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 I CR 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 promul gated 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 m achines, 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 in stall a control combination listed in the regulation, they must maintain quarterly , monthly , or weekly control device monitoring records based on the ty pe of control device installed as specified in the regulation, and installation dates of each cleaning m achine and its control devices. T he frequency o f 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 optio n must perform an idling emission test on their solvent cleaning machines and monitor idling emission control parameters. E mission control parameters to be maintained and monitored must be established during the test. Inm ost cases, this test will be completed by

the manufacturer of the solvent cleaning machine. A ll respondents using2

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 clean ing 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 oc currence 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 installatio n 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 operat or 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 cleanin g 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 necess ary 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 autho rity . 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 (I CR) will be $4,992,917 (rounded). The Office of Management and Budget (OMB) approved the currently active Information3

Collection Request (I CR) 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 b e 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 app licable 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 an d 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.
Inthe 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 d esigned 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.4

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 i nstalled and operated, that leaks are being detected a nd 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 I CR is used by the Agency

to ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation. A dequate monitoring, recordkeeping, and reporting are nece ssary 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 eviden ce 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 s tate or local agency

h as adopted their own similar standards to implement the Federal standards, a cop y 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 IC R 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
Inestimating the affected numbe r 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 I CR, consulted with the preparer of the active I CR, and used other resources to obtain the most recent data available. We reviewed information available from the Online Tracking Information System (OTI S) which is the primary s ource of information regarding the number of existing sources. OTI S data was used in conjunction with industry consultation to verify the number of sources and the industry growth rate.5

3(d) Effects of Less Frequent Collection Less frequent information collection woul d 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. I f 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 reporti ng 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 ye ars. T hi s is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the part 70 permit program and the five

- ye ar statute of limitations on which the permit program is ba sed. Also, the retention of records for five ye ars would allow EPA to establish the compliance history o f 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 ye ars. 3(f) Confi dentiality 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, chap ter 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
No ne 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 halo genated solvent cleaning machines. The United States Standard I ndustrial Classification (SI C) codes for the respondents affected by the standard are listed below. These correspond to the6

North American In dustry

C lassification System (NAI CS) 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, ply

wood, and engineered wood product manufacturi ng 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 f ood manufacturing 2034 3114 Dairy product manufacturing 2026 3115 Seafood product preparation and packaging 2092 3117 Bakeries and tortilla manufacturing 2051 3118 Other food manufact

uring 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 33137

Halogenated Solvent Cleaning (40 CFR part 63, subpart T) SIC Codes NAICS Codes 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 In dustrial 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 instrume nts 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 I CR 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 m ake the following reports:

Reports for 40 CFR part 63, subpart T In itial notification 63.09(b), 63.468(a) Construction/reconstruction 63.05(d), 63.468(b) In itial compliance report 63.09(h), 63.468(c) In itial 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)8 Reports for 40 CFR part 63, subpart T Semiannual and quarterly exceedance report 63.10(b), 63.468(h

- i) A source must keep the following records:

Recordkeepin g 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 so lvent 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 in structions. In stall, 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.9 Respondent Activities Adjust the existing ways to comply with any previously

applica ble 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 ty

pe 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, analy

ze, and m aintain data in the Air Facility Sy stem (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 i nstalled 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 re spondents 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.
In formation 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 l ocal and state regulatory a gencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analy ze the data.10

The records required by

this regulation must be retained by the owner or operator for five ye ars. 5(c) Small Entity Flexibility According to the Final Rule (72 FR 25138): “The final rule is expected to affect 125 ultimate parent entitie s that will be regulated as major sources. Forty of the parent entities, or approximately

o ne - third, are defined as small according to the SBA small business size standards.” Therefore, this I CR 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 ty pe 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 S chedule The specific frequency

f or each information collection activity w ithin this request is shown below in Table s 1(a), 1(b), and 1(c): Annual Industry Burden for NESHAP for Halogenated Solvent Cleaners (40 CFR part 63, subpart T) (Renewal)

. 6. Estim ating 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 f or the subpart included in this I CR. The indivi dual 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 col lection 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 t o industry over the next three years from these recordkeeping and reporting requirements is estimated to be 41,035 (Total L abor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, A gency

knowledge and experience with the NESHAP program, the previously approved I CR, and any

comments received.11

6(b) Estimating Respondent Costs (i) Estimating Labor Costs
This I CR uses the following labor rates: Managerial $114.77 ($54.65 + 1 10%) 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 ty pes of industry

cost associated with the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one

- time cost when a f acility 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 Capit al/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)

Tem perature mo nitoring 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 I CR is zero. This is the tot al of column D in the above table. The total operation and maintenance (O&M) costs for this I CR 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 I CR is estimated to be $1,015,000 (rounded)

.12

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 I CR is estimated to be $325,437 (rounded) [see Table 2 in Section 6(e)]. Costs in the proposed I CR 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%)
Th ese rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian Workers, by O ccupational and In dustry group.” T he 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 s ubject 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 sourc es averaged over the three

- ye ar period (i.e., the total of the number of13

new respondents over the three

- ye ar 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 Numb er of Responses Per Year table above. The total annual labor costs are $3,977,9 1 7 (rounded). Details regarding these estimates may be found below in Table 1(c). Annual Respondent Burden and Cost, NESHAP for Halogenated Solvent Cleaning/Halogenated Hazard ous 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 IC R compared to the previous IC R. T his 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 I CR reflect the current burden to the respondents and are reiterated in this I CR. There is an increase in both respondent and Agency costs resulting from labor rate increases from 2003 to 2009. T his IC R uses 2009 labor rates because burden and cost calculations in Tables 1 and 2 of this IC R were expanded to inc lude managerial and clerical labor rates, and the previous I CR only

provided a technical labor rate for 2003. Therefore, this I CR 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 disclo se 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 verify ing 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.14

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 Numb er. 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 I CR 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 In formation 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 docke t is available online at www.regulations.gov

. T his 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 . Wh en 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, Attentio n: Desk Officer for EPA. P lease 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 co llecting this information.15
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/ Year b Technical

Hours/ Year b Clerical

Hours/ Year b Cost per

year a 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 30.78 307.8 3 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 activitie s 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 Solve nt 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 $3,720,54316

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 th e table has been increased by 110 percent to account for the benefit packages available to those employed by private ind ustry. b. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical ho urs. 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%@$9 7.59/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 estimat e 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 th e 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 dev ice monitoring. m. We assume that 50 percent of the facilities will c hoose 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.17 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/Year b Technical

Hours/Year b Clerical

Hours/Year b Cost

per Year a Burden Item s 1. APPLICATIONS N/A 2. SU RVEYS 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 notific ation 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 De partment 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 ho urs. 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.18

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 (sub total) 1 0 0 0 T TOTAL ANNUAL COST BURDEN (rounded) 155 1,180 41,035 $3,977,91719

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 Occ urrence Occurrences Per

Year Technical

hrs/year a (C=AxB) Managem ent

hrs/year a (D=Cx0.05) Clerical

hrs/year a (E=Cx0.1) EPA

Cost/year a Burden Item s Report Activity 1. Batch vapor and in

- line cleaning machine A Initial n otification 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 report i 0.25 0 0 0 0 $0 TOTAL ANNUAL BURDEN j 3,009 150.45 300.9 $32 5,437 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, “Tab le 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 faci lities 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 facilit ies are expected to submit annual compliance reports summarizing either solvent consumption data or monitoring results for ea ch 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.