**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal) , EPA I CR Number 0657.11 , OMB Control Number 2060

- 0105 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) f or the Graphic Arts Industry were : 1) proposed on October 28, 1980 ; 2) promulgated on November 8, 1982 ; and 3) last

- amended on April 9, 2004 . These regulations apply to each publication rotogravure printing press (not including proof presses) commencing construction, modification , or rec onstruction after the date of proposal

. This information is being collected to assure compliance with 40 CFR part 60 , subpart QQ

. In general, all NSPS standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports ar e sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of 2 0 existing respondents per ye ar will be subject to the standard , 0.33 additional respondent per ye ar will become subject to the standard. Also, this I CR assumes 30 percent of existing facilities will either add or modify operations over the 3

- ye ar ICR period, yi elding an average of 2 facilities per year (20*0.3/3 = 2) that will also be come subject to initial reporting requirements. The Office of Management and Budget ( OMB ) approved the currentl y active ICR without any

“Terms of Clearance.”2

The “Affected Public” are owners or operators of graphic arts facilities . The “burden ” to the Affected Public may be found below in Table 1: Annual Respondent Burden and C ost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal). The “burden ” to the “Federal Government” is attributed entirel y to work performed b y either F ederal employees or government contractors. This burden may be found below in Ta

ble 2: Average Annual EPA Burden and Cost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for**  **the Collection** The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to thi s charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. In addition, section 114(a) states that the Administrator may require any

o wner/operator subject to any

requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in ac cordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgment , volatile organic compound (VOC ) emissions from publication rotogravure printing presses c ause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for3

this source category

at 40 CFR part 60 , subpart QQ. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure s compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to det ermine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard s at all times

. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, and that the standard i s being met. The performance test may also be observed. The required semiannual reports are u sed to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60 , subpart QQ

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitte d to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comm ent period for the renewal of this ICR was published in the Federal Register (78 FR 33409) on June 4, 2013 . No comments were received on the burden published in the Federal Register

.4

**3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compli ance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In developing this I CR, the EPA contacted : 1) the Printing Industries of America , at ( 202 ) 730

- 7970 ; and 2) the Printing & Graphics Association Mid Atlantic , at (410) 319

- 0900. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Coll ection**  Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be le ss likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are owners or operators of graphic arts facilities

. The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standard i s SI C 2754 ( Commercial Printing, Gravure ), which correspond s to the North American Industry Classification System (NAI CS) code 323111 for Commercial Printing, except Screen and Books. **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NSPS for the Graphic Arts Industry

(40 CFR Part 60, Subpart QQ)

. A source must make the following reports:

**Notifications and Reports**  Construction/reconstruction 60.7(a)(1) Actual startup 60.7(a)(3) Initial performance test results 60.8(a) and 60.433 (e)(6) Initial performance test 60.8(d) Physical or operational change 60.7(a)(4) Semiannual Reports 60.7(c)
A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunctions 60.7(b) Records necessary

to determine conditions of the performance test 60.7(f), 60.8(c), and 60.433(a)(5)6 **Recordkeeping** Records showing information to make monthly calculations of emissions 60.7(f), and 60.434(a)
Records are required to be retained for two ye ars. 60.7(f)
Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting systems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respon dent**  **Activities**

**Respondent Activities** Read instructions. Perform initial performance test, Reference Method 24A t est, and repeat performance tests if necessary . Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. Adjust the existing ways to comply with any previously applicable instructions and requirements.7 **Respondent Activities** Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities**  Observe initial performance tests and repeat performance tests if necessary

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

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **5( b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capab ility to compl y with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned fa cilities. EPA uses the OTI S for tracking air pollution compliance and8

enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility** There are no small entities (i.e., small businesses) affected b y this regulation. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in below Table 1 : Annual Respondent Burden and Cost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 1,802 hours ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously

approved IC R, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 3

. 04 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 5 1

. 18 ($2 4

. 37 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March9

2013 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are neither capital/startup n or operation and maintenance costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  The only type of industry costs associated with the information collection activity in the regulation is labor costs. There are no mandatory capital/startup or operation and maintenance costs. **6(c) Estimating Agency Burden and C ost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 8,475

. This cost is based on the average hourl y labor rate as follows:

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 3 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear below in Table 2 : Average Annual EPA Burden and Cos t

– NSPS for the Graphic Arts Industry

(40 CFR Part 60, Subpart QQ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 20 existing respondents will be subject to the s tandard. It is estimated that 0.33 additional respondent per year will become subject. Also, this I CR assumes 30 percent of existing facilities will add or modify

operations over the 3

- ye ar period of this ICR, yielding an average of 2 facilities per ye ar (20*0.3/3 = 2) that also will become subject to initial reporting requirements.10

The overall average number of respondents, as shown in the table below, is 20.33 p er year . The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents 1 (E)

Number of Respondents (E=A+B+C

- D)

1 2. 3 3 19.66 0 2 20 2 2. 3 3 2 0 0 2 20.33 3 2. 3 3 2 0 .33 0 2 20 .66 Average 2. 3 3 2 0 0 2 20.33
1 Over the 3

- year ICR period, we have assumed that 30 percent of existing respondents will modify operations (20* 30% = 6) and that 1 new facility will come on

- line. The three

- year average is 2.33 per year ((6 + 1)/3 = 2.33). C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 20.33. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B)

Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Notification of construction/ reconstruction 2. 3 3 1 0 2. 33

Notification of actual startup 2.33 1 0 2. 3 3 Notification of initial performance test 2. 33 1 0 2. 3 3
Initial performance test report 2. 33 1 0 2. 3 3 Semiannual reports 20 2 0 40 Total 49 (rounded)11

The number of Total Annual Responses is 49 responses . The total annual labor costs are $ 176,264

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,802 hours at a cost of $176,264

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 37 h ours per response . There are no annual capital/startup and O&M costs to the regulated entity . The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 188 labor hours at a cost of $ 8,475 . See below Table 2 : Average Annual EPA Burden and Cost

– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)

. **6(f) Reasons for Change in Burden** There is an increase in the total estimated respondent burden as currently identified in the OMB Inventory of Approved Burdens. The change in burden is due to an increase in the number of sources subject to the standard, and is not due to any program changes. The number of sources has been increased to account for industry growth that has occurred since the most

recently ICR was approved. Also, there is an increase in the respondent cost from the most recentl y- approved ICR due to the use of updated labor rates. This ICR references labor rates from the Bureau of Labor Statistics to calculate the respondent burden cost. There is a decrease in the total estimated Agency burden as compared to the most recentl y approved ICR . This change is due to a revision in the labor burden estimate for repeat performance testing. Due to a discrepancy in the previous I CR , the labor burden for repeat12

performance testing included respondents who passed the initial performance test. Th e revision account s onl y for respondents who failed the initial performance test resulted in the reduced labor burden observed in this I CR. Also, note that the IC R also incorporates updated labor rates from OPM. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 37 hours per response. “ Burden ” means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for thi s information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- O ECA

- 2013

- 0302. An electronic version of the public docket is available at http://www.regulations.gov/ , which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the system , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open fro m 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2013

- 0302 and OMB Control Number 2060

- 0105 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.13

**Table 1 : Annual Respondent Burden and Cost** 

**– NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year Technical** 

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost per** 

**year a**  **($)**

1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions b 1 1 1 2.33 2.33 0.12 0.23 $ 262.38 B. Required activities New sources Initial performance test b 60 1 60 2.33 139.8 6.99 13.98 $ 15,726.1 0 Repeat of performance test c 60 1 60 0.47 28.2 1.41 2.82 $ 3,172.22 C. Create information See 3B D. Gather existing information See 3B E. Write report New sources Notification of construction, reconstruction, or modification b 2 1 2 2.33 4.66 0.23 0.47 $ 524.04 Notification of actual startup b 2 1 2 2.33 4.66 0.23 0.47 $ 524.04 Notification of initial performance test b 2 1 2 2.33 4.66 0.23 0.47 $ 524.04 Report of performance test See 3B Semiannual report d 8 2 16 20 320 16 32 $ 35,996.8 0 **Subtotal for reporting Requirements 5**  **79.95 $**  **56,7 29.62**  4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 4C C. Im plement activities See 3B D. Develop record system e 3 1 3 0.33 0.99 0.05 0.1 $ 111.4814

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year Technical** 

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost per** 

**year a**  **($)**

E. Time to enter information Records of startups, shutdowns, malfunctions, etc. f, g 0.2 4.28 0.86 20.33 17.48 0.87 1.75 $ 1,965.94 Records of VOC for monthly materials and emissions calculation f, h 1 51.36 51.36 20.33 1,044.15 52.21 104.42 $ 117,457 .00
F. Time to train personnel N/A G. Time for audits N/A **Subtotal for Recordkeeping Requirements 1,222**  **.02 $**  **119,534 .42**  **TOTAL ANNUAL BURDEN AND COST ( rounded** **) 1,802**  **$ 176,264**  Assumptions:
a. T his ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to tho se emplo yed by private industry. b. Over the 3

- year ICR period, we have assumed that 30 percent of existing respondents will modify operations (20*30% = 6) and that 1 new f acility will come on

line. The three

- year average is 2.33 per year ((6 + 1)/3 = 2.33).
c. We have assumed 20 percent of respondents will have to repeat the performance test due to fa ilure (2.33*20% = 0.47). d. We have assumed all existing respondents will su bmit semiannual reports.
e. We have assumed one new facility will become subje ct to the standard over the next three years. Therefore, there will be an average of 0.33 new respondents per year over the active life of this ICR. f. We have assumed that 20 existing respondents are subject to the standard, plus 0.33 new respondents per year for a total of 20.33 respondents per year. g. We have assumed there are 20 existing respondents with an average of 4 presses per facility (20*4 = 80), plus 6 modified pres ses, and 1 press at the new respondent facility, for a total of 87 presses that are subject to the rule. The number of occurrences per respondent per year is 4.28 (87/20.33 = 4.28). h. We estimate the number of occurrences per respondent per year to be 51.36 (4.28*12 = 51.36).15

**Table 2 : Average Annual EPA Burden and Cost** 

**– NSPS for**  **the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year Technical** 

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year a**  **($)**

Initial performance test New plant b 24 1 24 2.33 55.92 2.8 5.59 $ 2,898.23 Repeat performance test New plant c 24 1 24 0.47 11.3 0.56 1.13 $ 584.38 Report review New plant Notification of construction, reconstruction, or modification b 2 1 2 2.33 4.66 0.23 0.47 $ 241.42 Notification of actual startup b 0.5 1 0.5 2.33 1.17 0.06 0.12 $ 60.8 0 Notification of initial performance test b 0.5 1 0.5 2.33 1.17 0.06 0.12 $ 60.8 0 Report of performance test b 4 1 4 2.33 9.32 0.47 0.93 $ 483.2 0 Semiannual report d 2 2 4 20 80 4 8 $ 4,145.96 **TOTAL ANNUAL BURDEN AND COST ( rounded** **) 188**  **$ 8,475**  Assumptions:
a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These r ates are from the Office of Personnel Management (OPM), 2013 General Schedule, which excludes locality rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government employees. b. Over the 3

- year ICR period, we have assumed that 30 percent of existing respondents will modify operations (20*30% = 6) and that 1 new facility will come on

line. The three

- year average is 2.33 per year ((6 + 1)/3 = 2.33).
c. We have assumed 20 percent of respondents will have to repeat the performance test due to fa ilure (2.33*20% = 0.47). d . We have assumed all existing respondents wil l submit semiannual reports.