SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ)

	1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Petroleum Dry Cleaners
were proposed on December 14, 1982, promulgated on September 21, 1984,
and amended on October 17, 2000 (65 FR 61773).  These standards apply to
owners or operators of petroleum dry cleaning facilities constructed,
reconstructed, or modified after December 14, 1982, with a total
manufacturers’ rated dryer capacity equal to or greater than 38
kilograms (84 pounds).  This information is being collected to assure
compliance with 40 CFR part 60, subpart JJJ.

	In general, all NSPS standards require initial notifications,
performance tests and periodic reports.  Owners or operators also are
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 notification, reports, and records are essential in
determining compliance and are required of all sources subject to NSPS.

	Any owner/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.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	There are approximately 342 existing sources that currently are
associated with the rule, with an estimated 18 new additional sources
per year over the next three years.  The rule stipulates that only new
sources with one-time-only requirements are subject to this subpart. 
Therefore, we concluded that the number of respondents for this renewal
ICR is 18 sources per year.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (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 (CAA), 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 the Administrator's judgment, pollutant emissions from volatile
organic compounds (VOCs) 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 JJJ.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information also is
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard 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, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

	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 its 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 (70 FR 55368) on September 21,
2005.  No comments were received on the burden published in the Federal
Register.

	3(c)  Consultations

Consultation with industry representatives (i.e., respondents) was
conducted to determine if there is any way for EPA to reduce the
recordkeeping and reporting burden, or improve the language in the
standard to make it easier to comply.  Our contacts were: Mr. David
Dawson, R. R. Street and Company Incorporated, (630) 416-4244; Mr.
William Olinger, Hoyt Corporation, (508) 636-8811; and Mr. John Meijer,
International Fabricare Institute (IFI) (301) 622-1900.

We also referenced the most recent ICR, consulted with the preparer of
the active ICR, and used other resources to obtain the most recent data
available.  We reviewed information available from the United States
Census Bureau, the Air Facility System (AFS), which is the primary
source of information regarding the number of existing sources, and
websites covering petroleum dry cleaners.  We also consulted with EPA's
Office of Air Quality Planning and Standards, Information Transfer and
Program Integration Division.

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 that 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 reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB at 5 CFR part 1320, section 1320.5.

	3(f)  Confidentiality

	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

	The reporting, or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
petroleum dry cleaners.  The United States Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which corresponds to the North American Industry
Classification System (NAICS) codes, are listed below for source
category descriptions.

Standard (40 CFR part 60, subpart JJJ)	SIC Codes	NAICS Codes

Coin-Operating Laundry and Drycleaning	7215	812310

Drycleaning Plants, Except Rug Cleaning	7216	812320

Industrial Launderers	7218	812332



	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

In this ICR, all the data that are recorded or reported are required by
NSPS for Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Notification of construction/reconstruction	60.7(a)(1)

Notification of actual startup	60.7(a)(3)

Notification of initial performance test	60.8(d)

Notification of physical or operational change	60.7(a)(4)

Initial performance test results	60.8(a)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	60.7(b)

Initial and repeat of performance tests	60.625

Records are required to be retained for two years	60.7(f)



Electronic Reporting

	Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems still are not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions.

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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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.  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 data for approximately 125,000 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/operator for two years.

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., 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.

	5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NSPS for
Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ).

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.

	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 1,664
hours (Total Labor Hours from Table 1).  This estimate is based on
Agency studies and background documents from the development of this
regulation, Agency knowledge and experience with the NSPS program, the
previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

 

	This ICR uses the following labor rates: 

		Managerial	$97.46  per hour     ($46.41 + 110%)

		Technical	$83.71  per hour     ($39.86 + 110%)

		Clerical	$42.55  per hour     ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  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 costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
There are no capital/startup or operation and maintenance costs.

	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
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $26,936.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$57.20   per hour    (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45   per hour    (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96   per hour    (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden, NSPS for Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ).

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

	Based on our research for this ICR, over the next three years,
approximately 18 respondents per year will be subject to the standard. 
The rule stipulates that only new sources with one-time-only
requirements are subject to this subpart.

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	18	0	0	0	18

2	18	0	0	0	18

3	18	0	0	0	18

Average	18	0	0	0	18



	To avoid double-counting respondents column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 18 per year.  This number appears on the OMB 83-I form in
block 13(a), Number of respondents.

 

	The total number of annual responses per year is calculated using the
following table: 

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Notification of construction/reconstruction	18	1	0	18

Notification of actual startup	18	1	0	18

Notification of initial performance test	18	1	0	18

Report of performance test	18	1	0	18

Report of repeat of performance test	3.6	1	0	3.6



	Total	75



	The number of Total Annual Responses is 75.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

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

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $134,355.  The annual labor costs are
not shown on the OMB 83-I form.  Details regarding these estimates may
be found in Table 1. Annual Respondent Burden and Cost, NSPS for
Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ).  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 22 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $0.  This number is shown on the OMB 83-I form in block 14(c), Total
annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

		(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is
estimated to be 646 labor hours at a cost of $26,736.  See Table 2.
Annual Agency Burden and Cost, NSPS for Petroleum Dry Cleaners (40 CFR
part 60, subpart JJJ).

	

	6(f)  Reasons for Change in Burden

	The increase in burden from the most recently approved ICR is due to
the fact that we are accounting for not only technical person-hours but
also management and clerical person-hours.

	There are no capital/startup and operations and maintenance (O&M) costs
associated with this ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 25 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 request for 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-2005-0066, which is available for public 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 is (202) 566-1752.  An electronic version of the
public docket is available through the Federal Docket Management System
(FDMS) at http://www.regulations.gov.  Use FDMS 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 Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2005-0066 and OMB Control Number 2060-0079 in any
correspondence.

Part B of the Supporting Statement

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



Table 1:  Annual Respondent Burden and Cost – NSPS for Petroleum Dry
Cleaners (40 CFR part 60, subpart JJJ) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting Requirements









   A.  Read instructions 	Included in 4E







	   B.  Required activities









       Initial performance test c, d	61	1	61	18	1,098	54.9	109.8
$101,936.12

       Repeat of performance test c, d, e	61	1	61	3.6	219.6	10.98	21.96
$20,387.23

   C.  Create information	See 3B







	   D.  Gather existing information	See 3B







	   E.   Write report









       Notification of construction/                     modification c,
f	2	1	2	18	36	1.8	3.6	$3,342.17

       Notification of actual startup c, f	2	1	2	18	36	1.8	3.6	$3,342.17

       Notification of initial performance           test c, f	2	1	2	18
36	1.8	3.6	$3,342.17

       Report of performance test	Included in 3B







	4.  Recordkeeping requirements









   A.  Read instructions 	Included in 3A







	   B.  Plan activities	Included in 4C







	   C.  Implement activities 	Included in 3B







	   D.  Develop record system	N/A





	 

   E.  Time to enter information









       Record of all performance tests c, g	1	1.2	1.2	18	21.6	1.08	2.16
$2,005.30

   F. Time for audits 	N/A







	Subtotals Labor Burden and cost  



	1,447.2	72.36	144.72	$134,355.16

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	1,664	$134,355



Assumptions:

    a  We have assumed that there are approximately 342 existing sources
that are currently subject to the rule with an estimated 18 new
additional sources per year over the         next three years.  The rule
stipulates that only new sources with one-time-only requirements are
subject to this subpart.  We therefore, concluded that the number of    
           respondents for this renewal ICR is 18 sources per year. 

    b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour     for Clerical labor.  These
rates are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, (Table 2. Civilian Workers, by occupational

    and industry group.(  The rates are from column 1, (Total
compensation.(  The rates have been increased by 110% to account for the
benefit packages available to those         employed by private
industry.

    c  This is a one-time only activity.

    d  We have assumed that it will take 61 hours for each respondent to
complete the required activity.

    e  We have assumed that 20 percent of respondents will have to
repeat initial performance tests due to failure.

    f  We have assumed that it will take 2 hours for respondents to
write report.

    g  We have assumed that it will take each respondent one hour to
enter information on all performance tests.

Table 2:  Average Annual EPA Burden - NSPS for Petroleum Dry Cleaners
(40 CFR part 60, subpart JJJ) 

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants per year  a	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

1.   Initial performance test 	16	1	16	18	288	14.4	28.8	$13,710.52

2    Repeat performance test c, d	16	1	16	3.6	57.6	2.88	5.76	$2,742.11

3.   Report review









        Notification of  construction/                  reconstruction c
2	1	2	18	36	1.8	3.6	$1,713.82

        Notification of actual startup c	1	1	1	18	18	0.9	1.8	$856.91

        Initial performance test c, e	7.5	1	7.5	18	135	6.75	13.5
$6,426.81

        Repeat performance test c, f	7.5	1	7.5	3.6	27	1.35	2.7	$1,285.36

Subtotals Labor Burden and cost



	561.6	28.08	56.16	$26,735.53

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	646	$26,736



Assumptions:

    a  We have assumed that there are approximately 342 existing sources
that are currently subject to the rule with an estimated 18 new
additional sources per year over the         next three years.  The rule
stipulates that only new sources with one-time-only requirements are
subject to this subpart.  We therefore, concluded that the number of    
           respondents for this renewal ICR is 18 sources per year. 

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $57.20 (GS-13, Step 5, $35.75 x 1.6),
Technical rate of $42.45 (GS-12, Step 1, $26.53 x 1.6), and Clerical
rate of $22.96 (GS-6, Step 3, $14.35 x 1.6).  These rates are from the
Office of Personnel Management (OPM) (2006 General Schedule( which
excludes locality rates of pay.

c  This is a one-time only activity.     

d  We have assumed that 20 percent of respondents will have to repeat
performance test

e  We have assumed that each respondent will take 7.5 hours to review
the initial performance test report.

f  We have assumed that 20 percent of respondents will have to review
the repeat performance test report.

 PAGE   8 

 PAGE   9 

