2004 Michigan App

Final Report: Michigan Environmental Results Program (ERP) for the
Dry Cleaning Sector

Appendix A
Michigan Environmental Results Program
Statistical Analysis

Prepared by:
Richard Krop, The Cadmus Group, Inc.
with support from Michael Crow and
Dr. A. Richard Bolstein (consultants)
April 2009

Analysis of the Michigan Department of Environmental Quality Retail Dry Cleaner ERP
Inspection Data
The Michigan Department of Environmental Quality (DEQ) is implementing an Environmental Results
Program (ERP) for retail dry cleaners. The DEQ conducted inspections of two different samples of
dry cleaners that use perchlorate solvents. Baseline inspections were conducted for a sample of 262
establishments. Dry cleaners were then given the opportunity to voluntarily self-certify their
environmental performance. Follow-up inspections were conducted at a second random sample of
272 establishments after self-certification. During both rounds of inspections, the DEQ collected data
on a large number of environmental business practices. The inspections assess facilities against a
checklist of practices, indicating which ones are being used at each facility. The primary objective of
the program is the protection of air and water quality. Secondary objectives include control of
hazardous waste for underground injection control and addressing brownfield issues.
1. Description of the Data
The data from the two rounds of inspections along with the self-certification results were provided by
DEQ. The check list question numbers are not the same in the two rounds of inspections. The
question numbers from the second round were used for this analysis. (Questions that were in the
baseline but not the follow-up round of inspections were renumbered and added the list of questions.)
A consolidated data base was created that combined the data from the two rounds in a consistent
format. Exhibit 1 shows the questions and their numbers in the combined dataset.
The data were provided by DEQ in the Access data file “Dry Cleaners Audit Results.mdb,” dated
March 4, 2009. The data were imported into Stata for the analysis. The baseline inspection
responses were 1 for “Yes”, 2 for “No”, or 3 for “N/A”. Some questions were left blank as well. Yes
responses were coded as 1 in the analytical file; No’s were recorded as zeros. Special codes were
created for N/A and blanks. The follow-up inspection data used the same coding. Responses for two
establishments for one question each was “yh.” This response was recoded as blank. (This is
consistent with the treatment of this response in the summary of the data provided by DEQ.)
Self-certification data also were provided in the same Access file. Unlike the baseline and follow-up
data, the self-certification responses are recorded as Yes or No. The data were recoded into numeric
form—Yes was coded as 1 and No was coded as 0.. As with the inspection data, “yh” were recoded
as blanks. “N/A”, “N/”, and “n/a” were all coded as “N/A”. Several other responses also were recorded:
“b”, “ky”, “t”, and “u”. These were given a separate code of “Other” and were treated like blanks.
The data provided were in the “wide” format: there was one record for each establishment and one
variable for each question. The data were reshaped for the analysis. Each establishment has multiple
rows in the new data set, one row for each question. The responses to the questions are shown in a
single field, and a new field indicates which question each response corresponds to. The baseline
and follow-up inspection data are stored in one dataset. The self-certification data are in a separate
data set. Exhibit 2 shows the variables in the combined dataset.
2. Analysis of Results
2.1. Sample Design and Analysis
Stratified random samples were drawn in each round of inspections. The baseline inspections were
divided into four strata, one for each inspector based largely on geographic region. The baseline
sample size by strata is:

Appendix A - 1

Strata (Inspector)
Jack
Joe
Jong
Karl
Total

Sample
Size
49
77
89
47
262

The follow-up inspections were divided into eight strata. The additional strata were necessary
because one of the inspectors dropped out of the second round of inspections. The eight strata
represent a cross-tabulation of two groups of inspectors: the inspectors that were originally scheduled
to conduct the follow-up inspections and the inspectors that carried out the follow-up inspections. The
follow-up sample by strata is:
Strata
Scheduled Actual
Inspector
Inspector
Jack
Jack
Karl
Jack
Joe
Joe
Jong
Joe
Jong
Jong
Jack
Jong
Joe
Jong
Karl
Jong
Total

Sample
Size
38
21
82
26
8
22
50
25
272

The estimated proportions and scores reflect these sample designs. The estimates are weighted by
the inverse of the selection probabilities. The estimates of the standard error reflect the sampling
strata and incorporate a finite population correction.
Three sets of analyses were conducted on each round of inspections. The first analysis examines the
proportion of establishments that responded yes to each question on the check list. The second
analysis looks at a facility-based score that is based the responses to a subset of the check list
questions. The third analysis looks at aggregate achievement rates using the same subset of
questions. The results are reported for each round with a 90 percent confidence interval. The
differences between rounds also are reported, again with a 90 percent confidence interval.
Estimates of the confidence intervals for the proportions use the normal approximation of the binomial
distribution. (Cochran, p. 107.) The estimates of the facility-based score and its confidence interval
assumes the score is a continuous variable. (Cochran, p. 107.) A ratio estimate is used to estimate
the aggregate achievement rate. (Cochran, p. 150.) Differences between the two rounds of
inspections assume the two samples are independent with unequal variances. (Snedecor and
Cochran, p. 96.)
The self-certification data also are available. The establishments that self-certified are treated as a
census of self-certifiers; therefore, there is no sampling error associated with these estimates and no
confidence intervals are provided. Estimates of the proportion of self-certifiers that responded Yes to
each question is reported, along with facility scores and aggregate achievement rates.
The analysis was conducted using Stata, version 10.0. The results were exported to Excel for
presentation. The results are in the file MichiganResults(version number).xls. The analyses are
contained in separate tabs within each workbook, as described below.
Appendix A - 2

2.2. Analysis of Each Round of Inspections
2.2.1. Analysis of Proportional Data
The number of establishments that answered No, Yes, N/A, or left the response blank is reported for
each question in both rounds. The number of valid observations—those that answered No or Yes—
also is shown. The design-based estimate of the proportion and the 90 percent confidence interval is
shown for each question in each round. The difference between the two rounds and the 90 percent
confidence interval for the difference is shown for each question as well. Differences between rounds
that are statistically significant are indicated. The results are shown in the tab “Round 1 and Round 2
Proportions.”
The check list included three questions to determine whether establishments are improperly emptying
wastewater into drains that flow to wastewater treatment plants. Question 5-1 asks whether the
establishment is connected to a sewer system. If it is, the establishment is in question 5-2 asked
whether it empties wastewater from the dry cleaning machine to a drain, sink, or toilet. Question 5-3
asks if the system has permission from the wastewater treatment plant to dispose of the wastewater
from the dry cleaning equipment. The establishment is considered to be in compliance if it does not
empty the wastewater into a drain, sink, or toilet, or if it has permission to do so. The proportions
sheet includes the proportion of systems that are in compliance.
2.2.2. Analysis of Facility-Based Scores and Aggregate Achievement Rates
An EBPI score was created for each facility. The score is equal to the number of good responses on
EBPI measure questions divided by the total number of EBPI measure questions. The EBPI measure
questions are:
1-4
1-7
1-19
3-3
3-10
3-22
5-2 and 5-3
Question 5-2 asks whether the establishment empties wastewater from dry cleaning machines into a
drain, toilet, or sink. Question 5-3 asks whether the establishment has permission from their
wastewater treatment to do so. Together, these two variables whether the establishment is in
compliance. If they answered “No” to 5-2 or they answered “Yes” to 5-3, the establishment is
considered to be in compliance and receives a “good” score for its facility score.
The deciles, the mean, and 90 percent confidence for the mean are presented for the facility score for
each round. The mean difference between the two rounds and the 90 percent confidence interval for
this difference are presented as well. The results are shown in the tab “Round 1 and Round 2
Scores.”
An aggregate achievement rate is constructed based on the EBPI measure. The same questions
used to build the facility-based score are used for to develop this achievement rate. The achievement
rate is the ratio of the good responses to all responses, across all establishments. The ratio—and 90
percent confidence intervals—were computed. The difference in between rounds and the 90 percent
confidence interval for the differences are also computed. The results are shown in the tab “Round 1
and Round 2 Scores.”

Appendix A - 3

2.3. Analysis of Self-Certification Data
2.3.1. Analysis of Proportional Data
The number of establishments that answered No, Yes, N/A, left the response blank, or had another
response is reported for each question. The number of valid observations—those that answered No or
Yes—also is shown. The estimate of the proportion of self-certifiers with valid responses that
responded Yes is shown for each question. The results are shown in the tab “Self-Certification
Proportions.”
2.3.2. Analysis of Facility-Based Scores and Aggregate Achievement Rates
The EBPI score was created for each facility. As with the inspection data, the score is equal to the
number of good responses on EBPI measure questions divided by the total number of EBPI measure
questions. The deciles and the mean are presented. The results are shown in the tab “SelfCertification Scores.”
The aggregate achievement rate is constructed based on the EBPI measure. The same questions
used to build the facility-based score are used for to develop this achievement rate. The achievement
rate is the ratio of the good responses to all responses, across all establishments. The results are
shown in the tab “Self-Certification Scores.”
3. References
Cochran, W. G. 1977. Sampling Techniques, 3rd Edition, New York: Wiley.
Snedecor, G. W., and W. G. Cochran. 1989. Statistical Methods, 8th Edition, Iowa: Iowa State Press.

Appendix A - 4

Exhibit 1. Check List Items
Round 1 Round 2
Question Question
Number
Number
Question Text
Is the Machine operated according to manufacturers’
1-1
1-1
specifications?
1-2
1-2
Are machine operating manuals kept on site?
Is the dry cleaning machine door kept closed, except for
1-3
1-3
loading and unloading?
Does facility keep a log of the gallons of perc purchased
1-4
1-4
each month?
1-5
1-5
Are all perc purchase logs kept on file for five years?
1-6
1-6
Are all cartridge filters drained 24 hours before removal?
Are specified components of the machine inspected
1-7
1-7
weekly/bi-weekly for perceptible leaks?
Are specified components inspected monthly for vapor
leaks while in operation with a halogenated hydrocarbon
detector PCE gas analyzer?
1-8
If a leak is detected, is it repaired in 24 hours or if it
cannot be repaired in 24 hours are parts ordered within
2 working days and installed within 5 days of receiving
them?
1-8
1-9
does facility keep a log of the date of any necessary
1-9
1-10
repairs made to the machine?
Does facility keep a log of machine inspections that
1-10
1-11
identifies any components that are leaking?
Small Area Source? Dry-to-dry machine installed before
12/9/91 AND did facility purchase less than 140 gallons
1-11
1-12
of perc per year during all previous 12-month periods?
Do all dry-to-dry machines installed before 12/9/91 have
an external refrigerated condenser OR a carbon
adsorber that was installed prior to 9/22/93? (Choose
N/A if machine installed after 12/9/91)
1-12
1-13
Do all dry-to-dry machines installed after 12/9/91 have
an internal refrigerated condenser? (Choose N/A if
machine installed before 12/9/91)
1-13
1-14
Do all dry-to-dry machines initially installed after
12/21/05 have an internal carbon adsorber AND
refrigerated condenser? (Choose N/A if machine
1-14
1-15
installed before 12/21/05)
If major source, is concentration of perc in the machine
drum at the end of the cycle measured weekly with a
colorimetric detector tube or PCE gas analyzer? (choose
N/A if not major source)
1-16
1-17
Is the concentration of perc less than 300 ppm?
Are the external refrigerated condensers on a vented
machine routed properly so the air-perc stream is not
1-18
vented directly to atmosphere while drum is rotating?
Is the outlet temperature of the vapor stream passing
through the cooling coil (refrigerated condenser) read
1-15
1-19
weekly and is it equal to or less than 45deg F (±2° F) or

Included
in EBPI
Score
No
No
No
Yes
No
No
Yes

No

No
No
No

No

No

No

No

No
No

No

Yes

Appendix A - 5

Exhibit 1. Check List Items
Round 1 Round 2
Question Question
Number
Number
Question Text
7.2deg C (±1.1degC)?

1-20
1-21
1-16

1-22

1-17

1-23
1-24

1-18

1-25

1-19

1-26

1-20

1-27

1-21

1-28

1-22

1-29

1-23

1-30

1-24

1-31
1-32

1-25

1-33

2-1

2-1

2-2
2-3

2-2
2-3

2-4

2-4

2-5
2-6

2-5
2-6

Appendix A - 6

Are the high and low pressures of the refrigeration
system read and recorded on a weekly basis? (Choose
N/A if no pressure gauges)
Are the pressures within those specified by the
manufacturer? (Choose N/A if no pressure gauges)
Is the date, temperature sensor or pressure gauge
monitoring results recorded weekly?
Is the date, temperature sensor or pressure gauge
monitoring results kept on file for five years?
Is the machine equipped with an external carbon
adsorber?
If an external carbon adsorber is installed on a vented
machine, is none of the air-perchloroethylene gas-vapor
stream allowed to bypass the carbon adsorber to the
atmosphere?
Is the concentration of perc in the exhaust of the external
carbon adsorber measured weekly using a colorimetric
detector tube or PCE gas analyzer?
Is the concentration of perc in the exhaust of the external
carbon adsorber less than 100 parts per million per
volume?
Are the date and colorimetric detector tube monitoring
results recorded weekly?
Are the date and colorimetric detector tube monitoring
results kept on file for 5 years?
Are necessary repairs made to the refrigerated
condenser and/or carbon adsorber?
Was a Notification of Compliance Status Form submitted
to the MDEQ?
Has the facility paid their air quality fee?
Has the facility paid their MDEQ Dry Cleaning License
Fee?
Does the facility have a dry cleaning machine that uses
a petroleum solvent?
Is the TOTAL manufacturers’ rated dryer capacity for all
dryers used for petroleum solvent equal to or greater
than 84 pounds (38 kilograms)? (see explanation below)
AND Was the equipment installed after December 14,
1982?
Is the filter a cartridge filter?
Are cartridge filters drained in their sealed housings for
at least eight hours prior to their removal?
Is leak inspection and leak repair cycle information in the
operating manual and on a clearly visible label posted on
the dryer?
Was the dryer installed between December 14, 1982

Included
in EBPI
Score

No
No
No
No
No

No

No

No
No
No
No
No
No
No
No

No
No
No

No
No

Exhibit 1. Check List Items
Round 1 Round 2
Included
Question Question
in EBPI
Number
Number
Score
Question Text
and September 21,1984
Does facility use more than 4,700 gallons (17,791 liters)
2-7
2-7
of solvent per year?
No
2-8
2-8
Is the dryer a solvent recovery dryer?
No
Was an initial performance test conducted to verify that
the flow rate of recovered solvent from the solvent
recovery dryer at the termination of the recovery cycle is
2-9
2-9
no greater than 0.05 liters per minute?
No
Does the facility have a copy of the initial performance
2-10
2-10
test?
No
Does facility generate less than 220 pounds of
3-1
3-1
hazardous waste per month?
No
Does facility have a site identification number when
needed for waste shipment? (Choose N/A if you do not
ship waste off-site)
3-2
3-2
No
Does each shipment of hazardous waste or liquid
industrial waste have a manifest or receipt from the
waste hauler that identifies manifest number and the
type and quantity of waste shipped?
3-3
3-3
Yes
Is the waste properly listed on the manifest form (e.g.,
F002) and is the quantity shipped entered on the
3-4
3-4
manifest form?
No
Has a copy of each manifest been signed by the waste
hauler and submitted to the MDEQ by the 10th of the
3-5
3-5
month following the shipment?
No
Are all copies of the manifest that are signed by the
hauler and disposal facility kept on file for at least 3
years?
3-6
3-6
No
Is each storage container labeled with the name of the
contents (e.g., perc waste, filters) and is the label
readable? Container may be labeled using purchased
labels, a stencil, or the completed shipping label.
3-7
3-7
No
Is each container that is being shipped labeled according
to the US DOT Shipping requirements? (E.g. does it
3-8
3-8
have a completed US DOT shipping label?)
No
Is less than 2,200 pounds (5 drums) of hazardous waste
3-9
3-9
accumulated on site?
No
Are containers in good condition and kept closed except
3-10
3-10
when adding or removing waste?
Yes
Is the exterior of the storage containers kept free of the
3-11
3-11
liquid waste and its residue?
No
Are containers protected from the weather? If storing
containers outdoors, they are placed on an impervious
surface and protected from the elements.
3-12
3-12
No
Are containers protected from fire and secure from
vandalism and physical damage such as that caused by
fork lifts or other equipment?
3-13
3-13
No

Appendix A - 7

Exhibit 1. Check List Items
Round 1 Round 2
Question Question
Number
Number
Question Text
Are the containers compatible with the type of waste
being stored in them and are containers that have
wastes that could react with each other separated by a
physical barrier, like a dike, berm, or wall, or by a safe
distance?
3-14
3-14
Is there adequate aisle space for unobstructed
3-15
3-15
movement of emergency equipment and personnel?
If contents have a flashpoint below 200° F, are they
isolated according to local fire department
3-16
3-16
recommendations?
If a leak or spill occurs does facility immediately stop and
3-17
3-17
contain the leak and repair or replace the container?
Have employees been trained on how to properly
3-18
3-18
manage waste?
Does hazardous waste storage area have secondary
containment such as a curb, ramped pad, dike, or
3-19
3-19
containment room?
Are you doing any of the best management practices
3-20
3-20
listed in Table 3.1 of the Self Audit Workbook?
Are hazardous wastes that are a liquid shipped to a
licensed recycling, treatment, storage, or disposal
facility?
3-21
3-21
Is facility complying with the following?
-Liquid haz waste not disposed of in dumpster, landfill,
incinerator
-Waste not put into municipal sanitary sewer without
WWTP authorization
-Haz waste not into septic tank, storm drain, into stream
or ground
3-22
3-22
Is facility doing any of the following best management
practices?
3-23
3-23
Does facility recycle fluorescent tubes, incandescent
lamps, and/or dry cell batteries?
3-24
3-24
Are fluorescent tubes, incandescent lamps, dry cell
batteries, stored for recycling according to the following
requirements?
3-25
3-25
Have employees who handle fluorescent tubes,
incandescent lamps, and dry cell batteries, been
informed about proper handling of these waste materials
3-26
3-26
and any emergency procedures?
Does facility…? Recharge and use rechargeable
batteries; Use low-mercury, energy-efficient
fluorescent/HID light bulbs;
Keep recycling or disposal receipts for 3 yrs and know
who recycles or disposes of them
3-27
3-27
Is all solid waste hauled to a recycling center or a
licensed disposal facility, which includes: a landfill,
3-28
3-28
incinerator, or a transfer/processing facility?

Appendix A - 8

Included
in EBPI
Score

No
No

No
No
No

No
No

No

Yes
No
No

No

No

No

No

Exhibit 1. Check List Items
Round 1 Round 2
Question Question
Number
Number
Question Text
Is waste stored in leak-proof, covered containers (e.g.
covered dumpster)?
3-29
3-29
Does your facility recycle or reuse office paper,
corrugated cardboard, wood pallets, 55-gallon clean
drums, other containers, or scrap metal?
3-30
3-30
Does your facility store fuel, solvents, or other material in
4-1
4-1
an aboveground storage tank?
4-2
4-2
Does the storage tank have secondary containment?
Is the tank any of the following? Used to supply
flammable or combustible liquid w/storage capacity of
>1100 gal; Flammable compressed gas or LPG
container fill location; LPG tank w/water capacity >2000
gal or 2 or more tanks w/aggregate capacity >4000gal
4-3
4-3
Has the tank been certified by the MDEQ, Waste and
Hazardous Materials Division?
4-4
4-4
Does the tank meet the requirements in Table 4.1 of the
Self Audit Workbook?
4-5
4-5
5-1
Does facility have a boiler?
4-51
Does facility keep a record of the amount of fuel the
boiler uses per month (e.g., monthly bill from utility
5-2
company)?
4-52
Does the boiler stack discharge vertically upwards and
are all devices used to prevent precipitation from
entering the sack not restricting the vertical flow of the
5-3
exhaust gas stream?
4-53
5-4
Does boiler comply with the requirements below?
4-54
Is Facility doing any of the following best management
practices for boilers?
5-5
4-55
Is facility connected to a sewer system that goes to a
wastewater treatment plant?
6.1
5-1
Does facility empty wastewater from any dry cleaning
6.2
5-2
machine into a drain, toilet, or sink?
Does facility have permission from the wastewater
treatment plant to dispose of wastewater from dry
cleaning machine into the sewer system? (e.g., permit,
6.3
5-3
letter, or written authorization from WWTP)
Does facility empty wastewater from laundry area, air
compressor, boiler, vacuum, or floor cleaning into a
6.4
5-4
drain, toilet, or sink?
Does facility have permission from the wastewater
treatment plant to dispose of wastewater from laundry
area, air compressor, boiler, vacuum, or floor cleaning
into the sewer system? (e.g., permit, letter, or written
authorization from WWTP)
6.5
5-5
Does facility use an evaporator device to dispose of
6.6
5-6
wastewater?
6.7
5-7
Is any wastewater collected in a holding tank?
6.8
5-8
Is wastewater that is collected in holding tank disposed

Included
in EBPI
Score
No

No
No
No

No
No
No
No

No

No
No
No
No
Yes

Yes

No

No
No
No
No
Appendix A - 9

Exhibit 1. Check List Items
Round 1 Round 2
Question Question
Number
Number
Question Text
of by a licensed and registered hauler?
6.9
5-9
Does any wastewater from facility go to a septic system?
Does facility empty wastewater from dry cleaning
machine, laundry area, air compressor, boiler, vacuum,
or floor cleaning onto the ground, storm sewer, steam, or
6.1
5-10
ditch?
6.11
5-11
Are there any floor drains in facility?
Do they empty to the sewer system that goes to a
6.12
5-12
wastewater treatment plant or a holding tank?
Have floor drains that empty to a storm sewer, stream,
or ditch been plugged with concrete or a locked down
cement cap so that they are inaccessible and unusable?
6.13
5-13
Are there at least two portable fire extinguishers (or one
extinguisher for perc dry cleaning facilities) with at least
a 2a,10bc rating at the facility and is one of those fire
7.1
6-1
extinguishers mounted near the dry cleaning machine?
7.2
6-2
Does facility have an approved organic vapor respirator?

Included
in EBPI
Score
No

No
No
No

No

No
No

Questions 1.32 and 1.33 were not asked in round 2. They correspond to round 1 questions
1-24 and 1-25, respectively. Questions 4.51, 4.52, 4.53, 4.54, and 4.55 were not asked in
round 2. They correspond to round 1 questions 5-1, 5-2, 5-3, 5-4, and 5-5, respectively.

Exhibit 2: Contents of Dataset used in Analysis of Michigan ERP
Field
Descriptions
round
Baseline (1), follow-up (2) round of inspections, or selfcertification data (3)
facility
Facility number (unique facility identifier)
name
Facility name
inspector
Name of inspector
question
Check list question
q1
Check list question number from baseline check list
response
Check list response
ebpi
Indicator that question is included in EBPI score
strata
Sampling strata
weight
Sampling weight
fpc
Finite population correction

Appendix A - 10

Michigan ERP

This workbook contains summaries of the inspections and self-certification responses for the
Michigan Department of Environmental Quality (DEQ) Retail Dry Cleaner Environmental Results
Program (ERP). The DEQ conducted inspections of two different samples of dry cleaners that
use perchlorate solvents. Baseline inspections were conducted for a sample of 262
establishments. Dry cleaners were then given the opportunity to voluntarily self-certify their
environmental performance. Follow-up inspections were conducted at a second random sample
of 272 establishments after self-certification. During both rounds of inspections, the DEQ
collected data on a large number of environmental business practices. The inspections assess
facilities against a checklist of practices, indicating which ones are being used at each facility.
The workbook contains the following sheets:
Sheet
Questions

Contents
Checklist questions

Round 1&2 Achievement Rates

Achievement rates (proportions) on environmental practices, as reported
by inspectors in the baseline and follow-up inspections, and the
performance change

Rd 1&2 Fac.Score&Agg.Achieve

Facility scores and aggregate achievement rates from the baseline and
follow-up inspections.

Self-Cert Achievement Rates

Achievement rates (proportions) on environmental practices from selfcertification

SC Facility Score&Agg. Achieve

Facility scores and aggregate achievement rates from self-certification

Appendix A - 11

Michigan ERP: Check List Questions

Round 1 Round 2
Question Question
Number Number
1-1
1-1
1-2
1-2
1-3
1-3
1-4
1-4
1-5
1-5
1-6
1-6
1-7
1-7
1-8
1-8
1-9
1-10

1-9
1-10
1-11

1-11

1-12

1-12

1-13

1-13

1-14

1-14

1-15
1-16
1-17
1-18

1-15

1-16
1-17

1-19
1-20
1-21
1-22
1-23
1-24

1-18

1-25

1-19

1-26

1-20
1-21
1-22
1-23
1-24
1-25
2-1

1-27
1-28
1-29
1-30
1-31
1-32
1-33
2-1

2-2
2-3
2-4

2-2
2-3
2-4

2-5
2-6
2-7
2-8

2-5
2-6
2-7
2-8

2-9
2-10

2-9
2-10

Question Text
Is the Machine operated according to manufacturers’ specifications?
Are machine operating manuals kept on site?
Is the dry cleaning machine door kept closed, except for loading and unloading?
Does facility keep a log of the gallons of perc purchased each month?
Are all perc purchase logs kept on file for five years?
Are all cartridge filters drained 24 hours before removal?
Are specified components of the machine inspected weekly/bi-weekly for perceptible leaks?
Are specified components inspected monthly for vapor leaks while in operation with a halogenated hydrocarbon
detector PCE gas analyzer?
If a leak is detected, is it repaired in 24 hours or if it cannot be repaired in 24 hours are parts ordered within 2
working days and installed within 5 days of receiving them?
does facility keep a log of the date of any necessary repairs made to the machine?
Does facility keep a log of machine inspections that identifies any components that are leaking?
Small Area Source? Dry-to-dry machine installed before 12/9/91 AND did facility purchase less than 140 gallons
of perc per year during all previous 12-month periods?
Do all dry-to-dry machines installed before 12/9/91 have an external refrigerated condenser OR a carbon
adsorber that was installed prior to 9/22/93? (Choose N/A if machine installed after 12/9/91)
Do all dry-to-dry machines installed after 12/9/91 have an internal refrigerated condenser? (Choose N/A if
machine installed before 12/9/91)
Do all dry-to-dry machines initially installed after 12/21/05 have an internal carbon adsorber AND refrigerated
condenser? (Choose N/A if machine installed before 12/21/05)
If major source, is concentration of perc in the machine drum at the end of the cycle measured weekly with a
colorimetric detector tube or PCE gas analyzer? (choose N/A if not major source)
Is the concentration of perc less than 300 ppm?
Are the external refrigerated condensers on a vented machine routed properly so the air-perc stream is not
vented directly to atmosphere while drum is rotating?
Is the outlet temperature of the vapor stream passing through the cooling coil (refrigerated condenser) read
weekly and is it equal to or less than 45deg F (±2 F) or 7.2deg C (±1.1degC)?
Are the high and low pressures of the refrigeration system read and recorded on a weekly basis? (Choose N/A if
no pressure gauges)
Are the pressures within those specified by the manufacturer? (Choose N/A if no pressure gauges)
Is the date, temperature sensor or pressure gauge monitoring results recorded weekly?
Is the date, temperature sensor or pressure gauge monitoring results kept on file for five years?
Is the machine equipped with an external carbon adsorber?
If an external carbon adsorber is installed on a vented machine, is none of the air-perchloroethylene gas-vapor
stream allowed to bypass the carbon adsorber to the atmosphere?
Is the concentration of perc in the exhaust of the external carbon adsorber measured weekly using a colorimetric
detector tube or PCE gas analyzer?
Is the concentration of perc in the exhaust of the external carbon adsorber less than 100 parts per million per
volume?
Are the date and colorimetric detector tube monitoring results recorded weekly?
Are the date and colorimetric detector tube monitoring results kept on file for 5 years?
Are necessary repairs made to the refrigerated condenser and/or carbon adsorber?
Was a Notification of Compliance Status Form submitted to the MDEQ?
Has the facility paid their air quality fee?
Has the facility paid their MDEQ Dry Cleaning License Fee?
Does the facility have a dry cleaning machine that uses a petroleum solvent?
Is the TOTAL manufacturers’ rated dryer capacity for all dryers used for petroleum solvent equal to or greater
than 84 pounds (38 kilograms)? (see explanation below) AND Was the equipment installed after December 14,
1982?
Is the filter a cartridge filter?
Are cartridge filters drained in their sealed housings for at least eight hours prior to their removal?
Is leak inspection and leak repair cycle information in the operating manual and on a clearly visible label posted
on the dryer?
Was the dryer installed between December 14, 1982 and September 21,1984
Does facility use more than 4,700 gallons (17,791 liters) of solvent per year?
Is the dryer a solvent recovery dryer?
Was an initial performance test conducted to verify that the flow rate of recovered solvent from the solvent
recovery dryer at the termination of the recovery cycle is no greater than 0.05 liters per minute?
Does the facility have a copy of the initial performance test?

Appendix A - 12

Included
in EBPI
Score
No
No
No
Yes
No
No
Yes

"Good"
Response
Yes
Yes
Yes
Yes
Yes
Yes
Yes

No

Yes

No
No
No

Yes
Yes
Yes

No

Yes

No

Yes

No

Yes

No

Yes

No
No

Yes
Yes

No

Yes

Yes

Yes

No
No
No
No
No

Yes
Yes
Yes
Yes
Yes

No

Yes

No

Yes

No
No
No
No
No
No
No
No

Yes
Yes
Yes
Yes
Yes
Yes
Yes
No

No
No
No

Yes
Yes
Yes

No
No
No
No

Yes
Yes
No
Yes

No
No

Yes
Yes

Michigan ERP: Check List Questions

Round 1 Round 2
Included
Question Question
in EBPI
Number Number Question Text
Score
Does facility generate less than 220 pounds of hazardous waste per month?
3-1
3-1
No
Does facility have a site identification number when needed for waste shipment? (Choose N/A if you do not ship
waste off-site)
3-2
3-2
No
Does each shipment of hazardous waste or liquid industrial waste have a manifest or receipt from the waste
hauler that identifies manifest number and the type and quantity of waste shipped?
3-3
3-3
Yes
Is the waste properly listed on the manifest form (e.g., F002) and is the quantity shipped entered on the manifest
form?
3-4
3-4
No
Has a copy of each manifest been signed by the waste hauler and submitted to the MDEQ by the 10th of the
month following the shipment?
3-5
3-5
No
3-6

3-6

3-7

3-7

3-8
3-9
3-10
3-11

3-8
3-9
3-10
3-11

3-12

3-12

3-13

3-13

3-14
3-15

3-14
3-15

3-16

3-16

3-17
3-18

3-17
3-18

3-19
3-20

3-19
3-20

3-21

3-21

3-22
3-23
3-24

3-22
3-23
3-24

3-25

3-25

3-26

3-26

3-27

3-27

3-28
3-29

3-28
3-29

3-30
4-1
4-2

3-30
4-1
4-2

4-3
4-4

4-3
4-4

Are all copies of the manifest that are signed by the hauler and disposal facility kept on file for at least 3 years?
Is each storage container labeled with the name of the contents (e.g., perc waste, filters) and is the label
readable? Container may be labeled using purchased labels, a stencil, or the completed shipping label.
Is each container that is being shipped labeled according to the US DOT Shipping requirements? (E.g. does it
have a completed US DOT shipping label?)
Is less than 2,200 pounds (5 drums) of hazardous waste accumulated on site?
Are containers in good condition and kept closed except when adding or removing waste?
Is the exterior of the storage containers kept free of the liquid waste and its residue?
Are containers protected from the weather? If storing containers outdoors, they are placed on an impervious
surface and protected from the elements.
Are containers protected from fire and secure from vandalism and physical damage such as that caused by fork
lifts or other equipment?
Are the containers compatible with the type of waste being stored in them and are containers that have wastes
that could react with each other separated by a physical barrier, like a dike, berm, or wall, or by a safe distance?
Is there adequate aisle space for unobstructed movement of emergency equipment and personnel?
If contents have a flashpoint below 200° F, are they isolated according to local fire department
recommendations?
If a leak or spill occurs does facility immediately stop and contain the leak and repair or replace the container?
Have employees been trained on how to properly manage waste?
Does hazardous waste storage area have secondary containment such as a curb, ramped pad, dike, or
containment room?
Are you doing any of the best management practices listed in Table 3.1 of the Self Audit Workbook?
Are hazardous wastes that are a liquid shipped to a licensed recycling, treatment, storage, or disposal facility?
Is facility complying with the following?
-Liquid haz waste not disposed of in dumpster, landfill, incinerator
-Waste not put into municipal sanitary sewer without WWTP authorization
-Haz waste not into septic tank, storm drain, into stream or ground
Is facility doing any of the following best management practices?
Does facility recycle fluorescent tubes, incandescent lamps, and/or dry cell batteries?
Are fluorescent tubes, incandescent lamps, dry cell batteries, stored for recycling according to the following
requirements?
Have employees who handle fluorescent tubes, incandescent lamps, and dry cell batteries, been informed about
proper handling of these waste materials and any emergency procedures?
Does facility…? Recharge and use rechargeable batteries; Use low-mercury, energy-efficient fluorescent/HID
light bulbs;
Keep recycling or disposal receipts for 3 yrs and know who recycles or disposes of them
Is all solid waste hauled to a recycling center or a licensed disposal facility, which includes: a landfill, incinerator,
or a transfer/processing facility?
Is waste stored in leak-proof, covered containers (e.g. covered dumpster)?
Does your facility recycle or reuse office paper, corrugated cardboard, wood pallets, 55-gallon clean drums,
other containers, or scrap metal?
Does your facility store fuel, solvents, or other material in an aboveground storage tank?
Does the storage tank have secondary containment?
Is the tank any of the following? Used to supply flammable or combustible liquid w/storage capacity of >1100 gal;
Flammable compressed gas or LPG container fill location; LPG tank w/water capacity >2000 gal or 2 or more
tanks w/aggregate capacity >4000gal
Has the tank been certified by the MDEQ, Waste and Hazardous Materials Division?

"Good"
Response
Yes
Yes
Yes
Yes
Yes

No

Yes

No

Yes

No
No
Yes
No

Yes
Yes
Yes
Yes

No

Yes

No

Yes

No
No

Yes
Yes

No

Yes

No
No

Yes
Yes

No
No

Yes
Yes

No

Yes

Yes
No
No

Yes
Yes
Yes

No

Yes

No

Yes

No

Yes

No
No

Yes
Yes

No
No
No

Yes
No
Yes

No
No

Yes
Yes

Appendix A - 13

Michigan ERP: Check List Questions

Round 1 Round 2
Question Question
Number Number Question Text
Does the tank meet the requirements in Table 4.1 of the Self Audit Workbook?
4-5
4-5
Does facility have a boiler?
5-1
4-51
Does facility keep a record of the amount of fuel the boiler uses per month (e.g., monthly bill from utility
company)?
5-2
4-52
Does the boiler stack discharge vertically upwards and are all devices used to prevent precipitation from entering
the sack not restricting the vertical flow of the exhaust gas stream?
5-3
4-53
Does boiler comply with the requirements below?
5-4
4-54
Is Facility doing any of the following best management practices for boilers?
5-5
4-55
Is facility connected to a sewer system that goes to a wastewater treatment plant?
6.1
5-1
Does facility empty wastewater from any dry cleaning machine into a drain, toilet, or sink?
6.2
5-2
Does facility have permission from the wastewater treatment plant to dispose of wastewater from dry cleaning
machine into the sewer system? (e.g., permit, letter, or written authorization from WWTP)
6.3
5-3
Combination of questions 5-02 and 5-03 (See note at the bottom of this table for more info.)
3
Does facility empty wastewater from laundry area, air compressor, boiler, vacuum, or floor cleaning into a drain,
toilet, or sink?
6.4
5-4
Does facility have permission from the wastewater treatment plant to dispose of wastewater from laundry area,
air compressor, boiler, vacuum, or floor cleaning into the sewer system? (e.g., permit, letter, or written
authorization from WWTP)
6.5
5-5
Does facility use an evaporator device to dispose of wastewater?
6.6
5-6
Is any wastewater collected in a holding tank?
6.7
5-7
Is wastewater that is collected in holding tank disposed of by a licensed and registered hauler?
6.8
5-8
Does any wastewater from facility go to a septic system?
6.9
5-9
Does facility empty wastewater from dry cleaning machine, laundry area, air compressor, boiler, vacuum, or floor
cleaning onto the ground, storm sewer, steam, or ditch?
6.1
5-10
Are there any floor drains in facility?
6.11
5-11
Do they empty to the sewer system that goes to a wastewater treatment plant or a holding tank?
6.12
5-12
Have floor drains that empty to a storm sewer, stream, or ditch been plugged with concrete or a locked down
cement cap so that they are inaccessible and unusable?
6.13
5-13

7.1
7.2

6-1
6-2

Are there at least two portable fire extinguishers (or one extinguisher for perc dry cleaning facilities) with at least
a 2a,10bc rating at the facility and is one of those fire extinguishers mounted near the dry cleaning machine?
Does facility have an approved organic vapor respirator?

Included
in EBPI
Score
No
No
No

Yes

No
No
No
No
With 5.03

Yes
Yes
Yes
Yes
No

With 5.02
Yes

Yes
Yes

No

No

No
No
No
No
No

Yes
Yes
Yes
Yes
No

No
No
No

No
No
Yes

No

Yes

No
No

Yes
Yes

NOTE: EBPIs denoted in yellow highlighting.
Questions 1.32 and 1.33 were not asked in round 2. They correspond to round 1 questions 1-24 and 1-25, respectively. Questions 4.51, 4.52,
4.53, 4.54, and 4.55 were not asked in round 2. They correspond to round 1 questions 5-1, 5-2, 5-3, 5-4, and 5-5, respectively.
Question 5.01, 5.02, and 5.03 determine whether establishments are improperly emptying wastewater into drains that flow to wastewater
treatment plants. Establishments that are connected to a sewer system (i.e., they answered "Yes" to 5.01) are considered in compliance if
(1) they do not empty wastewater in a drain (they responded "No" to 5.02) or (2) for those that do empty wastewater in a drain, they have
permission to do so (they answered "Yes" to 5.03). The comibination of 5.02 and 5.03 is "Yes" if they answered "No" to 5.02 or if they answered
"Yes" to both 5.02 and 5.03. It applies only to establishments with drains connected to sanitary sewers (i.e., that answered "Yes" to 5.01).

Appendix A - 14

"Good"
Response
Yes
Yes

Michigan ERP: Response to Check List Items
Baseline
Sample Responses
Round 2
Question

1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20
1.21
1.22
1.23
1.24
1.25
1.26
1.27
1.28
1.29
1.30
1.31
1.32
1.33
2.01
2.02
2.03
2.04
2.05
2.06
2.07
2.08
2.09
2.10
3.01
3.02
3.03
3.04
3.05
3.06
3.07
3.08
3.09
3.10
3.11

Design-based Estimates
Propor90 Percent
tion Confidence Interval

No

Yes

Blank

Valid
Responses

3
5
1
79
114

253
253
255
177
139
242
205

6
4
6
6
9
20
8

256
258
256
256
253
242
254

98.7
98.0
99.5
65.7
49.1
100.0
78.6

1

252
197
182
20
32
206
35

198
25
195

9
10
15
17
30
31
31

253
252
247
245
34
206
36

99.7
76.0
71.2
7.2
94.5
100.0
96.9

44

178

2

38

222

77.1

73
91

157
141

2
2

30
28

230
232

65.3
56.4

234
232
232
232
232

27
28
28
28
28
71

1
2
2
2
2
191

0.0
100.0
100.0
100.0
100.0
100.0

16
12
47
255
261
260
261
260
262
260
260
260
7
11
18
21
28
24
17
24
12
15
19

246
250
215
7
1
2
1
2

94.2
97.0
2.6
17.2
100.0
100.0
100.0
0.0

2
2
2
255
251
244
241
234
238
245
238
250
247
243

59.9
0.0
0.0
83.9
96.3
79.5
83.1
78.3
72.6
75.6
79.6
98.4
93.6
98.8

49
1
55
65
225
2

1
2
2
2
2
191
14
7
209
6

232
243
6
1
1
2
1

2
1
2
2
36
9
43
35
45
58
53
41
4
14
3

1

219
242
201
206
189
180
192
197
246
233
240

N/A

97.7
96.8
98.8
61.8
46.0
100.0
75.0

99.8
99.3
- 100.0
69.7
52.2
- 100.0
82.3
99.3 - 100.0
72.2 79.8
67.2 75.2
5.2 9.3
87.9 - 100.0
100.0 - 100.0
91.8 - 100.0
73.3 80.8
61.0 69.7
52.3 60.5
100.0 - 100.0
92.1 96.3
95.5 98.6
1.1 4.2
0.0 47.7
80.8 87.1
94.6 98.0
76.0 83.0
79.8 86.5
74.5 82.1
68.6 76.5
71.9 79.3
76.2 83.0
97.2 99.5
91.3 96.0
97.8 99.8
Appendix A - 15

Michigan ERP: Response to Check List Items
Baseline
Sample Responses
Round 2
Question

3.12
3.13
3.14
3.15
3.16
3.17
3.18
3.19
3.20
3.21
3.22
3.23
3.24
3.25
3.26
3.27
3.28
3.29
3.30
4.01
4.02
4.03
4.04
4.05
4.51
4.52
4.53
4.54
4.55
5.01
5.02
5.03
5.02 & 5.03
5.04
5.05
5.06
5.07
5.08
5.09
5.10
5.11
5.12
5.13
6.01
6.02

No

Yes

5
6
3
2

238
235
241
245
240
244
193
54
107
244
241
209
9
5
6
110
242
243
71
10
3

1
44
193
131
3
4
39
241
6
4
130
1
1
173
240
5
8
4
3
65
37
3
7
4
186
40
40
23
83
193
163
31
235
230
60
10
3
17
16

3
246
184
210
244
239
248
61
20
204
224
137
58
86
51
11
17
187
177
7
231
232

N/A

Blank

19
21
18
15
22
17
25
15
24
15
17
14
12
251
252
22
19
18
18
12
254
254
262
255
13
13
15
15
16
10
15
202
18
15
42
11
13
180
16
15
15
75
252
14
14

Valid
Responses

Design-based Estimates
Propor90 Percent
tion Confidence Interval

243
241
244
247
240
245
237
247
238
247
245
248
250
11
10
240
243
244
244
250
8
8

97.9
97.4
98.8
99.2
100.0
99.6
79.0
21.1
41.4
98.8
98.4
86.7
3.3
45.0
62.3
47.5
99.7
99.6
27.5
3.6
37.9
0.0

96.6
95.9
97.8
98.4
100.0
99.0
75.2
17.5
38.1
97.8
97.4
84.7
1.8
10.6
34.7
43.1
99.2
99.0
24.1
2.1
3.4
0.0

7
249
249
247
247
246
252
247
60
244
247
220
251
249
82
246
247
247
187
10
248
248

45.3
98.9
68.4
87.6
98.8
97.1
98.6
23.9
31.7
83.7
90.2
62.3
22.6
35.1
62.6
4.1
6.5
75.2
95.2
72.5
92.7
93.0

0.3
98.0
66.2
86.1
97.9
95.6
97.5
20.3
24.8
80.7
87.4
60.0
18.9
33.4
55.1
2.4
4.4
71.3
93.1
48.2
90.2
90.6

Notes:
EBPIs denoted in yellow highlighting.
Questions 1.32 and 1.33 were not asked in the follow-up round. They
correspond to baseline questions 1-24 and 1-25, respectively. Questions
4.51, 4.52, 4.53, 4.54, and 4.55 were not asked in the follow-up. They
correspond to baseline questions 5-1, 5-2, 5-3, 5-4, and 5-5, respectively.

Appendix A - 16

-

99.2
98.9
99.8
100.0
100.0
100.0
82.7
24.7
44.7
99.8
99.5
88.7
4.7
79.4
89.9
51.9
100.0
100.0
31.0
5.2
72.4
0.0
90.3
99.8
70.6
89.2
99.8
98.6
99.6
27.5
38.6
86.7
92.9
64.6
26.2
36.8
70.1
5.8
8.7
79.1
97.4
96.9
95.1
95.4

Michigan ERP: Response to Check List Items
Follow-up
Sample Responses
Round 2
Question

1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20
1.21
1.22
1.23
1.24
1.25
1.26
1.27
1.28
1.29
1.30
1.31
1.32
1.33
2.01
2.02
2.03
2.04
2.05
2.06
2.07
2.08
2.09
2.10
3.01
3.02
3.03
3.04
3.05
3.06
3.07
3.08
3.09
3.10
3.11

No

Yes

1
4
1
100
110

270
267
268
169
159
263
205
33
264
214
204
21
17
227
18

64
233
4
53
63
242
9
3
3
4
1
58
106
14
67
87
249

1
92

24
191
12
103
192
172
2
1
1
1
1
1
242
151

258
7

9
1

N/A

230
31
237
250
232
8
138
135

1
1
4
5
32
9
24
57
37
18
2
15
6

261
253
225
247
231
200
221
237
257
245
254

3

Design-based Estimates
Propor90 Percent
tion Confidence Interval

Blank

Valid
Responses

1
1
3
3
3
9
3
6
4
5
5
9
16
14
14
19
268
15
15
16
20
13
13
21
271
271
271
271
271
29
29

271
271
269
269
269
263
269
266
268
267
267
263
26
227
21
3
4
25
249
118
117
259
259
251
1
1
1
1
1
243
243

99.6
98.4
99.6
62.7
59.3
100.0
75.8
11.4
98.1
79.5
75.7
8.2
64.5
100.0
87.7
0.0
0.0
96.1
77.0
10.3
87.8
74.4
67.0
0.5
100.0
100.0
100.0
100.0
100.0
99.5
61.7

5
264
272
272
272
272
272
271
271
272
7
11
15
16
17
15
14
17
13
12
12

267
8

2.4
5.6

1
1

100.0
100.0

265
258
257
256
255
257
258
255
259
260
260

99.0
97.9
87.7
96.6
89.9
78.0
86.5
93.3
99.4
94.5
97.8

99.1
97.3
99.1
59.3
55.9
100.0
72.5
8.9
96.8
76.4
72.3
5.9
55.7
100.0
75.7

- 100.0
99.5
- 100.0
66.1
62.7
- 100.0
79.0
13.9
99.4
82.7
79.0
10.5
73.3
- 100.0
99.6
0.0 0.0
89.5 - 100.0
73.7 80.2
6.0 14.5
83.5 92.2
71.0 77.8
63.5 70.5
0.0 1.1
98.7 - 100.0
57.4 66.0
1.4 3.5
0.0 18.3
98.4 99.6
96.6 99.2
85.1 90.3
95.0 98.2
87.4 92.5
74.7 81.2
83.7 89.4
91.3 95.4
98.8 99.9
92.7 96.4
96.5 99.1
Appendix A - 17

Michigan ERP: Response to Check List Items
Follow-up
Sample Responses
Round 2
Question

3.12
3.13
3.14
3.15
3.16
3.17
3.18
3.19
3.20
3.21
3.22
3.23
3.24
3.25
3.26
3.27
3.28
3.29
3.30
4.01
4.02
4.03
4.04
4.05
4.51
4.52
4.53
4.54
4.55
5.01
5.02
5.03
5.02 & 5.03
5.04
5.05
5.06
5.07
5.08
5.09
5.10
5.11
5.12
5.13
6.01
6.02

No

Yes

10
8
2

250
252
258
260
260
258
254
48
133
258
253
252
41
22
41
108
263
261
134
3
3
1

3
6
211
114
1
7
6
219
23
3
142

123
265
1
3

4

1
227
39
32
1
104
216
265
12
260
259
21
3
5
10
9

267
39
8
231
265
163
52
3
4
6
246
247
7
257
257

N/A

Blank

Valid
Responses

Design-based Estimates
Propor90 Percent
tion Confidence Interval

12
12
12
12
12
11
12
13
25
13
12
14
12
227
228
22
9
11
15
4
268
268
272
268

260
260
260
260
260
261
260
259
247
259
260
258
260
45
44
250
263
261
257
268
4
4

96.2
96.8
99.3
100.0
100.0
99.0
97.9
18.5
53.6
99.6
97.6
97.7
15.6
48.4
93.1
44.1
100.0
100.0
52.3
1.0
64.7
9.1

4

100.0

4
6
225
9
6
5
4
7
257
8
7
5
22
260
5
6

268
266
47
263
266
267
268
265
15
264
265
267
250
12
267
266

99.6
14.0
14.7
88.0
99.6
61.0
19.6
0.0
21.4
1.5
2.2
91.6
98.8
60.6
96.2
96.6

94.6
95.3
98.6
100.0
100.0
98.3
96.7
15.2
51.2
99.1
96.4
96.5
12.7
36.9
86.7
40.2
100.0
100.0
50.3
0.1

99.1
11.1
6.8
85.3
99.1
60.2
16.3
0.0
13.5
0.5
1.0
89.3
97.9
34.8
94.8
95.0

-

The estimated proportion and 90% confidence interval are "design-based." I.e.,
they incorporate the sample weights, strata, and a finite population correction.

Appendix A - 18

97.8
98.3
100.0
100.0
100.0
99.7
99.1
21.8
56.0
100.0
98.8
99.0
18.4
59.8
99.6
48.0
100.0
100.0
54.3
1.8

100.0
16.8
22.5
90.7
100.0
61.9
22.9
0.0
29.3
2.5
3.5
93.9
99.7
86.3
97.7
98.1

Michigan ERP: Response to Check List Items

Round 2
Question

1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20
1.21
1.22
1.23
1.24
1.25
1.26
1.27
1.28
1.29
1.30
1.31
1.32
1.33
2.01
2.02
2.03
2.04
2.05
2.06
2.07
2.08
2.09
2.10
3.01
3.02
3.03
3.04
3.05
3.06
3.07
3.08
3.09
3.10
3.11

Follow-up Minus Baseline
Design-based Estimates
Propor90 Percent
tion Confidence Interval
Change between Rounds

0.9
0.4
0.1
-3.0
10.2
0.0
-2.8

-0.3
-1.3
-0.8
-8.2
5.6
0.0
-7.7

-1.6
3.6
4.5
1.0
-30.0
0.0
-9.2

-2.9
-1.4
-0.7
-2.2
-40.8
0.0
-22.0

-0.1

-5.0

9.1
10.6

3.6
5.2

100.0
0.0
0.0
0.0
0.0
-0.5

0.0
0.0
0.0
0.0
-1.3

-0.2
-11.5

-2.1
-42.3

40.1
100.0
15.1
1.6
8.2
13.5
11.6
5.4
10.9
13.7
1.0
0.9
-1.0

11.9
-0.6
3.8
9.8
7.0
0.3
6.3
9.7
-0.3
-2.1
-2.6

-

2.0
2.0
1.0
2.1
14.8
0.0
2.0
-0.2
8.5
9.7
4.1
-19.2
0.0
3.6

4.9

14.6
15.9

0.0
0.0
0.0
0.0
0.2

1.6
19.2

18.3
3.7
12.6
17.2
16.2
10.5
15.6
17.7
2.3
3.9
0.7

No Significant Change
No Significant Change
No Significant Change
No Significant Change
Significant Increase
No Significant Change
No Significant Change
N/A
Significant Decrease
No Significant Change
No Significant Change
No Significant Change
Significant Decrease
No Significant Change
No Significant Change
N/A
N/A
N/A
No Significant Change
N/A
N/A
Significant Increase
Significant Increase
N/A
N/A
No Significant Change
No Significant Change
No Significant Change
No Significant Change
No Significant Change
N/A
N/A
N/A
No Significant Change
No Significant Change
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Significant Increase
No Significant Change
Significant Increase
Significant Increase
Significant Increase
Significant Increase
Significant Increase
Significant Increase
No Significant Change
No Significant Change
No Significant Change

Include
Variable in
EBPI Score

No
No
No
Yes
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
No
Appendix A - 19

Michigan ERP: Response to Check List Items

Round 2
Question

3.12
3.13
3.14
3.15
3.16
3.17
3.18
3.19
3.20
3.21
3.22
3.23
3.24
3.25
3.26
3.27
3.28
3.29
3.30
4.01
4.02
4.03
4.04
4.05
4.51
4.52
4.53
4.54
4.55
5.01
5.02
5.03
5.02 & 5.03
5.04
5.05
5.06
5.07
5.08
5.09
5.10
5.11
5.12
5.13
6.01
6.02

Follow-up Minus Baseline
Design-based Estimates
Propor90 Percent
tion Confidence Interval
Change between Rounds

-1.7
-0.6
0.5
0.8
0.0
-0.6
18.9
-2.6
12.2
0.8
-0.9
11.0
12.3
3.4
30.9
-3.4
0.3
0.4
24.8
-2.7
26.8
9.1

-3.8
-2.7
-0.7
0.0
0.0
-1.5
14.9
-7.5
8.1
-0.3
-2.4
8.7
9.1
-32.1
2.9
-9.3
-0.1
-0.2
20.8
-4.5

54.7

1.1
-9.9
-17.0
4.3
9.5
-1.3
-2.9
-35.1
-41.2
-2.6
-4.3
16.4
3.6
-12.0
3.6
3.5

0.0
-14.5
-27.3
0.3
6.7
-3.7
-7.9
-36.8
-51.8
-4.5
-6.8
11.9
1.3
-45.2
0.7
0.7

-

0.4
1.5
1.7
1.6
0.0
0.3
22.9
2.3
16.3
1.9
0.7
13.4
15.5
38.9
58.8
2.5
0.8
1.0
28.8
-0.9

2.2
-5.3
-6.7
8.3
12.3
1.2
2.0
-33.4
-30.6
-0.6
-1.8
21.0
5.9
21.3
6.4
6.4

No Significant Change
No Significant Change
No Significant Change
Significant Increase
No Significant Change
No Significant Change
Significant Increase
No Significant Change
Significant Increase
No Significant Change
No Significant Change
Significant Increase
Significant Increase
No Significant Change
Significant Increase
No Significant Change
No Significant Change
No Significant Change
Significant Increase
Significant Decrease
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
No Significant Change
Significant Decrease
Significant Decrease
Significant Increase
Significant Increase
No Significant Change
No Significant Change
Significant Decrease
Significant Decrease
Significant Decrease
Significant Decrease
Significant Increase
Significant Increase
No Significant Change
Significant Increase
Significant Increase

Include
Variable in
EBPI Score

No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
With 5.03
With 5.02
Yes
No
No
No
No
No
No
No
No
No
No
No
No

Question 5.01, 5.02, and 5.03 determine whether establishments are improperly
emptying wastewater into drains that flow to wastewater treatment plants.
Establishments that are connected to a sewer system (i.e., they answered "Yes"
to 5.01) are considered in compliance if (1) they do not empty wastewater in a
drain (they responded "No" to 5.02) or (2) for those that do empty wastewater in a
drain, they have permission to do so (they answered "Yes" to 5.03). The
comibination of 5.02 and 5.03 is "Yes" if they answered "No" to 5.02 or if they
answered "Yes" to both 5.02 and 5.03. It applies only to establishments with
drains connected to sanitary sewers (i.e., that answered "Yes" to 5.01).

Appendix A - 20

Michigan ERP: Facility Scores and Aggregate Achievement Rates

Round
Baseline
Follow-up
Follow-up Minus
Baseline

Valid
Observations
261
271

10th
50.0
42.9

20th
66.7
57.1

30th
71.4
71.4

-7.1

-9.5

0.0

Facility Score for All EBPIs
Mean 90% Confidence
Percentile
40th 50th 60th 70th 80th 90th Score
Interval
85.7 85.7 100.0 100.0 100.0 100.0
82.6 81.0 84.3
85.7 100.0 100.0 100.0 100.0 100.0
82.8 81.2 84.4
0.0

14.3

0.0

0.0

0.0

0.0

0.2

-2.1

-

2.5

Aggregate Achievement
Rate for All EPBIs
90% Confidence
Rate
Interval
82.4 80.7 84.0
83.3 81.7 84.8
0.9

-1.4

-

3.2

Only questions with valid responses in both rounds are included in the scores .
The scores, 90 percent confidence intervals, and aggregate achievement rates reflect the design of the sample. In other words, they incorporate
the sample weights, strata, and a finite population correction.

Appendix A - 21

Michigan ERP: Response to Check List Items

Self-Certification
Round 2
Question

1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1.20
1.21
1.22
1.23
1.24
1.25
1.26
1.27
1.28
1.29
1.30
1.31
2.01
2.02
2.03
2.04
2.05
2.06
2.07
2.08
2.09
2.10
3.01
3.02
3.03
3.04
3.05
3.06
3.07
3.08
3.09
3.10
3.11

Appendix A - 22

No

Yes

3
5
1
6
30
6
8
263
1
20
28
288
8
2
8
21
5
2
4
24
5
11
41
226
12
42
11
32
38
9
165
321
60
9
4
2
33
27
6
6
8
21
9
8
3
22
18
34
8
20

471
467
472
467
439
449
461
193
469
448
435
160
41
299
45
3
114
195
308
234
244
351
315
122
117
83
106
88
80
322
214
39
12
32
32
36
5
3
25
20
20
449
392
417
418
397
402
411
428
426
448
446

N/A

4

1
309
63
308
335
2
157
48
103
106
1
1
1
11
1
1
1
1
1
1
1
1
1

1
1
27

1
1
1
1

Blank

Other

16

5
23

22
22
26
36
26
39
25
27
32
46
137
131
134
136
374
141
135
134
140
132
138
146
355
370
377
374
376
163
113
135
422
453
458
456
457
465
464
468
466
25
67
70
74
76
75
49
58
49
46
48

2

Valid
Responses

Proportion

474
472
473
473
469
455
469
456
470
468
463
448
49
301
53
24
119
197
312
258
249
362
356
348
129
125
117
120
118
331
379
360
72
41
36
38
38
30
31
26
28
470
401
425
421
419
420
445
436
446
448
446

99.4
98.9
99.8
98.7
93.6
98.7
98.3
42.3
99.8
95.7
94.0
35.7
83.7
99.3
84.9
12.5
95.8
99.0
98.7
90.7
98.0
97.0
88.5
35.1
90.7
66.4
90.6
73.3
67.8
97.3
56.5
10.8
16.7
78.0
88.9
94.7
13.2
10.0
80.6
76.9
71.4
95.5
97.8
98.1
99.3
94.7
95.7
92.4
98.2
95.5
100.0
100.0

Include in
Variable in
EBPI Score

No
No
No
Yes
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
No

Michigan ERP: Response to Check List Items

Self-Certification
Round 2
Question

N/A

Blank

3.12
2
444
2
3.13
1
446
2
3.14
4
440
2
3.15
9
442
3.16
4
434
1
3.17
450
3.18
37
410
3.19
177
266
3.20
68
361
3.21
2
448
3.22
3
450
3.23
29
420
3.24
289
148
3.25
42
159
3.26
22
188
3.27
246
188
3.28
3
440
3.29
6
439
3.30
264
175
4.01
421
42
4.02
21
48
4.03
58
9
4.04
7
38
4.05
8
49
1
5.01
97
361
5.02
357
29
5.03
61
37
5.02 & 5.03
9
373
5.04
177
205
5.05
104
150
5.06
327
147
5.07
333
133
5.08
31
146
5.09
441
29
5.10
424
49
5.11
177
292
5.12
90
216
5.13
28
98
1
6.01
1
482
6.02
13
465
Notes:
EBPIs denoted in yellow highlighting.

No

Yes

47
46
49
44
56
45
48
52
3
45
42
46
56
294
285
61
52
50
56
32
426
428
450
437
37
109
397
113
113
241
21
29
318
25
22
25
189
368
12
17

Other

63

2

1

Valid
Responses

Proportion

446
447
444
451
438
450
447
443
429
450
453
449
437
201
210
434
443
445
439
463
69
67
45
57
458
386
98
382
382
254
474
466
177
470
473
469
306
126
483
478

99.6
99.8
99.1
98.0
99.1
100.0
91.7
60.0
84.1
99.6
99.3
93.5
33.9
79.1
89.5
43.3
99.3
98.7
39.9
9.1
69.6
13.4
84.4
86.0
78.8
7.5
37.8
97.6
53.7
59.1
31.0
28.5
82.5
6.2
10.4
62.3
70.6
77.8
99.8
97.3

Include in
Variable in
EBPI Score

No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
With 5.03
With 5.02
Yes
No
No
No
No
No
No
No
No
No
No
No
No

Question 5.01, 5.02, and 5.03 determine whether establishments are improperly
emptying wastewater into drains that flow to wastewater treatment plants.
Establishments that are connected to a sewer system (i.e., they answered "Yes"
to 5.01) are considered in compliance if (1) they do not empty wastewater in a
drain (they responded "No" to 5.02) or (2) for those that do empty wastewater in a
drain, they have permission to do so (they answered "Yes" to 5.03). The
comibination of 5.02 and 5.03 is "Yes" if they answered "No" to 5.02 or if they
answered "Yes" to both 5.02 and 5.03. It applies only to establishments with
drains connected to sanitary sewers (i.e., that answered "Yes" to 5.01).

Appendix A - 23

Michigan ERP: Facility Score and Aggregate Achievement Rates

Round
Self-certification

Appendix A - 24

Valid
Facility Score for All EBPIs
ObserMean
Percentile
vations 10th 20th 30th 40th 50th 60th 70th 80th 90th Score
488 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0
98.7

Aggregate
Achievement Rate
for All EPBIs
Rate
98.7