U.S. Environmental Protection Agency
Information Collection Request
Title: NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal)
OMB Control Number: 2060-0541
EPA ICR Number: 2079.10
Abstract:
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal Can Manufacturing Surface Coating were proposed on January 15, 2003, promulgated on November 13, 2003, and most recently amended on February 25, 2020. The latest amendment was a residual risk and technology review (RTR) required of periodic air emissions testing, revisions to the startup, shutdown, and malfunction (SSM) provisions, and the use of electronic data reporting for performance test data submittals notifications, and reports. These regulations apply to existing and new facilities in this source category that use 5,700 liters (1,500 gallons) per year or more of coatings and that is a major source of hazardous air pollutant (HAP). The metal can surface coating source category includes any facilities that coat or print metal cans (including decorative tins), metal ends for metal or composite cans, or metal crowns or closures for any type of can during any stage of the can manufacturing process. The source category does not include the coating of metal coils for cans or can parts. Coil coating for cans and can parts is included in the NESHAP for the surface coating of metal coil (40 CFR Part 63, Subpart SSSS). The source category does not include the coating of pails and drums, which is covered in the NESHAP for the surface coating of miscellaneous metal parts and products (40 CFR Part 63, Subpart MMMM). New facilities include those that commenced construction or reconstruction after January 15, 2003. 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.
Over the next three years, approximately 5 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.
The Office of Management and Budget (OMB) approved the currently active ICR with the following Terms of Clearance:
“In accordance with 5 CFR 1320, the information collection is approved for three years. As terms of clearance, upon renewal of this collection, EPA is required to include the following in its supporting statement for this and other NESHAP ICRs: (1) a description of the regulatory text applicable to the ICR including submission specifications; (2) a clear description of the data elements being collected under the ICR; (3) screen shots of the electronic portal where the reporting requirements are submitted to EPA (with the control number and burden statement); (4) a detailed discussion of how information is submitted and the extent to which electronic reporting is available; (5) evidence of consultation with respondents (by actively reaching out to stakeholders as permitted by the PRA) to ensure the supporting statement's accuracy on availability of data, frequency of collection, clarity of instructions, accuracy of burden estimate, relevance of data elements, and similar PRA matters; and (6) discussion of how EPA addressed substantive concerns raised by respondents and other stakeholders during consultation and in response to comments received on FR notices. In addition, please convert the supporting statement to the standard 18 question SS-A format upon renewal.”
The relevant regulatory text is referenced in section 12b of this document. We have created a supplementary document including the regulatory text that describes the ICR requirements, which includes a description of the data elements being collected under the ICR, as identified in section 12b of this document. All electronic collection in this information collection is submitted through EPA's ERT, as discussed in section 12b of this document. Additional Paperwork Reduction Act requirements for CEDRI and ERT, including the burden statement and OMB control number, are available at: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert. We have created supplementary documents that include screenshots of the electronic portal where the reporting requirements are submitted online to EPA, including the OMB burden statement on the electronic portal. A description of the EPA’s consultation with respondents and how EPA responded to any concerns raised by respondents or other stakeholders is discussed in section 8 of this document. Per the Terms of Clearance on the previous ICR, this supporting statement follows the standard 18-question format.
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate 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/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 surface coating cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart KKKK.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the CAA. The collected information is also used for targeting inspections and as evidence in legal proceedings.
For facilities using the emission rate with add-on control compliance option, performance tests are required to determine an affected facility’s initial and ongoing capability to comply with the emission standard. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance. Continuous parameter monitoring systems are used to ensure compliance with the standard at all times.
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.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
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.
The rule was amended to include electronic reporting provisions on February 25, 2020. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and performance evaluation reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts. Respondents are also required to submit electronic copies of certain notifications through EPA’s CEDRI. The notification is an upload of their currently required notification in portable document format (PDF) file. The semiannual compliance reports are to be created using the electronic template included with this Supporting Statement. The template is an Excel spreadsheet which can be partially completed and saved for subsequent annual and semiannual reports to limit some of the repetitive data entry. It reflects the reporting elements required by the rule and does not impose additional reporting elements. The OMB Control Number is displayed on the Welcome page of the template, with a link to an online repository that contains the PRA requirements. The For purposes of this ICR, it is assumed that there is no additional burden associated with the requirement for respondents to submit the notifications and reports electronically. The supplemental files to this ICR renewal contain screenshots showing the CDX homepage for CEDRI login, the CEDRI PRA screen, the CEDRI interface for managing reports for various subparts, and the landing page of the ERT that shows the link to PRA information.
Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.
Information contained in these reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by the EPA's Office of Compliance. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze the data.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication.
For all other reports, 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 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.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
A majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum 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.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
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.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB 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 with 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.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (89 FR 63933) on August 6, 2024. No comments were received on the burden published in the Federal Register for this renewal.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately six respondents will be subject to the standard over the three-year period covered by this ICR.
Industry trade association(s) 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. In developing this ICR, we contacted both the Can Manufacturers Institute at (202) 232-4677, and the American Coatings Association at (202) 462-6272. In this case, no comments were received.
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.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts are made to respondents.
ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
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).
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
The respondents to the recordkeeping and reporting requirements are owners or operators of existing major sources coating metal cans, ends, metal crowns and closures. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standards are listed in the table below:
Standard (40 CFR Part 63, Subpart KKKK) |
SIC Codes |
NAICS Codes |
Metal Can Manufacturing |
3411 |
332431 |
Metal Crown, Closure, and Other Metal Stamping (except Automotive) |
3466 |
332119 |
Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers |
3999 |
332812 |
All Other Miscellaneous Fabricated Metal Product Manufacturing |
3497 |
332999 |
Based on our research for this ICR, on average over the next three years, approximately five existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject, for an overall total of five respondents per year. The number of respondents is calculated using the table Number of Respondents that addresses the three years covered by this ICR. None of the facilities in the United States are owned by either state, local, or tribal entities or by the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries. Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).
The total number of annual responses per year is calculated using the table Total Annual Responses shown below. The number of Total Annual Responses is 20.
In this ICR, all the data that are recorded or reported is required by the Surface Coating of Metal Cans NESHAP (40 CFR Part 63, Subpart KKKK). Any owner/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.
A source must make the following reports:
Notifications |
|
Initial notification (electronic submission) |
§63.3510(b), §63.5(d), §63.9(b) |
Notification of compliance status (electronic submission) |
§63.3510(c), §§63.9(h)(1-3) |
Notification of construction or reconstruction |
§63.3510(a), §63.5(a) |
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 of changes in information (reclassification to area source status or to revert to major source status) (electronic submission) |
§63.9(b), §63.9(j) |
Reports |
|
Semiannual compliance report |
§63.3511(a) |
Excess emissions report |
§§63.3511(a)(5-8) |
Report of performance test (electronic submission) |
§§63.3511(b) and (d), §63.10(d)(2). |
Startup, shutdown, malfunction report |
§63.3511(c) |
A source must keep the following records:
Recordkeeping |
|
Copies of notifications and reports |
§63.3512(a) |
Material formulation data |
§63.3512(b) |
HAP content calculations |
§63.3512(c) |
Names and volume of materials used |
§63.3512(d) |
Mass fraction of HAP in each material used |
§63.3512(e) |
Volume fraction of coating solids 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 date, time, and duration of each deviation |
§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) |
Respondent Activities |
Familiarization with the regulatory requirements. |
Install, calibrate, maintain, and operate CPMS for operating limit parameters for emission capture systems and for add-on control devices, if using them to demonstrate compliance. |
Perform initial performance test, using applicable methods: Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 18, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E, 204F, 301, 311, ASTM Methods D2697-86 and D1475-90. Test and repeat performance tests if using an emission capture system and add-on control device to demonstrate compliance. |
If owner or operator chooses to account for the mass of organic HAP in wastewater, Reference Method 25D, 301, 305, 624, 625, 1624, 1625. |
Write the notifications and reports listed above. |
Enter information required to be recorded above. |
Electronically submit the required reports via CEDRI, 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 processing and maintaining information. |
Develop, acquire, install, and utilize technology and systems for disclosing and providing information. |
Train personnel to be able to respond to a collection of information. |
12d. Respondent Burden Hours and Labor Costs
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 average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1,940 hours (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.
This ICR uses the following labor rates:
Managerial $172.41 ($82.10 + 110%)
Technical $141.75 ($67.50 + 110%)
Clerical $71.36 ($33.98 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
The type of industry costs associated with the information collection activities in the subject standard(s) are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to this regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.
The total capital/startup costs for this ICR are $9,380. This is the total of column D shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) Costs.
The total operation and maintenance (O&M) costs for this ICR are $6,000. This is the total of column G shown below in the table Capital/Startup vs. Operation and Maintenance (O&M) Costs.
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 $15,400.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:
• Observe initial performance tests, and repeated 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 Enforcement and Compliance History Online (ECHO) and ICIS.
Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
14b. Agency Labor Cost
The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors. The only costs to the Agency are those costs associated with analysis of the reported information. The EPA's overall compliance and enforcement program includes such activities 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 burden and cost during the three years of the ICR is estimated to be 188 hours at a cost of $10,400. See Table 2: Average Annual EPA Burden and Cost – Table 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal).
This cost is based on the average hourly labor rate as follows:
Managerial $76.91 (GS-13, Step 5, $48.07 + 60%)
Technical $57.07 (GS-12, Step 1, $35.67 + 60%)
Clerical $30.88 (GS-6, Step 3, $19.30+ 60%)
These rates are from the Office of Personnel Management (OPM), 2024 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 at the end of this document in Table 2: Average Annual EPA Burden and Cost – Table 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal).
14c. Agency Non-Labor Costs
There are no non-labor costs to the Agency associated with this information collection.
REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
There is a decrease in burden from the most recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. The burden currently identified in the OMB Inventory of Approved Burdens is 1954 hours, which is the sum of the incremental burden from the 2020 amendments (54 hours per year) and the total burden from the prior ICR renewal (1940 hours per year). The previous ICR reflected those burdens and costs associated with the initial activities for subject facilities due to the 2020 amendments. This included time to familiarize with CEDRI for electronic reporting and revision of record systems due to the revisions for periods of startup, shutdown, and malfunction. There is also a decrease in the Capital O&M compared to the previously approved ICR. Most of the Capital O&M included with the previous ICR is associated with capital and startup costs. This ICR, by in large, reflects the on-going burden and costs for existing facilities following rulemaking activities.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
All non-CBI data submitted electronically to the Agency through CEDRI are available to the public for review and printing and are accessible using WebFIRE. Electronically submitted emissions data from performance testing or performance evaluations using the Electronic Reporting Tool or templates attached to CEDRI, as well as data from reports from regulations with electronic templates, are tabulated; data submitted as portable document format (PDF) files attached to CEDRI are neither tabulated nor subject to complex analytical techniques. Electronically submitted emissions data used to develop emissions factors undergo complex analytical techniques and the draft emissions factors are available on the Clearinghouse for Inventories and Emission Factors listserv at https://www.epa.gov/chief/chief-listserv for public review and printing. Electronically submitted emissions data, as well as other data, obtained from one-time or sporadic information collection requests often undergo complex analytical techniques; results of those activities are included in individual rulemaking dockets and are available at https://www.regulations.gov/ for public review and printing.
DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
EPA will display the expiration date for OMB approval of the information collection.
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions to the topics of the certification statement.
Table 1: Annual Respondent Burden and Cost – NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal)
Burden Item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Technical person-hours per respondent per year (AxB) |
(D) Respondents per year b |
(E) Technical hours per year (CxD) |
(F) Management hours per year (Ex0.05) |
(G) Clerical hours per year (Ex0.1) |
(H) Total cost per year ($) a |
1. Reporting Requirements |
|
|
|
|
|
|
|
|
a. Familiarization with the regulatory requirements |
4 |
1 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
b. Compile and process data |
4 |
4 |
16 |
5 |
80 |
4 |
8 |
$12,601 |
c. Write reports |
|
|
|
|
0 |
0 |
0 |
$0 |
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 c |
2 |
1 |
2 |
0.2 |
0.4 |
0.02 |
0.04 |
$63 |
vi. Report of performance test c |
10 |
1 |
10 |
0.2 |
2 |
0.1 |
0.2 |
$315 |
vii. Semiannual report |
6 |
2 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
viii. Excess emissions report |
2 |
2 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
ix. Startup, shutdown, malfunction report d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
x. Add-on control performance test e |
30 |
1 |
30 |
0.2 |
6 |
0.3 |
0.6 |
$945.04 |
Subtotal for Reporting Requirements |
|
|
|
|
217 |
$29,674 |
||
2. Recordkeeping requirements |
|
|
|
|
|
|
|
|
a. Familiarization with the regulatory requirements |
4 |
1 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
b. Plan activities |
12 |
1 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
c. Implement activities |
12 |
1 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
d. Maintain record system for material used |
20 |
1 |
20 |
5 |
100 |
5 |
10 |
$15,751 |
e. Revise record systems due to SSM revisions f |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
f. Time to enter information |
|
|
|
|
|
|
|
|
i. Material usage |
0.5 |
365 |
182.5 |
5 |
912.5 |
45.625 |
91.25 |
$143,725 |
ii. Compliance calculation |
2 |
12 |
24 |
5 |
120 |
6 |
12 |
$18,901 |
g. Time to train personnel |
10 |
1 |
10 |
5 |
50 |
2.5 |
5 |
$7,875 |
h. Store, file, and maintain records |
2 |
12 |
24 |
5 |
120 |
6 |
12 |
$18,901 |
i. Retrieve records/reports |
1 |
12 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
Subtotal for Recordkeeping Requirements |
|
|
|
|
1,728 |
$236,654 |
||
TOTAL ANNUAL BURDEN AND COST (ROUNDED) e |
|
|
|
|
1,940 |
$266,000 |
||
Capital and O&M Cost (see Section 6(b)(iii)): e |
|
|
|
|
|
$15,400 |
||
TOTAL COST: e |
|
|
|
|
1,940
|
$282,000 |
||
Assumptions: |
||||||||
a. We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional sources over the three-year period of this ICR. |
||||||||
b. This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
||||||||
c. We have assumed that it will take four hours to review the notification of the test and the test plan for each respondent. We have further assumed that one facility will be required to conduct testing not already required by their Part 70 permit once every 5 years (1 facility / 5 years = 0.2 facility per year). |
||||||||
d. We have assumed that it will take eight hours to review the test report for each respondent. |
||||||||
e. The 2020 rule amendment eliminated the SSM report requirement. f. We assume no record systems will need to be revised during the 3-year period of this ICR due to SSM revisions from the 2020 amendments. g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
||||||||
Table 2: Average Annual EPA Burden and Cost – NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal)
Burden Item |
(A) EPA hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) EPA person-hours per respondent per year (AxB) |
(D) Plants per year b |
(E) Technical hours per year (CxD) |
(F) Management hours per year (Ex0.05) |
(G) Clerical hours per year (Ex0.1) |
(H) Total cost per year a ($) |
|
|
1. Initial performance test |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
2. Repeat performance test |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
3. Report review |
|
|
|
|
|
|
|
|
|
|
a. Initial notification |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
b. Notification of performance test c |
8 |
1 |
8 |
0.2 |
1.6 |
0.08 |
0.16 |
$102 |
|
|
c. Notification of compliance status |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
d. Notification of construction/reconstruction |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
e. Notification of actual startup |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
f. Report of performance test d |
8 |
1 |
8 |
0.2 |
1.6 |
0.08 |
0.16 |
$102 |
|
|
g. Semiannual report |
12 |
2 |
24 |
5 |
120 |
6 |
12 |
$7,681 |
|
|
h. Excess emissions report |
4 |
2 |
8 |
5 |
40 |
2 |
4 |
$2,560 |
|
|
i. Startup, shutdown, report e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
j. Review record systems due to SSM revisions f |
2 |
2 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
TOTAL (ROUNDED) g |
188 |
$10,400 |
|
|||||||
|
Assumptions: a. We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional sources over the three-year period of this ICR. |
|||||||||
|
b. This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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. |
|||||||||
|
c. We have assumed that it will take four hours to review the notification of the test and the test plan for each respondent. We have further assumed that one facility will be required to conduct testing not already required by their Part 70 permit once every 5 years (1 facility / 5 years = 0.2 facility per year). |
|||||||||
|
d. We have assumed that it will take eight hours to review the test report for each respondent. e. The 2020 rule amendment eliminated the SSM report requirement. f. We assume no record systems will need to be revised during the 3-year period of this ICR due to SSM revisions from the 2020 amendments. g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|||||||||
|
|
|||||||||
Number of Respondents |
|||||
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
||
Year |
(A) Number of New Respondents 1 |
(B) Number of Existing Respondents |
(C) Number of Existing Respondents that keep records but do not submit reports |
(D) Number of Existing Respondents That Are Also New Respondents |
(E) Number of Respondents (E=A+B+C-D) |
1 |
0 |
5 |
0 |
0 |
5 |
2 |
0 |
5 |
0 |
0 |
5 |
3 |
0 |
5 |
0 |
0 |
5 |
Average |
0 |
5 |
0 |
0 |
5 |
a New respondents include sources with constructed, reconstructed and modified affected facilities.
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 |
0.2 |
1 |
0 |
0.2 |
Report of performance test |
0.2 |
1 |
0 |
0.2 |
Semiannual report |
5 |
2 |
0 |
10 |
Excess emissions report |
5 |
2 |
0 |
10 |
Startup, shutdown, malfunction report |
0 |
1 |
0 |
0 |
|
|
|
Total (rounded) |
20 |
a New respondents include sources with constructed, reconstructed and modified affected facilities.
Capital/Startup vs. Operation and Maintenance (O&M) Costs |
||||||
(A) Continuous Monitoring Device |
(B) Capital/Startup Cost for One Respondent |
(C) Number of New Respondents |
(D) Total Capital/Startup Cost, (B X C) |
(E) Annual O&M Costs for One Respondent |
(F) Number of Respondents with O&M |
(G) Total O&M, (E X F) |
Testing a |
$18,750 / $14,063 |
0.2 |
$9,375 |
$0 |
0 |
$0 |
CPMS b |
$16,000 |
0 |
$0 |
$1,200 |
5 |
$6,000 |
Totals (rounded) c |
|
|
$9,380 |
|
|
$6,000 |
a. We assume three add-on control devices at one facility will be required to conduct periodic performance testing once every five years (1 facility / 5 years = 0.2 facility per year). We assume that all three devices will be tested during one visit by a testing company. EPA assumes that the cost of testing is 25% less for the second unit and subsequent units at one site. Assuming the cost for testing one control device is $18,750, the cost for testing three control devices at one site is $18,750 + $14,063 + $14,063 = $46,876.
b. CMPS is required for complying with operating limits such as RTO temperature monitoring.
c. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | McGrath, Daniel |
| File Modified | 0000-00-00 |
| File Created | 2025-03-01 |