SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
Subpart
KKKK
Metal
Cans
(
Surface
Coating)

1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.
"
Monitoring,
Recordkeeping,
and
Reporting
Requirements
for
the
Metal
Can
Manufacturing
(
Surface
Coating)
National
Emission
Standard
for
Hazardous
Air
Pollutants."
This
is
a
new
information
collection
request
(
ICR)
and
the
tracking
number
is
EPA
ICR
No.
2079.01.

(
b)
Short
Characterization.
This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
rulemaking
amends
Title
40,
Chapter
I,
Part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
subpart
KKKK­­
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Surface
Coating
of
Metal
Cans.
Hereafter,
this
subpart
is
referred
to
as
the
"
metal
can
NESHAP."
The
metal
can
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
Respondents
are
owners
or
operators
of
facilities
that
perform
surface
coating
operations
on
metal
cans.
Metal
can
manufacturing
surface
coating
operations
include
any
facilities
that
coat
or
print
metal
cans
or
metal
can
parts
(
e.
g.,
metal
ends
for
composite
cans).
It
includes
the
coating/
printing
of
metal
sheets
for
subsequent
processing
into
cans
or
can
parts,
but
not
the
coating
of
metal
coil(
s)
for
cans
or
can
parts.
This
source
category
also
includes
the
coating/
printing
of
metal
decorative
tins,
crowns,
and
closures
(
except
for
coil
coating).
It
is
estimated
that
142
major
source
facilities
are
subject
to
the
provisions
of
this
NESHAP
in
the
United
States
and
must
be
in
compliance
with
the
requirements
of
the
metal
can
NESHAP
within
3
years
of
the
effective
date
(
promulgation
date)
of
the
rule.
No
new
growth
is
expected
in
the
metal
can
surface
coating
industry.

Respondents
to
this
ICR
are
required
to
submit
a
detailed
listing
of
coatings
and
solvents
used
during
coating
and
thinning
operations.
This
report
should
include
the
amount
of
material
used,
the
amount
of
solids
content
in
the
material
as
a
volume
percentage,
a
breakdown
of
HAPs
contained
in
each
material,
and
an
overall
average
of
HAP
content
expressed
in
units
of
mass
of
organic
HAP
per
volume
of
solids.
For
sources
using
addon
control
devices
to
lower
HAP
emissions,
the
report
must
also
include
the
capture
and
control
efficiencies
achieved
by
the
add­
on
control
device.
All
information
should
be
collected
on
a
monthly
basis
and
submitted
on
a
semiannual
basis,
with
the
requirement
that
the
12­
month
rolling
average
organic
HAP
emission
rate
not
exceed
the
limit
set
forth
by
this
NESHAP.
All
records
should
be
maintained
for
a
period
of
5
years
and
should
be
maintained
at
the
source
for
a
period
of
at
least
2
years.
2
The
metal
can
NESHAP
also
requires
existing
and
new
or
reconstructed
affected
sources
to
submit
a
one­
time
Initial
Notification.
This
Initial
Notification
must
be
submitted
no
later
than
120
calendar
days
after
the
promulgation
date
of
the
subpart.

Owners
and
operators
of
affected
sources
are
subject
to
the
requirements
of
40
CFR
Part
63,
Subpart
A,
the
General
Provisions,
unless
the
regulation
specifies
otherwise.

The
metal
can
NESHAP
also
requires
affected
sources
to
submit
a
Notification
of
Compliance
Status.
This
notification
must
be
signed
by
a
responsible
company
official
who
certifies
its
accuracy
and
certifies
that
the
source
has
complied
with
the
standards.
In
addition,
the
affected
sources
using
add­
on
control
devices
to
meet
the
requirements
of
the
standard
are
required
by
the
Administrator
to
conduct
a
performance
test
of
the
addon
control
device.
The
results
of
the
performance
test
must
be
submitted
to
the
EPA
in
the
Notification
of
Compliance
Status.

For
new
or
reconstructed
and
existing
sources,
the
Notification
of
Compliance
Status
must
be
submitted
1
year
and
30
days
following
the
compliance
date,
and
must
include
the
results
of
the
performance
test
(
if
performance
testing
is
required).

Periodic
reports
documenting
deviations
are
also
required
to
be
submitted
to
the
EPA
semiannually
to
demonstrate
compliance.
The
periodic
reports
must
also
contain
documentation
of
inspections
and
a
statement
that
no
deviations
occurred
during
the
reporting
period,
if
appropriate.

The
metal
can
NESHAP
requires
owners
or
operators
to
develop
a
startup,
shutdown,
and
malfunction
plan
(
SSMP),
documenting
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
Startup,
shutdown,
and
malfunction
reports
also
are
required
to
be
submitted
that
demonstrate
that
the
actions
taken
by
an
owner
or
operator
during
a
startup,
shutdown,
or
malfunction
event
comply
with
the
SSMP.
When
actions
taken
are
consistent
with
the
plan,
reports
are
required
semiannually.
When
actions
taken
are
inconsistent
with
the
plan,
immediate
reports
are
required.

Each
facility
is
required
to
submit
all
necessary
reports
to
the
respondent's
Regional,
State,
local
or
tribal
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
that
all
sources
subject
to
the
NESHAP
are
achieving
the
requirements.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.
The
EPA
is
charged
under
Section
112(
d)
of
the
CAA
to
establish
standards
to
limit
HAP
emissions
from
stationary
sources.
In
the
Administrator's
judgment,
the
metal
can
manufacturing
surface
coating
industry
causes
or
contributes
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Metal
can
3
manufacturing
surface
coating
operations
are
listed
as
an
affected
source
category
in
a
Federal
Register
notice
dated
July
16,
1992
(
see
57
FR
31576.)

Section
114
of
the
CAA
gives
the
EPA
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to:
(
1)
identify
new
or
reconstructed
and
existing
sources
subject
to
the
metal
can
NESHAP,
and
(
2)
ensure
that
the
metal
can
NESHAP,
based
on
maximum
achievable
control
technology
(
MACT)
for
major
sources,
is
being
achieved.

(
b)
Use/
Users
of
the
Data.
The
EPA's
enforcement
personnel
will
use
the
emissions
data
collected
by
each
metal
can
surface
coating
facility
to
(
1)
identify
new
or
reconstructed
and
existing
organic
HAP
emission
sources
subject
to
the
metal
can
NESHAP,
(
2)
identify
the
emission
control
devices
and
control
methodologies
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
control
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

The
records
and
reports
will
also
be
useful
in
identifying
facilities
that
are
out
of
compliance
with
the
terms
of
the
metal
can
NESHAP.
Based
on
the
reported
information,
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
indicates
to
EPA
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
control
methodologies
properly.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.
A
search
of
the
EPA's
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
metal
can
NESHAP.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
metal
can
NESHAP.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
Since
this
is
a
rule­
related
ICR,
it
is
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
ICR
to
OMB.
However,
a
public
review
and
comment
period
will
occur
after
proposal
of
the
metal
can
NESHAP
in
the
Federal
Register.

(
c)
Consultations.
Consultations
were
conducted
with
various
representatives
of
industry,
coating
suppliers,
and
trade
associations
during
the
development
of
the
metal
can
NESHAP.
The
following
persons
provided
input
during
development
of
the
rule:
4
Name
Affiliation
Telephone
Thomas
Alcaro
Exal
Corporation
330­
744­
2267
Pat
Aluotto
BASF
513­
576­
3132
Mike
Antry
Crown
Cork
&
Seal
Company
215­
698­
5308
Joette
Bailey
Ball
Corporation
303­
460­
5433
David
Bittner
Valspar
412­
734­
8677
Cheryl
Bradley
Oklahoma
Department
of
Environmental
Protection
Bob
Brady
Coors
Brewing
Company
303­
277­
2196
Dan
Brennan
The
Glidden
Company
440­
826­
5150
Robert
Budway
Can
Manufacturers
Institute
202­
232­
4677
Ron
Butcher
Technical
Coatings
7­
8­
786­
4334
Stephen
Byrne
Cytec
Industries
908­
862­
6000
ext
231
Tim
Case
Ball
Corporation
303­
460­
5239
Glenn
Ceckowski
J.
L.
Clark,
Incorporated
815­
961­
5686
William
Chelak
ARCO
Chemical
610­
359­
7091
Jun
Choi
Central
Can
Company
773­
254­
8700
Stacy
Coburn
Ohio
EPA
Division
of
Air
Pollution
Control
614­
644­
4837
John
Cook
Watson
Standard
Dennis
Cornish
Silgan
Containers
Corporation
818­
710­
3791
Donna
Cosper
TNRCC
Office
of
Air
Quality,
New
Source
Review­
Permits
Division,
COCO
Section
512­
239­
1301
Lee
Cox
Independent
Can
Company
410­
272­
0090
Fran
Craner
New
York
State
DEC
Division
of
Air
Resources
518­
457­
7688
Geoff
Cullen
Can
Manufacturers
Institute
202­
232­
4677
David
Curreri
W.
R.
Grace
&
Company
617­
498­
4915
Bill
Danielson
CCL
Container
Corp.
­
Adv.
Monobloc
Aerosol
Div.
724­
981­
4420
Manish
Desai
Can
Corporation
of
America,
Inc.
610­
926­
3044
Kirk
Drucker
Georgia
DNR,
Air
Protection
Branch
404­
363­
7097
Susan
Eastridge
Shell
Chemical
Company
713­
241­
5985
Joseph
Eller
South
Carolina
DHEC
516­
444­
0212
Charles
Erikson
Campbell
Soup
Company
609­
342­
6458
Name
Affiliation
Telephone
5
Ralph
Fasano
White
Cap
Incorporated
773­
804­
3579
Don
Fay
AKZO
Nobel
847­
295­
2729
Mark
Finch
Silgan
Containers
Corporation
414­
569­
5240
Barbara
Francis
CMA
703­
741­
5609
John
Friedman
Darco
Metal
312­
243­
3000
Alan
Gans
U.
S.
Can
Company
847­
888­
5538
Robert
Gere
Mostardi­
Platt
Associates,
Inc.
630­
993­
9000
Don
Gust
Silgan
Containers
Corporation
414­
569­
5279
Marc
Himmelstein
National
Environmental
Strategies
202­
333­
2524
Stephanie
John
Dexter
Packaging
Products
847­
625­
4443
Alison
Keane
National
Paint
&
Coatings
Association
202­
462­
6272,
ext.
248
John
Koch
Watson
Standard
412­
362­
8300
Lee
Landauer
The
Valspar
Corporation
501­
359­
2438
Robert
Lanham
Metal
Container
Corporation
314­
957­
0769
Ron
Leisner
PPG
Industries
513­
576­
3046
Bob
Levanduski
PPG
Industries
614­
363­
9610
Michael
Levin
Leonard
Hurt
202­
223­
2500
Charles
Licht
Charles
Licht
Engineering
Associates,
Inc.
708­
333­
6669
Joe
McCloskey
Benjamin
Moore
&
Co.
201­
252­
2651
Andrew
Miles
Dexter
Packaging
Products
205­
854­
5454
Dwayne
Mock
Valspar
Corporation
Packaging
Coatings
Group
800­
873­
5575
Tim
Moczulewsi
AKZO
Nobel
Coatings
847­
872­
1000,
ext.
269
Elizabeth
Munsey
Georgia
DNR,
Air
Protection
Branch
404­
363­
7113
Hank
Naour
Illinois
EPA
217­
785­
4140
Bob
Nelson
National
Paint
&
Coatings
Association
202­
462­
6272
Dan
Nickey
Iowa
Waste
Reduction
(
small
business)
319­
273­
2079
Carol
Niemi
C.
J.
Consulting
571­
631­
4923
Venkata
Panchakarla
Florida
DEP
904­
488­
0114
Leon
Parker
Bway
Corportation
513­
388­
2219
Name
Affiliation
Telephone
6
David
Pennings
PPG
Industries
614­
363­
9610
Sueanne
Pfifferling
Pfifferling
&
Associates,
Inc.
(
CMI
Consultant)
202­
363­
0334
Marlin
Plejdrup
Smith
Environmental
Engineering
Corporation
909­
923­
3331
Dean
Pusch
Anheuser­
Busch
Companies
314­
577­
4162
Samuel
Ragusa
CCL
Containers
Corporation
Douglas
Raymond
Sherwin
Williams
216­
498­
6049
Steve
Roosz
CCL
Containers
Corporation
724­
837­
8558
Alexander
Ross
RadTech
International
North
America
703­
534­
9313
Robert
Scheibe
Peerless
Tube
Company
973­
743­
5100
Jason
Schnepp
Illinois
EPA
217­
782­
7395
Greg
Staiti
International
Technology
(
IT)
Corporation
423­
690­
3211
Kris
Sterns
National
Coatings,
Inc.
309­
342­
4184
Robert
Strieter
The
Aluminum
Association,
Inc.
202­
862­
5132
Vernon
Taylor
Reynolds
Metals
Company
804­
743­
5174
Terry
Taylor
Ohio
Art
Company
419­
636­
3141
Bob
Tragert
W.
R.
Grace
&
Co.
617­
861­
6600,
ext.
2283
Robert
Tucker
Sexton
Can
Company
304­
267­
8923
Greg
Verret
ERM­
North
Central
office
314­
928­
0300
Richard
Wilson
National
Environmental
Strategies
202­
333­
2524
Geoff
Wortley
Rexam
Beverage
773­
399­
3389
Ken
Zarker
TNRCC
EXEC
Pollution
Prevention
&
Modeling
512­
239­
3145
(
d)
Effects
of
Less
Frequent
Collection.
If
results
were
collected
less
frequently,
there
would
be
little
assurance
that
each
source
was
in
compliance
during
the
previous
12­
month
period,
as
the
rule
requires.
Also,
the
EPA's
authority
to
take
administrative
action
would
be
reduced.

(
e)
General
Guidelines.
None
of
the
monitoring,
recordkeeping,
or
reporting
requirements
contained
in
40
CFR
Part
63
Subpart
KKKK
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.5.
7
(
f)
Confidentiality
Confidential
business
information
will
be
handled
using
Agency
guidelines
on
confidentiality,
set
forth
in
Title
40
Chapter
1,
Part
2
Subpart
B
­
Confidentiality
of
Business
Information
(
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).

(
g)
Sensitive
Questions.
Information
to
be
reported
consists
of
emission
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAICS
Codes.
Respondents
are
owners
or
operators
of
facilities
that
surface
coat
metal
cans.
The
following
is
a
list
of
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
the
metal
can
industry.
Respondents
in
these
NAICS
codes
are
only
affected
if
surface
coating
operations
are
performed
on
site.

The
NAICS
codes
for
the
respondents
affected
by
this
standard
include:
332431
­
Metal
Can
Manufacturing
332115
­
Crown
and
Closure
Manufacturing
332116
­
Metal
Stamping
332812
­
Metal
Coating,
Engraving
(
except
Jewelry
and
Silverware),
and
Allied
Services
to
Manufacturers
332999
­
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
This
list
is
not
meant
to
be
exhaustive;
other
NAICS
codes
could
be
included
if
the
facility
fulfills
the
definition
of
a
metal
can
and
performs
surface
coating.

(
b)
Information
Requested.
(
i)
Data
items,
including
recordkeeping
requirements
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
KKKK.
All
major
sources
must
fulfill
these
requirements.
8
Notifications
Initial
Notification
63.3510
(
b),
63.5(
d),
63.9(
b)

Notification
of
Compliance
Status
63.3510
(
c),
63.9(
h)

Notification
of
Intent
to
Conduct
Performance
Test
63.7(
b)(
1),
63.8(
e)(
2),
63.9(
e)

Performance
test
and
evaluation
63.3510
(
c)(
9)(
ii),
63.7(
a),
63.7(
c),
63.7(
d),
63.7(
e),
63.7(
g),
63.8(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Notification
of
alternative
monitoring
method
63.8(
f)(
4)

Waiver
of
monitoring,
recordkeeping,
or
reporting
requirements
63.10(
f)

Additional
notifications
63.9(
c),
63.9(
d),
63.9(
g)(
1),
63.9(
g)(
2),
63.9(
j)

Reports
Startup,
shutdown,
malfunction
reports
63.3520
(
c),
63.6(
e)(
3),
63.10(
d)(
5)(
i),
63.10(
d)(
5)(
i)

Semiannual
compliance
report
63.3520
(
a),
63.10(
e)

Deviation
and
CMS
performance
reports
63.10(
a)

Performance
test
reports
63.3520(
b),
63.10(
d)(
2),
63.10(
e)

Monitoring
and
Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

Emission
test
results
and
other
data
needed
to
determine
emissions,
operating
parameters,
etc.
63.3530(
b),
63.3530
(
c),
63.3530
(
d),
63.3530(
e),
63.3530(
f),
63.3530
(
g),
63.3530
(
h),
63.3530
(
k)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.3530(
c)(
5),
63.10(
b),
63.10(
c)

Records
of
maintenance
63.10(
b)(
2)

Startup,
shutdown,
and
malfunction
records
63.10(
b)(
2)(
i)
­
(
iv)

Records
for
initial
notification
and
notification
of
compliance
status
63.10(
b)(
2)(
xiv)
9
Records
are
required
to
be
retained
for
5
years.
All
MACT
standards
require
5
years
of
record
retention.
The
first
2
years
of
records
must
be
kept
onsite.

(
ii)
Respondent
Activities
Read
regulation.
Apply
for
waiver,
if
applicable.
Technical
activities:
Train
coating­
related
personnel.
Set­
up
and
maintain
coating
data
spreadsheet
for
regulation
compliance.
Supervise
performance
test.
Write
Initial
Notification.
Write
Notification
of
Intent
to
Conduct
Performance
Test.
Write
Performance
Test
Report.
Write
Compliance
Status
Report.

5.
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.
Attend
add­
on
control
device
performance
testing.
Repeat
performance
test.
A.
Retesting
preparation.
B.
Attend
retesting.
Deviations­­
enforcement
activities.
Reporting
requirements.
A.
Review
regulation.
B.
Review
waivers.
C.
Review
Initial
Notification.
D.
Review
performance
test
report.

(
b)
Collection
Methodology
and
Management.
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
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
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
The
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
10
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
5
years
and
maintained
at
the
site
for
2
years.

(
c)
Small
Entity
Flexibility.
This
industry,
including
small
businesses,
should
routinely
track
the
amount
of
coatings
and
thinning
solvents
used
for
costing
purposes,
via
purchase
orders
or
receipts.
The
monitoring,
recordkeeping,
and
reporting
burden
is
the
same
for
all
entities,
regardless
of
size.
The
requirements
are
viewed
by
the
agency
as
the
minimum
needed
to
ensure
compliance
and
cannot
reduce
them
further
for
small
entities.

(
d)
Collection
Schedule.
Collection
of
data
will
begin
after
the
promulgation
date
of
the
metal
can
NESHAP,
tentatively
scheduled
for
The
schedule
for
reports
required
by
the
metal
can
NESHAP
and
the
General
Provisions
is
detailed
below.

The
Initial
Notification
is
due
not
later
than
120
calendar
days
after
the
promulgation
date
of
the
subpart
for
all
existing
affected
sources.

The
Notification
of
Compliance
Status
must
be
submitted
1
year
and
30
days
following
the
compliance
date.
The
Notification
of
Compliance
Status
includes
performance
test
results
and
deviation
reports,
if
applicable.

Major
sources
are
required
to
submit
periodic
reports
on
a
semiannual
basis.
Major
sources
using
add­
on
control
devices
to
comply
with
the
NESHAP
must
submit
startup,
shutdown,
and
malfunction
reports
semiannually
when
actions
taken
in
the
event
of
a
startup,
shutdown,
or
malfunction
are
consistent
with
the
source's
SSMP.
If
actions
taken
are
not
consistent
with
the
source's
plan,
an
immediate
deviation
report
must
be
submitted.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.
The
existing
major
source
annual
burden
estimates
for
monitoring,
recordkeeping,
and
reporting
are
presented
in
Tables
1
through
3.
These
costs
are
incurred
during
the
first,
second,
and
third
year
following
the
promulgation
date,
respectively.
The
annual
burden
estimates
are
based
on
an
estimated
142
major
affected
sources
in
the
metal
can
manufacturing
surface
coating
industry.
All
assumptions
made
in
the
labor
estimates
are
included
as
footnotes
to
the
tables.
Tables
4
and
5
summarize
the
operation
and
maintenance
costs
necessary
to
implement
the
standard.
These
costs
include
photocopying,
postage,
and
filing
cabinets.
Table
6
summarizes
the
respondent
costs
and
calculates
the
average
annual
respondent
burden.
11
As
shown
in
Table
6,
overall
burden
for
the
first
three
years
is
estimated
to
be
6,184
hours
and
$
1.63
million
for
all
142
major
source
facilities.
The
annual
average
burden
is
1,815
hours
and
$
544,837.

(
b)
Estimating
Respondent
Costs.
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
calculated
for
the
affected
SIC
codes
listed
in
4(
a)
of
this
supporting
statement.
The
labor
rates
for
technical,
management,
clerical,
and
coating
operations
staff
were
calculated
using
Bureau
of
Labor
Statistics
data
for
SIC
code
341.
The
fully
burdened
labor
rate,
which
includes
overhead,
profit,
and
all
employee
benefits,
was
found
by
summing
the
base
labor
rate
and
110%
of
the
base
labor
rate,
per
guidance
from
EPA's
Regulatory
Information
Department
(
RID).
The
hourly
rates
used
for
technical,
managerial,
clerical,
and
"
coating,
painting
and
spraying
machine
operator"
were
$
73.35,
$
83.58,
$
27.93,
and
$
30.26,
respectively.
These
labor
rates
were
then
applied
to
the
activities
required
in
4(
b)(
ii).
The
total
labor
cost
for
the
entire
industry
of
142
major
source
facilities
is
estimated
to
be
$
375,425
for
the
first
three
years
after
the
effective
date
of
the
standard.

(
ii)
Estimating
Capital
Costs
(
computer
equipment)
Monitoring,
recordkeeping,
and
reporting
costs
assume
the
use
of
a
computer
and
software
for
tracking
the
coating
usages
for
each
facility.
Assumptions
were
made
concerning
the
cost
of
computer
equipment
and
the
number
of
respondents
required
to
buy
the
equipment.
A
cost
of
$
2000
for
the
equipment
was
estimated,
including
spreadsheet
software.
Facilities
using
more
than
100,000
gallons
per
year
were
excluded
because
of
the
assumption
that
computer
equipment
is
readily
available.
Of
the
estimated
industry
of
142
major
source
facilities,
an
estimated
35
facilities
will
require
computer
equipment.
Assuming
that
a
new
computer
will
be
bought
every
five
years
and
the
interest
rate
is
7%,
the
capital
recovery
factor
is
0.2439.
Multiplying
the
capital
investment
cost
of
$
2000
by
the
capital
recovery
factor
yields
an
annualized
computer
equipment
cost
of
$
488
per
facility,
bringing
the
total
annualized
industry
cost
for
computer
equipment
to
approximately
$
17,000.

It
was
assumed
that
the
computer
equipment
will
be
purchased
in
the
second
year
after
promulgation,
so
that
the
computer
system
will
be
functional
before
the
compliance
date.
Since
this
cost
is
annualized
over
five
years,
the
capital
costs
are
shown
in
Tables
2
and
3.

(
iii)
Estimating
Capital
Costs
(
performance
testing
costs)
All
major
sources
that
purchase
and
install
new
capture
and
control
equipment
to
comply
with
the
NESHAP
will
also
have
to
conduct
performance
testing.
Performance
testing
on
a
regenerative
thermal
oxidizer
(
RTO)
was
estimated
to
require
160
hours
per
air
pollution
control
device
(
APCD).
Testing
of
the
associated
capture
device(
s)
or
enclosure(
s)
using
method
204
was
estimated
to
require
80
hours
per
device,
for
a
total
of
240
hours
per
APCD.
Contract
labor
was
estimated
at
$
80
per
hour
for
conducting
the
performance
testing,
resulting
in
a
total
cost
estimate
of
$
19,200
per
APCD
(
240
hours
x
$
80/
hr).
Since
performance
testing
is
expected
to
occur
once
with
each
title
V
permit
12
renewal
and
renewals
typically
occur
once
every
5
years,
performance
testing
costs
are
annualized
using
a
5­
year
life
cycle
and
7
percent
interest
rate,
giving
a
cost
recovery
factor
of
0.2439.
This
results
in
an
annualized
cost
of
$
4,683
per
control
device.
The
total
annualized
industry
cost
for
performance
testing
is
$
1.1
million.

It
was
assumed
that
the
performance
testing
would
occur
during
the
third
year
after
promulgation,
so
that
the
add­
on
control
equipment
would
be
functional
before
the
compliance
date.
Therefore,
these
capital
costs
are
shown
in
Table
3.

(
iv)
Estimating
Capital
Costs
(
monitoring
equipment)
All
major
sources
that
purchase
and
install
new
capture
and
control
equipment
to
comply
with
the
NESHAP
will
also
be
required
to
purchase
monitoring
equipment.
We
assumed
that
the
RTO
combustion
temperature
would
be
monitored
using
a
continuous
parameter
monitoring
system
(
CPMS)
to
meet
the
standard.
The
cost
of
a
data
acquisition
system
was
estimated
to
be
$
4,000,
which
includes
$
3,000
for
a
data
logger
and
$
1,000
for
software
and
necessary
accessories
(
i.
e.,
thermocouples,
electrical
wiring,
etc.).
We
also
estimated
a
10­
year
equipment
life
cycle
for
the
monitoring
equipment
and
7
percent
interest
rate,
resulting
in
a
cost
recovery
factor
of
0.1424.
Since
we
estimate
that
122
of
the
142
major
source
facilities
will
require
monitoring
equipment,
the
total
annualized
cost
per
facility
is
approximately
$
570
per
year.
The
total
annualized
industry
cost
for
monitoring
equipment
is
approximately
$
70,100.

It
was
assumed
that
the
monitoring
equipment
will
be
purchased
in
the
third
year
after
promulgation,
so
that
the
monitoring
equipment
can
be
tested
along
with
the
add­
on
control
equipment
during
the
performance
test.
Therefore,
this
capital
cost
is
shown
in
Table
3.

(
v)
Estimating
Operation
and
Maintenance
Costs
(
photocopying
and
postage)
Operation
and
maintenance
covers
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
rules
that
require
respondents
to
submit
notifications
and
reports
to
EPA
and
maintain
records
of
these
reports,
costs
are
estimated
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
labor
rate
of
$
27.93/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
will
be
applied
to
the
143
responses
submitted
during
the
first
year.
Since
there
are
no
other
reports
or
notification
due
until
year
4,
the
total
industry
cost
for
operation
and
maintenance
is
$
1,006
for
the
first
three
years
after
the
effective
date.
These
costs
are
shown
in
Tables
1
through
4
and
6.

(
vi)
Estimating
Capital
Costs
(
file
cabinets)
The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
source.
Assuming
$
235
per
file
cabinet,
the
annualized
capital
cost
per
file
cabinet
is
$
35.
The
total
annualized
industry
cost
for
file
cabinets
is
$
4,970.
13
It
was
assumed
that
the
filing
cabinets
would
be
purchased
in
the
third
year
after
promulgation
so
that
storage
space
would
be
available
for
future
recordkeeping.
These
costs
are
shown
in
Tables
3
and
5.

(
c)
Estimating
Agency
Burden
and
Cost.
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
metal
can
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.

Because
monitoring,
recordkeeping,
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
the
EPA's
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
shown
in
5(
a).
Labor
rates
and
associated
costs
are
based
on
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
These
hourly
rates
include
a
factor
of
1.6
to
account
for
employee
benefits.

The
activities
shown
in
5(
a)
are
divided
among
the
first,
second,
and
third
years
after
promulgation.
The
costs
and
related
assumptions
are
shown
in
Tables
5
through
7,
respectively.
The
total
agency
burden
for
the
first
three
years
following
promulgation
of
subpart
KKKK
is
2,500
hours
and
$
121,000.
The
annual
agency
average
is
825
hours
and
$
40,000.
These
burden
estimates
are
shown
in
Table
10.

(
d)
Estimating
Respondent
Universe
and
Total
Burden
Cost.
The
number
of
existing
major
sources
subject
to
MACT
Subpart
KKKK
is
142.
No
growth
is
expected
in
this
industry.
The
total
average
annual
cost
for
the
industry
is
estimated
to
be
1,815
hours
and
$
544,837
for
the
142
major
sources
during
the
first
three
years
after
the
effective
date.
This
cost
includes
labor,
capital
equipment
costs
(
computers,
monitoring
equipment,
filing
cabinets),
performance
testing,
and
operation
and
maintenance
costs.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.
Please
refer
to
Table
6
and
Table
10.

(
f)
Reasons
for
Change
in
Burden.
This
section
does
not
apply
because
this
is
a
new
collection.
14
(
g)
Burden
Statement.
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
a
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Ms
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
and
OMB
Control
Number
in
any
correspondence.
15
PART
B
OF
THE
SUPPORTING
STATEMENT
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
TABLE
1.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
4
1
4
142b
568
28
57
$
45,623
B.
Apply
for
waiver
6c
1
6
1d
6
0
1
$
482
C.
Required
activities
D.
Create
information
Incl.
in
3B
$
0
E.
Gather
existing
information
Incl.
in
3B
$
0
F.
Write
reports/
notifications
Write
initial
notification
2
1
2
142
284
14
28
$
22,811
TOTAL
ONE­
TIME
BURDEN
AND
COST
858
43
86
$
68,916
OPERATION
AND
MAINTENANCE
COSTe
71
$
5,991
TOTAL
BURDEN
AND
COST
858
43
157
$
74,907
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
6
0
1
$
528
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
73.35,
management
at
$
83.58,
and
clerical
at
$
27.93.

b
Assumes
all
142
major
source
facilities
will
read
the
regulation.

c
From
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping."

d
Assumes
1%
of
142
major
source
facilities
will
apply
for
a
waiver.

e
See
Table
4
for
more
details.
17
TABLE
2.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
B.
Apply
for
waiver
C.
Required
activities
Technical
Set­
up
and
maintain
coating
data
spreadsheet
for
regulation
compliance
4
1
4
142
568
28
57
$
45,623
D.
Create
information
Incl.
in
3B
$
0
E.
Gather
existing
information
Incl.
in
3B
$
0
F.
Write
reports/
notifications
TOTAL
ONE­
TIME
BURDEN
AND
COST
(
LABOR)
568
28
57
$
45,623
TOTAL
CAPITAL
EQUIPMENT
COSTS
(
COMPUTER
COSTS)
c
$
17,000
TOTAL
ONE­
TIME
BURDEN
AND
COST
568
28
57
$
62,623
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
4
0
0
$
441
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
73.35,
management
at
$
83.58,
and
clerical
at
$
27.93.

b
Assumes
122
of
142
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
the
NESHAP.

c
The
use
of
computer
equipment
is
based
on
the
coating
usage
of
each
facility
and
is
costed
at
$
2000
per
facility
with
an
interest
rate
of
7
percent
and
an
equipment
life
of
5
years.

d
See
Table
4
for
more
details.
18
TABLE
3.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
B.
Apply
for
waiver
C.
Required
activities
Technical
Training
of
coating­
related
personnel
each
year
4
4e
16
142
2,272
114
227
$
182,492
Supervise
performance
test
20
0.20b
4
122c
488
24
49
$
39,197
D.
Create
information
Incl.
in
3B
$
0
E.
Gather
existing
information
Incl.
in
3B
$
0
F.
Write
reports/
notifications
Write
performance
test
report
20
0.20b
4
122c
488
24
49
$
39,197
TOTAL
ONE­
TIME
BURDEN
AND
COST
(
LABOR)
3,248
162
325
$
260,886
TOTAL
CAPITAL
COSTS
(
MONITORING
EQUIPMENT)
d
$
70,100
TOTAL
CAPITAL
EQUIPMENT
COSTS
(
COMPUTER
COSTS)
e
$
17,000
TOTAL
COSTS
FOR
PERFORMANCE
TESTING
OF
CONTROL
EQUIPMENTf
$
1,147,000
TOTAL
CAPITAL
EQUIPMENT
COSTS
(
FILING
CABINETS)
g
$
4,970
TOTAL
ONE­
TIME
BURDEN
AND
COST
3,248
162
325
$
1,499,956
AVERAGE
ONE­
TIME
BURDEN
AND
COST
PER
FACILITY:
23
1
2
$
10,563
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
73.35,
management
at
$
83.58,
clerical
at
$
27.93,
and
"
coating,
painting
and
spraying
machine
operator"
at
$
30.26.

b
Assumes
one
test
every
5
years
or
0.20
test
reports
per
year.

c
Assumes
122
of
142
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
the
NESHAP.

d
Assumes
data
acquisition
system
consists
of
$
3000
for
data
logger
and
$
1000
for
software
annualized
over
5
years
at
7%
interest.

e
Computer
equipment
is
based
on
the
coating
usage
of
each
facility
and
is
annualized
at
$
2000
per
facility
for
5
years
with
an
interest
rate
of
7
percent.

f
Performance
testing
assumes
the
use
of
a
contractor
for
240
hours
at
a
rate
of
$
80
per
hour
annualized
over
5
years
at
7%
interest.

g
See
Table
5
for
more
details.
19
TABLE
4.
OPERATION
AND
MAINTENANCE
COSTS
FOR
PHOTOCOPYING
AND
POSTAGE
FOR
THE
FIRST
6
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Cost
item
Photocopy
cost/
report
Postage
cost/
report
Reports/
respondent
Respondents/

year
Reports/

year
Photocopy
cost
Postage
cost
Application
for
waiver
Year
1
$
13.47
$
7.63
1
1
1
$
13
$
8
Year
2­
3
$
13.47
$
7.63
1
0
0
$
0
$
0
Initial
Notification
Year
1
$
13.47
$
7.63
1
142
142
$
1,912
$
1,083
Years
2­
3
$
13.47
$
7.63
1
0
0
0
0
Notification
of
compliance
status
(
with
performance
test)

Years
1­
3,
5,
6
$
13.47
$
7.63
1
0
0
$
0
$
0
Year
4
$
13.47
$
7.63
1
122
122
$
1,643
$
931
Notification
of
compliance
status
(
without
performance
test)

Years
1­
3,
5,
6
$
13.47
$
7.63
1
0
0
$
0
$
0
Year
4
$
13.47
$
7.63
1
20
20
$
269
$
153
Semi­
annual
compliance
report
Year
1­
3
$
13.47
$
7.63
2
0
0
$
0
$
0
Year
4
$
13.47
$
7.63
1
142
142
$
1,912
$
1,083
Year
5­
6
$
13.47
$
7.63
2
142
284
$
3,824
$
2,167
TOTAL
(
Year
1)
143
$
1,925
$
1,091
TOTAL
(
Year
2)
0
$
0
$
0
TOTAL
(
Year
3)
0
$
0
$
0
TOTAL
(
Year
4)
284
$
3,824
$
2,167
TOTAL
(
Year
5)
284
$
3,824
$
2,167
TOTAL
(
Year
6)
284
$
3,824
$
2,167
AVERAGE
(
Years
1­
3)
48
$
642
$
364
AVERAGE
(
Years
4­
6)
284
$
3,824
$
2,167
20
TABLE
5.
FILE
CABINET
COSTS
FOR
THE
FIRST
3
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Capital
cost/

respondent
Annualized
capital
cost/

respondent
Capital
cost
respondents/
yr
Annual
cost
respondents/
yr
Capital
cost
Annualized
capital
cost
Year
1
$
235
$
35
0
0
$
0
$
0
Year
2
$
235
$
35
0
0
$
0
$
0
Year
3
$
235
$
35
142
142
$
33,370
$
4,970
TABLE
6.
SUMMARY
OF
RESPONDENT
BURDEN
HOURS
AND
COSTS
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
Year
Technical
hours
Management
hours
Clerical
hours
Total
hours
Labor
costs
Non­
labor
costs
Total
costs
Capital
costs
O&
M
costs
Year
1
858
43
157
1,058
$
68,916
$
0
$
5,991
$
74,907
Year
2
568
28
57
653
$
45,623
$
17,000
$
0
$
62,623
Year
3
3,248
162
325
3,735
$
260,886
$
1,239,070
$
0
$
1,499,956
Totals
4,674
234
538
5,446
$
375,425
$
1,256,070
$
5,991
$
1,637,486
Average
burden
1,815
$
125,142
$
418,690
$
1,997
$
545,829
21
TABLE
7.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
$
186
B.
Review
waivers
2
2
4
1b
4
0
0
$
186
C.
Review
reports/
notifications
Review
initial
notification
2
2
4
142
568
28
57
$
26,396
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
576
29
58
$
26,767
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
1%
of
142
major
source
facilities
will
apply
for
a
waiver.
22
TABLE
8.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
$
186
B.
Review
waivers
C.
Review
reports/
notifications
Review
notification
of
intent
to
conduct
performance
test
2
2
4
122b
488
24
49
$
22,678
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
492
25
49
$
22,864
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
122
of
142
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
NESHAP.
23
TABLE
9.
ESTIMATED
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
32
1b
32
24c
768
38
77
$
35,690
2.
Repeat
performance
test
A.
Retesting
preparation
12
1b
12
6d,
e
72
4
7
$
3,346
B.
Attend
retesting
32
1b
32
6
192
10
19
$
8,922
3.
Deviations­­
enforcement
activities
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
$
186
B.
Review
waivers
$
0
C.
Review
reports/
notifications
Review
performance
test
report
2
0.2f
0
122g
49
2
5
$
2,268
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
1,085
54
108
$
50,412
ANNUAL
AVERAGE
TRAVEL
EXPENSESh
$
21,000
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
1,085
54
108
$
71,412
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
These
costs
are
based
on
2000
wages
listed
by
U.
S.
Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
1
add­
on
control
device
per
facility.

c
Assumes
EPA
will
attend
20%
of
performance
tests
for
122
facilities
using
add­
on
control
devices.

d
Assumes
20%
of
facilities
will
fail
the
initial
performance
test
and
all
those
who
fail
will
repeat
it.

e
Assumes
EPA
will
attend
25%
of
the
retests.

f
Assumes
one
performance
test
per
facility
with
add­
on
control
devices
every
five
years
(
or
0.20
reports
per
year).

g
Assumes
122
of
142
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
NESHAP.

h
Assumes
performance
tests
require
4
days
per
facility:
(
Travel
costs=
[(
1
person
x
(
24+
6)
facilities/
yr
x
4
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
(
24+
6)

round
trips/
yr)])
24
TABLE
10.
SUMMARY
OF
AGENCY
BURDEN
HOURS
AND
COSTS
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
Total
burden
(
hours)
Total
costs
($)

First
year
following
the
effective
date
662
$
26,767
Second
year
following
the
effective
date
566
$
22,864
Third
year
following
the
effective
date
1,247
$
71,412
Total
2,475
$
121,043
Bottom
line
annual
burden
825
$
40,348
25
ATTACHMENT
1
Burden
and
Cost
of
Monitoring,
Recordkeeping,
and
Reporting
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
26
BURDEN
AND
COST
OF
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
1.
The
Information
Collected
 
­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
there
are
many
activities
that
occur
in
the
three
years
between
the
effective
date
and
the
compliance
date
of
the
regulation.
These
include
the
Initial
Notification,
the
Notification
of
Intent
to
Conduct
a
Performance
Test,
performance
test
report,
buying
computer
equipment,
buying
monitoring
equipment,
buying
filing
cabinets,
setting
up
a
spreadsheet
tracking
system,
and
training
the
coating
personnel
to
accurately
track
coating
usages.

In
the
three
years
following
the
compliance
date,
there
are
recurrent
activities
that
are
required
of
the
respondents.
These
include
training,
coordinating
the
transfer
of
information
between
departments,
checking
spreadsheets
for
accuracy,
compiling
and
maintaining
records
of
coatings
data
each
week,
adjusting
process
to
comply
with
standard,
calculating
12­
month
rolling
average
organic
HAP
emissions,
entering
data
into
spreadsheet,
tracking
coating
usage
in
spreadsheet
or
log
book,
writing
semiannual
reports,
writing
compliance
status
reports,
writing
reports
of
no
deviations,
and
writing
deviation
reports
(
if
necessary).

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
the
agency
burden
include
many
activities
during
the
three
years
between
the
effective
date
and
the
compliance
date.
These
include
reviewing
the
notifications,
and
attending
the
performance
testing
and
re­
testing,
if
needed.

During
the
three
years
following
the
compliance
date,
the
agency
burden
increases
with
recurrent
activities
such
as
responding
to
deviations
through
enforcement
activities,
reviewing
regulation,
reviewing
semiannual
reports,
reviewing
compliance
status
reports,
reviewing
reports
of
no
deviations,
and
reviewing
deviation
reports.

2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.
This
ICR
uses
labor
rates
calculated
for
the
affected
Standard
Industrial
Classification
(
SIC)
code
3411.
The
labor
rates
for
technical,
management,
clerical,
and
coating
operations
staff
were
calculated
using
Bureau
of
Labor
Statistics
data
for
SIC
code
341.
The
fully
burdened
labor
rate,
which
includes
overhead,
profit,
and
all
employee
benefits,
was
found
by
summing
the
base
labor
rate
and
110%
of
the
base
labor
rate,
per
guidance
from
EPA's
Regulatory
Information
Department
(
RID).
The
hourly
rates
used
for
technical,
managerial,
clerical,
and
"
coating,
painting
and
spraying
machine
operator"
were
$
73.35,
$
83.58,
$
27.93,
and
$
30.26,
respectively.
27
Since
the
respondent
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
1,
along
with
all
assumptions
made.
For
these
three
years,
the
total
burden
to
the
142
major
sources
is
estimated
to
be
$
7.5
million.
The
labor
requirements
total
169,402
hours.

(
ii)
Estimating
capital
costs.
There
are
no
capital
costs
estimated
for
the
three
years
following
the
compliance
date.

(
b)
Estimating
Agency
Burden
and
Costs
Labor
rates
and
associated
costs
are
based
on
2000
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
The
estimated
wage
rates
are
$
67.44/
hr
(
GS­
15/
3
level)
for
management,
$
40.80/
hr
(
GS­
12/
3
level)
for
technical,
and
$
22.99/
hr
(
GS­
6/
3
level)
for
clerical.
These
hourly
rates
include
a
factor
of
1.6
to
account
for
employee
benefits.

Since
the
agency
activities
are
recurrent
for
years
four,
five,
and
six,
the
information
is
shown
in
Table
2,
along
with
all
assumptions
made.
For
these
three
years,
the
total
agency
burden
is
estimated
to
be
$
61,081
annually.
The
labor
requirements
total
1,408
hours
annually.
28
TABLE
1.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)

Cost,
$
a
1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
requirements
A.
Read
regulation
1
1
1
142b
142
7
14
11,406
B.
Required
activities
Technical
Training
of
coating­
related
personnel
each
year
4
4c
15.2
142
2,158
108
216
173,367
Coordinate
purchasing,
operations
and
clerical
for
information
transfer
each
month
1
12
12
142
1,704
85
170
136,869
Check
spreadsheet
for
data
entry
errors
weekly
1
50d
50
142
7,100
355
710
570,286
Compile
and
maintain
records
of
coatings
data
each
week
1.5e
50d
75
142
10,650
533
1,065
855,429
Using
compiled
data,
adjust
process
to
comply
with
standard
every
quarter
2
4
8
142
1,136
57
114
91,246
Clerical
Enter
data
into
spreadsheet
to
tabulate
information
each
day
1f
250g
250
142
0
0
35,500h
991,515
Operations
Track
coating
usage
in
spreadsheet
or
log
book
each
shift
1i
500j
500
142
71,000
0
0
2,148,460k
Periodic
checking
of
monitoring
equipment
0.5l
500j
250
122m
30,500
0
0
922,930k
Maintenance
of
monitoring
equipment
2n
4
8
122m
976
0
0
29,534k
Calibration
of
CPMS
8o
1
8
122m
976
0
0
29,534k
D.
Create
information
Incl.
in
3B
0
E.
Gather
existing
information
Incl.
in
3B
0
F.
Write
semi­
annual
report
Write
compliance
status
report
4e
2
8
135p
1,080
54
108
86,748
Report
of
no
deviations
8e
2
16
135p
2,160
108
216
173,496
Write
report
of
excess
emissions
16e
2
32
7q
224
11
22
17,992
TOTAL
RECURRENT
BURDEN
AND
COST
129,806
1,318
38,135
6,238,811
TOTAL
CAPITAL
COSTS
(
MONITORING
EQUIPMENTr
70,100
TOTAL
CAPITAL
COSTS
(
COMPUTER
EQUIPMENT)
s
17,000
TOTAL
CAPITAL
EQUIPMENT
COSTS
(
FILING
CABINETS)
4,970
TOTAL
COSTS
FOR
PERFORMANCE
TESTING
OF
CONTROL
EQUIPMENTt
1,147,000
OPERATION
AND
MAINTENANCE
COSTu
142
5,991
TOTAL
RECURRENT
BURDEN
AND
COST
(
ALL)
129,806
1,318
38,277
7,483,872
AVERAGE
RECURRENT
BURDEN
AND
COST
PER
FACILITY:
914v
9
270
52,703
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
73.35,
management
at
$
83.58,
clerical
at
$
27.93,
and
"
coating,
painting
and
spraying
machine
operator"
at
$
30.26.

b
Assumes
all
142
major
source
facilities
will
read
the
regulation.

c
Training
will
occur
quarterly
with
9
trainees
per
session.

d
Assumes
50
weeks
per
year.

e
From
ESD
manual
Table
3
"
Burden
of
NSPS
and
NESHAP
Notification
Reports,
Excess
Emission
Reports
and
Recordkeeping."

f
Assumes
1
minute
per
entry.

g
Assumes
50
weeks
per
year
and
5
days
per
week.

h
Assumes
clerical
instead
of
technical
labor
rate
for
data
entry.
(
G=
C
x
D)

i
Assumes
2
minutes
per
entry
per
shift.

j
Assumes
2
shifts
per
day,
5
days
per
week,
and
50
weeks
per
year.

k
Cost
is
based
on
a
Coating,
Painting
and
Spraying
Machine
Operator
weighted
labor
rate
of
$
30.26.

l
Assumes
one
15­
minute
monitor
check
per
shift
and
2
shifts
per
day.

m
Assumes
122
of
142
major
source
facilities
will
use
add­
on
control
devices
to
comply
with
the
NESHAP.

n
Assumes
2
hours
of
preventative
maintenance
on
a
quarterly
basis.

o
Assumes
8
hours
of
calibration
occurs
once
per
year.

p
Assumes
95
percent
of
142
major
source
facilities
will
be
in
compliance.

q
Assumes
5
percent
of
142
major
source
facilities
will
be
out
of
compliance
r
Assumes
data
acquisition
system
consists
of
$
3000
for
data
logger
and
$
1000
for
software
and
accessories
annualized
over
5
years
at
7%
interest.

s
The
use
of
computer
equipment
is
based
on
the
coating
usage
of
each
facility
and
is
costed
at
$
2000
per
facility
with
an
interest
rate
of
7
percent
and
an
equipment
life
of
5
years.

t
Performance
testing
assumes
the
use
of
a
contractor
for
240
hours
at
a
rate
of
$
80
per
hour
annualized
over
5
years
at
7%
interest.

u
Operation
and
maintenance
costs
include
photocopying
and
postage
costs
for
284
reports
per
year
using
a
postage
of
$
7.63
per
report
and
0.5
hours
of
clerical
labor
for
photocopying.

v
Includes
186
hours
of
technical
labor
at
$
73.35
per
hour
and
729
hours
of
a
machine
operator
at
$
30.26
per
hour.
TABLE
2.
ESTIMATED
RECURRENT
BURDEN
AND
COST
TO
THE
AGENCY
TO
IMPLEMENT
MONITORING,
RECORDKEEPING,
AND
REPORTING
REQUIREMENTS
FOR
METAL
CAN
MANUFACTURING
(
SURFACE
COATING)
NESHAP
Burden
item
(
A)

Personhours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)

EPA­
hours
per
facility
per
year
(
C
=
A
x
B)
(
D)
Facilities
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
person­
hours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,

$
a
1.
Attend
add­
on
control
device
performance
testing
2.
Repeat
performance
test
A.
Retesting
preparation
B.
Attend
retesting
3.
Deviations­­
enforcement
activities
16b
1
16
7c
112
6
11
$
5,205
4.
Reporting
requirements
A.
Review
regulation
2
2
4
1
4
0
0
$
186
B.
Review
waivers
C.
Review
semi­
annual
reports
Review
compliance
status
report
2
2
4
135d
540
27
54
$
25,094
Review
performance
test
report
Review
report
of
no
deviations
2
2
4
135d
540
27
54
$
25,094
Review
deviation
report
2
2
4
7c
28
1
3
$
1,301
ANNUAL
AVERAGE
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
1,224
61
122
$
56,881
ANNUAL
AVERAGE
TRAVEL
EXPENSESd
$
4,200
AVERAGE
TOTAL
COST
=
ANNUAL
AVERAGE
COST
+
ANNUAL
AVERAGE
TRAVEL
EXPENSES
1,224
61
122
$
61,081
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
40.80,
management
at
$
67.44,
and
clerical
at
$
22.99.
These
costs
are
based
on
2000
wages
listed
by
U.
S.

Office
of
Personnel
Management
for
GS
Level
12,
Step
5;
GS
Level
15,
Step
5;
and
GS
Level
7,
Step
5,
respectively.

b
Assumes
an
EPA
follow­
up
visit
of
2
days
per
deviation
report.

c
Assumes
5%
of
142
major
source
facilities
will
be
out
of
compliance.

d
Assumes
95%
of
142
major
source
facilities
will
be
in
compliance.

e
Assumes
enforcement
visits
require
2
days
per
facility:

[
Travel
costs=
[(
1
person
x
7
facilities/
yr
x
2
d/
facility
x
$
50/
d)
+
($
500/
round
trip
x
7
round
trips/
yr)]
