**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Petroleum Dry Cleaners (40 CFR**  **P art 60,**  **S ubpart JJJ** **) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS for Petroleum Dry

Cleaners (40 CFR P art 60, S ubpart JJJ ) (Renewal), EPA I CR Number 0997. 10 , OMB Control Number 2060

- 0079

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for the Petroleum Dry Cleaners ( 40 CFR part 60, subpart JJJ ) were proposed on December 14, 1982, promulgated on September 21, 1984 , and amended on October 17, 2000 . These regulations apply to existing and new petroleum dry cleaning facilit ies that have a total manufacturer s’ rated dryer capacity equal to or greater than 38 kilograms (84 pounds). New facilities include those that commenced construction, modification, or reconstruction after the data of proposal. A dryer installed between December 14, 1982, and September 21, 1984, in a plant with an annual solvent consumption level of less than 17,791 liters (4,700 gallons), is exempt from the requirements of this subpart. This information is being collected to assure compliance with 40 CFR part 60, subpart JJJ

. In general, all NSPS standards require initial notifications, 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 an y startup, shutdown, o r malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities sub ject to NSPS. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are se nt to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representat ives, there is an average of one affected facility

at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).
T here are approximately 1,000 existing sources that currently are associated with the rule , an d over the next three years an average of 20 respondents per year will be come subject to the standard. The rule stipulates that only new sources with one

- time

- only requirements are subject to this subpart . T herefore, we concluded that the number of respo ndent s for this renewal IC R is 20 sources per year.2

The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request (I CR) with the following “Terms of Clearance (TOC)”:

This request is approved. Prior to resubmission of this information c ollection for renewal, the agency should reassess estimated of b urden taking into account most rec ent experience with the program. EPA has addressed each item of concern in the TOC. The respondent universe and burden hours have been thoroughl y checked and all estimates updated; industry consultations and updated labor rates were utilized to reassess the burden and cost associated with the ICR. The respondents to this ICR (the “Affected Public) are publicl y owned and oper ated petroleum dry

cleaning facilities . None of the facilities are owned b y either state, local and tribal agen cies or the Federal government. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Petroleum Dry Cleaners (40 CFR Part 60, S ubpart JJJ) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed b y either F ederal emplo yees or government contractors; this burden may be found below in Table 2: Average Annu al EPA Burden and Cost

– NSPS for Petroleum Dry Cleaners (40 CFR P art 60, S ubpart JJJ) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every

four ye ars. In addition, section 114(a) states that the Administrator may require any

owner or operator subject to an y requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain su ch monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions3 (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 i nformation as the Administrator may reasonabl y require. In the Administrator's judgment, pollutant emissions from petroleum dry cleaning facilities cause or contribute to air po llution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NSP S were promulg ated for this source category at 40 CFR part 6 0 , subpart JJJ

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard s ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information also is 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 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 s 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 properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 6 0 , subpart JJJ

. **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 directl y 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 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, duplication does not exist.4

**3(b) Publ ic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (7 6 FR 26900 ) on May 9 , 20 11 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard is the Online Tracking Information Sy stem ( OTIS ) , which is operated and maintained b y EPA’s Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compliance data.
In dustry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR , we contacted : 1) the National Cleaners Association , at ( 212 ) 967

- 3 002 ; 2) the Drycleaning and Laundry Institute (DLI) , at ( 800 ) 638

- 2627 ; 3) Highland Cleaners , at ( 502 ) 454

- 46 41 ; 4) Yale Cleaners , at (918) 461

- 8612 ; and 5) Young Cleaners , at (704) 786

- 3011. 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. **3(d) Effects of Less Frequent Collection** Less frequent information collect ion 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 emissio n limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

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 at 5 CFR part 1320, section 1320.5. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, part 2, subpart B

- Confidentiality of Business Information (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).5

**3(g) Sensitive Questions**
T he reporting , or recordkeeping , requirements in the standard do not include an y sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are o wners or operators of petroleum dry

cleaning facilities . The United States Standard Industrial Classification (SI C) codes for the respond ents affected b y the standards, and the correspond ing North American Industry Classification Sy stem (NAICS) codes, are listed in the following table. **Standard (40 CFR P**  **art 60, S**  **ubpart JJJ )**  **SIC Codes NAICS Codes**  Coin

- Operating Laundry

and Dryc leaning 7215 812310 Dryc leaning Plants, Except Rug Cleaning 7216 812320 Industrial Launderers 7218 812332 **4(b) Information Requested (i) Data Items**  In this ICR, a ll the data that are recorded or reported are required b y NSP S for Petroleum Dry Cleaners (40 CFR P art 6 0 , S ubpart JJJ ). A source must make the following reports:
**Notifications** Notification of construction/reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Notification of initial performance test 60.8(d) Notification of ph ys ical or operational change 60.7(a)(4)
**Re ports**  Initial performance test results 60.8(a) Repeat performance test results 60.8(a)
A source must keep the following records : **Recordkeeping** Record of startup, shutdown, and malfunctions 6 0.7(b) Initial and repeat of p erformance tests 6 0.6256 **Recordkeeping** Records are required to be retained for tw o ye ars 6 0.7(f) Electronic Reporting Some of the respondents 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 recordk eeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems still are not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Perform initial performance 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be a

ble to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. 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 Methodolog y, and Information**  **Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information.7 **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, anal yz e, and maintain data in the Online Tracking Information Sy stem ( OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and gover nment

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e. , small businesses) was taken into consideration during the development of the regulation. The exact number of small entities affected by this rule could not be determined, based on review of the following sources: the promulgated rule notice in the Feder al Register ; the Petroleum Dry Cleaners

– Background Information for Proposed Standards (1982); and a search of publicly available current data sources. The petroleum dry cleaning industry

comprises both commercial facilities (most of which are small enti ties) and industrial facilities (most of which are large entities). Due to technical considerations involving the process operations and the ty pes 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. To the extent that larger businesses can use economies of scale to reduce their burden, the ov erall burden will be reduced. **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 Costs

− NSP S for Petroleum Dry8

Cleaners (40 CFR P art 60, S ubpart JJJ ) (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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this inform ation 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 avera ge annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1, 849 hours (Total Labor Hours from Table 1). Th is estimate is based on Agency studies and background documents from the developm ent of this regulation, Agency

knowledge and experience with the NSP S program, the previously approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Manag erial $ 121.42 per hour ( $ 57.82 + 110%) Technical $99.14 per hour ($47.21 + 110%) Clerical $49.81 per hour ($2 3

. 72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 20 11 , “Table 2 : Civilian Workers, by O ccupational and Industry group.” The rates are from column 1, “Total C ompensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed b y private industry

.

**(ii) Estimating Capital/Startup and Operation and Maintenance Costs**  The only costs to the regulated industry resulting from information collection activities required b y the subject standard s are labor costs. There are no capital/startup or operation and mai ntenance (O&M) costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only t ype of industry costs associated with the information collection activity in the regulations is labor costs. There are no capital/startup or operation and maintenance costs.9

**6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is 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 emission, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 32,337

. This cost is b ased on the average hourl y labor rate as follows:

Managerial $ 62.27 per hour (GS

- 13, Step 5, $ 38.92 x 1.6) Technical $46.21 per hour (GS

- 12, Step 1, $28.88 x 1.6) Clerical $25.01 per hour (GS

- 6, Step 3, $15.63 x 1.6) These rates are from the Office of Personnel Management (OPM) “20 11 General Schedule” which excludes locality rates of pay . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

− NSP S for Petroleum Dry Cleaners (40 CFR P art 60, S ubpart JJJ ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three years, approximately 20 respondents per ye ar will be subject to the standard. The rule stipulates that only new sources with one

- time

- only

requirements are subject to this subpart. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do

Not Submit Any Reports

Y ear (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)
1 20 0 0 0 20 2 20 0 0 0 20 3 20 0 0 0 20 Average 20 0 0 0 20 Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 20 per year
. The total number of annual responses per ye ar is calculated using the following table:10 **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 Notification of construction/reconstruction 20 1 0 20 Notification of actual startup 20 1 0 20 Notification of initial performance test 20 1 0 20 Report of performance test 20 1 0 20 Report of repeat of performance test 4 1 0 4 Total 84 The number of Total Annual Responses is 84

. The total annual labor costs are $177,191 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Petroleum Dry Cleaners (40 CFR Part 60, S ubpart JJJ) (Renewal). **6(e) Bottom Line Burden Hours Burden and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2, respectively , and summarized below. **(i) Respondent Tally** The total annual labor costs are $ 177,191

. Details regarding the se estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Petroleum Dry Cleaners (40 CFR Part 60, S ubpart JJJ) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $0

. The cost calculations are detailed in Section 6(b)( iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over the next three years is estimated to be 718 labor hours at a cost of $ 32,337 . See below Table 2 : Average Annual EPA B urden and Cost

− NSP S for Petroleum Dry Cleaners (40 CFR P art 60, S ubpart JJJ ) (Renewal)

.11

**6(f) Reasons for Change in Burden** There is an increase in labor hours for both the respondents and the Agency in this I CR compared to the previous IC R. The adjustment increase is due to an increase in the number of new or modified sources. This increase is not due to any program changes.
T here is a lso an increase in the total labor and Agency costs as currentl y identified in the OMB Inventory

of Approved Burdens. The change in cost estimates reflects the changes in respondent numbers (described above) and updated labors rates available from the Bureau of Labor Statistics. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for thi s collection of information is estimated to average 2 2 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing infor mation; adjust the existing way s to compl y 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 trans mit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques , EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0270. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of informati on, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA D ocket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. 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, yo u can send comments to the Office of In formation 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 ID12

Number EPA

- HQ

- OECA

- 2011

- 0270 and OMB Control Number 2060

- 0079 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.13

**Table 1: Annual Respondent Burden and Cost**

**– NSPS for Petroleum Dry Cleaners (40 CFR**  **P art 60,**  **S ubpart JJJ** **) (Renewal)** 

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year**  **(C)**

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read instructions Included in 4E B. Required activities Initial performance test c, d 61 1 61 20 1,220 61 122 $1 34 , 435

. 83 Repeat of performance test c, d, e 61 1 61 4 244 12.2 24.4 $26,887.17 C. Create information See 3B D. Gather existing information See 3B E. Write report Notification of construction/ mo dification c, f 2 1 2 20 40 2 4 $ 4,407.73 Notification of actual startup c, f 2 1 2 20 40 2 4 $4,407.73 Notification of initial performance test c , f 2 1 2 20 40 2 4 $4,407.73 Report of performance test Included in 3B **S ubtotal**  **for Reporting**  **Requirements 1,82**  **1.6** 4. Recordkeeping requirements A. Read instructions Included in 3A B. Plan activities Included in 4C C. Implement activities Included in 3B D. Develop record system N/A E. Time to enter information Record of all performance tests c, g 1 1.2 1.2 20 24 1.2 2.4 $ 2,644.64 F. Time for audits N/A **S ubtotal for**  **Recordkeeping Requirements**  **2 7.6**  **TOTAL LABOR BURDEN AND COST (rounded)**  **1,849 $1**  **77 ,**  **191**14

**Assu mptions:**  a We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only ne w sources with one

- time

- only requirements are subject to this subpart. We therefore, concluded that the number of respo ndents for this renewal ICR is 20 sources p er year. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Septem ber 2011 , “ Table 2. Civilian Workers, by O ccupational and I ndustry group. ” The rates are from column 1, “ Total C om pensation. ” The rates have been increased by 110% to account for the benefit packages available to those em

ployed by private industry. c This is a one

- time only activity. d We have assumed that it will take 61 hours for each respondent to complete the required activity. e We have assumed that 20 percent of respondents will have to repeat initial performance tests due to failure. f We have assumed that it will take 2 hours for respondents to write report. g We have assumed that it will take each respondent one hour to enter information on all performance tests.15

**Table 2: Average Annual EPA Burden and Cost** 
**- NSPS for Petroleum Dry Cleaners (40 CFR**  **P a**  **rt 60, S**  **ubpart JJJ )**  **(Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person hours per**  **plant per year**  **(C=AxB) (D)** 

**Plants per year**  **a (E)**  **Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Initial performance test 16 1 16 20 320 16 32 $ 16,583.17 2 Repeat performance test c, d 16 1 16 4 64 3.2 6.4 $ 3,316.63 3. Report review Notification of construction/ reconstruction c 2 1 2 20 40 2 4 $ 2,072.90 Notification of actual startup c 1 1 1 20 20 1 2 $ 1,036.45 Initial performance test c, e 7.5 1 7.5 20 150 7.5 15 $ 7,773.36 Repeat performance test c, f 7.5 1 7.5 4 30 1.5 3 $1, 554.67 **Subtotals Labor Burden and C**  **ost** 624 31.2 62.4 $ 32,337.18 **TOTAL ANNUAL BURDEN AND COST (rounded)**  718 $ 32,337

**Assu mptions:**  a We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only ne w sources with one

- time

- only requirements are subject to this subpart. We theref ore, concluded that the number of respondents for this renewal ICR is 20 sources per year. b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $ 62.27 (GS

- 13, Step 5, $ 38.92 x 1.6), Technical rate of $ 46.21 (GS

- 12, Step 1, $28.88 x 1.6), and Clerical rate of $ 25.01 (GS

- 6, Step 3, $ 15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “ 20 11 General Schedule ” which exc ludes locality rates of pay. c This is a one

- time only activity. d We have assumed that 20 percent of respondents will have to repeat performance test e We have assumed that each respondent will take 7.5 hours to review the initial performance test report. f We have assumed that 20 percent of respondents will have to review the repeat performance test report.