Burden Calculations Table

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Overview

Summary
Table 1
Table 2
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	39
Number of Respondents	6
Total Estimated Burden Hours	470
Total Estimated Costs	$56,200
Annualized Capital O&M	$0
Total Annual Responses	12
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total cost per year ($) b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$157.61
3. Reporting requirements										Technical	$123.94
A. Familiarize with regulatory requirements c	3	1	3	6	18.0	0.90	1.80	$2,485.33		Clerical	$62.52
B. Required activities
Initial performance test d	60	1	60	0	0	0.00	0.0	$0
Repeat of performance test d, e	60	1	60	0	0.0	0.00	0.00	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction, reconstruction, or modification d	2	1	2	0	0	0.00	0.00	$0
Notification of actual startup d	2	1	2	0	0	0.00	0.00	$0
Notification of initial performance test d	2	1	2	0	0	0.00	0.00	$0
Report of performance test	See 3B
Semiannual report f	8	2	16	6	96	4.8	9.6	$13,255.10
Subtotal for reporting Requirements					131			$15,740
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	0	0.00	0.00	$0
E. Time to enter information
Records of startups, shutdowns, malfunctions, etc. h	0.2	4	0.80	6	4.8	0.24	0.48	$662.75
Records of VOC for monthly materials and emissions calculation i	1	48	48	6	288	14.4	29	$39,765.30
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					337			$40,428		responses	hr/response
TOTAL LABOR BURDEN AND COSTS (rounded) j					470			$56,200		12	39
TOTAL CAPITAL AND O&M COSTS (rounded) j								$0
GRAND TOTAL (rounded) j								$56,200
Assumptions:
a We estimate that an average of 6 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and 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.
c We have assumed all new and existing sources will have to familiarize with the regulatory requirements each year. This requirement has been increased in order to allow facilities ample time to familiarize with the regulatory requirements. This includes the costs associated with obtaining a technical consultant.
d Costs are covered in Section 6(b)(iii) of the supporting statement. The number of respondents is covered in Section 6(d) of the supporting statement.
e We assume that 20% of new or modified sources will need to repeat the performance test.
f We have assumed all respondents will submit semiannual reports.
g We have assumed no new facilities will become subject to the standard over the next three years.
h We have assumed there are 6 existing respondents with an average of 4 presses per facility (6*4 = 24), and there are no new or modified presses due to consolidation with industry. The number of occurrences per respondent per year is 4 (24/6=4).
i There are 4 presses per plant, so we estimate the number of occurrences per respondent per year to be 48 (4*12 = 48).
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for the Graphic Arts Industry (40 CFR Part 60, Subpart QQ) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total cost per year ($) b
1. Review Reports										Labor Rates
Initial performance test c	24	0	0	0	0	0	0	0		Management	$70.56
Repeat performance test d	24	0	0	0	0	0	0	0		Technical	$52.37
Report review										Clerical	$28.34
Notification of construction, reconstruction, or modification c	2	0	0	0	0	0	0	0
Notification of actual startup c	0.5	0	0	0	0	0	0	0
Notification of initial performance test c	0.5	0	0	0	0	0	0	0
Report of performance test c	4	0	0	0	0	0	0	0
Semiannual report e	2	6	12	6	72	3.60	7.20	$4,228.70
TOTAL COST (rounded) f					83			$4,230
Assumptions:
a We estimate that an average of 6 existing respondents per year will be subject to the rule, and that no new, modified, or reconstructed facilities will become subject over the three-year period of this ICR.
b 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%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. 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 Assumes oversight of initial performance test. This is a one-time only activity for newly constructed, and reconstructed or modified sources.
d Assumes oversight of initial performance test. We have assumed 20 percent of respondents will have to repeat the performance test due to failure.
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.

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Sheet 4: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of initial performance test	0	1	0	0
Initial performance test report	0	1	0	0
Semiannual reports	6	2	0	12
			Total	12

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Sheet 5: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a, b	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	6	0	0	6
2	0	6	0	0	6
3	0	6	0	0	6
Average	0	6	0	0	6
a New respondents include sources with constructed, reconstructed and modified affected facilities.