SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Halogenated Solvent Cleaning (40 CFR Part 60 Subpart T)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Halogenated Solvent Cleaning (40 CFR Part 63, Subpart T)
(Renewal), 

EPA ICR Number 1652.07, OMB Control Number 2060-0273

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Halogenated Solvent Cleaning was promulgated on December 2, 1994 (59
FR 61805), and amended to the final standards published June 5, 1995 (60
FR 29485), and December 11, 1998 (63 FR 68400).  These standards apply
to the following facilities in 40 CFR subpart T, batch vapor or in-line
cleaning machines, and batch cold cleaning machines.  This information
is being collected to assure compliance with 40 CFR part 63, subpart T.

Respondents are owners or operators of solvent cleaning machines using
any solvent containing methylene chloride (MC), perchloroethylene (PCE),
1,1,1-trichloroethane (TCA), trichloroethylene (TCE), carbon
tetrachloride (CT), chloroform (C), or any combination of these
halogenated solvents in a concentration greater than 5 percent
by-weight.  This includes batch vapor, in-line vapor, in-line cold, and
batch cold solvent cleaning machines.

Owners or operators of a batch vapor or in-line cleaning machine subject
to this regulation must choose between an equipment/work practice
standard and a solvent emission limit standard in order to comply.  All
respondents must submit an initial report for applicability
determination and an initial statement of compliance that delineates the
compliance alternative chosen for each solvent cleaning machine, and how
the requirements are being met.  To meet the equipment standards,
respondents must install and monitor specific control device
combinations listed in the regulation, or they must monitor the idling
emission control parameters that they have established.  If the
respondents choose to install a control combination listed in the
regulation, they must maintain quarterly, monthly, or weekly control
device monitoring records based on the type of control device installed
as specified in the regulation, and installation dates of each cleaning
machine and its control devices.  The frequency of monitoring and
recordkeeping of certain control device parameters is reduced if
parameter compliance is consistent and increased when a parameter is
exceeded.

Respondents choosing the idling emission option must perform an idling
emission test on their solvent cleaning machines and monitor idling
emission control parameters.  Emission control parameters to be
maintained and monitored must be established during the test.  In most
cases, this test will be completed by the manufacturer of the solvent
cleaning machine.  All respondents using idling emission parameter
monitoring to demonstrate compliance must keep records of the monitoring
results, test results (if an idling emission test was required), and
installation dates or certification of each cleaning machine and its
control devices.

If the respondents choose the overall solvent emissions limit option,
they must: 1) maintain a log of the dates and amounts of solvent
additions and deletions, and the solvent composition of wastes removed;
2) calculate monthly emissions and rolling 3-month average emissions;
and 3) maintain the calculation sheets showing how the emissions were
determined.  These records must be maintained for five years for each
solvent cleaning machine.

Owners or operators of all batch vapor or in-line cleaning machines must
submit to EPA: 1) an annual report of monitoring or solvent emission
results; 2) a biannual exceedance report; and 3) a quarterly report if
exceedances occur.  The circumstances under which an exceedance of a
monitored control parameter occurs under the equipment standard are
outlined in the regulation.  Some exceedances occur when a monitored
parameter does not meet specified requirements within 15 days of the
initial occurrence of an exceedance of a specified requirement.  Other
exceedances occur immediately upon the exceedance of a specified
requirement.  An exceedance of the overall solvent emissions limit
occurs at the time when the emission limit is not met.

Owners or operators of batch vapor or in-line cleaning machines must
maintain all control device monitoring or solvent consumption records
on-site for five years.  Owners or operators of batch vapor and in-line
cleaning machines must retain records of installation dates of each
machine and related equipment, owner’s manuals, and any test reports
for the life of the machine.  For existing cleaning machines for which
an operator or owner no longer has an owner's manual or any installation
records, an owner or operator must provide and maintain certification
that the machine and/or its controls were installed prior to the
proposal date.

Owners or operators of batch cold cleaning machines have no
recordkeeping requirements.  Owners or operators of a batch cold
cleaning machine must comply with an equipment standard and work
practices.  All respondents must submit an initial notification report
and an initial statement of compliance.

Records and reports required by the NESHAP for halogenated solvent
cleaners are necessary to enable EPA to identify sources subject to the
standards and to ensure that the standards are being achieved.  Records
and reports must be maintained at the facility and/or submitted to EPA. 
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 1,431 sources are currently subject to the regulation, and
no additional sources are expected to become subject to the standard in
the next three years.  The respondent labor and operation and
maintenance (O&M) costs of this Information Collection Request (ICR)
will be $4,992,917 (rounded).

The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (ICR) without any “Terms of
Clearance.”

The burden to the “Affected Public” may be found below in Table
1(a): Annual Industry Burden - NESHAP for Halogenated Solvent Cleaning
(40 CFR Part 63, Subpart T) (Renewal).  The burden to the “Federal
government” is attributed entirely to work performed by federal
employees or government contractors; this burden may be found below in
both Table 1(b): Annual EPA Burden - NESHAP for Halogenated Solvent
Cleaning (40 CFR Part 63, Subpart T) (Renewal) for Batch Cold Cleaning
Machines and Table 2: Annual EPA Burden - NESHAP for Halogenated Solvent
Cleaning (40 CFR Part 63, Subpart T) (Renewal).

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 (HAPs). 
These standards are applicable to new or existing sources of HAPs 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, HAP emissions from halogenated solvent
cleaning machines either cause or contribute 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 T.

2(b)  Practical Utility/Users of the Data

The control of emissions of pollutant from halogenated solvent cleaning
machines requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of HAPs from halogenated solvent cleaners are the result of
operation of the affected facilities.  The subject standard is achieved
by the reduction of HAPs emission using control technology and leak
detection and repairs procedures.

The notifications required in the applicable regulations 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 regulations are being met.  The semiannual
reports are used for problem identification, as a check on source
operation and maintenance, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting
requirement described in this ICR is used by the Agency to ensure that
facilities affected by the NESHAP continue to operate the control
equipment in compliance with the regulation.  Adequate monitoring,
recordkeeping, and reporting are necessary to ensure compliance with the
applicable regulations, 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.

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under (40 CFR
part 63, subpart T).

3(a)  Non-duplication

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 (74 FR 38006) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

In estimating the affected number of sources and the growth rate of
halogenated solvent cleaning facilities subject to this standard during
the previous renewal, EPA contacted Mr. Alton D. Romig, Environmental
Consultant, at (610) 865-2284.  During the previous renewal, we
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 Online Tracking
Information System (OTIS) which is the primary source of information
regarding the number of existing sources.  OTIS data was used in
conjunction with industry consultation to verify the number of sources
and the industry growth rate. 

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

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 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

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 (CBI) (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 Codes

The respondents to the recordkeeping and reporting requirements are
owners and operators of halogenated solvent cleaning machines.  The
United States Standard Industrial Classification (SIC) codes for the
respondents affected by the standard are listed below.  These correspond
to the North American Industry Classification System (NAICS) codes
listed below for source description. 

Halogenated Solvent Cleaning (40 CFR part 63, subpart T)	SIC Codes	NAICS
Codes

Lumber and Wood Products, Except Furniture



Sawmills and wood preservation	2421	3211

Veneer, plywood, and engineered wood product manufacturing	2435	3212

Other wood product manufacturing	2499	3219

Furniture and Fixtures



Household and institutional furniture and kitchen cabinet manufacturing
2514	3371

Office furniture (including fixtures) manufacturing	2522	3372

Other furniture related product manufacturing	2599	3379

Electronic and Other Electrical Equipment and Components, Except
Computer Equipment



Electric lighting equipment manufacturing	3648	3351

Household appliance manufacturing	3639	3352

Electrical equipment manufacturing	3699	3353

Other electrical equipment and component manufacturing	3699	3359

Transportation Equipment



Motor vehicle manufacturing	3714	3361

Motor vehicle body and trailer manufacturing	3711	3362

Aerospace product and parts manufacturing	3761	3364

Ship and boat building	3731	3366

Railroad rolling stock manufacturing	3743	3365

Other miscellaneous manufacturing	3999	3399

Food and Kindred Products



Animal food manufacturing	2048	3111

Grain and oilseed milling	2076	3112

Sugar and confectionery product manufacturing	2061	3113

Fruit and vegetable preserving and specialty food manufacturing	2034
3114

Dairy product manufacturing	2026	3115

Seafood product preparation and packaging	2092	3117

Bakeries and tortilla manufacturing	2051	3118

Other food manufacturing	2098	3119

Primary Metal Industries



Iron and steel mills and ferroalloy manufacturing	3312	3311

Steel product manufacturing from purchased steel	3325	3312

Alumina and aluminum production and processing	3365	3313

Nonferrous metal (except aluminum) production and processing	3396	3314

Foundries	3325	3315

Industrial and Commercial Machinery and Computer Equipment



Agriculture, construction and mining machinery manufacturing	3531	3331

Industrial machinery manufacturing	3569	3332

Commercial and service industry machinery manufacturing	3567	3333

Ventilation, heating, air-conditioning, and commercial refrigeration
equipment manufacturing	3564	3334

Metalworking machinery manufacturing	3545	3335

Engine, turbine, and power transmission equipment manufacturing	3511
3336

Other general purpose machinery manufacturing	3559	3339

Measuring, Analyzing, and Controlling Instruments; Photographic, Medical
and Optical Goods; Watches and Clocks



Navigational, measuring, electro-medical, and control instruments	3812
3345

Manufacturing and reproducing magnetic and optical media	3695	3346



4(b)  Information Requested

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

(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 Halogenated
Solvent Cleaning/Halogenated Hazardous Air Pollutants (40 CFR part 63,
subpart T).

A source must make the following reports:

Reports for 40 CFR part 63, subpart T

Initial notification	63.09(b), 63.468(a)

Construction/reconstruction	63.05(d), 63.468(b)

Initial compliance report	63.09(h), 63.468(c)

Initial performance test results 	63.10(d), 63.468(d)

Monitoring of control equipment	63.09(g), 63.468(d)(4)

Annual report on training operators and solvent emission	63.468(f), (g)

Semiannual and quarterly exceedance report	63.10(b), 63.468(h-i) 



A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart T

Maintain owner’s manual or written maintenance and operating
procedures.	63.10(b), 63.467(a), (a)(1)

Records of parametric monitoring data, system maintenance and
calibration.	63.467(b)

Maintain records on method used to determine the cleaning capacity.
63.467(d)

Maintain records of initial performance test, which includes the idling
emission rate and values of the monitoring parameters measured.
63.467(a)(4)

Records of halogenated HAP solvent for each solvent used in solvent
cleaning machine.	63.467(a)(5)

Record of applicability.	63.10(b)(3)

All reports and notifications.	63.10(b)



Electronic Reporting

Some state 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.  The estimated amount of
electronic reporting is 10 percent.

(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Install, calibrate, maintain, halogenated HAP solvents cleaning
machines.

Perform initial performance test, Reference Method 18 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 the 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., halogenated HAP solvents. 
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.

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 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.  The semiannual reports are used for problem
identification, as a check on source operation and maintenance, and for
compliance determinations.

Information contained in the reports is entered into 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
and annual emission inventory data for more than 100,000 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
or operator for five years.

5(c)  Small Entity Flexibility

According to the Final Rule (72 FR 25138): “The final rule is expected
to affect 125 ultimate parent entities that will be regulated as major
sources.  Forty of the parent entities, or approximately one-third, are
defined as small according to the SBA small business size standards.” 
Therefore, this ICR assumes that one-third of the affected facilities
are small entities (e.g., small businesses).  However, the impact on
small entities was taken into consideration during the development of
the regulation.  Due to technical considerations involving the process
operations and the type 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.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Tables 1(a), 1(b), and 1(c): Annual
Industry Burden for NESHAP for Halogenated Solvent Cleaners (40 CFR part
63, subpart T) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1(a), Table 1(b), and Table 1(c) document 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 41,035
(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 the following labor rates: 

Managerial	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 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.

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

The types of industry cost associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time cost when a facility
becomes subject to the regulation.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitors and other costs
such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/ Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Temperature monitoring device	$2,700 1	0	0	$860	1,180 2	$1,014,800

1 The reason for zero capital/startup cost is due to a ruling that was
promulgated in December 1994, stating that the existing sources were not
required to comply with the standard after December 1997.

2 The O&M only applies to the 1,180 batch vapor or in-line solvent
cleaning machines, not the 251 batch cold solvent cleaners.

The total capital/startup costs 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
$1,015,000 (rounded).  This is the total of column G.

The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
estimated to be $1,015,000 (rounded).

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 $325,437 (rounded) [see Table 2 in Section 6(e)].  Costs
in the proposed ICR are based on the following labor breakdown:

Managerial	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 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.

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

Approximately 1,431 sources are currently subject to the regulation, and
it is estimated that no additional sources per year will become subject
to the regulation in the next three years.

Respondent Universe and Number of Responses Per Year

Regulation Citation	(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

Batch vapor or in-line cleaning machines (w/o exceedance)	0	0	1,062	2	

0	2,124



Batch vapor or in-line cleaning machines (with exceedance)	0	0	118	4	0	
472

Batch cold cleaning machines	0	0	251	0	251	251



The number of total respondents is 1,431.  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 2,847.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table above.

The total annual labor costs are $3,977,917 (rounded).  Details
regarding these estimates may be found below in Table 1(c). Annual
Respondent Burden and Cost, NESHAP for Halogenated Solvent
Cleaning/Halogenated Hazardous Air Pollutants (40 CFR part 63, subpart
T) (Renewal).

 

Note that the total annual capital and O&M costs to the regulated entity
are $1,015,000 (rounded).  These costs are detailed in Section
6(b)(iii), Capital/Startup vs. Operation 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 14
hours per response.

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  This is due to two considerations: 1) the regulations
have not changed over the past three years and are not anticipated to
change over the next three years; and 2) the growth rate for the
respondents is very low, negative or non-existent.  Therefore, the labor
hours in the previous ICR reflect the current burden to the respondents
and are reiterated in this ICR.

There is an increase in both respondent and Agency costs resulting from
labor rate increases from 2003 to 2009.  This ICR uses 2009 labor rates
because burden and cost calculations in Tables 1 and 2 of this ICR were
expanded to include managerial and clerical labor rates, and the
previous ICR only provided a technical labor rate for 2003.  Therefore,
this ICR is updated to present the most recent available labor rates for
each of the three labor categories.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 14 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 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-2009-0531, which is available for online
viewing at http:// 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 3334, 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) 566-1752.  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 Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2009-0531 and OMB Control
Number 2060-0273 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(a):  Annual Industry Burden - NESHAP for Halogenated Solvent
Cleaning (40 CFR Part 63, Subpart T) (Renewal) 



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

	Hours per Occurrence	Occurrences/Respondent/ Year	Hours/
Respondent/Year	Respondents per Year	Total Hours per Year

(E=CxD)	Managerial Hours/ Yearb	Technical Hours/ Yearb	Clerical Hours/
Yearb	Cost per yeara

Burden Item  	 	 	 	 	 	 	 	 	 











	1.  APPLICATIONS

N/A







	2.  SURVEY AND STUDIES

N/A







	3.  REPORTING REQUIREMENTS









	  A.  Read Instructions c & d	2	1	2	0	0	0	0	0	$0 

  B.  Gather existing information

Included in 3C







	  C.  Write Report









	          Initial notification report d	1	1	1	0	0	0	0	0	$0 

          Initial compliance report d                	4	1	4	0	0	0	0	0	$0


         Performance test results d & e	30	1	30	0	0	0	0	0	$0 

         Annual compliance report d	1.5	1	1.5	1,180	1,770	153.91	1539.13
76.96	$171,582 

Report with exceedance g &h	1	3	3	118	354	30.78	307.83	15.39	$34,316 

     Report with no exceedance g & i	0.5	1	0.5	1,062	531	46.17	461.74
23.09	$51,475 

Subtotal Reporting



	2,655



$257,373 

4.  RECORDKEEPING REQUIREMENTS









	  A.  Read instructions

Included in 3A







	  B.  Plan activities j	1	1	1	393	393	34.17	341.74	17.09	$38,097 

  C.  Implement activities









	     Performance test e & f	50	1	50	39	1,950	169.57	1695.65	84.78
$189,031 

          Control device monitoring k & l	1.64	12	19.68	590	11,611.2
1009.67	10096.70	504.83	$1,125,580 

          Solvent consumption log m &n       	1.5	12	18	590	10,620
923.48	9234.78	461.74	$1,029,494 

  D.  Record Data

	   







          Control device monitoring l & o	1.2	12	14.4	590	8,496	738.78
7387.83	369.39	$823,595 

          Solvent emission calculation	0.75	12	9	590	5,310	461.74
4617.39	230.87	$514,747 

  E.  Time to train personnel p









	Subtotal Recordkeeping



	38,380



$3,720,543

TOTAL ANNUAL BURDEN (rounded)



	41,035



$3,977,917 

Assumptions:





















a. We assume a technical labor rate of $97.59, managerial rate $114.77,
and clerical rate of $48.26 from the United States Department of Labor,



	 Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers,
by occupational and industry group.”







Workers by Occupational and Industry Group.  The rates are from column
1: Total compensation.  The wage rate obtained from the table has been
increased by 110 percent to 

	account for the benefit packages available to those employed by private
industry.







	b. This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.





	c. It is assumed that it will take 2 hours to read instructions.









d. We assume that there will be no new sources.









e. It is estimated that idling emission or dwell test reports require 70
technical hours and 10 managerial hours or (87.5%@$97.59/hr + 12.5% @
$114.77 hr = $106.18/hr average hourly rate).  The hours were then
divided between the test itself (50 hours) and the test report (30
hours).

f. We assume that 1,180 facilities are required to complete the annual
compliance report.







	g. The burden of one quarterly and one semiannual exceedance report was
included in the burden estimate for the annual report.





	h. We assume that 10 percent of 1,180 facilities are in exceedance at
least one time per year (quarterly reporting).







i. We assume that 90 percent of 1,180 facilities are not in exceedance
(semiannual reporting).







	j. One-time cost was based on 1,180 facilities averaged over three
years (1,180/3years) for a total of 393 facilities.







k. Actual monitoring is conducted weekly, monthly or quarterly for
specific control devices.  The estimated time was based on the typical
control devices expected to be installed.

	l. We assume that 50 percent of the facilities will choose the standard
equipment and will be required to conduct control device monitoring.  





	m. We assume that 50 percent of the facilities will choose to do
solvent consumption monitoring.







	n. This activity is assumed to be performed by a manager.









o. We assume that it would take 1.2 hours per facility to record data.







	p. We assume that no special training requirements are required.







	

TABLE 1(b): Average Annual  EPA Burden - NESHAP for Halogenated Solvent
Cleaning (40 CFR Part 63, Subpart T) For Batch Cold Cleaning Machines
(Renewal)

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

	Hours per Occurrences	Occurrences Respondent/ Year	Hours Respondent/
Year	Respondents per Year	Hours per year

(E=CxD)	Managerial Hours/Yearb	Technical Hours/Yearb	Clerical
Hours/Yearb	Cost per Yeara

Burden Items                                 	 	 	 	 	 	 	 	 	 

1.  APPLICATIONS

N/A







	2.  SURVEYS AND STUDIES

N/A







	3.  REPORTING REQUIREMENTS









	     A.  Read Instructions b & c	0.5	1	0.5	0	0	0	0	0	$0 

     B.  Gather existing information	     	Included in 3C







	     C.  Write Report b & d









	           Initial notification report	0.25	1	0.25	0	0	0	0	0	$0 

           Initial compliance report  	0.25	1	0.25	0	0	0	0	0	$0 

Subtotal Reporting



	0



$0 

 4. RECORDKEEPING REQUIREMENTS

N/A







	Subtotal Recordkeeping

N/A







	SUBTOTAL ANNUAL HOUR



	0



$0 

 	 	 	 	 	 	 	 	 	 

Assumptions:





















a. The cost at technical labor rate of $97.59, managerial rate $114.77,
and clerical rate of $48.26 from the United States Department of Labor,
Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by
Occupational and Industry group.”

b. This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.





c. Estimated number of new facilities with batch cold cleaning machines
is zero.







	d. It is assumed that it will take 0.5 hours to read instructions.









e. It is assumed that it will take 0.25 hours to write report.













TABLE 1 (c):  Aggregate Burden for Burden Identified on Table 1(a) and
1(b) 

Activity	

       Person hours 

       per respondent 

       per year	

Respondents

per year	

Total Hours

per year	

Total Cost

per year



Ba  Batch Vapor and In-line Cleaning Machines (subtotal)	

154	

1,180	

41,035	

$3,977,917



Ba  Batch Cold Cleaning Machines (subtotal)	

    1	

0	

0	

0



T    TOTAL ANNUAL COST BURDEN (rounded)	

155	

1,180	

41,035	

$3,977,917



TABLE 2:  Average Annual  EPA Burden - NESHAP for Halogenated Solvent
Cleaning (40 CFR Part 63, Subpart T) (Renewal)

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

	EPA hrs Occurrence	Occurrences Per Year	Technical hrs/yeara  

(C=AxB)	Management hrs/yeara 

(D=Cx0.05)	Clerical hrs/yeara 

(E=Cx0.1)	EPA Cost/yeara

Burden Items	 	 	 	 	 	 

Report Activity







1.  Batch vapor and in-line cleaning machine







     A  Initial notification report b	1	0	0	0	0	$0 

     B  Initial compliance report b	2	0	0	0	0	$0 

     C  Performance test results c & d	8	0	0	0	0	$0 

     D  Annual compliance report e	2	1,180	2,360	118	236	$255,245 

     E  Report with exceedance f & g	1	118	118	5.9	11.8	$12,762 

     F  Report with no exceedance f & h	0.5	1,062	531	26.55	53.1	$57,430


2.  Batch Cold Cleaning Machines          







     A  Initial notification/compliance reporti	0.25	0	0	0	0	$0 

TOTAL ANNUAL BURDEN j

	3,009	150.45	300.9	$325,437 

       







Assumptions:















a. Costs are based on the following hourly rates: Technical at $97.59,
Management at $114.77, and Clerical at $48.26 from the United States
Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2.
Civilian Workers, by occupational and industry group.”  Management
person-hours and Clerical person-hours are assumed to be 5 percent, and
10 percent of technical person-hours respectively.

b. It is assumed that a one-time cost was based on 393 facilities per
year.





c. We assume that it will take 8 hours to review performance test
results.





d. We assume that 50 percent of the facilities will choose the standard
equipment; 20 percent of those will conduct one-time idling tests.

e. All facilities are expected to submit annual compliance reports
summarizing either solvent consumption data or monitoring results for
each cleaning machine.

f. The burden of one quarterly and one semiannual exceedance report was
included in the burden estimate for the annual report.

g. We assume that 10 percent of 1,180 facilities are in exceedance at
least one time per year. 



	h. We assume that 90 percent of 1,180 facilities are not in exceedance.
 





i. It is assumed that there are 251 facilities with batch cold cleaning
machines.



	j. To get total annual burden hours, add the totals from lines C, D,
and E.

	

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