Burden Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	43
Number of Respondents	46
Total Estimated Burden Hours	4,970
Total Estimated Costs	$777,600
Annualized Capital O&M	$96,600
Form Number	Not Applicable

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Sheet 2: Table 1

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) No. of occurrence per respondent per year	(C) Person-hours per respondent per year (C = A x B)	(D) Respondents per yeara	(E) Technical person-hours per year (E = C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Cost b $
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Mgmt.	$172.41
3. Reporting Requirements										Tech.	$141.75
A. Familiarization with regulatory requirements	1	1	1	46	46	2.3	4.6	$7,245.30		Cler.	$71.36
B. Required activities
i. Initial Performance Test	60	1	60	0	0	0	0	$0
ii. Repeat Performance Test c	60	0.2	12	0	0	0	0	$0
C. Gather Existing Information	3B
D. Write report
i. Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
ii. Notification of initial performance test	2	1.2	2.4	0	0	0	0	$0
iii. Notification of actual startup	2	1	2	0	0	0	0	$0
iv. Report of performance test	3B
v. Semiannual report d	8	2	16	46	736	36.8	73.6	$115,924.78
vi. Excess emissions report d	5	0.5	2.5	46	115	5.75	11.5	$18,113.25
Subtotal for Reporting Requirements					1,032			$141,283
4. Recordkeeping Requirements
A. Familiarization with regulatory requirements	3A
B. Plan activities	3B
C. Implement activities (Monthly Performance Test)	1	12	12	46	552	27.6	55.2	$86,943.59
D. Develop record system	N/A
i. Records of operating parameter e	0.25	250	62.5	46	2875	143.75	287.5	$452,831.19
Subtotal for Recordkeeping Requirements					3,941			$539,775
TOTAL LABOR BURDEN AND COSTS (rounded): f					4,970			$681,000		hr/response
TOTAL CAPITAL AND O&M COST (rounded): f								$96,600		43.0
GRAND TOTAL (rounded): f								$777,600
Assumptions:
a Assumes an average of 46 affected facilities, with no new plants coming online.
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.
c Assumed 20% rate of failed performance tests.
d Each plant files an excess emission report every other year and a semiannual report twice a year.
e Assume operation 250 days per year as specified in the NSPS review document.
f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Beverage Can Surface Coating (40 CFR Part 60, Subpart WW) (Renewal)
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person-hours per plant per year (C = A x B)	(D) Plants per year a	(E) Technical person-hours per year (E = C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost b $
1. Initial Performance Test	23	1	23	0	0	0	0	$0		Agency Labor Rates
2. Repeat Performance Test c	23	1	23	0	0	0	0	$0		Technical	$57.07
3. Report Review										Managerial	$76.91
A. New Plants										Clerical	$30.88
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	46	184	9.2	18.4	$11,776.64
ii. Excess Emissions Reports	2	0.5	1	46	46	2.3	4.6	$2,944.16
TOTAL (rounded): d					265			$14,700
Assumptions:
a Assumes an average of 46 affected facilities, with no new plants coming online.
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 Assumed 20% rate of failed performance tests.
d Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

6(b)(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 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)
Temperature	$8,000	0	$0	$2,100	46	$96,600

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Sheet 5: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	46	0	0	46
2	0	46	0	0	46
3	0	46	0	0	46
Average	0	46	0	0	46
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 6: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	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	46	2	0	92
Excess emissions report	46	0.5	0	23
		Total (rounded)		115