| Table 1: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal) |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Total Cost
Per year b |
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| 1. Reporting Requirements |
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Labor Rates |
| a. Familiarization with the regulatory requirements |
4 |
1 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
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$172.41 |
Managerial |
| b. Compile and process data |
4 |
4 |
16 |
5 |
80 |
4 |
8 |
$12,601 |
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$141.75 |
Technical |
| c. Write reports |
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0 |
0 |
0 |
$0 |
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$71.36 |
Clerical |
| i. Initial notification |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| ii. Notification of compliance status |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| iii. Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| iv. Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| v. Notification of performance test c |
2 |
1 |
2 |
0.2 |
0.4 |
0.02 |
0.04 |
$63 |
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| vi. Report of performance test c |
10 |
1 |
10 |
0.2 |
2 |
0.1 |
0.2 |
$315 |
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| vii. Semiannual report |
6 |
2 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
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| viii. Excess emissions report |
2 |
2 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
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| ix. Startup, shutdown, malfunction report d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| x. Add-on control performance test e |
30 |
1 |
30 |
0.2 |
6 |
0.3 |
0.6 |
$945.04 |
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| Subtotal for Reporting Requirements |
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217 |
$29,674 |
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| 2. Recordkeeping requirements |
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| a. Familiarization with the regulatory requirements |
4 |
1 |
4 |
5 |
20 |
1 |
2 |
$3,150 |
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| b. Plan activities |
12 |
1 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
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| c. Implement activities |
12 |
1 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
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| d. Maintain record system for material used |
20 |
1 |
20 |
5 |
100 |
5 |
10 |
$15,751 |
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| e. Revise record systems due to SSM revisions f |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| f. Time to enter information |
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| i. Material usage |
0.5 |
365 |
182.5 |
5 |
912.5 |
45.625 |
91.25 |
$143,725 |
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| ii. Compliance calculation |
2 |
12 |
24 |
5 |
120 |
6 |
12 |
$18,901 |
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| g. Time to train personnel |
10 |
1 |
10 |
5 |
50 |
2.5 |
5 |
$7,875 |
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| h. Store, file, and maintain records |
2 |
12 |
24 |
5 |
120 |
6 |
12 |
$18,901 |
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| i. Retrieve records/reports |
1 |
12 |
12 |
5 |
60 |
3 |
6 |
$9,450 |
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| Subtotal for Recordkeeping Requirements |
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1,728 |
$236,654 |
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| TOTAL LABOR BURDEN AND COST (rounded) g |
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1,940 |
$266,300 |
hrs/response |
95 |
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| Total CAPITAL and O&M COST (rounded) g |
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$15,400 |
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| GRAND TOTAL (rounded) g |
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1,940 |
$282,000 |
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| Assumptions: |
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| 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. |
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| b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and 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. |
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| c. We have 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). |
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| d. Previous ICR assumed 25 percent of facilities use add-on controls and submit startup, shutdown, malfunction (SSM) reports once per year. The 2020 rule amendment eliminated the SSM report requirement. |
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| e. Facilities that comply using emission capture systems and add-on controls are required to conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the facility to obtain the testing contractor, plan and attend the test, review the test report, and load it to ERT. One facility has three add-on controls and is not already required to perform periodic testing by the facility's state-issued permit. The final RTR amendments will require this facility to do performance testing every five years. |
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| f. We assume no facilities will need to revise their record systems due to SSM revisions from the 2020 amendments. |
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| g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Renewal) |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| EPA person- hours per occurrence |
No. of occurrences per plant per year |
EPA person- hours per plant per year (C=AxB) |
Plants per year a |
Technical person- hours per year (E=CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Cost, $ b |
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| 1. Initial performance test |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
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Labor Rates |
| 2. Repeat performance test |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
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$76.91 |
Managerial |
| 3. Report review |
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$57.07 |
Technical |
| a. Initial notification |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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$30.88 |
Clerical |
| b. Notification of performance test c |
8 |
1 |
8 |
0.2 |
1.6 |
0.08 |
0.16 |
$102 |
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| c. Notification of compliance status |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| d. Notification of construction/reconstruction |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| e. Notification of actual startup |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| f. Report of performance test d |
8 |
1 |
8 |
0.2 |
1.6 |
0.08 |
0.16 |
$102 |
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| g. Semiannual report |
12 |
2 |
24 |
5 |
120 |
6 |
12 |
$7,681 |
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| h. Excess emissions report |
4 |
2 |
8 |
5 |
40 |
2 |
4 |
$2,560 |
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| i. Startup, shutdown, reporte |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| j. Review record systems due to SSM revisions f |
2 |
2 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| TOTAL (rounded) g |
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188 |
$10,400 |
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| Assumptions: |
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| 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. |
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| 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. |
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| 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). |
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| d. We have assumed that it will take eight hours to review the test report for each respondent. |
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| e. The 2020 rule amendment eliminated the SSM report requirement. |
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| 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. |
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| g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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| Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E X F) |
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| Testing a |
$18,750 / $14,063 |
0.2 |
$9,375 |
$0 |
0 |
$0 |
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| CPMS b |
$16,000 |
0 |
$0 |
$1,200 |
5 |
$6,000 |
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| Totals (rounded) c |
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$9,380 |
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$6,000 |
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$15,400 |
| 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. |
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| b CMPS is required for complying with operating limits such as RTO temperature monitoring. |
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| c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Total Annual Responses |
| (A) |
(B) |
(C) |
(D) |
(E) |
| Information Collection Activity |
Number of Respondents a |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
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 |
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Total (rounded) |
20 |
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| a New respondents include sources with constructed, reconstructed and modified affected facilities. |
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