SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ)
(
Renewal)

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
facility
in
NSPS
subpart
QQ:
each
publication
rotogravure
printing
presses
(
not
including
proof
presses)
commencing
construction,
modification
or
reconstruction
after
the
date
of
a
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.
These
are
a
one­
time­
only
notification
of
the
actual
dates
of
startup,
recordkeeping
of
monthly
emissions
calculations,
and
a
report
of
the
initial
performance
test.
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
two
years
following
the
date
of
such
reports
and
records.
In
addition,
semiannual
reports
are
required
for
respondents
(
i.
e.,
sources)
that
experience
excess
emissions.

Approximately
19
facilities
are
currently
subject
to
the
standard,
and
it
is
estimated
that
one
additional
facility
will
become
subject
to
the
standard
over
the
next
three
years.
It
is
assumed
seven
of
those
facilities
will
add
or
modify
a
press
at
their
facility
during
the
three­
year
period,
and
that
the
one
new
facility
will
begin
operations.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
108,663.

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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

In
the
development
of
the
ICR,
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance
(
TOC)"
on
the
active
ICR.
The
TOC
are
as
follows:

This
ICR
is
approved
for
three
years.
When
EPA
resubmits
the
ICR
for
renewal,
the
Agency
should
update
the
wage
rates
used
in
the
supporting
statement
and
should
ensure
that
the
rates
have
been
2
properly
loaded
to
include
overhead.

EPA
has
addressed
the
items
of
concern
in
the
TOC
as
instructed
by
OMB
in
the
active
ICR.
See
sections
6(
b)
and
6(
c)
for
updated
labor
figures
and
attached
Tables
1
&
2
for
the
specific
calculations.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
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
non­
air
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
the
Administrator's
judgment,
volatile
organic
compound
(
VOC)
emissions
from
publication
rotogravure
printing
presses
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
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
publication
rotogravure
printing
presses
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
from
publication
rotogravure
printing
presses
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
capture
of
VOC
emissions
using
control
technology
and
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
records
of
a
source's
initial
3
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
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
NSPS
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
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
60,
subpart
QQ.

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
a
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
(
69
FR
29718)
on
May
25,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
and
accessed
the
most
recent
data
(
May
20,
2004)
available
on
the
Air
Facility
System
(
AFS)
database.
We
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Printing
Industry,"
the
United
States
Census
Bureau
via
the
internet,
and
other
websites
covering
graphic
art's
industry
and
publication
rotogravure
printing.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division,
and
RR
Donnelley
and
Sons,
North
Eastern
Division,
Mr.
Fritz
Shaak
at:
(
717)
392­
4074.

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
4
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
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(
d)(
2).

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,
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
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
the
graphic
arts'
industry.
The
United
States
Standard
Industrial
Classification
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
2754
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
code
323111
for
Graphic
Arts
Industry.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5(
d)(
2).

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
New
Source
Performance
Standards,
(
NSPS)
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ).

A
source
must
make
the
following
reports:
5
Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction
or
modification.
60.7(
a)(
1)

Notification
of
actual
startup.
60.7(
a)(
3)

Notification
of
initial
performance
test.
60.8(
d)

Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate.
60.7(
a)(
4)

Reports
Initial
performance
test
60.8(
a)
and
60.433(
e)(
6)

Semiannual
reports
60.7(
c)

A
source
must
keep
the
following
records:

Recordkeeping
Startups,
shutdowns,
malfunctions.
60.7(
b)

Records
necessary
to
determine
conditions
of
the
performance
test.
60.8(
c),
60.7(
f),
and
60.433(
a)(
5)

Records
showing
information
to
make
monthly
calculations
of
emissions.
60.7(
f),
and
60.434(
a)

Maintain
records
for
two
years.
60.7(
f)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
solvent
recovery
systems
or
a
solvent
vapor
capture
system
to
control
emissions.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
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.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
6
Respondent
Activities
Read
instructions.

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.

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.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
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,
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.
7
Agency
Activities
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.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.

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
data
for
approximately
125,000
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
two
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
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
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
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
8
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
Paperwork
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
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
1,718
(
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
NSPS
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:

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standard
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
types
of
industry
cost
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs,
because
the
equipment
used
by
the
respondent
is
the
same
equipment
used
in
their
day­
to­
day
9
operations
to
maintain
quality
control
over
the
surface
coating
produced
for
sale.

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
$
18,989.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.02
(
GS­
13,
Step
5,
$
33.76
x
1.6)
Technical
$
40.08
(
GS­
12,
Step
1,
$
25.05
x
1.6)
Clerical
$
21.70
(
GS­
6,
Step
3,
$
13.56
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
19
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
one
additional
source
per
year
will
become
subject
to
the
standard
over
the
next
three
years
and
that
30
percent
of
the
existing
sources
will
be
reconstructed
or
modified.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
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)
10
Number
of
Respondents
1
2.23
1
19
0
1.9
19.33
2
2.23
1
19
0
1.9
19.33
3
2.23
1
19
0
1.9
19.33
Average
2.23
1
19
0
1.9
19
(
rounded)

1
One
new
facility
will
become
subject
to
the
standard
and
5.7
facilities
per
year
will
be
modified
or
reconstructed
over
the
next
three
years.
The
average
per
year
is
2.23.

To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
19.33.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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
construction/
reconstruction
2.23
1
N/
A
2.23
Notification
of
actual
startup
2.23
1
N/
A
2.23
Notification
of
initial
performance
test
2.23
1
N/
A
2.23
Initial
performance
test
report
2.23
1
N/
A
2.23
Semiannual
reports
19
2
N/
A
38
Total
47
(
rounded)

The
number
of
Total
Annual
Responses
is
47.
This
number
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
$
108,663.
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,
NSPS
for
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
11
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
37
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
the
burden
from
the
most
recently
approved
ICR
is
due
to
a
more
accurate
estimate
of
existing
and
anticipated
new
sources.
Our
data
shows
that
there
are
nineteen
plant
sites,
as
compared
with
the
active
ICR
having
thirty­
one
plant
sites.
Our
data
also
indicated
that
there
will
be
one
new
facility
over
the
next
three
years
of
this
ICR.
Therefore,
there
is
a
net
decrease
in
the
burden
to
industry.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
37
(
rounded)
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.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
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
OECA­
2004­
0012,
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,
NW,
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
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
12
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
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
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0012
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.
13
Table
1:
Annual
Respondent
Burden
and
Cost
­
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ)

Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
2.23b
2.23
0.11
0.22
$
161.96
B.
Required
activities
Initial
performance
test
60
1
60
2.23b
133.8
6.69
13.38
$
9,733.88
Repeat
performance
test
60
1
60
0.45c
27.45
1.37
2.75
$
1,996.94
C.
Create
information
Included
in
3B
D.
Gather
existing
information
Included
in
3B
E.
Write
Report
Notification
of
construction/

reconstruction
2
1
2
2.23
b
4.46
0.22
0.45
$
324.34
Notification
of
actual
startup
2
1
2
2.23b
4.46
0.22
0.45
$
324.34
Notification
of
initial
performance
test
2
1
2
2.23
b
4.46
0.22
0.45
$
324.34
Report
of
performance
test
Included
in
3B
Semiannual
reports
8
2
16
19d
304
15.2
30.4
$
22,115.85
4.
Recordkeeping
Requirements
14
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
A.
Read
instructions
Included
in
3A
B.
Plan
activities
Included
in
4C
C.
Implement
activities
Included
in
3B
D.
Develop
record
system
3
1
3
0.33e
0.99
0.05
0.10
$
73.11
E.
Time
to
enter
information
a.
Records
of
startup,

shutdown,
malfunction,
etc.
0.2
4.29g
0.2
19.33f
16.59
0.83
1.66
$
1,207.00
b.
Records
of
VOC­
for
monthly
materials
and
emissions
calculation
1
51.48h
12
19.33f
995.11
49.8
99.6
$
72,401.42
G.
Time
to
train
personnel
N/
A
H.
Time
for
audits
N/
A
Subtotal
Labor
Burden
1,493.55
74.71
149.46
$
108,663.18
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
1,718
$
108,663
Assumptions:

a
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."

b
We
have
assumed
that
30
percent
of
respondents
will
modify
their
operations
over
the
three­
year
period
of
this
ICR
(
19x30%=
5.7).
The
one
new
facility
will
come
on
lines
over
the
three­
year
period.
Average
over
three
years
is
2.23
[(
5.7+
1)/
3=
2.23]
per
year.
15
c
Assume
that
20
percent
would
have
to
repeat
the
performance
test
due
to
failure.

d
We
have
assumed
that
90
percent
of
the
respondents
will
submit
semiannual
reports.

e
It
is
assumed
that
one
new
facility
will
become
subject
to
the
standard
over
the
next
three
years.
For
each
year
within
the
three
years
of
the
active
life
of
this
ICR
there
will
be
.33
new
respondent.

f
We
have
assumed
that
there
are
19
existing
respondents,
plus
.33
new
respondent
for
a
total
of
19.33
respondents
per
year.

g
We
have
assumed
that
there
are
19
existing
respondents
with
an
average
of
four
presses
per
facility
(
19x4=
76),
plus
six
modified
presses,
and
one
at
a
new
respondent
for
a
total
of
83
presses
that
are
subject
to
the
rule.
Therefore,
the
number
of
occurrences
per
respondent
per
year
is
4.29
(
83/
19.33=
4.29).

h
We
have
assumed
that
the
number
of
occurrences
per
respondent
per
year
to
record
VOC
is
51.48
(
4.29x12
months).
16
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
the
Graphic
Arts
Industry
(
40
CFR
part
60,
subpart
QQ)

Burden
Item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Initial
Performance
Test
24
1
24
7b
168
8.4
16.8
$
7,581.77
Repeat
initial
performance
test
24
1
24
1.4c
33.6
1.68
3.36
$
1,510.36
Report
Review
for
new
plants:

Notification
of
construction
reconstruction
and
startup
2
1
2
7
b
14
0.7
1.4
$
629.31
Notification
of
actual
startup
0.5
1
0.5
7b
3.5
0.175
0.35
$
157.33
Notification
of
initial
performance
test
0.5
1
0.5
7b
3.5
0.175
0.35
$
157.33
Review
test
results
4
1
4
7b
28
1.4
2.8
$
2,036.99
Semiannual
reports
2
2
4
19d
76
3.8
7.6
$
3,416.28
Subtotal
326.6
16.33
32.66
$
15,489.37
Travel
Expenses
e
(
1
person
x
7
plant/
yr
x
2
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
7
round
trips/
yr)
=

$
3,500
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
366
$
18,989
17
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.02
for
Managerial
(
GS­
13,
Step
5,
$
33.76
x
1.6),
$
40.08
for
Technical
(
GS­
12,
Step
1,
$
25.05
x
1.6)
and
$
21.70
Clerical
(
GS­
6,
Step
3,
$
13.56
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
We
have
assumed
that
30%
of
affected
facilities
will
modify
their
presses
per
year
over
the
three
year
periods
of
this
ICR
(
19/
30%=
5.7)
six
rounded.
The
one
new
facility
will
add
three
presses
over
the
three­
year
period
(
one
press
per
year)
for
a
total
of
seven
presses
(
six
modified
+
one
new
press).

c
Assume
that
20
percent
would
have
to
repeat
the
performance
test
due
to
failure.

d
We
have
assumed
that
all
19
respondents
will
submit
semiannual
reports.

e
Assume
that
it
will
take
one
person
two
days
to
visit
each
of
the
seven
plants.
