**SUPPORTIN G STATEMENT**  **ENVIRONMENTAL PROTECTION AGENCY NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40**  **CFR Part 63, Subpart T) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the**  **Information Collection** NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal), EPA I CR Number 1652.08, OMB Control Number 2060

- 0273

. **1 (b) Short Characterization/Abstract**  The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Halogenated Solvent Cleaners/ Halogenated Hazardous Air Pollutants were proposed on November 29, 1993 , and promulgated on December 2, 1994

. The NESHAP was amended on : June 5, 1995 ; December 11, 1998 ; July 13, 1999; August 19, 1999; and May 3, 2007

. Collectively , the se amendments corrected errors and clarified regulatory text , promulgated compliance extension dates , permanently exempted area batch cold solvent cleaning machines that use halogenat ed solvent s from the Federal operating permit program , deferred Federal operating permit requirements for subject area halogenated solvent cleaning machines , provided compliance options for continuous web cleaning machines , and revised standards to further limit hazardous air pollutant ( HAP ) emissions. None of the se amendments affected the respondent reporting or recording requirements promulgated in the final rule published on December 2, 1994. The regulations listed in 40 CFR part 63, subpart T , apply t o each individual batch vapor , in

- line vapor, in

- line cold, and batch cold solvent cleaning machine that uses an y solvent containing meth yl ene chloride, perchloroethylene, 1, 1, 1

- trichloroethane , trichloroeth yl ene , carbon tetrachloride , chloroform, or an y combination of these halogenated HAP solvents, in a total concentration greater than 5 percent b y weight, as a cleaning and/or drying agent

. New facilities include those that commenced construction or reconstruction on or after December 2, 1994 . This information is being collected to assure compliance with 40 CFR part 63 , subpart T

. In general, all NESHAP 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

.2

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

. S

. Environme ntal Protection Agency (EPA) regional office. Over the next three ye ars, an average of 1,431 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the standard. The Office of Management and Bu dget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance. ” The “Affected Public” are owners or operators of solvent cleaning machines using any solvent co ntaining meth ylene chloride , perchloroethylene, 1, 1, 1

- trichloroethane , trichloroeth yl ene , carbon tetrachloride , chloroform , or any combination of these halogenated solvents in a concentration greater than 5 percent by

- weight. The burden to the “Affected Public” may

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

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)

. T he burden to the Federal Government is attributed entirely to work performed b y F ederal emplo ye es or government contractor s , and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal).
**2. Need for and Use of the Collection 2(a)**  **Need/Authority for the Collecti on**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or exist ing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such interval s, 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 certif

ications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgment, HAP emissions from solvent cleaning machines cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or3

welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63 , subpart T

. **2(b) Practical Utility/Users of the Data** The rec ordkeeping and reportin g requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidenc e in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard . Continuous emission monitors are used to ensure compliance with the standard 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 notificat ions required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing 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 standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operat ion/maintenance procedures and for compliance determinations. The information generated by the monitoring, recordkeeping and reporting requirement described in this I CR is used by the Agency

to ensure that facilities affected by the NESHAP continue to ope rate 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 an d 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to th e 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,4

duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 77 FR 63813 ) on October 17, 2012

. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compli ance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In developing this I CR, the EPA contacted : 1) the Halogenated Solvents Industry Alliance (HSIA) , at (703) 741

- 5780 ; and 2) the American Chemistry Council , at (703) 741

- 5583 . EPA did not receive an y comments from either consu ltant

. 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelin es**  T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

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

- ye ar statute of limitations on which the per mit program is5

based. T h e retention of records for five ye ars allow s EPA to establish the compliance history of a source , an y pattern of non - compliance , and to determine the appropriate level of enforcement action. EPA has found that the most flagrant vi olators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitted to the Agency for which a c laim 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**
T he reporting or recordkeeping requirements in the standard do not include 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 Ind ustrial Classification (SI C ) codes and corresponding North American Industry Classification Sy stem (NAICS ) codes for the respondents affected by the standard are listed below

.
**Standard (40 CFR Part 63, Subpart T)**  **SIC Codes NAICS Codes**  **Lumber and Wood Products, Except Furniture** Sawmills and wood preservation 2421 3211 Veneer, ply

wood, and engineered wood product 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 33516
**Standard (40 CFR Part 63, Subpart T)**  **SIC Codes NAICS Codes**  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 ferroallo y manufacturing 3312 3311 Steel product manufacturing from purchased steel 3325 3312 Alumina and aluminum production and processing 3365 3313 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 3511 33367
**Standard (40 CFR Part 63, Subpart T)**  **SIC Codes NAICS Codes**  manufacturing 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 (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T)

. A source must make the following reports: **Notifications/Reports** Initial notification 63. 9(b), 63 .46 2 (d), 63.468(a) , 63.468(b) Notification that source is subject to special compliance requirements 63.9( d) Notification of performance test 63.9( e ) C ompliance report 63.468(c) Statement of Compliance 63.468 (d) , 63.468( e ) Annual report on operator training 63.468(f) Annual report on solvent emissions 63.468(g) Semiannual or quarterly

exceedance report s 63.468(h and i) Equivalency

request report 63.468(k) A source must keep the following records: **Recordkeeping** Maintain equipment records for the lifetime of the machine, including owners’ manual, installation date, dwell testing, initial performance testing, halogenated HAP solvent contents, and squeegee and air knife 63.467(a)8 **Recordkeeping** sy stem determinations and monitoring Maintain control device monitoring, maintenance, annual solvent consumption , and carbon adsorber record s for five years 63.467(b) Maintain solvent consumption, waste composition, and emissions calculations records for five years 63.467( c )
Maintain records on method used to determine cleaning capacity 63.467(d) Maintain solvent consumption, solvent recovery , waste composition, and emissions calculations for five ye ars 63.467( e )

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 recordke eping at a plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents us e electronic reporting.

**(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 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.9 **Respondent Activities** Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y 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 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 ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Act ivi**  **ties** EPA conducts the following activities in connection with the acquisition, analy sis, 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, 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 could 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 capab ility to compl y with the emission standard, and to 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 semiannua l reports are used for problem10

identification, as a check on source operation and maintenance, and for compliance determinations.
In formatio n contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y local and state regulat ory agencies, EPA regional offices and EPA headquarters. EPA and its delegated a

uthorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility**  According to the Final Rule (72 FR 25138): “The final rule is expected to affect 125 ultimate parent entities that will be regulated as major sources. Forty of the parent entities, or approximately

one - third, is defined as small entities according to the SBA small business size standards.” Therefore, this I CR assumes that one

- third of the affected facilities are small entities (e.g., small businesses). T he impact on small entities (i.e., small businesses) was t aken into consideration during the development of the regulation. 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 to be the minimum requirements 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 b urden, 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 Cost

– NESHAP for Halogenated Solvent Cleaner s/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (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 appropriate, specific tasks and major assumptio ns 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

.11

**6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 45,242 hours ( Total Labor Hours from Table 1 below ). T hese 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. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**  The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs , which are addressed elsewhere in this ICR , and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance (O &M) costs are the ongoing costs to maintain the monitor 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 1 (G)

Total O&M, (E X F)

Tem perature mo nitoring device $2,700 0 0 $860 1,180 $1,014,800

1 T he O&M cost only app lies to the 1,180 batch vapor and in

- line solvent cleaning machines, and does not include the 251 batch cold solvent cleaning machines

.12

The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total O&M costs for this I CR are $ 1,014,800

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 1,014,800

. **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 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 $ 201,805

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Perso nnel Management (OPM) , 20 1 1 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (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 ye ars, approximately 1,431 existing respondents will be subject to the standard. No additional respondents per ye ar will become subject. The overall average number of respondent s, as shown in the table below, is 1,431 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR :13 **Number of Respondents**
Respondents That Submit Reports Respondents That Do Not Submit An y Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

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

Number of Respondents (E=A+B+C

- D)
Batch vapor and in

- line cleaning machines
1 0 1,180 0 0 1,180
2 0 1,180 0 0 1,180 3 0 1,180 0 0 1,180 Average 1,180 1,180 Batch cold cleaning machines
1 0 0 251 0 251
2 0 0 251 0 251 3 0 0 251 0 251 Average 251 251 TOTAL ( sum of average batch vapor, in

- line, and batch cold cleaning machines) 1,431 1 New respondent include sources with constructed, reconstructed , and modified affected facilities. C olumn 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 1,431

. **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

**Batch vapor and in**
**- line cleaning m**  **achines** Annual compliance report 1,180 1 0 1,180 Quarterly exceedance reports 118 4 0 472 Semiannual e xceedance reports 1,062 2 0 2,12414 **Total Annual Responses Batch cold cleaning machines**  Initial notification report and compliance report 0 2 251 251

Total 4, 027 The number of Total Annual Responses is 4, 027

. The total annual labor costs are $ 4,380,761

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

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2 , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 45,242 at a cost of $4,380,761

. Details regarding these estimates may

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

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 1,014,800

. 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 next three years is estimated to be 4,478 labor hours at a cost of $ 201,805 . See below Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)

. **6(f) Reasons for Change in Burden** There is an apparent i ncrease in burden hours for the respondent and the Agency as compared to the previous I CR due to burden calculation revisions. The calculations presented in the previous ICR assumed that total respondent hours per ye ar associated with each burden item15

inc luded technical, managerial, and clerical labor. The previous ICR then back

- calculated technical, managerial, and clerical labor hours as being 85, 5, and 10 percent, respectivel y, of the total hours. To be consistent with the estimation methodology used in other ICRs, this I CR considers total respondent hours to include only technical labor , and that managerial and clerical hours account for an additional 5 and 10 percent , respectivel y, of thos e technical labor hours. Additionally , there is an adjustment increase in the respondent labor estimates associated with semiannual and quarterl y reporting. The previous ICR estimated labor burdens for one semiannual report and three quarterl y reports pe r year. We have revised the calculations to account for the burden associated with two semiannual and four quarterl y reports per year. There is also an increase in the respondent cost as compared to the most recently approved ICR due to the use of update d labor rates. This I CR references the most recent labor rates from the Bureau of Labor Statistics. There is a decrease in the Agency cost due to the correction of a calculation error that was identified in the previous I CR. The previous ICR incorrectl y estimated Agency cost s using civilian labor rates, which resulted in an overestimate d total Agency cost. This I CR corrects this discrepancy

by using current labor rates from the Office of Personnel Management. There is also an adjustment increase in th e estimated number of responses due to a correction. The previous I CR did not include annual compliance reports in calculating the number of responses. This I CR corrects the error, which results in an increase of 1,180 responses. There is a decrease of $200 in total O&M costs in this I CR as compared to the previous ICR. The previous ICR calculated an O&M cost of $1,014,800, but rounded the estimate to the nearest thousand ($1,015,000). This I CR presents a more accurate estimate; there are no actual changes to the O&M costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 11 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, vali dating, and verifying information, processing and maintaining information, and disclosing and providing information; 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 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 infor

mation 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 15.16

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

- 2012

- 0660 . 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 acces s 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 Compli ance 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 ho liday 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, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 1 7th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OEC A

- 2012

- 0660 and OMB Control Number 20 60

- 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.17

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

**– NESHAP for Halogenated Solvent**  **Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H P**  **erson hours per**  **occurrence No. of** 

**occurrences per**  **re spondent**  **per year P**  **erson**

**hours per respondent**  **per year (**  **C= AxB)**  **Respondents**

**per year a**  **Technical**

**person**   ** hours** **per year (**  **E= CxD)**  **Managem ent** 

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost per** 

**year ($)**  **b**

1. A pplications a
. Batch vapor and in

- line cleaning machines N/A b

. Batch cold cleaning machines N/A 2. S urvey and studies a
. Batch vapor and in

- line cleaning machines N/A b

. Batch cold cleaning machines N/A 3. Reporting Requirements a
. Batch vapor and in

- line cleaning machines i. Read Instructions c 2 1 2 0 0 0 0 $ 0 ii. Gath er existing information Included in 3A(iii) iii. Write Report Initial notification report 1 1 1 0 0 0 0 $ 0 Initial compliance report 4 1 4 0 0 0 0 $ 0 Performance test results d 30 1 30 0 0 0 0 $ 0 Annual compliance report e 1.5 1 1.5 1,180 1,770 88.5 177 $ 197,094.81 Report with exceedance f, g 1 4 4 118 472 23.6 47.2 $ 52,558.62 Report with no exceedance f, h 0.5 2 1 1,062 1,062 53.1 106.2 $ 118,256.89 b

. Batch cold cleaning machines i. Read Instructions i 0.5 1 0.5 0 0 0 0 $ 0 ii. Gather existing information Included in 3B(iii) iii. Write Report j18

**Burden Item A**  **B C**  **D E**  **F G**  **H P**  **erson hours per**  **occurrence No. of** 

**occurrences per**  **re spondent**  **per year P**  **erson**

**hours per respondent**  **per year (**  **C= AxB)**  **Respondents**

**per year a**  **Technical**

**person**   ** hours** **per year (**  **E= CxD)**  **Managem ent** 

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost per** 

**year ($)**  **b**

Initial notification report 0.25 1 0.25 0 0 0 0 $ 0 Initial compliance report 0.25 1 0.25 0 0 0 0 $ 0 **Subtotal for Reporting Requirements 3,799.6**  **$ 367,910.3**  **2** 4. **R ecordkeeping**  **R equirements**  a
. Batch vapor and in

- line cleaning machines i. Read instructions Included in 3A(i) ii. Plan activities N/A iii. Im plement activities Performance test d 50 1 50 0 0 0 0 $ 0 Control device monitoring k, l 1.64 12 19.68 590 11,611.2 580.56 1,161.12 $ 1,292,941.95 Solvent consumption log m 1.5 12 18 590 10,620 531 1,062 $ 1,182,568.86 iv. Recor d Data Control device monitoring l, n 1.2 12 14.4 590 8,496 424.8 849.6 $ 946,055.09 Solvent emission calculation m, o 0.75 12 9 590 5,310 265.5 531 $ 591,284.43 v. Time to train personnel p b

. Batch cold cleaning machines N/A **Subtotal for Recordkeeping Requirements 41,442.8**  **$ 4,012,850.33**  **TOTAL ANNUAL BURDEN AND COST ( rounded**  **) 45,242**  **$ 4,380,761**  Assumptions:
a. We estimate that an average of 1,431 existing respondents will be subject to the rule over the three

- year period of this ICR. Of this total, 1,180 respondents are subject to batch vapor and in

- line cleaning machine requirements while 2 51 respondents are subject to batch cold cleaning machine requirements. No new respondents are expected. b. This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial, and $50.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.19

c. We assume it will take 2 hours to read instructions. d. We estimate that idling emission or dwell test reports will require 80 technical hours, which are divided between the test report (30 hours) and the test itself (50 hours).
e. We assume that 1,180 facilities are required to complete the annual complianc e report. f. The burden of one quarterly and one semiannual exceedance report is 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 (quarterly reporting). h

. We assume that 90 percent of 1,180 facilities are not in exceedance (semiannual reporting). i. We assume that it will take 0.5 hours to read instructions. j. We assume that it will take 0.25 hours to w rite each report. k. Ac tual monitoring is conduct ed weekly, monthly or quarterly for specific control devices. The estimated time is based on the typical control devices exp ected to be installed. l. We assume that 50 percent of the facilities will choose the standard equipment and will be required to c onduct control device monitoring.
m. We assume that 50 percent of the facilities will choose to do solvent consumption monitoring.
n. We assume that it would take 1.2 hours per facility to record data.
o. We assume that it would take 0.75 hours per fa cility to record solvent consumption data. p. We assume that no special training requirements are required.20

**Table 2 : Average Annual EPA Burden and Cost** 

**– NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air**  **Pollutants (40 CFR Part 63, Subpart T) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per respondent**  **per year Technical** 

**person -**  **hours per**  **respondent per year**  **(AxB) Respondents** 

**per year Technical** 

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **a**

Report Activity 1. Batch vapor and in

- line cleaning machine a . Initial notification report 1 1 1 0 0 0 0 $ 0 b . Initial compliance report 2 1 2 0 0 0 0 $ 0
c . Performance test results b 8 1 8 0 0 0 0 $ 0 d . Annual compliance report c 2 1 2 1,180 2,360 118 236 $ 122,305.82 Report with exceedance d, e 1 4 4 118 472 23.6 47.2 $ 24,461.16 Report with no exceedance d, f 0.5 2 1 1,062 1,062 53.10 106.2 $ 55,037.62 2. Batch Cold Cleaning Machines a . Initial notification/compliance report 0.25 1 0.25 0 0 0 0 $ 0 **TOTAL ANNUAL BURDEN AND COST (**  **rounded )**  **4,478 $**  **201,805** Assumptions:
a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These r ates are from the Office of Personnel Management (OPM), 2011 General Schedule, which excludes locality rates of pay. The rates h ave been increased by 60 percent to account for the benefit packages available to government employees. b. We assume that it will take 8 hours to review performance test results.
c. All facilities are expected to submit annual compliance reports summarizing either solvent consumption data or monitoring res ults for each cleaning machine. d. The burden of one quarterly and one semiannual exceedance report is included in the burden es timate for the annual report.
e. We assume that 10 percent of 1,180 facilities are in exceedance at least one time per year. f. We assume that 90 percent of 1,180 facilities are not in exceedance.