1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
MACT
Subpart
M,
Perchloroethylene
(
PCE)
Dry
Cleaning
Facilities
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
1.
Identification
of
the
Information
Collection
1(
a)
ICR
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Perchloroethylene
(
PCE)
Dry
Cleaning
Facilities
Subpart
M
­
Recordkeeping
and
Reporting
Requirements
1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Perchloroethylene
Dry
Cleaning
Facilities
Subpart
M
were
proposed
on
December
9,
1991
and
promulgated
on
September
22,
1993
.
These
standards
apply
to
the
following
dry
cleaning
facilities:
existing
facilities
operating
dry­
to­
dry
machines
only
and
consuming
over
0.8
megagrams
per
year
(
Mg/
yr)
[
140
gallons
(
gal)]
of
PCE;
existing
facilities
operating
transfer
machines
systems
consuming
over
1.1
Mg/
yr
(
200
gal);
existing
facilities
operating
both
dry­
todry
machines
and
transfer
machine
systems
consuming
over
0.8
Mg/
yr
of
PCE;
or
new
facilities
entering
the
dry
cleaning
business.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
Subpart
M.
Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
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.
Monitoring
requirements
specific
to
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Perchloroethylene
(
PCE)
Dry
Cleaning
Facilities
Subpart
M
provide
information
on
the
operation
of
the
control
device
and
pollution
prevention
practices
along
with
compliance
with
the
standard.
All
facilities
must
maintain
yearly
PCE
consumption
records,
and
must
implement
a
leak
detection
and
repair
program.
Owners
or
operators
must
submit
required
reports
to
the
EPA
or
the
delegated
State
regulatory
authority.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
MACT.
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
5
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Approximately
25,090
sources
are
currently
subject
to
the
standard.
This
estimate
was
based
on
the
assumption
that
there
will
be
2,571
new
affected
facilities
each
year,
but
that
the
overall
number
of
facilities
will
remain
constant
as
the
new
owners
will
take
over
old
existing
facilities.
It
is
further
assumed
that
there
is
an
average
of
one
affected
facilities
per
plant
(
respondent).
The
cost
of
this
ICR
will
be
$
8,851,444.88.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
2
sent
directly
to
the
EPA
Regional
Office.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction:
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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
perchloroethylene
emissions
from
dry
cleaning
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
63
Subpart
M.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
perchloroethylene
from
dry
cleaning
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
perchloroethylene
from
dry
cleaning
facilities
are
the
result
of
operating
the
dry
cleaning
units.
These
standards
rely
on
the
reduction
of
PCE
emissions
by
refrigerated
condensers
or
carbon
absorbers,
and
pollution
prevention
.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
records
and
reports
are
necessary
to
enable
the
reviewing
authority
to
identify
facilities
that
may
not
be
in
compliance
with
the
standard.
Based
on
reported
information,
the
reviewing
authority
can
decide
which
facilities
should
be
offered
compliance
assistance
and/
or
inspected,
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
the
facilities
maintain
would
indicate
to
the
authority
whether
transfer
emissions
and
other
fugitive
emissions
are
being
properly
controlled.
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
MACT
continue
to
operate
the
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
3
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.
To
minimize
the
burden,
much
of
the
information,
which
is
kept
onsite,
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
the
authority.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
are
required
under
40
CFR
Part
63
Subpart
M.
If
the
standard
has
not
been
delegated
the
information
is
sent
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
regulation
to
implement
the
Federal
Regulation,
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
Standard.
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
October
29,
1999
[
64
FR
58396].

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
63
Subpart
M
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.
4
3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
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
contained
in
40
CFR
Part
63
Subpart
M
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
existing
dry
cleaning
facilities
operating
dry­
to­
dry
machines
only
with
and
consuming
0.8
megagrams
per
year
(
Mg/
yr)
[
140
gallons
(
gal)]
of
PCE;
existing
facilities
operating
transfer
machines
systems
consuming
over
1.1
Mg/
yr
(
200
gal);
existing
facilities
operating
both
dry­
to­
dry
machines
and
transfer
machines
systems
consuming
over
0.8
Mg/
yr
of
PCE;
or
new
facilities
entering
the
dry
cleaning
business
(
SIC
Code
7215,
7216,
and
7218).
New
dry
cleaning
facilities
are
those
systems
that
commences
construction
or
reconstruction
on
or
after
December
9,
1991.
Other
systems
are
existing
PCE
dry
cleaning
facilities.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
M
Perchloroethylene
Dry
Cleaning
Facilities.
A
source
must
make
the
following
reports
Provide
notification
of:
­
initial
notifications
(
63.324(
a))
Report
on:
­
initial
report
requirements
(
63.324(
a))
­
compliance
report
(
63.324(
b))
­
facility
status
change
(
63.324(
c))
­
exceedance
of
low
solvent
consumption
exemption
level
(
63.324(
c))
A
source
must
keep
the
following
records
­
solvent
purchases
per
month
and
calculation
of
yearly
PCE
consumption
(
63.324(
d))
5
­
weekly
or
biweekly
inspections
(
63.324(
d))
­
date
of
repairs
or
purchase
orders
for
repairs
(
63.324(
d))
­
monitoring
of
control
equipment
(
63.324(
d))
­
design
specification
and
operating
manual
for
dry
cleaning
systems
and
emission
control
device
(
63.324(
e))
­
all
reports
and
notifications
63.10(
b)
­
record
of
applicability
63.10(
b)(
3)
Records
are
required
to
be
retained
for
5
years
onsite.
All
MACT
standards
require
5
years
of
record
retention.
b.
Respondent
Activities
­
Read
instructions
­
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;
­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;
­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information;
­
adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
­
training
personnel
to
be
able
to
respond
to
a
collection
of
information;
­
transmitting,
or
otherwise
disclosing
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
information
required
under
40
CFR
Subpart
M:
­
Reviews
notifications
and
reports
required
to
be
submitted
by
industry
­
Audits
facility
records
­
Inputs,
analyzes,
and
maintains
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database
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.
Initial
notification
reports
and
compliance
method
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
the
operating
condition,
e.
g.
annual
6
solvent
consumption,
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
records
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
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
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
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
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
five
years.

5(
c)
Small
Entity
Flexibility
The
dry
cleaning
industry
is
considered
to
be
composed
primarily
of
small
businesses;
therefore,
almost
all
facilities
are
small
entities.
When
developing
the
regulation,
the
EPA
took
special
steps
to
ensure
that
the
burdens
imposed
on
small
entities
were
reasonable.
For
example,
an
in­
depth
economic
analysis
(
comparable
to
a
Regulatory
Flexibility
Analysis)
was
conducted
and
documented
in:
"
Economic
Impact
of
Regulatory
Control
in
the
Dry
Cleaning
Industry",
EPA­
45/
3­
91­
021.
Because
of
the
large
number
of
small
businesses
in
this
industry,
the
reporting
requirements
for
the
individual
cleaning
facilities
are
minimal.
There
is
not
any
quarterly,
semiannual
or
annual
reporting
requirements
as
there
are
with
most
regulated
large
industries.
The
burden
is
further
minimized
since
costly
monitoring
equipment,
such
as
a
continuous
monitor,
is
not
required.
In
a
conscience
effort
to
allow
smaller
businesses
to
carry
less
burden
than
their
larger
counterparts,
the
weekly
recordkeeping
requirement
for
leak
detection
and
repair
is
reduced
to
biweekly
for
the
smallest
dry
cleaning
facilities.
Several
steps
have
been
taken
to
ensure
that
small
entities
are
informed
of
the
NESHAP
and
their
reporting
and
recordkeeping
responsibilities.
Following
the
publication
of
the
promulgated
rule,
copies
of
the
Federal
Register
notice
and,
in
some
cases,
background
documents
were
mailed
to
all
industries
and
organizations
who
have
had
input
during
the
regulation
development
and
to
relevant
State
and
local
agencies.
Trade
associations
distributed
copies
to
their
members.
Also,
newspaper
articles
were
published
to
reach
the
smallest
dry
cleaning
facility
owners
or
operators.
The
EPA,
States
and
local
agencies
offer
compliance
assistance
to
dry
cleaners
concerning
the
NESHAP
to
assist
them
in
complying
with
the
regulations
with
minimal
burden.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.
7
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
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
at
1,212,129
(
total
from
industry
table)
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
MACT
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
managers
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1998,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group
and
labor
rates
of
launders
and
dry
cleaning
machine
operators
from
the
Bureau
of
Labor
Statistics,
http://
stats/
bls.
gov/
special.
requests/
ocwc/
octl/
ncsos/
ncs/.
Executive,
Administrative,
and
Managerial
$
50.48
($
24.04
per
hour
+
110%
overhead)
Launder
and
Dry
Cleaning
Machine
Operators
$
15.10
($
7.19
per
hour
+
110%
overhead)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital
or
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
zero.
The
standards
do
not
require
the
facilities
to
install
or
operate
any
continuous
monitoring
equipment.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
only
monitoring
requirements
are
for
a
leak
detection
and
repair
standard
(
LDAR).
There
is
no
requirement
for
continuous
monitoring
which
may
generate
operating
and
maintenance
costs.
8
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
217,588.50
(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
GS10
step
1
employee
rate,
G12
step
12
manager,
and
GS3
step
1
clerical
support
staff
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
NESHAP
for
Perchloroethylene
Dry
Cleaning
Facilities
Subpart
M
is
25,090.
The
number
of
new
sources
subject
to
NESHAP
for
Perchloroethylene
Dry
Cleaning
Facilities
Subpart
M
is
2,571.
The
number
of
total
respondents
is
25,090.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year
minus
the
number
of
discontinued
sources
in
one
year.
Because
the
dry
cleaning
industry
is
dominated
by
small
businesses
with
a
high
turnover
rate,
it
is
estimated
that
new
sources
are
typically
replacing
older
sources.
The
total
annual
responses
is
5,270.
This
number
is
calculated
from
the
number
of
new
sources
multiplied
by
the
number
of
initial
reports,
plus
the
number
of
existing
sources
multiplied
by
the
consumption
exceedance
cutoff
reports.
The
total
annual
labor
costs
are
$
8,581,444.88
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
zero
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Table
2,
Annual
Respondent
Burden
and
Cost
of
Reporting
&
Record
Keeping
Requirements
6(
f)
Reasons
for
Change
in
Burden
The
burden
from
the
most
recently
approved
ICR
is
similar
to
the
burden
determined
in
this
ICR.

6(
g)
Burden
Statement
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
9
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
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.
Include
the
EPA
ICR
number
1415.04
and
OMB
control
number
2060­
0234
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
