| Table 1: Annual Respondent Burden and Cost – NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) |
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92.59 |
135.18 |
54.71 |
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| 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 |
| 4b(ii) Reporting requirements |
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| Familiarization with regulatory requirements |
2 |
1 |
2 |
44 |
88 |
4.4 |
8.8 |
$9,224.16 |
| Familiarization with CEDRI and CDX registration. |
2.0 |
1 |
2.0 |
44 |
88.00 |
4.4 |
8.8 |
$9,224.16 |
| VOC emission reports c |
1 |
4 |
4 |
44 |
176 |
8.8 |
17.6 |
$18,448.32 |
| Temperature reports d |
1 |
2 |
2 |
44 |
88 |
4.4 |
8.8 |
$9,224.16 |
| TOTAL LABOR BURDEN AND COST |
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|
506 |
$46,120.80 |
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| Assumptions |
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| a We have assumed that there are approximately 44 existing respondents, and no new respondents over the next 3 years of this ICR. |
| b This ICR uses the following labor rates: $135.18 per hour for Executive, Administrative, and Managerial labor; $92.59 per hour for Technical labor, and $54.71 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, , “May 2020 National Industry-Specific Occupational Employment and Wage Estimates NAICS 336100 – Motor Vehicle Manufacturing.” The rates are from column 8, “Mean hourly wage.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
| c We have assumed each respondent will submit 4 quarterly VOC emission reports per year. |
| d We have assumed each respondent will submit 2 temperature reports per year. |
| Table 2: Average Annual EPA Burden and Cost – NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) |
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52.37 |
70.56 |
28.34 |
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| 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 |
| 4b(ii) Reporting requirements |
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| Electronic reporting regulatory requirements |
1 |
1 |
0.5 |
44 |
22 |
1.10 |
2.20 |
$1,292.10 |
| Support CEDRI and CDX registration and template. |
1 |
1 |
0.5 |
44 |
22 |
1.1 |
2.2 |
$1,292.10 |
| VOC emission reports |
1 |
4 |
1 |
44 |
44 |
2.2 |
4.4 |
$2,584.21 |
| Temperature reports |
1 |
2 |
1 |
44 |
44 |
2.2 |
4.4 |
$2,584.21 |
| TOTAL LABOR BURDEN AND COST |
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|
152 |
$7,800 |
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| Assumptions |
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| a We have assumed that there are approximately 44 existing respondents, with no new respondents per year over the next 3 years of this ICR. |
| b These rates are from the United States Department of Labor, Bureau of Labor Statistics, , “May 2020 National Industry-Specific Occupational Employment and Wage Estimates NAICS 336100 – Motor Vehicle Manufacturing.” The rates are from column 8, “Mean hourly wage.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |