SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
part
63,
subpart
KK)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
part
63,
subpart
KK)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
Printing
and
Publishing
Industry
were
proposed
on
March
14,
1995
(
60
FR
13664),
and
promulgated
on
May
30,
1996
(
61
FR
27131).
These
standards
apply
to
the
following
facilities
in
40
CFR
subpart
KK:
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.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
KK.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
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.
Monitoring
requirements
specific
to
the
NESHAP
for
the
Printing
and
Publishing
Industry
in
subpart
KK,
provide
information
on
the
operation
of
the
emissions
control
device
and
compliance
with
the
(
opacity)
standard.
Semiannual
reports
of
excess
emissions
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required,
in
general,
of
all
sources
subject
to
NESHAP.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
measurements,
maintenance
reports,
and
records.

Approximately
350
major
sources
comprised
of
150
major
sources
and
200
area
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
two
sources
per
year
will
become
subject
to
the
standard
over
the
next
three
years.
The
cost
of
this
Information
Collection
Request
(
ICR)
will
be
$
3,553,424
(
rounded).

The
Office
of
Management
and
Budget
(
OMB)
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."
2
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.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
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,
Hazardous
Air
Pollutants
(
HAP)
emissions
from
printing
and
publishing
industry
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
KK.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
printing
and
publishing
industry
are
the
result
of
operation
of
the
publication
rotogravure,
product
and
packing
rotogravure,
and
wide­
web
flexographic
printing
presses.
For
the
businesses
that
do
not
use
materials
substitution
as
a
means
of
complying,
the
control
of
emissions
of
HAP
from
the
printing
and
publishing
industry
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
These
standards
rely
on
the
capture
and
reduction
of
HAP
emissions
by
control
devices
like
oxidizers
and
solvent
recovery
systems
or
by
material
substitution.
Facilities
may
use
continuous
emissions
monitoring
or
other
measurement
tests.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
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
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
3
Agency's
records
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Operating
conditions
may
include
combustion
zone
temperature,
catalytic
bed
inlet
temperature,
and
volumetric
gas
flow.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
continuous
compliance
with
the
regulation.

Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
(
40
CFR
Part
63,
Subpart
KK.

3(
a)
Nonduplication
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
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
September
26,
2002.
We
received
comments
via
e­
mail
dated
August
20,
2003,
from
Bill
Juris
of
Ohio
EPA­
DAPC,
phone
number
(
614)
644­
3593,
with
reference
to
area
sources,
whether
or
not
area
sources
have
been
properly
accounted
for
in
the
industrial
recordkeeping
and
reporting
burden.

We
have
included
area
sources
and
has
properly
accounted
for
the
Burden
in
this
ICR.

3(
c)
Consultations
For
this
information
collection,
we
used
several
different
resources
to
obtain
the
most
recent
data
available
for
printing
and
publishing
industry
sources.
We
referenced
the
most
recent
ICR,
and
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Printing
Industry,"
and
the
Sector
Notebook
Data
Refresh
­
1997.
We
also
accessed
the
4
most
recent
data
(
June
11,
2003)
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
In
addition,
we
contacted
a
number
of
Trade
Associations,
they
are
as
follow:
1)
Graphic
Arts
Technical
Foundation,
contact
person,
Mr.
Gary
Jones
at
(
412)
741­
6860;
2)
Printing
Industries
of
America,
contact
person,
Mr.
Ron
Davis
at
(
703)
519­
8102;
3)
A
F
Lewis
Data
Base,
contact
person,
Mr.
Carl
Sartori
at
(
646)
746­
7429;
4)
Flexographic
Packaging
Association,
contact
person,
Mr.
Ram
Singh­
Hal
at
(
410)
694­
0823;
5)
Gravure
Association
of
America,
contact
person,
Mr.
Dick
Dunnington
at
(
585)
436­
2150,
and
6)
Flexographic
Technical
Association,
contact
person,
Ms.
Doreen
Monteleone
at
(
631)
737­
6020.

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
is
useful
technique
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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
However,
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
(
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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
5
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
and
operators
of
publication
rotogravure,
product
and
packaging
rotogravure,
and
wide­
web
flexographic
printing
presses
subject
to
NESHAP
Subpart
KK
facilities.
The
SIC
(
United
States
Standard
Industrial
Classification)
codes
which
corresponds
to
the
NAICS
(
The
North
America
Industry
Classification
System)
codes
could
be
found
in
the
following
table.

Standard
SIC
Codes
NAICS
Codes
List
each
Standard
(
e.
g.,
40
CFR
Part
63,
Subpart
KK)
2392
314911
2652
322213
2653
322211
2656
322215
2657
322212
2671
322221
2673
322223
&
326111
2674
322224
2676
322291
2679
322299,
322211,
322231,
&
322222
2721
511120
2741
511199
2754
323111
2759
323112
&
323119
2771
323112,
323111,
&
323119
3089
326199
3497
322225
3996
326192
4(
b)
Information
Requested
6
These
standards
require
affected
facilities
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
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
National
Emission
Standards
for
Hazardous
Air
pollutants
for
Printing
and
Publishing
Industry
(
40
CFR
Part
63,
Subpart
KK).

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
63,
Subpart
KK
Initial
notification
63.830(
b),
63.5(
d),
63.9(
b),
63.10(
f)

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
63.830(
b),
63.7(
b),
63.9(
e),
(
g),
(
j)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Initial
performance
test
results
63.830(
b),
63.6(
g),
63.10(
d),
(
e)

Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
startup,
shutdown,
malfunction
reports
63.830(
b),
63.6(
e),
63.10(
a),
(
d)

Summary
report
63.830(
b),
63.10(
e)

Excess
emission
and
continuous
monitoring
system
(
CMS)
performance
reports
63.830(
b),
63.10(
a),
(
e)
7
A
source
must
keep
the
following
records:

Recordkeeping
for
40
CFR
Part
63,
Subpart
KK
Startups,
shutdowns,
malfunctions
periods
where
the
continuous
monitoring
system
is
inoperative.
63.829(
b),
63.10(
b)(
2)

Emission
test
results
and
other
data
needed
to
determine
emissions,
operating
parameters,
etc.
63.824(
b)
63.825(
b),
(
c),
(
d),
(
e),
(
f),
(
g)
63.828(
a),
63.829(
b),
(
c),
(
d),
(
e),
(
f)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

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

Records
of
HAP
usage
for
area
sources
63.829(
d)

Record
of
maintenance
63.829(
b),
63.10(
b)(
2)

Electronic
Reporting
Some
State
Regulatory
Agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
Agencies.
The
estimated
amount
of
electronic
reporting
is
20%.

(
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.
Respondent
Activities
8
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.

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
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,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
9
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.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
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
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
There
is
a
distribution
of
business
sizes.
The
standard
applies
to
owners
and
operators
of
publication
rotogravure,
product
and
packaging
rotogravure,
and
wide­
web
flexographic
presses
located
at
both
major
and
area
sources.
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
requirements
the
minimum
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
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
Part
63,
Subpart
KK).

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
the
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
10
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
requirements
is
estimated
to
be
50,796
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
Technical
Labor
Rate
of
$
61.66
per
hour,
and
5%
of
$
89.94
per
hour
for
Managerial
labor;
also,
10%
of
$
38.39
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standards
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
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
1
One
new
major
source
per
year
11
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
1
(
D)
Total
Capital/
Startu
p
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
1
$
7,000
$
9,000
45
$
405,000
The
total
capital/
startup
cost
for
this
ICR
is
$
7,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
405,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
412,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

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
includes
activities
such
as
the
examination
of
records
maintained
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
$
15,046.
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
1.6
benefits
multiplication
factors
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
Part
63,
Subpart
KK).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
12
Approximately
350
sources
comprised
of
150
major
sources
and
200
area
sources
that
are
currently
subject
to
the
regulation.
It
is
estimated
that
two
additional
sources
per
year
will
become
subject
to
the
regulation
over
the
next
three
years.

Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
40
CFR
Part
63,
Subpart
KK
2
4
150
2
200
508
The
number
of
total
respondents
is
352.
This
number
is
the
sum
of
column
A,
column
C,
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period
(
i.
e.,
the
total
of
the
number
of
new
respondents
over
the
three­
year
period
divided
by
three
years).
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
is
508.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table
above.
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
3,553,424.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
the
Printing
and
Publishing
Industry,
(
40
CFR
Part
63,
Subpart
KK).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
412,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
100
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
13
There
is
a
decrease
of
1,699
hours
in
the
total
estimated
burden
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.

Even
though
there
is
a
decrease
of
hours
in
the
total
estimated
burden
from
the
most
recently
approved
ICR,
there
was
a
slight
increase
in
the
number
of
new
or
modified
sources,
and
an
additional
burden
of
area
sources
of
HAP
usage
recordkeeping
which
was
omitted
from
the
previous
ICRs,
for
which
we
have
accounted
for
in
the
renewal
ICR.
There
is
also
an
increase
in
the
annual
labor
costs,
which
were
due
to
the
use
of
revised
updated
hourly
rates
from
the
United
States
Department
of
Labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
100
hours
per
response.
Burdens
means
the
total
time,
effort,
or
financial
resources
expended
by
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
a
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0049,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
to
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0049
and
OMB
Control
Number
2060­
0335
in
any
correspondence.

Part
B
of
the
Supporting
Statement
14
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
TABLE
1:
Annual
Industry
Burden
­
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
part
63,
subpart
KK)

Occurrences/
Hours/

Hours
per
Respondent/
Respondent/
Respondents
Hours
Cost/

Occurrence
Year
Year
per
Year
per
Year
Year
a
Reporting/
Recordkeeping
(
A)
(
B)
(
C=
A
x
B)
(
D)
(
E
=
C
x
D)
(
F=
E
x
$
70.00)
___________________________________________________________________________________________________________________________

1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
REQUIREMENTS
New
Sources
b
A.
Read
Instructions
b
4
1
4
3
12
$
840.00
B.
Required
Activities
New
Sources
Initial
performance
test
c
&
d
&
e
240
1
240
1
240
$
16,800.00
Repeat
performance
test
d
&
f
240
1
240
0.33
79.2
$
5,544.00
Install
CMS
g
100
1
100
0.33
33
$
2,310.00
Develop
CMS
QC
program
100
1
100
0.33
33
$
2,310.00
and
test
plan
g
Conduct
CMS
performance
300
1
300
0.33
99
$
6,930.00
evaluation
g
Maintain,
adjust,
and
calibrate
CMS
6
52
312
45
14,040
$
982,800.00
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
New
Sources
Notification
of
initial
and
HAP
e
4
1
4
2
8
$
560.00
usage
Notification
of
compliance
status
e
4
1
4
2
8
$
560.00
Notification
of
performance
test
e
2
1
2
1
2
$
140.00
Report
of
performance
test
e
40
1
40
1
40
$
2,800.00
Existing
Plants
Startup/
shutdown/
malfunction
report
j
2
2
4
30
120
$
8,400.00
Semi­
annual
excess
emission
and
h
16
2
32
75
2,400
$
168,000.00
CMS
performance
report
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
e
40
1
40
1
40
$
2,800.00
E.
Time
to
Enter
Information
Records
of
maintenance
i
4
52
208
105
21,840
$
1,528,800.00
Records
of
startup,
shutdown,
j
2
52
104
30
3,120
$
218,400.00
malfunction
Records
of
malfunctioning
or
j
2
2
4
30
120
$
8,400.00
16
inoperative
CMS
Records
of
applicability
determination
e
2
1
2
1
2
$
140.00
Records
of
CMS
operation
2
52
104
45
4,680
$
327,600.00
Records
of
liquid­
liquid
material
i
2
12
24
105
2,520
$
176,400.00
balances;
HAP,
volatile
material,

solid
and
materials
applies;
operating
parameters
Records
of
materials
used
by
b
40
1
40
4
160
$
11,200.00
incidental
printers
Records
of
HAP
usage
0.5
12
6
200
1,200
$
84,000.00
(
area
sources)
k&
l
F.
Time
to
train
personnel
Included
in
3A
G.
Audits
N/
A
TOTAL
ANNUAL
BURDEN
(
rounded)
50,796
$
3,553,424.

Assumptions:

a.
Costs
are
based
on
the
following:
$
70.00
per
hour
which
was
calculated
from,
1)
technical
hours
@
$
61.66,
2)
management
hours
at
5%
of
$
89.94
and,

3)
clerical
hours
at
10%
of
$
38.39.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."

b.
One
new
facility
and
two
existing
facilities
are
required
to
read,
review
instructions
and
train.

c.
Time
required
to
complete
pretest
conferences
and
surveys;
clean
calibrate,
and
pack
equipment;
conduct
performance
tests,
analyze
samples,
reduce
data,
and
write
reports
included
in
3E.

d.
Time
required
to
compete
performance
test
(
hours):
240
e.
It
is
assumed
that
two
new
facilities
will
complete
an
initial
performance
test,
initial
notification,
develop
record
system,
and
record
applicability
determination
and
one
major
source
per
year
will
conduct
a
performance
test.

f.
Assume
one
of
the
three
new
facilities
during
the
three­
year
period
of
the
ICR
will
need
to
repeat
the
test.

g.
We
assume
that
33%
of
the
facilities
will
install
CMS,
and
that
one
of
the
three
new
facilities,
during
the
three­
year
period
of
the
ICR
will
use
CMS
and
need
to
perform
all
the
initial
work.

h.
We
assume
that
45
facilities
are
fitted
with
CMS
control
with
an
additional
30
facilities
that
may
encounter
excess
emissions.

i.
We
assume
that
these
facilities
do
not
have
CMS
installed
in
them.

j.
Assume
that
20%
of
the
facilities
will
have
startup/
shutdown/
malfunction
incidents
with
equipment
or
inoperative
CMS.

k.
We
have
assumed
that
approximately
200
area
sources
which
includes;
products
and
packaging
rotogravure
and
wide­
web
floxographic
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.

l.
We
have
assumed
that
it
will
take
0.5
hours
to
record
HAP
usage.
17
TABLE
2:
AVERAGE
Annual
EPA
Burden
­
NESHAP
for
the
Printing
and
Publishing
Industry
(
40
CFR
part
63,
subpart
KK)

EPA
hrs/
Occurrences
EPA
hr/
Plants/
EPA
Occurrences
Plant/
Year
Plant/
Year
Year
Hrs/
Year
Burden
Items
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)

______________________________________________________________________________________________

Required
Activities
New
Plant
Initial
performance
tests
a
24
1
24
0
0
Repeat
performance
tests
b
24
0.2
4.8
0
0
Report
Review
New
Plant
Notification
of
initial
startup
c
2
1
2
2
4
Notification
of
compliance
status
d
4
1
4
2
8
Notification
of
performance
test
e
1
1
1
1
1
Review
test
results
f
8
1
8
1
8
Existing
Plants
Semi­
annual
excess
emissions
and
CMS
g
2
2
4
75
300
performance
report
Periodic
startup/
shutdown/
malfunction
h
2
1
2
30
60
report
TOTAL
ANNUAL
HOUR
381
Travel
expenses
(
0
person
x
0
plant/
year
x
0
days/
plant
x
$
75
per
diem)
+
($
350
round
trip/
plant
x
0
plant/
year)
=
$
0/
year
Salary
i
(
1
person
x
381
hr/
year
x
$
39.49/
hrs
)
=
$
15,045.69
TOTAL
ANNUAL
BURDEN
=
$
15,046
(
rounded)
________________________________________________________________________________________________________________________

______________________________________________________________________________________________________________

Assumptions:

a.
Time
required
to
participate
in
the
performance
test
(
hours
per
plant):
24
b.
Rate
of
failed
performance
tests:
20%

c.
Time
required
to
review
initial
startup
test
notification
(
hours):
2
d.
Time
required
to
review
compliance
status
notification
(
hours):
4
e.
Time
required
to
review
performance
test
report
(
hours)
for
one
major
source
per
year:
1
f.
Time
required
to
review
test
results
(
hours)
for
one
major
source
per
year:
8
g.
At
least
50%
of
the
sources
will
have
to
submit
one
semi­
annual
excess
emissions
report.

h.
At
least
20%
of
the
periodic
startup/
shutdown/
malfunction
may
be
submitted
with
the
semi­
annual
report.
18
i.
EPA's
labor
rate
at
a
GS­
12,
Step
1,
times
1.6
government
overhead
expenses:
$
39.49.
