**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 I CR Number 1739.07 , OMB Control Number 2060

- 0335

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (N ESHAP) for Printing and Publishing Industry ( 40 CFR subpart KK) were proposed on March 14, 1995 (60 FR 13664), promulgated on May

30, 1996 (61 FR 27131), and amended on May 24, 2006 (71 FR 29792). These regulations apply

to both existing and new facilities in: publication rotogravure, product and packaging rotogravure, and wide

- web flexographic printing presses at major sources, existing or commencing construction or reconstruction after the effective date of this subpart. Th e s e standard s also ap pl y to owners or operators who choose to commit to and meet the criteria of establishing the facility to be an area source of hazardous air pollutants (HAP). New facilities include those that comme nced 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 notifications, performance tests, and periodic reports b y the owners/operators of the affected facili ties. They are also required to maintain records of the occurrence and duration of an y 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 NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the fil e 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 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 facilities at each plant site and 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 352 respondents per ye ar will be subject to the standard s , and no additional re spondents per year will become subject to the standard. Of the 352 facilities, 152 are major sources and 200 are area sources that are currently subject to the standard s
. The Office of Management and Budget ( OMB ) approved the currentl y active I CR2

without any “ Terms of Clearance ”

. All the printing and publishing facilities in the United States are owned and operated b y the printing and publishing industry (the “Affected Public”). None of the facilities in the United States are owned by an y stat e, local, tribal or the Federal government entities . They are all privately owned , for

- profit businesses. The burden to the “Affected Public” may be found b elow 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 Government is attributed entirel y to work performed b y either F ederal emplo ye es or government contractor s and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for P rinting and Publishing Industry

(40 CFR Part 63, Subpart KK) (Renewal).
**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 the maximum degree of emission reduction. Inaddition, 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 co ntrol 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 Administrat or may reasonabl y require. In the Administrator's judgment, HAP emissions from the printing and publishing industry cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were p romulgated for this source category at 40 CFR part 63, subpart KK

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements i n the standard ensure compliance with the applicable regulations which where promulgated in acc ordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.3

Performance tests are required in order to determine an affected facility ’ s initial capability to comp ly

with the emiss ion standard . Continuous emission monitors are used to ensure compliance with the standard 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 notificat ions 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 a uthority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired , and the standard is 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 and repor ting 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 directl y to the appropriate EPA regional office. Otherwise, the information is se nt 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 submitted to the state or local agency can be sent to the Administrator in li eu of the report required b y the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announceme nt of a public comment period for the renewal of this I CR was published in the Federal R egister ( 77 FR 63813 ) on October 17, 2012

. No comments were received on the burden published in the Federal Register

. **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 standard, is the Online Tracking Information Sy stem (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA ’ s database for the collection,4

maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s i nternal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as it was being developed and the standard s has previously been reviewed to determine the minimum information needed for compliance purposes. Ind eveloping this ICR, we contacted: 1) the Printing Industries of America , at (434) 591

- 0527 ; and 2) the Flexible Packaging Association (FPA) , at (410) 694

- 0823. EPA received comments from the FPA, a national trade association representing manufacturers and suppliers of flexible packaging for food, healthcare and industrial products using paper, plastics, films, and foil or an y combination of these materials. FPA indicated that most, if not all, FP A members comply with this NESHAP by

utilizing compliant coatings. Therefore, the primary

burden for these member companies are the costs associated with data sy stems management, recordkeeping, and reporting, rather than costs associated with conducting pe rformance tests and maintaining continuous monitoring s ys tems. FPA also expressed that many member companies who were “major source s ” are now emitting at levels of an area source due to material substitution. It is our policy

to respond after a thorough review of comments received since the last I CR renewal as well as those submitted in response to the f irst Federal Register n otice. **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 frequentl y, the proper operation 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 b y 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 y ears. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar 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 source , an y 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 ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

.5

**3(f) Confidentiality** Any informati on 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, Sep tember 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 ( SI C ) code for the r espondents affected b y the standards , which corresponds to the North American Industry Classification Sy stem (NAI CS ) codes, listed below.

**Standard (40 CFR**  **Pa rt 63**  **, S**  **ubpart 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 322211 Die

- Cut Paper and Paperboard Office Supplies Manufacturing 2675, 2679 3222316

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** 
In 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) (Renewal). A source must make the following reports:

**Notification s**  **/ Reports** Initial notification 63.5(d), 63.9(b), 63.10(f), 63.830(b) Notification of change 63.821(a)(6), 63.820(a)(2) Notification of compliance status 63.9(h), 63.830(b) Initial performance test and evaluation 63.7(b), 63.9(e), (g), (j), 63.830(b) Rescheduled initial performance test 63.7(b)(2) Initial performance test results 63.6(g), 63.10(d

- e), 63.830(b) Opacit y or visible emissions 63.10(d)(3) Periodic startup, shutdown, malfunction reports 63 .6(e), 63.10(a), (d), 63.830(b) Summary report 63.10(e), 63.830(b) Excess emission and continuous monitoring sy stem (CMS) performance reports 63.10(a), (e), 63.830(b)

A source must keep the following records:7 **Recordkeeping** Startups, shutdowns, and malfunctions periods where the continuous monitoring sy stem is inoperative. 63.10(b)(2), 63.829(b) 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 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 monitori ng and recordkeeping at a plant site. Also, regulatory

agencies in c ooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 2 0 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS 63.824(b), 63.825(c)(d), 63.828(a), 63.8(c). Perform initial performance test, Reference Method 311 test, and repeat performance tests if necessary . Conduct CMS performance evaluation. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the r equired reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and m aintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y previously applicable instructions and8 **Respondent Activities** requirements. 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, analy sis, 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 Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution contr ol devices are pr operl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y with the emission standard. 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 check on source operation and maintenance, and for compliance determinations.
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 facilities. EPA uses the OTI S for tracking air poll ution compliance and9

enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. Both EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be re tained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents 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 ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency consider s 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 overa ll burden will be reduced. **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

– 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are ma ndatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry ove r the next three y ears from these recordkeeping and reporting requirement s is estimated to be 58,162 ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved ICR, and an y comments received.10

**6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ 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 employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**
T he ty pe of industry

costs associated with the information collection activ ities in the subject standard 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. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs su ch as photocop ying and postage.

**(iii) Capital/Startup vs. Operation and Maintenanc e (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)

Tem perature $7,000 0 $0 $9,000 46 $414,000 Note: 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 I CR are zero . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR 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 IC R is estimated to be $ 414,000

. These are recordkeeping costs.11

**6(c) Estimating Agency Burden and Cost**  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 i ncludes such activities as the examination of records maintained by the respondents, the periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three y ears of the ICR is estimated to be $18,864

. This cost is based on the average hourl y labor rat e 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 2 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 employ ees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA 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 I CR, on average over the next three ye ars, approximately 352 existing respondents will be subject to the standard. Of the 352 respondents, 152 are major sources and 200 are area sources. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as sho wn in the table below, is 352 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.12 **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 (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 respondent 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 ye ar period of this ICR is 352. 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 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 $5,631,789

. 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)

.13

**6(e) Bottom L ine 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 58,162 hours at a cost of $5,631,789

. 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)

. Furthermore, the annual pub lic reporting and recordkeeping burden for this collection of information is estimated to average 95 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 y ears is estimated to be 419 labor hours at a cost of $18,864 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal). **6(f) Reasons for Change in Burden** There is a small decrease in the respondent labor hours from the most recently approved ICR due to an adjustment . T he previous ICR calculated the burden assuming a percentage of the respondent universe are subject to specific burden activities; in some cases, the calculations included non

- integer number of respondents. This I CR uses whole (rounded) values for the numb er of respondents, which results in an overall decrease in labor hours. There is also a decrease in the Agency

burden costs due to a mathematical correction for the review of startup, shutdown, and malfunction reports in the previous I CR. There is also an adjustment increase in the respondent labor costs. This increase is not due to an y program changes; rather, the increase was due to an adjustment in labor rates. This ICR uses updated labor rates to estimate all burden costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 95 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 ut ilize technology and s ys tems for the purposes of collecting, validating, and14

verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instruct ions 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 display s 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

- 2012

- 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 th e docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , 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), EPA 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 Frid ay , excluding legal holiday s. 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 Manage ment and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 12

- 0666 and OMB Control Number 2060

- 0335 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 Industry (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. Read instructions c 4 1 4 2 8 0.4 0.8 $890.82 b. Required activities I nitial 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 $1,598,138.26
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 $0 **Existing Sources** Startup, shutdown, malfunction report f 2 2 4 30 120 6 12 $13,362.36 Semiannual excess emission and CMS performance report g 16 2 32 76 2,432 121.6 243.2 $270,810.50 **Subtotal for Reporting Requirements 19,448.8**  **$1,883,201.94**16

4 Recordkeeping requirements a. Read instructions 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 $2,431,949. 2 Records of startup, shutdown, and malfunction i 2 52 104 30 3,120 156 312 $347,421.36 Records of malfunction or inoperative CMS i 2 2 4 30 120 6 12 $13,362.36 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 $532,712.75 Records of liquid

- liquid material balances; HAP, volatile material, solids and materials applied, operating parameters k 2 12 24 105 2,520 126 252 $280,609.56 Records o f materials used by incidental printers l 40 1 40 2 80 4 8 $8,908.24 Records of HAP usage (area sources) m & n 0.5 12 6 200 1,200 60 120 $133,623.60 f. Time to train personnel See 3A g. Time for audits N/A **Subtotal for Recordkeeping Requirements 38,713.6**  **$3,748,587.39 TOTAL**  **LABOR BURDEN AND COST (rounded) 58,162**  **$5,631,789**
**Assu mptions:**  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 T his ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per ho ur for Technical labor, and $50.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, 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.
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 respondent s (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 ipment or inoperative CMS reports to complete. g We h ave assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissio ns.17

h We have assumed that these facilities do not have CMS installed in them. i We have assumed that 20 percent of respondents w ill enter information on startup, shutdown, malfunction problems with equipment 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 ins talled 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, which includes products and packaging rotogravure and wide

- we b 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.18

**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 Total** 

**Cost per**  **year $**  **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 $15,754.65 Periodic startup, shutdown, malfunction report e 2 1 2 30 60 3 6 $3,109.47 **TOTAL ANNUAL BURDEN AND COST (rounded) 419**  **$18,864**
**Assu mptions:**  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 w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate, $46.21 Technical rate, and $25.01 Clerical rate. These rates are from the Office of Personnel Management (OPM) 20 12 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, an d 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.