SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, 

Subpart OOOO) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 CFR Part 63, 

Subpart OOOO) (Renewal), EPA ICR Number 2071.06, OMB Control Number 2060-0522. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Printing, 

Coating and Dyeing of Fabrics and Other Textiles were proposed on July 11, 2002, promulgated 

on May 29, 2003, and amended on April 4, 2004 and May 24, 2006. These regulations apply to 

each existing, new, or reconstructed source involved in printing, coating, slashing, dyeing or 

finishing of fabric and other textiles. New facilities include those that commenced construction 

or reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart OOOO.

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 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.

 Based on our consultations with industry representatives, there is an average of one

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

The “Affected Public” are private sector businesses that coat fabrics and textiles. The 

“burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden 

and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 CFR 

Part 63, Subpart OOOO) (Renewal). The Federal Government “burden” 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 Printing, Coating and Dyeing 

of Fabrics and other Textiles (40 CFR Part 63, Subpart OOOO) (Renewal).
2

Over the next three years, we estimate 146 respondents per year will be subject to the 

standard. The estimate consists of 72 coating and printing sources, and 74 slashing, dyeing, and 

finishing sources. We also estimate one additional coating and printing source per year will 

become subject to the standard. 

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 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 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, hazardous air pollutant (HAP) emissions from printing, 

coating and dyeing of fabrics and other textiles facilities cause or contribute to air pollution that 

may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP

standards were promulgated for this source category at 40 CFR Part 63, Subpart OOOO.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the 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 the standards at all times. During the performance test a record of 
3

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 the 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, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

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

OOOO.

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 (79 FR 30117) on May 27, 2014. 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 the standard, 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 associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 
4

this ICR, we contacted both the National Council of Textile Organizations (NCTO), at (202) 

822-8026, and the American Association of Textile Chemists & Colorists (AATCC), at (919) 

549-8141.

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.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

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 

the standards. 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. 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 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 the standard do not include sensitive 
5

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities involved 

in printing, coating and dyeing of fabrics and other textiles. The United States Standard 

Industrial Classification (SIC) codes for the respondents affected by the standards and the 

corresponding North American Industry Classification System (NAICS) codes are listed in the 

table below. 

Standard (40 CFR Part 63, Subpart OOOO) SIC Codes NAICS Codes

Broadwoven Fabric Mills, Cotton 2211 313210

Broadwoven Fabric Mills, Manmade Fiber and Silk 2221 313210

Broadwoven Fabric Mills, Wool (including dyeing and 

finishing) 2231 313210

Textile Goods, NEC (broadwoven fabrics of jute, linen, 

hemp, and ramie and hand woven fabrics) 2299 313210

Narrow Fabric and Other Smallware Mills; Cotton, Wool, 

silk and Manmade Fiber 2241 313221

Textile Goods, NEC (narrow woven fabric of jute, linen, 

hemp, and ramie) 2299 313221

Knitting Mills, NEC (knitting weft fabric and fabricating 

textile products, such as bedspreads, curtains, or towels 2259 313241

Broadwoven Fabric Mills, Wool (wool broadwoven fabric 

finishing without weaving fabric) 2231 313311

Finishers of Broadwoven Fabrics of Cotton 2261 313311

Finishers of Broadwoven Fabrics of Manmade Fiber and Silk 2262 313311

Broadwoven Fabric Mills, Wool (wool fabric, except 

broadwoven, finishing without weaving fabric) 2231 313312

Knit Outerwear Mills (dyeing and finishing knit outerwear 

without knitting outerwear) 2253 313312

Knit Underwear and Nightwear Mills (dyeing and finishing 

underwear and nightwear without knitting garments) 2254 313312

Weft Knit Fabric Mills (finishing weft fabric without knitting 

weft fabric) 2257 313312

Lace and Warp Fabric Mills (Finishing lace or warp fabric 

without knitting lace or warp fabric) 2258 313312
6

Finishers of Textiles, NEC (except linen fabric finishing) 2269 313312

Thread Mills (finishing thread without manufacturing thread) 2284 313312

Textile Goods, NEC (finishing hard fiber thread and yarn 

without manufacturing thread or yarn) 2299 313312

Coated Fabrics, Not Rubberized 2295 313320

Fabricated Rubber Products, NEC (rubberizing fabric or 

purchased textile products) 3069 313320

Carpets and Rugs 2273 314110

Rubber and Plastics Hose and Belting 3052 326220

Gaskets, Packing, and Sealing Devices 3053 339991

Fabricated Rubber Products, NEC (rubberizing fabric or 

purchased textile products) 3069 313320

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO). 

A source must make the following reports:

Notifications

Initial notification 63.9(b), 63.4310(b)

Notification of intent to construction/reconstruction 63.9(b)(4), 63.4310

Notification of anticipated startup 63.9(b)(4), 63.4310

Notification of actual startup 63.9(b)(4), 63.4310

Request for extension of compliance date 63.9(c), 63.4283

Notification of performance test 63.9(e), 63.6310

Notification of compliance status 63.9(h)(2), 63.4310

Continuous monitoring system 63.9(h)

Reports

Performance test report 63.10(d)(2), 

63.4311

Startup, shutdown, malfunction (SSM) report 63.6.(e)(3), 
7

Reports

63.4311

Excess emissions or no excess emissions report 63.10(e)(3), 

63.4311

A source must keep the following records:

Recordkeeping

Record of startup, shutdown, and malfunctions 63.6(e)(3), 63.4311

Records are required to be retained for five years 63.10(b)(2)

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. 

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 204, 204A, 204B, 204D or E tests, 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.
8

Respondent Activities

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

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 Integrated Compliance Information System (ICIS) and 

ECHO. 

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 five

years.
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5(c) Small Entity Flexibility

A 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 the regulation. 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 below in Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating 

and Dyeing of Fabrics and other Textiles (40 CFR Part 63, Subpart OOOO) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 22,400 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 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: 
10

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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 type of industry costs associated with the information collection activities in the 

subject standard 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 that occur 

when a facility becomes subject to the regulations. The annual operation and maintenance costs 

are the ongoing costs to maintain the monitor 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)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F) 1

Parametric 

monitoring 

(contractor)

$2,953 1 $2,953 $26 146 $3,796

TOTAL

(rounded) $2,950 $3,800

1 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $2,950. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $3,800. 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 $6,750. 

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 
11

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 

$50,200. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 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 – NESHAP for Printing, 

Coating and Dyeing of Fabrics and other Textiles (40 CFR Part 63, Subpart OOOO) (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

145 existing respondents will be subject to the standard. It is estimated that an additional one

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 146 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR: 
12

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(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 1 144 0 0 145

2 1 145 0 0 146

3 1 146 0 0 147

Average 1 145 0 0 146

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

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 146.

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

Initial notification 1 1 0 1

Application of 

construction/reconstruction 1 1 0 1

Notification of anticipated 

startup 1 1 0 1

Notification of actual startup 1 1 0 1

Notification of compliance 

status 1 1 0 1

Notification of performance 

test 1 1 0 1

Performance test report 1 1 0 1

Report of monitoring 

exceedances1 7.2 2 0 14.4

Report of no excess 64.8 2 0 129.6
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Total Annual Responses

emissions1

Startup, shutdown, 

malfunction report2 7.2 2 0 14.4

Report of compliance 

deviation3 7.4 2 0 14.8

Report of no compliance 

deviations3 66.6 2 0 133.2

Total 313

1

It is assumed that 10 percent of the 69 coating and printing sources will report monitoring exceedances semiannually. The 

remaining 90 percent will have no excess emissions. 

2

It is assumed that 10 percent of the 69 coating and printing sources will file startup, shutdown, malfunction reports 

semiannually.

3

It is assumed that 10 percent of the 74 slashing, dyeing and finishing sources will report compliance deviations semiannually.

The remaining 90 percent will have no deviations. 

The number of Total Annual Responses is 313. 

The total annual labor costs are $2,250,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating 

and Dyeing of Fabrics and other Textiles (40 CFR Part 63, Subpart OOOO) (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 22,400 hours, at a cost of $2,250,000. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 CFR Part 63, 

Subpart OOOO) (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 72 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $6,750. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.
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(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

1,100 labor hours at a cost of $50,200. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 CFR Part 63, 

Subpart OOOO) (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 respondent and Agency burden, including an 

increase in the O&M cost. This is not due to any program changes; rather, it is due to an increase 

in the estimated number of sources. We assume an additional coating and printing facility will 

become subject to the rule each year. In addition, we have updated all burden calculations using 

the latest labor rates, which contributes to an increase in cost. 

There is a small apparent decrease in the Agency labor hours due to rounding. In this 

ICR, we rounded the total annual burdens and costs to 3 significant values.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 72 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-2014-0092. An electronic version of the public docket is 
15

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-2014-0092 and OMB Control Number 2060-0522 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
16

Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 

CFR Part 63, Subpart OOOO) (Renewal)

Burden item

(A)

Person -

hours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(C=AxB)

(D)

Respondent

per year 

a

(E)

Technical 

Person -

hours per 

year

(E=CxD)

(F)

Management 

personhours per 

year

(Ex0.05)

(G)

Clerical 

person -

hours per 

year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Familiarization with rule 

requirement 4 1 4 146 584 29.2 58.4 $67,536.97 

 B. Required activities

 Initial oxidizer performance test c, e

280 1 280 1 280 14 28 $32,380.74 

 Repeat oxidizer performance test c, 

e, f 280 1 280 0.2 56 2.8 5.6 $6,476.15 

 Initial capture performance test c, e

215 1 215 1 215 10.75 21.5 $24,863.78 

 Repeat capture performance test c, 

e, f 215 1 215 0.2 43 2.15 4.3 $4,972.76 

 Startup, shutdown, malfunction 

plan c 40 1 40 1 40 2 4 $4,625.82 

 Solvent recovery system 

compliance determination c, p 4 12 48 14.4 691.2 34.56 69.12 $79,934.17 

 Emission rate limit compliance 

determination 4 12 48 146 7,008 350.4 700.8 $810,443.66 

 Coordination with suppliers g

40 1 40 146 5,840 292 584 $675,369.72 

 C. Create information See 4B
17

Burden item

(A)

Person -

hours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(C=AxB)

(D)

Respondent

per year 

a

(E)

Technical 

Person -

hours per 

year

(E=CxD)

(F)

Management 

personhours per 

year

(Ex0.05)

(G)

Clerical 

person -

hours per 

year

(Ex0.1)

(H)

Cost, $ b

 D. Gather existing information See 4B

 E. Write report

 Initial notification c

2 1 2 1 2 0.1 0.2 $231.29 

 Notification of 

construction/reconstruction c 2 1 2 1 2 0.1 0.2 $231.29 

 Notification of anticipated startup c

2 1 2 1 2 0.1 0.2 $231.29 

 Notification of actual startup c

2 1 2 1 2 0.1 0.2 $231.29 

 Notification of compliance status c

4 1 4 1 4 0.2 0.4 $462.58 

 Notification of performance test c, 

e 2 1 2 1 2 0.1 0.2 $231.29 

 Performance test report c, e

40 1 40 1 40 2 4 $4,625.82 

 Report of monitoring exceedances 

c, h, k 16 2 32 7.2 230.4 11.52 23.04 $26,644.72 

 Report of no excess emissions c, i, 

k 8 2 16 64.8 1,037 51.84 103.68 $119,901.25 

 Startup, shutdown, malfunction 

report c, j, k 8 2 16 7.2 115.2 5.76 11.52 $13,322.36 

 Report of compliance deviation d, 

k, l 16 2 32 7.4 236.8 11.84 23.68 $27,384.85 

 Report of no compliance 

deviations d, k, m 8 2 16 66.6 1,066 53.28 106.56 $123,231.84 

Subtotal for Reporting Requirements 20,120 $2,023,333.67

4. Recordkeeping Requirements
18

Burden item

(A)

Person -

hours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(C=AxB)

(D)

Respondent

per year 

a

(E)

Technical 

Person -

hours per 

year

(E=CxD)

(F)

Management 

personhours per 

year

(Ex0.05)

(G)

Clerical 

person -

hours per 

year

(Ex0.1)

(H)

Cost, $ b

 A. Familiarization with rule 

requirement See 4B

 B. Plan activities N/A

 C. Implement activities N/A

 D. Develop record system N/A

 E. Time to enter information

 Records of all information 

required by standards n 0.25 52 13 146 1,898 94.9 189.8 $219,495.16 

 F. Time to train personnel N/A

 G. Time to adjust existing ways to 

comply with previously applicable 

requirements 

N/A

 H. Time to transmit or disclose 

information o 0.25 2 0.5 146 73 3.65 7.3 $8,442.12 

 I. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 2,267 $227,937.28

TOTAL LABOR BURDEN AND 

COST q 22,400 $2,250,000

Capital and O&M Cost (see Section 

6(b)(iii)): q$6,750

TOTAL COST: q$2,260,000 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 146, which equates to 72 coating and printing sources, and 74
19

slashing, dyeing, and finishing sources. There will be one additional new source per year that will become subject to the rule over the three-year period of this 

ICR. 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2: Civilian 

Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the 

benefit packages available to those employed by private industry.

c

 This applies only to coating and printing facilities.

d

 This applies only to slashing, dyeing and finishing facilities.

e

 Occurs one time for new sources and involves one-time startup costs associated with initial compliance determination and acquisition, installation, and 

utilization of technology and systems needed to support recordkeeping and reporting.

f

 It is assumed that 20 percent of respondents will have to repeat performance tests. 

g We have assumed that it will take 40 hours for each respondent to coordinate with suppliers.

h

 We have assumed that 10 percent of respondents will report monitoring exceedances.

i

 We have assumed that 90 percent of respondents will report no excess emissions.

j

 We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction reports.

k

 Semiannual reports are required.

l

 It is assumed that 10 percent of respondents will report compliance deviations.

m

It is assumed that 90 percent of respondents will report no compliance deviations.

n

 It is assumed that all of the respondents will be required to record information on a weekly basis.

o

 It is assumed that respondents will be required to transmit/disclose information on a semiannual basis. 

p

 It is assumed that 20 percent of the coating and printing facilities will use solvent recovery equipment.

q Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
20

Table 2: Average Annual EPA Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles (40 

CFR Part 63, Subpart OOOO) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA

person 

hours 

per 

plant 

per year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

personhours per 

year

(Ex0.05)

(G)

Clerical 

personhours 

per 

year

(Ex0.1)

(H)

Cost, $ b

1. Initial performance test c

495 1 495 1 495 24.75 49.5 $25,908.30

2. Repeat performance test preparations c, e 4 0.1 0.4 1 0.4 0.02 0.04 $20.94 

3. Repeat performance test c, e 495 0.1 49.5 1 49.5 2.475 4.95 $2,590.83 

4. Report Review

 Notification of applicability 2 1 2 1 2 0.1 0.2 $104.68 

 Notification of construction/ reconstruction 2 1 2 1 2 0.1 0.2 $104.68 

 Notification of anticipated startup 2 1 2 1 2 0.1 0.2 $104.68 

 Notification of actual startup 2 1 2 1 2 0.1 0.2 $104.68 

 Notification of initial performance test c

2 1 2 1 2 0.1 0.2 $104.68 

 Notification of compliance status c

2 1 2 1 2 0.1 0.2 $104.68 

 Review of initial performance test report c

8 1 8 1 8 0.4 0.8 $418.72 

 Review of repeat performance test report c, f 8 0.1 0.8 1 0.8 0.04 0.08 $41.87 

 Review of excess emissions report c, g 8 1 8 7.2 57.6 2.88 5.76 $3,014.78 

 Review of no excess emissions report c, h 2 1 2 64.8 129.6 6.48 12.96 $6,783.26 

 Review of startup, shutdown, malfunction 

reports c, i 2 1 2 7.2 14.4 0.72 1.44 $753.70 

 Review of compliance deviations report d, j 8 1 8 7.4 59.2 2.96 5.92 $3,098.53 

 Review of no compliance deviations reports d, k 2 1 2 66.6 133.2 6.66 13.32 $6,971.69 
21

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA

person 

hours 

per 

plant 

per year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

personhours per 

year

(Ex0.05)

(G)

Clerical 

personhours 

per 

year

(Ex0.1)

(H)

Cost, $ b

TOTAL ANNUAL BURDEN AND COST l

1,100 $50,200 

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 146, which equates to 72 coating and printing sources, and 74 

slashing, dyeing, and finishing sources. There will be one additional new source per year that will become subject to the rule over the three-year period of this 

ICR.

b This cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial 

rate of $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). 

These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.

c

 This applies only to coating and printing facilities. 

d

 This applies only to slashing, dyeing and finishing facilities. 

e

 We have assumed that 10 percent of new sources will have to repeat performance test preparations and testing.

f

 Assume that 10 percent of new sources will review the repeat performance test report.

g

 We have assumed that 10 percent of respondents will be engaged in the reviewing of excess emissions reports.

h

 We have assumed that 90 percent of respondents will be engaged in the reviewing of no excess emissions reports.

i

 We have assumed that 10 percent of respondents will have to review the startup, shutdown, malfunction reports.

j

 We have assumed that 10 percent of respondents will review the compliance deviations report.

k

 We have assumed that 90 percent of respondents will review the no compliance deviations report.

l Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.