**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part**  **60 ,**  **Subpart MM** **) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal), EPA I CR Numb er 1064.1 7 , OMB Control Number 2060

- 0034 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Automobile and Light Duty Truck Surface Coating Operations were proposed on October 5, 1979 , promulgated on December 24, 1980 (45 FR 85415), and most recentl y amended on October 17, 2000 (65 FR 61760) . These regulations appl y to the following automobile and light duty truck assembly

plant operations: each prime coat operation, guide coat operation, and top coat operation commencing construction, modification or reconstruction after October 5, 1979. This information is being collected to assure compliance with 40 CFR part 60, subpart MM

. In general, all NSPS 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 s ys tem is inoperative. These notifications, reports, and records are essential in determining com pliance, and are required of all affected facilities subject to NSPS. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional offic e. Over the next three ye ars, an average of 58 respondents per ye ar will be subject to the standard , and 2 additional respondents per ye ar will become subject to the standard. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance ”

. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)

. The Federal Government “burden ” is attributed entirely to work performed b y either F ederal emplo yees or government contractor s , and may be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Automobile and L ight2

Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to es tablish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best

- demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise su ch standards e very four years. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any

requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such moni toring 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 Admini strator may reasonabl y require. In the Administrator's judgment, volatile organic compound (VOC) emissions from automobile and light duty truck coating operations cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart MM

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean3

Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to det ermine an affected facility ’ s initial capability to comp ly

with the emission standard . Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which c ompliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. When thermal or catal ytic incineration is performed, the owner or operator shall keep records of each three

- hour period during which the i ncinerator temperature averaged more than 28 degrees centigrade below the temperature of the most recent performance test, and when the average temperature difference across the catal ys t bed is less than 80% of the average temperature difference recorded d uring the most recent performance test. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the s ource to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping an d reporting are required under 40 CFR part 60, subpart MM

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Publ ic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 77 FR 63813 ) on October 17, 2012

. No comments were received from the public on the burden publ ished in the Federal Register

.4

**3(c) Consultations** The Agency

has consulted i ndustry

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 Online Tracking Information Sy stem (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested partie s 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 I CR, we co ntacted : 1) the Mississippi Automotive Manufacturers Association , at (601) 982

- 9570 ; and 2) the Auto Alliance , at (202) 326

- 5500. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitt ed in response to the f irst Federal Register n otice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was co llected less frequently , the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 Pro visions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for f ive 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 ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.5

**3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive question s. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are owners and operators of plants that conduct automobile and light duty truck surface coating operations . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards and the corresponding North American Industry Classification S ystem (NAICS ) codes are listed in the following table.
**Standard (**  **40 CFR P**  **art 60,**  **S ubpart M**  **M )**  **SIC Codes NAICS Codes**  Automobile Manufacturing 3711 336111 Li ght Truck and Utility

Vehicle Manufacturing 336112 Motor Vehicle Body Manufacturing 336211 **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required by the NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM)

. A source must make the following reports:6

**Notification s**  Notification of construction/reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Initial performance test 60.8(d) Phy sical or operational change. 60.7(a)(4) Notify the Administrator 30 day s in advance of any test by Reference Method 25. 60.395(d)

**Reports** Initial performance test results 60.8(a) Report volume weighted average mass of VOC per volume of applied coatings solid in initial compliance report. 60.395(a)
Report the gas temperature upstream and downstream of catal ys t bed, total mass of VOC per volume of applied coating solids, capture efficiency , destruction efficiency , and method used to determine VOC captured and sent to the control device in initial compliance report or subsequent performance test report. 60.395(a)

Monthly performance test. 60.393(b), 60.393(c) Install, calibrate, maintain, and operate temperature monitoring device Quarterl y reports of excess VOC emissions, semiannual reports if no exceed ences. 60.395(b)

Reports of low incinerator temperature. 60.395(c) Record the incinerator combustion temperature. 60.395(d) A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunctions, and periods where the continuous monitoring sy stem is inoperative. 60.7(b)
Records are required to be retained for two ye ars. Records must be 60.87 **Recordkeeping** retained at the facility. Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordke eping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respondents use electronic repor

ting. **(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for temperature. Perform initial performance test, Reference Method 24 or Method 25 test, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining info rmation. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel8

at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard. 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. In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agenci es, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for two ye ars.

**5(c) Small Entity Flexibil ity** 9

There are no small entities (i.e., small businesses) affected b y this regulation. This estimate is based on the discussion on affected small entities during the development of the rule (see BID EPA

- 450/3

- 80

- 003a). **5(d) Collection Schedule**  The specific frequency

for each information collection activity within this request is shown in below Table 1 : Annual Respondent Burden and Cost

– NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this inform ation collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these record

keeping and reporting requirement s is estimated to be 175,195 hours ( T otal L abor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously

approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and ind

ustry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

.10
**(ii) Estimating Capital/Startup and Operation and Mainten ance Costs**  The ty pe of industry

costs associated with the information collection activ ities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance cost s are the ongoin g costs to maintain the monitors and other costs su ch as photocop yi ng and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Costs**  (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup 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)

Tem perature mo nitoring device $850 2 $1,700 $1,750 58 $101,500
The total capital/startup costs for this I CR are $ 1,700 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 101,500

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 103,200

. These are the costs of recordkeeping. **6(c) Estimating Age ncy Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $3 4,438

. This cost is based on the average hourl y labor rat e as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% )11 Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Co st

– NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal) **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 58 existing respondents will be subject to the standard. It is estimated that an additional 2 respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 60 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.

**Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

Number of Existing Respondents That Are Also New Respondents (E) Number of Respondents (E=A+B+C

- D)

1 2 56 0 0 58 2 2 58 0 0 60 3 2 60 0 0 62 Average 60 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondent s . As shown above, the average Number of Respondents over the three ye ar period of this ICR is 60

. The total number of annual responses per ye ar is calculated using the following table:12
**Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Notification of construction/ reconstruction 2 1 0 2

Notification of actual startup 2 1 0 2 Notification of initial performance test 2 1 0 2
VOC emission reports 58 4 0 232 Temperature reports 58 2 0 116 Total 354 The number of Total Annual Respons es is 354. The total annual labor costs are $16,963,868

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 175,195 hours at a cost of $16,963,868

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 495 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $103,200

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.13 **(ii) The Agency Tally** The average annual Agency burden and cost over n ext three years is estimated to be 764 labor hours at a cost of $ 34,438 . See Table 2 below : Average Annual EPA Burden and Cost

– NSPS for Automobile and L ight Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal) **6(f) Reasons for Change in Burden** There is an increase in burden for both the respondents and the Agency from the most recentl y approved ICR . The adjustment increase is not due to any program changes ; rather, it reflects an increased number of respondents subject to the standard since the last I CR

. This I CR uses updated data from OTI S in estimating the respondent univers e , which is consistent with the projected industry

growth in the previous IC R. This I CR also uses updated labor rates in calculating all burden costs. The overall result is an increase in labor hours , labor costs, as well as total O&M costs This I CR co rrects a mathematical error in calculating th e number of responses. Furthermore, we corrected the number of sources that are required to maintain continuous monitoring sy stem (CMS) in Table 1, line item 5. This I CR assumes that all sources incur costs as sociated with CMS and data management sy stems, which is consistent with the methodology used in calculating O&M costs. These changes also contribute to an increase in the number of total responses, as well as an increase in labor hours and costs. **6(g) Burden Statement**  The annual p ublic reporting and recordkeeping burden for this collection of information is estimated to average 495 hours per response. “ Burden ” means the total time, effort, or financial resources expended by persons to generate, maint ain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying infor mation, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0654 . An electroni c version of the public docket is14

available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regu latory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 12

- 0654 and OMB Control Number 2060

- 0034 in any correspondence. **Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.15

**Table 1: Annual Respondent Burden and Cost** 

**– NSPS for Automobile and Light Duty Truck Surface Coating Operations (40**  **CFR Part 60, Subpart MM) (Renewal)** 

Burden Items (A) Person h ours per o ccurr ence (B)

Number of o ccurr ences per r espondent per Year (C)

Person h ours per r espondent per Year (C=A x B) (D)

Number of r espondents per Year (E)

Technical person hours per Year (E=C x D) e (F)

Management person hours per Year (F= E x 0.05) e (G)

Clerical person hours per Year (G= E x 0.1) e Total Labor

Costs per Year

1. **A pplications**  a 17.4 1 17.4 2 34.8 1.74 3.48 $3,875.08 2. **Survey and s**  **t udies**  116.5 1 116.5 2 233 11.65 23.3 $25,945.25 3. **R eporting**  **r equirem**  **ents** A. Read i nstructions b 8.7 1 8.7 58 504.6 25.23 50.46 $56,188.72 B. Required a ctivities Initial performance test c 2,434.8 1 2,434.8 2 4,869.6 243.48 486.96 $542,244.57 Demonstration of CMS N/A Repeat performance test c, d 573.9 1 573.9 0.4 229.56 11.48 22.96 $25,562.19 C. Create i nformation

------------------------ Included in 3b

---------------------------- D. Gather e xisting i nformation

------------------------ Included in 3e

---------------------------- E. Write Report Notification of construction/reconstruction 1.7 1 1.7 2 3.4 0.17 0.34 $378.60 Notification of actual startup 1.7 1 1.7 2 3.4 0.17 0.34 $378.60 Notification of initial performance test 35.7 1 35.7 2 71.4 3.57 7.14 $7,950.60 Report of performance test

------------------------ Included in 3b

---------------------------- Excess e mission r eports VOC e mission r eports 8.7 4 34.8 58 2,018.4 100.92 201.84 $ 224,754.90 Tem perature r eports 26.1 2 52.2 58 3,027.6 151.38 302.76 $ 337,132.34 **Subtotal for Reporting Requirements 12,645**  **$1,224,410.86** 4. **Recordkeeping Requirements** A. Read i nstructions 8.7 1 8.7 58 504.6 25.23 50.46 $ 56,188.72 B. Plan a ctivities 17.4 1 17.4 58 1,009.2 50.46 100.92 $ 112,377.45 C. Implement a ctivities16

Monthly performance test 1,669.6 1 1,669.6 58 96,836.8 4,841.84 9,683.68 $10,783,068.19 D. Develop r ecord s ystem 4,347.8 1 4,347.8 2 8,695.6 434.78 869.56 $ 968,281.15 E. Time to e nter information Records of t em

perature 417.4 1 417.4 58 24,209.2 1,210.46 2,420.92 $ 2,695,767.05 F. Train p ersonnel 34.8 1 34.8 58 2,018.4 100.92 201.84 $ 224,754.90 G. Audits 17.4 1 17.4 58 1,009.2 50.46 100.92 $ 112,377.45 5. Equipment and analytical e valuation e xpense A. Continuous m onitoring & e valuation 34.8 1 34.8 58 2,018.4 100.92 201.84 $ 224,754.90 B. Routine t esting and maintenance 52.2 1 52.2 58 3,027.6 151.38 302.76 $ 337,132.34 C. Systems of manage data 34.8 1 34.8 58 2,018.4 100.92 201.84 $224,754.90 **Subtotal for Recordkeeping Requirements 162,550**  **$ 15,739,457**  **TOTAL LABOR**  **BURDEN AND COST**  **( rounded)**  **175,195 $16,963,868** 
**Assu mptions** 

a. Number of new facilities (per year) = 2 b. Number of existing affected facilities (per year) = 58
c. It is assumed the EPA Reference Method 24 test performed on the coatings used by the respondents is generally done by the coatings manufacturers, who provide the test results to the respondents. It is further assumed that the coatings manufacturers routin ely perform an EPA Method 24 analysis on their coatings as a quality control measure, so there will be no additional cost incurred by the co atings manufacturers. d. Rate of failed performance tests = 20%
e. Technical labor rate (Bureau of Labor Statistics) = $100.23 Managerial Labor rate (Bureau of Labor Statistics) = $121.44 Clerical Labor rate (Bureau of Labor Statistics) = $50.5117

**Table 2: Average Annual EPA Burden and Cost** 

**– NSPS for Automobile and Light Duty**  **Truck Surface Coating Operations (40 CFR Part 60, Subpart MM)**  **(Renewal)**

Burden Items (A) Person Hours per occurrence (B)

Number of o ccurr ences per Plant per Year (C)

EPA Hours per respondents per year (C=AxB) (D)

Plants per Year (E) Technical h ours per Year (E=C xD ) c (F)

Management Hours per Year (E x 0.05) c (G)

Clerical Hours per Year (E x 0.1 ) c (H)

Total Costs per Year Initial performance test New Plant a 20.9 1.2 25.08 2 50.16 2.51 5.02 $2,599.52 Report review New Plant Notification of construction 1.7 1 1.7 2 3.4 0.17 0.34 $176.20 Notification of initial startup 0.4 1 0.4 2 0.8 0.04 0.08 $41.46 Notification of actual startup 0.4 1 0.4 2 0.8 0.04 0.08 $41.46 Notification of initial performance test b 0.4 1.2 0.48 2 0.96 0.05 0.10 $49.75 Review test results b 7 1.2 8.4 2 16.8 0.84 1.68 $870.65 Existing Plant VOC emission reports 1.7 4 6.8 58 394.4 19.72 39.44 $20,439.58 Tem perature reports 1.7 2 3.4 58 197.2 9.86 19.72 $10,219.79 **TOTAL ANNUAL BURDEN AND COST (rounded)**  **764 $3**  **4,438**
**Assu mptions** 
a. Number of new plants (per year) 2 b. Rate of failed performance tests 20%

c. EPA technical labor rate (GS

- 13 Step 1 x 1.6 for overhead) $46.21 EPA managerial labor rate (GS

- 12 Step 5 x 1.6 for overhead) $62.27 EPA clerical labor rate (GS

- 6 Step 3 x 1.6 for overhead) $25.01