**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 I CR 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

- recentl y am ended on October 17, 2000. These regulations apply to each operation of the following surface coating lines in the Beverage Can Surface Co ating 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 s ys tem 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 directl y 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 F ederal 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 ye ars, approximately 48 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the standard s . The Office of Management and Budg et ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance. ”
**2. Need for and Use of the C ollection**  **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 Administrat or determines has been adequatel y 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 reasonabl y 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 reasonabl y 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 the se 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 affecte d facility ’ s initial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the se standard s 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 che ck if the pollution control devices are properl y installed and operated , leaks are being detected and repaired , and the standard s are being met. The performance test may also be observed. The requir ed 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report s ubmitted 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 an d 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 recordkeep ing and reporting provisions in the standard s , is the Integrated Compliance Information Sy stem (I CI S). IC IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. The growth rat e 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 devel oped. In developing this I CR, 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 emissio n limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines** The se reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 ( SI C ) code for the respondents affected b y the standards is SI C 3411 , which correspond s 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 b y the NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW )

. A source must make the following reports:

**Notification s**  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) Phy sical or operational change 60.7(a)(4)
**Reports** Initial performance test results 60.8 (a), 60.495(a) Demonstration of continuous monitoring sy stem 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 sy stem is inoperative 60.7(b) Monthly performance test 60.493(b) Records are required to be retained for two ye ars. 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 recordke eping 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of pro cessing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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.7

**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, anal yz e, and maintain data in Enforcement and Compliance History Online (ECHO) and I CI S. **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 properl y installed and operated. Performance test reports are used b y 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 b y 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 f or compliance determinations.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices a nd EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for two ye ars. **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 operation s and the ty pes 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 minimum8

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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden unde r 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 col lection 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 requirement s is estimated to be 5,1 9 0 ( 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 I CR uses the following labor rates: Managerial $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 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 b y 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 ty pe of industry

costs associated with the information collection activities in the9

subjec t standard(s) are both labor costs which are addressed elsewhere in this I CR 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)
Tem perature 8,000 0 $0 $2,100 48 $ 10 0 , 8 00 **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 I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 10 1 , 0 00

. 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 ye ars of the IC R is estimated to be $ 10 1 , 0 00

. 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 anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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 hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 5 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 I CR, on average over the next three ye ars, approximately 48 existing respondents will be subject to the standard. It is estimated that no additional respon dents per ye ar 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 ye ars covered b y this ICR.

**Number of Respondents** 

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 48

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction 0 1 0 0 Notification of performance test 0 1.2 0 011 **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 $5 22 ,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 , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 5,1 9 0 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 ty

pical tasks for manager s are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical 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 ty

pical 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 ty pical 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 I CR, we assume all existing sources will take some time each ye ar 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 I CR. **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 b y persons to generate, maintain, retain, or disclo se or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 201 2

- 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 do cuments in the public docket that are available electronically

. When in the sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 20 12

- 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.14

**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)

Person

hours per respondent per year (D)

Respondents per yeara (E)

Technical person hours 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 1,0**  **76 $10**  **8 ,**  **244 .6** **1** 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 $66,612.0715

Burden item (A) Person

- hours per occurrence (B)

No. of occurrence per respondent per year (C)

Person

hours per respondent per year (D)

Respondents per yeara (E)

Technical person hours 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): f**  **5,1 9**  **0 $522**  **,000 Capital and O&M Cost (see Section**  **6(b)(iii)): f**  **$ 101,000**  **TOTAL COST: f**  **$ 6**  **23 ,000** 

a Assumes an average of 48 affected fac ilities, 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. Civili an Workers, by occupational and industry group. The rates are from column 1, “Total compensation.” The rates have been increas ed 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 person

hours per occurrence (B)

No. of occurrences per plant per year (C)

EPA person hours per plant per year (D)

Plants per year (E)

Technical person hours per year (F) Management person - hours per year (G)

Clerical person hours 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. No tification 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):**  **d 276**  **$12,600**
**Assu mptions:** 

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, $1 5.78 + 60%) for Clerical. These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rate s of pay.17

c Assumed 20% rate of failed performance tests.
d Totals have been rounded to 3 significant values. F igures may not add exactly due to rounding.