1064ss19

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 Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal), EPA ICR Number 1064.19, 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, and amended on October 17, 2000. These regulations apply 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 system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents and retain the file for at least two years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency’s (EPA) regional offices.

The “Affected Public” are owners or operators of automobile and light duty truck surface coating operations. The “burden” to the Affected Public may be found below at the end of this document 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’s “burden” is attributed entirely to work performed by either Federal employees or government contractors and may be found below at the end of this document in 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). There are approximately 70 automobile and light duty truck surface coating facilities, all which are owned and operated by the automobile and light duty truck surface coating industry. None of the 70 facilities in the United States are owned by either state, local, tribal or 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).

Over the next three years, approximately 70 respondents per year will be subject to these standards, and 2 additional respondents per year will become subject to these same standards, for an overall average of 72 respondents per year.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance”.

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 establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system 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 Administrator determines has been adequately 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 such standards every eight 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 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, VOC emissions from automobile and light duty truck coating operations either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/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 these standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standards. Continuous emission monitors are used to ensure compliance with these same standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

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 source to check if the pollution control devices are properly 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.

When thermal or catalytic incineration is performed, the owner or operator shall keep records of each three-hour period during which the incinerator temperature averaged more than 28 degrees centigrade below the temperature of the most recent performance test, and when the average temperature difference across the catalyst bed is less than 80% of the average temperature difference recorded during the most-recent performance test.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and 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 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 similar 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.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (83 FR 24785) on May 30, 2019. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

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 these standards, 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 70 respondents will be subject to these same standards over the three-year period covered by this ICR, with an anticipated additional 2 new respondents per year.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Mississippi Automotive Manufacturers Association, at (601) 707-5221; and 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 for those submitted in response to the first Federal Register notice. 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 these 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.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

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 these standards do not include sensitive questions.

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 facilities that conduct automobile and light duty truck surface coating operations. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standard and the corresponding North American Industry Classification System (NAICS) codes are listed in the following table:

Standard (40 CFR Part 60, Subpart MM)	SIC Codes	NAICS Codes
Automobile Manufacturing	3711	336111
Light 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 are recorded or reported is required by the NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM).

A source must make the following reports:

Notifications
Notification of construction/reconstruction	§60.7(a)(1)
Notification of actual startup	§60.7(a)(3)
Initial performance test	§60.8(d)
Physical or operational change	§60.7(a)(4)
Notify the Administrator 30 days 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 catalyst 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)
Quarterly reports of excess VOC emissions, semiannual reports if no exceedances	§60.395(b)
Reports of low incinerator temperature	§60.395(c)

A source must keep the following records:

Recordkeeping
Startups, shutdowns, malfunctions, and periods where the continuous monitoring system is inoperative	§60.7(b)
Records are required to be retained for two years. Records must be retained at the facility	§60.8
Record the incinerator combustion temperature	§60.395(c)

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 recordkeeping at a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for temperature.

Perform initial performance test, Reference Method 24 or 25 tests, 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 systems for 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.

Transmit, or otherwise disclose the information.

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, analysis, storage, and distribution of the required information:

Agency Activities

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.

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 properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standards and note that 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. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. 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.

The records required by this regulation must be retained by the owner/operator for two years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by 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 below at the end of this document 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).

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 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 Agency may neither conduct nor 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 both these record-keeping and reporting requirements is estimated to be 214,000 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of this 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 ICR uses the following labor rates:

Managerial $147.40 ($70.19+ 110%)

Technical $117.92 ($56.15 + 110%)

Clerical $57.02 ($27.15 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standards 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 costs are the ongoing costs to maintain the monitors and other costs such as photocopying 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)
Temperature monitoring device	$850	2	$1,700	$1,750	72	$126,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $1,700. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $126,000. 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 ICR is estimated to be $128,000. These are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 $44,100.

This cost is based on the average hourly labor rate as follows:

Managerial $65.71 (GS-13, Step 5, $41.07 + 60%)

Technical $48.75 (GS-12, Step 1, $30.47 + 60%)

Clerical $26.38 (GS-6, Step 3, $16.49 + 60%)

These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear below at the end of this document in 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).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 70 existing respondents will be subject to these standards. It is estimated that an additional 2 respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 72 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

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	2	68	0	0	70
2	2	70	0	0	72
3	2	72	0	0	74
Average	2	70	0	0	72

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 72.

The total number of annual responses per year is calculated using the following table:

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	72	4	0	288
Temperature reports	72	2	0	144
			Total	438

The number of Total Annual Responses is 438 responses.

The total annual labor costs are $24,300,000.00 (rounded). Details regarding these estimates may be found below at the end of this document 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).

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 below in Tables 1 and 2 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 214,000 hours. Details regarding these estimates 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).

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.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 489 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $128,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 928 labor hours at a cost of $44,100; see below in 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).

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.

6(f) Reasons for Change in Burden

There is an overall adjustment increase in the change in ‘burden’ in this ICR compared to the previous renewal. The increase is not due to any program changes. The burden has been adjusted to reflect an increase in the estimated number of sources, based on a continued growth rate of 2 new facilities per year. The increase in the number of respondents also results in an increase in the number of responses and in the operation and maintenance costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 489 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, 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 neither conduct nor 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 this ICR under Docket ID Number EPA-HQ-OECA-2012-0654. An electronic version of the public docket is 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 system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC 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 holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory 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-2012-0654 and OMB Control Number 2060-0034 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

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 Item	(A)Person hours per occurrence	(B)Number of occurrences per respondent per Year		(C) Person hours per respondent per year (AxB)	(D) Number of respondents per Year a		(E) Technical person hours per year (CxD)		(F) Management person hours per year (Ex0.05)		(G) Clerical person hours per year (E x 0.1)		(H) Total Labor Costs per Year b
1. Applications a	17.4	1		17.4	2		34.8		1.74		3.48		$4,558.52
2. Survey and studies	116.5	1		116.5	2		233		11.65		23.3		$30,521.14
3. Reporting requirements
A. Familiarization with the regulatory requirements	8.7	1		8.7	72		626.4		31.32		62.64		$82,053.39
B. Required activities
Initial performance test c	2,434.8	1		2,434.8	2		4,869.60		243.48		486.96		$637,878.64
Demonstration of CMS	N/A
Repeat performance test c, d	573.9	1		573.9	0.4		229.56		11.478		22.956		$30,070.52
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/reconstruction	1.7	1		1.7	2		3.4		0.17		0.34		$445.37
Notification of actual startup	1.7	1		1.7	2		3.4		0.17		0.34		$445.37
Notification of initial performance test	35.7	1		35.7	2		71.4		3.57		7.14		$9,352.83
Report of performance test	See 3B
Excess emission reports
VOC emission reports	8.7	4		34.8	72		2,505.6		125.28		250.56		$328,213.56
Temperature reports	26.1	2		52.2	72		3,758.4		187.92		375.84		$492,320.33
Subtotal for Reporting Requirements							14,186						$1,615,859.68
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	8.7	1		8.7	72		626.4		31.32		62.64		$82,053.39
B.  Plan activities	17.4	1		17.4	72		1,252.8		62.64		125.28		$164,106.78
C. Implement activities
Monthly performance test	1,669.6	1		1669.6	72		120,211.2		6010.56		12021.12		$15,746,705.51
D.  Develop record system	4,347.8	1		4347.8	2		8,695.6		434.78		869.56		$1,139,054.04
E.  Time to enter information
Records of temperature	417.4	1		417.4	72		30,052.8		1,502.64		3005.28		$3,936,676.38
F.   Train personnel	34.8	1		34.8	72		2,505.6		125.28		250.56		$328,213.56
G.  Audits	17.4	1		17.4	72		1,252.8		62.64		125.28		$164,106.78
5. Equipment and analytical evaluation expense
A. Continuous monitoring & evaluation	34.8	1		34.8	72		2,505.6		125.28		250.56		$328,213.56
B. Routine testing and maintenance	52.2	1		52.2	72		3,758.4		187.92		375.84		$492,320.33
C. Systems of manage data	34.8	1		34.8	72		2,505.6		125.28		250.56		$328,213.56
Subtotal for Recordkeeping Requirements							199,372						$22,709,664
TOTAL LABOR BURDEN AND COST (rounded) e							214,000						$24,300,000
TOTAL CAPITAL AND O&M COSTS (rounded): e													$128,000
GRAND TOTAL (rounded): e													$24,400,000
Assumptions
a We have assumed that there are approximately 70 existing respondents, with 2 new respondents per year over the next 3 years of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2: Civilian Workers, by Occupational and Industry Group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
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 routinely perform an EPA Method 24 analysis on their coatings as a quality control measure, so there will be no additional cost incurred by the coatings manufacturers.
d Rate of failed performance tests is 20 percent.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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 occurrences per Plant per Year	(C) EPA hours per respondent per year (AxB)	(D) Plants per Year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical Hours per Year (Ex0.1)	(H) Total costs per year b
Initial performance test
New Plant	20.9	1.2	25.08	2	50.16	2.51	5.02	$2,742.42
Report review
New Plant
Notification of construction	1.7	1	1.7	2	3.4	0.17	0.34	$185.89
Notification of initial startup	0.4	1	0.4	2	0.8	0.04	0.08	$43.74
Notification of actual startup	0.4	1	0.4	2	0.8	0.04	0.08	$43.74
Notification of initial performance test c	0.4	1.2	0.48	2	0.96	0.05	0.10	$52.49
Review test results c	7	1.2	8.4	2	16.8	0.84	1.68	$918.51
Existing Plant
VOC emission reports	1.7	4	6.8	72	489.6	24.48	48.96	$26,768.15
Temperature reports	1.7	2	3.4	72	244.8	12.24	24.48	$13,384.07
TOTAL COST (rounded) d					928			$44,100
Assumptions
a We have assumed that there are approximately 70 existing respondents, with 2 new respondents per year over the next 3 years of this ICR.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical and $26.38 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c Rate of failed performance tests is 20 percent.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.