SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY 

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), 

EPA ICR Number 0657.10, OMB Control number 2060-0105 

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the Graphic Arts
Industry (40 CFR part 60, subpart QQ) were proposed on October 28, 1980,
and promulgated on November 8, 1982.  These standards apply to the
following affected facilities in NSPS subpart QQ: each publication
rotogravure printing press (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.

Approximately 19 facilities are currently subject to the standard, and
it is estimated that one additional facility will begin operations and
will become subject to the standard over the next three years.  It is
assumed that 30 percent of those facilities will add or modify a press
at their facility during the three-year period. 

	

The current ICR is based on the most recently approved Information
Collection Request (ICR).  The cost of this ICR will be $163,005
(rounded).  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.

OMB approved the currently active ICR without any “Terms of
Clearance.”

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 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 eight 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, 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, 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 (VOCs) 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 VOCs from publication
rotogravure printing presses are the result of the 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 recordkeeping and reporting requirements in the standard ensures
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard.
Continuous emission monitors are used to ensure compliance with the
standard at all times.

The notifications 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 authority may then inspect the source
to check if the pollution control devices are properly installed and
operated and the standards are being met.  The performance test may also
be observed. 

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures, and for compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, 

subpart QQ.

3(a)  Non-duplication

 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state, or local agency. 
If a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state, or local agency 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 July 8, 2009 (74 FR 32581).  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

For this information collection, the previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“Expedited Approach” option provided in May 1, 2008 guidance.  Per
this guidance, all data and assumptions from the previous ICR renewal
were used as the basis for estimating the hourly and cost burdens
associated with this renewal.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.  In this case, no comments were received.
 

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 5 CFR Part 1320, Section 1320.5.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC and NAICS Codes

The respondents to the recordkeeping and reporting requirements are
magnetic tape manufacturers.  The SIC code for the respondents affected
by the standards is SIC (United States Standard Industrial
Classification) 2754 which corresponds to the NAICS (The North American
Industry Classification System) 323111 for Graphic Arts Industry.

4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 60, subpart QQ.

A source must make the following reports:

Notifications and Reports



Construction/reconstruction	

60.7(a)(1)



Actual startup	

60.7(a)(3)



Initial performance test results	

60.8(a) and 60.433 (e)(6)



Initial performance test	

60.8(d)



Physical or operational change	

60.7(a)(4)



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.	

60.7(f), 60.8(c), and 60.433(a)(5)



Records showing information to make monthly calculations 

of emissions.	

60.7(f), and 60.434(a)



Records are required to be retained 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

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.



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 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

	

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 below in Table 1: Annual Respondent Burden and
Cost for NSPS for the Graphic Arts Industry (40 CFR part 60, subpart QQ)
(Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the 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).  The recordkeeping hours shown in
Table 1 are 1,353.  The reporting requirement hours shown in Table 1 are
365.  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	$114.49 ($54.52 + 110%)   

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “Table 2. Civilian Workers, 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 and Operations 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. Operating 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 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 $13,797 (rounded).  

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Average Annual Agency Burden and Cost for
NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ)
(Renewal).

.

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

	

Based on our research for this ICR, approximately 19 existing sources
currently are subject to the standard.  It is estimated that one
additional source per year will become subject to the regulation over
the next three years.  It is further assumed that and that 30 percent of
the existing sources will be reconstructed or modified over the next
three years.

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)



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. 

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.  

The total annual labor costs are $163,005.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost for NSPS for the Graphic Arts Industry (40 CFR part 60, subpart QQ)
(Renewal).

 

Note that the total annual capital and O&M costs to the regulated entity
are $0.  These costs are detailed in Section 6(b)(iii), Capital/Startup
vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2 below,
respectively, and summarized below.  

(i) Respondent Tally

The total annual labor hours are 1,718. Details regarding these
estimates may be found below in Table 1:  Annual Respondent Burden and
Cost for NSPS for the Graphic Arts (40 CFR part 60, subpart QQ)
(Renewal).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 37
(rounded) hours per response.

There are no annual capital/startup and O&M costs to the regulated
entity.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 228 labor hours at a cost of $13,797.  See below Table
2:  Average Annual Agency Burden and Cost for NSPS for the Graphic Arts
Industry (40 CFR part 60, subpart QQ) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR because the regulations have not
changed over the past three years and are not anticipated to change over
the next three years.  Since this ICR renewal was approved to be
processed under the “Expedited Approach” option, EPA has maintained
the same estimate for the number of sources currently subject to this
standard as indicated in the most recently approved ICR.  Therefore, the
labor hour figures in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 37 (rounded) hours per response. 
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 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
EPA-HQ-OECA-2009-0409. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system,   SEQ CHAPTER \h \r 1 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 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) 566-1752.  Also, comments can be sent
to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Officer for EPA. Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0409 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.

 PAGE   

 PAGE   10 

