1716ss10

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 Number 1716.10, OMB Control Number 2060-0324.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) were proposed on December 6, 1994, and promulgated on December 7, 1995. Amendments to the rule were proposed on December 21, 2010, and promulgated on November 21, 2011. These standards apply to both existing and new wood furniture manufacturing operations that are major sources of hazardous air pollutants (HAPs). A “major source” is a stationary source or group of stationary sources that emit or have the potential to emit 10 tons per year (tpy) or more of a HAP or 25 tpy or more of a combination of HAPs. New facilities include those that commenced construction, modification, or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart JJ.

These standards also apply to existing and new incidental sources and to area sources. These sources are only required to maintain purchase or usage records demonstrating that they meet the definition for incidental or area sources. Incidental and area sources are not subject to any other provisions of these standards. An “incidental source,” as defined in these standards, is a major source that is primarily engaged in the manufacture of products other than wood furniture or wood furniture components, and that uses no more than 100 gallons per month of finishing material or adhesives in the manufacture of wood furniture or wood furniture components. An “area source” is any stationary source that is not a major source.”

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They 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. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least five years following the generation date of such maintenance reports, and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The “Affected Public” are owners and operators of wood furniture manufacturing facilities. The vast majority of the facilities are privately-owned, for-profit businesses¹. We assume that they will all respond to EPA inquiries. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors, and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

Based on our consultations with industry representatives, there is an average of one affected facility at each plant site, and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, an average of 406 existing major sources and 450 existing incidental/area sources will be subject to these standards. Of these sources, 150 will use coatings containing formaldehyde, and will be subject to the formaldehyde documentation and reporting requirements. No new sources are expected to become subject to these same standards over the next three years.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/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, HAP emissions from wood furniture manufacturing operations either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart JJ.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with the applicable regulations, which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standards. Continuous emission monitors are used to ensure compliance with these standards at all times.

The notifications required in these standards 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 and semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart JJ.

3(a) Non-duplication

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 its 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, duplication does not exist.

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 (82 FR 29552) on June 29, 2017. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Kitchen Cabinets Manufacturers Association, at 703-264-1690, and the American Home Furnishings Alliance, at 336-884-5000.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.

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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to these 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. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, Subpart B - Confidentiality of Business Information (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

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and operators of wood furniture manufacturing facilities. The United States Standard Industrial Classification (SIC) codes and corresponding North American Industry Classification System (NAICS) codes for respondents affected by the standard are listed in the following table:

Standard (40 CFR Part 63, Subpart JJ)	SIC Codes	NAICS Codes
Wood Kitchen Cabinet and Countertop Manufacturing	2434	337110
Household and Institutional Furniture Manufacturing	2511, 2519, 2599	33712
Wood Office Furniture Manufacturing	2521	337211
Custom Architectural Woodwork and Millwork Manufacturing	2541	337212
Other Furniture Related Products Manufacturing	2515	337910
All Other Furniture Related Products Manufacturing	2499	321999

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ).

A source must make the following reports:

Notifications
Notification of applicability.	63.807(a), 63.9(b)
Notification and application of construction or reconstruction.	63.807(a), 63.5(d)
Notification of physical or operational change (e.g. modification) which may increase the emission rate.	63.807(a), 63.5(b)(6)
Notification of anticipated date of initial startup.	63.807(a), 63.5(b), 63.9(b)
Notification of actual startup.	63.9b(4)(v), 63.9(b)(5)(ii)
Notification of performance tests (applies only to affected sources using a control device to comply with the rule).	63.807(a), 63.7(b), (c), and (g), 63.8(e), 63.9(e), 63.10(d)(2)
Notification of compliance status (initial).	63.807(b), 63.9(h)
Notification of increase of annual VHAP usage.	63.807(e), 63.803(l)(4)

Reports
Semiannual compliance status reports.	63.807(c) 63.807(d), and 63.10(e)
Quarterly excess emission reports.	63.807(d)

A source must keep the following records:

Recordkeeping
Work practice standards implementation plan.	63.803(a), 63.806(e)
Leak inspection and maintenance plan.	63.803(c)
Formulation assessment plan	63.803(l)
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)
Records of product data sheets, the types and quantities of finishing material, thinner, contact adhesive, and strippable spray booth coatings and viscosity, VHAP, VOC, and formaldehyde content.	63.806(b), 63.806(d), and 63.10(b)(2)
Records of monitoring system compliance data.	63.10(b)(2), 63.10(c)
Records of monthly average emission calculations.	63.806(c)
Work practice standards records for annual operator training/refresher, inspection and maintenance inspections, solvent accounting, formulation assessment	63.806(e), 63.803(b), 63.803(c), 63.803(d), 63.803(l)
Records of control efficiency calculations, operating parameters, compliance certifications, and semiannual or quarterly reports.	63.806(f) and (g), 63.806(h-j)
Startup, shutdown or malfunctions and corrective action records.	63.806(k), 63.10(b)(2)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for the control device.

Perform initial performance test, Reference Method 18 (HAP concentration of gaseous air streams); 1 or 1A (sample and velocity traverses); 2, 2A, 2C, or 2D (velocity and volumetric flow rates); 3 (exhaust gases); and 4 (stack gas moisture) tests, and repeat performance tests 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.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and 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 and quarterly reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS 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/operator for five years.

5(c) Small Entity Flexibility

The majority of respondents are large entities (i.e., large businesses). During rule development, the Agency conservatively estimated that approximately 9.5 percent of affected sources were small entities (i.e., small businesses). Therefore, of the total affected facilities (i.e., 856), the Agency estimates that approximately 81 are small entities (856 x 9.5% = 81).

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 types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for 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. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 70,800 hours (Total Labor Hours from Table 1 below). 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 $149.35 ($71.12 + 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 standard 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 these regulations. The annual operation and maintenance (O&M) 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)
Control device (several options available)	$0	0	$0	$600	41	$24,600

¹ EPA assumes 10% of affected major sources will use control devices to comply with the standard (406 x 0.1 = 41, after rounding).

There are no total capital/startup costs for this ICR, as shown above in column D.

The total operation and maintenance (O&M) costs for this ICR are $24,600. 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 $24,600. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is estimated to be $380,000.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

These rates are from the Office of Personnel Management (OPM), 2017 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: Average Annual EPA Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new sources are expected to become subject to these standards over the next three years. The overall average number of respondents, as shown in the table below, is 856 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports 2	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	406	450	0	856
2	0	406	450	0	856
3	0	406	450	0	856
Average	0	406	450	0	856

¹ New respondents include sources with constructed, reconstructed, and modified affected facilities.

² Incidental/area sources are only required to maintain purchase or usage records demonstrating that they meet the definition for incidental or area sources.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 856.

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

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Application for construction, reconstruction, and modification	53	1	0	53
Notification of construction/ reconstruction	12	0	0	12
Notification of applicability (one-time)	0	0	0	0
Notification of modification	41	1	0	41
Notification of anticipated startup	53	1	0	53
Notification of actual startup	53	1	0	53
Notification of performance test	5	1	0	5
Notification of compliance status	0	0	0	0
Notification of increased annual VHAP usage	0	0	0	0
Semiannual compliance status reports (compliant coatings)e	365	2	0	730
Semiannual excess emissions reports (control devices)f	39	2	0	78
Quarterly excess emissions reports	2	4	0	8
Records for incidental and area sources	0	0	450	450
			Total	1,483

The number of Total Annual Responses is 1,483.

The total annual labor costs are $7,760,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor hours are 70,800 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 48 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $24,600. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 8,090 labor hours at a cost of $380,000; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

The increase in burden hours and the number of responses from the most recently approved ICR is due to several adjustments: 1) this ICR accounts for the time for each source to refamiliarize themselves with the regulatory requirements each year; and 2) this ICR added in one-time requirements for reconstructed and modified sources that were missing from the previous renewal and edited the frequency of records to better match regulatory requirements. Overall, these changes resulted in an increase of 4,565 hours.

Regarding the number of responses, this ICR adds in new responses for notifications of performance tests for reconstructed and modified sources, and it adds a row for 450 area sources that keep records but do not submit reports. In addition, it removed 406 responses for types and quantities of materials used, including VHAP and solids content data since these are record requirements, but not reports. Overall, these changes resulted in an increase of 49 responses.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 48 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 neither conduct nor 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 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-2014-0057. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the 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 in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2014-0057 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) (Renewal)

Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b
1. Applications for construction, reconstruction, and modification c	4	1	4	53	212	10.6	21.2	26, 696.84
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with the regulatory requirements	1	1	1	856	856	42.8	85.6	107,794.80
B. Create information d	See 4D
C. Gather existing information	See 3D
D. Write reports
Notification of applicability (one-time)a	2	1	2	0	0	0	0	0
Notification of construction/ reconstruction c	2	1	2	12	24	1.2	2.4	3,022.28
Notification of modification (physical/operational changes) c	8	1	8	41	328	16.4	32.8	41,304.55
Notification of anticipated startup (including reconstruction and modification) c	2	1	2	53	106	5.3	10.6	13,348.42
Notification of actual startup c	2	1	2	53	106	5.3	10.6	13,348.42
Notification of performance test c	2	1	2	5	10	0.5	1	1,259.29
Notification of compliance status	Included in semiannual compliance status reports
Notification of increased annual VHAP usage d	2	1	2	0	0	0	0	0
Semiannual compliance status reports (compliant coatings) e	4	2	8	365	2,920	146	292	367,711.22
Semiannual compliance status reports (control devices) f	4	2	8	39	312	15.6	31.2	35,127.46
Quarterly excess emissions reports g	4	4	16	2	32	1.6	3.2	4,029.71
Subtotal for Reporting Requirements					5,642			617,805
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
Prepare work practice standards implementation planh	8	1	8	53	424	21.2	42.4	53,393.68
Prepare leak inspection and maintenance planh	8	1	8	53	424	21.2	42.4	53,393.68
Formulation assessment plan h	8	1	8	53	424	21.2	42.4	53,393.68
D. Time to enter information
Records of applicabilityi	1	1	1	53	53	2.7	5.3	6,674.21
Records of performance testc	1	1	1	5	5	0.3	0.5	629.64
Records of types and quantities of materials used, including VHAP, VOC, viscosity and solids content dataj	1.5	12	18	856	15,408	770.4	1540.8	1,940,306.33
Records of formaldehyde content k	2	12	24	150	3,600	180	360	453,342.60
Records of CMS parameters l	1.5	52	78	41	3,198	159.9	319.8	402,719.34
Records of monthly averaging Calculations m	2	12	24	91	2,184	109.2	218.4	275,027.84
Records of operators training work practice n	1	1	1	856	856	42.8	85.6	107,794.80
Records of other work practices (inspection and maintenance, solvent accounting, formulation assessment) o	2	12	24	856	20,544	1,027.2	2,054.4	2,587,075.10
Records of semi-annual reports and supporting calculations e,f	1	2	2	404	808.0	40.4	80.8	101,750.23
Records of quarterly reports and supporting calculations g	1	4	4	2	8.0	0.4	0.8	1,007.43
Records of start-up, shutdown and malfunction p	2	12	24	4	96.0	4.8	9.6	12,089.14
E. Records for incidental and area sources q	1	12	12	450	5,400	270	540	680,013.90
F. Annual personnel refresher course n	8	1	8	406	3,248	162.4	324.8	409,015.77
G. Audits	N/A
Subtotal for Recordkeeping Requirements					65,182			7,137,627
TOTAL ANNUAL BURDEN AND COST (ROUNDED)r					70,800			7,760,000
TOTAL CAPITAL AND O&M COST (rounded)r								24,600
GRAND TOTAL (rounded)r								7,780,000

^a EPA estimates 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new major or area sources will become subject over the next 3 years therefore the one-time notification of applicability requirement does not apply. Modified or reconstructed sources will submit their applicability notifications as part of their notifications of construction or modification. We assume that each source subject to the standard will have to familiarize with the regulatory requirements each year.

^b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c EPA assumes 3% of sources will apply for reconstruction (406 x 0.03 = 12, after rounding) and 10% will apply for modification (406 x 0.1 = 41, after rounding). Of these 53 sources, 10% of the sources (rounded to 5 sources) will comply using control devices and be required to submit notification of the performance test.

^d EPA does not estimate any sources will need to report a notification of increased annual VHAP usage.

^e EPA assumes 90% of sources will comply by using compliant coatings or by using the HAP averaging approach (406 x 0.9 = 365, after rounding ).

^f EPA assumes 10% of sources will comply by using control devices. However, only 95% are assumed to be in compliance at any given time, and would be required to submit reports semiannually rather than quarterly. Therefore, the number of affected sources submitting semiannual reports is 39 (406 x 0.1 x 0.95 = 39, after rounding).

^g EPA assumes 2 sources will submit quarterly reports (406 x 0.1 x (1 - 0.095) = 2, after rounding).

^h This is a one-time requirement. EPA assumes only the reconstructed or modified sources will require this plan to be created or updated to reflect new operations. Other sources are assumed to already have a plan on file. This plan is not required to be submitted, but only kept on-site as a record.

ⁱ Records of applicability is a one-time requirement. EPA assumes only the reconstructed or modified sources will require to create this record. Other existing sources have previously created this record.

^j EPA assumes all major sources will record information once per month.

^k EPA estimates 150 major sources will use coatings containing formaldehyde. These sources will be required to record the formaldehyde content of their coatings on a monthly basis. Reporting of formaldehyde content will occur on an annual basis and will coincide with existing reporting requirements mentioned above. Therefore, the only burden incurred by sources will be that of documenting the information.

^l EPA assumes 10% of affected sources will use control devices to comply with the standard (406 x 0.1 = 41, after rounding).

^m EPA assumes that of the 90% of affected sources that use the compliant coatings or emissions averaging approach, 25% will use the HAP averaging approach and must keep the records to support the calculations (406 x 0.9 x 0.25 = 91 , after rounding).

ⁿ EPA assumes all major sources will participate in the annual personnel refresher course once per year and record the training participation.

^o EPA assumes all major sources will conduct monthly inspections and maintain records of these and other work practices.

^p EPA assumes that 10% of all sources using control devices (0.1 x 41 = 4, when rounded) will have startup, shutdown, or malfunction records to document once per month.

^q EPA assumes 450 affected incidental/area sources per year will record information once per month in order to demonstrate they are an area source, pursuant to 40 CFR Part 63 Subpart JJ, 63.800(b)(1)-(3).

^r Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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

Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b
1. Excess emissions enforcement activities	N/A
2. Report review
A. Review notification of construction/reconstruction c	2	1	2	12	24	1.2	2.4	1,294.13
B. Review notification of modification (physical/operational changes) c	2	1	2	41	82	4.1	8.2	4,421.60
C. Performance Tests c	8	1	8	5	40	2	4	2,156.88
D. Review notification of increased VHAP usage d	2	1	2	0	0	0	0	0.00
E. Review semiannual compliance status report (compliant coatings) f	8	2	16	365	5,840	292	584	314,904.5
F. Review semiannual excess emission reports f	8	2	16	39	624	31.2	62.4	33,647.33
G. Review quarterly excess emission reports g	16	4	64	2	128	6.4	12.8	6,902.02
H. Review annual records of formaldehyde content h	2	1	2	150	300	15	30	16,176.60
TOTAL ANNUAL BURDEN AND COST (ROUNDED)i					8,090			380,000

^a EPA estimates 406 existing major sources and 450 existing incidental/area sources will be subject to the standard. No new major or area sources will become subject over the next 3 years.

^b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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.

^c EPA assumes 3% of sources will apply for reconstruction (406 x 0.03 = 12, after rounding) and 10% will apply for modification (406 x 0.1 = 41, after rounding). Of these 53 sources, 10% of the sources (rounded to 5 sources) will comply using control devices and be required to submit notification of the performance test.

^d EPA does not estimate any sources will need to report a notification of increased annual VHAP usage.

^e EPA assumes 90% of sources will comply by using compliant coatings or by using the HAP averaging approach (406 x 0.9 = 365, after rounding ).

^f EPA assumes 10% of sources will comply by using control devices. However, only 95% are assumed to be in compliance at any given time, and would be required to submit reports semiannually rather than quarterly. Therefore, the number of affected sources submitting semiannual reports is 39 (406 x 0.1 x 0.95 = 39, after rounding).

^g EPA assumes 2 sources will submit quarterly reports (406 x 0.1 x (1 - 0.095) = 2, after rounding).

^h EPA estimates 150 major sources will use coatings containing formaldehyde. These sources will be required to record the formaldehyde content of their coatings on a monthly basis. Reporting of formaldehyde content will occur on an annual basis and will coincide with existing reporting requirements. Therefore, the only burden incurred by sources will be that of recording the information.

ⁱ Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

1 A small percentage of the facilities may be owned by the Federal government, but the exact number is unknown.