SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal), 

EPA ICR 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 facilities that have a total manufacturers’ 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 any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

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

and are required of all affected facilities subject 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 sent to the delegated state or local authority. 

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

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, 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).

There are approximately 1,000 existing sources that currently are associated with the rule,

and over the next three years an average of 20 respondents per year will become subject to the 

standard. The rule stipulates that only new sources with one-time-only requirements are subject 

to this subpart. Therefore, we concluded that the number of respondents for this renewal ICR is 

20 sources per year.
2

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) with the following “Terms of Clearance (TOC)”:

This request is approved. Prior to resubmission of this information

collection for renewal, the agency should reassess estimated of

burden taking into account most recent experience with the program.

EPA has addressed each item of concern in the TOC. The respondent universe and 

burden hours have been thoroughly 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 publicly owned and operated 

petroleum dry cleaning facilities. None of the facilities are owned by either state, local and tribal 

agencies 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, Subpart JJJ) (Renewal). The burden to the “Federal Government” is attributed entirely

to work performed by either Federal employees or government contractors; this burden may be 

found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Dry

Cleaners (40 CFR Part 60, Subpart 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 system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately 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 years.

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 
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(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, pollutant emissions from petroleum dry cleaning 

facilities cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 

CFR part 60, subpart JJJ.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 standards 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 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 60, 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 directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.
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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 (76 FR 26900) on May 9, 2011. 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 System (OTIS), which is operated 

and maintained by EPA’s Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. 

Industry 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 ICR, we contacted: 1) the National Cleaners Association, at (212) 967-3002; 2) the 

Drycleaning and Laundry Institute (DLI), at (800) 638-2627; 3) Highland Cleaners, at (502) 454-

4641; 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 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 proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These 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).
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3(g) Sensitive Questions

The reporting, or recordkeeping, requirements in the standard do not include any 

sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of petroleum dry cleaning facilities. The United States Standard Industrial Classification (SIC) 

codes for the respondents affected by the standards, and the corresponding North American 

Industry Classification System (NAICS) codes, are listed in the following table. 

Standard (40 CFR Part 60, Subpart JJJ) SIC Codes NAICS Codes

Coin-Operating Laundry and Drycleaning 7215 812310

Drycleaning Plants, Except Rug Cleaning 7216 812320

Industrial Launderers 7218 812332

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported are required by NSPS for Petroleum 

Dry Cleaners (40 CFR Part 60, Subpart 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 physical or operational change 60.7(a)(4)

Reports

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 60.7(b)

Initial and repeat of performance tests 60.625
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Recordkeeping 

Records are required to be retained for two years 60.7(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 recordkeeping at 

a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems 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 

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.

Train personnel to be able 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 system. 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.
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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 Online Tracking Information System (OTIS).

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 operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs.

Information contained in the reports is entered into OTIS 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 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

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 

Federal 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 entities) and 

industrial facilities (most of which are large entities). Due to technical considerations involving 

the process operations and the types 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 overall 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 − NSPS for Petroleum Dry
8

Cleaners (40 CFR Part 60, Subpart 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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever 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 1,849 hours (Total Labor Hours from Table 1). 

This estimate is based on Agency studies and background documents from the development of 

this regulation, Agency knowledge and experience with the NSPS program, the previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 per hour ($57.82 + 110%)

Technical $99.14 per hour ($47.21 + 110%)

Clerical $49.81 per hour ($23.72 + 110%)

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

September 2011, “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 only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are no capital/startup or operation and 

maintenance (O&M) costs.

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

The only type 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.
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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 

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 based on the average hourly 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) “2011 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 − NSPS for Petroleum Dry Cleaners

(40 CFR Part 60, Subpart JJJ) (Renewal).

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

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

20 respondents per year 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 

years covered by this ICR.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of 

New

Respondents

(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-year period of this ICR is 20 per year.

The total number of annual responses per year 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, Subpart 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 these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Dry

Cleaners (40 CFR Part 60, Subpart 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 Burden and Cost

− NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart 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 ICR 

compared to the previous ICR. 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.

There is also an increase in the total labor and Agency costs as currently 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 this collection of information 

is estimated to average 22 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA 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-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 information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 
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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.
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Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal)

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 $134,435.83

 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/ 

modification 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

Subtotal for Reporting Requirements 1,821.6

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

Subtotal for Recordkeeping Requirements 27.6

TOTAL LABOR BURDEN AND COST

(rounded)

1,849 $177,191
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Assumptions:

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 new sources with one-time-only requirements are subject to this subpart. We therefore, concluded that the 

number of respondents for this renewal ICR is 20 sources per 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, September 2011, “Table 2. Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages 

available to those employed 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.
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Table 2: Average Annual EPA Burden and Cost - NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) 

(Renewal)

Activity

(A)

EPA 

personhours 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

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 Cost 624 31.2 62.4 $32,337.18

TOTAL ANNUAL BURDEN AND COST 

(rounded) 718 $32,337

Assumptions:

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 new sources with one-time-only requirements are subject to this subpart. We therefore, 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 which 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) “2011 General Schedule” which excludes 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.