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 2079.05, 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 were: proposed on January 15, 2003, promulgated on November 

13, 2003, and last-amended on April 20, 2006. These regulations apply to both existing and new 

facilities in this source category that: 1) use 5,700 liters (1,500 gallons) or more of coatings per 

year and; 2) constitute a major source of hazardous air pollutant (HAP). The metal can surface 

coating source category includes any facilities that either coat or print or fabricate metal cans and

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. 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 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/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

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

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

owner/operator of the plant site).

Over the next three years, an average of 71 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these standards.
2

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) without any “Terms of Clearance.”

The “Affected Public” is defined as either owners or operators of metal can 

manufacturing facilities. 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 either Federal employees or government contractors. 

This burden may be found below in Table 2: Average Annual EPA 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. 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 metal can manufacturing 

operations either cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this 

source category at 40 CFR part 63, subpart KKKK.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards at all times.

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

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

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

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, 

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 (78 FR 33409) on June 4, 2013. 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, 

maintenance, and retrieval of all compliance data. The growth rate for industry is based on our 

consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 
4

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

purposes. In developing this ICR, we contacted: 1) the Can Manufacturers Institute, at (202) 

232-4677; and 2) the American Coatings Association, at (202) 462-6272.

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

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

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

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

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

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

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

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

nonexistence of essential records.

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.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of metal can manufacturing facilities. The United States Standard Industrial Classification (SIC)

codes and corresponding North American Industry Classification System (NAICS) codes are 

presented in the following table.

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

Metal Can Manufacturing 3411 332431

Metal Crown, Closure, and Other Metal Stamping 

(except Automotive)

3466 332119

Metal Coating, Engraving (except Jewelry and 

Silverware), and Allied Services to Manufacturers

3999 332812

All Other Miscellaneous Fabricated Metal Product 

Manufacturing

3497 332999

4(b) Information Requested

(i) Data Items

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

Can Manufacturing Surface Coating (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)
6

Reports

Semiannual report 63.3511(a)

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. 
7

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 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.

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.

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, 
8

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 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 

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

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. 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. During 

rulemaking for subpart KKKK, EPA identified 13 small businesses that are subject to this rule. 

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 
9

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. 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 27,517 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

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

September 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.
10

(ii) Estimating Capital/Startup and Operation 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 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 monitors 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)

CEM $16,000 0 $0 $1,200 71 $85,200

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

above table. 

The total operation 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/start-up 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 

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

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

emissions, and the publication and distribution of collected information. 
11

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), 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 Metal 

Can Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 71 existing respondents will be subject 

to these standards on an average over the next three years. 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 71 per year.

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

years covered by this ICR. 

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 71 0 0 71

2 0 71 0 0 71

3 0 71 0 0 71

Average 0 71 0 0 71

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 71.

The total number of annual responses per year is calculated using the following table:
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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 $3,173,600. 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).

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 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 27,517 hours at a cost of $3,173,600. 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 

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

(O&M) Costs.

(ii) The Agency Tally
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The average annual Agency burden and cost over the next three years is estimated to be 

2,778 labor hours at a cost of $125,208;see below Table 2: Average Annual EPA 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. However, there is an adjustment 

increase in the respondent cost due to labor rate increases.

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 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-2013-0345. An electronic version of the public docket is 

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

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

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

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

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

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

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

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

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 
14

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-2013-0345 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.
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

No. of 

occurrences 

per 

respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per 

year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

1. Reporting Requirements

 a. Read rules and instructions 4 1 4 71 284 14.2 28.4 $37,668.06

 b. Compile and process data 4 4 16 71 1,136 56.8 113.6 $150,672.22

 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 c2 1.2 2.4 0 0 0 0 $0

vi. Report of performance test c10 1.2 12 0 0 0 0 $0

vii. Semiannual report e6 2 12 71 852 42.6 85.2 $113,004.17

viii. Excess emissions report f2 2 4 71 284 14.2 28.4 $37,668.06

ix. Startup, shutdown, malfunction report d2 1 2 18 36 1.8 3.6 $4,774.82

Subtotal for Reporting Requirements 2,980.8 $343,787.33

2. Recordkeeping requirements

 a. Read rules and instructions 4 1 4 71 284 14.2 28.4 $37,668.06

 b. Plan activities 12 1 12 71 852 42.6 85.2 $113,004.17

 c. Implement activities 12 1 12 71 852 42.6 85.2 $113,004.17

 d. Maintain record system for material used 20 1 20 71 1,420 71 142 $188,340.28

 e. Time to enter information

i. Material usage g0.5 365 182.5 71 12,957.5 647.88 1,295.75 $1,718,605.06

ii. Compliance calculation h2 12 24 71 1,704 85.2 170.4 $226,008.34

 f. Time to train personnel 10 1 10 71 710 35.5 71 $94,170.14

 g. Store, file, and maintain records h2 12 24 71 1,704 85.2 170.4 $226,008.34

 h. Retrieve records/reports i1 12 12 71 852 42.6 85.2 $113,004.17

Subtotal for Recordkeeping Requirements 24,535.83 $2,829,812.73
16

Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per 

year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

TOTAL ANNUAL BURDEN AND COST (rounded) 27,517 $3,173,600

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 71 existing sources. There will be no additional sources over the

three-year period of this ICR. 

b This ICR uses the following labor rates: $101.28 for technical, $122.49 for managerial, and $50.80 for clerical labor. These rates are from the United States

Department of Labor, Bureau of Labor Statistics, September 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

 This ICR assumes a re-test rate of 20 percent.

d This ICR assumes twenty-five percent of facilities use add-on controls and submit startup, shutdown, malfunction reports once per year.

e

 We have assumed that it will take each respondent 2 hours two time per year to compile semiannual reports.

f

 We have assumed that each respondent will take two hours two time per year to complete the excess emissions report.

g

 We have assumed that each respondent will take 0.5 hours 365 times per year to enter material usage.

h

 We have assumed that each respondent will take 2 hours once per month to complete task.

i

 We have assumed that each respondent will take 1 hour once per month to retrieve records/reports.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Metal Can Manufacturing Surface Coating (40 CFR Part 63, 

 Subpart KKKK) (Renewal)

Activity

A B C D E F G H

EPA hours 

per 

occurrence

No. of 

occurrences 

per year

EPA

hours per 

respondent 

per year 

(AxB)

Plants per 

year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b

($)

1. Initial performance test 24 1 24 0 0 0 0 $0

2. Repeat performance test 24 0.2 5 0 0 0 0 $0

3. Report review

 a. Initial notification 8 1 8 0 0 0 0 $0

 b. Notification of performance test 8 1.2 10 0 0 0 0 $0

 c. Notification of compliance status 8 1 8 0 0 0 0 $0

 d. Notification of 

construction/reconstruction 8 1 8 0 0 0 0 $0

 e. Notification of actual startup 8 1 8 0 0 0 0 $0

 f. Report of performance test 8 1.2 10 0 0 0 0 $0

 g. Semiannual report c12 2 24 71 1,704 85.2 170.4 $88,308.95

 h. Excess emissions report d4 2 8 71 568 28.4 56.8 $29,436.32

 i. Startup, shutdown, malfunction report e8 1 8 18 144 7.2 14.4 $7,462.73

TOTAL ANNUAL BURDEN AND COST (rounded) 2,778 $125,208

Notes and Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 71 existing sources. There will be no additional sources over

the three-year period of this ICR. 

b

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2011 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.

c

 We have assumed that it will take each respondent 12 hours two time per year to review the semiannual report.

d

 We have assumed that each respondent will take 4 hours two time per year to review the excess emissions report.

e

 We have assumed that 25 percent of respondents will each take 8 hours one time per year to review the startup, shutdown, malfunction report.