SUPPORTING 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 ICR 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, these amendments corrected errors and clarified regulatory text, promulgated 

compliance extension dates, permanently exempted area batch cold solvent cleaning machines 

that use halogenated solvents 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 these 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 to each individual batch 

vapor, in-line vapor, in-line cold, and batch cold solvent cleaning machine that uses any solvent 

containing methylene chloride, perchloroethylene, 1, 1, 1-trichloroethane, trichloroethylene, 

carbon tetrachloride, chloroform, or any combination of these halogenated HAP solvents, in a 

total concentration greater than 5 percent by 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 system 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. 
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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.

Over the next three years, an average of 1,431 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard.

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

without any “Terms of Clearance.”

The “Affected Public” are owners or operators of solvent cleaning machines using any 

solvent containing methylene chloride, perchloroethylene, 1, 1, 1-trichloroethane, 

trichloroethylene, 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). The burden to the Federal Government is attributed entirely to work performed by 

Federal employees or government contractors, 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 Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, 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 intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from solvent cleaning machines cause 

or contribute to air pollution that may reasonably be anticipated to endanger public health or 
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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 recordkeeping and reporting 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 evidence 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 notifications 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 properly 

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 operation/maintenance procedures and for compliance 

determinations.

The information generated by the monitoring, recordkeeping and reporting requirement 

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP 

continue to operate the control equipment in compliance with the regulation. Adequate 

monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable 

regulations, as required by the Clean Air Act. The information collected from recordkeeping and 

reporting requirements is also used for targeting inspections, and is of sufficient quality to be 

used as evidence in court.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart T.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted 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, 
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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 ICR 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 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 the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance 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 ICR, 

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 any comments 

from either consultant.

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 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-year records retention requirement is consistent the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 
5

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance, and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. 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 claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The 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 Industrial 

Classification (SIC) codes and corresponding North American Industry Classification System

(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, plywood, and engineered wood product manufacturing 2435 3212

Other wood product manufacturing 2499 3219

Furniture and Fixtures

Household and institutional furniture and kitchen cabinet 

manufacturing

2514 3371

Office furniture (including fixtures) manufacturing 2522 3372

Other furniture related product manufacturing 2599 3379

Electronic and Other Electrical Equipment and Components, Except Computer 

Equipment

Electric lighting equipment manufacturing 3648 3351
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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 ferroalloy 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 3336
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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 by 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), 63.462 (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)

Compliance 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 reports 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

system determinations and monitoring

Maintain control device monitoring, maintenance, annual solvent 

consumption, and carbon adsorber records 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 years

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 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 are still 

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.

Install, calibrate, maintain, halogenated HAP solvents cleaning machines.

Perform initial performance test, Reference Method 18 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.
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Respondent Activities

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

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.

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 could 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, 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 semiannual reports are used for problem 
10

identification, as a check on source operation and maintenance, and for compliance 

determinations.

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 five 

years.

5(c) Small Entity Flexibility

According to the Final Rule (72 FR 25138): “The final rule is expected to affect 125 

ultimate parent entities that will be regulated as major sources. Forty of the parent entities, or 

approximately one-third, is defined as small entities according to the SBA small business size 

standards.” Therefore, this ICR assumes that one-third of the affected facilities are small entities 

(e.g., small businesses). The impact on small entities (i.e., small businesses) was taken 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 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 Cost – NESHAP for Halogenated 

Solvent Cleaners/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 ICR. The 

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

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, 

a collection of information unless it displays a currently valid OMB Control Number.
11

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 45,242 hours (Total Labor Hours from Table 1 

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 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 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 type 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)

Temperature 

monitoring 

device

$2,700 0 0 $860 1,180 $1,014,800

1 The O&M cost only applies 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 ICR are $0. This is the total of column D in the 

above table. 

The total O&M costs for this ICR 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 ICR 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 analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$201,805.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 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 ICR, on average over the next three years, approximately

1,431 existing respondents will be subject to the standard. No additional respondents per year 

will become subject. The overall average number of respondents, 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 

years covered by this ICR: 
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Number of Respondents

Respondents That Submit Reports

Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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.

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 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 machines

Annual compliance report 1,180 1 0 1,180

Quarterly exceedance reports 118 4 0 472

Semiannual exceedance reports 1,062 2 0 2,124
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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 increase in burden hours for the respondent and the Agency as 

compared to the previous ICR due to burden calculation revisions. The calculations presented in 

the previous ICR assumed that total respondent hours per year associated with each burden item 
15

included technical, managerial, and clerical labor. The previous ICR then back-calculated 

technical, managerial, and clerical labor hours as being 85, 5, and 10 percent, respectively, of the 

total hours. To be consistent with the estimation methodology used in other ICRs, this ICR 

considers total respondent hours to include only technical labor, and that managerial and clerical 

hours account for an additional 5 and 10 percent, respectively, of those technical labor hours. 

Additionally, there is an adjustment increase in the respondent labor estimates associated with 

semiannual and quarterly reporting. The previous ICR estimated labor burdens for one 

semiannual report and three quarterly reports per year. We have revised the calculations to 

account for the burden associated with two semiannual and four quarterly 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 updated labor rates. This ICR 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 ICR. The previous ICR incorrectly estimated Agency costs using 

civilian labor rates, which resulted in an overestimated total Agency cost. This ICR corrects this 

discrepancy by using current labor rates from the Office of Personnel Management.

There is also an adjustment increase in the estimated number of responses due to a 

correction. The previous ICR did not include annual compliance reports in calculating the 

number of responses. This ICR 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 ICR 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 ICR 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 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.
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 ICR 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 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 

Number EPA-HQ-OECA-2012-0660 and OMB Control Number 2060-0273 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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

Person

hours per 

occurrence

No. of 

occurrences 

per 

respondent

per year

Person

hours per 

respondent 

per year

(C=AxB)

Respondents 

per year a

Technical 

personhours 

per year 

(E=CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year 

($) b

1. Applications

 a. Batch vapor and in-line cleaning machines N/A

 b. Batch cold cleaning machines N/A

2. Survey 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 c2 1 2 0 0 0 0 $0

ii. Gather 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 d30 1 30 0 0 0 0 $0

 Annual compliance report e1.5 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 i0.5 1 0.5 0 0 0 0 $0

ii. Gather existing information Included in 3B(iii)

iii. Write Report j
18

Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per 

respondent

per year

Person

hours per 

respondent 

per year

(C=AxB)

Respondents 

per year a

Technical 

personhours 

per year 

(E=CxD)

Management 

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 $367,910.32

4. Recordkeeping Requirements

 a. Batch vapor and in-line cleaning machines

 i. Read instructions Included in 3A(i)

ii. Plan activities N/A

iii. Implement activities

 Performance test d50 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 m1.5 12 18 590 10,620 531 1,062 $1,182,568.86

iv. Record 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 251 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, 

“Total 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 compliance 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 write each report.

k.

 Actual monitoring is conducted weekly, monthly or quarterly for specific control devices. The estimated time is based on the typical control devices expected to 

be installed.

l.

 We assume that 50 percent of the facilities will choose the standard equipment and will be required to conduct control device monitoring. 

m.

 We assume that 50 percent of the facilities will choose to do solvent consumption monitoring.

n.

 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 facility 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)

Management 

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 b8 1 8 0 0 0 0 $0 

 d. Annual compliance report c2 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 rates are from the Office of Personnel 

Management (OPM), 2011 General Schedule, which excludes locality rates of pay. The rates have 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 results for each cleaning machine.

d.

 The burden of one quarterly and one semiannual exceedance report is included in the burden estimate 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.