was
agreed
upon
by
the
negotiating
committee
to
avoid
duplication.

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
3/
31/
2000.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
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.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
noncomplying
wood
heaters
would
decrease.

3(
e)
General
Guidelines
This
section
discusses
the
special
circumstances
where
the
regulations
exceed
two
of
the
nine
Paperwork
Reduction
Act
guidelines.
5
These
two
items
are
as
follows:

(
a)
Requiring
respondents
to
prepare
a
written
response
to
an
information
collection
request
in
less
than
30
days
after
its
receipt.

Accredited
laboratories
are
required
to
report
to
the
Agency
within
24
hours
whenever
a
manufacturer
which
has
notified
the
laboratory
that
it
intends
to
apply
for
alternative
certification
for
a
model
line
fails
to
submit
on
schedule
a
representative
unit
of
that
model
line
for
certification
testing.
This
requirement
is
designed
to
limit
circumvention
by
manufacturers
who
self­
certify,
but
who
then
fail
to
submit
on
schedule
the
self­
certified
model
for
testing
at
an
accredited
laboratory.
The
one­
day
reporting
requirement
will
enable
the
Agency
to
effectively
police
the
manufacture
and
sale
of
self­
certified
wood
heaters.

(
b)
Requiring
respondents
to
retain
records,
other
than
health,
medical,
or
tax
records,
for
more
than
3
years.

Manufacturers
and
laboratories
are
required
to
retain
certification
records
for
5
years,
and
to
retain
wood
heater
units
tested
for
certification
as
long
as
the
certification
is
in
effect.
Each
wood
heater
model
line
is
certified
for
a
5­
year
period,
and
records
must
be
maintained
to
answer
any
enforcement
questions
that
arise
during
that
period.

Manufacturers
are
also
required
to
maintain
sales
records
for
5
years.
This
information
is
useful
for
determining
compliance
with
requirements
based
on
volume
production.
The
information
is
also
useful
for
allowing
dissemination
of
emission
control
and
maintenance
information
to
commercial
owners,
and
assisting
State
and
local
officials
in
developing
emission
control
strategies
for
nonattainment
areas.

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).
6
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
Codes
The
appropriate
SIC
codes
for
the
respondents
affected
by
this
collection
activity
are
3433,
3631,
and
8734.
The
corresponding,
respective,
NAICS
codes
are
333414,
335221
and
541380.

4(
b)
INFORMATION
REQUESTED
(
i)
Data
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
60.530
thru
60.539(
b),
New
Source
Performance
Standards
for
New
Residential
Wood
Heaters
(
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
New
Residential
Wood
Heaters
­
NSPS
Subpart
AAA.
See
Table
A
Manufacturers,
testing
laboratories
and
retailers/
distributors
of
new
residential
wood
heaters
must
keep
the
following
records:
7
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
New
Residential
Wood
Heaters
­
NSPS
Subpart
AAA.
See
Table
A
(
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
tofuel
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.
Respondent
Activities
8
Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

The
means
of
collecting
the
required
information
does
not
employ
the
use
any
special
automated,
mechanical,
or
technical
collection
techniques.

The
reports
that
are
submitted
by
the
manufacturer
to
EPA
are
either
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.

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

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,
New
Residential
Wood
Heaters
­
NSPS
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
the
Agency
headquarters.
Portions
of
the
data
are
entered
into
a
special
database
program
maintained
exclusively
by
the
Agency
for
later
retrieval,
study
and
essential
reports.
9
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
regulatorynegotiation
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,
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
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
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
10
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.
There
are
no
new
rule
requirements,
since
the
last
ICR,
that
would
require
the
respondent
to
adjust
their
existing
recordkeeping
or
reporting
from
previously
applicable
instructions
or
requirements
that
burden
must
be
included.
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.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
Chapter
15.

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
7,653
(
rounded)
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
is
an
NSPS
rule
that
focuses
on
model
line
certification
using
specific
emission
testing
protocol
which
requires
technically
trained
personnel.
The
other
requirements
in
the
rule,
with
a
few
minor
exceptions,
would
also
employ
technically
oriented
personnel.
Therefore,
this
ICR
uses
a
single,
technical
labor
rate.

The
technical
labor
rate
used
is
derived
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
compensation
and
is
$
26.16
per
hour.
This
wage
rate
has
been
loaded
by
adding
110%
overhead
which
yields
a
final
labor
rate
of
$
54.94
per
hour.
11
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
total
annualized
capital/
startup
costs
are
$
527,978
(
rounded).
The
cost
are
taken
from
Table
2
and,
for
manufacturers,
consist
of
the
Certification
Test
($
498,750.00),
and
the
Application
For
Certification($
29,228.08)
and,
for
the
laboratories,
consist
of
the
Proficiency
Test
­
Accreditation
($
7,416.90)
and
Notice
of
Proficiency
Test
($
54.94).

The
annual
O&
M
costs
consist
of
all
the
remaining
costs
listed
in
Table2
and
total
$
972,595
(
rounded).
It
should
be
noted
that
the
manufacturer's
O&
M
costs
reflects
the
dollar
amount
paid
by
the
manufacturer
to
the
testing
laboratory
to
perform
certification
test(
with
no
associated
hourly
costs).
On
the
other
hand,
the
O&
M
costs
to
the
testing
laboratory
reflect
those
hourly
costs
necessary
to
comply
with
specific
rule
provisions
regarding
accrediation
and
the
maintenance
of
certification
test
records.

The
overall
burden
cost
to
industry
is
similar
to
that
reported
in
the
previous
ICR
($
1,347,984).
Two
minor
items
that
were
previously
listed
under
capital/
startup
cost
have
been
redesignated
as
O
&
M
costs.
The
overall
burden
cost
increase
is
attributed
entirely
to
the
higher
technical
labor
rate
used
in
this
IRC.

(
iii)
Capital/
Start­
up
vs.
O&
M
Costs
There
are
no
new
respondents
and
their
associated
capital
start­
up
costs
for
this
ICR.
The
O&
M
costs
have
been
previously
reported.

(
iv)
Summary
This
rule
is
involves
the
certification
of
wood
heater
model
lines
rather
than
the
installation
of
control
equipment
and
the
use
of
continuous
monitors.
For
reporting
purposes
on
the
OMB
83­
I
form,
the
figures
generated
under
item
6(
b)(
i)
are
reported
as
Capital/
Startup
and
O&
M
costs
[
item
6(
b)(
2)].

Therefore,
the
Capital/
Start­
up
costs
for
this
ICR
are
$
527,978.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14a:
Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
972,595.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
12
14b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
1,500,573.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

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
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
194,452
(
from
Table
1:
Agency
Burden
Costs).
This
cost
is
based
on
an
average
wage
of
a
(
GS
10
step
1
employee
rate,
($
17.09
hr
+
110%
overhead
=
$
35.89.
This
rate
is
from
OPM's
2000
General
Schedule,
excluding
locality
pay,
basic
rates.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Title
(
A)
No.
New
Sources
per
Year
(
B)
No.
of
Initial
Reports
for
New
Sources
(
C)
No.
of
Existing
Sources
(
D)
No.
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
Wood
Heater
NSPS
Zero
Zero
54
3,093
3,093
The
number
of
total
respondents
is
54.
This
number
is
the
sum
of
numbers
in
columns
A
and
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13a.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
13
anticipated
in
one
year.

The
total
annual
responses
is
3,093.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13b.
The
total
annual
labor
costs
are
7,653.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
1,500,573.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14c.
These
costs
are
detailed
in
sections
6(
b)(
i)­(
iii)
of
this
ICR.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
are
attached
as
Table
1:
Agency
Burden,
and
Table
2:
Industry
Burden.

6(
f)
Reasons
for
Change
in
Burden
The
wood
heater
has
been
fairly
stagnate
over
the
past
three
years
and
the
number
of
affected
sources
remains
approximately
the
same.
Therefore,
the
rather
modest
burden
cost
increase
is
attributed
entirely
to
the
higher
technical
labor
rate
used
in
this
IRC.
6(
g)
Burden
Statement
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
14
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
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
1176.06
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.
