Supporting Statement for NSPS for Automobile and Light Duty Truck
Surface Coating Operations

(40 CFR part 60, subpart MM)

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).

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Automobile and Light
Duty Truck Surface Coating Operations (40 CFR part 60, subpart MM) were
proposed on October 5, 1979, and promulgated on December 24, 1980 (45 FR
85415).  These standards 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 63, subpart MM.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators 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, in general, of all sources
subject to NSPS.

Any owner or 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 directly to the United States Environmental Protection
Agency (EPA) regional office.

Approximately 52 sources are currently subject to the standard, and it
is estimated that an additional two sources per year will become subject
to the regulation in the next three years.  This estimate is based on
discussions with the industry, EPA’s Air Facility System (AFS), and
the previously approved Information Collection Request (ICR).

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, 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 four years. 

In addition, Section 114(a) states that the Administrator may require
any owner or 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, volatile organic compound (VOC)
emissions from automobile and light duty truck coating operations cause
or contribute to air pollution that may reasonably 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 control of emissions of VOCs from automobile and light duty truck
coating operations requires not only the installation of properly
designed equipment, but also the operation and maintenance of that
equipment.  Emissions of VOCs from automobile and light duty truck
coating operations are the result of operation of the affected
facilities.  The subject standards are achieved by the capture and
destruction of pollutant emissions using incinerators or through the use
of coatings which contain lower amounts of VOCs.  The notifications
required in the applicable regulations 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 and the regulations are being met.  Performance test reports
are needed as these are the Agency’s record of a source’s initial
capability to comply with the emission standards, and serve as a record
of the operating conditions under which compliance was achieved.  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.  The semiannual reports are used for problem
identification as a check on source operation and maintenance and for
compliance determinations.  The information generated by the monitoring,
recordkeeping and reporting requirements described in this ICR is used
by the Agency to ensure that facilities affected by the NSPS continue to
operate the control equipment in compliance with the regulation. 
Adequate monitoring, recordkeeping, and reporting are necessary to
ensure compliance with these standards, as required by the Clean Air
Act.  The information collected from recordkeeping and reporting
requirements is also used for targeting inspections, and is of
sufficient quality to be used as evidence in court. 

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, 

subpart MM.

3(a)  Nonduplication

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 their 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, no duplication
exists.

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 on June 21, 2006 (71 FR 35652). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

	The primary source of information as reported by industry, in
compliance with the record keeping and reporting provisions in the
standard, is the ARS (Airs Facility Subsystem) which is operated and
maintained by EPA’s Office of Compliance.  AFS is the Agency’s
database for the collection, maintenance and retrieval of all compliance
data.  In consultation with the Agency’s industry experts and the AFS
database, we have determined that there has been no growth in the number
of respondents since the last ICR.

	In determining the correct burden estimate associated with this ICR,
industry trade associations and other interested parties have been
provided an opportunity to comment on the burden associated with the
standard as it was being developed and in subsequent renewals of the
ICR.  It is our policy to carefully review any comments received since
the last ICR renewal, including those submitted in response to the first
federal register notice, and respond appropriately. Per this guidance,
all data assumptions from the previous ICR renewal were used as the
basis for estimating the hourly and cost burdens associated with this
renewal.  

	Also, for this information collection, the previous ICR renewal was
used to obtain burden estimates since this ICR renewal was processed
under the “renew without change” option.  Per this guidance, all
data and assumptions from the previous ICR renewal were used as the
basis for estimating the hourly and cost burdens associated with this
renewal.

In the previous ICR, EPA discussed the burden and cost estimates for
this activity with the Alliance of Automobile Manufacturers (AAM) and
the Association of International Automobile Manufacturers (AIAM) at the
last ICR renewal, and revised its estimates accordingly.  EPA’s Office
of Air Quality Planning and Standards (OAQPS) conducted an extensive
review and consultations with industry during development  of the
National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Automobile and Light Duty Truck Surface Coating that affects
substantially the same universe of sources.  For this information
collection, the previous ICR renewal was used to obtain burden estimates
since this ICR renewal was processed under the “renew without
change” option.  Per this guidance, all data and assumptions from the
previous ICR renewal were used as the basis for estimating the hourly
and cost burdens associated with this renewal.  

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.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB in 5 CFR 1320.6.

3(f)  Confidentiality

The required information has been determined not to be confidential. 
However, 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 (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

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are
automobile and light duty truck surface coating operations for which
construction or modification commenced after October 5, 1979.

Standard	

SIC Codes	

North American Industrial Classification System (NAICS) Codes



40 CFR part 60, subpart MM	

3711	

336111



	

	

336112



	

	

336211



4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
NSPS for Automobile and Light Duty Truck Surface Coating Operations (40
CFR part 60, subpart MM).

A source must make the following reports:

Reports



Construction/reconstruction	

60.7(a)(1)



Actual startup	

60.7(a)(3)



Initial performance test results	

60.8(a)



Initial performance test	

60.8(d)



Physical or operational change.	

60.7(a)(4)



Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	

60.7(b)



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)



Install, calibrate, maintain, and operate temperature monitoring device
Quarterly reports of excess VOC emissions, semiannual reports if no
exceedences.	

60.395(b)



Reports of low incinerator temperature.	

60.395(c)



Record the incinerator combustion temperature.	

60.395(d)



Notify the Administrator 30 days in advance of any test by Reference
Method 25.	

60.395(d)



A source must maintain the following records:

Recordkeeping



Startups, shutdowns, malfunctions, 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



(ii)  Respondent Activities

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate the compliance monitoring
system (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 systems for the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of 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.



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



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, analyze, and maintain data in the Air Facility System (AFS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might 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 standard, and note 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 entered into the AFS which is
operated and maintained by EPA’s Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for over 100,000 industrial and
government-owned facilities.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and state regulatory
agencies, EPA regional offices and EPA headquarters.  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 or
operator for 

two years.

5(c)  Small Entity Flexibility

The majority of affected facilities are large entities (e.g., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.  

The number of small entities potentially subject to the requirements of
this ICR is estimated to be zero percent of the respondent universe. 
This estimate is based on the discussion at the 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 Table 1: Annual Respondent Burden and Cost,
NSPS for Automobile and Light Duty Truck Surface Coating Operations (40
CFR part 60, subpart MM).

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 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 recordkeeping and reporting requirements is estimated to be
156,362 ( Total Labor Hours from Table 1).  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 consultations with the industry.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses a Technical Labor Rate of $61.66 per hour.  This rate is
from the United States Department of Labor, Bureau of Labor Statistics,
September 2002, “Table 10. Private industry, by occupational and
industry group.”  The rate is from column 1, “Total compensation.”
 The rate has been increased by 110% to account for the benefit packages
available to those employed by private industry.

(ii)  Estimating Capital and Operations and Maintenance Costs

 

The type of industry costs associated with the information collection
activities in the subject standard(s) 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 monitor(s) and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operating and Maintenance (O&M) Costs

Capital/Startup vs. Operating 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	

52	

$91,000

 

The total capital/startup costs for this ICR are $1,700.  The total
operating and maintenance (O&M) costs for this ICR are $91,000.  This is
the total of column G.  

The total respondent costs have been calculated as the addition of the
capital/startup costs, and the annual operation and maintenance costs. 
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 $92,700.  

The continuous monitoring costs that are included in this section
consist only of those capital/startup and O&M costs that a source incurs
as a result of the standard.  Some continuous monitoring costs may not
be included in this section.  For instance, if a particular industry
typically utilizes a control device that must have a continuous monitor
(e.g., temperature, pressure drop, etc.) to function properly, and the
recordation of additional measurements beyond the minimum is required by
the standard, then there is no capital/startup or O & M cost, but there
is a labor cost to record the additional readings.  Such a cost would
not appear in this section, but in the industry burden Section 6(d)
below.

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 $32,887 (rounded) [see Table 2 in Section 6(e)].  This
cost is based on the average hourly labor rate at a GS-12, Step 1, times
a 1.6 benefits multiplication factor to account for government overhead
expenses for a total of $39.49.

These rates are from the Office of Personnel Management (OPM) “2003
General Schedule” which excludes locality rates of pay.  These rates
can be obtained from the OPM web site,
http//www.opm.gov/oca/payrates/index/htm.  Details upon which this
estimate is based appear in Table 2: Annual Agency Burden and Cost, NSPS
for Automobile and Light Duty Truck Surface Coating Operations (40 CFR
part 60, subpart MM), below.

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

Approximately 52 existing sources are currently subject to the
regulation, and it is estimated that an additional two sources per year
will become subject to the regulation in the next three years.  See
Section 1(b).

Respondent Universe and Number of Responses Per Year



Regulation Citation	

(A)

Average Number of New Respondents per Year	

(B)

Number of Reports for New Sources	

(C)

Number of Existing Respondents	

(D)

Number of Reports for Existing Sources	

(F)

Number of Respondents That Keep Records But Do Not Submit Reports	

(E)

Total Annual  Responses =

(AxB)+(CxD)+F



NSPS subpart MM	

2	

1	

52	

4	

0	

210



The number of total respondents is 54.  This number is the sum of column
A and column C of the Respondent Universe and Number of Responses Per
Year table.  This represents the number of existing sources plus the
number of new sources averaged over the three-year period (i.e., the
total of the number of new respondents over the three-year period
divided by three years).  

The number of Total Annual Responses is 210.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table above.  

The total annual labor costs for Respondents are $9,641,281 (rounded). 
Details regarding these estimates may be found in Table 1. Annual
Respondent Burden and Cost, NSPS for Automobile and Light Duty Truck
Surface Coating Operations (40 CFR part 60, subpart MM).  Note that the
total annual capital and O&M costs to the regulated entity are 92,700. 
These costs are detailed in Section 6(b)(iii), Capital/Startup vs.
Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 745
(rounded) hours per response.

6(f)  Reasons for Change in Burden

There is no change in burden from the most recently approved ICR.  This
ICR renewal was approved under the “renew without change” option and
reflects no increase in the number of new or modified sources.

	

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 745 (rounded) hours per response.
 Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, 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 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 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’s 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-2006-0416.  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), 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 holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Enforcement and Compliance Docket and Information Center Docket is (202)
566-1514.  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 Office for EPA. Please include
the EPA Docket ID Number EPA-HQ-OECA-2006-0416 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.                                   



 

 PAGE   

 PAGE   16 

