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. 
EPA has reviewed the standards under sections 112(d) (6) and 112(f) of
the Clean Air Act and, effective July 27, 2006, established additional
monitoring requirements beyond those promulgated on September 22, 1993. 
The additional requirements are to implement an enhanced leak detection
and repair (LDAR) program under which monthly leak detection using
handheld instruments is performed.  These standards apply to each dry
cleaning facility that uses PCE.  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 an enhanced LDAR 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 in general, are required 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 EPA regional office.

Approximately 28,000 area sources are currently subject to the standard.
 Of those, 8,000 are located in states (California, Maine, New York ,
Rhode Island) that already require an enhanced LDAR program similar to
the proposed NESHAP revisions.  Therefore, an existing 20,000 area
sources will be affected by the enhanced LDAR requirement.  It is
estimated that an additional 2,330 area sources per year will become
subject to the regulation in the next 3 years, but that the overall
number of facilities will remain constant due to retirement of old
existing facilities.  There are 12 existing major sources subject to the
regulation, and no new major sources are expected.  The estimated labor
cost of this Information Collection Request (ICR) is $149,772,225.

	

	The Office of Management and Budget (OMB) approved the currently active
ICR with the following Terms of Clearance (TOC):

When this ICR is resubmitted for renewal, EPA should revise the annual
hour and cost burden to incorporate the additional burden associated
with the July 27, 2006 final rule for 40 CFR part 63, subpart M ("Final
rule for leak detection"), which is currently recorded in a separate ICR
package.

EPA has addressed each item of concern in the TOC.  This ICR renewal
presents the additional reporting and recordkeeping requirements
associated with the required implementation of an enhanced LDAR program
at affected facilities.  The burden estimates for these additional
requirements were based on the ICR prepared to meet the Paperwork
Reduction Act requirements in the July 27, 2006 Federal Register notice
for this rulemaking.  

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost.  The burden to the “Federal Government”
is attributed entirely to work performed by Federal employees or
government contractors.  This burden may be found in Table 2: Average
Annual EPA Burden.

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/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 emissions from dry
cleaning facilities cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for this source category at 40
CFR part 63 subpart M.

2(b)  Practical Utility/Users of the Data

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

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.

Subsequent 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 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 (74 FR 32581) on July 8, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed, and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.  EPA
aimed to reduce the impact of the 2006 revisions on small entities. 
When developing the 2006 revisions, EPA took special steps to ensure
that the burden, including recordkeeping and reporting, imposed on small
entities were minimal.  The EPA conducted several meetings with industry
trade associations to discuss regulatory options and the corresponding
recordkeeping and reporting.  See section 5(c) of this supporting
statement for a description of small entity flexibility.

For this renewal, EPA accessed the Online Tracking Information System
(OTIS) to verify the estimate of total number of affected facilities. 
NAICS codes 812332, 812310, and 812320 were queried.

Also for this renewal, EPA contacted representatives of industry trade
organizations to request a voluntary opinion as to the accuracy of the
burden estimates associated with this ICR and whether there is any way
to reduce the burden.  Halogenated Solvents Industry Alliance, Inc.
(HSIA) stated: “HSIA has not identified any concerns regarding the
burden estimates in this ICR.” (Paul Dugard, telephone: 703-741-5780).
 Drycleaning & Laundry Institute (DLI, formerly International Fabricare
Institute) stated:

The Drycleaning & Laundry Institute generally agrees with EPA’s
assessment regarding the renewal of the Information Collection Request
(ICR) for the Perchloroethylene Dry Cleaning Facilities NESHAP.  While
it is very difficult to track the true burden for small area source
drycleaners, DLI generally agrees with EPA’s estimates.  The record
keeping and reporting requirements for [perchloroethylene] drycleaners
has been in existence since September 22, 1996.  The revised 2006 NESHAP
for [perchloroethylene] drycleaners did increase the burden for area
sources by including an enhanced leak detection program.  However, EPA
minimized the burden by allowing for the use halogenated leak detectors,
which can be readily purchased for approximately $250 per unit.

DLI’s primary concern with the ICR is that it does not take into
account state mandates that significantly increase the total burden on
the drycleaning industry, including time, effort and lack of financial
resources.  Ultimately, the additional time needed to comply with state
and local mandates significantly increase the burden to small business. 
(Jon Meijer, telephone: 301-622-1900.)

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

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

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.

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/NAICS Codes

Respondents are existing dry cleaning facilities that use PCE.  There
are 12 major source dry cleaning facilities (NAICS 812332), and no new
major source facilities are expected.  The EPA estimates that there are
28,000 existing area sources (NAICS Codes 812310, 812320, and 812332). 
An additional 2,330 new area sources per year will become subject to the
regulation in the next 3 years, but the overall number of facilities
will remain constant due to retirement of old existing facilities.

4(b)  Information Requested 

(i)  Data Items

In this ICR, all the data that is recorded 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 notifications and reports:

Notifications and Reports for 40 CFR part 63, subpart M

Initial notifications	63.324(a)

Initial report requirements	63.324(a)

Notification of Compliance Status	63.324(b) and 63.324(f)

Facility status change	63.324(c)

Exceedence of solvent consumption exemption level.	63.324(c)



A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart M

Monthly enhanced LDAR	63.322(o)

Date of repairs or purchase orders for repairs	63.324(d)(4)

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)



Electronic Reporting

Currently, 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.

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still 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.

Complete monthly LDAR using a handheld instrument.

Adjust existing ways to comply with any previously applicable
instructions and requirements.

Modify the existing recordkeeping system for the purpose of recording
results of monthly enhanced LDAR.

Enter information required to be recorded above.

Install, calibrate, maintain, and operate control device and LDAR
instruments.

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.



Currently, 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 exceedances of solvent
combustion levels, emissions reports, PCE solvent combustion levels, and
compliance status 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 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 AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
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 five years.

5(c)  Small Entity Flexibility

Affected facilities are primarily small entities (e.g., small
businesses).  According to the Federal Register Notice for the 2006
final rule (71 FR 42742), “… over 99 percent of commercial dry
cleaning firms are small.”  When developing the 2006 revisions, EPA
took special steps to ensure that the burden imposed on small entities
was reasonable.  The EPA conducted several meetings with industry trade
associations to discuss regulatory options and the corresponding
recordkeeping and reporting.  In addition, for the 1993 promulgated
standards, 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.  To complete
monthly enhanced LDAR, area source dry cleaning facilities may use a
halogenated leak detector, instead of a more costly PCE gas analyzer as
required for major sources.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost 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
1,531,851.  (Total Labor Hours from Table 1).  The recordkeeping hours
shown in Table 1 are 1,516,647.  The reporting requirement hours shown
in Table 1 are 15,204.  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 the following labor rates: 

Managerial	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2009, “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.  Dry cleaning facilities do not typically have
clerical labor, so these ICR labor costs assume that all reporting is
divided between managerial and technical staff.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

Dry cleaning facilities must use a handheld instrument to conduct leak
detection on a monthly basis.  Major sources must use a
perchloroethylene gas analyzer (photo ionization detector (PID), flame
ionization detector, or infrared analyzer) to perform leak checks
according to Method 21 on a monthly basis, while area sources may use a
halogenated hydrocarbon leak detector (HHD), which is less expensive
than the gas analyzer required for major sources.  Capital/startup costs
for new area sources include the purchase of the respective monitor and
operation and maintenance costs include the annualized cost of the
monitor.  There are no new major sources expected in the next three-year
ICR period.

The annual operation and maintenance costs are the ongoing costs to
maintain the monitors and other costs such as photocopying and postage. 
Annual Operation and Maintenance (O&M) costs for the monitors apply to
both new and existing sources because these costs are incurred each
year.  For the 8,000 area source facilities that are in states that
already require an enhanced LDAR program, this ICR does not estimate
capital and annual O&M costs for the monitors.  The annual costs for
postage are applied to new sources and sources with exceedances that
must submit reports.  All other existing sources must only keep records,
and, as such, an annual photocopying charge is assessed for all sources
keeping records.  These costs are summarized in the table below.

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

The capital/startup costs are one-time costs when a facility becomes
subject to the regulation.  Major source facilities would purchase a
perchloroethylene gas analyzer and area sources would purchase a
halogenated hydrocarbon leak detector.  The annual operation and
maintenance costs are the ongoing cost to maintain the monitors and
other costs such as photocopying and postage for submitting reports.

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

(A)

Item	(B)

Capital/ Startup Cost for One Respondent	(C)

Number of New Respondents 	(D)

Total Capital/Startup Cost,

(BxC)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M

(E X F)

PID	$3,300.00	0	0	$95.00	12	$1,140

HHD	$250.00	2,330	$582,500	$14.00	20,000	$280,000

Initial notification & compliance report 	-	-	-	$6.37	2,330	$14,842

Report exceed consumption cutoff	-	-	-	$6.00	117	$702

Photocopying 	-	-	-	$2.40	28,012	$67,229





	TOTAL	$353,913



The total capital/startup costs for this ICR are $582,500.  This is the
total of column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are
$353,913.  This is the total of column G. 

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $936,413.  These are recordkeeping 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
emissions, and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
estimated to be $243,856 (see Table 2).

This cost is based on the average hourly labor rate as follows:

	Managerial	$61.36 (GS-13, Step 5, $38.35 + 60%) 

	Technical	$45.52 (GS-12, Step 1, $28.45 + 60%)

	Clerical	$24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Average Annual EPA Burden.

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

Based on our research for this ICR, on average over the next three
years, approximately 28,012 existing respondents will be subject to the
standard.  It is estimated that an additional 2,330 respondents (area
sources) per year will become subject; but that the overall number of
facilities will remain constant due to the retirement of old existing
facilities.  The overall average number of respondents, as shown in the
table below, is 28,012 per year. 

The number of respondents is calculated using the following table that
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)

3-year Average	2,330	0	25,682	0	28,012



As shown above, the average Number of Respondents over the three-year
period of this ICR is 28,012

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

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	2,330	1	25,682	0	25,682	28,012

Compliance Method Report	1,631	1	N/A	0	N/A	1,631

Solvent Consumption Report	699	1	N/A	0	N/A	699

Report Exceed Consumption Cutoff	117	1	N/A	0	N/A	117





	TOTAL	30,459



The number of Total Annual Responses is 30,459.

The total annual labor costs are $149,772,225.  Details regarding these
estimates may be found below in Table 1. Annual Respondent Burden and
Cost.

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $936,413.  The cost calculations are detailed in Section
6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The average annual Agency cost over next three years is estimated to be
$243,875.  See Table 2. Annual Agency Burden and Cost.

6(e)  Bottom Line Burden Hours 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 below,
respectively, and summarized below.  

(i) Respondent Tally

The total annual labor hours are 1,531,851.  Details regarding these
estimates may be found in Table 1.  Annual Respondent Burden and Cost. 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 50 hours per
response.

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $936,413.  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 cost over next three years is estimated to be
$243,875.  See Table 2. Annual Agency Burden and Cost.

6(f)  Reasons for Change in Burden

In this ICR, the burden has increased somewhat due to a revision to the
standard.  However, this increase is more than offset by a decrease in
burden associated with a reduction in the number of respondents. 
Therefore, the overall burden has decreased for this renewal.

  

The revision to the standard requires   SEQ CHAPTER \h \r 1 owners and
operators of major and area sources to conduct enhanced LDAR and keep
monthly records of enhanced LDAR events.  Owners and operators would
incur the capital/startup cost of purchasing the monitors, plus ongoing
annual operation and maintenance costs of those instruments.  In the
previous ICR renewal, there were no capital/startup costs and operation
and maintenance (O&M) costs as required by the revision to the standard.
 Section 6(b)(iii), of this ICR includes   SEQ CHAPTER \h \r 1
capital/startup cost of new facilities purchasing monitoring equipment,
plus ongoing annual operation and maintenance costs of those instruments
for all affected facilities.  

In the previous ICR renewal, there was a larger estimated respondent
universe.  Based on more recent data presented in the 2006 rule update
ICR, there is a fewer number of affected facilities: 28,012 versus
32,000 as previously estimated.

There is also a reduction the capital/startup and O&M costs.  In the
previous ICR addressing a revision to the standard, a large number of
respondents were required to purchase monitoring equipment.  For this
renewal, only new respondents must purchase monitors.  Therefore, the
capital/startup and O&M costs are reduced.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 50 hours (rounded) per response. 
Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA 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-2009-0386.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Avenue, NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1752.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009–0386 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.

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

Burden Item	A

Hours per Occurrence	B

Number of occurrences per respondent per year	C

Hours per respondent per year 

(AxB)	D

Respondents per year	E

Management hours per yeara	F

Technical hours per yearb	G

Employee hours per year

(E+F)	H

Total cost per year ($)

1.  Applications	N/A	 	 	 	 

 	 

2.  Survey and Studies	N/A	 	 	 	 

 	 

3.  Reporting Requirements	 	 	 	 	 	 	 	 

A.  Read Instructions 	1	1	1	2,330c	2,330e	0.00	2,330.00	267,414.10

B.  Required activities	N/A	 	 	 	 	 	 	 

C.  Create Information	N/A	 	 	 	 	 	 	 

D.  Gather existing information	 	 	 	 	 	 	 	 

Initial report information	2	1	2	2,330c	233.00	4,427.00	4,660.00
458,772.34

Solvent consumption	1	1	1	2,330c	116.50	2,213.50	2,330.00	229,386.17

Compliance method report	1	1	1	1,631d	81.55	1,549.45	1,631.00	160,570.32

E.  Write Report	 	 	 	 	 	 	 	 

Initial notification report	1	1	1	2,330c	116.50	2,213.50	2,330.00
229,386.17

Compliance method report	1	1	1	1,631d	1,631e	0.00	1,631.00	187,189.87

Solvent consumption report 	0.25	1	0.25	699g	174.75e	0.00	174.75
20,056.06

Report-exceed consumption cutoff	1	1	1	117h	116.5e	0.00	117.00	13,428.09

Reporting Subtotal	 	 	 	 	 	 	15,204 (rounded)	1,566,203.12

4.  Recordkeeping Requirements	 	 	 	 	 	 	 	 

A.  Read Instructions	Included in 3A	 	 	 	 	 	 	 

B.  Plan activities	1	1	1	2,330c	0.00	2,330i	2,330.00	227,384.70

C.  Implement activities	 	 	 	 	 	 	 	 

Above consumption cutoff: 

Weekly LDAR	0.75	52j	39	19,608n	0.00	764,727.60i	764,727.60
74,629,766.48

Below consumption cutoff:

Bi-weekly LDAR	0.75	26k	19.5	8,404n	0.00	163,870.20i	163,870.20
15,992,092.82

Major: Monthly enhanced LDAR	1	48q	48	12o	28.80	547.20	576.00	56,706.62

Major: Weekly Carbon adsorber

 monitoring	0.25	208r	52	12o	31.20	592.80	624.00	61,432.18

Area: Monthly enhanced LDAR	0.75	12s	9	20,000p	9,000.00	171,000.00
180,000.00	17,720,820.00

D.  Develop record system	 	 	 	 	 	 	 	 

Solvent consumption	1	1	1	2,330c	0.00	2,330i	2,330.00	227,384.70

Enhanced LDAR	1	1	1	2,330c	0.00	2,330i	2,330.00	227,384.70

Monitoring records	1	1	1	1,631d	0.00	1,631i	1,631.00	159,169.29

Carbon adsorber monitoring records	1	1	1	 	 	 	0.00	0.00

E.  Time to enter information	 	 	 	 	 	 	 	 

Monthly records of solvent consumption 	0.25	12l	3	28,012m	7.88f
84,028.12	84,036.00	8,201,208.59

Above consumption cutoff: 

Records of weekly inspections	0.25	52j	13	19,608n	34.14f	254,875.06
254,909.20	24,877,175.35

Below consumption cutoff: 

Records of bi-weekly inspections	0.25	26k	6.5	8,404n	0.00	54,623.40i
54,623.40	5,330,697.61

Major: Enhanced LDAR	Included in 4C	 	 	 	 	 	 	 

Major: Carbon adsorber monitoring	Included in 4C	 	 	 	 	 	 	 

Area: Enhanced LDAR	Included in 4C	 	 	 	 	 	 	 

F.  Time to Train personnel	 	 	 	 	 	 	 	 

Leak detection	1	2t	2	2,330c	2,330u	2,330u	4,660.00	494,798.80

G.  Time for audits	N/A	 	 	 	 	 	 	 

Recordkeeping Subtotal	 	 	 	 	 	 	1,516,647 (rounded)
148,206,021.84

TOTAL ANNUAL BURDEN	 	 	 	 	 	 	1,531,851	149,772,225



Assumptions:

a. We have assumed that management hours are 5 percent of the employee
hours unless otherwise noted.  The management labor rate of $114.77 was
obtained from the United States Department of Labor, Bureau of Labor
Statistics, March 2009, ATable 2. Civilian Workers, by occupational and
industry group.@  The rate is from column 1, ATotal compensation.@  The
base rate of $54.65 was increased by 110 percent to account for the
benefit packages available to those employed by private industry.

b. We have assumed that technical hours are 95 percent of the employee
hours unless otherwise noted.  The technical labor rate of $97.59 was
obtained from the United States Department of Labor, Bureau of Labor
Statistics, March 2009, ATable 2. Civilian Workers, by occupational and
industry group.@  The rate is from column 1, ATotal compensation.@  The
base rate of $46.47 was increased by 110 percent to account for the
benefit packages available to those employed by private industry.

c. We have assumed that there are 28,000 existing cleaners and that
2,330 cleaners will leave the industry and will be replaced by 2,330 new
dry cleaners.









d. This is based on the estimate that 1,631 (70 percent) of the 2,330
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. This is based on the estimate that 699 (30 percent) of the 2,330 new
facilities will be below the cutoff and thus required to perform this
task.









h. It is estimated that 5 percent of new 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. We have assumed that facilities below cutoff performs leak detection
and repairs on a bi-weekly basis.









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









m. This is based on 28,000 facilities performing this task every year.









n. We have assumed that of 28,000 perchloroethylene dry cleaners 19,608
(70 percent) will be above the per consumption cutoff, which will
require that the cleaner conduct weekly leak detection and repair.  The
remaining 8,404 perchloroethylene dry cleaners are below the consumption
cutoff and are only required to conduct bi-weekly leak detection and
repair.

o. Approximately 28,000 existing area sources and 12 existing major
sources are subject to the NESHAP.









p. Approximately 8,000 existing area sources are located in states that
already require enhanced monitoring.









q. Major sources contain an average of four machines.  Task requires 1
hour times 4 machines/major source.









r. Major sources contain an average of four machines.  Task requires
0.25 hour times 4 machines/major source.









s. Area sources contain an average of one machine.  Task requires 0.75
hour times 1 machine/area source. 









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









u. 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                Year        	             Year      	  

									   $45.52                     $61.36 e	       $24.64 e   			

________________________________________________________________________
___________________________________________________

Report Review

  New Plant a

      Initial notification report				1	 2,330	     	2,330	      	116.5	 
    	      233       	      118,951.16

      Solvent consumption report b			1	    699	 	   699	        	 34.95	
        	      69.9		        35,685.35

      Report-exceed consumption cutoff c			1	    117	                  
117                        5.85	         	      11.7		          5,973.08

      Compliance method report d	      		1	 1,631	       	1,631	        
        81.55    	       	    163.1		        83,265.81   	

Total Burden and Cost						            5,493.55				    		      	     
$243,875.40

               

Assumptions:

a. These agency rates are from the Office of Personnel Management (OPM),
2009 General Schedule, which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.

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

c. Assume that 5 percent of new sources will have to report-exceed
consumption cutoff.

d. Area sources consuming between 140 to 200 gallons of
perchloroethylene per year: 70 percent of total number of new sources.

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

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