SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Metal Can Manufacturing Surface Coating (40 CFR part 63,
subpart KKKK) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Metal Can Manufacturing Surface Coating (40 CFR part 63,
subpart KKKK) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 63, subpart KKKK were
proposed on January 15, 2003 and promulgated on November 13, 2003. 
These regulations apply to facilities that perform surface coating
operations on metal cans.  Metal can manufacturing surface coating
operations include any facilities that coat or print metal cans or metal
can parts (e.g., metal ends for composite cans).  The source category
also includes the coating/printing of metal decorative tins, crowns, and
closures, except for coil coating.  Regulated activities include the
coating/printing of metal sheets for subsequent processing into cans or
can parts, but not the coating of metal coils for cans or can parts. 
This information is being collected to assure compliance with 40 CFR
part 63, subpart KKKK.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period during which the
monitoring system is inoperative.  These notifications, reports, and
records are essential in determining compliance, and are required of all
affected facilities subject to NESHAP.

 

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an
average of one  affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

Over the next three years, an average of 71 respondents per year will be
subject to the standard, and zero additional respondents per year will
become subject to the standard.  The Office of Management and Budget
(OMB) approved the currently active ICR without any “Terms of
Clearance.” 

The term, “Affected Public”, applies to private sector businesses or
other for-profits that manufacture metal cans.  The burden to the
“Affected Public” may be found in Table 1: Annual Respondent Burden
and Cost, NESHAP for Metal Can Manufacturing Surface Coating (attached).
 The burden to the “Federal Government” is attributed entirely to
work performed by federal employees or government contractors, and may
be found in Table 2: Annual Agency Burden and Cost, NESHAP for Metal Can
Manufacturing Surface Coating (attached).

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner or operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from metal can
manufacturing operations cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, NESHAP for this source category were promulgated at 40 CFR
part 63, subpart KKKK.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times. 

The notifications required in the standards are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated and the standards are being met.  The
performance test may also be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

 

The NESHAP also requires affected sources to submit a Notification of
Compliance Status.  This notification must be signed by a responsible
company official who certifies its accuracy and certifies that the
source has complied with the standards.  The results of the performance
test must be submitted to the EPA in the Notification of Compliance
Status.

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

3.  Nonduplication, Consultations, and Other Collection Criteria

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

3(a)  Nonduplication

 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (71 FR 58853) on October 5, 2006. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

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 standard, is the AFS (AIRS Facility Subsystem) which
is operated and maintained by EPA's Office of Compliance.  AFS is
EPA’s database for the collection, maintenance, and retrieval of all
compliance data.  The growth rate for the industry is based on our
consultations with the Agency’s internal industry experts. 
Approximately 71 respondents will be subject to the standard over the
three-year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.  In this case, no comments were received.


3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five year records retention requirement is consistent
the Part 70 permit program and the five year statute of limitations on
which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies 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).

3(g)  Sensitive Questions

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

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC and NAICS Codes

The respondents of the recordkeeping and reporting requirements are
owners or operators of metal can manufacturing operations. 

Standard	NAICS Codes

40 CFR part 63, subpart KKKK	332431  Metal Can Manufacturing

	332115  Crown and Closure Manufacturing

	332116  Metal Stamping

	332812  Metal Coating, Engraving (except Jewelry and Silverware), and
Allied Services to Manufacturers

	332999  All Other Miscellaneous Fabricated Metal Product Manufacturing



4(b)  Information Requested

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
40 CFR part 63, subpart KKKK.

A source must make the following reports:

Notifications

Initial notification	63.3510(b), 63.5(d), 63.9(b)

Notification of compliance status	63.3510(c), 63.9(h)

Notification of construction or reconstruction	63.3510(a), 63.5

Notification of actual startup	63.3510(a), 63.9(b)

Notification of performance test	63.3510(a), 63.7(b), 63.8(e), 63.9(e)



Notification Reports

Semiannual report	63.3511(a)

Excess emissions report	63.3511(a)(4-8)

Report of performance test	63.3511(b)

Startup, shutdown, malfunction report	63.3511(c)



	A source must keep the following records:

Recordkeeping

Five year retention of records	63.3513(b), 63.10(b)

Material formulation data	63.3512(b)

Records of HAP content calculations	63.3512(c)

Copies of notifications and reports	63.3512(a)

Records of names of materials used	63.3512(d)

HAP fractions in each material used	63.3512(e)

Coating solids fraction in each material used	63.3512(f)

Density of materials used	63.3512(g)

Documentation of waste material shipped offsite	63.3512(h)

Documentation of deviations	63.3512(i)

Start-up, shutdown, and malfunction plan/records	63.3512(j), 63.6(e)

Records of continuous compliance with operating limits	63.3512(j)

Documentation of capture system efficiency determination	63.3512(j)

Documentation of add-on control device destruction or removal efficiency
determination	63.3512(j)

Documentation of control device performance tests	63.3512(j), 63.10(b)

Determination of capture system and add-on control operating limits
63.3512(j)

Work practice plan/records	63.3512(j)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site. 

In addition, regulatory agencies, in cooperation with the respondents,
continue to create reporting systems to transmit data electronically. 
However, electronic reporting systems are still not widely used.  At
this time, it is estimated that approximately 10 percent of the
respondents use electronic reporting.

ii.  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature, for gas
flow, or for pressure drop for oxidizer, carbon adsorber, condenser,
concentrator, or capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D,
2F, 2G, 3, 3A, 3B, 4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E,
204F, 311, or ASTM Method D1475-98, D2697-86, D6093-97 test, and repeat
performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Adjust the existing ways to comply with any previously applicable
instructions and requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



5.  The Information Collected -- Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports including: performance test reports;
excess emissions reports; startup, shutdown, malfunction plan; and the
CMS quality control plan.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Performance test reports are used by
the Agency to discern a source’s initial capability to comply with the
emission standard.  Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. 
The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS 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.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and state regulatory
agencies, EPA regional offices and EPA headquarters.  EPA and its
delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or
operator for five years.

5(c)  Small Entity Flexibility

During rulemaking for subpart KKKK, EPA identified 13 small businesses
subject to the rule.  A majority of the respondents are large entities
(i.e., large businesses).  However, the impact on small entities (i.e.,
small businesses) was taken into consideration during the development of
the regulation.  Small entities were afforded extensive flexibility in
demonstrating compliance through compliance options that give small
entities flexibility in choosing the most cost effective and least
burdensome alternative for their operation.  Due to technical
considerations involving the process operations and the types of control
equipment employed, the recordkeeping and reporting requirements are the
same for both small and large entities.  The Agency considers these to
be the minimum requirements needed to ensure compliance and, therefore,
cannot reduce them further for small entities.  To the extent that
larger businesses can use economies of scale to reduce their burden, the
overall burden will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost,
NESHAP for Metal Can Manufacturing Surface Coating (attached).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 27,517
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial	$105.36 ($50.17 + 110%)  

Technical	$92.09   ($43.85 + 110%)

Clerical	$45.15   ($22.50 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2006, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

(ii)  Estimating Capital and Operating and Maintenance Costs

This section covers the costs associated with all types of continuous
monitoring equipment (e.g., CEMS and continuous parameter monitors). 
The type of industry costs associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitors and
other costs such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

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



The total Capital/Start-up costs for this ICR are zero.  This is the
total of column D in the above table. 

 

The total Operating and Maintenance (O&M) costs for this ICR are
$85,200.  This is the total of column G.

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $85,200.  The continuous monitoring costs that are
included in this section consist only of those capital/startup and O&M
costs that a source incurs as a result of the standard.  Some continuous
monitoring costs may not be included in this section.  For instance, if
a particular industry typically utilizes a control device that must have
a continuous monitor (e.g., temperature, pressure drop, etc.) to
function properly, and the recordation of additional measurements beyond
the minimum are required by the standard, then there is no
capital/startup or O&M cost, but there is a labor cost to record the
additional readings.  Such a cost would not appear in this section, but
in the industry burden Section 6(d) below.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
estimated to be $116,971 [see Table 2 in Section 6(e)]. 

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

	Managerial	$58.18  (GS-13, Step 5, $36.36 + 60%)  

	Technical	$43.17  (GS-12, Step 1, $26.98 + 60%)

	Clerical	$23.36  (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) “2007
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60% to account for the benefit packages available
to government employees.  Details upon which this estimate is based
appear in Table 2: Annual Agency Burden and Cost, NESHAP for Metal Can
Manufacturing Surface Coating (40 CFR Part 63, Subpart KKKK), below.

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

Based on our research for this ICR, there are approximately 71 existing
sources currently subject to the standard.  It is estimated that an
additional zero sources per year will become subject to the regulation
in the next three years.

Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

Year	(A)

Number of New Respondents 	(B)

Number of Existing Respondents	(C)

Number of Respondents That Keep Records But Do Not Submit Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	0	71	0	0	71

2	0	71	0	0	71

3	0	71	0	0	71

Average	0	71	0	0	71



To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 71. 

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Initial notification	0	1	0	0

Notification of compliance status	0	1	0	0

Notification of construction/reconstruction	0	1	0	0

Notification of actual startup 	0	1	0	0

Notification of performance test 	0	1.2	0	0

Report of performance test	0	1.2	0	0

Semiannual report 	71	2	0	142

Excess emissions report	71	2	0	142

Startup, shutdown, malfunction report	18	1	0	18



	Total	302



The number of Total Annual Responses is 302. 

The total annual labor costs are $2,437,568.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost,
NESHAP for Metal Can Manufacturing Surface Coating (attached).

Note that the total annual capital and O&M costs to the regulated entity
are $85,200.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below. 

(i) Respondent Tally

	The total annual labor hours are 27,517.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost,
NESHAP for Metal Can Manufacturing Surface Coating (attached). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 91 hours per
response.

The total annual capital/startup and O&M costs to the regulated entity
are $85,200.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 2,778 labor hours at a cost of $116,971.  See Table 2.
Annual Agency Burden and Cost,

NESHAP for Metal Can Manufacturing Surface Coating (attached).

6(f)  Reasons for Change in Burden

The number of respondents has decreased from the most recently approved
ICR due to an adjustment.  The adjustment decrease is due to an improved
estimate of the number of facilities subject to the standard as reported
in AFS, EPA’s database for the collection, maintenance, and retrieval
of all compliance data.

The increase in burden from the most recently approved ICR is also due
to an adjustment.  The previous ICR included only the burden incurred by
facilities initiating activities related to compliance in advance of the
compliance date.  The increase in burden reflects the need for
facilities to comply with the rule requirements on a continuing basis.

The previous ICR shows higher capital/startup and O&M costs than this
ICR due to installation of monitoring equipment so that the only costs
incurred are those associated with O&M of the monitoring equipment.  At
this point in time, all of the subject facilities have installed the
required monitoring equipment.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 91 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA–2006–0738.  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), EPA
West, Room 3334, 1301 Constitution Avenue, 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, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA–2006–0738 and OMB Control Number 2060-0541 in any
correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

Table 1.  Annual Respondent Burden and Cost:

NESHAP for Metal Can Manufacturing Surface Coating (40 CFR part 63,
subpart KKKK)

Burden Item	

(A) Person-hours per occurrence	

(B) 

Number of occurrences per year	

(C) Person-hrs. per respondent per year

 (C=A*B)	

(D) Respondents per year 	

(E) Technical person-hrs. per year (E=C*D)	

(F) Management person-hrs. per year 

(F=E*0.05)	

(G) Clerical person-hrs. per year (G=E*0.1)	

(H) 

Annual costs ($)

1. Reporting requirements

	a. Read rule and instructions	4	1	4	71	284	14	28	28,932

b. Compile and process data	4	4	16	71	1,136	57	114	115,728

c. Write reports

	i. Initial notification	2	1	2	0	0	0	0	0

ii. Notification of compliance status	2	1	2	0	0	0	0	0

iii. Notification of construction/reconstruction	2	1	2	0	0	0	0	0

iv. Notification of actual startup	2	1	2	0	0	0	0	0

v. Notification of performance test	2	1.2	2.4	0	0	0	0	0

vi. Report of performance test	10	1.22	12	0	0	0	0	0

vii. Semiannual report	6	2	12	71	852	43	85	86,796

viii. Excess emissions report	2	2	4	71	284	14	28	28,932

ix. Startup, shutdown, malfunction report	2	1	2	182	36	2	4	3,667

Subtotal Reporting Labor and Cost Burden	2,981	264,055

2. Recordkeeping requirements

	a. Read rule and instructions	4	1	4	71	284	14	28	28,932

b. Plan activities	12	1	12	71	852	43	85	86,796

c. Implement activities	12	1	12	71	852	43	85	86,796

d. Maintain record system for material used	20	1	20	71	1,420	71	142
144,660

e. Time to enter information

	i. Material usage	0.5	365	183	71	12,958	648	1,296	1,320,019

ii. Compliance calculation	2	12	24	71	1,704	85	170	173,592

f. Time to train personnel	10	1	10	71	710	36	71	72,330

g. Store, file, and maintain records	2	12	24	71	1,704	85	170	173,592

h. Retrieve records/reports	1	12	12	71	852	43	85	86,796

Subtotal Recordkeeping Labor and Cost Burden	24,536	2,173,513

Total Burden (Hrs) and Costs

	

	

	23,928	1,196	2,393



Totals	27,517

$2,437,568



Table 2.  Annual Agency Burden and Cost:

NESHAP for Metal Can Manufacturing Surface Coating (40 CFR part 63,
subpart KKKK)

Burden Item	

(A)

Person-hours 

per 

occurrence	

(B)

Number of occurrences per year	

(C)

Number of respondents	

(D)

Technical person-hours per year

(D=A*B*C)	

(E)

Management person-hours per year

(E=D*0.05)	

(F)

Clerical person-hours per year

(F=E*0.1)	

(G)

Annual costs 

($)



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



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



3. Report review 	

	









	

  a) Initial notification	

8	

1	0	0	0	0	0



b) Notification of performance test	

8	

1.2	0	0	0	0	0



c) Notification of compliance status	

8	

1	0	0	0	0	0



d) Notification of construction/reconstruction	

8	

1	0	0	0	0	0

e)  Notification of actual startup	

8	

1	0	0	0	0	0

f) Report of performance test	

8	

1.2	0	0	0	0	0

g) Semiannual report	

12	

2	71	1,704	85	170	82,499

  h) Excess emissions report	

4	

2	71	568	28	57	27,500

i) Startup, shutdown,          malfunction report	

8	

1	18	144	7	14	6,972



Total Burden (Hrs) and Costs	

	



2,416	121	241





	Totals	2,778

$116,971



 20 percent retest.

 Estimated 25 percent of facilities use add-on controls, submit startup,
shutdown, malfunction report once per year.

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