SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR part 63,
subpart M) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR part 63,
subpart M) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Perchloroethylene (PCE) Dry Cleaning Facilities in subpart M were
proposed on December 9, 1991, and promulgated on September 22, 1993. 
These standards apply to the following dry cleaning facilities in
subpart M: 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-to-dry
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 NESHAP for Perchloroethylene Dry
Cleaning Facilities in 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 United States
Environmental Protection Agency (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 NESHAP.  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 five 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 32,000 sources are currently subject to the regulation,
and it is estimated that an additional 2,240 sources per year will
become subject to the regulation in the next three years, but that the
overall number of facilities will remain constant as the new owners will
take over old existing facilities.  The estimated labor cost of this
Information Collection Request (ICR) will be $25,725,630 (rounded).

	

The Office of Management and Budget (OMB) approved the current 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 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, 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, perchloroethylene emission from dry
cleaning facilities causes or contributes to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was 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 NESHAP continue
to operate the control equipment and achieve continuous 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.  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

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart M.

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

3(c)  Consultations

For this information collection, we used several different resources to
obtain the most recent data available for dry cleaning facilities
sources.  We referenced the most recent ICR, and reviewed information
available from the Office of Compliance Sector Notebook “Profile of
the Dry Cleaning Industry,” and the Sector Notebook Data Refresh -
1997.  We also accessed the most recent data available on the Air
Facility System (AFS) database as maintained by the Office of
Compliance.  In addition, we contacted the Census Bureau, Mr. John
Meijer, International Fabricare Institute (IFI), (301) 622-1900.

Based on conversations with consultants and information gathered, we
estimate that there will be 32,000 respondents with 2,240 turn over of
affected facilities per year over the next three years.

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

These standards require affected facilities to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

No other reporting or recordkeeping requirements violate the regulations
established by OMB at 5 CFR 1320.5.

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 and NAICS Codes

The respondents to the recordkeeping and reporting requirements are
existing cleaning facilities operating dry-to-dry machines only and
consuming 0.8 megagrams per year (Mg/yr) [140 gallons (gal)] of PCE;
existing facilities operating transfer machines systems consuming more
than 1.1 Mg/yr (200 gals); existing facilities operating both dry-to-dry
machines and transfer machines systems consuming more than 0.8 Mg/yr of
PCE; or new facilities entering the dry cleaning business (United States
Standard Industrial Classification (SIC) Codes 7215, 7216, and 7218
corresponding to North American Industry Classification System (NAICS)
Codes 812310, 812320, and 812332).  New dry cleaning facilities are
those systems that commence construction/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
National Emission Standards for Hazardous Air Pollutants for
Perchloroethylene Dry Cleaning Facilities (40 CFR part 63, subpart M).

A source must make the following reports:

Reports for 40 CFR part 63, subpart M

Initial notifications	63.324(a)

Initial report requirements	63.324(a)

Compliance report	63.324(b)

Facility status change	63.324(c)

Exceedence of low solvent consumption exemption level.	63.324(c) 



A source must maintain the following records:

Recordkeeping for 40 CFR part 63, subpart M

Solvent purchases per month and calculation of yearly PCE consumption.
63.324(d)

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)



(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate control device.

Perform initial performance 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 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.



Presently, sources are using monitoring equipment that provides
parameter data in an automated way (e.g., leaks of perchloroethylene). 
Although personnel at the source still need to evaluate the data, this
type of monitoring equipment has significantly reduced the burden
associated with monitoring and recordkeeping.  In addition, some
regulatory agencies are setting up electronic reporting systems to allow
sources to report electronically which is reducing the reporting burden.
 However, electronic reporting systems are still not widely used by the
regulatory agencies.

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 Air Facility System 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 operational.  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.

Information contained in the reports is entered into the Air Facility
System (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 government-owned facilities.  EPA uses 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 five years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are primarily small entities
(e.g., small businesses).  When developing the regulation, 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 are no 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 a
lesser 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 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 of the Federal Register notice to their
members.  Also, newspaper articles were published to reach the smallest
dry cleaning facility owners or operators.  The EPA, States and local
agencies offered compliance assistance to dry cleaners in order to
assist them in complying with the NESHAP regulations with minimal
burdens.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Perchloroethylene Dry Cleaning Facilities (40 CFR part 63, subpart M).

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
1,537,784 (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 NESHAP program, the
previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

This ICR uses a Technical rate for dry cleaner employees of $7.86 per
hour.  This rate is from the United States Department of Labor, Bureau
of Labor Statistics, Occupational Employment Statistics, ”2001
National Occupational Employment and Wage Estimates.”  The Managerial
rate of $31.10 per hour was used.  This rate is from the United States
Department of Labor, Bureau of Labor Statistics, “Table 10. Private
industry, by occupational and industry group,” December 2002.  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 only type of industry cost associated with the information
collection activity in the regulations are labor costs and operation and
maintenance costs.  There are no capital/startup costs.  The average
annual burden for capital costs to industry over the next three years of
the ICR is estimated to be zero.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitors and other costs
such as photocopying and postage which are itemized in the following
table.

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

The capital/startup costs are one-time-only cost when a facility becomes
subject to the regulation.  The annual operation and maintenance costs
are the ongoing cost to maintain the monitors and other costs such as
photocopying and postage.

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

(A)

Continuous Monitoring Device	(B)

Startup Cost for One Affected Facility	(C)

Number of New Affected Facilities to Startup	(D)

Total Startup

(B X C)	(E) 

Annual O&M Costs for One Affected Facility	(F)

Number of Affected Facilities with O&M	(G)

Total O&M

(E X F)

N/A	N/A	N/A	N/A	$1.20	32,000	$38,400.00

N/A	N/A	N/A	N/A	$6.37	2,240	$14,268.80

N/A	N/A	N/A	N/A	$6.00	112	$672.00





	TOTAL	$53,340.80



The total capital/startup cost for this ICR is zero.  This is the total
of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are
$53,341.  This is the total of column G.

The total respondent non-labor 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 of the next three years of
the ICR are estimated to be $53,341.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  Publication and distribution of the
information are part of the AFS 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 Agency cost during the three years of the ICR is
estimated to be $203,862.  (See Table 2: Average Annual EPA Burden -
NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR part 63,
subpart M)).  This cost is based on the average wage of a GS-13, Step 5,
for manager rates, GS-12 Step 1, for technical rates, and GS-6, Step 3,
for clerical support and travel associated with compliance activities. 
Details upon which this estimate is based appear in Table 2.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation

40 CFR Part 63,

Subpart M	(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

Write Initial Notification Report	2,240	1	32,000	0	32,000	34,240

Compliance Method Report	1,568	1	N/A	0	N/A	1,568

Solvent Consumption Report	672	1	N/A	0	N/A	672

Report Exceed Consumption Cutoff	112	1	N/A	0	N/A	112





	TOTAL	36,592

	

The number of total respondents is 34,240.  This number is the sum of
column A, line 1 and column C, line 1 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 36,592.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.

The total annual labor costs are $25,725,630 (rounded).  Details upon
which this estimate is based appear in Table 1: Annual Respondent Burden
and Cost - NESHAP for Perchloroethylene Dry Cleaning Facilities, (40 CFR
part 63, subpart M).

The total annual capital and O&M costs to the regulated entity are
$53,000.  These costs are detailed in section 6(b)(iii), Capital/Startup
vs. Operating 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 are estimated to average one
hour per response.

6(f)  Reasons for Change in Burden

There is no change in hours in the total estimated burden currently
identified in the OMB Inventory of Approved ICR Burdens.  It is
estimated that an additional 2,240 sources per year will remain subject
to the regulation in the next three years, but that the overall number
of facilities will remain constant as the new owners will take over old
existing facilities.  This was verified by contacting a number of Trade
Associations, and subsequently determined that the number of respondents
subject to the rules addressed by this ICR is 32,000.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average approximately 42 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 for 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.

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-2006-0441, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Avenue, N.W., Washington, D.C.  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) 566-1927.  An
electronic version of the public docket is available online at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public 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 above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention:
Desk Office for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2006-0441 and OMB Control Number 2060-0234 in any
correspondence.

NOTE:  The EPA Docket Center suffered damage due to flooding during the
last week of June 2006.  The Docket Center is continuing to operate. 
However, during the cleanup, there will be temporary changes to Docket
Center telephone numbers, addresses, and hours of operation for people
who wish to visit the Public Reading Room to view documents.  Consult
EPA's Federal Register notice at 71 FR 38147 (July 5, 2006) or the EPA
website at   HYPERLINK "http://www.epa.gov/epahome/dockets.htm" 
www.epa.gov/epahome/dockets.htm  for current information on docket
status, locations and telephone numbers.  

Part B of the Supporting Statement

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



Table 1. Annual Industry Burden - NESHAP for Perchloroethylene Dry
Cleaning Facilities (40 CFR part 63, subpart M)

					       (A)	     	        (B)	      	        (C)		       (D)	       
 	     (E)	                (F)	       (G)	                  (H)

					  Hours per	Occurrences	    Hours		Respondent/	Mgmt hrs/       
Tech hrs/      Employee             Cost, $

                                                                        
        Occurrence	Respondent/ 	Respondent/	   per Year	    Year a	     
       Year b         hrs/Year	Year

						                      Year	                       Year			    	    
$65.31              $16.51	   (E + F)

Burden Item								     (A x B)

________________________________________________________________________
________________________________________________________________________
___

1.  APPLICATIONS		  	              N/A												

2.  SURVEY AND STUDIES		              N/A

3.  REPORTING REQUIREMENTS	 

      A.  Read Instructions 			                1		 1                    
 1	   	 2,240c	 	 2,240e		       0	    2,240	       146,294.40

      B.  Required activities			             N/A

      C.  Create Information			             N/A

      D.  Gather existing information

	Initial report information			2		 1	         2             	 2,240c	   	
   224		4,256 	    4,480	         84,896.00

      	Solvent consumption			1		 1	         1	      	 2,240c 	     	   
112	                2,128	    2,240            42,448.00

	Compliance method report			1		 1	         1		 1,568d		      78	        
       1,490	    1,568            29,694.08	

       E.  Write Report

     	Initial notification report			1		 1	         1		 2,240c 		    112	
               2,128	    2,240            42,448.00

	Compliance method report			1		 1	         1		 1,568d		 1,568		       0e
    1,568          102,406.08

	Solvent consumption report 	      	                0.25		 1	        
0.25	    672g         	    168	                       0e 	       168    
       10,972.08

                Report-exceed consumption cutoff		1		 1	         1		   
112h	     	    112		       0e	       112              7,314.72

4.  RECORDKEEPING REQUIREMENTS

     A.  Read Instructions			    Included in 3A 

     B.  Plan activities				1		 1	         1     	  2,240c	     	       
0                      2,240i	    2,240            36,982.40

     C.  Implement activities  

	Weekly Leak detection/repair 	    	0.75	              52j 	       39	  
             22,400n                           0                 
873,600i	873,600     14,423,136.00 

 	Bi-weekly leak detection/repair 		0.75	              26k	       19.5	 
    	  9,600n		        0                  187,200i	187,200      
3,090,672.00

     D.  Develop record system

     	Solvent consumption			1		 1	         1		  2,240c	      	        0	
               2,240i 	    2,240	         36,982.40

     	Leak detection				1		 1	         1	             	  2,240c		       
0	                2,240i 	    2,240	         36,982.40

     	Monitoring records			 	1		 1	         1	                  1,568d 	
       	        0 	                1,568i 	    1,568	         25,886.68

     E.  Time to enter information

      	Records of solvent consumption          		0.25	              12l 
         3	     	32,000m           	        9f                   95,991 
       96,000       1,585,399.19

               Records weekly inspections 	      		0.25	             
52j 	       13	                22,400n 	    	      39f                
291,161       291,200       4,809,615.19

	Records of bi-weekly inspections	             	0.25	              26	  
      6.5		  9,600n 		        0	              62,400i         62,400    
 1,030,224.00

     F.  Time to Train personnel

     	Leak detection				1	               2o 	         2	                
 2,240c	   	 2,240p	               2,240p	     4,480         183,276.80

     G.  Time for audits		                             N/A

TOTAL ANNUAL BURDEN										 6,902	        1,530,882      1,537,784   
25,725,630.42	

(C) = (A) x (B)

(G) = (E) + (F)

Assumptions:

a. Assume that hours are 5% of the employee hours unless otherwise
noted.  The management labor rate of $31.10 was obtained from the United
States Department of Labor, Bureau of Labor Statistics, September 2002,
“Table 10. Private industry, by occupational and industry group.” 
The wage rate obtained from the table has been increased by 110% to
account for the benefit packages available to those employed by private
industry.

b. Assume technical labor rate for dry cleaner employees of  $7.86,  was
obtained from the United States Department of Labor, Bureau of Labor
Statistics, September 2002, “Table 10. Private industry, by
occupational and industry group.”  The wage rate obtained from the
table has been increased by 110% to account for the benefit packages
available to those employed by private industry.

c. Assume that there are 32,000 existing cleaners and that 2,240
cleaners will leave the industry and will be replaced by 2,240 new dry
cleaners.

d. Based on the estimate that 1,568 (70%) of the 2,240 new facilities
will be above the cutoff and thus required to perform this task.

e. This task requires management hours only.

f. This task is performed primarily by technical staff.  Management
hours are only for a limited number of major sources.

g. Based on the estimate that 672 (30%) of the 2,240 new facilities will
be below the cutoff and thus required to perform this task.

h. 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.

i. This task requires only technical employee hours.

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

k. Assume that facilities below cutoff performs leak detection and
repairs on a bi-weekly basis.

l. Occurrences based on twelve months rolling average of
PCE/perchloroethylene consumption, determined once per month.  

m. Based on 32,000 facilities performing this task every year.

n. Assume that of 32,000 perchloroethylene dry cleaners 22,400 will be
above the per consumption cutoff, which will require that the cleaner
conduct weekly leak detection and repair.  The remaining 9,600
perchloroethylene dry cleaners are below the consumption cutoff and are
only required to conduct bi-weekly leak detection and repair.

o. Estimates includes hours for training, one owner/operator and one
employee.

p. This task requires an equal amount of management and technical
employee hours.

TABLE 2: AVERAGE Annual EPA Burden - NESHAP for Perchloroethylene Dry
Cleaning Facilities (40 CFR part 63, subpart M)

  

					       (A)	     	        (B)	   	    (C)		      (D)	         	     
 (E)		              (F)

				         EPA Technical  	Occurrences	 Technical              Mgmt
hrs/ 	Clerical hrs/	        EPA COST/	  

Burden Item			         hrs / Occurrence    	   Per year	hrs / year	
hour/year                Plant/Year        	             Year      	  

									   $39.49                     $53.22 e	       $21.38 e   			

________________________________________________________________________
___________________________________________________

Report Review

  New Plant a

      Initial notification report				1	 2,240	     	2,240	      	112	   
  	     224       	        99,207.36

      Solvent consumption report b			1	    672	 	   672	        	  34	  
      	        67		        29,779.22

      Report-exceed consumption cutoff c			1	    112	       	   112     
   	    6	         	        11		          4,977.38 

      Compliance method report d	      		1	 1,568	       	1,568		  78   
       	      179		        69,898.50       	

Total Burden and Cost						    	4,592				    		      203,862.46

               

Assumptions:

a. Costs are based on the following hourly rates obtained from the
Office of Personnel Management (OPM) “2003 General Schedule” which
excludes locality rates of pay: 

1) Clerical at $13.36, 2) Technical at $24.68, and 3) Managerial at
$33.26.  These rates are increased by 60% to account for government
overhead expenses.

b. Area sources consuming less than 140 gallons of perchloroethylene per
year: 30 % of total number of new sources.

c. Assume that 5% will have to report-exceed consumption cutoff.

d. Area sources consuming between 140 to 200 gallons of
perchloroethylene per year: 70%

    e. Management hours and clerical hours amount to 5% and 10%,
respectively, of the technical hours.

       1) The cost of photocopying 32,000 one page per month for twelve
months @ $1.20, 2) The cost of postage to mail initial  notification and
compliance report for 2,240 @ $6.37, 3) The cost of postage to mail
solvent consumption report is $6.00 per report.

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