SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)
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 0657.12, OMB Control Number 2060-0105.
1(b) Short Characterization/Abstract
The New Source Performance Standards (NSPS) for (40 CFR Part 60, Subpart QQ) for the Graphic Arts Industry were proposed on October 28, 1980, promulgated on November 8,1982, and most recently amended on April 9, 2004. These regulations apply to 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.
In general, all NSPS standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They 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. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.
Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least two years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.
All of the publication rotogravure printing press facilities in the United States are owned and operated by the graphic arts industry (aka: the “Affected Public”). None of the facilities in the United States are owned by either state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. This burden may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal).
Over the next three years, approximately 21 existing respondents per year will be subject to the standard, and 0.33 additional respondents per year will become subject to these standards (one new respondent over the three-year ICR period). Also, this ICR assumes 30 percent of existing facilities will either add or modify operations over the three-year ICR period, yielding an average of 2.1 facilities per year (21*0.3/3 = 2.1) that will also become subject to these initial reporting requirements. The overall average number of respondents for this ICR is 21.33 per year.
The Office of Management and Budget (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/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 emissions from publication rotogravure printing presses either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/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 recordkeeping and reporting requirements in these standards ensure compliance with the applicable regulations which were 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 standards. Continuous emission monitors are used to ensure compliance with these standards at all times.
The notifications required in these standards 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 that these 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, duplication does not exist.
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 (81 FR 26546) on May 3, 2016. No comments were received on the burden published in the Federal Register.
3(c) Consultations
The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.
Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both: 1) the Printing Industries of America, at (202) 730-7970; and 2) the Printing & Graphics Association Mid Atlantic, at (877) 319-0906.
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 these 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
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 Codes
The respondents to the recordkeeping and reporting requirements owners and operators of publication rotogravure printing presses. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 2754, which corresponds to the North American Industry Classification System (NAICS) 323111 for Commercial Printing, except Screen and Books.
4(b) Information Requested
(i) Data Items
In this ICR, all the data that is recorded or reported is required by the NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ).
A source must make the following reports:
Notifications and Reports |
|
Notification of construction/reconstruction |
60.7(a)(1) |
Notification of actual startup |
60.7(a)(3) |
Report of initial performance test results |
60.8(a) and 60.433 (e)(6) |
Notification of initial performance test |
60.8(d) |
Notification of physical or operational change |
60.7(a)(4) |
Semiannual Reports |
60.7(c) |
A source must keep the following records:
Recordkeeping |
|
Records of 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), and 60.434(a) |
Electronic Reporting
Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.
(ii) Respondent Activities
Respondent Activities |
Familiarization with the regulatory requirements. |
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. |
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 Enforcement and Compliance History Online (ECHO) and ICIS. |
5(b) Collection Methodology and Management
Following notification of startup, the reviewing authority could 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. 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS 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/operator for two years.
5(c) Small Entity Flexibility
There are no small entities (i.e., small businesses) affected by this regulation.
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 – 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 record-keeping and reporting requirements is estimated to be 1,920 hours (Total Labor Hours from Table 1 below). 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 $138.43 ($65.92+ 110%)
Technical $106.45 ($50.69 + 110%)
Clerical $52.77 ($25.13 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “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/Startup and Operation and Maintenance Costs
The only costs to the regulated industry resulting from information collection activities required by the subject standards 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 type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.
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 $9,210.
This cost is based on the average hourly labor rate as follows:
Managerial $64.16 (GS-13, Step 5, $40.10 + 60%)
Technical $47.62 (GS-12, Step 1, $29.76 + 60%)
Clerical $25.76 (GS-6, Step 3, $16.10 + 60%)
These rates are from the Office of Personnel Management (OPM), 2016 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 EPA Burden and Cost – 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, on average over the next three years, approximately 21 existing respondents will be subject to these standards. It is estimated that an additional 0.33 respondents per year will become subject. Also, this ICR assumes 30 percent of existing facilities will add or modify operations over the 3-year period of this ICR, yielding an average of 2.1 facilities per year (21*0.3/3 = 2.1) that also will become subject to initial reporting requirements. The overall average number of respondents, as shown in the table below, is 21.33 per year.
The number of respondents is calculated using the following table that 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 1, 2 |
(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 |
2.43 |
20.66 |
0 |
2.1 |
21 |
2 |
2.43 |
21 |
0 |
2.1 |
21.33 |
3 |
2.43 |
21.33 |
0 |
2.1 |
21.66 |
Average |
2.43 |
21 |
0 |
2.1 |
21.33 |
1 New respondents include sources with constructed, reconstructed and modified affected facilities.
2 Over the 3-year ICR period, we have assumed that 30 percent of existing respondents will modify operations (21*30% = 6.3) and that 1 new facility will come on-line. The three-year average is 2.43 per year ((6.3 + 1)/3 = 2.43).
Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 21.33.
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 |
2.43 |
1 |
0 |
2.43 |
Notification of actual startup |
2.43 |
1 |
0 |
2.43 |
Notification of initial performance test |
2.43 |
1 |
0 |
2.43 |
Initial performance test report |
2.43 |
1 |
0 |
2.43 |
Semiannual reports |
21.33 |
2 |
0 |
42.66 |
|
|
|
Total |
52 (rounded) |
The number of Total Annual Responses is 52 (rounded).
The total annual labor costs are $198,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal).
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, respectively, and summarized below.
(i) Respondent Tally
The total annual labor hours are 1,920 hours. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal).
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
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. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.
(ii) The Agency Tally
The average annual Agency burden and cost over next three years is estimated to be 198 labor hours at a cost of $9,210. See Table 2: Average Annual EPA Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal).
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
6(f) Reasons for Change in Burden
There is an adjustment increase in the total estimated burden and cost as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The change in the burden and cost estimates occurred for two reasons: 1) this ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year; and 2) the burden has increased due an increase in the estimated number of sources subject to these standards. The number of sources has increased by one since the last ICR in order to account for industry growth in the past three years.
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 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-2013-0302. 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, 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), WJC 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 docket center is (202) 566-1752. Also, you can send comments 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-2013-0302 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.
Table 1: Annual Respondent Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) (G=Ex0.1) |
(H) |
1. Applications |
N/A |
|
|
|
|
|
|
|
2. Surveys and studies |
N/A |
|
|
|
|
|
|
|
3. Reporting requirements |
|
|
|
|
|
|
|
|
A. Familiarize with regulatory requirements c |
1 |
1 |
1 |
21.33 |
21.33 |
1.07 |
2.13 |
$2,530.77 |
B. Required activities |
|
|
|
|
|
|
|
|
Initial performance test d |
60 |
1 |
60 |
2.43 |
145.8 |
7.29 |
14.58 |
$17,298.95 |
Repeat of performance test e |
60 |
1 |
60 |
0.49 |
29.4 |
1.47 |
2.94 |
$3,488.27 |
C. Create information |
See 3B |
|
|
|
|
|
|
|
D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
E. Write report |
|
|
|
|
|
|
|
|
Notification of construction, reconstruction, or modification d |
2 |
1 |
2 |
2.43 |
4.86 |
0.24 |
0.49 |
$576.63 |
Notification of actual startup d |
2 |
1 |
2 |
2.43 |
4.86 |
0.24 |
0.49 |
$576.63 |
Notification of initial performance test d |
2 |
1 |
2 |
2.43 |
4.86 |
0.24 |
0.49 |
$576.63 |
Report of performance test |
See 3B |
|
|
|
|
|
|
|
Semiannual report f |
8 |
2 |
16 |
21.33 |
341.28 |
17.06 |
34.13 |
$40,492.36 |
Subtotal for reporting Requirements |
|
|
|
|
635 |
$65,540 |
||
4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
A. Familiarize with regulatory requirements c |
See 3A |
|
|
|
|
|
|
|
B. Plan activities |
See 4C |
|
|
|
|
|
|
|
C. Implement activities |
See 3B |
|
|
|
|
|
|
|
D. Develop record system g |
3 |
1 |
3 |
0.33 |
0.99 |
0.05 |
0.10 |
$117.46 |
E. Time to enter information |
|
|
|
|
|
|
|
|
Records of startups, shutdowns, malfunctions, etc. h |
0.2 |
4.28 |
0.86 |
21.33 |
18.26 |
0.91 |
1.83 |
$2,166.34 |
Records of VOC for monthly materials and emissions calculation i |
1 |
51.36 |
51.36 |
21.33 |
1,095.51 |
54.78 |
109.55 |
$129,980.48 |
F. Time to train personnel |
N/A |
|
|
|
|
|
|
|
G. Time for audits |
N/A |
|
|
|
|
|
|
|
Subtotal for Recordkeeping Requirements |
|
|
|
|
1,282 |
$132,264 |
||
TOTAL ANNUAL BURDEN AND COST (rounded) j |
|
|
|
|
1,920 |
$198,000 |
||
TOTAL CAPITAL AND O&M COST (rounded) j |
|
|
|
|
|
|
|
$0 |
GRAND TOTAL (rounded) j |
|
|
|
|
|
|
|
$198,000 |
Assumptions:
a We have assumed there is an average of 21 existing respondents per year subject to the rule. We have also assumed that over the 3-year ICR period, 30 percent of existing respondents will modify operations (21*30% = 6.3) and that 1 new facility will come on-line. The three-year average is 2.43 new sources per year ((6.3 + 1)/3 = 2.43). The overall average number of sources per year subject to the rule is 21.33 (21 existing source + (1 new source/3 yr) = 21.33).
b This ICR uses the following labor rates: $106.45 for technical, $138.43 for managerial, and $52.77 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “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.
c We have assumed all new and existing sources will have to familiarize with the regulatory requirements each year.
d This is a one-time only activity for newly constructed, and reconstructed or modified sources.
e We have assumed 20 percent of respondents will have to repeat the performance test due to failure (2.43*20% = 0.49).
f We have assumed all respondents will submit semiannual reports.
g We have assumed one new facility will become subject to the standard over the next three years. Therefore, there will be an average of 0.33 new respondents per year over the active life of this ICR.
h We have assumed there are 21 existing respondents with an average of 4 presses per facility (21*4 = 84), plus 6.3 modified presses, and 1 press at the new respondent facility, for a total of 91.3 presses that are subject to the rule. The number of occurrences per respondent per year is 4.28 (91.3/21.33 = 4.28).
i We estimate the number of occurrences per respondent per year to be 51.36 (4.28*12 = 51.36).
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Table 2: Average Annual EPA Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
Initial performance test c |
24 |
1 |
24 |
2.43 |
58.32 |
2.92 |
5.83 |
$3,114.52 |
Repeat performance test d |
24 |
1 |
24 |
0.49 |
11.76 |
0.59 |
1.18 |
$628.03 |
Report review |
|
|
|
|
|
|
|
|
Notification of construction, reconstruction, or modification c |
2 |
1 |
2 |
2.43 |
4.86 |
0.24 |
0.49 |
$259.54 |
Notification of actual startup c |
0.5 |
1 |
0.5 |
2.43 |
1.22 |
0.06 |
0.12 |
$64.89 |
Notification of initial performance test c |
0.5 |
1 |
0.5 |
2.43 |
1.22 |
0.06 |
0.12 |
$64.89 |
Report of performance test c |
4 |
1 |
4 |
2.43 |
9.72 |
0.49 |
0.97 |
$519.09 |
Semiannual report e |
2 |
2 |
4 |
21.33 |
85.32 |
4.27 |
8.53 |
$4,556.43 |
TOTAL ANNUAL BURDEN AND COST (rounded) f |
|
|
|
|
198 |
$9,210 |
||
Assumptions:
a We have assumed there is an average of 21 existing respondents per year subject to the rule. We have also assumed that over the 3-year ICR period, 30 percent of existing respondents will modify operations (21*30% = 6.3) and that 1 new facility will come on-line. The three-year average is 2.43 new sources per year ((6.3 + 1)/3 = 2.43). The overall average number of sources per year subject to the rule is 21.33 (21 existing source + (1 new source/3 yr) = 21.33).
b This ICR uses the following labor rates: $47.63 for technical, $64.16 for managerial, and $25.76 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2016 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.
c This is a one-time only activity for newly constructed, and reconstructed or modified sources.
d We have assumed 20 percent of respondents will have to repeat the performance test due to failure (2.43*20% = 0.49).
e We have assumed all respondents will submit semiannual reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | ICR Package Instructions |
| Author | rmarshal |
| File Modified | 0000-00-00 |
| File Created | 2021-01-23 |