Table 1: Annual Respondent Burden and Cost for NSPS for Graphic Arts Industry

(40 CFR part 60, subpart QQ) (Renewal)

0.869565 $98.20 $114.49 $48.53

(A)

Respondent 

Hours per 

Occurence 

(Technical 

hours) 

(B)

Number of 

Occurences per 

Respondent per 

Year 

(C)

Hours per 

Respondent per 

Year

(C=A x B) 

(D)

Number of 

Respondents per 

Year b 

(E)

Technical Hours 

per Year

@ $98.20

(E=C x D) 

(F)

Management 

Hours per Year

@ $114.49

(F= E x 0.05) 

(G)

Clerical Hours 

per Year

@ $48.53

(G= E x 0.1) 

 Total Labor 

Costs per Year 

1. APPLICATIONS N/A N/A N/A N/A N/A N/A N/A N/A

2. SURVEY AND STUDIES N/A N/A N/A N/A N/A N/A N/A N/A

3. REPORTING REQUIREMENTS

A. Read Instructions 1 1 1 2.23 2.23 0.112 0.22 $242.94

B. Required Activities

New Sources

60 1 60 2.23 134 6.70 13.40 $14,576.18

Repeat of performance test 60 1 60 0.45 27 1.35 2.70 $2,936.99

C. Create Information

D. Gather Existing Information

E. Write Report

New Sources

Notification of construction/reconstruction/modification 2 1 2 2.23 4.5 0.22 0.45 $485.87

Notification of actual startup 2 1 2 2.23 4.5 0.22 0.45 $485.87

Notification of initial performance test 2 1 2 2.23 4.5 0.22 0.45 $485.87

Report of performance test 

Semiannual Report 8 2 16 19 304 15.20 30.40 $33,068.36

317 16 32

TOTAL REPORTING BURDEN 365 Hours $52,828

4. RECORDKEEPING REQUIREMENTS

A. Read Instructions

B. Plan Activities

C. Implement Activities

D. Develop Record System 3 1 3 0.33 1.00 0.05 0.10 $108.78

E. Time to Enter Information 

Records of startups, shutdowns, malfunctions, etc. 0.20 4.29 0.86 19.33 16.6 0.83 1.66 $1,804.40

Records of VOC for monthly materials and emissions calculation 1 51.48 51.48 19.33 995.3 49.76 99.53 $108,264.07

F. Train Personnel N/A N/A N/A N/A N/A N/A N/A N/A

G. Audits N/A N/A N/A N/A N/A N/A N/A N/A

1,176 59 118

TOTAL RECORDKEEPING BURDEN 1,353 Hours $110,177

TOTAL ANNUAL BURDEN 1,718 Hours $163,005

Assumptions:

c

 Assume that 20 percent would have to repeat the performance test due to failure.

d

 We have assumed that 90 percent of the existing respondents will submit semiannual reports.

e

 It is assumed that one new facility will become subject to the standard over the next three years. For each year within the three years of the active life of this ICR there will be .33 new respondent.

f

 We have assumed that there are 19 existing respondents, plus .33 new respondent for a total of 19.33 respondents per year.

h

 We have assumed that the number of occurrences per respondent per year to record VOC is 51.48 (4.29 x 12 months).

REPORTING/RECORDKEEPING REQUIREMENT

Initial performance test 

------------------------Included in 3B----------------------------

------------------------Included in 3B----------------------------

Total Reporting Hours by Labor Category

------------------------Included in 3B----------------------------

------------------------Included in 3B----------------------------

------------------------Included in 4C----------------------------

------------------------Included in 3A----------------------------

Total Reporting Hours by Labor Category

g

 We have assumed that there are 19 existing respondents with an average of four presses per facility (19x4=76), plus six modified presses, and one at a new respondent for a total of 83 presses that are subject to the rule. Therefore, 

the number of occurrences per respondent per year is 4.29 (83/19.33=4.29).

a

 The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” 

The rate has been increased by 110% to account for the benefit packages available to those employed by private industry.

b

 We have assumed that 30 percent of respondents will modify their operations over the three-year period of this ICR (19x30%=5.7). The one new facility will come on lines over the three-year period. Average over three years is 

2.23 [(5.7+1)/3=2.23] per year.
Table 2: Average Annual Agency Burden for NSPS for Graphic Arts s Industry

(40 CFR part 60, subpart QQ) (Renewal)

0.869565 $46.22 $62.27 $25.01

(A)

EPA Hours 

per 

Occurence 

(Technical 

hours) 

(B)

Number of 

Occurences 

per Plant per 

Year 

(C)

EPA Hours 

per Year

(C=A x B) 

(D)

Plants per 

Year 

(E) 

Technical 

Hours per 

Year 

@ $46.22 

(E=C x D) 

(F)

Management 

Hours per Year 

 @ $62.27

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

@ $25.01

(G= E x 0.1) 

Costs per Year 

INITIAL PERFORMANCE TESTS

New Plant 24 1 24 2.23 53.5 2.68 5.35 $2,774.13

REPEAT PERFORMANCE TEST 

New Plant 24 1 24 2.23 53.5 2.68 5.35 $2,774.13

REPORT REVIEW

New Plant

Notification of construction, reconstruction and startup 2 1 2 2.23 4.5 0.22 0.45 $231.18

Notification of actual startup 0.5 1 0.5 2.23 1.12 0.06 0.11 $57.79

Notification of initial performance test 0.5 1 0.5 2.23 1.12 0.06 0.11 $57.79

Review test results 4 1 4 2.23 8.9 0.45 0.89 $462.35

Semiannual Reports 2 2 4 19 76 3.80 7.60 $3,939.35

TOTAL ANNUAL HOURS 199 10 20

SALARY BURDEN (per year) $10,296.72

ANNUAL TRAVEL EXPENSES

$3,500.00

TOTAL ANNUAL BURDEN 228 Hours $13,797

Assumptions:

c

 Assume that 20 percent would have to repeat the performance test due to failure.

d

 We have assumed that all 19 respondents will submit semiannual reports.

e

 Assume that it will take one person two days to visit each of the seven plants.

REPORTING/RECORDKEEPING REQUIREMENT

(1 person x 7 plants/year x 2 d/plant x $50 per diem) + ($400 round 

trip/plant x 7 plant/yr) = 

a This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.219 

for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) "2009 General Schedule" which excludes 

locality rates of pay.

b

 We have assumed that 30 percent of respondents will modify their operations over the three-year period of this ICR (19x30%=5.7). The one new facility will come on lines over the three-year period. Average ove

three years is 2.23 [(5.7+1)/3=2.23] per year.
(rounded)

Average over