                             SUPPORTING STATEMENT
                        ENVIRONMENTAL PROTECTION AGENCY

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

1.  Identification of the Information Collection

      1(a)  Title of the Information Collection

NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal),             EPA ICR Number 0663.11, 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, and promulgated on August 25, 1983.  These regulations apply to each operation of the following surface coating lines in the Beverage Can Surface Coating industry: 1) exterior base; 2) over-varnished; and 3) inside spray.  These regulations apply to beverage can surface coating facilities commencing 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.  Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative.  These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.
      
      Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records.  All reports are sent to the delegated state or local authority.   In the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

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        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).
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      Over the next three years, an average of 48 respondents per year will be subject to the standard, and no 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 "Affected Public" is 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" burden is attributed entirely to work performed by either Federal employees or government contractors and is found below in Table 2: Average Annual EPA Burden and Cost  -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).

2.  Need for and Use of the Collection

      2(a)  Need/Authority for the Collection

      The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect: 
      
            . . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best-demonstrated technology (BDT).  Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years.

	In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to: 

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

      In the Administrator's judgment, emissions from beverage can coating facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health 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

      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. 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 standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations.  The reviewing authority may then inspect the source to check if: 1) the pollution control devices are properly installed and operated 2) leaks are being detected and repaired; and 3) the standards are being met.  The performance test may also be observed.
      
      The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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

      The recordkeeping and reporting requested are required under 40 CFR part 60, subpart WW.

      3(a)  Non-duplication

       If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office.  Otherwise, the information is sent directly to the delegated state or local agency.  If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency     can be sent to the Administrator in lieu of the report required by the Federal standards.  Therefore, duplication does not exist.
      
      3(b)  Public Notice Required Prior to ICR Submission to OMB

      An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (77 FR 47631) on August 9, 2012.  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 Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance.  OTIS is the EPA 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.
      
      Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed.  In developing this ICR, we contacted: 1) the American Coatings Association (ACA), at (202) 719-3703; and 2) 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.  In this case, no comments were received

      3(d)  Effects of Less Frequent Collection
	
      Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards.  Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met.  If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
      
      3(e)  General Guidelines

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

      The respondents to the recordkeeping and reporting requirements are facilities that conduct surface coating of beverage cans.  The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 3411, which corresponds to the North American Industry Classification System (NAICS) 332431 for Metal Can Manufacturing.

      4(b)  Information Requested 

            (i)  Data Items

      All data in this ICR that is recorded and/or reported is required by 40 CFR part 60, subpart WW.

      A source must make the following reports:

                                 Notifications
Construction/reconstruction
60.7(a)(1) 
Anticipated startup
60.7(a)(2)
Actual startup
60.7(a)(3)
Notification of initial performance test
60.8(d)
Physical or operational change
60.7(a)(4)
      
                                    Reports
Initial performance test results
60.8 (a), 60.495(a)
Demonstration of continuous monitoring system
60.7(a)(5)
Semiannual report
60.7(c), 60.495(c)
Excess emissions report
60.7(c), 60.495(c)
      
      A source must maintain the following records:

                                 Recordkeeping
Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative
60.7(b)
Monthly performance test
60.493(b)
Records are required to be retained for two years.  The first two years of records must be retained at the facility.
60.495(d)
Maintain a file of all measurements including the monitoring device, and performance testing measurements, and monitoring device calibrations, checks, adjustments and maintenance performed on these devices.
60.7(e)
Maintain daily records of incinerator combustion temperature, or amounts of solvent recovered.
60.494(c)

Electronic Reporting

      Some of the respondents are using monitoring equipment that automatically records parameter data.  Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. 
      
      Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically.  However, electronic reporting systems are still not widely used.  At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.
      
            (ii)  Respondent Activities

                             Respondent Activities
Read instructions.
Install, calibrate, maintain, and operate a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance.
Perform initial performance test, Reference Method 24 or Reference Method 25 test, and repeat performance tests if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.
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.

      Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring system.  Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping

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

      5(a)  Agency Activities

      EPA conducts the following activities in connection with the acquisition, analysis, 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, and excess emissions reports, required to be submitted by industry.
Audit facility records.
Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

      5(b)  Collection Methodology and Management

      Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source's initial capability to comply with the emission standards. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.  The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
      
      Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance.  OTIS is EPA's database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities.  EPA uses the OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.  EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
      
       The records required by this regulation must be retained by the owner/operator for two years.
      
      5(c)  Small Entity Flexibility

      A majority of the affected facilities are large entities (e.g., large businesses).  However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation.  Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities.  The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities.  To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.
      
      5(d)  Collection Schedule

	The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost  -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).

6.  Estimating the Burden and Cost of the Collection

     Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR.  The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act.  Wherever appropriate, specific tasks and major assumptions have been identified.  Responses to this information collection are mandatory.
     
     The Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.
     
      6(a)  Estimating Respondent Burden

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      The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 5,134 (Total Labor Hours from Table 1 below).   These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.

      6(b)  Estimating Respondent Costs

            (i)  Estimating Labor Costs

      This ICR uses the following labor rates: 

            Managerial	$121.44   ($57.83 + 110%)   
            Technical	$100.23   ($47.73 + 110%)
            Clerical	$50.51   ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, "Table 2. Civilian Workers by occupational and industry group."  The rates are from column 1, "Total compensation."  The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

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

      The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring.  The capital/startup costs are one-time costs when a facility becomes subject to the regulation.  The annual operation and maintenance costs are the ongoing costs to maintain the 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 Costs, 
                                    (B X C)
                                      (E)
                    Annual O&M Cost for One Respondent
                                      (F)
                      Number of Respondents with O&M
                                      (G)
                             Total O&M Costs,
                                    (E X F)
                                  Temperature
                                     8,000
                                       0
                                      $0
                                    $2,100
                                      48
                                   $100,800
                                     TOTAL
                                       
                                       
                                       
                                       
                                       
                                   $100,800

      There are no capital/startup costs for this ICR.  This is the total of column D in the above table. 

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      The total operation and maintenance (O&M) costs for this ICR are $100,800. This is the total of column G. 
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      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 $100,800.  This is the  cost of recordkeeping. 
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      6(c)  Estimating Agency Burden and Cost

      The only costs to the Agency are those costs associated with analysis of the reported information.  EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. 
      
      The average annual Agency cost during the three years of the ICR is estimated to be $12,437.
      
      This cost is based on the average hourly labor rate as follows:
      
            Managerial	$62.27   (GS-13, Step 5, $38.92 x 1.6)
            Technical	$46.21   (GS-12, Step 1, $28.88 x 1.6)
            Clerical	$25.01   (GS-6, Step 3, $15.63 x 1.6)
      
These rates are from the Office of Personnel Management (OPM), 2012 General Schedule, which excludes locality, rates of pay.  The rates have been increased by 60 percent to account for the benefit packages available to government employees.  Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).

      6(d)  Estimating the Respondent Universe and Total Burden and Costs
      
      Based on our research for this ICR, on average over the next three years, approximately 48 existing respondents will be subject to the standard.  It is estimated that no additional respondents per year will become subject.  The overall average number of respondents, as shown in the table below, is 48 per year.  

                             Number of Respondents
                                     Year
                                      (A)
                         Number of New Respondents [1]
                                      (B)
                        Number of Existing Respondents
                                      (C)
  Number of Existing Respondents That Keep Records but Do Not Submit Reports
                                      (D)
         Number of Existing Respondents That Are Also New Respondents
                                      (E)
                             Number of Respondents
                                  (E=A+B+C-D)
                                       1
                                       0
                                      48
                                       0
                                       0
                                      48
                                       2
                                       0
                                      48
                                       0
                                       0
                                      48
                                       3
                                       0
                                      48
                                       0
                                       0
                                      48
                                    Average
                                       0
                                      48
                                       0
                                       0
                                      48
      [1] New respondent include sources with constructed, reconstructed and modified affected facilities.

      Column D is subtracted to avoid double-counting respondents.  As shown above, the average Number of Respondents over the three-year period of this ICR is 48.  
      
      The total number of annual responses per year is calculated using the following table:

                            Total Annual Responses
                                      (A)
                        Information Collection Activity
                                      (B)
                             Number of Respondents
                                      (C)
                              Number of Responses
                                      (D)
  Number of Existing Respondents That Keep Records But Do Not Submit Reports
                                      (E)
                            Total Annual Responses 
                                   E=(BxC)+D
Notification of construction/reconstruction
                                       0
                                       1
                                       0
                                       0
Notification of performance test
                                       0
                                      1.2
                                       0
                                       0
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 $497,092.  Details regarding these costs may be found below in Table 1: Annual Respondent Burden and Cost  -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal).
      
      6(e)  Bottom Line Burden Hours and Cost Tables
      
      The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.
      
      	(i)  Respondent Tally

      The total annual labor hours are 5,134 at a cost of $497,092.  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).  
      
      Furthermore, the annual public reporting and recordkeeping burden for this collection    of information is estimated to average 43 hours per response.
      
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      The total annual capital/startup and O&M costs to the regulated entity are $100,800.  The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.
      
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            (ii)  The Agency Tally
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      The average annual Agency burden and cost over next three years is estimated to be 276 labor hours at a cost of $12,437.  See: Table 2: Average Annual EPA Burden and Cost  -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal). 
      
      The bottom line burden hours and cost tables for both the Respondents and Agency are attached below and are shown in Tables 1 and 2, respectively, and summarized below.
      
      6(f)  Reasons for Change in Burden

      There is no change in labor hours in this ICR compared to the previous ICR.  This is due to two considerations: 1) the regulations have not changed over the past three years and are not anticipated to change over the next three years; and 2) the growth rate for the industry is very low, negative or non-existent, so there is no significant change in the overall burden. However, there is an increase in the total labor and Agency costs as currently identified in the OMB Inventory of Approved Burdens.  This increase is not due to any program changes.  The change in cost estimates reflects updated labors rates available from the Bureau of Labor Statistics.

      6(g)  Burden Statement
      
      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 43 hours per response.  "Burden" means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.
      
      An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number.  The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA - HQ - OECA - 2012 - 0532.  An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the docket ID number identified in this document.  The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA - HQ - OECA - 2012 - 0532 and OMB Control Number 2060-0001 in any correspondence.
      
Part B of the Supporting Statement

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










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)
                 Number of Occurrences Per Respondent Per Year
                                      (C)
                     Hours Per Respondent Per Year (C=AxB)
                                      (D)
                       Number of Respondents Per Year[a]
                                      (E)
                       Technical Hours Per Year (E=CxD)
                                      (F)
                     Management Hours Per Year (F=Ex0.05)
                                      (G)
                       Clerical Hours Per Year (G=Ex0.1)
                                      (H)
                            Total Costs Per Year[b]
                                      1.
Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      2.
Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      3.
Reporting Requirements



                                       
                                       
                                       
                                       


                                      a.
Read instructions
                                       1
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                      $0

                                      b.
Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       



Initial performance tests
                                      60
                                       1
                                      60
                                       0
                                       0
                                       0
                                       0
                                      $0



Repeat of performance tests [c]
                                      60
                                      0.2
                                      12
                                       0
                                       0
                                       0
                                       0
                                      $0

                                      c.
Gather existing information
Included in 3b

                                      d.
Write report





                                                                               
                                                                               
                                                                               



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



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



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



Report of performance test
Included in 3b



Semiannual report [d]
                                       8
                                       2
                                      16
                                      48
                                      768
                                     38.4
                                     76.8
                                  $85,521.14



Excess emissions report [d]
                                       5
                                      0.5
                                      2.5
                                      48
                                      120
                                       6
                                      12
                                  $13,362.68

Subtotal for Reporting Requirements
                                       
                                       
                                       
                                       
                                    1,021.2
                                  $98,883.82
                                      4.
Recordkeeping Requirements









                                      a.
Read instructions
Included in 3a

                                      b.
Plan activities
Included in 3b

                                      c.
Implement activities (monthly performance test)
                                       1
                                      12
                                      12
                                      48
                                      576
                                     28.8
                                     57.6
                                  $64,140.85

                                      d.
Develop record system
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       



Records of operating parameter [e]
                                     0.25
                                      250
                                     62.5
                                      48
                                     3,000
                                      150
                                      300
                                  $334,066.95

Subtotal for Recordkeeping Requirements




                                    4,112.4
                                  $398,207.80

TOTAL LABOR BURDEN AND COST
(rounded)
                                       
                                       
                                       
                                       
                                     5,134
                                   $497,092
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Assumptions:
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   [a]  Assumes an average of 48 affected facilities, with no new plants coming online.	
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   [b]  This ICR uses the following labor rates:  $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51 per hour for Clerical labor.  These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, Table 2. Civilian Workers, by occupational and industry group.  The rates are from column 1, "Total compensation."  The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
--------------------------------------------------------------------------------
   [c]  Assumed 20% rate of failed performance tests.
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   [d]  Each plant files an excess emission report every other year and a semiannual report twice a year.
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   [e]  Assume operation 250 days per year as specified in the NSPS review document.

Table 2.  Average Annual EPA Burden and Cost  -  NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal)
                                  Burden Item
                                      (A)
                        EPA person-hours per occurrence
                                      (B)
                     No. of occurrences per plant per year
                                      (C)
                      EPA person-hours per plant per year
                                    (C=AxB)
                                      (D)
                              Plants per year [a]
                                      (E)
                        Technical person-hours per year
                                    (E=CxD)
                                      (F)
                       Management person-hours per year
                                   (Ex0.05)
                                      (G)
                        Clerical person-hours per year
                                    (Ex0.1)
                                      (H)
                            Total cost per year [b]
1.  Initial performance test
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                      $0
2.  Repeat performance test [c]
                                      24
                                      0.2
                                      4.8
                                       0
                                       0
                                       0
                                       0
                                      $0
3.  Report review







                                       
  A.  New Plants	
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i.  Notification of construction
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                      $0
    ii.  Notification of initial startup
                                      0.5
                                       1
                                      0.5
                                       0
                                       0
                                       0
                                       0
                                      $0
    iii. Notification of actual startup
                                      0.5
                                       1
                                      0.5
                                       0
                                       0
                                       0
                                       0
                                      $0
    iv. Notification of initial test
                                      0.5
                                      1.2
                                      0.6
                                       0
                                       0
                                       0
                                       0
                                      $0
    v. Review test results
                                       8
                                      1.2
                                      9.6
                                       0
                                       0
                                       0
                                       0
                                      $0
  B.  Existing Plants








    i.  Semiannual reports
                                       2
                                       2
                                       4
                                      48
                                      192
                                      9.6
                                     19.2
                                   $9,949.90
    ii.  Excess emissions reports
                                       2
                                      .5
                                       1
                                      48
                                      48
                                      2.4
                                      4.8
                                   $2,487.48
Subtotal Annual Burden and Cost



                                       
                                      240
                                      12
                                      24
                                  $12,437.38
TOTAL  ANNUAL BURDEN AND COST
(rounded)



                                       
                                      276
                                    $12,437
--------------------------------------------------------------------------------
Assumptions:
--------------------------------------------------------------------------------
  [a]  Assumes an average of 48 affected facilities, with no new plants coming online.
--------------------------------------------------------------------------------
  [b]  This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of Personnel Management (OPM) 2012 General Schedule, which excludes locality rates of pay.
--------------------------------------------------------------------------------
  [c]  Assumed 20% rate of failed performance tests.
