SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) 

(Renewal), EPA ICR Number 1415.10, OMB Control Number 2060-0234.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for Perchloroethylene Dry Cleaning Facilities were proposed on December 9, 1991, 

promulgated on September 22, 1993, and was last amended on July 11, 2008. EPA has 

reviewed the standards under sections 112(d) (6) and 112(f) of the Clean Air Act and, 

effective July 27, 2006, established additional monitoring requirements beyond those 

promulgated on September 22, 1993. The additional requirements are to implement an 

enhanced leak detection and repair (LDAR) program under which monthly leak detection 

using handheld instruments is performed. These standards apply to existing and new dry

cleaning facilities that use perchloroethylene (PCE). New facilities include those that 

commenced construction or reconstruction after the date of proposal. This information is 

being collected to assure compliance with 40 CFR part 63, subpart M.

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. 

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 average of one 

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Approximately 28,012 sources are currently subject to the standards, of which 12 are 

major sources and the remainder are area sources. Of the 28,000 area sources, 8,000 are located 

in states (California, Maine, New York, Rhode Island) that already require an enhanced LDAR 
2

program; therefore, the NESHAP will affect 20,000 existing area sources. No new major 

sources are expected over the next three years. We estimate that 2,330 additional area sources 

per year will become subject to the regulation in the next three years, but that the overall number 

of facilities will remain constant due to the retirement of old existing facilities.

The active (previous) ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent burden,

universe, labor rates, and capital costs and ensure these estimates have

been updated.

EPA has addressed each item of concern in the TOC by reviewing the aforementioned

items and updating the estimates accordingly.

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent 

Burden and Cost – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, 

Subpart M) (Renewal). The Federal Government “burden” is attributed entirely to work 

performed by federal employees or government contractors and refer to Table 2 below: Average 

Annual EPA Burden and Cost – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 

CFR Part 63, Subpart M) (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.
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In the Administrator's judgment, perchloroethylene emissions from dry cleaning facilities 

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

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

63, subpart M.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards 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. Emission monitors are used to ensure 

compliance with the standard at all times.

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 and the standard are being met. The performance test may also be 

observed.

The required reports are used to determine periods of excess emissions, identify

problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

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

subpart M.

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.

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.
4

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 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, 

EPA contacted: 1) the Halogenated Solvents Industry Alliance, Inc., at (703) 741-5780; and 2) 

the Drycleaning & Laundry Institute, at (301) 622-1900.

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 

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 
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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 dry cleaning 

facilities that use PCE. The United States Standard Industrial Classification (SIC) codes and 

corresponding North American Industry Classification System (NAICS) codes for the

respondents affected by the standards are provided in the following table.

Standard (40 CFR Part 63, Subpart M) SIC Codes NAICS Codes

Coin-Operated Laundries and Drycleaners 7215 812310

Drycleaning and Laundry Services (except 

Coin-Operated)

7211, 7212, 7216, 

7219, 7251, and 7389

812320

Industrial Launderers 7218 812332

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M). 

A source must make the following reports:

Notifications/Reports

Initial notifications 63.324(a)

Initial report requirements 63.324(a)

Notification of Compliance Status 63.324(b) 63.324(f)

Facility status change 63.324(c)

Exceedance of solvent consumption exemption level 63.324(c)
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A source must keep the following records:

Recordkeeping

Monthly enhanced LDAR 63.322(o)

Date of repairs or purchase orders for repairs 63.324(d)(4)

Solvent purchases per month and calculation of yearly PCE 

consumption 63.324(d)

Weekly or biweekly inspections 63.324(d)

Date of repairs or purchase orders for repairs 63.324(d)

Monitoring of control equipment. 63.324(d)

Design specification and operating manual for dry cleaning systems 

and emission control device 63.324(e)

All reports and notifications 63.10(b)

Record of applicability 63.10(b)(3)

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 20 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Complete monthly LDAR using a handheld instrument.

Adjust existing ways to comply with any previously applicable instructions and requirements.

Modify the existing recordkeeping system for the purpose of recording results of monthly

enhanced LDAR.

Enter information required to be recorded above.

Install, calibrate, maintain, and operate control device and LDAR instruments.
7

Respondent Activities

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.

Adjust 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

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 note the operating conditions under which compliance 
8

was achieved. 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. 

Both 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

The majority of respondents are small entities (e.g., small businesses). According to the 

Federal Register Notice for the 2006 final rule (71 FR 42742), “... over 99 percent of 

commercial dry cleaning firms are small.” When developing the 2006 revisions, EPA took 

special steps to ensure that the burden imposed on small entities was reasonable. The EPA 

conducted several meetings with industry trade associations to discuss regulatory options and the 

corresponding recordkeeping and reporting. In addition, for the 1993 promulgated standards, an 

in depth economic analysis (comparable to a Regulatory Flexibility Analysis) was conducted and 

documented in “Economic Impact of Regulatory Control in the Dry Cleaning Industry,” (EPA 

45/3 91 021). Because of the large number of small businesses in this industry, the reporting 

requirements for the individual cleaning facilities are minimal. There are no quarterly, 

semiannual, or annual reporting requirements as there are with most regulated large industries. 

The burden is further minimized since costly monitoring equipment, such as a continuous 

monitor, is not required. To complete monthly enhanced LDAR, area source dry cleaning 

facilities may use a halogenated leak detector, instead of a more costly PCE gas analyzer as 

required for major sources.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Perchloroethylene 

Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal).
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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.

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 1,564,851 hours (Total Labor Hours from Table 1

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

development of the regulations, 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 costs are 

the ongoing costs to maintain the monitors and other costs such as photocopying and postage. 
10

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

Dry cleaning facilities must use a handheld instrument to conduct leak detection on a 

monthly basis. Major sources must use a PCE gas analyzer (photo ionization detector (PID), 

flame ionization detector, or infrared analyzer) to perform leak checks according to Method 21 

on a monthly basis, while area sources may use a halogenated hydrocarbon leak detector (HHD), 

which is less expensive than the gas analyzer required for major sources. Capital/startup costs 

for new area sources include the purchase of the respective monitor. There are 2,330 new area 

sources and no new major sources expected in the next three-year ICR period.

Annual O&M costs for the monitors apply to both new and existing sources because 

these costs are incurred each year. For the 8,000 area source facilities that are in those states that 

already require an enhanced LDAR program, this ICR does not estimate capital and annual 

O&M costs for the monitors. The annual costs for postage are applied to new sources and 

sources with exceedances that must submit reports. All other existing sources must only keep 

records, and, as such, an annual photocopying charge is assessed for all those sources keeping 

records. These costs are summarized in the table presented below.

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

PID $3,300 0 0 $95 12 $1,140

HHD $250 2,330 $582,500 $14 20,000 $280,000

Initial 

notification & 

compliance 

report 

- - - $6.37 2,330 $14,842

Report 

exceed 

consumption 

cutoff

- - - $6 117 $702

Photocopying - - - $2.40 28,012 $67,229

TOTAL $582,500 $363,913

The total capital/startup costs for this ICR are $582,500. This is the total of column D in 

the above table. 

The total O&M costs for this ICR are $363,913. 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 this ICR is estimated to be $946,413.
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6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

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

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

emissions, and the publication and distribution of collected information. 

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

$247,566. 

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), 2012 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 

Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal).

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

Based on our research for this ICR, approximately 28,012 existing respondents will be 

subject to the standards on average over the next three years. It is estimated that an additional

2,330 area sources, as well as no major sources, will become subject per year. The overall 

average number of respondents, as shown in the table below, is 28,012 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

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 No Longer 

Subject 2

(E)

Number of 

Respondents

(E=A+B+C-D)

1

2,330 28,012 0 2,330 28,012

2

2,330 28,012 0 2,330 28,012

3

2,330 28,012 0 2,330 28,012
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Number of Respondents

Average 28,012

1

New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard 

existing respondents submit initial notifications.

2 We assume that the overall number of facilities will remain constant due to retirement of old existing 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 28,012. 

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

New

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

Write Initial Notification Report 2,330 1 25,682 28,012

Compliance Method Report 1,631 1 N/A 1,631

Solvent Consumption Report 699 1 N/A 699

Report Exceed Consumption 

Cutoff 117 1 N/A 117

Total 30,459

The number of Total Annual Responses is 30,459.

The total annual labor costs are $156,283,515. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Perchloroethylene 

Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (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 in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 1,564,851 hours at a cost of $156,283,515. Details 

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

Cost – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) 

(Renewal). 
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Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 51 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $946,413. 

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 

5,494 labor hours at a cost of $247,566. See Table 2 below: Average Annual EPA Burden and 

Cost – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) 

(Renewal).

6(f) Reasons for Change in Burden

There is an increase in burden costs from the most recently approved ICR for both the 

respondents and the Agency, and is due to an increase in labor rates. This ICR uses updated 

labor rates from the Bureau of Labor Statistics to calculate respondent burden costs. This ICR 

also uses updated labor rates from OPM to calculate EPA burden costs.

There is an increase in respondent labor hours due to revisions in the calculation of 

burden hours. The previous ICR included technical and managerial labor hours only in its 

burden calculations. To be consistent with the estimation methodology used in other ICRs, 

we have revised the calculations to include clerical labor burden, and have assumed it to be equal 

to 10 percent of technical labor hours. These revisions resulted in an increase in the respondent 

labor burden and associated cost.

There is an increase in the total O&M cost for respondents. This increase is due to a 

mathematical error identified in the previous ICR and is not due to changes in individual O&M 

costs or the number of corresponding respondents.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 51 hours per response. “Burden” means the total time, effort, or financial 

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

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

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

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

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

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

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

the information.
14

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

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

Numbers for EPA 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-2012-0659. 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-2012-0659 and OMB Control Number 2060-0234 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 – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, 

 Subpart M) (Renewal)

Burden Item

A B C D E F G H

Hrs per 

occurrence

Occurrences 

per 

respondent 

per year

Hrs per 

respondent 

per year

Respondents 

per yeara

Technical 

hrs per 

year

Management 

hrs 

per year

Clerical 

hrs per 

year

Total cost per 

year ($)b

(AxB) (CxD) (Ex0.05) (Ex0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions c1 1 1 2,330 0 2,330 0 282,955.2

B. Required activities N/A

C. Create Information N/A

D. Gather existing information

Initial report information 2 1 2 2,330 4,660 233 466 518,904.98

Solvent consumption 1 1 1 2,330 2,330 116.5 233 259,452.49

Compliance method report d1 1 1 1,631 1,631 81.55 163.1 181,616.74

E. Write Report

Initial notification report 1 1 1 2,330 2,330 116.5 233 259,452.49

Compliance method report c, d 1 1 1 1,631 0 1,631 0 198,068.64

Solvent consumption report c, e 0.25 1 0.25 699 0 174.75 0 21,221.64

Report-exceed consumption cutoff c, f 1 1 1 117 0 117 0 14,208.48

Subtotal for Reporting Requirements 16,846.40 1,735,880.66

4. Recordkeeping Requirements

A. Read Instructions See 3A

B. Plan activities g1 1 1 2,330 2,330 0 0 233,535.9

C. Implement activities

Above consumption cutoff: Weekly 

LDAR g, h, i 0.75 52 39 19,600 764,400 0 0 76,615,812

Below consumption cutoff: Bi- 0.75 26 19.5 8,400 163,800 0 0 16,417,674
16

Burden Item

A B C D E F G H

Hrs per 

occurrence

Occurrences 

per 

respondent 

per year

Hrs per 

respondent 

per year

Respondents 

per yeara

Technical 

hrs per 

year

Management 

hrs 

per year

Clerical 

hrs per 

year

Total cost per 

year ($)b

(AxB) (CxD) (Ex0.05) (Ex0.10)

weekly LDAR g, i, j

Major: Monthly enhanced LDAR k, l 1 48 48 12 576 28.8 57.6 64,139.33

Major: Weekly Carbon adsorber 

monitoring l, m 0.25 208 52 12 624 31.2 62.4 69,484.27

Area: Monthly enhanced LDAR n, o 0.75 12 9 20,000 180,000 9,000 18,000 20,043,540

D. Develop record system

Solvent consumption g1 1 1 2,330 2,330 0 0 233,535.90

Enhanced LDAR g1 1 1 2,330 2,330 0 0 233,535.90

Monitoring records d, g 1 1 1 1,631 1,631 0 0 163,475.13

Carbon adsorber monitoring recordsp1 1 1 0 0 0 0 0

E. Time to enter information

Monthly records of solvent 

consumption q, r, s 0.25 12 3 28,012 84,036 9 0 8,424,021.24

Above consumption cutoff: Records 

of weekly inspections h, i, s 0.25 52 13 19,600 254,800 39 0 25,543,340.16

Below consumption cutoff: Records 

of bi-weekly inspections g, i, j 0.25 26 6.5 8,400 54,600 0 0 5,472,558

Major: Enhanced LDAR See 4C

Major: Carbon adsorber monitoring See 4C

Area: Enhanced LDAR See 4C

F. Time to Train personnel

Leak detection t, u 1 2 2 2,330 4,660 4,660 0 1,032,982.2

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 1,548,005 154,547,634.03

TOTAL ANNUAL BURDEN (rounded) 1,564,851 $156,283,515
17

Assumptions:

a.

 We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources over 

the next three years. We have also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NESHAP over 

the three-year period of this ICR.

b.

 This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent 

of Technical hours.

c.

 This task requires management hours only.

d.

 This is based on the estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the cutoff and thus required to perform this task.

e

. This is based on the estimate that 699 (30 percent) of the 2,330 new facilities will be below the cutoff and thus required to perform this task.

f.

 We estimate that 5 percent of new facilities each year will exceed the cutoff, thus requiring submission of the exceed-consumption cutoff report.

g.

 This task requires only technical employee hours.

h

. Occurrences are based on weekly inspection, assuming 52 weeks per year.

i

. We have assumed that of 28,000 perchloroethylene dry cleaners 19,600 (70 percent) will be above the per consumption cutoff, which will require that the 

cleaner conduct weekly leak detection and repair. The remaining 8,400 perchloroethylene dry cleaners will be below the consumption cutoff and are only 

required to conduct bi-weekly leak detection and repair.

j.

 We have assumed that facilities below cutoff performs leak detection and repairs on a bi-weekly basis.

k.

 Major sources contain an average of four machines. Task requires 1 hour times 4 machines/major source.

l.

 Approximately 12 existing major sources are subject to the NESHAP.

m

. Major sources contain an average of four machines. Task requires 0.25 hour times 4 machines/major source.

n.

 Area sources contain an average of one machine. Task requires 0.75 hour times 1 machine/area source. 

o.

 Approximately 8,000 existing area sources are located in states that already require enhanced monitoring; therefore, 20,000 existing area sources are subject to 

the NESHAP's enhanced LDAR program.

p

.

 No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbon adsorber 

monitoring record systems.

q.

 Occurrences are based on twelve months rolling average of PCE consumption, determined once per month. 

r.

 This is based on 28,000 area sources and 12 major sources performing this task every year.

s.

 This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume only three major 

sources will require managerial review.

t.

 Estimate includes hours for training one owner/operator and one employee.

u.

 This task requires an equal amount of management and technical employee hours.
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63,

 Subpart M) (Renewal)

Burden Item

A B C F G H

EPA technical 

hrs per 

occurrence

Occurrences 

per 

Year a

Technical 

hrs per 

year 

(AxB)

Management 

hrs per 

year 

(Cx0.05)

Clerical 

hrs per 

year 

(Cx0.10)

Total cost 

per year 

($)b

1. Report review

A. Initial notification report 1 2,330 2,330 116.5 233 120,751.09

B. Solvent consumption report c1 699 699 34.95 69.9 36,225.33

C. Report-exceed consumption cutoff d1 117 117 5.85 11.7 6,063.47

D. Compliance method reporte1 1,631 1,631 81.55 163.1 84,525.76

Total Labor Burden and Cost (rounded) 5,494 $247,566

Assumptions:

a.

 We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources over 

the next three years. We have also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NESHAP over 

the three-year period of this ICR.

b.

 This cost is based on the average hourly labor rate as follows: Technical $46.21 (GS-12, Step 1, $28.88 + 60%); Managerial $62.27 (GS-13, Step 5, $38.92 + 

60%); and Clerical $25.01 (GS-6, Step 3, $15.63 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 

10 percent of Technical hours. These rates are from the OPM, 2012 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.

c.

 We assume that 30 percent of new sources will consume less than 140 gallons of PCE per year.

d.

 We assume that five percent of new sources will have to report-exceed consumption cutoff.

e.

 We assume that 70 percent of new area sources will consume between 140 to 200 gallons of PCE per year.