Table
2.
ANNUAL
RESPONDENT
BURDEN
&
COST
OF
REPORTING
&
RECORDKEEPING
REQUIREMENTS
OF
PART
63
SUBPART
M
(
B)
(
C)

(
A)
#
of
Person­
hr/
(
D)
(
E)
(
F)
(
G)

Person­
hr
per
occurrence/
respondent/
Respondent/
Mgmt­
hr/
Tech­
hr/
Employee­
hr
(
H)

Burden
Item
occurrence
respondent/
yr
yr
year
(
a)
year
(
b)
Year
Year
Cost,
$
(
c)

1.
Applications
Not
applicable
2.
Surveys
&
Studies
Not
applicable
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
2,571
(
d)
2,571
(
e)
10
2,571
129,794.36
B.
Required
activities
Not
applicable
C.
Create
Information
Not
applicable
D.
Gather
existing
information
Initial
report
information
2
1
2
2,571
(
d)
256
4,885
5,141
86,682.52
Solvent
consumption
1
1
1
2,571
(
d)
129
2,442
2,571
43,384.19
Compliance
method
report
1
1
1
1,786
(
f)
88
1,698
1,786
30,126.69
E.
Write
report
Initial
notification
report
1
1
1
2,571
(
d)
129
2,442
2,571
43,384.19
Compliance
method
report
1
1
1
1,786
(
f)
1,786
0
(
r)
1,786
90,164.42
Solvent
consumption
report
0.25
1
0.25
785
(
h)
196
0
(
r)
196
9,907.49
Report­
exceed
consumption
cutoff
1
1
1
128
(
i)
128
0
(
r)
128
6,461.95
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
activities
1
1
1
2,571
(
d)
0(
j)
2,571
(
j)
2,571
38,819.53
C.
Implement
activities
Weekly
Leak
detection/
repair
0.75
52
(
k)
39
17,428
(
n)
0(
j)
679,692
(
j)
679,692
10,262,669.51
Bi­
weekly
leak
detection/
repair
0.75
26
(
m)
19.5
7,662
(
n)
0(
j)
149,409
(
j)
149,409
2,255,926.49
D.
Develop
record
system
Solvent
consumption
1
1
1
2,571
(
d)
0(
j)
2,571
(
j)
2,571
38,819.53
Leak
detection
1
1
1
2,571
(
d)
0
(
j)
2,571
(
j)
2,571
38,819.53
Monitoring
records
1
1
1
1,786
(
f)
0
(
j)
1,786
(
j)
1,786
26,966.81
E.
Time
to
enter
information
Records
of
solvent
consumption
0.25
12
(
p)
3
25,090
(
l)
9
(
g)
75,261
75,270
1,137,006.57
Records
of
weekly
inspections
0.25
52
(
k)
13
17,428
(
n)
39
(
g)
226,525
226,564
3,421,394.68
Records
of
bi­
weekly
inspections
0.25
26
6.5
7,662
(
n)
0
(
g)
49,793
49,793
752,480.34
F.
Time
to
Train
personnel
Leak
detection
1
2
(
q)
2
2,571
(
d)
2,571
2,571
5,142
168,613.89
G.
Time
for
audits
Not
applicable
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

Totals
Burdens
and
Cost
7,704
1,204,226
1,212,129
8,581,444.88
(
C)
=
(
A)
x
(
B
(
G)
=
(
E)
+
(
F)
FOOTNOTES
FOR
TABLE
2.

a.
Number
of
estimated
respondents
based
on
growth
rates
applied
to
1987
Census
Data.
All
facilities,
except
for
industrial
sources,
have
1.25
machines.

b.
Management
hours
are
assumed
to
be
0.05
x
employee
hours,
unless
otherwise
noted.

c.
Cost
are
based
on
the
following
hourly
rates:
management
at
$
24.04,
and
employee
at
$
7.19
plus
110
percent
overhead.
The
employee
rate
was
obtained
from
Bureau
of
Labor
for
launders
and
dry
cleaners
machine
operators.

d.
Of
the
estimated
existing
25,090
cleaners
it
is
estimates
that
2,571
cleaners
will
leave
the
industry
and
will
be
replaced
by
2,571
new
dry
cleaners.

e.
This
task
requires
management
hours
only.

f.
Based
on
the
estimate
that
1,786
(
or
70%)
of
the
2,571
new
facilities
will
be
above
the
cutoff
and
thus
required
to
perform
this
task.

g.
This
task
is
performed
by
technical
staff.
Management
hours
are
only
are
for
the
limited
number
major
sources.

h.
Based
on
the
estimate
that
785
(
or
30%)
of
the
2,571
new
facilities
will
be
below
the
cutoff
and
thus
required
to
perform
this
task.

i.
It
is
estimated
that
5%
of
existing
facilities
each
year
that
were
initially
below
the
consumption
cutoff
will
exceed
the
cutoff,
thus
requiring
submission
of
the
Exceed
Consumption
Cutoff
Report,
2,554
x
0.05
=
128.

j.
This
task
requires
only
technical
employee
hours.

k.
Occurrences
based
on
weekly
inspection,
assuming
52
weeks
per
year.

l.
Based
on
25,090
facilities
performing
this
task
every
year.

m.
Facilities
below
cutoff
perform
leak
detection
and
repair
on
a
biweekly
basis.

n.
Estimated
that
of
25,090
perc
dry
cleaners
17,428
will
be
above
the
perc
consumption
cutoff,
which
will
require
that
the
cleaner
conduct
weekly
leak
detection
and
repair.
The
remaining
7,662
perc
dry
cleaners
are
below
the
consumption
cutoff
and
are
only
required
to
conduct
bi­
weekly
leak
detection
and
repair.

o.
Records
are
prepared
for
monitoring
with
a
colorimetric
indicator
tube
for
an
existing
carbon
adsorber,
or
a
temperature
reading
for
a
refrigerator
condenser.

p.
Occurrences
based
on
twelve
month
rolling
average
of
PCE/
perc
consumption,
determined
once
per
month.

q.
Estimate
includes
hours
for
training
for
one
owner/
operator
and
one
employee.

r.
This
task
requires
only
management
hours.
