1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
QQ
Graphic
Arts
Industry
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
QQ
­
Graphic
Arts
Industry
Subject
to
New
Source
Performance
Standards
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
QQ
were
proposed
on
October
28,
1980,
and
promulgated
on
November
8,
1982.
These
standards
apply
to
the
following
facilities
in
NSPS
Subpart
QQ,
each
publication
rotogravure
printing
press
(
not
including
proof
presses)
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
QQ.
Owners
or
operators
of
the
affected
facilities
described
have
certain
notification,
reporting,
and
recordkeeping
requirements
under
this
rule.
One
example
of
each
is:
a
one­
time­
only
notification
of
the
date
of
the
anticipated
and
actual
dates
of
startup;
keep
records
of
monthly
emissions
calculations,
and
a
report
of
the
initial
performance
test.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
reports
and
records.
Approximately
30
facilities
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
3
facilities
will
become
subject
to
the
standard
in
the
next
three
years,
for
a
total
of
31.
The
existing
30
facilities
each
have
an
average
of
9
units
subject
to
this
rule.
It
is
further
assumed
that
less
than
half
of
those
facilities
will
add
or
modify
a
press
at
their
facility
during
the
three
year
period.
The
3
new
facilities
will
begin
operations
with
6
presses
each.
Therefore
there
are
270
existing
presses
subject
to
this
standard
and
an
additional
10
affected
units
will
be
added
each
year.
This
is
based
upon
the
AIRS
Facility
Subsystem
Report.
The
annual
cost
of
this
ICR
will
be
$
153,949.67.
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
EPA
Regional
Office.
Information
is
entered
into
the
AIRS
database.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
2
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
nonair
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
interval,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.
In
the
Administrator's
judgment,
volatile
organic
compounds
(
VOCs)
emissions
from
NSPS
Subpart
QQ
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
QQ
.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
volatile
organic
compounds
from
NSPS
Subpart
QQ
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
volatile
organic
compounds
from
NSPS
Subpart
QQ
are
the
result
of
operation
of
the
publication
rotogravure
printing
presses.
These
standards
rely
on
the
use
of
waterborne
ink
systems,
or
solvent­
bourne
ink
systems
in
conjunction
with
either
fixed­
bed
carbon
adsorption/
solvent
recovery
systems
or
a
solvent
vapor
capture
system
to
control
VOC
emissions.
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
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard.
The
information
generated
by
the
monitoring,
and
recordkeeping
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
achieve
compliance
with
the
NSPS.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
3
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
QQ.
If
the
standard
has
not
been
delegated
the
information
is
sent
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
regulation
to
implement
NSPS
Subpart
QQ,
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
Standard.
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
15,
2000,
(
65
FR
55955);
no
comments
were
received.

3(
c)
Consultations
No
additional
consultations
were
conducted..

3(
d)
Effects
of
Less
Frequent
Collection
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
main
consequence
would
be
that
the
chances
of
detecting
poor
operation
and
maintenance
of
control
equipment
would
decrease.
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
4
determined
not
to
be
private.
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
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
NSPS
Subpart
QQ
(
SIC
Code
2754)
that
commenced
construction,
modification,
or
reconstruction
after
October
28,1980.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and
reported
is
required
by
40
CFR
Part
60
Subpart
QQ.
Provide
notification
of
­
construction/
reconstruction
(
60.7(
a)(
1)
)
­
anticipated
startup
(
60.7(
a)(
2))
­
actual
startup
(
60.7(
a)(
3))
­
initial
performance
test
(
60.8(
d))
­
physical
or
operational
change
(
60.7(
a)(
4))
Report
on
­
initial
performance
test
(
60.8
(
a),
60.433(
e)(
6))
Record
­
startups,
shutdowns,
and
malfunctions
(
60.7(
b))
­
records
necessary
to
determine
conditions
of
the
performance
test
(
60.8(
c)
and
60.433(
a)(
5),
and
60.7(
f))
­
records
showing
information
to
make
monthly
calculations
for
emissions
(
60.434(
a)
and
60.7(
f))

Records
are
required
to
be
retained
for
2
years.

b.
Respondent
Activities
­
Read
instructions
5
­
perform
initial
performance
test,
Reference
Method
24A
test,
and
repeat
performance
tests
if
necessary
­
write
the
notifications
and
reports
listed
above
­
enter
information
required
to
be
recorded
above.
­
submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information;
­
developing
systems
and
acquiring,
installing,
and
utilizing
technology
if
necessary
for
the
purpose
of
processing
and
maintaining
information;
­
developing
systems
and
acquiring,
installing,
and
utilizing
technology
if
necessary
for
the
purpose
of
disclosing
and
providing
information;
­
adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
­
training
personnel
to
be
able
to
respond
to
a
collection
of
information;
­
transmitting,
or
otherwise
disclosing
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
information
required
under
40
CFR
Part
60
Subpart
QQ:
­
Observes
initial
and
repeat
performance
tests
­
Reviews
notifications
and
reports
required
to
be
submitted
by
industry
­
Audits
facility
records
­
Compiles
data
in
the
AIRS
database
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
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.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.
Information
contained
in
the
reports
is
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Offices
and
Headquarters.
EPA
can
edit,
store,
retrieve
and
analyze
the
data
via
PC
terminals.
6
The
records
required
by
this
NSPS
must
be
retained
by
the
owner
or
operator
for
(
two)
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
The
reporting
and
recordkeeping
requirements
have
been
in
existence
since
1982.
Responses
to
this
information
collection
are
mandatory.
(
40
CFR
Part
60,
and
the
U.
S
Code
Section
111
of
the
Clean
Air
Act)
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
at
3871
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
18.94
plus
110%
overhead
for
the
technical
occupation
labor
level
from
the
Employment
Cost
Index
from
the
Department
of
Commerce
Bureau
of
Labor
Statistics.
The
testing,
reporting,
notifications,
and
recordkeeping
requirements
are
all
tasks
that
are
accomplished
by
the
technical
personnel
who
actually
design
and
run
the
test,
and
run
and
maintain
the
equipment.
There
should
be
no
management
or
clerical
involvement.
Labor
rates
for
industry
are
consistent
with
the
hourly
wage
rates
from
a
Bureau
of
Labor
Statistics
publication
on
employment
and
earnings.
Rates
also
include
the
cost
of
overhead
and
fringe
benefits,
as
appropriate.
7
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
It
is
not
applicable
since
there
is
no
continuous
monitoring.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
20,565.83.
This
cost
is
based
on
an
average
wage
of
a
GS10
step
1
employee
rate
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
Part
60
Subpart
QQ
is
30.
The
number
of
new
sources
expected
to
be
subject
to
40
CFR
Part
60
Subpart
QQ
is
3.
There
are
an
average
of
9
affected
units
at
each
facility
source.
The
burdened
is
based
on
less
than
half
of
the
facilities
will
be
adding
or
modifying
presses
during
the
three
year
period.
The
total
annual
labor
costs
are
$
153,949.67
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0.00
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
attached
tables.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
increase
in
the
number
of
facilities
affected
by
this
rule.
8
6(
g)
Burden
Statement
Burden
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.
An
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.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Susan
Auby,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
DC
20460­
0001;
and
to
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget
(
OMB),
Attention:
Desk
Officer
for
EPA,
725
17th
Street,
N.
W.,
Washington,
DC
20503.
Include
the
EPA
ICR
number
0657.07
and
OMB
control
number
2060­
0105
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
