Burden Calculations Table

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

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
	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	18	72	3.6	7.2	$9,809.28			Labor Costs
2. Surveys and studies	N/A										Managerial	$149.84
3. Reporting requirements											Technical	$122.66
A. Familiarization with the regulatory requirements	1	1	1	230	230	11.5	23.0	$31,335.20			Clerical	$60.88
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	4	8	0.4	0.8	$1,089.92
Notification of modification (physical/operational changes) c	8	1	8	14	112	5.6	11.2	$15,258.88
Notification of anticipated startup (including reconstruction and modification) c	2	1	2	18	36	1.8	3.6	$4,904.64
Notification of actual startup c	2	1	2	18	36	1.8	3.6	$4,904.64
Notification of performance test c	2	1	2	2	4	0.2	0	$544.96
Notification of increased annual VHAP usage d	2	1	2	0	0	0	0	$0
Notification of compliance status / Semiannual compliance status reports (compliant coatings) e	4	2	8	128	1,024	51	102	$139,509.76
Semiannual compliance status reports (control devices) f	4	2	8	13	104	5.2	10.4	$14,168.96
Quarterly excess emissions reports g	4	4	16	1	16	0.8	1.6	$2,179.84
Subtotal for Reporting Requirements					1,888			$223,706
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 plan h	8	1	8	18	144	7.2	14.4	$19,618.56
Prepare leak inspection and maintenance plan h	8	1	8	18	144	7.2	14.4	$19,618.56
Formulation assessment plan h	8	1	8	18	144	7.2	14.4	$19,618.56
D. Time to enter information
Records of applicability i	1	1	1	18	18	0.9	1.8	$2,452.32
Records of performance test c	1	1	1	2	2	0.1	0.2	$272.48
Records of types and quantities of materials used, including VHAP, VOC, viscosity and solids content data j	1.5	12	18	142	2,556	128	256	$348,229.44
Records of formaldehyde content k	2	12	24	52	1,248	62	125	$170,027.52
Records of CMS parameters l	1.5	52	78	14	1,092	55	109	$148,774.08
Records of monthly averaging calculations m	2	12	24	32	768	38	77	$104,632.32
Records of operators training work practice n	1	1	1	142	142	7.1	14.2	$19,346.08
Records of other work practices (inspection and maintenance, solvent accounting, formulation assessment) o	2	12	24	142	3,408	170	341	$464,305.92
Records of semi-annual reports and supporting calculations e,f	1	2	2	141	282	14.1	28.2	$38,419.68
Records of quarterly reports and supporting calculations g	1	4	4	1	4.0	0.2	0.4	$544.96
Records of start-up, shutdown and malfunction p	2	12	24	1	24	1.2	2.4	$3,269.76
E. Records for incidental and area sources q	1	12	12	88	1,056	53	106	$143,869.44
F. Annual personnel refresher course n	8	1	8	142	1,136	57	114	$154,768.64
G. Audits	N/A
Subtotal for Recordkeeping Requirements					13,993			$1,657,768
TOTAL LABOR BURDEN AND COSTS (rounded) r					15,900			$1,880,000
TOTAL CAPITAL AND O&M COST (rounded) r								$12,900			35.5 hrs/response
GRAND TOTAL (rounded) r								$1,890,000
Assumptions
a EPA estimates 142 existing major sources and 88 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: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 (142 x 0.03 = 4, after rounding) and 10% will apply for modification (142 x 0.1 = 14, after rounding). Of these 18 sources, 10% of the sources (rounded to 2 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 (142 x 0.9 = 128, 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 13 (142 x 0.1 x 0.95 = 13, after rounding).
g EPA assumes 1 source will submit quarterly reports (142 x 0.1 x (1 - 0.095) = 1, 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 52 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 (142 x 0.1 = 14, 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 (142 x 0.9 x 0.25 = 32 , 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 (142 x 0.1 x 0.1 = 1, when rounded) will have startup, shutdown, or malfunction records to document once per month.
q EPA assumes 88 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.

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Sheet 2: Table 2

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		Labor Rates
1. Excess emissions enforcement activities	N/A									Managerial	$69.04
2. Report review										Technical	$51.23
A. Review notification of construction/reconstruction c	2	1	2	4	8	0.4	0.8	$459.64		Clerical	$27.73
B. Review notification of modification (physical/operational changes) c	2	1	2	14	28	1.4	2.8	$1,608.74
C. Performance Tests c	8	1	8	2	16	1	2	$919.28
D. Review notification of increased VHAP usage d	2	1	2	0	0	0	0	$0
E. Review semiannual compliance status reports (compliant coatings) e	8	2	16	128	2,048	102	205	$117,667.84
F. Review semiannual compliance status reports (control devices) f	8	2	16	13	208	10.4	20.8	$11,950.64
G. Review quarterly excess emission reports g	16	4	64	1	64	3.2	6.4	$3,677.12
H. Review annual records of formaldehyde content h	2	1	2	52	104	5	10	$5,975.32
TOTAL (rounded) i					2,850			$142,000
Assumptions
a EPA estimates 142 existing major sources and 88 existing incidental/area sources will be subject to the standard. No new major or area sources will become subject over the 3-year period of this ICR.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 (142 x 0.03 = 4, after rounding) and 10% will apply for modification (142 x 0.1 = 14, after rounding). Of these 18 sources, 10% of the sources (rounded to 2 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 (142 x 0.9 = 128, 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 13 (142 x 0.1 x 0.95 = 13, after rounding).
g EPA assumes 1 source will submit quarterly reports (406 x 0.1 x (1 - 0.095) = 1, after rounding).
h EPA estimates 52 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

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Sheet 3: O&M

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	18	142	88	18	230
2	18	142	88	18	230
3	18	142	88	18	230
Average	18	142	88	18	230
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	18	1	0	18
Notification of applicability (one-time)	0	0	0	0
Notification of construction/reconstruction	4	1	0	4
Notification of modification	14	1	0	14
Notification of anticipated startup	18	1	0	18
Notification of actual startup	18	1	0	18
Notification of performance test	2	1	0	2
Notification of increased annual VHAP usage	0	0	0	0
Semiannual compliance status reports (compliant coatings) e	128	2	0	256
Semiannual compliance status reports (control devices) f	13	2	0	26
Quarterly excess emissions reports	1	4	0	4
Records for incidental and area sources			88	88
			Total	448
Source Type	Number
Existing (major)	142
Existing (area)	88
Formaldehyde	52
New	0
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)		CEPCI Index
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M a	Total O&M, (ExF)		Year 2001	394.3	$600.00
Control device (several options available)	$0	0	$0	$924	14	$12,900		Year 2019	607.5	$924.42
a EPA assumes 10% of affected major sources will use control devices to comply with the standard (142 x 0.1 = 14, after rounding).
b The annual O&M costs have been updated from year 2001 to year 2019 using the CEPCI Index.