SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal ),

EPA ICR Number 1739.0 8

, OMB Control Number 2060

- 0335

.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the

P rinting and Publishing Industry were proposed on March 14, 1995 , promulgated on May 30,

1998, and most

- recently amended on April 21, 2011

. The amendment re

- adopts the current

MACT standard, eliminates the SSM exemption, and requires an electronic submittal of

performance test data to improve efficiency. These revisions cause no substantial changes in

costs to industry. These regulations apply to both existing and new facilities in: publication

rotogravure, product and packaging rotogravure, and wid e

- web flexographic printing presses at

major sources, existing or commencing construction or reconstruction after the effective date of

this subpart. These standards also apply to owners or operators who choose to commit to and

meet the criteria of establi shing the facility to be an area source of hazardous air pollutants

(HAP). New facilities include those that commenced construction or reconstruction after the date

of prop osal. This information is being collected to assure compliance with 40 CFR Part 63,

Subpart KK

.

In general, all NESHAP standards require initial notification report s, 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 system is

inoperative. These notifications, reports, and records are essential in determining compliance,

and are required of all affecte d facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these

measurements, and retain the file for at least five 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 are sent directly to the U

. S

. Environmental Protection Agency (EPA) regional office.

All of the printing and publishing facilities in the United States are owned and operated

by the printing and publishing industry (the “Affected Public”). None of the facilities in the

United States are owned by any state, local, tribal or the Federal government entities. They are

all pri vately

- owned, for

- profit businesses. The “ burden ” to the Affected Public may be found

below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Printing and Publishing

Industry (40 CFR Part 63, Subpart KK) (Renewal). T he “ burden ” to the Federal Gov ernment is2

attributed entirely to work performed by either F ederal employees or government contractors and

can be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Printing

and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal ).

Based on our consultations with industry representatives, there is an average of one

affected facilit y 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 years, approximately 352 respondents per year will be subject to

the se standard s , and no addi tional respondents per year will become subject to the se same

standard s

. Of the 352 facilities, 152 are major sources and 200 are area sources

.

The Office of Management and Budget ( OMB ) approved the currently active Information

Collection Request ( ICR ) without any “ Terms of Clearance ”

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish

standards of performance for each category or subcategory of major sources and area sources of

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous

air pollutants and shall require t he maximum degree of emission reduction. In addition, section

114(a) states that the Administrator may require any owner/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

accordance 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 Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from printing and publishing industry

either cause or contribute to air pollution that may reasonably be anticipated to endanger public

heal th and/ or welfare. Therefore, the NESHAP were promulgated for this source category at 40

CFR Part 63, Subpart KK

.3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the se standard s ensure 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 determine an affected fa cility ’ s initial

capability to comply with the emission standard s . Continuous emission monitors are used to

ensure compliance with the se standard s at all times. During the performance test a record of

the operating parameters under which compliance was achieved may be recorded and used to

determine compliance in place of a continuous emission monitor.

The notifications required in the se standard s are used to inform the Agency or delegated

authority when a source becomes subject to the requirements of th e regulations. The reviewing

authority may then inspect the source to check if the pollution control devices are properly

installed and operated

, leaks are being detected and repaired

, and that the standard s are being

met. The performance test may also be observed.

The required semiannual reports are used 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 an d reporting are required under 40 CFR Part 63, Subpart

KK

.

3(a) Non

- duplication

If the subject standards have not been delegated, the information is sent directly to the

appropriate EPA regional office. Otherwise, the information is sent directly to either the

delegated state or local agency. If a state or local agency has adopted its own similar standards

to implement the Federal standards, a copy of the report submitted to the state or local agency

ca n 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 comment period for the renewal of this I CR was published

in the Federal Register (80 FR 32116 ) on June 5, 2015

. No comments were received on the

burden published in the Federal Register

.4

3(c) Consultations

The Agency has consulted i ndustry experts and internal data sources to project the

number of affected facilities and industry growth over the next three years. The primary source

of information as reported by industry, in compliance with the recordkeeping and reporting

provisions in the se standard s , is the Integrated Compliance Informati on System (ICIS). ICIS is

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. The growth rate for the industry is based on our consultations

with the Agency’s internal industry ex perts.

Industry trade associations and other interested parties were provided an opportunity

to comment on the burden associated with the se standard s as they were being developed. In

developing this ICR, we contacted both the Flexographic Technical Association

, at ( 631 ) 737

-

6020 ; and the Flexible Packaging Association (FPA)

, at (410) 694

- 0823

.

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 Collection

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

- frequently, the proper op eration and maintenance of control equipment and the

possibility of detecting violations would be less likely.

3(e) General Guidelines

T hese reporting or recordkeeping requirements do not violate any of the regulations

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and

notifications for at least five years. This is consistent with the General Provisions as applied to

the standards. EPA believes that the five

- year records retention requirement is consistent with the

Part 70 permit program and the five

- year statute of limitations on which the permit program is

based. T he retention of records for five years allow s EPA to establish the compliance history of a

sour ce

, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has found that the most flagrant violators have violations extending beyond five

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or

nonexistence of essential records

.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, par t 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

T he reporting or recordkeeping requirements in the standard do not include sensitive

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are the printing and

publishing industry

. The United States Standard Industrial Classification ( SIC ) code s for the

respondents affected by the standard and the corresponding North American Industry

Classification System (NAICS ) code s are listed in the table below :

40 CFR Part 63, Subpart, KK SIC Codes NAICS Codes

Textile Bag Mills 2392, 2393, 3069 314911

Setup Paperboard Box Manufacturing 2652 322213

Corrugated and Solid Fiber Box Manufacturing 2653, 2679 322211

Non

- folding Sanitary Food Container

Manufacturing 2656 322215

Folding Paperboard Box Manufacturing 2657 322212

Coated and Laminated Packaging Paper and

Plastics film Manufacturing 2671 322221

Plastics, Foil, and Coated Paper Bag

Manufacturing 2673 322223

Plastics Bag Manufacturing 2673 326111

Uncoated Paper and Multiwall Bag

Manufacturing 2674 322224

Sanitary Paper Product Manufacturing 2676, 3842 322291

All Other Converted Paper Product

Manufacturing 2675, 2679 322299

Corrugated and Solid Fiber Box Manufacturing 2653 3222116

Die

- Cut Paper and Paperboard Office Supplies

Manufacturing 2675, 2679 322231

Coated and Laminated Paper Manufacturing 2672, 2679 322222

Periodical Publishers 2721, 2741 511120

All Other Publishers (except newspaper,

magazine, books, directory, database, music, and

greeting card publishers) 2741 511199

Commercial Gravure Printing 2754, 2771 323111

Commercial Flexographic Printing 2759, 2771 323112

Other Commercial printing 2759, 2771 323119

All Other Plastics Product Manufacturing 3089, 3999 326199

Laminated Aluminum Foil Manufacturing for

Flexible Packaging Uses 3497 322225

Resilient Floor Covering Manufacturing 3069, 3996 326192

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required by the NESHAP for

Printing and Publishing Industry (40 CFR Part 63, Subpart KK)

.

A source must make the following reports:

Notification s /Reports

Initial notification 63.5(d), 63.9(b),

63.10(f),

63.830(b) (1)

Notification of change in information already provided 63.9(j)

Notification of compliance status 63.9(h), 63.830(b) (3)

Notification of initial performance test 63.7(b) (1) , 63.9(e),

(g), 63.830(b) (2)

Rescheduled initial performance test 63.7(b)(2)

Initial performance test results 63.10(d

- e),

63.830(b) (4),

63.830(c)

Semi

- annual summary report 63.10(e),

63.830(b) (6)7

Notification s /Reports

Excess emission and continuous monitoring system (CMS)

performance reports 63.10(a), (e),

63.830(b)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, and malfunctions periods where the continuous

monitoring system is inoperative. 63.10(b)(2),

63.829( g )

Emission test results and other data needed to determine emissions,

operating parameters, etc. 63.824(b) 63.825(b

g), 63.828(a),

63.829(b

- f)

All reports and notifications 63.10(b)

Record of applicability 63.10(b)(3)

Records for sources with continuous monitoring systems 63.10(c), 63.829 (b)

Records of HAP usage for area sources 63.829(d)

Record of maintenance 63.10(b)(2),

63.829(b)

Electronic Reporting

Some of the r espondents 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 recordkeeping at

a plant site.

Owners and operators of printing and publishing facilities are required to submit

electronic copies of applicable rep orts of performance tests to EPA’s WebFIRE database through

an electronic emissions test report structure called the Electronic ERT.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid

supply pressure for control device.8

Respondent Activities

Perform initial performance test, Reference Method 311 test, and repeat performance tests if

necessary.

Write the notificati ons and reports listed.

Enter information required to be recorded.

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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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

Review notifications and reports, including performance test reports, and excess emissions

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO)

and ICIS.

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 p roperly installed and operated.9

Performance test reports are used by the Agency to discern a source ’ s initial capability to

comp ly with the emission standard, and n ote 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. The semiannual reports are used for problem

identification, as a ch eck on source operation and maintenance, and for compliance

determinations.

Information contained in the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. EPA uses ICIS for tracking air pollution compliance and

enforcement by local and state regulatory agencies, EPA regional office s and EPA headquarters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

A majority of the res pondents are large entities (i.e., large businesses). However, the

impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Due to technical considerations involving the process operations

and the types of control equipment employed, the recordkeeping and reporting requirements are

the same for both small and large entities. The Agency considers these to be the minimum

requirements needed to ensure compliance and, therefore, cannot reduce them further for small

entities. To the extent that larger businesses can use economies of scale to reduce their burden,

the overall burden will be reduced

.

5(d) Collection Schedule

The specific frequency for each information collection activity within this r equest is

shown b elow in Table 1: Annual Respondent Burden and Cost

– NESHAP for Printing and

Publishing Industry (40 CFR Part 63, Subpart KK) (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 ICR. The

individual burdens are expressed under standardized headings believed to be consistent with the

concept of burden under the Paperw ork Reduction Act. Where 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 inf ormation unless it displays a currently valid OMB Control Number.10

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 59,800 hours ( Total Labor Hours from Table 1).

T hese hours are based on Agency studies and background documen ts from the development of

the se regulation s , Agency knowledge and experience with the NESHAP program, the

previously

- approved ICR, and any comments received.

6(b) Es timating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June

2014

, “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from

column 1, “ Total compensation. ” The rates have been increased by 110 perc ent to account for

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the

subject s tandard s are both labor costs which are addressed elsewhere in this ICR and the costs

associated with continuous monitoring. The capital/startup costs are one

- time costs when a

facility becomes subject to the regulation s

. The annual operation and maintenance costs are the

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous

Monitoring

Device (B)

Capital/Startup

Cost for One

Respondent (C)

Number of

New

Respondents (D)

Total

Capital/Startup

Cost, (B X C) (E)

Annual O&M

Costs for One

Respondent (F)

Number of

Respondents

with O&M (G)

Total O&M,

(E X F)

Temperature $7,000 0 $0 $9,000 46 $414,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. This ICR

assumes that 30 percent of respondents (major source), or 46 sources will be required to maintain, adjust, and

calibrate CMS.

The total capital/startup costs for this ICR are $ 0

. This is the total o f column D in the11

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 414,000

. This is the

total of column G.

The average annual cost for capital/startup and operation and maintenance costs to

industry over the next three years of the ICR is estimated to be $ 414,000

.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported

information. EPA's overall compliance and enforcement program i ncludes activities such as

the examination of records maint a ined 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

$ 19,100

.

This cost is based on the average hourly labor rate as follows:

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

These rates are from the Office of Personnel Management (OPM)

, 20 1 5 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 EP A Burden and Cost

– NESHAP for Printing

and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

352 existing respondents will be subject to the se standard s

. It is estimated that no additional

respondents per year will become subject to these same standards

. The ov erall average number

of responden ts, as shown in the table below, is 352 per year.

The number of respondents is calculated using the following table that addresses the three

years covered by this ICR :

Number of Respondents

Respondents That Do12

Number of Respondents

Respondents That Submit Reports Not Submit Any Reports

Year (A)

Number of New

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 (E)

Number of

Respondents

(E=A+B+C

- D)

1 0 152 200 0 352

2 0 152 200 0 352

3 0 152 200 0 352

Average 352

1 New respondents include sources with constructed, reconstructed and modified affected facilities.

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the

average Number of Respondents over the three year period of this ICR is 352

.

The total number of annual responses per year 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 initial and HAP

usage 0 1 0 0

Notification of compliance status 0 1 0 0

Notification of performance test 0 1 0 0

Report of performance test 0 1 0 0

Startup/shutdown/malfunction

report 30 2 0 60

Semiannual excess emission and

CMS performance report 76 2 0 152

Records of HAP usage (area source) 200 2 0 400

Total 612

The number of Total Annual Responses is 612

.

The total annual labor costs are $6,010,000

. Details regarding these estimates may be13

found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Printing and

Publishing Industry (40 CFR Part 63, Subpart KK) (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, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 59,800

. Details regarding these estimates may be found

below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Printing and Publishing

Industry (40 CFR Part 63, Subpart KK) (Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical b urdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of

information is estimated to average 98 hours per response

.

The total annual capital/startup and O&M costs to the regulated entity are $414,000

. 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 419

labor hours at a cost of $19,100

. See below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in labor hour burden in this ICR from the most recently

approved ICR. This is not due to program changes. The increase occurred because this ICR

assumes all existing sources will have to re

- familiarize with the regulatory requirements each

year when calculating responde nt labor hours and costs

. 6(g) Burden Statement14

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 98 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 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; 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 i nformation 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 this 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 ICR under

Docket ID Number EPA

- HQ

- OECA

- 201 2

- 0666

. 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

Com pliance 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 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 docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 1 7th Street, NW,

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OECA

- 2012

- 0666 and OMB Control Number 2060

- 0 335 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this

information.15

Table 1: Annual Respondent Burden and Cost

– NESHAP for Printing and Publishing Ind ustry (40 CFR Part 63, Subpart KK)

(Renewal)

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

hours per

occurrence No. of

occurrences

per

respondent

per year Person

hours per

respondent

per year Respondents

per year a Technical

person

hours per

year Management

person hours

per year Clerical

person

hours per

year Total Cost Per

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

a. Familiarization with the regulatory

requirements c 4 1 4 352 1,408 70.4 140.8 $162,828.86

b. Required activities

Initial performance test d 240 1 240 0 0 0 0 $0

Repeat performance tests d 240 1 240 0 0 0 0 $0

Install CMS d 100 1 100 0 0 0 0 $0

Develop CMS/QC program and test plan d 100 1 100 0 0 0 0 $0

Conduct CMS performance evaluation d 300 1 300 0 0 0 0 $0

Maintain, adjust, and calibrate CMS e 6 52 312 46 14,352 717.6 1,435.2 $1,659,744.22

c. Create information See 3B

d. Gather existing information See 3E

e. Write report

New Sources

Notification of initial and HAP usage d 4 1 4 0 0 0 0 $0

Notification of compliance status d 4 1 4 0 0 0 0 $0

Notification of performance test d 2 1 2 0 0 0 0 $0

Report of performance test d 40 1 40 0 0 0 0 $016

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

hours per

occurrence No. of

occurrences

per

respondent

per year Person

hours per

respondent

per year Respondents

per year a Technical

person

hours per

year Management

person hours

per year Clerical

person

hours per

year Total Cost Per

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Existing Sources

Startup, shutdown, malfunction report f 2 2 4 30 120 6 12 $13,877.46

Semiannual excess emission and CMS

performance report g 16 2 32 76 2,432 121.6 243.2 $281,249.86

Subtotal for Reporting Requirements 21,059 $2,117,700.40

4 Recordkeeping requirements

a. Familiarization with the regulatory

requirements See 3A

b. Plan activities N/A

c. Implement activities N/A

d. Develop record system d 40 1 40 0 0 0 0 $0

e. Time to enter information

Records of maintenance h 4 52 208 105 21,840 1,092 2,184 $2,525,697.72

Records of startup, shutdown, and

malfunction i 2 52 104 30 3,120 156 312 $360,813.96

Records of malfunction or inoperative

CMS i 2 2 4 30 120 6 12 $13,877.46

Records of applicability determination d 2 1 2 0 0 0 0 $0

Records of CMS operation j 2 52 104 46 4,784 239.2 478.4 $553,248.07

Records of liquid

- liquid material balances;

HAP, volatile material, solids and materials

applied, operating parameters k 2 12 24 105 2,520 126 252 $291,426.66

Records of materials used by incidental

printers l 40 1 40 2 80 4 8 $9,251.6417

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

hours per

occurrence No. of

occurrences

per

respondent

per year Person

hours per

respondent

per year Respondents

per year a Technical

person

hours per

year Management

person hours

per year Clerical

person

hours per

year Total Cost Per

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Records of HAP usage (area sources) m & n 0.5 12 6 200 1,200 60 120 $138,774.60

f. Time to train personnel See 3A

g. Time for audits N/A

Subtotal for Recordkeeping Requirements 38,714 $3,893,090.11

TOTAL LABOR BURDEN AND COST

(rounded) o 59,800 $6,010,000

Capital and O&M Cost (see Section 6(b)(iii)): o $414,000

TOTAL COST: o $6,420,000

Assumptions:

a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area

sources. There will be no additional new sources over the three

- year period of this ICR.

b This ICR uses the following labor rates: $129.93 ($61.87+ 110%) per hour for Executive, Administrative, and Managerial labor;$1 03.97 ($49.51 + 110%)

per hour for Technical labor, and $51.79 ($24.66 + 110%)

per hour for Clerical labor. These rates are fro m the United States Department of Labor, Bureau of Labor Statistics, June 2014, Table 2. Civilian Workers, by

occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 perc ent to account for th e benefit

packages available to those employed by private industry.

c We have assumed that two existing facilities will need to read and review instructions.

d We have assumed that there will be no new sources during the three

- year period of this ICR.

e We have assumed that 30 percent of respondents (major source) will be required to maintain, adjust, and calibrate CMS.

f We have assumed that 20 percent of the respondents (major source) will have startup, shutdown, malfunction incidents with equ ipme nt or inoperative CMS

reports to complete.

g We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emi ssions.

h We have assumed that these facilities do not have CMS installed in them.18

i We have assumed that 20 percent of respondents will enter information on startup, shutdown, malfunction problems with equipme nt or inoperative CMS.

j We have assumed that 46 respondents (major source) will enter information on CMS operations.

k We have assumed that these facilities do not have CMS installed in them.

l We have assumed that 2 existing facilities will be required to enter information on records of materials used by incidental p rinters.

m We have assumed that 200 area sources, whic h includes products and packaging rotogravure and wide

- web flexographic printing presses, are subject to

recordkeeping requirements, and are required to keep a monthly record of HAP usage to show that they are meeting the limit.

n We have assumed that it will take each respondent 0.5 hours to record HAP usage.

o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.19

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Printing and Publishing Industry (40 CFR Part 63, Subpart

KK) (Renewal)

Activity (A) (B) (C) (D) (E) (F) (G) (H)

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA

person

hours per

plant per

year Plants per

year a Technical

person

hours per

year Management

person

hours per

year Clerical

person

hours per

year Cost, $ b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Required activities

New sources

Initial performance tests c 24 1 24 0 0 0 0 $0

Repeat performance tests c 24 1 24 0 0 0 0 $0

Report review

New sources

Notification of initial startup c 2 1 2 0 0 0 0 $0

Notification of compliance status c 4 1 4 0 0 0 0 $0

Notification of performance test c 1 1 1 0 0 0 0 $0

Review test results c 8 1 8 0 0 0 0 $0

Existing sources

Semiannual excess emissions and CMS

performance report d 2 2 4 76 304 15.2 30.4 $15,911.36

Periodic startup, shutdown, malfunction

report e 2 1 2 30 60 3 6 $3,140.40

TOTAL ANNUAL BURDEN AND COST

(rounded) f 419 $19,10020

Assumptions:

a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area

sources. There will be no additional new sources over the three

- year period of this ICR.

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90

Managerial rate, $46.67 Technical rate, and $25.25 Clerical rate. These rates are from the Office of Pe rsonnel Management (OPM) 2015 General Schedule,

which excludes locality rates of pay.

c We have assumed that there will be no new sources during the three

- year period of this ICR.

d We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions.

e We have assumed that 20 percent of sources will be required to submit periodic startup, shutdown, malfunction report.

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.