SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

EPA ICR Number 1739.08, 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 were proposed on March 14, 1995, promulgated on May 30, 

1998, and most-recently amended on April 21, 2011. The amendment re-adopts the current 

MACT standard, eliminates the SSM exemption, and requires an electronic submittal of 

performance test data to improve efficiency. These revisions cause no substantial changes in 

costs to industry. These regulations apply to both existing and new facilities in: publication 

rotogravure, product and packaging rotogravure, and wide-web flexographic printing presses at 

major sources, existing or commencing construction or reconstruction after the effective date of 

this subpart. These standards also apply to owners 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 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 notification reports, 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.

All of the printing and publishing facilities in the United States are owned and operated 

by the printing and publishing industry (the “Affected Public”). None of the facilities in the 

United States are owned by any state, local, tribal or the Federal government entities. They are 

all privately-owned, for-profit businesses. The “burden” to the Affected Public may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Printing and Publishing 

Industry (40 CFR Part 63, Subpart KK) (Renewal). The “burden” to the Federal Government is 
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attributed entirely to work performed by either Federal employees or government contractors and 

can be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Printing 

and Publishing Industry (40 CFR Part 63, Subpart KK) (Renewal). 

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).

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 Information 

Collection Request (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, HAP emissions from printing and publishing industry

either 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.
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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 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.

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

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 either 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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register. 
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3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity 

to comment on the burden associated with these standards as they were being developed. In 

developing this ICR, we contacted both the Flexographic Technical Association, at (631) 737-

6020; and the Flexible Packaging Association (FPA), at (410) 694-0823. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less-frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet 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.
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3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are the printing and 

publishing industry. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standard and the corresponding North American Industry 

Classification System (NAICS) codes are listed in the table below:

40 CFR Part 63, Subpart, KK SIC Codes NAICS Codes

Textile Bag Mills 2392, 2393, 3069 314911

Setup Paperboard Box Manufacturing 2652 322213

Corrugated and Solid Fiber Box Manufacturing 2653, 2679 322211

Non-folding Sanitary Food Container 

Manufacturing 2656 322215

Folding Paperboard Box Manufacturing 2657 322212

Coated and Laminated Packaging Paper and 

Plastics film Manufacturing 2671 322221

Plastics, Foil, and Coated Paper Bag 

Manufacturing 2673 322223

Plastics Bag Manufacturing 2673 326111

Uncoated Paper and Multiwall Bag 

Manufacturing 2674 322224

Sanitary Paper Product Manufacturing 2676, 3842 322291

All Other Converted Paper Product 

Manufacturing 2675, 2679 322299

Corrugated and Solid Fiber Box Manufacturing 2653 322211
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Die-Cut Paper and Paperboard Office Supplies 

Manufacturing 2675, 2679 322231

Coated and Laminated Paper Manufacturing 2672, 2679 322222

Periodical Publishers 2721, 2741 511120

All Other Publishers (except newspaper, 

magazine, books, directory, database, music, and 

greeting card publishers)

2741 511199

Commercial Gravure Printing 2754, 2771 323111

Commercial Flexographic Printing 2759, 2771 323112

Other Commercial printing 2759, 2771 323119

All Other Plastics Product Manufacturing 3089, 3999 326199

Laminated Aluminum Foil Manufacturing for 

Flexible Packaging Uses 3497 322225

Resilient Floor Covering Manufacturing 3069, 3996 326192

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 and Publishing Industry (40 CFR Part 63, Subpart KK).

A source must make the following reports:

Notifications/Reports

Initial notification

63.5(d), 63.9(b), 

63.10(f), 

63.830(b)(1)

Notification of change in information already provided 63.9(j)

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)

Initial performance test results

63.10(d-e), 

63.830(b)(4), 

63.830(c)

Semi-annual summary report 63.10(e), 

63.830(b)(6)
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Notifications/Reports

Excess emission and continuous monitoring system (CMS) 

performance reports

63.10(a), (e), 

63.830(b)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, and malfunctions periods where the continuous 

monitoring system is inoperative.

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(bg), 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.

Owners and operators of printing and publishing facilities are required to submit 

electronic copies of applicable reports of performance tests to EPA’s WebFIRE database through 

an electronic emissions test report structure called the Electronic ERT. 

(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.
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Respondent Activities

Perform initial performance test, Reference Method 311 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed.

Enter information required to be recorded.

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.

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 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. 
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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.

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 and 

Publishing Industry (40 CFR Part 63, Subpart KK) (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.
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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).

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 $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 standards 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 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)

Temperature $7,000 0 $0 $9,000 46 $414,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. This ICR 

assumes that 30 percent of respondents (major source), or 46 sources will be required to maintain, adjust, and 

calibrate CMS.

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

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$19,100.

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 

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 Do 
12

Number of Respondents

Respondents That Submit Reports 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 0 152 200 0 352

2 0 152 200 0 352

3 0 152 200 0 352

Average 352

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 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) 200 2 0 400

Total 612

The number of Total Annual Responses is 612.

The total annual labor costs are $6,010,000. Details regarding these estimates may be 
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found below in Table 1: Annual Respondent Burden and Cost – NESHAP for 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, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 59,800. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for 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 98 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $414,000. The 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 419

labor hours at a cost of $19,100. See below in Table 2: Average Annual EPA Burden and Cost –

NESHAP for 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 an adjustment increase in labor hour burden in this ICR from the most recently 

approved ICR. This is not due to program changes. The increase occurred because this ICR 

assumes all existing sources will have to re-familiarize with the regulatory requirements each 

year when calculating respondent labor hours and costs. 

6(g) Burden Statement
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The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 98 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-2012-0666. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0666 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.
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Table 1: Annual Respondent Burden and Cost – NESHAP for 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 

personhours per 

year

Management 

person hours 

per year

Clerical 

person 

hours per 

year

Total Cost Per 

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

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 $162,828.86 

 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 $1,659,744.22 

 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 
16

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 

personhours per 

year

Management 

person hours 

per year

Clerical 

person 

hours per 

year

Total Cost Per 

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

 Existing Sources

 Startup, shutdown, malfunction report f 2 2 4 30 120 6 12 $13,877.46 

 Semiannual excess emission and CMS 

performance report g 16 2 32 76 2,432 121.6 243.2

$281,249.86 

Subtotal for Reporting Requirements 21,059 $2,117,700.40 

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 $2,525,697.72 

 Records of startup, shutdown, and 

malfunction i 2 52 104 30 3,120 156 312 $360,813.96 

 Records of malfunction or inoperative 

CMS i 2 2 4 30 120 6 12 $13,877.46 

 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 $553,248.07 

 Records of liquid-liquid material balances; 

HAP, volatile material, solids and materials 

applied, operating parameters k 2 12 24 105 2,520 126 252

$291,426.66 

 Records of materials used by incidental 

printers l 40 1 40 2 80 4 8 $9,251.64 
17

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 

personhours per 

year

Management 

person hours 

per year

Clerical 

person 

hours per 

year

Total Cost Per 

year b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

 Records of HAP usage (area sources) m & n 0.5 12 6 200 1,200 60 120 $138,774.60

 f. Time to train personnel See 3A

 g. Time for audits N/A

Subtotal for Recordkeeping Requirements 38,714 $3,893,090.11

TOTAL LABOR BURDEN AND COST 

(rounded) o 59,800 $6,010,000

Capital and O&M Cost (see Section 6(b)(iii)): o $414,000

TOTAL COST: o $6,420,000

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: $129.93 ($61.87+ 110%) per hour for Executive, Administrative, and Managerial labor;$103.97 ($49.51 + 110%) 

per hour for Technical labor, and $51.79 ($24.66 + 110%) 

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 percent to account for the benefit 

packages available to those employed by private industry.

c

 We have assumed that two existing facilities will need 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 respondents (major source) will be required to maintain, adjust, and calibrate CMS.

f

 We have assumed that 20 percent of the respondents (major source) 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 these facilities do not have CMS installed in them.
18

i

 We have assumed that 20 percent of respondents 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 these 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.
19

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

KK) (Renewal)

Activity

(A) (B) (C) (D) (E) (F) (G) (H)

EPA 

personhours per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA 

personhours per 

plant per 

year

Plants per 

year a

Technical 

personhours per 

year

Management 

personhours per 

year

Clerical 

personhours 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

$15,911.36 

 Periodic startup, shutdown, malfunction 

report e 2 1 2 30 60 3 6 $3,140.40 

TOTAL ANNUAL BURDEN AND COST 

(rounded) f 419 $19,100 
20

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 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 

Managerial rate, $46.67 Technical rate, and $25.25 Clerical rate. These rates are from the Office of Personnel Management (OPM) 2015 General Schedule, 

which excludes locality rates of pay.

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 sources 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.