SUPPORTING STATEMENT FOR OMB REVIEW OF ICR NO. 1984.02 REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS ( NESHAP) FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS MANUFACTURING PLANTS U. S. ENVIRONMENTAL PROTECTION AGENCY EMISSION STANDARDS DIVISION RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711 October 2003 2 PART A OF THE SUPPORTING STATEMENT 1. Identification of the Information Collection ( a) Title and Number of the Information Collection " Reporting and Recordkeeping Requirements for the National Emission Standards for Hazardous Air Pollutants ( NESHAP) for Plywood and Composite Wood Products Manufacturing Plants." This is a new information collection request ( ICR). The U. S.

Environmental Protection Agency ( EPA) tracking number is 1984.02.

( b) Short Characterization ( i) Applicability. Respondents are owners or operators of new and existing plywood and composite wood products ( PCWP)

manufacturing facilities. Plywood and/ or composite wood products are manufactured by bonding wood material ( fibers, particles,

strands, veneers, etc.) or agricultural fiber with resin,

generally under heat and pressure, to form a structural panel or engineered wood product. Plywood and composite wood products include, but are not limited to, plywood, veneer, particleboard,

oriented strand board, hardboard, fiberboard, medium density fiberboard, laminated strand lumber, laminated veneer lumber,

wood I joists, kiln dried lumber, and glue laminated beams. A PCWP manufacturing facility is a major source of hazardous air pollutant ( HAP) emissions either in and of itself, or because it is located with other major sources of HAP. A major source of HAP is a plant site that emits, or has the potential to emit, any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year.

Approximately 223 of the PCWP facilities nationwide are expected to meet the applicability criteria defined in the rule. 3 However, only 212 of these facilities have equipment that is subject to the control requirements of the rule. In addition,

there are approximately 34 major source sawmill facilities that produce kiln dried lumber; although these sawmill facilities meet the applicability criteria in the rule, there are no control requirements for any of the equipment located at the sawmills.

An estimated 19 new PCWP facilities are expected to be constructed in the next 5 years. These 19 new facilities are expected to include six oriented strand board facilities, five medium density fiberboard, four particleboard, and four laminated veneer lumber facilities. ( An increase of 19 facilities over the next 5 years is 3.8 facilities per year; rather than assume 3.8 facilities, we assumed 4 facilities per year for the first 3 years after the effective date in calculating the burden estimates.)

( ii) PCWP manufacturing facilities. Owners or operators of PCWP manufacturing facilities subject to this rule must install and monitor a specific control system that reduces HAP emissions to the compliance level or comply with the alternative emissions averaging or production based compliance option provisions included in the rule.

Owners or operators are required to install, operate, and maintain a continuous monitoring system ( CMS), either a continuous parameter monitoring system CPMS or continuous emission monitoring system CEMS depending on which monitoring system the facility chooses, to demonstrate compliance with the add on control system compliance options in Table 1b of the rule and the operating limits in Table 2 of the rule; they must also record the values of equipment operating parameters as specified in Table 7 of the rule. As specified in Table 8 of the rule,

owners or operators of certain equipment are required to record the values of the inlet wood moisture content, dryer inlet 4 temperature, and volume percent softwood species processed to demonstrate compliance with the work practice standards in Table 3 of the rule. Certain owners or operators are also required to prepare and follow a plan for minimizing fugitive emissions to demonstrate compliance with the work practice standards.

The respondents are subject to sections of subpart A of 40 CFR part 63 relating to NESHAP. These requirements include those associated with applicability determinations; notifications that the facilities are subject to the rule; notifications of performance tests; notifications of compliance status, including the results of performance tests and other initial compliance demonstrations that do not include performance tests; startup,

shutdown, and malfunction reports; and initial and semi annual compliance reports. In addition to the requirements of subpart A, existing facilities that wish to implement emissions averaging provisions must submit an emissions averaging plan. Facilities attempting to use a wet control device to meet the emission limits of the rule must submit a plan addressing how they will prevent re release to the atmosphere of HAP in the wet control system wastewater. Facilities may also submit a request for a routine control system maintenance exemption to justify the need for routine maintenance on the control system and to show how the facilities plan to minimize emissions to the greatest extent possible during the maintenance.

All reports are to be submitted to the respondent's State or local agency or to the EPA Regional Office, whichever has been delegated enforcement authority by EPA. The information is used to determine whether or not all sources subject to the rule are achieving the emission limitations and work practice standards in the rule. 5 ( iii) Deviations from the standard. If the owner or operator identifies any deviation resulting from a known cause for which no Federally approved or promulgated exemption from an emission limitation or work practice standard applies, the compliance report must also include all records that the source is required to maintain that pertain to the periods during which such deviation occurred, as well as the following: the magnitude of each deviation; the reason for each deviation; a description of the corrective action taken for each deviation, including action taken to minimize each deviation and action taken to prevent recurrence; and a copy of all quality assurance activities performed on any element of the monitoring protocol.

( iv) Record retention. Owners or operators of a PCWP manufacturing facility must maintain a copy of all monitoring data that demonstrate compliance with the operating limits in the rule. In addition, some facilities must maintain records of inlet wood moisture content, dryer inlet temperature, volume percent softwood species processed, and their plan for minimizing fugitive emissions that demonstrate compliance with the work practice standards in the rule. Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of a source, or any period during which the monitoring system is inoperative. Those records must be maintained for a minimum of 5 years. At a minimum, the most recent 2 years of data must be retained onsite. The remaining 3 years of data may be retained offsite.

2. Need For and Use of the Collection ( a) Need/ Authority for the Collection 6 The EPA is charged under section 112( d) of the Clean Air Act ( CAA), as amended, to establish emission standards for each category or subcategory of major and area sources of HAP listed for regulation in section 112( b). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction.

The predominant HAP emitted from PCWP manufacturing facilities include acetaldehyde, acrolein, formaldehyde,

methanol, phenol, and propionaldehyde. In the Administrator's judgment, the pollutants emitted from PCWP manufacturing facilities cause or contribute significantly to air pollution that may reasonably be anticipated to endanger public health.

Therefore, the PCWP source category is listed for regulation under section 112. ( Note: The PCWP source category was originally listed as the plywood and particleboard source category on July 16, 1992 ( 57 FR 31576). The name of the source category was changed to PCWP on November 18, 1999 ( 64 FR 63025)

to more accurately reflect the types of manufacturing facilities covered by the source category.)

Section 114( a) of the CAA states that the Administrator may require any owner or operator subject to any requirement of the CAA 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, as 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. 7 Certain records and reports are necessary to enable the Administrator to identify sources subject to the work practice standards and emission limitations and to ensure that the work practice standards and emission limitations, which are based on maximum achievable control technology ( MACT) for PCWP manufacturing facilities, are being achieved. After the compliance date, all respondents must submit initial and semiannual ( every 6 months) compliance reports that contain the information requested in § 63.2281( c) through ( e) of the rule. In addition, respondents that elect to use the emissions averaging provisions in the rule must submit an emissions averaging report ( as specified in § 63.2281( f)) as part of the semi annual report.

These records and reports are required under the General Provisions of 40 CFR part 63, subpart A ( as authorized under sections 101, 112, 114, 116, and 301 of the CAA as amended by Pub. L 101 549 [ 42 U. S. C. 7401, 7412, 7414, 7416, 7601]).

( b) Practical Utility/ Users of the Data The information will be used by EPA enforcement personnel to: ( 1) identify new, modified, reconstructed, and existing sources subject to the rule; ( 2) ensure that MACT is being properly applied; and ( 3) ensure that the emission control systems are being properly operated and maintained on a continuous basis.

In addition, records and reports are necessary to enable EPA to identify PCWP manufacturing facilities that are not in compliance with the emission limitations and work practice standards in the rule. Based on reported information, EPA can decide which PCWP manufacturing facilities should be inspected and what records or processes should be inspected at these facilities. The records that facilities maintain will indicate 8 to EPA whether the owners or operators are in compliance with the emission limitations and work practice standards.

Much of the information EPA needs to determine compliance will be recorded on a continuous, hourly, operating shift, or daily basis. Such information will be reviewed by enforcement personnel during an inspection and will need to be summarized and reported on a semi annual basis.

3. Nonduplication, Consultations, and Other Collection Criteria ( a) Nonduplication Certain reports required by State or local agencies may duplicate information required by the rule ( such as, reports of performance tests). In such cases, a copy of the report submitted to the State or local agency can be provided to the Administrator in lieu of the report required by the rule.

A search of existing rules revealed some duplication of information gathering efforts in those cases where facilities are subject to other rules in addition to the PCWP manufacturing NESHAP. In each case that has been identified, an effort has been made to eliminate this duplication. Some examples of these efforts are provided below.

The PCWP manufacturing NESHAP includes sources that use urea formaldehyde resins as the binder, which have been specifically excluded from regulation under the wood furniture NESHAP;

conversely, other emission points that are covered under the wood furniture NESHAP are being excluded from regulation under the PCWP manufacturing NESHAP.

Because the PCWP manufacturing NESHAP regulates emissions from direct fired dryers, those combustion units associated with direct fired dryers are excluded from the requirements of other combustion related NESHAP, such as the Industrial, Commercial, 9 Institutional Boilers NESHAP and the Process Heaters NESHAP.

However, those combustion units that supply heat or steam to indirect fired dryers or presses and those thermal oil heaters that supply hot oil for presses but which do not exhaust through dryers are not covered under the PCWP manufacturing NESHAP; they will be subject to the requirements of the applicable combustionrelated NESHAP.

( b) Public Notice Required Prior to ICR Submission to OMB This section is not applicable because this is a rule related ICR. A public review and comment period occurred following proposal of the PCWP manufacturing NESHAP in the Federal Register.

( c) Consultations The EPA published a list of categories of major and area sources of HAP on July 16, 1992 ( 57 FR 31576), under authority of section 112( c); this notice listed the plywood and particleboard manufacturing as a category of major sources of HAP. ( As noted above, the plywood and particleboard source category was changed to the PCWP source category on November 18, 1999 ( 64 FR 63025) to more accurately reflect the types of manufacturing facilities covered by the source category.)

Representatives of the affected companies and industry trade associations were consulted during the development of the rule,

and several meetings have been held with them during this time.

The industry trade associations include the American Forest and Paper Association ( AF& PA), National Council of the Paper Industry for Air and Stream Improvement ( NCASI), Hardwood Plywood and Veneer Association ( HPVA), Composite Panel Association ( CPA),

American Hardboard Association ( AHA), American Fiberboard Association ( AFA), and APA   The Engineered Wood Association. 10 During these meetings, the representatives were given the opportunity to comment on the regulatory approach. The major topics of these discussions included the applicability, MACT floor approach, regulatory strategies, and the national impacts of the rule. No specific information was provided to the representatives with respect to burden estimates prior to proposal of the rule.

The EPA provided a 60 day public comment period following proposal of the PCWP manufacturing NESHAP, during which all affected parties were given the opportunity to comment on the proposed rule. Comments were received from PCWP industry representatives, environmental interest groups, and State and local agencies. The EPA considered the comments received and, as appropriate, incorporated them into the final rule.

( d) Effects of Less Frequent Data Collection In the 3 years following the effective date of the rule,

existing sources will submit only one time notifications to EPA.

In this instance, less frequent reporting would not be practical because EPA needs the information provided in these one time notifications. In addition to one time notifications, new and reconstructed sources will also submit initial and semi annual compliance reports in the 3 years following the effective date of the rule. If the relevant information was collected less frequently, EPA would not be reasonably assured that the facilities are applying good operation and maintenance practices and meeting the emission limitations and work practice standards in the rule. Less frequent collection could decrease the likelihood of detecting poor operation and maintenance of control equipment and long term deviations from the applicable emission limitations and work practice standards. 11 In addition, EPA's authority to take administrative action would be significantly reduced. Section 113( d) of the CAA limits the assessment of administrative penalties to deviations which occur no more than 12 months before initiation of the administrative proceeding. Since administrative proceedings are less costly and require fewer resources than judicial proceedings, both EPA and the regulated community benefit from preservation of EPA's administrative powers.

Also, the reporting frequency in the rule is consistent with the requirements of Title V permit programs. Consequently, less frequent reports would not result in a reduced burden.

( e) General Guidelines The PCWP manufacturing NESHAP requires that facilities retain records for a period of 5 years, which exceeds the 3 year retention period specified in the general information collection guidelines in 5 CFR 1320.6( f) of the Office of Management and Budget ( OMB) regulations implementing the Paperwork Reduction Act. However, the 5 year retention period is consistent with the retention requirement in the General Provisions in subpart A of 40 CFR part 63 and the retention requirement in the operating permit program under 40 CFR part 70. All sources subject to this rule will be required to obtain operating permits either through the State approved permitting program or, if one does not exist,

in accordance with the provisions of 40 CFR part 71. Thus, the 5 year record retention requirement of the rule adds no additional burden. At a minimum, respondents will be required to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR 1320.6 are being exceeded. 12 ( f) Confidentiality All information submitted to EPA for which a claim of confidentiality is made will be safeguarded according to EPA policies set forth in title 40, Chapter 1, Part 2,

Subpart B   Confidentiality of Business Information. ( See 40 CFR part 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999,

September 8, 1978; 43 FR 42251, September 28, 1978; and 44 FR 17674, March 23, 1979.)

( g) Sensitive Questions The information to be reported consists of emissions data and other information that are not of a sensitive nature.

Therefore, this section is not applicable because this ICR does not involve matters of a sensitive nature.

4. The Respondents and the Information Requested ( a) Respondents/ SIC and NAICS Codes Respondents are owners or operators of any facilities that manufacture plywood and/ or composite wood products and are classified as major sources of HAP under section 112 of the CAA.

Table 1 lists the primary Standard Industrial Classification ( SIC) and North American Industrial Classification System ( NAICS)

codes used to classify the respondents affected by the PCWP manufacturing NESHAP. Not all processes classified in the SIC or NAICS codes in Table 1 will be regulated by the PCWP manufacturing NESHAP ( i. e., they will not be regulated if they are already subject to another NESHAP). 13 ( b) Information Requested ( i) Data items. Attachment 1, Source Data and Information Requirements, summarizes the reporting and recordkeeping requirements.

( ii) Respondent activities. The respondent activities required by the rule in the first 3 years following the effective date are listed in the first columns of Tables 2a through 2f and are presented in section 6( a). The respondent activities are described in more detail in Attachment 2, Description of Respondent Activities. One time and recurrent respondent activities are presented in Tables 2a and 2b for the first year,

Tables 2c and 2d for the second year, and Tables 2e and 2f for the third year.

5. The Information Collected Agency Activities, Collection Methodology, and Information Management ( a) Agency Activities The Agency activities in the first 3 years following the effective date of the rule are listed in the first columns of Tables 3a through 3c and are presented in section 6( c).

Tables 3a, 3b, and 3c present the Agency activities for the first, second, and third years, respectively, after the effective date of the rule.

( b) Collection Methodology and Management Information contained in the initial, one time only notifications will be entered in the Aerometric Information Retrieval System ( AIRS) Facility Subsystem operated and maintained by EPA's Office of Air Quality Planning and Standards ( OAQPS). AIRS is EPA's database for the collection, maintenance,

and retrieval of compliance and annual emission inventory data 14 for over 100,000 industrial and government owned facilities. The EPA uses AIRS for tracking air pollution compliance and enforcement by State and local agencies and EPA Regional Offices and Headquarters. The EPA and its delegated authorities can edit, store, retrieve, and analyze the data. The AIRS database can be publicly accessed via the Internet at http:// www. epa. gov/ enviro/ index_ java. html or through a Freedom of Information Act request to EPA. Data obtained during periodic visits by EPA personnel, from records maintained by the respondents, and from information provided in semi annual reports will be tabulated and published for internal EPA use in compliance and enforcement programs.

The rule does not require the use of automated, electronic,

mechanical, or other technology data collection techniques or other forms of information technology. Although many of the large companies have elaborate collection methods, automated systems are not expected to reduce the burden.

( c) Small Entity Flexibility Minimizing the information collection burden for all sizes of organizations is a continuing effort by EPA. The EPA has reduced the reporting and recordkeeping burden for respondents to include only the information that EPA needs to determine compliance with the rule. Few of the 212 existing facilities with control requirements under the PCWP manufacturing NESHAP are expected to meet the applicability criteria for small businesses.

The EPA does not expect that small PCWP manufacturing businesses will experience adverse impacts related to the cost of the required reporting and recordkeeping.

( d) Collection Schedule 15 Collection of data will begin after the effective date of the PCWP manufacturing NESHAP. The schedule for notifications and reports required by the rule is summarized below.

For all existing PCWP manufacturing facilities, the initial notification stating that the facility is subject to the rule must be submitted no later than 120 days after the effective date of the rule. New or reconstructed PCWP manufacturing facilities for which startup occurs on or after the effective date must submit the initial notification no later than 120 days after the source becomes subject to the rule. New or reconstructed facilities must comply immediately upon the effective date of the final rule if their startup date is before the effective date or upon startup if the startup date is on or after the effective date.

Facilities required to conduct a performance test must submit a notification of intent to conduct a performance test at least 60 days before the performance test is scheduled to begin.

For each initial compliance demonstration that does not include a performance test, facilities must submit an initial notification of compliance status no later than 30 days following the completion of the initial compliance demonstration. For each initial compliance demonstration that includes a performance test, facilities must submit an initial notification of compliance status no later than 60 days following the completion of the performance test. If averaging emissions, existing facilities must also submit an emissions averaging plan at least 1 year before their compliance date. ( The compliance date for existing facilities is 3 years after the effective date.)

Records necessary to determine compliance must be compiled on a daily basis, and compliance reports must be submitted to the Administrator on a semi annual basis, as discussed in section 1( b). 16 6. Estimating The Burden and Cost of the Collection ( a) Estimating Respondent Burden The annual burden estimates for reporting and recordkeeping activities for the first 3 years after the effective date of the rule are presented in Tables 2a through 2f. One time and recurrent burden estimates to the industry are presented in Tables 2a and 2b for the first year, Tables 2c and 2d for the second year, and Tables 2e and 2f for the third year. The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts.

( b) Estimating Respondent Costs ( i) Estimating labor costs. The annual labor costs for reporting and recordkeeping activities are also presented in Tables 1a through 1f. Labor costs for reporting and recordkeeping activities were estimated based on the most recently available labor rate data from the U. S. Bureau of Labor Statistics ( BLS) ( http:// www. bls. gov/ ncs/ ect/ home. htm). Labor costs are divided into the following three categories: ( 1)

technical, ( 2) management, and ( 3) clerical. The labor rates,

including fringe benefits, reported by BLS for June 2003 ( the most recent rates available) are $ 32.12 per hour ($ 32.12/ hr) for technical personnel, $ 48.41/ hr for managerial personnel, and $ 22.29/ hr for clerical personnel. The base labor rates were adjusted by an overhead rate of 167 percent. The final total labor rates are $ 53.64 for technical personnel, $ 80.84 for management, and $ 37.22 for clerical.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities: capital costs and operation and maintenance ( O& M) 17 costs. The methods used to estimate the capital and O& M costs for this Supporting Statement are presented in Attachment 3,

Methods Used in Cost Estimates.

One time capital costs usually include any produced physical good, such as computers, machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest rate. For this Supporting Statement, capital costs were annualized over 15 years, assuming an interest rate of 7 percent.

In most cases, administrative charges, insurance, and property taxes were also included with the annualized capital costs,

estimated at 4 percent of the capital cost.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs ( planning and selection), and a data acquisition system ( data logger, computer, logging and reporting software, and printer).

The capital costs for the monitoring equipment were estimated based on the following assumptions: ( 1) the parameter monitoring equipment for thermal oxidizers, catalytic oxidizers, and biofilters include thermocouples; ( 2) facilities that already have these control systems are also assumed to have the required parameter monitoring equipment, so no costs have been assigned to these parameter monitoring equipment and it was assumed that the facilities will elect to monitor parameters rather than using CEMS; ( 3) for those facilities that would be required to install one of these control systems in order to comply with the rule,

the control systems are assumed to include the required parameter monitoring equipment; consequently, no cost has been assigned to these parameter monitoring equipment and it was assumed that the 18 facilities will elect to monitor parameters rather than using CEMS; ( 4) one data acquisition system will be required for each control system, at a cost of $ 7,300 ($ 3,000 for data logger,

$ 3,000 for computer, $ 1,000 for logging and reporting software,

and $ 300 for printer); and ( 5) data acquisition systems will be purchased for the seven control systems ( thermal oxidizers)

expected to be installed during each of the first 3 years after the effective date of the rule ( based on an estimated 34 new thermal oxidizers installed over 5 years).

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file cabinet). The annualized capital cost per file cabinet is $ 35.

An estimated four new facilities will purchase this equipment in each of the first 3 years after the effective date of the rule ( based on an estimated 19 new facilities over 5 years).

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. The capital costs associated with performance testing include the costs for Method 25A performance tests for all control systems. Performance test costs were estimated based on the following assumptions: ( 1) all facilities will use control systems and will choose to demonstrate compliance with the 90 percent THC reduction emission limit included in the rule; ( 2) capital costs per performance test are $ 10,000, based on testing both the inlet and outlet of the control system; ( 3) one performance test will be conducted for each control system at a facility; ( 4) performance tests will be conducted for the seven control systems ( thermal oxidizers)

expected to be installed during each of the first 3 years after the effective date ( based on an estimated 34 new thermal oxidizers installed over 5 years); and ( 4) no facilities will 19 repeat the performance test during the first three years after the effective date. Because no equipment is purchased, no administrative charges, insurance, or property taxes were estimated for performance testing.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. Because facilities that already have control systems are also assumed to have the required parameter monitoring equipment, there are no additional O& M costs associated with the monitoring equipment. For those facilities that would be required to install a control system to comply with the rule, it is assumed that the control system already has the required parameter monitoring equipment. Consequently, there are also no additional O& M costs associated with this monitoring equipment.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. The O& M costs for rules that require respondents to submit notifications and reports to EPA and maintain records are estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 37.22/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs will be applied to the 290 responses submitted during the first year, the 41 responses submitted during the second year, and the 261 responses submitted during the third year. ( The number of responses was determined by adding the number of reports submitted to EPA by respondents, as shown in Tables 1a through 1f and in Attachment 3.) 20 ( c) Estimating Agency Burden and Costs Because the information collection requirements were developed as an incidental part of the standards development, no costs can be attributed to the development of these requirements.

In addition, no operational costs will be incurred by the Federal Government because reporting and recordkeeping requirements on the part of the respondents are required under section 112 of the CAA. Publication and distribution of the information are part of the AIRS Facility Subsystem, with the result that no Federal costs can be attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of facilities. Periodic inspections are part of EPA's overall compliance and enforcement program.

Therefore, this examination is not attributable to the ICR.

The only costs that the Federal Government will incur are user costs associated with the analysis of the information reported by the facilities in one time notifications and initial and semi annual compliance reports ( unless the compliance report indicates a deviation, thereby triggering an enforcement action).

Tables 3a, 3b, and 3c present the estimated annual burden to the Federal Government during the first, second, and third years,

respectively, after the effective date of the rule. Labor rates for Federal employees are based on the January 2002, Office of Personnel Management labor rates for General Schedule employees ( http:// www. opm. gov/ oca/ 02tables/ 02gsh. pdf). The base labor rates are $ 27.97/ hr for technical personnel ( GS 12, step 5),

$ 46.23 for management personnel ( GS 15, step 5), and $ 15.77/ hr for clerical personnel ( GS 7, step 5). The base labor rates were multiplied by the standard government benefits multiplication factor of 1.6. The resulting average hourly labor costs are $ 44.75 for technical personnel, $ 73.97 for management, and $ 25.23 for clerical. 21 ( d) Estimating the Respondent Universe and Total Burden and Costs Once the burden and costs per activity have been established on a per respondent basis, the total burden and cost must be calculated for all respondents and for the Agency. To calculate the total burden and costs, the number of respondents needed to complete each information collection activity must be estimated.

The total number of respondents is also referred to as the " respondent universe." The respondent universe varies among the activities listed because not all respondents must complete each activity.

Burden and costs were estimated for an existing respondent universe of 212 PCWP manufacturing facilities and a projected new respondent universe of 4 PCWP manufacturing facilities installed in each of the first 3 years after the effective date. To determine the burden for each activity for technical staff, the number of burden hours per respondent was multiplied by the number of respondents. Management and clerical labor hours were calculated at 5 percent and 10 percent of technical labor hours,

respectively. The total burden was determined by summing the technical, management, and clerical burden hour estimates. To determine the total labor cost, the burden hour estimates for technical, management, and clerical labor were multiplied by their respective wage rates and then summed.

( e) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 2a through 2f and dividing the sums by the 3 year review period. The total annual respondent burden hours and costs are summarized in Table 4. The bottom line annual burden, averaged over the first 3 years after the 22 effective date, is 4,692 labor hours, at a cost of $ 250,528.

The average annual burden per respondent, based on an average 220 respondents over the 3 year review period, is 21 labor hours, at a cost of $ 1,139.

On average, there are an estimated 197 total annual responses for the first 3 years after the effective date of the rule. Of the 197 total annual responses, approximately 20 percent are assumed to be collected electronically. The total annual responses are an average of the one time and recurrent notifications and reports submitted during the first, second, and third years after the effective date. An estimated 290 notifications and reports will be submitted during the first year, 41 during the second year, and 261 during the third year.

The total nationwide capital cost associated with monitoring equipment was estimated to be $ 51,100 in each of the first 3 years after the effective date of the rule. The average annualized capital cost for the monitoring equipment is $ 15,310 for the 3 years following the effective date.

The total nationwide capital cost associated with file cabinets for storing collected data and reports was estimated to be $ 940 in each of the first 3 years after the effective date of the rule. The average annualized capital cost for file cabinets is $ 280 for the 3 years following the effective date.

The total nationwide capital cost for performance tests was estimated to be $ 70,000 for each of the first 3 years after the effective date of the rule. The average annualized capital cost for the performance tests is $ 15,372 for the 3 years following the effective date.

Annual O& M costs, which include photocopying and postage for the reports, average $ 5,178 for the 3 years following the effective date of the rule. 23 Combining the average annualized capital costs for the monitoring equipment, file cabinets, and performance tests results in a total annualized capital cost of $ 30,962 for the 3 years following the effective date. Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 36,140 for the 3 years following the effective date.

A discussion of the respondent burden and costs in later years is provided in Attachment 4, Burden and Cost of Reporting and Recordkeeping Requirements For the Fourth, Fifth, and Sixth Years Following the Effective Date.

( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours and costs from Tables 3a, 3b, and 3c and then dividing by the 3 year review period. The total annual Agency burden hours and costs are summarized in Table 5. The bottom line annual burden,

averaged over the first 3 years after the effective date, is 732 labor hours, at a cost of $ 32,452. A discussion of the Agency burden and costs in later years is provided in Attachment 4,

Burden and Cost of Reporting and Recordkeeping Requirements For the Fourth, Fifth, and Sixth Years Following the Effective Date.

( iii) The complex collection. This section does not apply because this collection is a simple collection.

( iv) Variations in the annual bottom line. The annual burden hours and costs associated with one time activities vary over the course of the 3 year review period because existing sources are subject to different requirements in each year as follows: ( 1) reading instructions and notifying EPA that the facility is subject to the rule in the first year; ( 2) no activities in the second year; and ( 3) developing and submitting a request for routine control system maintenance exemption in the third year. ( No existing sources are assumed to submit emissions 24 averaging plans, which would also be submitted in the third year.) Increasing numbers of new sources installed after the effective date will also be subject to ongoing requirements, such as recordkeeping and submitting initial and semi annual compliance reports, over the 3 year review period.

The Agency burden hours and costs will also vary over the 3 year review period because EPA will be reviewing the following notifications and reports from existing sources:

( 1) notifications of applicability of the standard in the first year; ( 2) no notifications or reports in the second year; and ( 3) requests for routine control system maintenance exemption in the third year. The EPA will also review initial and semi annual compliance reports for increasing numbers of new sources over the 3 year review period.

( f) Reasons for Change In Burden This section does not apply because this collection is a new collection.

Burden Statement:

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 21 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; 25 search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

EPA has established a public docket for this ICR under Docket ID No. OAR 2002 0048, which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center ( EPA/ DC), EPA West, Room B102, 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 Air Docket is ( 202) 566 1742). An electronic version of the public docket is available through EPA Dockets ( EDOCKET) at http:// www. epa. gov/ edocket. Use EDOCKET 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. Once 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, NW, Washington, DC 20503, Attention: Desk Office for EPA.

Please include the EPA Docket ID No. ( OAR 2002 0048) in any correspondence. 26 TABLE 1. SIC AND NAICS CODES USED TO CLASSIFY PCWP RESPONDENTS SIC code NAICS code Description 2421 321999 Sawmills with lumber kilns 2435 321211 Hardwood plywood and veneer plants 2436 321212 Softwood plywood and veneer plants 2493 321219 Reconstituted wood products ( particleboard, medium density fiberboard, hardboard, fiberboard, agriboard,

and oriented strandboard plants)

2439 321213 Structural wood members, not elsewhere classified ( engineered wood products plants) 27 TABLE 2a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 216 216 11 22 248 $ 13,263 B. Required Activities C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/

reconstruction 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of anticipated startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of actual startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of applicability of standardd 2 1 2 261 522 26 52 600 $ 32,053 ° Emissions averaging plane 120 1 120 0 0 0 0 0 $ 0 ° Request for routine control system maintenance exemptionf 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of initial performance testg 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of compliance status With performance testg 80 1 80 4 320 16 32 368 $ 19,649 Without performance testh 120 1 120 1 120 6 12 138 $ 7,368 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemi 40 1 40 4 160 8 16 184 $ 9,825 28 TABLE 2a. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c E. Develop Startup, Shutdown,

Malfunction Planj 100 1 100 4 400 20 40 460 $ 24,562 F. Time to Train Personnelk 40 1 40 4 160 8 16 184 $ 9,825 G. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDEl 1,938 97 194 2,229 $ 119,001 Average cost per facilitym 216 $ 551 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule. Estimate includes 45 major source facilities that need only to submit the initial notification of applicability because they have no equipment subject to the rule ( e. g., sawmills with lumber kilns, certain engineered wood facilities).

e Assume no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will comply by conducting a performance test( s). The notification of compliance status includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes 40 hours to develop a record system for recording parameter monitoring information.

j Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/ revisions, for a total of 100 hours.

k Assumes 40 hours to train personnel.

l The one time burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 216) subject to the rule. 29 TABLE 2b. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS   FIRST YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Initial compliance reportd No deviationse 8 1 8 4 32 2 3 37 $ 1,965 Deviationse 24 1 24 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 1 8 4 32 2 3 37 $ 1,965 Control system maintenance reportg 8 1 8 4 32 2 3 37 $ 1,965 Emissions averaging reporth 20 1 20 0 0 0 0 0 $ 0 ° Semi annual compliance reportd No deviationse 8 2 16 0 0 0 0 0 $ 0 Deviationse 24 2 48 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 2 16 0 0 0 0 0 $ 0 Control system maintenance reportg 8 2 16 0 0 0 0 0 $ 0 Emissions averaging reporth 20 2 40 0 0 0 0 0 $ 0 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System N/ A E. Time to Enter Information ° Records of startup, shutdown,

and malfunction 1.5 52 78 4 312 16 31 359 $ 19,158 ° Records of continuous compliancei Record parameters/ information 0.25 365 91 4 365 18 37 420 $ 22,412 30 TABLE 2b. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c Compile data 24 2 48 4 192 10 19 221 $ 11,790 Enter/ verify information for semi annual reports 16 2 32 4 128 6 13 147 $ 7,860 ° Records of control system maintenance Included in 3E ° Records of emissions averaging credits/ debits Included in 3E F. Calibration of CMSj 16 1 16 4 64 3 6 74 $ 3,930 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelk 16 1 16 0 0 0 0 0 $ 0 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: l 1,157 58 116 1,331 $ 71,044 Average cost per facilitym 4 $ 17,761 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d Assumes that the respondents' compliance date is in the first half of the year, so respondents will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

e Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

f Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

g Assumes all facilities will submit a description of the control device maintenance performed.

h Assumes no existing facilities will choose to use the emissions averaging option; new facilities are not allowed to use emissions averaging.

i Includes records of CMS data for emission limitations and various records for work practice standards.

j Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming 2 CMS for each facility, a total of 16 hours per year per facility is required.

k Assumes 2 days ( 16 hours) to provide refresher training for personnel.

l The recurrent burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 4) complying with the rule. 31 TABLE 2c. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 4 4 0.2 0.4 5 $ 246 B. Required Activities C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/

reconstruction 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of anticipated startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of actual startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of applicability of standardd 2 1 2 4 8 0.4 0.8 9 $ 491 ° Emissions averaging plane 120 1 120 0 0 0 0 0 $ 0 ° Request for routine control system maintenance exemptionf 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of initial performance testg 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of compliance status With performance testg 80 1 80 4 320 16 32 368 $ 19,649 Without performance testh 120 1 120 1 120 6 12 138 $ 7,368 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemi 40 1 40 4 160 8 16 184 $ 9,825 E. Develop Startup, Shutdown,

Malfunction Planj 100 1 100 4 400 20 40 460 $ 24,562 F. Time to Train Personnelk 40 1 40 4 160 8 16 184 $ 9,825 G. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDEl 1,212 61 121 1,394 $ 74,422 Average cost per facilitym 220 $ 338 32 TABLE 2c. ( continued)

a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule.

e Assume no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will comply by conducting a performance test( s). The notification of compliance status includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes 40 hours to develop a record system for recording parameter monitoring information.

j Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/ revisions, for a total of 100 hours.

k Assumes 40 hours to train personnel.

l The one time burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 220) subject to the rule. 33 TABLE 2d. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Initial compliance reportd No deviationse 8 1 8 4 32 2 3 37 $ 1,965 Deviationse 24 1 24 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 1 8 4 32 2 3 37 $ 1,965 Control system maintenance reportg 8 1 8 4 32 2 3 37 $ 1,965 Emissions averaging reporth 20 1 20 0 0 0 0 0 $ 0 ° Semi annual compliance reportd No deviationse 8 2 16 4 64 3 6 74 $ 3,930 Deviationse 24 2 48 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 2 16 4 64 3 6 74 $ 3,930 Control system maintenance reportg 8 2 16 4 64 3 6 74 $ 3,930 Emissions averaging reporth 20 2 40 0 0 0 0 0 $ 0 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System N/ A E. Time to Enter Information ° Records of startup, shutdown,

and malfunction 1.5 52 78 8 624 31 62 718 $ 38,316 ° Records of continuous compliancei Record parameters/ information 0.25 365 91 8 730 37 73 840 $ 44,825 34 TABLE 2d. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c Compile data 24 2 48 8 384 19 38 442 $ 23,579 Enter/ verify information for semi annual reports 16 2 32 8 256 13 26 294 $ 15,719 ° Records of control system maintenance Included in 3E ° Records of emissions averaging credits/ debits Included in 3E F. Calibration of CMSj 16 1 16 8 128 6 13 147 $ 7,860 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelk 16 1 16 4 64 3 6 74 $ 3,930 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: l 2,474 124 247 2,845 $ 151,913 Average cost per facilitym 8 $ 18,989 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d Assumes that the respondents' compliance date is in the first half of the year, so respondents will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

e Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

f Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

g Assumes all facilities will submit a description of the control device maintenance performed.

h Assumes no existing facilities will choose to use the emissions averaging option; new facilities are not allowed to use emissions averaging.

i Includes records of CMS data for emission limitations and various records for work practice standards.

j Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming 2 CMS for each facility, a total of 16 hours per year per facility is required.

k Assumes 2 days ( 16 hours) to provide refresher training for personnel.

l The recurrent burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 8) complying with the rule. 35 TABLE 2e. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS THIRD YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 4 4 0.2 0.4 5 $ 246 B. Required Activities C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/

reconstruction 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of anticipated startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of actual startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of applicability of standardd 2 1 2 4 8 0.4 0.8 9 $ 491 ° Emissions averaging plan e 120 1 120 0 0 0 0 0 $ 0 ° Request for routine control system maintenance exemptionf 2 1 2 216 432 22 43 497 $ 26,527 ° Notification of initial performance test g 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of compliance status With performance testg 80 1 80 4 320 16 32 368 $ 19,649 Without performance testh 120 1 120 1 120 6 12 138 $ 7,368 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemi 40 1 40 4 160 8 16 184 $ 9,825 E. Develop Startup, Shutdown,

Malfunction Planj 100 1 100 4 400 20 40 460 $ 24,562 F. Time to Train Personnelk 40 1 40 4 160 8 16 184 $ 9,825 G. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDEl 1,636 82 164 1,881 100,457 Average cost per facilitym 224 $ 448 36 TABLE 2e. ( continued)

a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule.

e Assume no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will comply by conducting a performance test( s). The notification of compliance status includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes 40 hours to develop a record system for recording parameter monitoring information.

j Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/ revisions, for a total of 100 hours.

k Assumes 40 hours to train personnel.

l The one time burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 224) subject to the rule. 37 TABLE 2f. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS   THIRD YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Initial compliance reportd No deviationse 8 1 8 4 32 2 3 37 $ 1,965 Deviationse 24 1 24 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 1 8 4 32 2 3 37 $ 1,965 Control system maintenance reportg 8 1 8 4 32 2 3 37 $ 1,965 Emissions averaging reporth 20 1 20 0 0 0 0 0 $ 0 ° Semi annual compliance reportd No deviationse 8 2 16 7 112 6 11 129 $ 6,877 Deviationse 24 2 48 1 48 2 5 55 $ 2,947 Startup, shutdown, and malfunction reportf 8 2 16 8 128 6 13 147 $ 7,860 Control system maintenance reportg 8 2 16 8 128 6 13 147 $ 7,860 Emissions averaging reporth 20 2 40 0 0 0 0 0 $ 0 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System N/ A E. Time to Enter Information ° Records of startup, shutdown,

and malfunction 1.5 52 78 12 936 47 94 1076 $ 57,474 ° Records of continuous compliancei Record parameters/ information 0.25 365 91 12 1,095 55 110 1,259 $ 67,237 38 TABLE 2f. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c Compile data 24 2 48 12 576 29 58 662 $ 35,369 Enter/ verify information for semi annual reports 16 2 32 12 384 19 38 442 $ 23,579 ° Records of control system maintenance Included in 3E ° Records of emissions averaging credits/ debits Included in 3E F. Calibration of CMSj 16 1 16 12 192 10 19 221 $ 11,790 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelk 16 1 16 8 128 6 13 147 $ 7,860 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: l 3,823 191 382 4,396 $ 234,747 Average cost per facilitym 12 $ 19,562 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d Assumes that the respondents' compliance date is in the first half of the year, so respondents will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

e Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

f Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

g Assumes all facilities will submit a description of the control device maintenance performed.

h Assumes no existing facilities will choose to use the emissions averaging option; new facilities are not allowed to use emissions averaging.

i Includes records of CMS data for emission limitations and various records for work practice standards.

j Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming 2 CMS for each facility, a total of 16 hours per year per facility is required.

k Assumes 2 days ( 16 hours) to provide refresher training for personnel.

l The recurrent burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 12) complying with the rule. 39 TABLE 3a. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Litigation N/ A 4. Report Review A. Review of Notification of Construction/ Reconstruction 2 4 8 0.4 0.8 9 $ 408 B. Review of Notification of Anticipated Startup 2 4 8 0.4 0.8 9 $ 408 C. Review of Notification of Actual Startup 2 4 8 0.4 0.8 9 $ 408 D. Review of Notification of Applicability of Standard 2 261 522 26 52 600 $ 26,607 E. Review of Emissions Averaging Plane 40 0 0 0 0 0 $ 0 F. Review of Request for Routine Control System Maintenance Exemptionf 2 4 8 0.4 0.8 9 $ 408 G. Review of Notification of Initial Performance Test 2 4 8 0.4 0.8 9 $ 408 H. Review of Notification of Compliance Status ° With performance testg 40 4 160 8 16 184 $ 8,155 ° Without performance testh 40 1 40 2 4 46 $ 2,039 I. Review of Initial Compliance Reporti ° No deviationsj 2 4 8 0.4 0.8 9 $ 408 ° Deviationsj 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportk 2 4 8 0.4 0.8 9 $ 408 ° Control system maintenance reportl 2 4 8 0.4 0.8 9 $ 408 ° Emissions averaging reporte 8 0 0 0 0 0 $ 0 J. Review of Semi Annual Compliance Reporti ° No deviationsj 2 0 0 0 0 0 $ 0 ° Deviationsj 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportk 2 0 0 0 0 0 $ 0 ° Control system maintenance reportl 2 0 0 0 0 0 $ 0 ° Emissions averaging report 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): m 786 39 79 904 $ 40,064 TRAVEL EXPENSES FOR TEST ATTENDEDn = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trip/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 40,064 40 TABLE 3a. ( continued)

a Operations per year are equal to the number of operations per facility times the number of facilities. There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard, 4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

b Labor cost assumes a rate of $ 44.75/ hour for technical labor, $ 73.97/ hour for management labor, and $ 25.23/ hour for clerical labor.

c Assumes all facilities will conduct initial performance test( s), and EPA personnel will attend 10 percent of the initial tests.

d Assumes 5 percent of facilities will repeat the performance test( s), and EPA personnel will attend 10 percent of the repeat tests.

e Assumes no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will conduct an initial performance test( s) and submit a notification of compliance status that includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes that the facilities' compliance date is in the first half of the year, so facilities will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

j Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

k Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

l Assumes all facilities will submit a description of the control device maintenance performed.

m The burden and cost are equal to the totals added down each column.

n Tests attended include no initial performance tests and no repeat performance tests, for a total of 0 tests attended. 41 TABLE 3b. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Litigation N/ A 4. Report Review A. Review of Notification of Construction/ Reconstruction 2 4 8 0.4 0.8 9 $ 408 B. Review of Notification of Anticipated Startup 2 4 8 0.4 0.8 9 $ 408 C. Review of Notification of Actual Startup 2 4 8 0.4 0.8 9 $ 408 D. Review of Notification of Applicability of Standard 2 4 8 0.4 0.8 9 $ 408 E. Review of Emissions Averaging Plane 40 0 0 0 0 0 $ 0 F. Review of Request for Routine Control System Maintenance Exemptionf 2 4 8 0.4 0.8 9 $ 408 G. Review of Notification of Initial Performance Test 2 4 8 0.4 0.8 9 $ 408 H. Review of Notification of Compliance Status ° With performance testg 40 4 160 8 16 184 $ 8,155 ° Without performance testh 40 1 40 2 4 46 $ 2,039 I. Review of Initial Compliance Reporti ° No deviationsj 2 4 8 0.4 0.8 9 $ 408 ° Deviationsj 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportk 2 4 8 0.4 0.8 9 $ 408 ° Control system maintenance reportl 2 4 8 0.4 0.8 9 $ 408 ° Emissions averaging reporte 8 0 0 0 0 0 $ 0 J. Review of Semi Annual Compliance Reporti ° No deviationsj 2 8 16 0.8 2 18 $ 816 ° Deviationsj 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportk 2 8 16 0.8 2 18 $ 816 ° Control system maintenance reportl 2 8 16 0.8 2 18 $ 816 ° Emissions averaging reporte 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): m 320 16 32 368 $ 16,311 TRAVEL EXPENSES FOR TEST ATTENDEDn = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trip/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 16,311 42 TABLE 3b. ( continued)

a Operations per year are equal to the number of operations per facility times the number of facilities. There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard, 4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

b Labor cost assumes a rate of $ 44.75/ hour for technical labor, $ 73.97/ hour for management labor, and $ 25.23/ hour for clerical labor.

c Assumes all facilities will conduct initial performance test( s), and EPA personnel will attend 10 percent of the initial tests.

d Assumes 5 percent of facilities will repeat the performance test( s), and EPA personnel will attend 10 percent of the repeat tests.

e Assumes no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will conduct an initial performance test( s) and submit a notification of compliance status that includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes that the facilities' compliance date is in the first half of the year, so facilities will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

j Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

k Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

l Assumes all facilities will submit a description of the control device maintenance performed.

m The burden and cost are equal to the totals added down each column.

n Tests attended include no initial performance tests and no repeat performance tests, for a total of 0 tests attended. 43 TABLE 3c. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS THIRD YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical personhours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Litigation N/ A 4. Report Review A. Review of Notification of Construction/ Reconstruction 2 4 8 0.4 0.8 9 $ 408 B. Review of Notification of Anticipated Startup 2 4 8 0.4 0.8 9 $ 408 C. Review of Notification of Actual Startup 2 4 8 0.4 0.8 9 $ 408 D. Review of Notification of Applicability of Standard 2 4 8 0.4 0.8 9 $ 408 E. Review of Emissions Averaging Plane 40 0 0 0 0 0 $ 0 F. Review of Request for Routine Control System Maintenance Exemptionf 2 216 432 22 43 497 $ 22,020 G. Review of Notification of Initial Performance Test 2 4 8 0.4 0.8 9 $ 408 H. Review of Notification of Compliance Status ° With performance testg 40 4 160 8 16 184 $ 8,155 ° Without performance testh 40 1 40 2 4 46 $ 2,039 I. Review of Initial Compliance Reporti ° No deviationsj 2 4 8 0.4 0.8 9 $ 408 ° Deviationsj 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportk 2 4 8 0.4 0.8 9 $ 408 ° Control system maintenance reportl 2 4 8 0.4 0.8 9 $ 408 ° Emissions averaging reporte 8 0 0 0 0 0 $ 0 J. Review of Semi Annual Compliance Reporti ° No deviationsj 2 14 28 1 3 32 $ 1,427 ° Deviationsj 8 2 16 0.8 2 18 $ 816 ° Startup, shutdown, and malfunction reportk 2 16 32 2 3 37 $ 1,631 ° Control system maintenance reportl 2 16 32 2 3 37 $ 1,631 ° Emissions averaging reporte 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): m 804 40 80 925 $ 40,981 TRAVEL EXPENSES FOR TEST ATTENDEDn = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trip/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 40,981 44 TABLE 3c. ( continued)

a Operations per year are equal to the number of operations per facility times the number of facilities. There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard, 4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

b Labor cost assumes a rate of $ 44.75/ hour for technical labor, $ 73.97/ hour for management labor, and $ 25.23/ hour for clerical labor.

c Assumes all facilities will conduct initial performance test( s), and EPA personnel will attend 10 percent of the initial tests.

d Assumes 5 percent of facilities will repeat the performance test( s), and EPA personnel will attend 10 percent of the repeat tests.

e Assumes no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will conduct an initial performance test( s) and submit a notification of compliance status that includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests.

i Assumes that the facilities' compliance date is in the first half of the year, so facilities will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

j Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

k Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

l Assumes all facilities will submit a description of the control device maintenance performed.

m The burden and cost are equal to the totals added down each column.

n Tests attended include no initial performance tests and no repeat performance tests, for a total of 0 tests attended. 45 TABLE 4. SUMMARY OF RESPONDENT BURDEN HOURS AND COSTS Total burden,

hours Total costs,

$

Table 2a ( one time activities in first year) 2,229 $ 119,001 Table 2b ( recurrent activities in first year) 1,331 $ 71,044 Table 2c ( one time activities in second year) 1,394 $ 74,422 Table 2d ( recurrent activities in second year) 2,845 $ 151,913 Table 2e ( one time activities in third year) 1,881 $ 100,457 Table 2f ( recurrent activities in third year) 4,396 $ 234,747 Total 14,076 $ 751,585 Bottom line annual burden ( Total/ 3) 4,692 $ 250,528 46 TABLE 5. SUMMARY OF AGENCY BURDEN HOURS AND COSTS Total burden,

hours Total costs,

$

Table 3a ( first year) 904 $ 40,064 Table 3b ( second year) 368 $ 16,311 Table 3c ( third year) 925 $ 40,981 Total 2,197 $ 97,356 Bottom line annual burden ( Total/ 3) 732 $ 32,452 47 PART B OF THE SUPPORTING STATEMENT This section is not applicable because statistical methods are not used in the data collection associated with this rule.

4 attachments ATTACHMENT 1 Source Data and Information Requirements Attachment 1 SUMMARY OF RECORDKEEPING REQUIREMENTS Requirements Regulation Reference Record retention 63.10( b)( 1) and 63.2283 Documentation supporting initial notifications and notifications of compliance status 63.10( b)( 2)( xiv) and 63.2282( a)( 1)

Startup, shutdown, and malfunction plan 63.6( e)( 3) and 63.2250( c)

Records related to startup, shutdown, and malfunction 63.6( e)( 3)( iii)( iv) and 63.2282( a)( 2)

Records related to control device maintenance and documentation of routine control device maintenance exemption 63.2282( a)( 3)

Records of performance tests 63.10( b)( 2)( viii) and 63.2282( a)( 4)

Records for each CMS for emission limitations and records related to the work practice standards 63.8( d)( 3), 63.8( f)( 6)( i), 63.8( g), 63.10( b)( 2)( vi)( xi), and 63.2282( b)( c)

Records of information required to calculate emission debits and credits for emissions averaging 63.2282( d)

SUMMARY OF REPORTING REQUIREMENTS Requirements Regulation Reference Initial notifications ( including construction/ reconstruction) 63.5, 63.9( b), and 63.2280( a)( b)

Notification of performance test 63.7( b)( c), 63.9( e), and 63.2280( c)

Notification of compliance status ( including performance test results) 63.9( h), 63.10( d)( 2), and 63.2280( d)

Request for routine control device maintenance exemption 63.2280( e)

Emissions averaging plan 63.2280( f)

Notification of change to control system, emissions averaging process unit, monitoring parameter, or monitoring parameter value 63.2280( g)

Semi annual compliance report ° Startup, shutdown, and malfunction reports ° Control system maintenance reports ° Results of performance tests conducted during the semi annual reporting period ° No deviations/ no out of control CMS ° Deviations/ out of control CMS ° Emissions averaging reports 63.10( e)( 3) and 63.2281( b)( f) 63.10( d)( 5) and 63.2281( c)( 4) 63.2281( c)( 5) 63.2281( c)( 6)

63.2281( c)( 7)( 8) 63.2281( d)( e) 63.2281( f) ATTACHMENT 2 Description of Respondent Activities Attachment 2 DESCRIPTION OF RESPONDENT ACTIVITIES ( 1) Read Instructions represents the activities, less training, which involve comprehending the provisions in the rule and understanding how they apply to the respective emission points at a facility.

( 2) Plan Activities represents such burdens as design, redesign, scheduling, and selecting methods of compliance. The costs for planning and selection are included in the capital costs for the performance test, as explained in item ( 4) below.

( 3) Train Personnel represents activities involved in communicating specific definitions, compliance options, and other requirements, such as recordkeeping, monitoring, and reporting. An average facility may elect to provide classroom instructions for all workers directly impacted by the requirements. However, the rule does not require specific training itself.

( 4) Create Information represents the activities involving testing, retesting, establishing operating parameter limits, and analyzing point by point applicability. Because respondents are expected to hire outside contractors to conduct the performance tests, these costs are not included in the burden tables. Instead, the costs associated with the performance test are included as capital costs and are discussed in the text.

( 5) Gather Existing Information represents the activities involving physical inspections of equipment, collection of monitored data and other related activities.

( 6) Write Reports represents the activities normally associated with filling out forms. Since the rule requires no standard forms, these activities relate to the preparation of formal reports and cover letters, as appropriate.

( 7) Enter Information represent the activities that involve analysis of the information collected for accuracy, compliance, and appropriate records required as a result; software translation, duplication, or archival processes normally associated with data management and storage; and the management life cycle of records, from the time they are filed and boxed up to the time at which they are disposed. ATTACHMENT 3 Methods Used in Cost Estimates Attachment 3 1 METHODS USED IN COST ESTIMATES ( a) Costs for Monitoring Equipment The capital cost for the monitoring equipment was estimated based on the following assumptions:

1. Facilities will choose to monitor control device operating parameters instead of operating CEMS.

2. The monitoring equipment cost is $ 0 because the equipment ( e. g., thermocouples) are already being used by the facilities or are included with the control system cost.

3. The data acquisition system cost is $ 7,300, which includes $ 3,000 for data logger, $ 3,000 for computer, $ 1,000 for logging and reporting software, and $ 300 for printer.

4. One data acquisition system will be purchased for each control system.

To determine the total capital cost for monitoring equipment for existing and new facilities, the unit costs were applied to the individual control systems as shown in Table 1. The annualized capital cost for monitoring equipment was calculated as a sum of the capital recovery cost, administrative charges,

insurance, and property taxes. The capital recovery cost was determined as a product of a capital recovery factor and the total capital cost. The capital recovery factor was estimated to be 0.1098, based on a 15 year equipment life and 7 percent interest rate. The administrative charges, insurance, and property taxes were calculated as 4 percent of the capital cost.

Using these estimated costs, the capital and annualized capital costs for monitoring equipment for the first 6 years after the effective date were estimated as shown in Table 2.

( b) Costs for File Cabinets The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility. We assumed $ 235 per file cabinet. Using a capital recovery factor of 0.1098 and Attachment 3 2 estimating administrative charges, insurance, and property taxes at 4 percent of total capital cost, the average annualized capital cost per facility for file cabinets was estimated to be $ 35. Using these estimated costs, the capital and annualized capital costs for file cabinets for the first 6 years after the effective date were estimated as shown in Table 3.

( c) Costs for Performance Tests The capital costs associated with performance testing include the costs for Method 25A performance tests for all control systems. Performance test costs were estimated based on the following assumptions:

1. All facilities will use control systems and will choose to demonstrate compliance with the 90 percent THC reduction emission limit included in the rule.

2. Capital costs per performance test are $ 10,000, based on testing both the inlet and outlet of the control system.

3. One performance test will be conducted for each control system.

4. In the fourth year after the effective date, approximately 22 repeat tests will be conducted, assuming 5 percent of facilities ( i. e., 11 facilities) retest, one test per control system, and two control systems per facility.

5. In the sixth year after the effective date, facilities with biofilters will conduct the repeat tests required every two years.

To determine the total capital cost for initial and repeat performance tests for existing and new facilities, the unit cost was applied to the facilities as shown in Table 4. Using a capital recovery factor of 0.1098, the average annualized capital cost per facility for performance tests was estimated. Because no equipment is purchased, no administrative charges, insurance,

or property taxes were estimated for performance testing. Using these estimated costs, the capital and annualized capital costs Attachment 3 3 for performance testing for the first 6 years after the effective date were estimated as shown in Table 5.

( f) Costs for Operation and Maintenance Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. Because facilities that already have control systems ( e. g., catalytic oxidizers, thermal oxidizers,

biofilters) are also assumed to have the required monitoring,

there are no additional O& M costs associated with these monitoring equipment. For those facilities that would be required to install one of the control systems in order to comply with the rule, the control systems are already assumed to have the required monitoring equipment. Consequently, there are no additional O& M costs associated with these monitoring equipment either.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. The O& M costs for rules that require respondents to submit reports to EPA and maintain records are estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Using the estimated costs per response, the O& M costs for photocopying and postage for the first 6 years after the effective date were estimated as shown in Table 6. 4 Attachment 3 TABLE 1. MONITORING EQUIPMENT COSTS FOR EXISTING AND NEW FACILITIES Emission point No. of facilities Unit capital cost Capital cost Annualized capital cost Existing facilities Catalytic oxidizers 8 $ 7,300 $ 58,400 $ 8,748 Biofilters 5 $ 7,300 $ 36,500 $ 5,468 Thermal oxidizers 302 $ 7,300 $ 2,204,600 $ 330,249 TOTAL $ 2,299,500 $ 344,465 New facilities Thermal oxidizers ( each year) 7 $ 7,300 $ 51,100 $ 7,655 5 Attachment 3 TABLE 2. MONITORING EQUIPMENT COSTS FOR THE FIRST 6 YEARS FOLLOWING THE EFFECTIVE DATE Capital cost Annualized capital cost New facilities Existing facilities Total New facilitiesa Existing facilities Total Year 1 $ 51,100 $ 0 $ 51,100 $ 7,655 $ 0 $ 7,655 Year 2 $ 51,100 $ 0 $ 51,100 $ 15,310 $ 0 $ 15,310 Year 3 $ 51,100 $ 0 $ 51,100 $ 22,964 $ 0 $ 22,964 AVERAGE ( Years 1 3) $ 51,100 $ 0 $ 51,100 $ 15,310 $ 0 $ 15,310 Year 4 $ 51,100 $ 2,299,500 $ 2,350,600 $ 30,619 $ 344,465 $ 375,084 Year 5 $ 51,100 $ 0 $ 51,100 $ 38,274 $ 344,465 $ 382,739 Year 6 $ 51,100 $ 0 $ 51,100 $ 45,929 $ 344,465 $ 390,394 AVERAGE ( Years 4 6) $ 51,100 $ 766,500 $ 817,600 $ 38,274 $ 344,465 $ 382,739 aWith four new facilities being added each year, the increase in annualized capital costs each year is equal to the amount of annualized capital cost for four facilities. For example, the annualized capital cost for Year 1 ( four new facilities) would be $ 7,655, while the annualized capital cost for Year 2 ( eight new facilities) would be 2 times $ 7,655, or $ 15,310. ( Note that the annualized capital cost for Year 1 is rounded to $ 7,655 in the table, so the annualized capital costs for subsequent years may not be exact multiples of $ 7,655.) 6 Attachment 3 TABLE 3. FILE CABINET COSTS FOR THE FIRST 6 YEARS FOLLOWING THE EFFECTIVE DATE Capital cost/

respondent Annualized capital cost/

respondent Capital cost respondents/ yr Annual cost respondents/ yr Capital cost Annualized capital cost Year 1 $ 235 $ 35 4 4 $ 940 $ 140 Year 2 $ 235 $ 35 4 8 $ 940 $ 280 Year 3 $ 235 $ 35 4 12 $ 940 $ 420 AVERAGE ( Years 1 3) $ 940 $ 280 Year 4 $ 235 $ 35 216 228 $ 50,760 $ 7,980 Year 5 $ 235 $ 35 4 232 $ 940 $ 8,120 Year 6 $ 235 $ 35 4 236 $ 940 $ 8,260 AVERAGE ( Years 4 6) $ 17,547 $ 8,120 7 Attachment 3 TABLE 4. PERFORMANCE TEST COSTS FOR EXISTING AND NEW FACILITIES Emission point No. of control systemsa Unit capital cost Capital cost Annualized capital cost Existing facilities Catalytic oxidizers 8 $ 10,000 $ 80,000 $ 8,784 Biofilters 5 $ 10,000 $ 50,000 $ 5,490 Thermal oxidizers 302 $ 10,000 $ 3,020,000 $ 331,596 TOTAL $ 3,150,000 $ 345,870 New facilities Thermal oxidizers 7 $ 10,000 $ 70,000 $ 7,686 Repeat performance tests ( year 4) 22 $ 10,000 $ 220,000 $ 24,156 Biofilter repeat performance tests ( year 6) 5 $ 10,000 $ 50,000 $ 5,490 a The number of control systems is taken from the number used in the control cost estimate. Some facilities will need more than one control system. 8 Attachment 3 TABLE 5. PERFORMANCE TEST COSTS FOR THE FIRST 6 YEARS FOLLOWING THE EFFECTIVE DATE Capital cost Annualized capital cost New facilities Existing facilities Repeat tests Total New facilitiesa Existing facilities Repeat tests Total Year 1 $ 70,000 $ 0 $ 0 $ 70,000 $ 7,686 $ 0 $ 0 $ 7,686 Year 2 $ 70,000 $ 0 $ 0 $ 70,000 $ 15,732 $ 0 $ 0 $ 15,732 Year 3 $ 70,000 $ 0 $ 0 $ 70,000 $ 23,058 $ 0 $ 0 $ 23,058 AVERAGE ( Years 1 3) $ 70,000 $ 0 $ 0 $ 70,000 $ 15,732 $ 0 $ 0 $ 15,732 Year 4 $ 70,000 $ 3,150,000 $ 220,000 $ 3,440,000 $ 30,744 $ 345,870 $ 24,156 $ 400,77,0 Year 5 $ 70,000 $ 0 $ 0 $ 70,000 $ 38,430 $ 345,870 $ 24,156 $ 408,456 Year 6 $ 70,000 $ 0 $ 50,000b $ 120,000 $ 46,116 $ 345,870 $ 29,646b $ 421,632 AVERAGE ( Years 4 6) $ 70,000 $ 1,050,000 $ 90,000 1,210,000 $ 38,430 $ 345,870 $ 25,986 $ 410,286 aWith four new facilities being added each year, the increase in annualized capital costs each year is equal to the amount of annualized capital cost for four facilities. For example, the annualized capital cost for Year 1 ( four new facilities) would be $ 7,686, while the annualized capital cost for Year 2 ( eight new facilities) would be 2 times $ 7,686, or $ 15,732.

bIncludes cost of repeat performance tests required for biofilters every two years ($ 50,000 capital cost and $ 5,490 annualized cost). 9 Attachment 3 TABLE 6. O& M COSTS FOR PHOTOCOPYING AND POSTAGE FOR THE FIRST 6 YEARS FOLLOWING THE EFFECTIVE DATE Cost item Photocopy cost/ report Postage cost/

report Reports/ respondent Respondents/

year Reports/

year Photocopy cost Postage cost Notification of construction/ reconstruction ( Years 1 6) $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Notification of anticipated startup ( Years 1 6) $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Notification of actual start up ( Years 1 6) $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Emissions averaging plan ( Years 1 6) $ 18.61 $ 7.63 1 0 0 $ 0 $ 0 Notification of applicability of standard Year 1 $ 18.61 $ 7.63 1 261 261 $ 4,857 $ 1,991 Years 2 6 $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Notification of initial performance test Years 1 3, 5 6 $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Year 4 $ 18.61 $ 7.63 1 216 216 $ 4,020 $ 1,648 Notification of compliance status ( with performance test)

Years 1 3, 5 6 $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Year 4 $ 18.61 $ 7.63 1 216 216 $ 4,020 $ 1,648 Notification of compliance status ( without performance test)

Years 1 3, 5 6 $ 18.61 $ 7.63 1 1 1 $ 19 $ 8 Year 4 $ 18.61 $ 7.63 1 115 115 $ 2,140 $ 877 Request for routine control system maintenance exemption Years 1 2, 4 6 $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 10 TABLE 6. ( continued)

Attachment 3 Cost item Photocopy cost/ report Postage cost/

report Reports/ respondent Respondents/

year Reports/

year Photocopy cost Postage cost Year 3 $ 18.61 $ 7.63 1 216 216 $ 4,020 $ 1,648 Initial compliance report Years 1 3, 5 6 $ 18.61 $ 7.63 1 4 4 $ 74 $ 31 Year 4 $ 18.61 $ 7.63 1 216 216 $ 4,020 $ 1,648 Semi annual compliance report Year 1 $ 18.61 $ 7.63 2 0 0 $ 0 $ 0 Year 2 $ 18.61 $ 7.63 2 4 8 $ 149 $ 61 Year 3 $ 18.61 $ 7.63 2 8 16 $ 298 $ 122 Year 4 $ 18.61 $ 7.63 2 12 24 $ 447 $ 183 Year 5 $ 18.61 $ 7.63 2 228 456 $ 8,486 $ 3,479 Year 6 $ 18.61 $ 7.63 2 232 464 $ 8,635 $ 3,540 TOTAL ( Year 1) 290 $ 5,397 $ 2,213 TOTAL ( Year 2) 41 $ 763 $ 313 TOTAL ( Year 3) 261 $ 4,857 $ 1,991 AVERAGE ( Years 1 3) 197 $ 3,672 $ 1,506 TOTAL ( Year 4) 807 $ 15,018 $ 6,157 TOTAL ( Year 5) 489 $ 9,100 $ 3,731 TOTAL ( Year 6) 497 $ 9,249 $ 3,792 AVERAGE ( Years 4 6) 598 $ 11,123 $ 4,560 ATTACHMENT 4 Burden and Cost of Reporting and Recordkeeping Requirements For the Fourth, Fifth, and Sixth Years Following the Effective Date Attachment 4 1 BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE FOURTH, FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE 1. The Information Collected    Respondent Activities and Agency Activities ( a) Respondent Activities As shown in the Supporting Statement, there are several onetime notifications and reports that both existing and new sources must complete in the 3 years between the effective date of the PCWP manufacturing NESHAP and the compliance date for existing sources. These reports include: ( 1) determining applicability and notifying EPA that the facility is subject to the rule,

( 2) developing and submitting an emissions averaging plan ( if appropriate), and ( 3) developing and submitting a routine control system maintenance exemption request. New sources are also required to submit notifications of construction/ reconstruction and notifications of anticipated and actual startup, as well as initial and semi annual compliance reports.

In the 3 years following the compliance date for existing sources, existing sources must submit other one time notifications and reports, and ongoing recordkeeping and reporting begins. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), existing facilities must notify EPA of upcoming performance tests, conduct the performance tests, and submit the initial notification of compliance status. Existing facilities also must develop their startup, shutdown, and malfunction plans and begin ongoing monitoring and recordkeeping for various operating parameters, emissions averaging ( if appropriate), control system maintenance, etc. Existing facilities will begin to submit initial and semi annual reports of deviations and various other reports related to startup, Attachment 4 2 shutdown, and malfunction, emissions averaging ( if appropriate),

control system maintenance, etc.

The respondent activities required by the rule in the fourth, fifth, and sixth years following the effective date of the rule are listed in the first columns of Tables 1a through 1f of this attachment. One time and recurrent respondent activities are presented in Tables 1a and 1b for the fourth year, Tables 1c and 1d for the fifth year, and Tables 1e and 1f for the sixth year.

( b) Agency Activities As shown in the Supporting Statement, in the 3 years between the effective date of the NESHAP and the compliance date for existing sources, EPA will review the notifications of applicability, emissions averaging plans ( if appropriate), and routine control system maintenance exemption requests submitted by existing and new sources. The EPA will also review the notifications of construction/ reconstruction, notifications of actual and anticipated startup, and initial and semi annual compliance reports submitted by new sources over the 3 years between the effective date of the NESHAP and the compliance date for existing sources.

In the 3 years following the compliance date for existing sources, EPA will continue to review the notifications and initial and semi annual compliance reports submitted by new sources. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), the EPA will also review notifications and reports for existing sources, including the notifications of performance tests, notifications of compliance status, and initial compliance reports. The EPA will also review the ongoing semi annual compliance reports for existing sources in the fifth and sixth years following the effective date of the rule. Agency activities are listed in the first columns of Tables 2a, 2b, and Attachment 4 3 2c of this attachment for the fourth, fifth, and sixth years,

respectively, following the effective date of the rule.

2. Estimating the Burden and Cost of the Collection ( a) Estimating Respondent Burden and Costs ( i) Estimating respondent burden and labor costs. Tables 1a through 1f of this attachment present the annual respondent burden estimates and labor costs for reporting and recordkeeping activities for the fourth, fifth, and sixth years following the effective date of the rule. The one time and recurrent burden and cost estimates are presented in Tables 1a and 1b for the first year, Tables 1c and 1d for the second year, and Tables 1e and 1f for the third year. The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts.

Labor costs for reporting and recordkeeping activities were estimated based on the most recently available labor rate data from the U. S. Bureau of Labor Statistics ( BLS)

( http:// www. bls. gov/ ncs/ ect/ home. htm). Labor costs are divided into the following three categories: ( 1) technical, ( 2)

management, and ( 3) clerical. The labor rates, including fringe benefits, reported by BLS for June 2003 ( the most recent rates available) are $ 32.12 per hour ($ 32.12/ hr) for technical personnel, $ 48.41/ hr for managerial personnel, and $ 22.29/ hr for clerical personnel. The base labor rates were adjusted by an overhead rate of 167 percent. The final total labor rates are $ 53.64 for technical personnel, $ 80.84 for management, and $ 37.22 for clerical.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities   capital costs and O& M costs. The methods used to estimate the capital and O& M costs for this attachment to the Attachment 4 4 Supporting Statement are presented in Attachment 3, Methods Used in Cost Estimates.

One time capital costs usually include any produced physical good, such as computers, machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest rate. For this attachment to the Supporting Statement, capital costs were annualized over 15 years, assuming an interest rate of 7 percent. In most cases, administrative charges, insurance, and property taxes were also included with the annualized capital costs, estimated at 4 percent of the capital cost.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs ( planning and selection), and a data acquisition system ( data logger, computer, logging and reporting software, and printer).

The capital costs for the monitoring equipment were estimated based on the following assumptions: ( 1) the parameter monitoring equipment for thermal oxidizers, catalytic oxidizers, and biofilters include thermocouples; ( 2) facilities that already have these control systems are also assumed to have the required parameter monitoring equipment, so no costs have been assigned to these monitoring equipment and it is assumed that the facilities will elect to monitor parameters rather than using CEMS; ( 3) for those facilities that would be required to install one of these control systems in order to comply with the rule, the control systems are assumed to include the required parameter monitoring equipment; consequently, no cost has been assigned to these monitoring equipment and it is assumed that the facilities will elect to monitor parameters rather than using CEMS; ( 4) one data acquisition system will be required for each control system, at a cost of $ 7,300 ($ 3,000 for data logger, $ 3,000 for computer, Attachment 4 5 $ 1,000 for logging and reporting software, and $ 300 for printer);

and ( 5) data acquisition systems will be purchased for the estimated 322 control systems ( 8 catalytic oxidizers, 5 biofilters, and 309 thermal oxidizers) at existing and new facilities in the fourth year after the effective date of the rule; data acquisition systems will be purchased for the estimated 7 control systems ( thermal oxidizers) installed at new facilities in each of the fifth and sixth years after the effective date ( based on an estimated 34 new thermal oxidizers expected to be installed over 5 years).

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file cabinet). The annualized capital cost per file cabinet is $ 35.

Approximately 216 existing and new facilities will purchase this equipment in the fourth year after the effective date of the rule, and 4 new facilities will purchase this equipment in each of the fifth and sixth years after the effective date.

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. The capital costs associated with performance testing include the costs for Method 25A performance tests for all control systems. Performance test costs were estimated based on the following assumptions: ( 1) all facilities will use control systems and will choose to demonstrate compliance with the 90 percent THC reduction emission limit included in the rule; ( 2) capital costs per performance test are $ 10,000, based on testing both the inlet and outlet of the control system; ( 3) one performance test will be conducted for each control system at a facility; ( 4) performance tests will be conducted for the estimated 322 control systems ( 8 catalytic oxidizers, 5 biofilters, and 309 thermal oxidizers) at existing and new facilities during the fourth year after the effective date; performance tests will be conducted for the estimated 7 Attachment 4 6 control systems ( thermal oxidizers) installed at new facilities during each of the fifth and sixth years; ( 5) in the fourth year after the effective date, approximately 22 repeat tests will be conducted, assuming 5 percent of facilities ( i. e., 11 facilities)

retest, one test per control system, and two control systems per facility; and ( 6) in the sixth year after the effective date,

facilities with biofilters will conduct the repeat tests required every two years. Because no equipment is purchased, no administrative charges, insurance, or property taxes were estimated for performance testing.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. Because facilities that already have control systems are also assumed to have the required monitoring equipment, there are no additional O& M costs associated with the monitoring equipment. For those facilities that would be required to install a control system to comply with the rule, it is assumed that the control system already has the required monitoring equipment. Consequently, there are no additional O& M costs associated with this monitoring equipment.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. The O& M costs for rules that require respondents to submit notifications and reports to EPA and maintain records are estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 37.22/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs will be applied to the 807 responses submitted during the fourth year,

the 489 responses submitted during the fifth year, and the 497 responses submitted during the sixth year. ( The number of Attachment 4 7 responses was determined by adding the number of reports submitted to EPA by respondents, as shown in Tables 1a through 1f of this attachment and in Attachment 3.)

( b) Estimating Agency Burden and Costs Tables 2a, 2b, and 2c of this attachment present the estimated annual burden to the Federal Government during the fourth, fifth, and sixth years, respectively, following the effective date of the rule. The only burden and costs that the Federal Government will incur as a result of the information collection requirements are associated with the analysis of the information reported by facilities in one time notifications and initial and semi annual compliance reports ( unless the compliance report indicates a deviation, thereby triggering an enforcement action). Labor rates for Federal employees were based on the January 2002, Office of Personnel Management labor rates for General Schedule employees ( http:// www. opm. gov/ oca/ 02tables/ 02gsh. pdf). The base labor rates are $ 27.97/ hr for technical personnel ( GS 12, step 5),

$ 46.23 for management personnel ( GS 15, step 5), and $ 15.77/ hr for clerical personnel ( GS 7, step 5). The base labor rates were multiplied by the standard government benefits multiplication factor of 1.6. The resulting average hourly labor costs are $ 44.75 for technical personnel, $ 73.97 for management, and $ 25.23 for clerical.

( c) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 1a through 1f and dividing the sums by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date). The total annual respondent burden hours and costs are summarized in Table 3.

The bottom line annual burden, averaged over the fourth,

fifth, and sixth years after the effective date, is 113,050 labor Attachment 4 8 hours, at a cost of $ 6,036,300. The average annual burden per respondent, based on an average 232 respondents over the 3 year period, is 487 labor hours, at a cost of $ 26,019.

On average, there are an estimated 598 total annual responses for the fourth, fifth, and sixth years after the effective date. Of the 598 total annual responses, approximately 20 percent are assumed to be collected electronically. The total annual responses are an average of the one time and recurrent notifications and reports submitted during the fourth, fifth, and sixth years after the effective date. An estimated 807 one time and recurrent notifications and reports will be submitted during the fourth year, 489 during the fifth year, and 497 during the sixth year.

The total nationwide capital costs associated with monitoring equipment were estimated to be $ 2,350,600 the fourth year after the effective date of the rule, and $ 51,100 in each of the fifth and sixth years. The average annualized capital cost for the monitoring equipment is $ 382,739 for the fourth, fifth,

and sixth years following the effective date.

The total nationwide capital costs associated with file cabinets for storing collected data and reports were estimated to be $ 50,760 in the fourth year after the effective date of the rule, and $ 940 in each of the fifth and sixth years. The average annualized capital cost for file cabinets is $ 8,120 for the fourth, fifth, and sixth years following the effective date.

The total nationwide capital costs for performance tests were estimated to be $ 3,440,000 for the fourth year, $ 70,000 for the fifth year, and $ 120,000 for the sixth year after the effective date of the rule. The average annualized capital cost for the performance tests is $ 410,286 for the fourth, fifth, and sixth years following the effective date.

Annual O& M costs, which include photocopying and postage for the reports, average $ 15,683 nationwide for the fourth, fifth,

and sixth years following the effective date of the rule. Attachment 4 9 Combining the annualized capital costs for the monitoring equipment, file cabinets, and performance tests results in an average total annualized capital cost of $ 801,145 for the fourth,

fifth, and sixth years following the effective date. Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 816,828 for the fourth, fifth, and sixth years following the effective date.

( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours and costs from Tables 2a through 2c and then dividing by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date). The total annual Agency burden hours and costs are summarized in Table 4. The bottom line annual burden,

averaged over the fourth, fifth, and sixth years after the effective date, is 10,564 labor hours, at a cost of $ 476,067.

( d) Burden Statement ( i) The total annual reporting and recordkeeping burden and cost for this collection averaged over the fourth, fifth, and sixth years after the effective date of the rule were estimated to be 113,050 labor hours and $ 6,036,300. The average burden and cost, per respondent, are 487 labor hours and $ 26,019.

During these 3 years, new facilities are required to submit notifications of construction/ reconstruction and notifications of anticipated and actual startup, and existing facilities are required to submit notifications of performance test and notifications of compliance status. All facilities are required to submit initial and semi annual compliance reports to indicate their ongoing compliance status. Each respondent also must keep necessary records of data to determine compliance with the rule.

In the fourth year after the effective date, the collection requirements will be applicable to an estimated 228 respondents ( 212 existing facilities as of the effective date, 16 facilities constructed as of the fourth year after the effective date). An Attachment 4 10 estimated 4 additional facilities will be subject to the rule in each subsequent year.

( ii) The total capital cost in the fourth year after the effective date of the rule is $ 5,841,360; this cost includes $ 2,350,600 for monitoring equipment, $ 50,760 for file cabinets,

and $ 3,440,000 for performance tests. The total capital cost in the fifth year after the effective date is $ 122,040, which includes $ 51,100 for monitoring equipment, $ 940 for file cabinets, and $ 70,000 for performance tests. The total capital cost in the sixth year after the effective date is $ 172,040,

which includes $ 51,100 for monitoring equipment, $ 940 for file cabinets, and $ 120,000 for performance tests. The average annualized capital cost for the monitoring equipment, file cabinets, and performance tests is $ 801,145 for the fourth,

fifth, and sixth years after the effective date. The average annual O& M cost, which includes photocopying and postage for the reports, is $ 15,683 for the fourth, fifth, and sixth years after the effective date. Combining the annualized capital cost with the annual O& M cost gives a total annualized cost of $ 816,828 for the fourth, fifth, and sixth years after the effective date. 11 Attachment 4 TABLE 1a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 4 4 0.2 0.4 5 $ 246 B. Required Activities C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/

reconstruction 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of anticipated startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of actual startup 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of applicability of standardd 2 1 2 4 8 0.4 0.8 9 $ 491 ° Emissions averaging plane 120 1 120 0 0 0 0 0 $ 0 ° Request for routine control system maintenance exemptionf 2 1 2 4 8 0.4 0.8 9 $ 491 ° Notification of initial performance testg 2 1 2 216 432 22 43 497 $ 26,527 ° Notification of compliance status With performance testg 80 1 80 216 17,280 864 1,728 19,872 $ 1,061,061 Without performance testh 120 1 120 115 13,800 690 1,380 15,870 $ 847,375 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemi 40 1 40 216 8,640 432 864 9,936 $ 530,531 E. Develop Startup, Shutdown,

Malfunction Planj 100 1 100 216 21,600 1,080 2,160 24,840 $ 1,326,326 F. Time to Train Personnelk 40 1 40 216 8,640 432 864 9,936 $ 530,531 G. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDE: l 70,436 3,522 7,044 81,001 $ 4,325,052 Average cost per facilitym 228 $ 18,970 12 Attachment 4 TABLE 1a. ( continued)

a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule.

e Assumes no existing facilities will choose to use the emissions averaging option because all facilities assumed to install control systems; new facilities are not allowed to use emissions averaging.

f Assumes all facilities will submit a request for routine control device maintenance exemption.

g Assumes all facilities will comply by conducting a performance test( s). The notification of compliance status includes the report of the performance test( s).

h Assumes 1 new facility per year with softwood veneer dryers will submit a notification of compliance status without performance tests; assumes that 22 existing facilities with dry rotary dryers, 2 existing facilities with hardwood veneer dryers, and 90 existing facilities with softwood veneer dryers will submit notifications of compliance status in the fourth year after the effective date.

i Assumes 40 hours to develop a record system for recording parameter monitoring information.

j Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/ revisions, for a total of 100 hours.

k Assumes 40 hours to train personnel.

l The one time burden and cost are equal to the totals added down each column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 228) subject to the rule. 13 Attachment 4 TABLE 1b. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical personhours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Initial compliance reportd No deviationse 8 1 8 194 1,552 78 155 1,785 $ 95,299 Deviationse 24 1 24 22 528 26 53 607 $ 32,421 Startup, shutdown, and malfunction reportf 8 1 8 216 1,728 86 173 1,987 $ 106,106 Control system maintenance reportg 8 1 8 216 1,728 86 173 1,987 $ 106,106 Emissions averaging plan reporth 20 1 20 0 0 0 0 0 $ 0 ° Semi annual compliance reportd No deviationse 8 2 16 11 176 9 18 202 $ 10,807 Deviationse 24 2 48 1 48 2 5 55 $ 2,947 Startup, shutdown, and malfunction reportf 8 2 16 12 192 10 19 221 $ 11,790 Control system maintenance reportg 8 2 16 12 192 10 19 221 $ 11,790 Emissions averaging plan reporth 20 2 40 0 0 0 0 0 $ 0 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System N/ A E. Time to Enter Information ° Records of startup, shutdown,

and malfunction 1.5 52 78 228 17,784 889 1,778 20,452 $ 1,092,009 ° Records of continuous compliancei Record parameters/

information 0.25 365 91 228 20,805 1,040 2,081 23,926 $ 1,277,510 Compile data 24 2 48 228 10,944 547 1,094 12,586 $ 672,005 14 Attachment 4 TABLE 1b. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical personhours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c Enter/ verify information for semi annual reports 16 2 32 228 7,296 365 730 8,390 $ 448,004 ° Records of control system maintenance Included in 3E ° Records of emissions averaging credits/ debits Included in 3E F. Calibration of CMSj 16 1 16 228 3,648 182 365 4,195 $ 224,002 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelk 16 1 16 12 192 10 19 221 $ 11,790 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: l 66,813 3,341 6,681 76,835 $ 4,102,585 Average cost per facilitym 228 $ 17,994 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 212 existing major source facilities subject to the NESHAP. These 212 facilities include 166 facilities that must install control systems to comply with the NESHAP and 46 facilities that already have the required control systems. Assuming 19 new facilities built over the first 5 years after the effective date ( including 6 oriented strand board, 5 medium density fiberboard,

4 particleboard, and 4 laminated veneer lumber facilities), approximately 4 new facilities will be built each year.

c Labor cost assumes a rate of $ 53.64/ hour for technical labor, $ 80.84/ hour for management labor, and $ 37.22/ hour for clerical labor.

d Assumes that the respondents' compliance date is in the first half of the year, so respondents will submit one compliance report the first year that they start complying with the rule and two compliance reports the following years.

e Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

f Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the SSMP.

g Assumes all facilities will submit a description of the control device maintenance performed.

h Assumes no existing facilities will choose to use the emissions averaging option; new facilities are not allowed to use emissions averaging.

i Includes records of CMS data for emission limitations and various records for work practice standards.

j Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming a total of 2 CMS for each facility, a total of 16 hours per year per facility is required.

k Assumes 2 days ( 16 hours) to provide refresher training for personnel.

l The recurrent burden and cost are equal to the totals added down each column.