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),

EPA ICR Number 1415.11

, OMB Control Number 2060

- 0234

.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for

Perchloroethylene Dry Cleaning Facilities were proposed on December 9, 1991, promulgated on

September 22, 1993, and last

- amended on July 11, 2008

. The EPA has reviewed the se standard s

under sections 112(d) (6) and 112(f) o f 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 wh ich monthly leak detection using handheld instruments is performed.

These regulations apply to existing and new dry cleaning facilities that use perchloroethylene

(PCE). New facilities include those that commenced constru ction or reconstruction after the date

of proposal. This information is being collected to assure compliance with 40 CFR Part 63

, Subpart M

.

In general, all NESHAP standards require initial notification report s, performance tests,

and periodic reports by the owners/operators of the affected facilities. They 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 i s

inoperative. These notifications, reports, and records are essential in determining compliance,

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file containing

th ese documents , and retain the file for at least five years following the generation date of such

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 U

. S

. Environmental Protection Agency (EPA) regional office.

The “ burden ” to the “Affected Public” may be found below in Table 1: Annual

Respondent Burden and Cost

– NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR

Part 63, Subpart M) (Renewal)

. T he Federal Government ’s “ burden ” is attributed entirely to

work performed by either F ederal employees or government contractors and may be found below

in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Perch loroethylene Dry

Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.2

Based on our consultations with industry representatives, there is an average of one

affected facilit y at each plant site and that each plant site has only one respondent (i.e., the

owner/operator of the plant site).

Approximately 28,0 12 sources are currently subject to the se standard s , of which 12 are

major sources and the remainder are area sources. Of the 28,000 area sources, 8,000 are located

in states (California, Maine, Ne w York, Rhode Island) that already require an enhanced LDAR

program; therefore, the monthly LDAR requirement of the NESHAP will affect 20,000 existing

area sources. No new major sources are expected over the next three years. We estimate that

2,330 additional area sources per year will become subject to the regulation in the next three

years, but that the overall number of facilities will remain constant due to the retirement of old

existing facilities.

The Office of Manageme nt and Budget ( OMB ) approved the currently active ICR

without any “ Terms of Clearance ”

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish

standards of performance for each category or subcategory of major sources and area sources of

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous

air pollutants and shall require the maximum degree of emission reduction. In addition, section

114(a) states that the Administrator may require any owner/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 re cords 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, PCE emissions from perchloroethylene dry cleaning

f

acilities either cause or contribute to air pollution that may reasonably be anticipated to

endanger public health and/ 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 Data3

The recordkeeping and reporting requirements in the se standard s ensure compliance with

the applicable regulations which were promulgated in accordance with the Clean Air Act. The

collected information is also 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 s . Continuous emission monitors are used to

ensure compliance with the se same standard s 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

au thority may then inspect the source to check if the pollution control devices are properly

installed and operated

, leaks are being detected and repaired

, and the standard s are being met.

The performance test may also be observed.

The required reports are used to determine periods of excess emissions, identify problems

at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping an d reporting are required under 40 CFR Part 63, Subpart

M

.

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 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 require d by the Federal standards. Therefore, duplication does

not exist.

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 ( 80 FR 32116 ) on June 5, 2015

. No comments were received on the

burden published in the Federal Register

.

3(c) Consultations

T he Agency’s industry experts have been consulted, and the Agency’s internal data

sources and projections of industry growth over the next three years have been considered. The4

primary source of information as reported by industry, in compliance with the recordkeeping and

reporting provisions in the standard, is the Integrated Compliance Information System (ICIS).

ICIS is EPA’s database for the col lection, maintenance, and retrieval of compliance data for

industrial and government

- owned facilities. The growth rate for the industry is based on our

consultations with the Agency’s internal industry experts.

Industry trade associations and other intere sted parties were provided an opportunity to

comment on the burden associated with the standard as it was being developed. In developing

this ICR, we contacted both the Halogenated Solvents Industry Alliance, Inc

., at (703) 741

- 5780 ;

and the Drycleaning & Laundry Institute

, at (301) 622

- 1900.

It is our policy to respond after a thorough review of comments received since the last

ICR renewal

, as well as those submitted in response to the first Federal Register notice. In this

case, no comments were received.

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 techn iques 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

poss ibility of detecting violations would be less likely.

3(e) General Guidelines

T hese reporting or recordkeeping requirements do not violate any of the regulations

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents 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. T he retention of records for five years allow s EPA to establish the compliance history of a

source

, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has found that the most flagrant violators have violations extending beyond five

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or

nonexistence of essential record s

.

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 Informatio n (CBI) (see 40 CFR 2; 41 FR 36902,5

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

T he reporting or recordkeeping requirements in the standard do not i nclude sensitive

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are perchloroethylene

dry cleaning f acilities

. The United States Standard Industrial Classification ( SIC ) code for the

respondents affected by the standards and the corresponding North American Industry

Classification System (NAICS ) codes are listed in the table below

.

Standard ( 40 CFR P art 63, S ubpart M ) SIC Codes NAICS Codes

Coin

- Operated Laundries and Drycleaners 7215 812310

Drycleaning and Laundry Services

(except Coin

- Operated) 7211, 7212, 7216, 7219,

7251, and 7389 812320

Industrial Launderers 7218 812332

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required by the NESHAP for

Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M)

.

A source must make the following reports:

Notification s

Initial notifications 63.324(a)

Initial report requirements 63.324(a)

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

Facility status change 63.324(c)

Exceedance of solvent consumption exemption level 63.324(c)

A source must keep the following records:6

Recordkeeping

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

Some of the r espondents 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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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 informat ion 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.7

Respondent Activities

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 info rmation.

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.

5. The Information Collected: Agency Activities, Collection Methodology, and Information

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis,

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO)

and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to

determine whether the pollution control devices are p roperly installed and operated. Performance

test reports are used by the Agency to discern a source ’ s initial capability to comp ly with the

emission standard s , and note the op erating 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 sou rce operation and maintenance, and for compliance8

determinations.

Information contained in the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. EPA uses ICIS 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

The majority of respondents are 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 th e 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 numb er 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 fu rther 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

requi red for major sources.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Perchloroethylene

Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.

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 in formation collection are mandatory.9

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 ann ual burden to industry over the next three years from these recordkeeping

and reporting requirement s is estimated to be 1, 590 ,000 hours ( Total Labor Hours from Table 1

below ). T hese hours are based on Agency studies and background documen ts from the

develo pment 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 $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June

2014

, “ 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 type of industry costs associated with the information collection activities in the

subject standard 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 costs 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

Dry cleaning facilities must use a handheld instrument to conduct leak detection on a

monthly basis. Major sources must use a PCE 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 o f the respective monitor. There are 2,330 new area

sources and no new major sources expected in the next three

- year ICR period.10

Annual 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 those 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 exceedance s that must submit reports. All other existing sources must only keep

records, and, as such, an annual photocopying charge is assessed for all those sources keeping

records. These costs are summarized in the table presented below :

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)

PID $3,300 0 0 $95 12 $1,140

HHD $250 2,330 $582,500 $14 20,000 $280,000

Initial

notification &

compliance

report - - - $6.37 2,330 $14,842

Report exceed

consumption

cutoff - - - $6 117 $702

Photocopying

- - - $2.4 0 28,012 $67,229

Total $583,000 $364,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $ 583,000

. This is the total o f column D in

the above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 364,000

. 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 $ 947,000

.

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 i ncludes activities such as the

examination of records maint ained 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

$ 250,000

.11

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

These rates are from the Office of Personnel Management (OPM)

, 20 1 5 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 and Cost

– NESHAP for

Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.

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

Based on our r esearch for this ICR, on average over the next three years, approximately

28,012 existing respondents will be subject to the se standard s

. It is estimated that an additional

2,330 area sources per year will become subject to these same standards

. The overall average

number of responden ts, 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 1 (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 No Longer

Subject 2 (E)

Number of

Respondents

(E=A+B+C

- D)

1 2,330 28,012 0 2,330 28,012

2 2,330 28,012 0 2,330 28,012

3 2,330 28,012 0 2,330 28,012

Average 28,012

1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard

existing respondents submit initial notifications.

2 We assume that the overall number of facilities will remain constant due to retirement of old existing facilities.

C olumn D is subtracted to avoid double

- counting respondents

. 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:12

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

Write Initial Notification

Report 2,330 1 25,682 28,012

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

Solvent Consumption Report 699 1 N/A 699

Report Exceed Consumption

Cutoff 117 1 N/A 117

Total 30,459

The number of Total Annual Responses is 30,459

.

The total annual labor costs are $ 166 ,000,000

. Details regarding these estimates may be

found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Perchloroethylene

Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.

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, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 1, 590 ,000 hours

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for

Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.

In general, w e assume that burdens for manageri al tasks take 5% of the time required for

technical tasks because the typical tasks for managers are to review and approve reports. Clerical

burdens are assumed to take 10% of the time required for technical tasks because the typical

duties of clerical sta ff are to proofread the reports, make copies and maintain records. However,

the burden for each worker category may vary depending on the task. See Table 1 below for

additional details.

Furthermore, the annual public reporting and recordkeeping burden for this collection of

information is estimated to average 52 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $947,000

. The13

cost calculations a re 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 next three years is estimated to be

5,490 labor hours at a cost of $250,000

. See below in Table 2: Average Annual EPA Burden and

Cost

– NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M)

(Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical task s for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons f or Change in Burden

There is an adjustment increase in respondent labor hours in this ICR from the most

recently approved ICR. This is due to assuming all existing sources will have to re

- familiarize

with the regulatory requirements each year. Additionall y, there is an increase in the total capital

and O&M cost due to the rounding of all calculated values to three significant digits.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 52 hours per response. Burden means the total time, effort, or financial

resources expended by persons to generate, maintain, retain, or disclos e 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 m aintaining 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; co mplete 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 responden t burden, including the

use of automated collection techniques, EPA has established a public docket for this ICR under

Docket ID Number EPA

- HQ

- OECA

- 201 2

- 0659

. An electronic version of the public docket is

available at http://www.regulations.gov/

, which may be used to obtain a copy of the draft14

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 ar e 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 Do cket Center (EPA/DC), WJC West,

Room 3334 , 1301 Constitution Ave., 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 i s (202) 566

- 17 52

. 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

- 20 12

- 0659 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.15

Table 1: Annual Respondent Burden and Cost

– NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63,

Subpart M) (Renewal)

Burden Item A B C D E F G H

Hours per

occurrence Occurrences

per

respondent

per year Hours per

respondent

per year Respondents

per year a Technical

hours per

year Management

hours per

year Clerical

hours

per year Total cost per

year ($) b

(AxB) (CxD) * (Ex0.05) * (Ex0.10) *

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Familiarization with the regulatory

r equirements c 1 1 1 28,012 0 28,012 0 $3,639,599.16

B. Required activities N/A

C. Create Information N/A

D. Gather existing information

Initial report information 2 1 2 2,330 4,660 233 466 $538,908.03

Solvent consumption 1 1 1 2,330 2,330 116.5 233 $269,454.02

Compliance method report d 1 1 1 1,631 1,631 81.55 163.1 $188,617.81

E. Write Report

Initial notification report 1 1 1 2,330 2,330 116.5 233 $269,454.02

Compliance method report c, d 1 1 1 1,631 0 1,631 0 $211,915.83

Solvent consumption report c, e 0.25 1 0.25 699 0 174.75 0 $22,705.27

Report

- exceed consumption cutoff c, f 1 1 1 117 0 117 0 $15,201.81

Reporting Subtotal 42,528 $5,155,855.94

4. Recordkeeping Requirements

A. Familiarization with the regulatory

requirements See 3A

B. Plan activities g 1 1 1 2,330 2,330 0 0 $242,250.1016

Burden Item A B C D E F G H

Hours per

occurrence Occurrences

per

respondent

per year Hours per

respondent

per year Respondents

per year a Technical

hours per

year Management

hours per

year Clerical

hours

per year Total cost per

year ($) b

(AxB) (CxD) * (Ex0.05) * (Ex0.10) *

C. Implement activities

Above consumption cutoff: Weekly

LDAR g, h, i 0.75 52 39 19,600 764,400 0 0 $79,474,668.00

Below consumption cutoff: Bi

weekly LDAR g, i, j 0.75 26 19.5 8,400 163,800 0 0 $17,030,286.00

Major: Monthly enhanced LDAR k, l 1 48 48 12 576 28.8 57.6 $66,611.81

Major: Weekly Carbon adsorber

m onitoring l, m 0.25 208 52 12 624 31.2 62.4 $72,162.79

Area: Monthly enhanced LDAR n, o 0.75 12 9 20,000 180,000 9,000 18,000 $20,816,190.00

D. Develop record system

Solvent consumption g 1 1 1 2,330 2,330 0 0 $242,250.10

Enhanced LDAR g 1 1 1 2,330 2,330 0 0 $242,250.10

Monitoring records d, g 1 1 1 1,631 1631 0 0 $169,575.07

Carbon adsorber monitoring records p 1 1 1 0 0 0 0 $0

E. Time to enter information

Monthly records of solvent

consumption q, r, s 0.25 12 3 28,012 84,036 9 0 $8,738,392.29

Above consumption cutoff:

Records of weekly inspections h, i, s 0.25 52 13 19,600 254,800 39 0 $26,496,623.27

Below consumption cutoff:

Records of bi

- weekly inspections g, i, j 0.25 26 6.5 8,400 54,600 0 0 $5,676,762.00

Major: Enhanced LDAR See 4C

Major: Carbon adsorber monitoring See 4C

Area: Enhanced LDAR See 4C

F. Time to Train personnel17

Burden Item A B C D E F G H

Hours per

occurrence Occurrences

per

respondent

per year Hours per

respondent

per year Respondents

per year a Technical

hours per

year Management

hours per

year Clerical

hours

per year Total cost per

year ($) b

(AxB) (CxD) * (Ex0.05) * (Ex0.10) *

Leak detection t, u 1 2 2 2,330 4,660 4,660 0 $1,089,974.00

G. Time for audits N/A

Recordkeeping Subtotal 1,548,005 $160,357,995.53

TOTAL ANNUAL BURDEN AND COSTS

(rounded): v 1,590,000 $166,000,000

Capital and O&M Cost (see Section

6(b)(iii)): v 947,000

TOTAL COST: v 1 67 ,000,000

*Unless otherwise specified; see assumptions below.

Assumptions:

a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replac ed by 2,330 new area sources

over the next three years. We hav e also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NESHAP

over the three

- year period of this ICR.

b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%).

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers , by occupational and industry

group.” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those

employed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c This task requires management hours only.

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 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.

f We estimate that 5 percent of new facilities each year will exceed the cutoff, thus requiring submission of the exceed

- consumption cutoff repor t.

g This task requires only technical employee hours.

h Occurrences are based on weekly inspection, assuming 52 weeks per year.18

i We have assumed that of 28,000 perchloroethylene dry cleaners 19,600 (70 percent) will be above the per consumption cutoff , which will require that the

cleaner conduct weekly leak detection and repair. The remaining 8,400 perchloroethylene dry cleaners will be below the consumption cutoff and are only

required to conduct bi

- weekly leak detection and repair.

j We have assumed that facilities below cutoff performs leak detection and repairs on a bi

- weekly basis.

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

l Approximately 12 existing major sources are subject to the NESHAP.

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

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

o Approximately 8,000 existing area sources are located in states that already require enhanced monitoring; therefore, 20,000 existing area sources are subj ect to

the NESHAP's enhanced LDAR program.

p No new major sources are expected for the three

- year period of this ICR; therefore, n o burden is associated with the development of carbon adsorber

monitoring record systems.

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

r This is based on 28,000 area sources and 12 major sources performing this task every year.

s This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume only three major

sources will require managerial review.

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

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

v Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.19

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63,

Subpart M) (Renewal)

Burden Item A B C F G H

EPA technical

h ou rs per

occurrence Occurrences per

year a Technical h ou rs

per year (AxB) Management h ou rs

per year (Cx0.05) Clerical h ou rs

per year (Cx0.10) Total cost per

year ($) b

1. Report review

A. Initi al notification report 1 2,330 2,330 116.5 233 121,952.20

B. Solvent consumption report c 1 699 699 34.95 69.9 36,585.66

C. Report

- exceed consumption cutoff d 1 117 117 5.85 11.7 6,123.78

D. Compliance method report e 1 1,631 1,631 81.55 163.1 85,366.54

Total Labor Burden and Cost f 5,490 250,000

Assumptions:

a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources

over the next three years. We have also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NES HAP

over the three

- year period of this ICR.

b This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS

- 12, Step 1, $29.17 + 60%); Managerial $62.90 (GS

- 13, Step 5, $39.31 +

60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10

percent of Technical hours. These rates are from the OPM, 2015 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.

c We assume that 30 percent of new sources will consume less than 140 gallons of PCE per year.

d We assume that five percent of new sources will have to report

- exceed consumption cutoff.

e We assume that 70 percent of new area sources will consume between 140 to 200 gallons of PCE per year.

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.