| Table 1: Annual Respondent Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal) |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| 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 |
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(C=AxB) |
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(E=CxD) |
(Ex0.05) |
(Ex0.1) |
Per year b |
Technical |
$123.94 |
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| 1. Applications |
N/A |
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Managerial |
$157.61 |
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| 2. Surveys and studies |
N/A |
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Clerical |
$62.52 |
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| 3. Reporting requirements |
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| a. Familiarization with the regulatory requirements c |
4 |
1 |
4 |
352 |
1,408 |
70.4 |
140.8 |
$194,406.08 |
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| b. Required activities |
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| Initial performance test d |
240 |
1 |
240 |
0 |
0 |
0 |
0 |
$0 |
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| Repeat performance tests d |
240 |
1 |
240 |
0 |
0 |
0 |
0 |
$0 |
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| Install CMS d |
100 |
1 |
100 |
0 |
0 |
0 |
0 |
$0 |
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| Develop CMS/QC program and test plan d |
100 |
1 |
100 |
0 |
0 |
0 |
0 |
$0 |
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| Conduct CMS performance evaluation d |
300 |
1 |
300 |
0 |
0 |
0 |
0 |
$0 |
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| Maintain, adjust, and calibrate CMS e |
6 |
52 |
312 |
46 |
14,352 |
717.6 |
1,435.2 |
$1,981,616.52 |
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| c. Create information |
See 3B |
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| d. Gather existing information |
See 3E |
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| e. Write report |
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| New Sources |
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| Notification of initial and HAP usage d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Report of performance test d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Existing Sources |
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| Startup, shutdown, malfunction report f |
2 |
2 |
4 |
30 |
120 |
6 |
12 |
$16,568.70 |
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| Semiannual excess emission and CMS performance report g |
16 |
2 |
32 |
76 |
2,432 |
121.6 |
243.2 |
$335,792.32 |
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| Subtotal for Reporting Requirements |
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21,059 |
$2,528,383.62 |
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| 4 Recordkeeping requirements |
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| a. Familiarization with the regulatory requirements |
See 3A |
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| b. Plan activities |
N/A |
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| c. Implement activities |
N/A |
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| d. Develop record system d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| e. Time to enter information |
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| Records of maintenance h |
4 |
52 |
208 |
105 |
21,840 |
1,092 |
2,184 |
$3,015,503.40 |
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| Records of startup, shutdown, and malfunction i |
2 |
52 |
104 |
30 |
3,120 |
156 |
312 |
$430,786.20 |
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| Records of malfunction or inoperative CMS i |
2 |
2 |
4 |
30 |
120 |
6 |
12 |
$16,568.70 |
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| Records of applicability determination d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Records of CMS operation j |
2 |
52 |
104 |
46 |
4,784 |
239.2 |
478.4 |
$660,538.84 |
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| 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 |
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| Records of materials used by incidental printers l |
40 |
1 |
40 |
2 |
80 |
4 |
8 |
$11,045.80 |
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| Records of HAP usage (area sources) m , n |
0.5 |
12 |
6 |
200 |
1,200 |
60 |
120 |
$165,687.00 |
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| f. Time to train personnel |
See 3A |
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| g. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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38,714 |
$4,648,072.64 |
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| TOTAL LABOR BURDEN AND COST (rounded) o |
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59,800 |
$7,180,000 |
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| Capital and O&M Cost (rounded): o |
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$414,000 |
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| TOTAL COST (rounded): o |
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$7,590,000 |
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145 |
hr/resp |
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| Assumptions: |
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| 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. |
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| 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. |
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| c We have assumed that all facilities will take 4 hours to read and review instructions. |
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| d We have assumed that there will be no new sources during the three-year period of this ICR. |
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| e We have assumed that 30 percent of the 152 major source respondents (46 facilities) will be required to maintain, adjust, and calibrate CMS. |
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| 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. |
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| g We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions. |
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| h We have assumed that 105 facilities do not have CMS installed in them. |
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| i We have assumed that 20 percent of respondents (major source) will enter information on startup, shutdown, malfunction problems with equipment or inoperative CMS. |
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| j We have assumed that 46 respondents (major source) will enter information on CMS operations. |
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| k We have assumed that 105 facilities do not have CMS installed in them. |
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| l We have assumed that 2 existing facilities will be required to enter information on records of materials used by incidental printers. |
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| 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. |
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| n We have assumed that it will take each respondent 0.5 hours to record HAP usage. |
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| o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for the Printing and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal) |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| 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 |
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|
(C=AxB) |
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(E=CxD) |
(Ex0.05) |
(Ex0.1) |
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| Required activities |
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Technical |
$52.37 |
| New sources |
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Managerial |
$70.56 |
| Initial performance tests c |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
Clerical |
$28.34 |
| Repeat performance tests c |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
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| Report review |
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| New sources |
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| Notification of initial startup c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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| Review test results c |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Existing sources |
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| Semiannual excess emissions and CMS performance report d |
2 |
2 |
4 |
76 |
304 |
15.2 |
30.4 |
$17,854.53 |
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| Periodic startup, shutdown, malfunction report e |
2 |
1 |
2 |
30 |
60 |
3 |
6 |
$3,523.92 |
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| TOTAL ANNUAL BURDEN AND COST (rounded) f |
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419 |
$21,400 |
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| Assumptions: |
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| 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. |
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| 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. |
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| c We have assumed that there will be no new sources during the three-year period of this ICR. |
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| d We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions. |
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| e We have assumed that 20 percent of 152 major sources (30 facilities) will be required to submit periodic startup, shutdown, malfunction report. |
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| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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