1739ss10

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal), EPA ICR Number 1739.10, OMB Control Number 2060-0335.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) were proposed on March 14, 1995; promulgated on May 30, 1996; and subsequently amended on both May 24, 2006, and April 24, 2011. These regulations apply to both existing facilities and new facilities operating: publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses at major sources. These standards also apply to owners and/or operators who choose to commit to, and meet the criteria of establishing the facility to, be an area source of hazardous air pollutants (HAP). New facilities include those that commenced either construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart KK.

In general, all NESHAP 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 NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. If there is no such delegated authority, the EPA‘s regional offices can review them. All other reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA’s regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority, such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 

The “Affected Public” constitutes private-sector businesses that operate printing and publishing facilities in the United States. The ‘burden’ to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal). The ‘burden’ to the “Federal Government” is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal). There are approximately 352 printing and publishing facilities, which are owned and operated by the printing and publishing industry. None of the 352 facilities in the United States are owned by either state, or local, or tribal entities or by 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.

Based on our consultations with industry representatives, there are an average of one affected facilities at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 352 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards. Of the 352 facilities, 152 are major sources and 200 are area sources.

The Office of Management and Budget (OMB) approved the currently active ICR with the following “Terms of Clearance”:

“Upon resubmission, the agency must update the burden estimates to accurately reflect the number of respondents and include burden estimates for State reporting and recordkeeping requirements. Ensure that burden is calculated for all of the requirements and ensure that the requirements and burden tables are consistent. The agency must provide screen shots of the mode of collection, ICIS, that is used for this information collection. In addition, the agency must have a burden statement that aligns with the requirements under 5 CFR 1320.8(b)(3) and placement of the OMB control number for on-line submissions on the initial screen per 5 CFR 1320.3(f)(2).”

In renewing the currently-approved ICR, the agency has reviewed the number of respondents in industry and updated the burden estimates accordingly. In this case, we did not identify any changes to the number of respondents in the currently approved ICR. There are no reporting requirements for states. Burden has been calculated for all requirements, which are reflected in the burden tables in the supporting statement. All electronic collection in this information collection is submitted through EPA's CEDRI or ERT, as discussed in section 4(b)(i) of this document. Additional Paperwork Reduction Act requirements for CEDRI and ERT, including the burden statement and OMB control number, are available at: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to either new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/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, HAP emissions from printing and publishing facilities ether cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart KK.

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. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or its 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, leaks are being detected and repaired, and that 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.

Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of initial notifications required in 40 CFR 63.9(b), performance test reports, and changes in information for reclassifying area sources in 40 CFR 63.9(j) through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI).

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests. The EPA is also requiring that 40 CFR Part 63, Subpart KK performance test reports be submitted through the EPA’s ERT.

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

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart KK.

3(a) Non-duplication

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 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 (87 FR 43843) on July 22, 2022. No comments were received on the burden published in the Federal Register for this renewal.

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 both industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 352 respondents will be subject to these standards over the three-year period covered by this ICR.

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 Printing United, at (703) 385-1335, and the Flexible Packaging Association, at (410) 694-0800.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for 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 implemented and that 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.

These standards require the respondents to maintain all records, including reports and notifications, for at least five years. This is consistent with the General Provisions as applied to these standards. The EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. The EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records.

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 these standards 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 are the printing and publishing industry. The United States Standard Industrial Classification (SIC) codes for the respondents affected by these standards and the corresponding North American Industry Classification System (NAICS) codes are listed in the table below:

Standard (40 CFR Part 63, Subpart KK)	SIC Codes	NAICS Codes
Textile Bag and Canvas Mills	2392, 2393, 3069	314910
Setup Paperboard Boxes	2652	322219
Corrugated and Solid Fiber Box Manufacturing	2653, 2679	322211
Sanitary Food Containers	2656	322219
Folding Paperboard Box Manufacturing	2657	322212
Plastics Packaging Film and Sheet (including Laminated) Manufacturing	2671	322220
Paper Bag and Coated and Treated Paper Manufacturing	2673	322220
Plastics Bag and Pouch Manufacturing	2673	326111
Uncoated Paper and Multiwall Bag Manufacturing	2674	322220
Sanitary Paper Product Manufacturing	2676, 3842	322291
All Other Converted Paper Product Manufacturing	2675, 2679	322299
Periodical Publishers	2721, 2741	511120
All Other Publishers (except newspaper, magazine, books, directory, database, music, and greeting card publishers)	2741	511199
Commercial Printing (except Screen and Books)	2754, 2771	323111
Commercial Screen Printing	2759, 2771	323113

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK).

A source must make the following reports:

Notifications
Initial notification (electronic submission)	§§63.5(d), 63.9(b), 63.10(f), §63.830(b)(1)
Notification of compliance status	§63.9(h), §63.830(b)(3)
Notification of initial performance test	§§63.7(b)(1), 63.9(e), (g), §63.830(b)(2)
Rescheduled initial performance test	§63.7(b)(2)
Notification of changes in information (reclassification to area source status or to revert to major source status) (electronic submission)	§63.9(b), §63.9(j)

Reports
Initial performance test results (electronic submission)	§63.10(d),(e), §63.830(b)(4), §63.830(c)
Semi-annual summary report	§63.10(e), §63.830(b)(6)
Excess emission and continuous monitoring system (CMS) performance reports	§§63.10(a), (e), §63.830(b)(6)
Performance test reports (electronic submission)	§63.830(c)(1)

A source must keep the following records:

Recordkeeping
Occurrence and duration of each malfunction of operation (i.e., process equipment), air pollution control equipment, or monitoring equipment.	§63.10(b)(2), §63.829(g)
Emission test results and other data needed to determine emissions, operating parameters, etc.	§§63.824(b) 63.825(b-g), 63.828(a), 63.829(b-f)
All reports and notifications	§63.10(b)
Record of applicability	§63.10(b)(3)
Records for sources with continuous monitoring systems	§63.10(c), §63.829(b)
Records of HAP usage for area sources	§63.829(d)
Record of maintenance	§63.10(b)(2), §63.829(b)

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.

The rule was amended to include electronic reporting provisions on April 21, 2011. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application, rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts. Respondents are also required to submit electronic copies of notifications and certain reports through EPA’s CEDRI. The notification is an upload of their currently required notification in portable document format (PDF) file. For purposes of this ICR, it is assumed that there will be no additional burden associated with the proposed requirement for respondents to submit the notifications and reports electronically.

Electronic copies of records may also be maintained in order to satisfy Federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CEMS for total organic volatile matter or CMS for flow rate and temperature for an oxidizer.

Perform initial performance test, Reference Method 24A, 25, 311 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 collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for disclosing and providing information.

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

The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:

Agency Activities

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 these emission standards 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. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA’s regional offices, and the EPA headquarters. The 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 five years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of these regulations. 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 to be the minimum requirements 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 at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 below 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 neither conduct nor 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 59,800 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $157.61 ($75.05 + 110%)

Technical $123.94 ($59.02 + 110%)

Clerical $62.52 ($29.77 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in these subject standard(s) are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to these regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C) 2	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)2
Temperature a	$7,000	0	$0	$9,000	46	$414,000
Totals (rounded) b			$0			$414,000

^a This ICR assumes that 30 percent of respondents (major source), or 46 sources will be required to maintain, adjust, and calibrate CMS.

^b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $414,000. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $414,000. These are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. The EPA's overall compliance and enforcement program includes such activities 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 $21,400.

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

Managerial $70.56 (GS-13, Step 5, $44.10 + 60%)

Technical $52.37 (GS-12, Step 1, $32.73 + 60%)

Clerical $28.34 (GS-6, Step 3, $17.71 + 60%)

These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (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 352 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 352 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 a	(B) Number of Existing Respondents b	(C) Number of Existing Respondents that keep records but do not submit reports b	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	152	200	0	352
2	0	152	200	0	352
3	0	152	200	0	352
Average	0	152	200	0	352

^a New respondents include sources with constructed and reconstructed affected facilities.

^b The 152 major sources submit reports and keep records, and 200 area sources that only keep records.

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 352.

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 initial and HAP usage	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of performance test	0	1	0	0
Report of performance test	0	1	0	0
Startup/shutdown/malfunction report	30	2	0	60
Semiannual excess emission and CMS performance report	76	2	0	152
Records of HAP usage (area source) a	0	0	200	200
			Total	412

^a Area sources keep records of HAP usage but do not submit reports.

The number of Total Annual Responses is 412.

The total annual labor costs are $7,180,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (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 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 59,800 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (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 145 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $414,000. These 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 419 labor hours at a cost of $21,400; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (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 no change in ‘Burden’ from the most-recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. This is due to two considerations: 1) the regulations have not changed over the past three years and are not anticipated to change over the next three years; and 2) the growth rate for this industry is very low or non-existent, so there is no significant change in the overall burden. Since there are no changes in the regulatory requirements and there is no significant industry growth, there are also no changes in the capital/startup or operation and maintenance (O&M) costs. There is a slight increase in costs, which is wholly due to the use of updated labor rates. This ICR uses labor rates from the most-recent Bureau of Labor Statistics report (September 2021) to calculate respondent burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 145 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor 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-OAR-2022-0083. 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. 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-OAR-2022-0083 and OMB Control Number 2060-0335 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 – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)	Per year b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
a. Familiarization with the regulatory requirements c	4	1	4	352	1,408	70.4	140.8	$194,406.08
b. Required activities
Initial performance test d	240	1	240	0	0	0	0	$0
Repeat performance tests d	240	1	240	0	0	0	0	$0
Install CMS d	100	1	100	0	0	0	0	$0
Develop CMS/QC program and test plan d	100	1	100	0	0	0	0	$0
Conduct CMS performance evaluation d	300	1	300	0	0	0	0	$0
Maintain, adjust, and calibrate CMS e	6	52	312	46	14,352	717.6	1,435.2	$1,981,616.52
c. Create information	See 3B
d. Gather existing information	See 3E
e. Write report
New Sources
Notification of initial and HAP usage d	4	1	4	0	0	0	0	$0
Notification of compliance status d	4	1	4	0	0	0	0	$0
Notification of performance test d	2	1	2	0	0	0	0	$0
Report of performance test d	40	1	40	0	0	0	0	$0
Existing Sources
Startup, shutdown, malfunction report f	2	2	4	30	120	6	12	$16,568.70
Semiannual excess emission and CMS performance report g	16	2	32	76	2,432	121.6	243.2	$335,792.32
Subtotal for Reporting Requirements					21,059			$2,528,383.62
4 Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 3A
b. Plan activities	N/A
c. Implement activities	N/A
d. Develop record system d	40	1	40	0	0	0	0	$0
e. Time to enter information
Records of maintenance h	4	52	208	105	21,840	1,092	2,184	$3,015,503.40
Records of startup, shutdown, and malfunction i	2	52	104	30	3,120	156	312	$430,786.20
Records of malfunction or inoperative CMS i	2	2	4	30	120	6	12	$16,568.70
Records of applicability determination d	2	1	2	0	0	0	0	$0
Records of CMS operation j	2	52	104	46	4,784	239.2	478.4	$660,538.84
Records of liquid-liquid material balances; HAP, volatile material, solids and materials applied, operating parameters k	2	12	24	105	2,520	126	252	$347,942.70
Records of materials used by incidental printers l	40	1	40	2	80	4	8	$11,045.80
Records of HAP usage (area sources) m , n	0.5	12	6	200	1,200	60	120	$165,687.00
f. Time to train personnel	See 3A
g. Time for audits	N/A
Subtotal for Recordkeeping Requirements					38,714			$4,648,072.64
TOTAL LABOR BURDEN AND COST (rounded) o					59,800			$7,180,000
Capital and O&M Cost (rounded): o								$414,000
TOTAL COST (rounded): o								$7,590,000
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area sources. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $157.61 ($75.05 + 110%) per hour for Executive, Administrative, and Managerial labor; $123.94 ($59.02 + 110%) per hour for Technical labor, and $62.52 ($29.77 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed that all facilities will take 4 hours to read and review instructions.
d We have assumed that there will be no new sources during the three-year period of this ICR.
e We have assumed that 30 percent of the 152 major source respondents (46 facilities) will be required to maintain, adjust, and calibrate CMS.
f We have assumed that 20 percent of the 152 major source respondents (30 facilities) will have startup, shutdown, malfunction incidents with equipment or inoperative CMS reports to complete.
g We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions.
h We have assumed that 105 facilities do not have CMS installed in them.
i We have assumed that 20 percent of respondents (major source) will enter information on startup, shutdown, malfunction problems with equipment or inoperative CMS.
j We have assumed that 46 respondents (major source) will enter information on CMS operations.
k We have assumed that 105 facilities do not have CMS installed in them.
l We have assumed that 2 existing facilities will be required to enter information on records of materials used by incidental printers.
m We have assumed that 200 area sources, which includes products and packaging rotogravure and wide-web flexographic printing presses, are subject to recordkeeping requirements, and are required to keep a monthly record of HAP usage to show that they are meeting the limit.
n We have assumed that it will take each respondent 0.5 hours to record HAP usage.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal)

Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year	Plants per year a	Technical person- hours per year	Management person-hours per year	Clerical person-hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)
Required activities
New sources
Initial performance tests c	24	1	24	0	0	0	0	$0
Repeat performance tests c	24	1	24	0	0	0	0	$0
Report review
New sources
Notification of initial startup c	2	1	2	0	0	0	0	$0
Notification of compliance status c	4	1	4	0	0	0	0	$0
Notification of performance test c	1	1	1	0	0	0	0	$0
Review test results c	8	1	8	0	0	0	0	$0
Existing sources
Semiannual excess emissions and CMS performance report d	2	2	4	76	304	15.2	30.4	$17,854.53
Periodic startup, shutdown, malfunction report e	2	1	2	30	60	3	6	$3,523.92
TOTAL ANNUAL BURDEN AND COST (rounded) f					419			$21,400
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area sources. There will be no additional new sources over the three-year period of this ICR.
b This cost is based on the following hourly labor rates: $70.56 (GS-13, Step 5, $44.10 + 60%) for Managerial, $52.37 (GS-12, Step 1, $32.73 + 60%) for Technical, and $28.34 (GS-6, Step 3, $17.71 + 60%) Clerical. These rates are from the Office of Personnel Management (OPM), 2022 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 We have assumed that there will be no new sources during the three-year period of this ICR.
d We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions.
e We have assumed that 20 percent of 152 major sources (30 facilities) will be required to submit periodic startup, shutdown, malfunction report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.