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 1739.07, OMB Control Number 2060-0335. 

1(b) Short Characterization/Abstract

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

and Publishing Industry (40 CFR subpart KK) were proposed on March 14, 1995 (60 FR 13664), 

promulgated on May 30, 1996 (61 FR 27131), and amended on May 24, 2006 (71 FR 29792). 

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 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 facilities at each plant site and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 352 respondents per year will be subject to 

the standards, and no additional respondents per year will become subject to the standard. Of the 

352 facilities, 152 are major sources and 200 are area sources that are currently subject to the 

standards. 

The Office of Management and Budget (OMB) approved the currently active ICR 
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without any “Terms of Clearance”. 

All 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 

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 

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

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 the printing and publishing 

industry cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP were promulgated for this source category 

at 40 CFR part 63, subpart KK.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used 

to ensure compliance with the standard 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 the standard 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 standard is 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 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 (77 FR 63813) on October 17, 2012. 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 Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 
4

maintenance, and retrieval of all compliance data. 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 standards as it was being developed and the 

standards has previously been reviewed to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the Printing Industries of 

America, at (434) 591-0527; and 2) the Flexible Packaging Association (FPA), at (410) 694-

0823. EPA received comments from the FPA, a national trade association representing 

manufacturers and suppliers of flexible packaging for food, healthcare and industrial products 

using paper, plastics, films, and foil or any combination of these materials. FPA indicated that 

most, if not all, FPA members comply with this NESHAP by utilizing compliant coatings. 

Therefore, the primary burden for these member companies are the costs associated with data 

systems management, recordkeeping, and reporting, rather than costs associated with conducting 

performance tests and maintaining continuous monitoring systems. FPA also expressed that 

many member companies who were “major sources” are now emitting at levels of an area source 

due to material substitution. 

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. 
5

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) code for the 

respondents affected by the standards, which corresponds to the North American Industry

Classification System (NAICS) codes, listed below. 

Standard (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

Die-Cut Paper and Paperboard Office Supplies 

Manufacturing 2675, 2679 322231
6

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) (Renewal).

A source must make the following reports:

Notifications / Reports

Initial notification 63.5(d), 63.9(b), 63.10(f), 63.830(b)

Notification of change 63.821(a)(6), 63.820(a)(2)

Notification of compliance status 63.9(h), 63.830(b)

Initial performance test and evaluation 63.7(b), 63.9(e), (g), (j), 63.830(b)

Rescheduled initial performance test 63.7(b)(2)

Initial performance test results 63.6(g), 63.10(d-e), 63.830(b)

Opacity or visible emissions 63.10(d)(3)

Periodic startup, shutdown, malfunction reports 63.6(e), 63.10(a), (d), 63.830(b)

Summary report 63.10(e), 63.830(b)

Excess emission and continuous monitoring system 

(CMS) performance reports

63.10(a), (e), 63.830(b)

A source must keep the following records:
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Recordkeeping

Startups, shutdowns, and malfunctions periods where the continuous 

monitoring system is inoperative.

63.10(b)(2), 63.829(b)

Emission test results and other data needed to determine emissions, 

operating parameters, etc.

63.824(b) 63.825(b-g),

63.828(a), 63.829(b-f)

All reports and notifications 63.10(b)

Record of applicability 63.10(b)(3)

Records for sources with continuous monitoring systems 63.10(c), 63.829 

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 20 percent of the respondents use 

electronic reporting. 

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS 63.824(b), 63.825(c)(d), 63.828(a), 63.8(c).

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

necessary. Conduct CMS performance evaluation.

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.

Adjust the existing ways to comply with any previously applicable instructions and 
8

Respondent Activities

requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system.) Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

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

Observe initial performance tests and repeat performance tests if necessary.

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 Online Tracking Information System (OTIS). 

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. 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 entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 
9

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

Both 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 in below 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. Wherever 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 58,162 (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.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “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 when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(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: 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 zero. This is the total of column D in the 

above table. 

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

total of column G. 

 The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $414,000. These are 

recordkeeping costs. 
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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 such activities as the 

examination of records maintained by the respondents, the 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 

$18,864. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 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 the standard. Of the 352 respondents, 152 are major 

sources and 200 are area sources. It is estimated that no additional respondents per year will 

become subject. 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. 
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Number of Respondents

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 respondent 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 $5,631,789. 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).
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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 58,162 hours at a cost of $5,631,789. 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). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 95 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 $18,864. See below Table 2: Average Annual EPA Burden and Cost –

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

6(f) Reasons for Change in Burden

There is a small decrease in the respondent labor hours from the most recently approved 

ICR due to an adjustment. The previous ICR calculated the burden assuming a percentage of the 

respondent universe are subject to specific burden activities; in some cases, the calculations 

included non-integer number of respondents. This ICR uses whole (rounded) values for the 

number of respondents, which results in an overall decrease in labor hours. There is also a 

decrease in the Agency burden costs due to a mathematical correction for the review of startup, 

shutdown, and malfunction reports in the previous ICR. 

There is also an adjustment increase in the respondent labor costs. This increase is not 

due to any program changes; rather, the increase was due to an adjustment in labor rates. This 

ICR uses updated labor rates to estimate all burden costs. 

6(g) Burden Statement

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

is estimated to average 95 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 
14

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), EPA 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.
15

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. Read instructions c 4 1 4 2 8 0.4 0.8 $890.82 

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 $1,598,138.26 

c. Create information See 3B

d. Gather existing information See 3E

e. Write report

 New Sources

 Notification of initial and HAP usage d

4 1 4 0 0 0 0 $0 

 Notification of compliance status d

4 1 4 0 0 0 0 $0 

 Notification of performance test d

2 1 2 0 0 0 0 $0 

 Report of performance test d

40 1 40 0 0 0 0 $0 

 Existing Sources

 Startup, shutdown, malfunction report f

2 2 4 30 120 6 12 $13,362.36 

 Semiannual excess emission and CMS 

performance report g 16 2 32 76 2,432 121.6 243.2 $270,810.50 

Subtotal for Reporting Requirements 19,448.8 $1,883,201.94 
16

4 Recordkeeping requirements

a. Read instructions 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 $2,431,949.2 

 Records of startup, shutdown, and malfunction i

2 52 104 30 3,120 156 312 $347,421.36 

 Records of malfunction or inoperative CMS i

2 2 4 30 120 6 12 $13,362.36 

 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 $532,712.75 

 Records of liquid-liquid material balances; HAP, 

volatile material, solids and materials applied, 

operating parameters k

2 12 24 105 2,520 126 252 $280,609.56 

 Records of materials used by incidental printers l

40 1 40 2 80 4 8 $8,908.24 

 Records of HAP usage (area sources) m & n

0.5 12 6 200 1,200 60 120 $133,623.60 

f. Time to train personnel See 3A

g. Time for audits N/A

Subtotal for Recordkeeping Requirements 38,713.6 $3,748,587.39

TOTAL LABOR BURDEN AND COST (rounded) 58,162 $5,631,789 

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: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, 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.
17

h

 We have assumed that these facilities do not have CMS installed in them.

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.
18

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 

person- hours 

per year

Management 

personhours per 

year

Clerical 

personhours per 

year

Total 

Cost per 

year $ 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 $15,754.65 

 Periodic startup, shutdown, malfunction report e

2 1 2 30 60 3 6 $3,109.47 

TOTAL ANNUAL BURDEN AND COST (rounded) 419 $18,864 

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: $62.27 

Managerial rate, $46.21 Technical rate, and $25.01 Clerical rate. These rates are from the Office of Personnel Management (OPM) 2012 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.