SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal), 

EPA ICR Number 0663.12, OMB Control Number 2060-0001. 

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Beverage Can Surface Coating were 

proposed on November 26, 1980, promulgated on August 25, 1983, and most-recently amended 

on October 17, 2000. These regulations apply to each operation of the following surface coating 

lines in the Beverage Can Surface Coating industry: 1) exterior base; 2) over-varnished; and 

3) inside spray. New facilities include those that commenced construction, modification, or 

reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 60, Subpart WW.

In general, all NSPS 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 NSPS. 

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

measurements, and retain the file for at least two 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.

The “Affected Public” are private-sector businesses that coat beverage cans. The 

“burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and 

Cost – NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal). The 

Federal Government’s “burden” is attributed entirely to work performed by either Federal 

employees or government contractors and may be found below in Table 2: Average Annual EPA 

Burden and Cost – NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) 

(Renewal). 

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

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

owner/operator of the plant site).
2

Over the next three years, approximately 48 respondents per year will be subject to the 

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

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

without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years. 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, volatile organic compound (VOC) emissions from 

beverage can coating facilities either cause or contribute to air pollution that may reasonably be 

anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for 

this source category at 40 CFR Part 60, Subpart WW.

2(b) Practical Utility/Users of the Data
3

The recordkeeping and reporting requirements in these standard ensure compliance with 

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

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

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

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

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and 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 60, Subpart

WW.

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

burden published in the Federal Register.

3(c) Consultations
4

The Agency’s industry experts have been consulted, and the Agency’s 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 standards, is the Integrated Compliance Information System 

(ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data 

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

consultations with the Agency’s internal industry experts.

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

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the American Coatings Association (ACA), at (202) 719-3703, and 

the Association of Industrial Metallizers, Coaters and Laminators (AIMCAL), at (803) 802-7820. 

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

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

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

3(f) Confidentiality

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

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

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

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

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

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes
5

The respondents to the recordkeeping and reporting requirements are beverage can 

surface coating facilities. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 3411, which corresponds to the North American 

Industry Classification System (NAICS) code 332431 for Metal Can Manufacturing. 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Beverage 

Can Surface Coating (40 CFR Part 60, Subpart WW). 

A source must make the following reports:

Notifications

Construction/reconstruction 60.7(a)(1) 

Anticipated startup 60.7(a)(2)

Actual startup 60.7(a)(3)

Notification of initial performance test 60.8(d)

Physical or operational change 60.7(a)(4)

Reports

Initial performance test results 60.8 (a), 60.495(a)

Demonstration of continuous monitoring system 60.7(a)(5)

Semiannual report 60.7(c), 60.495(c)

Excess emissions report 60.7(c), 60.495(c)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative 60.7(b)

Monthly performance test 60.493(b)

Records are required to be retained for two years. The first two years 

of records must be retained at the facility.

60.495(d)

Maintain a file of all measurements including the monitoring device, 60.7(e)
6

Recordkeeping

and performance testing measurements, and monitoring device 

calibrations, checks, adjustments and maintenance performed on these 

devices.

Maintain daily records of incinerator combustion temperature, or 

amounts of solvent recovered. 60.494(c)

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate a device that continuously records the combustion 

temperature of any effluent gases incinerated to achieve compliance.

Perform initial performance test, Reference Method 24 or 25 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.
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5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Enforcement and Compliance History Online (ECHO) 

and ICIS. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source 

to determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to 

comply with the emission standard and note the operating conditions under which compliance 

was achieved. Data and records maintained by the respondents are tabulated and published for 

use in compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

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

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

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

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

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

years.

5(c) Small Entity Flexibility

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

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

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 
8

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 – NSPS for Beverage Can 

Surface Coating (40 CFR Part 60, Subpart WW) (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 5,190 (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 NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 
9

subject standard(s) are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

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

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

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Temperature 8,000 0 $0 $2,100 48 $100,800

TOTAL 1

$101,000

1 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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 $101,000. This is the 

total of column G. 

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

industry over the next three years of the ICR is estimated to be $101,000. These are the costs 

of record-keeping.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions, and the publication and distribution of collected information. 

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

$12,600. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 General Schedule,
10

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 – NSPS for Beverage 

Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

48 existing respondents will be subject to the standard. 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 48 per year. 

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

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 48 0 0 48

2 0 48 0 0 48

3 0 48 0 0 48

Average 0 48 0 0 48

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 48. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of 

construction/reconstruction

0 1 0 0

Notification of performance test 0 1.2 0 0
11

Total Annual Responses

Notification of actual startup 0 1 0 0

Report of performance test 0 1.2 0 0

Semiannual report 48 2 0 96

Excess emissions report 48 0.5 0 24

Total 120

The number of Total Annual Responses is 120. 

The total annual labor costs are $522,000 (rounded). Details regarding these estimates 

may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Beverage Can 

Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 5,190 hours (rounded). Details regarding these estimates 

may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Beverage Can 

Surface Coating (40 CFR Part 60, Subpart WW) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

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

information is estimated to average 43 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $101,000. The 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 276

labor hours at a cost of $12,600. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).
12

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden from the most recently

approved ICR. The increase in respondent labor hour is caused by a change in assumption; 

in this ICR, we assume all existing sources will take some time each year to re-familiarize 

themselves with the rule requirements. The small increase in the total O&M cost is due to 

rounding; the total estimated costs have been rounded to three significant digits in this ICR. 

6(g) Burden Statement

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

is estimated to average 43 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2012-0532. An electronic version of the public docket is 

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

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

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

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

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

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

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

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

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

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

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 
13

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

Number EPA-HQ-OECA-2012-0532 and OMB Control Number 2060-0001 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 – NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) 

(Renewal)

Burden item

(A)

Person-hours 

per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(D) 

Respondents 

per yeara

(E)

Technical 

personhours per 

year

(F)

Management 

person-hours 

per year

(G) Clerical 

person 

hours per 

year

(H) Cost b $

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

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Familiarize with rule requirements 1 1 1 48 48 2.4 4.8 $5,551.01

 B. Required activities

 Initial Performance Test 60 1 60 0 0 0 0 $0 

 Repeat Performance Test 60 0.2 12 0 0 0 0 $0 

 C. Gather Existing Information See 3B

 D. Write report 0 0 0 0 0 $0 

 i. Notification of construction/ reconstruction 2 1 2 0 0 0 0 $0 

 ii. Notification of initial performance test 2 1 2 0 0 0 0 $0 

 iii. Notification of actual startup 2 1 2 0 0 0 0 $0 

 iv. Report of performance test See 3B

 v. Semiannual report 8 2 16 48 768 38.4 76.8 $88,816.09 

 vi. Excess emissions report 5 0.5 2.5 48 120 6 12 $13,877.51 

Subtotal for Reporting Requirements 1,076 $108,244.61

5. Recordkeeping Requirements 

 A. Familiarize with rule requirements See 3A

 B. Plan activities See 3B

 C. Implement activities (Monthly Performance Test) 1 12 12 48 576 28.8 57.6 $66,612.07 
15

Burden item

(A)

Person-hours 

per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(D) 

Respondents 

per yeara

(E)

Technical 

personhours per 

year

(F)

Management 

person-hours 

per year

(G) Clerical 

person 

hours per 

year

(H) Cost b $

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

 D. Develop record system N/A

 Records of operating parameter 0.25 250 62.5 48 3,000 150 300 $346,937.85 

Subtotal for Recordkeeping Requirements 4,112 $413,549.92 

TOTAL ANNUAL BURDEN AND COSTS 

(rounded): f5,190 $522,000

Capital and O&M Cost (see Section 6(b)(iii)): f

$101,000

TOTAL COST: f

$623,000

a Assumes an average of 48 affected facilities, with no new plants coming online.

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, Table 2. Civilian 

Workers, by occupational and industry group. The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

c

 Assumed 20% rate of failed performance tests.

d

 Each plant files an excess emission report every other year and a semiannual report twice a year.

e

 Assume operation 250 days per year as specified in the NSPS review document.

f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
16

Table 2: Average Annual EPA Burden and Cost – NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) 

(Renewal)

Activity

(A)

EPA personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(D)

Plants per 

year

(E)

Technical 

personhours per 

year

(F)

Management 

person-hours 

per year

(G)

Clerical 

personhours per 

year

(H)

Costa$

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

1. Initial Performance Test 24 1 24 0 0 0 0 $0

2. Repeat Performance Test 24 1 24 0 0 0 0 $0

3. Report Review

A. New Plants

i. Notification of Construction 2 1 2 0 0 0 0 $0

ii. Notification of Initial Startup 0.5 1 0.5 0 0 0 0 $0

iii. Notification of Actual Startup 0.5 1 0.5 0 0 0 0 $0

iv. Notification of Initial Test 0.5 1.2 0.6 0 0 0 0 $0

v. Review Test Results 8 1.2 9.6 0 0 0 0 $0

B. Existing Plants

i. Semiannual Reports 2 2 4 48 192 9.6 19.2 $10,049.59

ii. Excess Emissions Reports 2 0.5 1 48 48 2.4 4.8 $2,512.40

TOTAL ANNUAL BURDEN AND COST 

(rounded): d276 $12,600

Assumptions:

a

 Assumes an average of 48 affected facilities, with no new plants coming online.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

$62.90 (GS-13, Step 5, $39.31 + 60%) for Managerial, $46.67 (GS-12, Step 1, $29.17 + 60%) for Technical, and $25.25 (GS-6, Step 3, $15.78 + 60%) for 

Clerical. These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.
17

c

 Assumed 20% rate of failed performance tests.

d Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.