SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63,
Subpart JJ) (Renewal)

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) (Renewal)

EPA ICR 1716.06, OMB Control Number 2060-0324

1(b)  Short Characterization/Abstract

The final National Emission Standards for Hazardous Air Pollutants
(NESHAP) 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, performance test measurements
and results; and 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.  In general, these notifications, reports and
records are required 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.

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 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 United States Environmental Protection
Agency (EPA) regional office.

Approximately 750 sources are currently subject to the standard, based
on information provided by the American Furniture Manufacturers
Association.  Of these sources, 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.

The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (ICR) with the following “Terms of
Clearance.”

The assumptions underlying estimates of industry and agency burden and
costs of the collection should be updated in the next renewal.

	The industry and cost burden have been updated using rates from the
United States Department of Labor, Bureau of Labor Statistics, March
2009, “Table 2. Civilian Workers, by Occupational and Industry
group” and the Office of Personnel Management (OPM), 2010 General
Schedule.

The wood furniture manufacturing operations consists of 750 facilities
in the United States, which are all privately owned and operated.  None
of the 750 facilities in the United States are owned by either state,
local, tribal or the Federal government.

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost - NESHAP for Wood Furniture Manufacturing
Operations (40 CFR part 63, subpart JJ).  The burden to the “Federal
government” is attributed entirely to work performed by Federal
employees or government contractors.  This burden may be found in Table
2: Average Annual EPA Burden - NESHAP for Wood Furniture Manufacturing
Operations (40 CFR part 63, subpart JJ).

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 (HAPs). 
These standards are applicable to new or existing sources of HAPs 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, the
NESHAP 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 from hazardous air pollutant emissions from
wood furniture manufacturing operations require the installation of
properly designed equipment and the operation and maintenance of that
equipment.  Emissions of HAPs from wood furniture manufacturers are the
result of operation of the affected facilities.  This standard relies on
the reduction of hazardous air pollutants by the use of compliant or low
HAP content coatings, or the use of control devices, or some combination
of these three control technologies.

The notifications required in the applicable regulations are used to
inform the Agency or delegated authority when a source becomes subject
to the requirements of the regulations.  The reviewing authority may
then inspect the source to check if the pollution control devices are
properly installed and functioning properly.  The required
quarterly/semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify operation/
maintenance procedures and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting
requirement described in this ICR is used by the Agency to ensure that
facilities affected by the NESHAP continue to operate the control
equipment in compliance with the regulation.  Adequate monitoring,
recordkeeping, and reporting are necessary to ensure compliance with the
applicable regulations, 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 (74 FR 34583) on July 8, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

During a previous renewal of this ICR, 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 as applied to the standards.  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
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

3(f)  Confidentiality

The required information has been determined not to be confidential. 
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 (CBI) (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 Codes

The respondents to the recordkeeping and reporting requirements are wood
furniture manufacturers.  The United States Standard Industrial
Classification (SIC) and the North American Industry Classification
System (NAICS) 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



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
National Emission Standards for Hazardous Air Pollutants for Wood
Furniture Manufacturing Operations (40 CFR part 63, subpart JJ).

A source must make the following reports:

Reports for 40 CFR part 63, subpart JJ

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), 63l7(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 for 40 CFR part 63, subpart JJ

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)

Work practice standards records	63.806(e), 63.10(b)(2)

Records of compliance monitoring system 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(a),
63.10(b)(3)

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

Records of performance test/evaluations	63.806(a), 63.10(b)(2)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., internal feed.  Although
personnel at the source still need to evaluate the data, this type of
monitoring equipment 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 percent of the
respondents use electronic reporting.

(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.

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 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.



 	Currently, sources are using monitoring equipment that provides
parameter data in an automated way.  Although personnel at the source
still need to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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,
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 operational.  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 and records maintained by the respondents
are tabulated and published for 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 AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
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

According to the Final Rule (64 FR 31358):

The Agency has found that two of the twenty-one firms that potentially
could be subject to the standards are small firms.  Of the two, data
indicate that one is an area source which would not be covered by the
standards.  The second source could be major and subject to the
requirements of the standards.  Information available to the Agency
shows that the second source is able to achieve the control levels of
the NESHAP using existing equipment.  The testing, monitoring,
recordkeeping and reporting requirements are essentially identical to
the current requirements and, thus, should cause little or no change in
these burdens.

This ICR conservatively assumes that two of twenty-one ownership firms
are small, and extrapolates this fraction to the affected facilities,
assuming that approximately 9½ percent, or 71 affected facilities, are
small entities (e.g., small businesses).  However, the impact on small
entities was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the type of control equipment employed, the recordkeeping
and reporting requirements are the same for both small and large
entities.  The Agency considers these requirements the minimum needed to
ensure compliance and, therefore, cannot reduce them further for small
entities.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ).

6.  Estimating the Burden and Cost of the Collection

Table 1 document the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Wherever 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 47,189
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

This ICR uses the following labor rates: 

Managerial	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2009, “Table 2. Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

	

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry costs associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup 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. 

The total operation and maintenance (O&M) costs for this ICR are
$18,000.  This is the total of column G. 

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. 

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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.

This cost is based on the average hourly labor rate as follows:

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

	These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

	

	Based on our research for this ICR, there are approximately 750
existing sources currently subject to the standard.  It is estimated
that no additional sources per year will become subject to the
regulation in the next three years.

	Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

Year	(A)

Number of New Respondents	(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



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.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

Number of Respondents That Keep Records But Do Not Submit Reports	(E)

Total Annual Responses =

(AxB)+(CxD)+F

40 CFR part 63, subpart JJ	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 respondents is 750.

The number of Total Annual Responses is 1,053.  This is the number in
column E of the Respondent Universe and Number of Responses per Year
table above.

The total annual labor costs are $4,438,012.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63,
subpart JJ), below.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

6(f)  Reasons for Change in Burden

There are no changes in the respondent labor hours in this ICR compared
to the previous ICR.  This is due to two considerations: 1) the
regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for the respondents is very low, negative or non-existent.  Therefore,
the labor hours in the previous ICR reflect the current burden to the
respondents and are reiterated (with a correction for rounding) in this
ICR.  It should be noted that there is an apparent decrease of one hour
in the total labor hours for this ICR.  Total labor hours for this ICR
are 47,189 rather than 47,190 as in the previous ICR.  The previous ICR
did not carryout decimal places for the calculations in Table 1.  

	There is an increase in both respondent and Agency labor costs
resulting from labor rate increases from 2003 to 2009.  In addition,
Tables 1 and 2 were expanded to include managerial and clerical labor
rates.

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
EPA-HQ-OECA-2009-0380, which is available for online viewing at
www.regulations.gov, or in person viewing at the Enforcement and
Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W.,
Washington, D.C.  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 (202) 566-1752.  An electronic version of
the public docket is available online at www.regulations.gov.  This site
can be used to submit or view public comments, access the index listing
of the contents of the public docket, and to access those documents in
the public docket that are available electronically.  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,
N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2009-0380 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.

Table 1:  Annual Respondent Burden and Cost – NESHAP for Wood
Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) 











Burden item









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

	Person-hours per occurrence	No. of occurrences per respondent per year
Person-hours per respondent per year	Respondents per year  a	Technical
person- hours per year	Management person-hours per year	Clerical person-
hours per year	Cost, $b



	(C=AxB)

(E=CxD)	(Ex0.05)	(Ex0.1)

	1.  Applications for construction, reconstruction and modification a,
d, e	4	1	4	39	156	7.8	15.6	$16,872 

2.  Survey and studies	N/A







	3.  Reporting Requirements









   A. Read instructions c	1	1	1	300	300	15	30	$32,446 

   B. Create information	See 3D







	   C. Gather existing information	See 3D







	   D. Write reports









        Notification of construction/reconstruction d	2	1	2	9	18	0.9	1.8
$1,947 

        Notification of modifications e                           
(physical/operational changes)	8	1	8	30	240	12	24	$25,957 

        Notification of anticipated startup                     
(including reconstruction and modification)	2	1	2	39	78	3.9	7.8	$8,436 

        Notification of actual startup	2	1	2	39	78	3.9	7.8	$8,436 

        Semiannual compliance status reports f	4	2	8	270	2,160	108	216
$233,614 

        Semiannual excess emissions reports g	4	2	8	29	232	11.6	23.2
$25,092 

        Quarterly excess emissions reports  h	4	4	16	2	32	1.6	3.2	$3,461


        List of types and quantities of materials              used,
including VHAP and solids content           data	1.5	52	78	300	23,400
1,170	2340	$2,530,815 

Subtotal Reporting



	30,698	$2,887,076 

4.  Recordkeeping requirements









   A. Read instructions 	See 3A







	   B. Plan activities 	N/A







	   C. Implement activities	N/A







	   D. Time to enter information 









        Record of operators completing training             courses	1	2
2	300	600	30	60	$64,893 

        Records of CMS parameters i	1.5	52	78	30	2,340	117	234	$253,082 

        Records of types and quantities of                     
materials used, including VHAP and solids         common data	See 3D







	   E. Records for incidental and area sources  j	1	12	12	450	5,400	270
540	$584,034 

   F. Annual personnel refresher course k	8	1	8	750	6,000	300	600
$648,927 

  G. Time for audits	N/A







	Subtotal Recordkeeping



	16,491	$1,550,936

Subtotals Labor Burden and cost  



	41,034	2,052	4,103	$4,438,012 

TOTAL LABOR BURDEN AND COST (rounded)



	47,189	$4,438,012 



















Assumptions:









a  We assume that the average number of respondents that will be subject
to the rule will be 750.  Of these sources, approximately 300 are major
sources and 450 are incidental/area sources.  There will be no
additional new sources that will become subject to the rule over the
three-year period of this ICR. 

b We assume a technical labor rate of $97.59, managerial rate $114.77,
and clerical rate of $48.26 from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by
Occupational and Industry group.” Workers by Occupational and Industry
Group.  The rates are from column 1: Total compensation.  The wage rate
obtained from the table has been increased by 110 percent to account for
the benefit packages available to those employed by private industry.

c  We have assumed that there will be 39 respondents (30 modified + 9
reconstructed) that will apply for construction, reconstruction and
modification.

d  It is assumed that approximately 3 percent of the total number of
major sources will apply for reconstruction of their facility (300x3=9).



e  It is assumed that 10 percent of the total number of major sources
will apply for modification of their facility (300x10=30). 



	f  We have assumed that 90 percent of the affected sources will comply
by using compliant coatings or by using the HAP averaging approach
(300x90%=270).

	g  We have assumed that 10 percent of the affected facilities will
comply by using control devices, but only 95 percent 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 report is 29 [300x10%x95%=29
(rounded)].

h   We have assumed that the number of sources submitting quarterly
reports is 2 [300x10%x5%=2 (rounded)].





i   It is assumed that 10 percent of affected facilities will use
control devices to comply (300x10%=30).

J  We have assumed that 450 incidental/area sources affected facilities
will record information once per month.





k  It is assumed that all of the affected sources will participate in
the annual personnel refresher source once per year.









Table 2:  Average Annual EPA Burden - NESHAP for Wood Furniture
Manufacturing Operations (40 CFR Part 63, Subpart JJ) 









Activity	(A)	(B)	(C)	(D)	(E)	(F)

	EPA person-hours per occurrence	 No. of occurrences per plant per year
Technical person-hours per year (C=AxB)	Management person-hours per year
(Cx0.05)	Clerical person-hours per year (Cx0.1)	Cost, $ b

1.  Excess emissions enforcement activities







2.  Report Review







     A.  Review notification of construction/reconstruction c	2	9	18	0.9
1.8	$1,947 

     B.  Review notification of modifications (physical/operational
changes) d	2	30	60	3	6	$6,489 

     C.  Review semiannual compliance status reports and certifications
e	8	270	2,160	108	216	$233,614 

     D.  Review semiannual excess emission reports f	8	29	232	11.6	23.2
$25,092 

     E.  Review quarterly excess emission reports g	16	2	32	1.6	3.2
$3,461 

Subtotals Labor Burden and cost

	2,502	125	250	$270,603 

 TOTAL ANNUAL BURDEN AND COST (rounded)

	2,877	$270,603 















Assumptions:







a  We have assumed that the average number of respondents that will be
subject to the rule will be 750.  Of these sources, approximately 300
are major sources and 450 are incidental/area sources.  There will be no
additional new sources that will become subject to the rule over the
three-year period of this ICR. 

b Assume a technical labor rate of $97.59, managerial rate $114.77, and
clerical rate of $48.26 from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by
Occupational and Industry group.” Workers by Occupational and Industry
Group.  The rates are from column 1: Total compensation.  The wage rate
obtained from the table has been increased by 110 percent to account for
the benefit packages available to those employed by private industry.

c  It is assumed that approximately 3 percent of the total number of
major sources will apply for reconstruction of their facility (300x3=9).


d  It is assumed that 10 percent of the total number of major sources
will apply for modification of their facility (300x10=30).

e  We have assumed that 90 percent of the affected sources will comply
by using compliant coatings or by using HAP averaging approach
(300x90%=270).

	f  We have assumed that 10 percent of the affected facilities will
comply by using control devices, but only 95 percent 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 report is 29 [300x10%x95%=29
(rounded)].

g  We have assumed that the number of sources submitting quarterly
reports is 2 [(300x10%x5%=2 (rounded)].

	

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