Burden Calculation Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	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

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Sheet 2: # Responses

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 applicability (one-time)	0	0	0	0
Notification of construction/reconstruction	12	1	0	12
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 compliance status 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

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Wood Furniture Manufacturing Operations (40 CFR Part 63, Subpart JJ) (Renewal)
										ERG Notes
Burden Item	A	B	C	D	E	F	G	H			TECH	$112.98
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b			MGMT	$149.35
1. Applications for construction, reconstruction, and modification c	4	1	4	53	212	10.6	21.2	26,696.84			CLER	$54.81
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			Source Type	No.
B. Create information d	See 4D										Existing (major)	406
C. Gather existing information	See 3D										Existing (area)	450
D. Write reports											Formaldehyde	150
Notification of applicability (one-time)a	2	1	2	0	0	0	0	0.00
Notification of construction/reconstruction c	2	1	2	12	24	1.2	2.4	3,022.28			New	0
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 semi-annual compliance status report counts.
Notification of increased annual VHAP usaged	2	1	2	0	0	0	0	-
Semiannual compliance status reports (compliant coatings) e	4	2	8	365	2,920	146.0	292.0	367,711.22
Semiannual compliance status reports (control devices) f	4	2	8	39	312	15.6	31.2	39,289.69
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 mainteance planh	8	1	8	53	424	21.2	42.4	53,393.68
Formulation assessment planh	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		this is just records not a report. See supporting statement and 63.806(b)-(d). Also, it appears that the records were listed as weekly previously, but monthly is the highest number I see in the rule.
Records of formaldehyde contentk	2	12	24	150	3,600	180	360	453,342.60
Records of CMS parametersl	1.5	52	78	41	3,198	159.9	319.8	402,719.34
Records of monthly averaging calculationsm	2	12	24	91	2,184	109.2	218.4	275,027.84
Records of operators training work practicen	1	1	1	856	856	42.8	85.6	107,794.80		changed frequency to once per year
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		new row - inspections have to occur monthly
Records of semi-annual reports and supporting calculationse,f	1	2	2	404	808.0	40.4	80.8	101,750.23
Records of quarterly reports and supporting calculationsg	1	4	4	2	8.0	0.4	0.8	1,007.43
Records of start-up, shutdown and malfunctionp	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 coursen	8	1	8	406	3,248	162.4	324.8	409,015.77		edited # of sources subject to this requirement, this now matches the # of sources keeping records for the training and matches the requirements in the rule.
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
								47.7 hrs/response
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.										edited to add note about reviewing requrieements 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.										noel to update the note based on new rates and data source.
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.										edited footnote to match assumption.
d EPA does not estimate any sources will need to report a notification of increased annual VHAP usage.										new footnote to match new burden line item and assumption
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 resconstructed 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.										new note
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 averagin 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).										new note
n EPA assumes all major sources will participate in the annual personnel refresher course once per year and record the training participation.										edited note; areas sources are not subject to this training.
o EPA assumes all major sources will conduct monthly inspections and maintain records of these and other work practices.										edited note; areas sources are not subject to this training.
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.										new note
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).										edited the note to make it clear what area sources are required to do.
r Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

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		TECH	$48.08
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b		MGMT	$64.80
1. Excess emissions enforcement activities	N/A									CLER	$26.02
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 Testsc	8	1	8	5	40	2	4	2,156.88		this row was missing previously
D. Review notification of increased VHAP usaged	2	1	2	0	0	0	0	0.00		this row was missing previously
E. Review semiannual compliance status reports (compliant coatings) e	8	2	16	365	5,840	292	584	314,904.5
F. Review semiannual compliance status reports (control devices) 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 LABOR 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 ).
e 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.
							38.57