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 ICR 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 manufacturing 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 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 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 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 United 

States Environmental Protection Agency (EPA) regional office.

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

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

owner/operator of the plant site).

Over the next three years, an average of 71 respondents 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 currently active Information 

Collection Request (ICR) with the following “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 entirely to work performed by Federal employees or government contractors, and may

be found 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 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 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, 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 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 compliance with 
3

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 determine 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 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 and the standards are being met. The performance test may also be 

observed.

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

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

determinations.

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 will 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 by 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 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, 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 ICR was published 

in the Federal Register (74 FR 32581) 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 ICR, the Agency’s industry experts have been 

consulted, and the Agency internal data sources and projections of industry growth over the next 

three years 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

System (AFS) which 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 industry 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 standard 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 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 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 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 the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 
5

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 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 ICR that are recorded and/or reported are required by 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 year 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 system 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 system 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 must 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 systems to transmit data electronically. However, electronic reporting systems 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 system.
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 

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 

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, 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; excess emissions reports; 

startup, shutdown, malfunction plan; and the CMS quality control plan.

Audit facility records

Input, analyze, and maintain data in the Air Facility System (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 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 the AFS which is operated and 
8

maintained by the EPA Office of Compliance. AFS is the EPA 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 by this regulation must be retained by the owner or operator for five 

years.

5(c) Small 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 ICR. The 

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

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

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

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 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 previously
9

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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 by 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 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 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 ICR are zero. This is the total of column D in the 

above table. 

The total Operating and Maintenance (O&M) costs for this ICR are $85,200. 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 $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 typically utilizes a control 
10

device that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function 

properly, and the recordation of additional measurements beyond the minimum are required by 

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 burden 

Section 6(d) below.

6(c) Estimating Agency Burden and Cost

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

information. The EPA 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 

$125,208. 

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), 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 ICR, there are approximately 71 existing sources currently 

subject to the standard. It is estimated that an additional zero sources per year will become 

subject to the regulation in the next three years.

Number of respondents is calculated using the following table which addresses the three 

years covered by 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 71
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To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 71. 

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection 

Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses 

E=(BxC)+D

Initial notification 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

Notification 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 $2,602,773. 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 total 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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 27,517. 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). Furthermore, the annual public 

reporting and recordkeeping burden for this collection of information is estimated to average 91 

hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $85,200. The 
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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 ICR compared to the previous ICR. This is 

due to two considerations: (1) the regulations have not changed over the past three years and are 

not anticipated to change over the next three years; and (2) the growth rate for the respondents is 

very low, negative or non-existent. Therefore, the labor hours in the previous ICR reflect the 

current burden to the respondents and are reiterated in this ICR.

There is an increase 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 ICR 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 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’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 burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR 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 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 
13

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

Room 3334, 1301 Constitution 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 

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, N.W., 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the 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.
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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 22 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. Plan activities 12 1 12 71 852 42.6 85.2 92,678

c. Implement activities 12 1 12 71 852 42.6 85.2 92,678
15

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 $2,602,773

Assumptions:

1

20 percent retest

2 Estimated 25 percent of facilities 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 hours 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 performance 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) Excess 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