**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 I CR 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 Cle an 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 monthl y leak detection using handheld instruments is performed. These standards appl y to existing and new dry cleaning facilit ies that use perchloroeth yl ene (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 an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities 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 directl y 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

28,0 12 sources are currentl y subject to the standard s , 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 LDAR2

program; therefore, the NESHAP will affect 20,000 existing area sources. No new major s ources 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 o ld existing facilities. The active (previous) IC R had the following Terms of Clearance (TOC):
When this I CR 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 accordingl y. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Perchloroeth yl en e Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

. T he Federal Government “burden ” is attributed entirely to work performed b y federal employees or government contractor s 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 establi sh 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 emiss ion 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 monito ring 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) ke ep 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 reasonabl y require.3

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 standard s ensure compliance with the applicable regulations which where promulg ated 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

w ith the emission standard. E mission 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 o f the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 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

.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 b y industry , in compliance with the record

keeping and reporting provisions in the standard, is the 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 compliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is an y 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 thi s I CR, 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 re newal 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. I f 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**
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 stand ards. 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 permit program is based. T he retention of records for five ye ars allow s EPA to establish th e 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 violators have violations extending beyond five ye ars. In addition, EPA would be prevent ed 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 made5

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** 
T he respondents to the recordkeeping and reporting requirements are dry cleaning facilities that use PCE. The United States Standard Industrial Classification (SI C) code s and corresponding North American Industry Classification System (NAICS) codes for the respondents affected b y the standards are provided in the following table.

**Standard (40 CFR**  **P art 63,**  **S ubpart 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 b y the NESHAP for Perchloroeth yl ene Dry

Cleaning Facilities (40 CFR Part 63, Subpart M)

. A source must make the following reports:

**Notification s**  **/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)6

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 yearl y PCE consumption 63.324(d) Weekly or biweekl y 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 sy stems 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 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 e stimated that approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Complete monthly

L DAR using a handheld instrument. Adjust existing way s to comply with an y previously applicable instructions and requirements. Modify the existing recordkeeping s ys tem 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust 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 type of monitoring equipment has sign ificantly 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, analy sis, 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, 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 capability to comply with the emission standard , and note the operating conditions under which compliance8

wa s achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. 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 regulatory agencies, EPA regional offices and EPA headquarters. Both EPA and its delegated Authorities 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** 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 associatio ns to discuss regulatory options and the corresponding recordkeeping and reporting. In addition, for the 1993 promulgated standards, an in depth economic analy sis (comparable to a Regulatory Flexibility

Analy sis) 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 quarterl y, 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 costl y PCE gas anal yz er as required for major sources. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in b elow Table 1: Annual Respondent Burden and Cost

– NESHAP for Perchloroeth yl ene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)

.9

**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 consi stent 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 per son 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 requirement s is estimated to b e 1,564,851 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 s , Agency knowledge and experience with the NESHAP pro gram, 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 rat es 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 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. Th e 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 mo nthly

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. Th ere are 2,330 new area sources and no new major sources expected in the next three

- ye ar IC R period. Annual O& M costs for the monitors apply to both new and existing sources because these costs are incurred each ye ar. 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 photocop yi ng 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

- - - $2.4 0 28,012 $67,229 TO TAL $582,500 $363,913 The total capital/startup costs for this I CR are $ 582,500

. This is the total o f column D in the above table. The total O&M costs for this I CR 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 th is ICR is estimated to be $ 946,413.11

**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 $ 247,566

. 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 Personnel Management (OPM) , 201 2 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 app ear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Perchloroeth yl ene 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 I CR, approximately 28,012 existing respondents will be subject to the standard s on average over the next three years . It is estimated that an additional 2,330 area sources , as wel l 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 ye ars covered b y this ICR. **Number of Respondents**

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 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 28,01212 **Number of Respondents** Average 28,012 1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondent s submit initial notifications. 2 We assume that the overall number of facilities will remain constant due to retirement of old existing 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 28 , 012

. The total number of annual responses per ye ar 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 Com pliance 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

. Th e 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 Perchloroeth yl ene 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, respectivel y , 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)

.13

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to averag e 5 1 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 recentl y 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 I CR 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 I CR included technical and managerial labor hours only in its burden calculations

. To be consistent with the estimation methodology used in other I CRs, we have revised the calculations to include clerical labor burden , and have assumed i t 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 o r the number of corresponding respondents. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of inf ormation is estimated to av erage 5 1 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 instructi ons; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y w ith 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.
T o 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 th is I CR 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 t he index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 13 01 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone numbe r for the docket center i s (202) 566

- 1 752

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EP A 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.15

**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 H**  **rs per**  **occurrence Occurrences** 

**per respondent**  **per year H**  **rs per**

**respondent per year**  **Respondents**

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

**h rs per**  **year Managem**  **ent**

**hrs per year**  **Clerical**

**h rs 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 c 1 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 Com pliance method report d 1 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 Com pliance 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**  **.4 0**  **1,735,880.66 4. Recordkeeping Requirements**  A. Read Instructions See 3A B. Plan activities g 1 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 16,417,67416

**Burden Item A**  **B C**  **D E**  **F G**  **H H**  **rs per**  **occurrence Occurrences** 

**per respondent**  **per year H**  **rs per**

**respondent per year**  **Respondents**

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

**h rs per**  **year Managem**  **ent**

**hrs per year**  **Clerical**

**h rs 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 mo nitoring 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 g 1 1 1 2,330 2,330 0 0 233,535.90 Enhanced LDAR g 1 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 records p 1 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 replac ed by 2,330 new area sources over the next three years. We have also assumed that there are 12 existing major sources and that n o 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, an d 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 th e 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 requi re 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 . M ajor 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 sourc es 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 mo nitoring 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 Perchl**  **oroethylene 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 Y**  **ear a**  **Technical**

**hrs per year**  **(AxB) Managem**  **ent**

**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 c 1 699 699 34.95 69.9 36,225.33 C. Report

- exceed consumption cutoff d 1 117 117 5.85 11.7 6,063.47 D. Compliance method report e 1 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 replac ed by 2,330 new area sources over the next three years. We have also assumed that there are 12 existing major sources and that n o 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 follow s: 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 loc ality , 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 fiv e 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.