SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)
1. Identification of the Information Collection 1(a) Title of the Information Collection NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal) , EPA I CR Number 2079.04, OMB Control Number 2060

- 0541 1(b) Short Characterization/Abstract The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal Can Manufacturing Surface Coating, published at 40 CFR part 63, subpart KKKK , were proposed on January 15, 2003 , and promulgated on November 13, 2003. These regulations apply to facilities that perform surface coating operations on metal cans. Metal can manufa cturing surface coating operations include any facilities that coat or print metal cans or metal can parts (e.g., metal ends for composite cans). The source category also includes the coating/printing of metal decorative tins, crowns, and closures, except for coil coating. Regulated activities include the coating/printing of metal sheets for subsequent processing into cans or can parts, but not the coating of metal coils for cans or can parts. This information is being collected to assure compliance with 40 CFR part 63, subpart KKKK. 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner or 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 repor

ts, 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 United States Environmental Protection Agency (EPA) regional office.
Based on o ur 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 ye ars, an average of 71 resp ondents per year will be subject to the standard, and zero additional respondents per year will become subject to the standard. The Office of Management and Budget (OMB) approve the currentl y active Information Collection Request (I CR) with the followin g “Terms of Clearance" (TOC):2 The burden and cost assumptions and calculations for the respondents and the agency should be updated in the next renewal. EPA has addressed each item of concern in the TOC by updating respondent assumptions using September 2009 labor rates from the United States Department of Labor, Bureau of Labor Statistics. Agency

assumptions were updated using the Office of Personnel Management (OPM), 2010 General Schedule for Agency labor. Respondent and Agency cost assumptions are provided in Sections 6(b)(i) and 6(c) of this document. The term, “Affected Public”, applies to private sector businesses or other for

- profits that manufacture metal cans. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)

. The burden to the “Federal government” is attributed entirel y to work performed b y Federal employees or government contractors, and may be foun d below in Table 2: Annual Agency Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal).
2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under secti on 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 HAP). 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 or 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, an d 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 reasonabl y require. In the Administrator's judgment, HAP emissions from metal can manufacturing operations cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, NESHAP for this source category were promulgated at 40 CFR part 63, subpart KKKK. 2(b) Practical Utility/Users of the Data The recordkeeping and reporting requirements in the standards ensure co mpliance with3

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. Performance tests are required in order to deter mine an affected facility ’s initial capability to comply

with the emission standards. Continuous emission monitors (CEMS) are used to ensure compliance with the standards at all times. The notifications required in the standards are used to inform the A gency 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 properl y installed and operated and the standards are bein g 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.
The NESHAP also requires affected sources to submit a Notification of Compliance Status which includes the performance test results. The NESHAP requires owners or operators to develop a startup, shutdown, and malfunction plan (SSMP), documenting procedures that wil l be taken in the case of any of these events. Other required submissions include startup, shutdown, and malfunction reports which demonstrate that the actions taken b y an owner or operator during a startup, shutdown, or malfunction event comply with the SSMP. When actions taken are consistent with the plan, reports are required semiannually . When actions taken are inconsistent with the plan, immediate reports are required. 3. Non

- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 63, subpart KKKK. 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 s ent directl y 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 cop y 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, no duplication exists. 3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 7 4 FR 3258 1 ) on July 8, 2009. No comments were received on the burden published in the Federal Register

.4

3(c) Consultations During a previous renewal of this I CR, the Agency ’s industry experts have been consulted, and the Agency internal data sources and projections of industry growth over the next three ye ars have been considered. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Air Facility Sy stem (AFS) wh ich is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry

is based on our consultations with the Agency ’s internal indus try experts. Approximately

71 respondents will be subject to the standard over the three

- year period covered by this ICR. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the s tandard as it was being developed, and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as we ll as those submitted in response to the f irst Federal Register n otice. 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 c ontinuing 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 frequentl y, the likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease. 3(e) General Guidelines These reporting or recordkeeping requirements do not violate any of the regul ations promulgated b y 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 th e standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allows EPA to estab lish 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 ye ars. In addition, EPA would be pre vented 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 made5

will be safeguarded according to the Agency policie s 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 and NAICS Codes The respondents of the recordkeeping and reporting requirements are owners or operators of metal can manufacturing operations.

Standard NAICS Codes 40 CFR part 63, subpart KKKK 332431 Metal Can Manufacturing 332115 Crown and Closure Manufacturing 332116 Metal Stamping 332812 Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers 332999 All Other Miscellaneous Fabricated Metal Product Manufacturing 4(b) Information Requested (i) Data Items All data in this I CR that are recorded and/or rep orted are required b y 40 CFR part 63, subpart KKKK. A source must make the following reports:
Notifications Initial notification 63.3510(b), 63.5(d), 63.9(b) Notification of compliance status 63.3510(c), 63.9(h) Notification of construction or reconstruction 63.3510(a), 63.5 Notification of actual startup 63.3510(a), 63.9(b) Notification of performance test 63.3510(a), 63.7(b), 63.8(e), 63.9(e) Notification Reports Semiannual report 63.3511(a)6 Notification Reports Excess emissions report 63.3511(a)(4

- 8) Report of performance test 63.3511(b) Startup, shutdown, malfunction report 63.3511(c) A source must keep the following records: Recordkeeping Five ye ar retention of records 63.3513(b), 63.10(b) Material formulation data 63.3512(b) Records of HAP content calculations 63.3512(c) Copies of notifications and reports 63.3512(a) Records of names of materials used 63.3512(d) HAP fractions in each material used 63.3512(e) Coating solids fraction in each material used 63.3512(f) Density of materials used 63.3512(g ) Documentation of waste material shipped offsite 63.3512(h) Documentation of deviations 63.3512(i) Start

- up, shutdown, and malfunction plan/records 63.3512(j), 63.6(e) Records of continuous compliance with operating limits 63.3512(j) Documentation of capture sy stem efficiency determination 63.3512(j) Documentation of add

- on control device destruction or removal efficiency determination 63.3512(j) Documentation of control device performance tests 63.3512(j), 63.10(b) Determination of capture sy stem and add

- on control operating limits 63.3512(j) Work practice plan/records 63.3512(j) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility mus t still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. In addition, regulatory

agencies, in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

ii. Respondent Activities

Respondent Activities Read instructions. Install, calibrate, maintain, and operate CMS for temperature, for gas flow, or for pressure drop for oxidizer, carbon adsorber, condenser, concentrator, or capture s ys tem.7 Respondent Activities Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E, 204F, 311, or ASTM Method D1475

- 98, D2697

- 86, D6093

- 97 test, 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. 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, analy sis, storage, and distribution of the required information. Agency Activities Observe initial performance tests and repeat performance tests if neces sary
. Review notifications and reports including: performance test reports; excess emissions reports; startup, shutdown, malfunction plan; and the CMS quality control plan. Audit facility

records Input, anal yz e, and maintain data in the Air Facility Sy s tem (AFS). 5(b) Collection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y 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 us ed for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and8

maintained by

the EPA Office of Compliance. AFS is the EP A database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government

- owned facilities. EPA uses the AFS 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 b y this regulation must be retained by the owner or operator for five ye ars. 5(c) Sm all Entity Flexibility During rulemaking for subpart KKKK, EPA identified 13 small businesses subject to the rule. 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. Small entities were afforded extensive flexibility in demonstrating compliance through compliance options that give small entities flexibility in choosing the most cost effective and least burdensome alternative for their operation. 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 Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (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 I CR. 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 inform ation 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 27,517 (Total Labor Hours from Table 1). 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 previously9

approved ICR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: Managerial $114.49 ($54.52 + 110%) Technical $98.20 ($46.76 + 110%) Clerical $48.53 ($23.11 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, ” 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 b y private industry

.

(ii) Estimating Capital and Operating and Maintenance Costs This section covers the costs associated with all types of continuous monitoring equipment (e.g., CEMS and continuous parameter monitors). The ty pe 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 regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

CEM $16,000 0 $0 $1,200 71 $85,200 The total Capital/Start

- up costs for this I CR are zero. This is the total of column D in the above table. The total Operating and Maintenance (O&M) costs for this I CR are $85,200. This is the total of column G. The average annual cost for capital/startup and operation and maintenance c osts to industry over the next three years of the IC R is estimated to be $85,200. The continuous monitoring costs that are included in this section consist only of those capital/startup and O&M costs that a source incurs as a result of the standard. Some continuous monitoring costs may not be included in this section. For instance, if a particular industry ty picall y utilizes a control10

device that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function properl y, and the recordation of additional measurements beyond the minimum are required b y the standard, then there is no capital/startup or O&M cost, but there is a labor cost to record the additional readings. Such a cost would not appear in this section, but in the industry b urden Section 6(d) below. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA compliance and enforcement program includes activities such as the examination o f 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 $125,208.
This cos t is based on the average hourl y 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), 2010 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: Annual Respondent Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR part 63, subpart KKKK) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, there are approximate ly 71 existing sources currentl y subject to the standard. It is estimated that an additional zero sources per ye ar will become subject to the regulation in the next three years. Number of respondents is calculated using the following table which addresse s the three ye ars covered b y this ICR. Number of Respondents

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of 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 71 0 0 71 2 0 71 0 0 71 3 0 71 0 0 71 Average 0 71 0 0 7111

To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar peri od of this ICR is 71. The total number of annual responses per ye ar 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 0 1 0 0 Notification of compliance status 0 1 0 0 Notification of construction/reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notif ication of performance test 0 1.2 0 0 Report of performance test 0 1.2 0 0 Semiannual report 71 2 0 142 Excess emissions report 71 2 0 142 Startup, shutdown, malfunction report 18 1 0 18 Total 302 The number of Total Annual Responses is 302. The total annual labor costs are $2,602,77 3 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)

. Note that the to tal annual capital and O&M costs to the regulated entity are $85,200. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. 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, respectivel y, and summarized below. (i) Respondent Tally The total annual labor hours are 27,517. Details regarding these estimates may be found below in Tab le 1 : Annual Respondent Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK ( Renewal ). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to avera ge 91 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $85,200. The12

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 2,778 labor hours at a cost of $125,208. See below Table 2 : Annual Agency Burden and Cost : NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) ( Renewal ). 6(f) Reasons for Change in Burden There is no change in the labor hours in this I CR compared to the previous ICR. This is due to two considerations: ( 1) the regulations have not changed over the past three ye ars and are not anticipated to chang e over the next three ye ars; and ( 2) the growth rate for the respondents is very low, negative or non

- existent. Therefore, the labor hours in the previous I CR reflect the current burden to the respondents and are reiterated in this I CR.
There is an incre ase in both respondent and Agency costs due to labor rate increases from 2003 to the most recent available rates. This ICR uses updated labor rates to address “Terms of Clearance” associated with the previous I CR renewal. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 91 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or p rovide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complet e 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’s 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 burde n, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

–2009

–0403. An electronic version of the public docket is available at http://www.regulations.gov, which may be use d 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 sy stem , se lect “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and13

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 C onstitution Avenue, N.W., 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 holiday s. 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 In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

–2009

–0403 and OMB Control Number 2060

- 0541 in any correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.14

Table 1. Annual Respondent Burden and Cost: NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)

Burden Item (A) (B) (C) (D) (E) (F) (G) (H) Person hours per occurrence Number of

occurrences per year Person

hrs. per respondent per year (C=A*B) Respondents

per year Technical

person hrs. per year (E=C*D) Management

person hrs. per year (F=E*0.05) Clerical

person hrs. per year (G=E*0.1) Annual

costs ($)

1. Reporting requirements a. Read rule and instructions 4 1 4 71 284 14.2 28.4 30,893 b. Compile and process data 4 4 16 71 1,136 56.8 113.6 123,571 c. Write reports i. Initial notification 2 1 2 0 0 0 0 0 ii. Notification of compliance status 2 1 2 0 0 0 0 0 iii. Notification of construction/reconstruction 2 1 2 0 0 0 0 0 iv. Notification of actual startup 2 1 2 0 0 0 0 0 v. Notification of performance test 2 1.2 2.4 0 0 0 0 0 vi. Report of performance test 1 10 1.2 12 0 0 0 0 0 vii. Semiannual report 6 2 12 71 852 42.6 85.2 92,678 viii. Excess emissions report 2 2 4 71 284 14.2 28.4 30,893 ix. Startup, shutdown, malfunction report 2 2 1 2 18 36 1.8 3.6 3,916 Subtotal Reporting Labor and Cost Burden 2,981 281,951 2. Recordkeeping requirements a. Read rule and instructions 4 1 4 71 284 14.2 28.4 30,893 b. P lan activities 12 1 12 71 852 42.6 85.2 92,678 c. Implement activities 12 1 12 71 852 42.6 85.2 92,67815

Table 1. Annual Respondent Burden and Cost: NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)

Burden Item (A) (B) (C) (D) (E) (F) (G) (H) Person hours per occurrence Number of

occurrences per year Person

hrs. per respondent per year (C=A*B) Respondents

per year Technical

person hrs. per year (E=C*D) Management

person hrs. per year (F=E*0.05) Clerical

person hrs. per year (G=E*0.1) Annual

costs ($)

d. Maintain record system for material used 20 1 20 71 1,420 71 142 154,464 e. Time to enter information i. Material usage 0.5 365 182.5 71 12,958 648 1,296 1,409,484 ii. Compliance calculation 2 12 24 71 1,704 85.2 170 185,357 f. Time to train personnel 10 1 10 71 710 35.5 71 77,232 g. Store, file, and maintain records 2 12 24 71 1,704 85.2 170 185,357 h. Retrieve records/reports 1 12 12 71 852 42.6 85.2 92,678 Subtotal Recordkeeping Labor and Cost Burden 24,536 2,320,822 Total Burden (Hrs) and Costs 23,928 1,196 2,393 Totals 27,517 $2,602,77 3
Assu mptions :

1 20 percent retest 2 Estimated 25 percent of facilitie s use add

- on controls, submit startup, shutdown, malfunction report once per year.16

Table 2. Annual Agency Burden and Cost: NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK) (Renewal)

Burden Item (A) Person hour s per occurrence (B)

Number of occurrences per year (C)

Number of respondents (D)

Technical person hours per year (D=A*B*C) (E)

Management person hours per year (E=D*0.05) (F)

Clerical person hours per year (F=E*0.1) (G)

Annual costs ($) 1. Initial perfo rmance test 24 1 0 0 0 0 0 2. Repeat performance test 24 0.2 0 0 0 0 0 3. Report review a) Initial notification 8 1 0 0 0 0 0 b) Notification of performance test 8 1.2 0 0 0 0 0 c) Notification of compliance status 8 1 0 0 0 0 0 d) Notification of construction/reconstruction 8 1 0 0 0 0 0 e) Notification of actual startup 8 1 0 0 0 0 0 f) Report of performance test 8 1.2 0 0 0 0 0 g) Semiannual report 12 2 71 1,704 85.2 170.4 $88,309 h) Exc ess emissions report 4 2 71 568 28.4 56.8 $29,436 i) Startup, shutdown, report 8 1 18 144 7.2 14.4 $7,463 Total Burden (Hrs) and Costs 2,416 121 242 Totals 2,778 $125,208