0223-00-008\Auto Refinishing Capital & Annual Cost 1

MEMORANDUM 

TO: Warren Johnson, U.S. EPA, Sectors Policies and Programs Division/Natural 

 Resources and Commerce Group 

FROM: Brandin McDonough and Brian Palmer, Eastern Research Group, Inc. (ERG) 

DATE: May 18, 2007 

SUBJECT: Estimate of Capital and Annual Costs For Automotive Refinishing Operations and 

Miscellaneous Surface Coating Operations Subject to the Proposed National 

Emission Standards for Hazardous Air Pollutants for Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources 

 This memo documents the procedures we used to estimate costs for all surface coating 

area sources that would be regulated under the Miscellaneous Surface Coating Area Source 

National Emission Standards for Hazardous Air Pollutants (NESHAP). We estimate that the 

controls required to comply with the proposed standards for surface coating operations at about 

36,000 automotive refinishing shops and 800 miscellaneous plastic and metal part surface 

coating operations would have no net annual costs to those surface coating operations. The 

initial cost of complying with the proposed standards would be off-set and recovered over time 

by cost savings as a result of more efficient use of labor and materials by surface coating 

operations. 

 Initial and annualized costs were estimated for the following proposed rule requirements: 

• Completing painter training to properly set up and use high-volume low-pressure 

(HVLP) spray guns to increase transfer efficiency at all by an estimated 94,533 

painters. 

• Upgrading to HVLP spray guns at 208 sources with the purchase of an average of 3 

guns per source (624 spray guns, total). 

• Installing enclosed and automated gun washers at 5,214 sources. 

• Complying with equipment specifications or minimum efficiency standards for paint 

spray booth exhaust filters. 

 
0223-00-008\Auto Refinishing Capital & Annual Cost 2

Table 1 summarizes the initial cost and annualized cost impacts of the miscellaneous surface 

coating standards. As explained in the following sections, we estimate that the proposed 

standards for surface coating operations will have no net annual cost after cost savings are taken 

into account. 

Table 1. National Initial and Annualized Costs of Miscellaneous Surface Coating Area 

Source Requirements. All costs are in millions (MM) of dollars. 

Cost Item Number required Capital Cost ($MM) Annualized Cost ($MM)

Painter 

Training 

94,533 $94.5 $18.9 

HVLP guns 624 $0.44 $0.06 

Gun washers 5,214 $9.4 $1.33 

Total $104.3 $20.29 

The cost of installing and operating spray booths are not included in the estimated total 

costs impacts for this rule because spray booths are previously required for compliance with 

existing OSHA standards (29 CFR 1910.94(c) and 1910.107(b)). Some surface coating sources 

may need to replace their current filters for ones with higher paint overspray capture efficiency, 

but the higher efficiency filters are readily available and will not result in an additional cost. 

Assumptions and Procedure for Estimating Painter Training Costs

To estimate painter training costs, we developed four categories of model shops. Three 

model shops represented automotive refinish shops and one model shop represented a 

miscellaneous surface coating operation. 

The three model automotive refinish shops were based on information obtained in the 

2003 U.S. Census County Business Patterns and through EPA site visits, and are summarized in 

Table 2.1 These models included the total number of employees and number of painters. 

 

1

 Memorandum. To: Kim Teal, U.S. EPA, Sector Policies and Programs Division/Natural Resources and Commerce 

Group (E143-03). From: Brian Palmer, Eastern Research Group, Inc. July 17, 2006. Development of Model Shops 

for Sources Subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Motor Vehicles 

and Mobile Equipment Refinishing Operations for Area Sources. 
0223-00-008\Auto Refinishing Capital & Annual Cost 3

Table 2. Summary of Automotive Refinishing Model Shop Parameters 

Shop Size Small Medium Large 

Number of Vehicles Refinished Per Month 40 100 200

Number of employees 1-9 10-19 20 or more

Estimated Number of Shops (from County 

Business Patterns) 

28,351 5,490 1,914

Total Number of Employees (estimated from 

County Business Patterns) 

107,674 79,605 74,349

Average number of employees per shop 3.8 14.5 39.4

Number of Painters Per Shop 2 4 7

Total Number of Painters Needing Training 56,702 21,960 13,398

We estimated the number of painters for the three sizes of auto shops based on 

observations made during EPA site visits. Table 3 presents the number of vehicles per month 

and the number of painters at each of the sites visited by EPA. The sites with very low numbers 

of vehicles (5 or fewer per month) were either custom restoration shops or mobile equipment 

repair shops. 

Table 3. Vehicle and Painter Information Collected During EPA Site Visits 

Name and Location 

Vehicles per 

Month 

No. of 

Painters 

Advanced Restoration and Autobody, Sacramento, CA 1 1

The Finish Line Restoration Services, Inc., Monrovia, CA 1 1

Durham School District Transportation Department Garage, Durham, NC 3 2

NC DOT Maintenance Garage, Raleigh, NC 5 1

Gemini Autobody, Cedar Falls, IA 8 1

Fulton Autobody, Sacramento, CA 15 1

McJack’s Corvette, Santa Ana, CA 20 1

Dale Bright Auto Service, Chino, CA 30 1

Walt Stickel Body and Frame Shop, Inc., Sacramento, CA 45 2

Cherry Auto Body, Chino, CA 60 2

Coffman's Body Shop, Cedar Falls, IA 72 4

Niello Collision Service, Sacramento, CA 90 3

California Auto Body, Sacramento, CA 100 4

Maaco Sacramento, CA 120 2

Zimmerman Ford , Cedar Rapids, IA 150 4

Bertolucci’s Body and Fender Shop, Inc., Sacramento, CA 200 5

Falconi's Collision Center, Las Vegas, NV 280 5

Deery Brothers Collision Center, Cedar Falls, IA 300 4

Seidner’s Collision Center, Duarte, CA 310 9

Based on the site visit information and contacts with industry, we estimated that a small 

shop (40 cars per month), would have two painters. For a medium shop (100 cars per month), 
0223-00-008\Auto Refinishing Capital & Annual Cost 4

we estimated four painters, and for a large shop (200 cars per month) we estimated seven 

painters. 

ERG contacted a coating vendor, Robert Blair of Finishmaster Automotive and Industrial 

Paint, who is a former auto refinisher and he concurred with our model shop estimates and 

observations for the number of painters at small and medium shops.2 He suggested that the 

number of painters for most of the large shops that we visited was probably too low because it 

only included the journeyman (finish) painters and did not include the painters that performed 

the priming and jamming, also known as prep painters. He confirmed that a shop servicing 300 

cars per month would have about nine painters, total. Therefore, for the large model shop, we 

estimated seven painters because it is the midpoint between the number of painters for a medium 

shop (100 cars per month) and the confirmed number of painters for a shop painting 300 cars 

visited during site visits. Since the proposed rule would require both prep and journeyman 

painters to receive training, we included both in the total number of painters. 

The model miscellaneous surface coating shop was developed from survey data collected 

from miscellaneous metal parts and miscellaneous plastic parts surface coating operations. The 

area source surface coating facilities reported an average of three coating scenarios. We 

assumed that the miscellaneous surface coating model shop would have three painters that would 

need training and three spray guns, one painter and spray gun per scenario. We estimated that 

831 facilities were represented by the miscellaneous surface coating model shop, for a total of 

2,463 painters who would need training. 

We estimated a training cost of $1,000 per painter for both automotive refinish painters 

and miscellaneous surface coating painters. This includes $360 tuition cost and $640 labor cost 

for 16 hours of training time at $40 per hour. These are based on the I-CAR 16-hour refinishing 

course sequence that included “Refinishing Equipment and VOC Regulations,” “Surface 

Preparation and Masking,” and “Color Theory, Application, Tinting, and Blending.”3

Since the training would be valid for a period of 5 years, the annualized cost was 

assumed to be one-fifth of the initial training cost, to account for worker turnover and the need to 

 

2

 Telephone Call Record: Robert Blair, Field Sales Manager, Finishmaster Automotive and Industrial Paints. March 

2, 2007. 

3

http://www.i-car.com/html_pages/training_programs/pricing.shtml. A the time these costs were first estimated by 

ERG in July 2006, costs were $90 per unit and each unit was equal to 4 hours of instruction; 16 hours of instruction 

would cost $360 for 4 units. 
0223-00-008\Auto Refinishing Capital & Annual Cost 5

train new painters. The initial national cost to train 94,553 painters would be $94.5 million and 

the annual cost would be $18.9 million. 

However, we believe that the actual annual cost of training to improve painter efficiency 

could be offset through reduced coating consumption and associated cost. Although the actual 

volume of coating use that can be reduced at each shop through training is difficult to estimate, it 

can be reduced substantially. Painter training programs that address increasing transfer 

efficiency, such as the Iowa Waste Reduction Center (IWRC) Spray Technique Analysis and 

Research (STAR®) program, have shown that the amount of coating sprayed per job can be 

reduced by 13 to 18 percent.4 This increase in efficiency is expected to translate into reduced 

coating costs, but a one-to-one savings is not expected since, in some cases, a minimum amount 

of coating may still need to be mixed to achieve the correct color match and the excess coating 

will result in some coating becoming waste. 

It is important to note that these “untrained” operators are not inexperienced painters. 

They often have many years of experience before they enter these training programs. However, 

they have not been specifically trained in how to best set up and operate high efficiency spray 

equipment and to optimize their technique to maximize transfer efficiency and minimize coating 

consumption. 

Annual coating costs were estimated for each model shop based on information provided 

by Robert Blair of Finishmaster Automotive and Industrial Paint.5 Mr. Blair provided the 

estimated coating costs for the following customer shops, which he felt are typical of many 

automotive refinish shops: 

Shop 1: 2 painters, 40 to 50 cars per month, $5,000 per month for coatings. 

Shop 2: 9 painters, 300 cars per month, $35,000 per month for coatings. 

 Mr. Blair felt that these two shops were indicative of the average coating cost for all likesized shops. Based on the information provided, we estimated the average coating cost per car is 

about $110: 

$35,000/month ÷ 300 cars/month = $116/car 

$5,000/month ÷ 45 cars/month = $111/car. 

 

4 www.iwrc.org/staruserqueries/avg_of_all_trainees.cfm (accessed on March 31, 2006) and 

http://www.star4d.org/database.cfm (accessed on July 17, 2006). 

5

 Telephone Call Record: Robert Blair, Field Sales Manager, Finishmaster Automotive and Industrial Paints. March 

2, 2007. 
0223-00-008\Auto Refinishing Capital & Annual Cost 6

The annual coating cost for the small (40 cars/month), medium (100 cars/month), and 

large (200 cars/month) model shops was calculated using the relative number of cars per month 

as follows: 

Small shops: ($110/car)(40 cars/month)(12 months) = $58,200/yr 

Medium shops: ($110/car)(100 cars/month)(12 months) = $132,000/yr 

Large shops: ($110/car)(200 cars/month)(12 months) = $264,000/yr 

We estimated the annual coating savings that would be required to offset the training cost 

of $1,000 per painter in a single year. Since the proposed rule would allow a painter to use 

training completed in the last 5 years to satisfy the training requirements and the training 

certification is valid for 5 years, we also estimated the annual coating savings that would be 

required to offset the training costs over a 5 year period.

Table 4 shows the percent reductions of coating use and cost required to offset the 

training costs for both 1 year and 5 year payback periods for each of the three model shop types. 

If a shop were able to reduce annual coating use and costs by 5 percent, then the model shops 

would see a net cost savings in the first year, even after including the cost of training. These 

savings based on a 5 percent coating reduction are also presented in Table 4. 

Table 4. Estimated Cost Savings Needed to Offset Training Costs in 1- and 5-Year Periods, 

and Estimated Net Cost Savings in 1 Year if Shops Reduce Coating Costs by 5 Percent 

Shop Size Small Medium Large

Number of Vehicles Refinished Per Month 40 100 200

Estimated Number of Painters 2 4 7

Estimated Training Cost per Shop $2,000 $4,000 $7,000

Annual Coating Cost $58,200 $132,000 $264,000

Reduction in coating use and cost required to 

recoup the training costs in 1 year. 

3.4% 3.0% 2.7%

Reduction in coating use and cost required to 

recoup the training costs in 5 years. 

0.7% 0.6% 0.5%

Coating cost savings at 5 percent reduction in 

annual coating cost 

$2,910 $6,600 $13,200

Net cost savings in 1 year after training cost at 

5 percent reduction in annual coating cost 

$910 $2,600 $6,200

The coating reduction required to offset the cost of painter training in a single year, 

included in Table 4, was calculated by dividing the estimated cost of painter training by the 

estimated annual coating cost, for each model shop. 
0223-00-008\Auto Refinishing Capital & Annual Cost 7

 Small shops: (2 painters * $1,000) ÷ $58,200 = 3.4 percent 

Medium shops: (4 painters * $1,000) ÷ $132,000 = 3.0 percent 

Large shops: (7 painters * $1,000) ÷ $81,000 = 2.7 percent 

 The coating reduction required to offset the cost of painter training over 5 years was 

calculated by simply dividing the reduction needed in a single year by 5. All size model shops 

could recover their training costs in 1 year if the coating costs were reduced by at least 3.5 

percent. We expect that most shops could reduce their costs by at least this amount, and could 

begin to see cost savings that exceed the cost of initial training in the first year after training is 

completed. 

These estimates are consistent with estimates from the Iowa Waste Reduction Centers 

STAR® program, as reported by the EPA’s Design for the Environment (DfE) program.6 The 

STAR® program, in year 2000, estimated that a shop refinishing 15 cars per week (60 cars per 

month) that switched from conventional to HVLP spray guns could save $6,900 per year in 

coating costs. The same shops switching to HVLP and receiving training to use more efficient 

spray techniques were estimated to save $13,000 per year. We could assume that the difference, 

$6,100/year, would be the savings from training alone at shops that already use HVLP spray 

guns. This value ($6,100/year) is between the estimated cost savings for the small and medium 

model shops, when we assume that coating costs were reduced by 5 percent. 

Although cost savings were not specifically estimated for miscellaneous surface coating 

shops, we expect that reduced coating consumption at these facilities would also be sufficient to 

offset the additional cost of painter training. 

Assumptions and Procedure for Estimating HVLP Spray Gun Costs

We have assumed that HVLP spray guns are the industry standard for auto refinishing 

area sources and that only a substantial number of miscellaneous surface coating facilities would 

need to purchase HVLP spray guns. We estimated that 25 percent of miscellaneous surface 

 

6

http://www.epa.gov/dfe/pubs/auto/spraygun/spraygun.pdf United States Environmental Protection Agency. 

Design for the Environment, Auto Refinishing Shop Project. June 2000. “HVLP SPRAY GUNS: Cost-effective, 

environment-friendly technology.” EPA 744-F-00-004. 
0223-00-008\Auto Refinishing Capital & Annual Cost 8

coating area sources do not use HVLP spray guns, based on the percentage of sources that did 

not report using these types of spray guns or an equivalent, such as electrostatic spray guns. We 

estimated that there are a total 831 miscellaneous surface coating area sources and an average of 

three coating scenarios per area source. The number of area sources and the estimated percent 

needing to purchase HVLP spray guns is based on survey data collected from area sources in 

response to the EPA surveys used to develop 40 CFR part 63, subparts MMMM and PPPP.7,8 

We assumed that area sources would probably need to purchase multiple spray guns and 

assumed that one new spray gun would be purchased for each coating scenario reported by a 

source. We estimated that the total number of spray guns required is: 

831 sources * 25% needing spray guns* 3 guns/source = 624 guns 

The estimated cost for an industrial quality HVLP spray gun and accessories (e.g., larger 

diameter hose, gauges, extra air caps) is $700, based on vendor information.9 The total capital 

cost to purchase 624 guns would be $0.44 million 

 We estimated annualized costs using the standard method and factors presented in the 

EPA Air Pollution Control Cost Manual (EPA/452/B-02-001). Table 5 shows the cost elements 

used to estimate annualized capitol costs. Capital recovery factors for all equipment were based 

on a 10-year economic life and 7 percent interest. 

 

7

 Memorandum. To: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural Resources and 

Commerce Group. From: Brian Palmer, Eastern Research Group, Inc. July 19, 2006. Estimating the Number of 

Miscellaneous Surface Coating Area Sources for Which EPA Has Data. 

8

 Memorandum to: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural Resources and Commerce 

Group (E143-03). From: Brian Palmer, Eastern Research Group, Inc. July 19, 2006. Analysis of Generally 

Available Control Technology (GACT) Options for the National Emission Standards for Hazardous Air Pollutants 

(NESHAP) for Miscellaneous Surface Coating Operations at Area Sources. 

9

 HVLP Spray Gun Costs – Model 248 Astro 

http://www.airmaxproducts.com/finishing_supplies.htm

Low End HVLP Spray Gun: High Point http://www.spraygunworld.com/products/HP/Highpoint2.html

Sata Jet 2000 HVLP Spray Gun: Model # SAT61168 http://search.cartserver.com/search/search.cgi?cartid=a6834&category=datapaint&maxhits=20&keywords=SAT61168

Compressed Air Hoses for HVLP – Costs 

http://www.1st-in-hvlp.com/compressed_air_hose.htm

Sata Satajet 3000 HVLP Spray Gun: Model SAT133025 

http://www.spraygunworld.com/products/SATA/SATA%20HVLP%20133025.htm

DeVilbiss HVLP Spray Gun: Model DEVGTI620S - GTI2000 HVLP 

http://www.spraygunworld.com/products/DeVilbiss/DeVilbiss%20DEVGTI620S.htm
0223-00-008\Auto Refinishing Capital & Annual Cost 9

Table 5. Derivation of Net Annualized Cost 

Capital Cost Elements 

Installed Cost A

Annualized Capitol Cost Elements

Equipment Economic Life n = 10 years

Interest Rate i = 7 percent (0.07)

Capital Recovery Factor B = i*(1 + i)n = 0.142

(1 + i)n -1 

Annualized Capital Recovery Cost C = A*B

Using the capital recovery factor as derived above (10 year life, 7 percent interest), the 

annualized capital cost for an HVLP gun is $700 × 0.142 = $100 per gun. We assumed that 

sources would have no additional insurance, tax, or other administrative overhead costs for the 

spray guns since these were replacements for existing spray guns. 

Cost savings from improved transfer efficiency and reduced coating usage were not 

estimated for the miscellaneous surface coating sources since we do not have coating cost data 

specific to these sources. However, based on the information collected by the IWRC and 

summarized above with respect to painter training, we expect that the cost savings compared to 

conventional spray guns would be sufficient to at least offset the annualized capital costs of 

purchasing HVLP or equivalent spray guns. 

Assumptions and Procedure for Estimating Gun Washer Costs

We estimated that about 5,214 sources would not have automated enclosed spray gun 

washers. While sources often use multiple spray guns, a single gun washer is typically adequate 

to service all spray guns at a facility, particularly for area sources. The EPA visited over 20 

automotive refinishing facilities and all but the smallest shop used an automatic, enclosed spray 

gun washer. The one shop that did not have a gun washer cleaned guns by hand in a small 

covered parts cleaning tray that held solvent. This latter shop would be able to comply with the 

proposed standards as long as no cleaning solvent was atomized through the spray gun. 

For automotive refinishing shops, we assumed that 14 percent of shops, or about 5,006 

shops, that did not report having a spray booth would also not have a gun washer. For 

miscellaneous surface coating shops, we assumed that the same 25 percent of shops that did not 

have HVLP spray guns, or about 208 shops, would also not have a gun washer. 
0223-00-008\Auto Refinishing Capital & Annual Cost 10

The estimated capital cost for a spray gun washer was $1,800, based on calls with gun 

washer vendors and information available from internet-based searches.10 We assumed that 

shops without a spray gun washer would install a durable, low-cost spray gun washer instead of a 

more expensive model. However, less expensive gun washers are available, including a 

frequently observed model that is available for less than $1,000. 

The total capital cost to purchase 5,213 gun washers would be $9.4 million. 

Using the same capital recovery factor as derived above, the annualized capital cost for a 

gun washer is $1,800 × 0.142 = $256. 

The total annualized cost for all 5,214 sources estimated to need an enclosed spray gun 

washer was $1.33 million per year. However, we estimate that the initial cost of a gun washer 

could be offset within 1 year at nearly all shops through reduced labor to wash spray guns and 

through more efficient use of cleaning solvent, compared to manual spray gun washing. The 

more efficient use of solvent would reduce solvent costs and the costs to properly dispose of 

spent solvent. 

Although spray gun washers can potentially reduce solvent and labor costs, and reduce 

emissions, the actual volume of solvent that can be reduced is difficult to estimate due to 

variances in enclosed gun cleaner makes, models, and solvent recovery efficiency. The 

Department of Defense’s Joint Services Pollution Prevention Handbook states that “automatic 

paint gun washers can reduce the amount of solvent used and paint solvent waste generated by 

70 to 80 percent when compared to manual paint gun cleaning.” 11 As a conservative estimate, 

we used a 70 percent reduction of solvents to calculate associated cost savings. Even greater 

reductions in solvent use and waste generation are possible with systems that also use a still to 

recover clean solvent from waste paint and spent solvent, but these are more expensive than just 

an automated gun washer. 

To estimate potential cost savings for automated gun washers compared to manual gun 

washing we used the following assumptions: 

Labor Rate ($/hour): $40.00 

Solvent cost: $6.75/gallon 

 

10 Paint Gun Equipment Washer from SAFETY-KLEEN: Model 1111 

http://www.safety-kleen.com/SKInternet/SKShoppingDetailParts.aspx?ItemCode=6512

Manual Paint Gun Washer from SAFETY-KLEEN: Model 1077 

http://www.safety-kleen.com/SKInternet/SKShoppingDetailParts.aspx?ItemCode=6630

11 http://p2library.nfesc.navy.mil/P2_Opportunity_Handbook/4_9.html 
0223-00-008\Auto Refinishing Capital & Annual Cost 11

Paint sludge waste disposal cost: $5.10/gallon 

Monthly equipment service fee: $17.00 

The labor rate is based on an industry survey by Body Shop Business magazine.12 The 

costs for solvent, paint sludge waste disposal, and the monthly service fee are based on 

information from a site visited by EPA. 

We assumed each vehicle would require at least 3 gun washings for a primer, color coat, 

and clear coat. We also assumed that manual gun washing would require 10 minutes and 

automatic gun washing would require 1 minute of labor to load the gun in the washer, based on 

the assumptions in the Joint Services Pollution Prevention Handbook.13 We assumed that 

manual gun cleaning would require the use of 10 ounces of solvent per gun and automated gun 

washing 3 ounces per gun (a 70-percent reduction). We assumed no costs for paint sludge waste 

or solvent disposal for manual gun cleaning, even though it would be difficult to avoid these 

costs and remain in full environmental compliance for waste disposal. For waste paint sludge 

disposal costs with a gun washer, we assumed that the volume of waste sludge was equal to 

solvent purchases to maintain a constant solvent level in the machine. 

The results of the gun washer cost analysis are presented in Table 6. Since we observed 

enclosed gun washers at all but one automotive refinishing shop visited by EPA, only results 

estimated for shops refinishing only 10, 20, and 40 cars per month are presented here since these 

are the shops most likely to have to purchase a gun washer. 

Even a shop refinishing 10 cars per month could see a net annual cost savings that would 

offset the initial cost of an enclosed spray gun washer. A major component of these cost savings 

is the cost of labor saved. However, even if the assumptions are changed to reduce the 

difference in labor required to clean guns manually and with a gun washer (e.g., 5 minutes and 2 

minutes, respectively), the cost savings could still offset the initial cost of a gun washer in 5 

years or less. 

 

12 http://www.babcox.com/editorial/bb/704OperationsProf.pdf 

13 http://p2library.nfesc.navy.mil/P2_Opportunity_Handbook/4_9.html 
0223-00-008\Auto Refinishing Capital & Annual Cost 12

Table 6. Gun Washer Cost Savings Analysis 

Model Shop Parameters 

Cars per month per model shop 10 20 40 

Gun washings per month 30 60 120 

Manual Gun Washing Calculated values 

Calculated manual solvent use per month 

(gallons) 2.3 4.7 9.4 

Manual solvent cost per month $ 15.82 $ 31.64 $ 63.28 

Manual gun washing labor per month 

(hours) 5.00 10.00 20.00 

Manual gun washing labor cost per month $ 200.00 $ 400.00 $ 800.00 

Total Monthly Cost $ 215.82 $ 431.64 $ 863.28 

Total Annual Cost for Manual Gun Washing $2,589.84 $5,179.69 $10,359.38 

Automated Gun Washing Calculated values 

Gun washer virgin solvent use per month 

(gallons) 0.7 1.4 2.8 

Gun washer solvent cost per month $ 4.75 $ 9.49 $ 18.98 

Gun washer waste sludge disposal cost per 

month $ 3.59 $ 7.17 $ 14.34 

Gun washer labor per month (hours) 0.50 1.00 2.00 

Gun washer labor cost per month $ 20.00 $ 40.00 $ 80.00 

Service fee per month $ 17.00 $ 17.00 $ 17.00 

Monthly cost for solvent, waste, labor and 

fee $ 45.33 $ 73.66 $ 130.33 

Annual cost for solvent, waste, labor, and 

fee $ 543.98 $ 883.97 $ 1,563.94 

Annualized capital cost of gun washer $ 256.28 $ 256.28 $ 256.28 

Total Annual Cost for Gun Washer $ 800.26 $1,140.25 $ 1,820.22 

Estimated Annual Cost Savings for 

Automated Gun Washer Compared to 

Manual Gun Washing $1,789 $4,039 $ 8,539 

Assumptions and Procedure for Estimating Spray Booth Costs 

The proposed rule would require all spray applied surface coating to be done in a 

ventilated enclosure, such as a spray booth, with fiberglass or polyester fiber filters on the 

exhaust, or filters that are demonstrated to achieve at least 98-percent overspray capture 

efficiency. The capital cost of installing a spray booth and annual operating costs were not 

included in the capital and annualized cost estimates because spray booths or similar enclosures 

are already required by existing OSHA standards such as 29 CFR 1910.94(c) or 1910.107(b). 

The proposed rule would only specify exhaust filter requirements, which are not addressed by 

the existing OSHA standards. We do not expect that the proposed standards would have any 
0223-00-008\Auto Refinishing Capital & Annual Cost 13

cost impacts since compliant exhaust filters are readily available and the cost difference among 

exhaust filters is negligible. 

We have included a discussion of spray booth capital and annualized costs for 

informational purposes for those affected sources that may need to install a spray booth to 

comply with this proposed rule as well as other existing rules. 

Based on this information we have gathered, we estimate that about 5214 area sources 

affected by this rule may not have a spray booth. This estimate includes 5005 automotive 

refinishing shops and 208 miscellaneous surface coating area sources. A 2003 reader survey 

reported that 51 percent of automotive refinishing shops had a downdraft spray booth and 35 

percent had a cross draft spray booth.14 We assumed this meant that 14 percent of shops had no 

spray booth. Based on a population of 35,755 automotive refinishing shops, according to the 

2003 County Business Patterns from the U.S. Census, we estimated that 5,006 shops may not 

have spray booths. 

For miscellaneous surface coating shops, we used data collected in support of 40 CFR 63 

subparts PPPP and MMMM that showed that 25 percent of miscellaneous surface coating area 

sources did not report having spray booths with dry filters. Based on this information, we 

estimated that 208 miscellaneous surface coating area sources affected by this rule may not have 

spray booths. 

 The estimated capital cost for a spray booth was $10,000, including installation. This 

approximate cost was based on the cost of an inexpensive cross draft automotive refinishing 

booth.15 We assumed that sources without a booth would purchase the lowest cost booth needed 

to comply, rather than more expensive booths, such as downdraft booths or booths with separate 

heating systems. We also assumed that this cost would be a reasonable surrogate for the cost of 

a booth used in miscellaneous surface coating operations. Using the capital recovery factor 

derived above (0.142), the annualized capital recovery cost for the booth is $1,420. 

The total annualized costs are equal to the annualized capital costs, plus the annual 

operating costs for the spray booth. The estimated annual operating costs for a spray booth are 

listed Table 7: 

 

14 http://www.bodyshopbusiness.com/bb/Purchases.pdf 

15 See, for example, http://www.sprayshield.com/cgi-bin/hazel-cgi/hazel.cgi?action=serve&item=ECF-1000.html. 

Web page for an economy cross flow spray booth ($4899), plus cost for exhaust package ($700) and fire suppression 

system ($2,999). 
0223-00-008\Auto Refinishing Capital & Annual Cost 14

Table 7. Estimated Spray Booth Annual Operating Costs. 

Annual Operating Cost Item Cost per year 

Air Intake Filters (Cross Flow Booth) $ 152

Exhaust Filters (paint extractors) (Cross Flow Booth) $ 58 

Exhaust Filters disposal $ 440

Taxes, insurance, admin. costs (4% of installed capital cost):$ 400

Natural gas to heat make-up air $ 2,011

Electricity for fan in booth $ 171

The costs for intake and exhaust filters and used filter disposal are based on the estimated 

costs provided by an automotive collision repair facility visited by EPA. These costs have been 

estimated for a small automotive refinishing facility that refinishes 40 cars per month, since these 

small facilities are most likely to not already have a booth. Taxes, insurance, and administrative 

costs were assumed to be 4 percent of the installed capital cost. This is a standard assumption 

for EPA cost estimates. 

Natural gas is needed to heat the air that is used by the booth during cold weather months 

to maintain a constant shop and booth temperature. We estimated the annual cost of natural gas 

using the following assumptions: 

• The booth would operate 1,000 hours per year at a flow rate of 10,000 cubic feet per 

minute. 

• For 500 hours per year of operation, the air would need to be heated from 50 degrees 

F (a national average wintertime temperature) to 70 degrees F. 

• The heater would be 80 percent efficient. 

• The price of natural gas would be $13.50 per thousand cubic feet (mcf), based on the 

average cost for natural gas from the Energy Information Administration for the 

Winter of 2005 to 2006 (October to March, inclusive). 

• The heating value of natural gas would be 950 Btu per cubic foot. 

The estimated annual cost of natural gas would be $2011: 

$2011

(density of air 13.1lb/cf)(0.8 0 heater efficiency )(950 Btu/cf)(1,000 cf/mcf)

(10,000 cfm)(heat capacity of air 0.24 Btu/lb oF)(70 50 - oF)($13.50/mcf)(60 min/hr)(50 0 hrs)

=

Electricity would be needed to operate the fans of a spray booth to move the air in and 

out of the spray booth. Electricity costs were estimated using an algorithm adapted from the 

OAQPS Control Cost Manual procedure to estimate operating costs for ventilation ductwork. 
0223-00-008\Auto Refinishing Capital & Annual Cost 15

The algorithm estimated annual electricity cost based on flow rate, pressure drop, and electricity 

cost per kilowatt-hour (kwh). We estimated the annual cost of electricity using the following 

equation and assumptions: 

Annual electricity cost ($/yr) = 0.0001175*Hours*Flow*∆P*Price/Efficiency 

Where: 

0.0001175 = an empirical computational constant with units of 

(hrs · acf · in. water/min · kwh) 

Hours = annual hours of operation, assumed to be 1,000 hours per year. 

Flow = booth air flow rate, assumed to be 10,000 cubic feet per minute, based on 

vendor information. 

∆P = The total pressure drop across the spray booth system (inlet filters, outlet 

filters, and ductwork) would be 1.0 inches of water. This is over twice the 

maximum pressure drop for a loaded spray booth filter to also account for 

the pressure drop of the inlet filters. 

Price = The price for electricity, $0.0872 per kwh, based on the national average 

for 2005 from the U.S. Energy Information Service. 

Efficiency = The fan and motor combined efficiency, using the standard assumption 

from the OAQPS Control Cost Manual of 60 percent. 

The annual operating cost for a spray booth is estimated to be $3,231. After adding the 

annualized capital cost of $1,424, the total annualized cost for a spray booth would be $4,655 per 

year.