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 
2

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 
3

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.
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 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. 
5

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 
6

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
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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

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)
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:

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.
9

Respondent Activities

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.
10

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.
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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 10 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).
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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 
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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.
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 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.
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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 d1 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 d1.5 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 j1 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
16

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.
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/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.
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 (subtotal) 1 0 0 0

T TOTAL ANNUAL COST BURDEN (rounded) 155 1,180 41,035 $3,977,917
19

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 b1 0 0 0 0 $0 

 B Initial compliance report b2 0 0 0 0 $0 

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

 D Annual compliance report e2 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 reporti0.25 0 0 0 0 $0 

TOTAL ANNUAL BURDEN j3,009 150.45 300.9 $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.