### 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:

cAssume 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.

eIt 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

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

### (rounded)

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