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Burden calculation tables

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File Type	application/vnd.openxmlformats-officedocument.spreadsheetml.sheet
File Title	Burden calculation tables
Author	EV
Last Modified By	Calc
File Modified	2019-06-25
File Created	2026-09-02
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Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Perchloroethylene Dry Cl
(Renewal)

Burden Item

1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Familiarization with the regulatory requirements c
B. Required activities
C. Create Information
D. Gather existing information
Initial report information
Solvent consumption
Compliance method report d
E. Write Report
Initial notification report
Compliance method report c, d
Solvent consumption report c, e
Report-exceed consumption cutoff c, f
Subtotal for Reporting Requirements
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements
B. Plan activities g
C. Implement activities
Above consumption cutoff: Weekly LDAR g, h, i
Below consumption cutoff: Bi-weekly LDAR g, i, j
Major: Monthly enhanced LDAR k, l
Major: Weekly Carbon adsorber monitoring l, m
Area: Monthly enhanced LDAR n, o
D. Develop record system
Solvent consumption g
Enhanced LDAR g
Monitoring records d, g
Carbon adsorber monitoring records p
E. Time to enter information
Monthly records of solvent consumption q, r, s
Above consumption cutoff: Records of weekly inspections h, i, s
Below consumption cutoff: Records of bi-weekly inspections g, i, j
Major: Enhanced LDAR
Major: Carbon adsorber monitoring
Area: Enhanced LDAR
F. Time to Train personnel
Leak detection t, u
G. Time for audits
Subtotal for Recordkeeping Requirements
Total Labor Burden and Cost (rounded) v
Total Capital and O&M Cost (rounded) v
Grand TOTAL (rounded) v

A
Hours per
occurrence

B
C
Occurrences per
Hours per
respondent per year respondent per
year
(AxB)

N/A
N/A
1
N/A
N/A

2
1
1

1
1
1

2
1
1

1
1
0.25
1

1
1
1
1

1
1
0.25
1

See 3A
1

0.75
0.75
1
0.25
0.75

52
26
48
208
12

39
19.5
48
52
9

1
1
1
1

0.25
0.25
0.25
See 4C
See 4C
See 4C

12
52
26

3
13
6.5

1
N/A

Assumptions
a
We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 n
all existing and new area sources are private sector facilities. There are 20 existing major sources and 13 of these sources are private sector f
subject to the NESHAP over the three-year period of this ICR.

This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Tech
from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Indust
The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
b

This task requires management hours only.
We estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the consumption cutoff and are required to perform this task.
e
We estimate that 699 (30 percent) of the 2,330 new facilities will be below the consumption cutoff (will consume less than 140 gallons of
f
We estimate that 5 percent of new facilities each year will exceed the cutoff, thus requiring submission of the exceed-consumption cutoff r
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 area source perchloroethylene dry cleaners, 19,600 (70 percent) will be above the per consumption cutoff
and repair. The remaining 8,400 area source perchloroethylene dry cleaners will be below the consumption cutoff and are only required to c
c

We have assumed that facilities below consumption cutoff perform leak detection and repairs on a bi-weekly basis.
Major sources contain an average of four machines. This task requires 1 hour times 4 machines per major source.
l
There are 13 existing private sector major sources subject to the NESHAP.
m
This task requires 0.25 hours times 4 machines per major source per week.
n
Area sources contain an average of one machine. This task requires 0.75 hours times 1 machine per area source.
o
Approximately 8,000 existing area sources are located in states that already require enhanced monitoring; therefore, 20,000 existing area s
j

No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbo
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 13 private sector 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 onl
p
q

Estimate includes hours for training one owner/operator and one employee.
This task requires an equal amount of management and technical employee hours.
v
Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
t

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

D
E
F
Respondents per Technical
Management
yeara
hours per year hours per year
(CxD)

(Ex0.05)

G
H
Clerical Total cost per year
($)b
hours per
year
(Ex0.10)

28,013

$4,129,116

2,330
2,330
1,631

4,660
2,330
1,631

233
116.5
81.55

466
233
163.1

$610,423
$305,211
$213,648

2,330
1,631
699
117

2,330
0
0
0

116.5
1,631
174.75
117
42,529

233
0
0
0

$305,211
$240,409
$25,758
$17,172
$5,846,949

2,330

$274,754

19,595
8,398
13
13
20,000

764,209
163,759
624
676
180,000

0
0
31.2
33.8
9,000

0
0
62.4
67.6
18,000

$90,115,513
$19,310,467
$81,739
$88,551
$23,578,560

2,330
2,330
1,631
0

2,330
2,330
1631
0

0
0
0
0

$274,754
$274,754
$192,328
$0

28,013
19,595
8,398

84,039
254,736
54,586

9
39
0

0
0
0

$9,911,205
$30,044,253
$6,436,822

2,330

4,660

$1,236,391

1,547,814
1,590,000

$181,820,091
$188,000,000
$947,000
$189,000,000

Labor Rates:
Management
$147.40
Technical
$117.92
Clerical
$57.02

will be replaced by 2,330 new area sources per year over the next three years. We assume that
sources are private sector facilities. We assume that that no additional major sources will be

; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are
by Occupational and Industry group.” The rates are from column 1, “Total Compensation.”
te industry.

quired to perform this task.
me less than 140 gallons of PCE per year) and are required to perform this task.
xceed-consumption cutoff report.

the per consumption cutoff, which will require that the cleaner conduct weekly leak detection
ff and are only required to conduct bi-weekly leak detection and repair.

asis.
ce.

e.
efore, 20,000 existing area sources are subject to the NESHAP's enhanced LDAR program.

h the development of carbon adsorber monitoring record systems.

sources, and we assume only three major sources will require managerial review.

Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Perchloroethylene Dry C
(Renewal)

Burden Item

A
Hours per
occurrence

B
C
Hours per
Occurrences per
respondent per year respondent per
year
(AxB)

N/A
N/A
1
N/A
N/A

2
1
1

1
1
1

2
1
1

1
1
0.25
1

1
1
1
1

1
1
0.25
1

See 3A
1

0.75
0.75
1
0.25
0.75

52
26
48
208
12

39
19.5
48
52
9

1
1
1
1

0.25

Above consumption cutoff: Records of weekly inspections

0.25

Below consumption cutoff: Records of bi-weekly inspections
Major: Enhanced LDAR
Major: Carbon adsorber monitoring
Area: Enhanced LDAR
F. Time to Train personnel
Leak detection
G. Time for audits
Subtotal for Recordkeeping Requirements
Total Labor Burden and Cost (rounded) k
Total Capital and O&M Cost (rounded) k

0.25
See 4C
See 4C
See 4C

6.5

1
N/A

Grand TOTAL (rounded) k

Assumptions
a
There are 7 existing major sources that are federal facilities and we assume that that no additional major sources will be subject to the NES

This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead
60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are fr
Schedule” which excludes locality rates of pay.
b

This task requires management hours only.
Major sources contain an average of four machines. This task requires 1 hour times 4 machines per major source.
e
There are 7 existing public sector major sources subject to the NESHAP.
f
This task requires 0.25 hours times 4 machines per major source per week.
g
No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbo
h
Occurrences are based on twelve months rolling average of PCE consumption, determined once per month.
i
This is based on 7 major sources performing this task every year.
j
This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume onl
c

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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

D
E
F
Respondents per Technical
Management
yeara
hours per year hours per year
(CxD)

(Ex0.05)

G
H
Clerical Total cost per year
hours per
($)b
year
(Ex0.10)

$460

0
0
0

$0
$0
$0

0
0
0
0

$0
$0
$0
$0
$460

0
0
7
7
0

0
0
336
364
0

0
0
17
18
0

0
0
34
36
0

$0
$0
$18,370
$19,901
$0

0
0
0
0

$0
$0
$0
$0

$1,615

835
842

$39,887
$40,300
$680

Labor Rates:
Management
$65.71
Technical
$48.75
Clerical
$26.38

$41,000

es will be subject to the NESHAP over the three-year period of this ICR.

t for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 +
9 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General

ce.

h the development of carbon adsorber monitoring record systems.

sources, and we assume only three major sources will require managerial review.

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector – NESHAP for Perchloroethyle
Facilities (40 CFR Part 63, Subpart M) (Renewal)
Affected Sector
Private
Public (Federal)
Total
Total (rounded)

Number of
Responses
30,460
7
30,467

Reporting
42,529
7
42,536

Labor Hours
Recordkeeping
1,547,814
835
1,548,649

or – NESHAP for Perchloroethylene Dry Cleaning

Hours
Total
1,590,343
842
1,591,185
1,590,000

Labor Cost
$188,000,000
$40,300
$188,040,300
$188,000,000

52 hrs/response

Capital and O&M
Cost
$947,000
$680
$947,680
$948,000

Table 2: Average Annual EPA Burden and Cost - NESHAP for Perchloroethylene Dry Cleaning Facilities (40
Subpart M) (Renewal)
A
Burden Item

1. Report review
A. Initial notification report
B. Compliance method report c
C. Solvent consumption report d
D. Report-exceed consumption cutoff e
TOTAL (rounded) f

EPA technical
hrs per
occurrence
1
1
1
1

Occurrences per Technical hrs per
year a
year (AxB)

2,330
1,631
699
117

2,330
1,631
699
117
5,490

Assumptions:
a
We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 n
year over the next three years. There are 20 existing major sources and we assume that that no additional major sources will be subject to th
three-year period of this ICR.

This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead
rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, S
These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
b

We estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the consumption cutoff and are required to perform this task.

We estimate that 699 (30 percent) of the 2,330 new facilities will be below the consumption cutoff (will consume less than 140 gallons of
required to perform this task.
d

e
f

We assume that five percent of new sources will have to report-exceed consumption cutoff.
Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

hylene Dry Cleaning Facilities (40 CFR Part 63,

Management hrs
Clerical hrs per
per year
year (Cx0.10)
(Cx0.05)
116.5
81.55
34.95
5.83
5,490

233
163.1
69.9
11.7

H
Total cost per
year ($) b

$127,389.26
$89,172.48
$38,216.78
$6,369.46
$261,000

he industry and will be replaced by 2,330 new area sources per
dditional major sources will be subject to the NESHAP over the

factor to account for government overhead expenses: Managerial
60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%).
h excludes locality rates of pay.

utoff and are required to perform this task.

toff (will consume less than 140 gallons of PCE per year) and are

Labor Rates:
Management
$65.71
Technical
$48.75
Clerical
$26.38

Capital/Startup vs. Operation and Maintenance (O&M) Costs - Private Sector
(A)

(B)
(C)
(D)
Capital/Startup
Total
Number of New
Cost for One
Capital/Startup
Respondents
Respondent
Cost, (B X C)

Continuous Monitoring Device

PID
HHD

$3,300
$250

0
2,330

(E)
Annual O&M
Costs for One
Respondent

$0
$582,500

(F)
Number of
Respondents
with O&M

$95
$14

13
20,000

Initial notification &
compliance report

$6.37

2,330

Report exceed consumption
cutoff

117

$2.40

28,013

Photocopying
Total
Total (rounded)

$582,500
$583,000
Total (rounded)

Number of Respondents
Respondents That Submit Reports

(A)

Year

1
2
3

(B)

Number of New
Respondents 1

Number of
Existing
Respondents

2,330
2,330
2,330

28,020
28,020
28,020

Respondents That
Do Not Submit
Any Reports

(C)

(D)

Number of
Number of
Existing
Existing
Number of
Respondents
Respondents
Respondents
that keep records
That Are No (E=A+B+C-D)
but do not
Longer Subject 2
submit reports
0
0
0

2,330
2,330
2,330

28,020
28,020
28,020
28,020

Average
1

(E)

New respondent include sources with constructed, reconstructed and modified affected facilities.
We assume that the overall number of facilities will remain constant due to retirement of old existing facilities.

Total Annual Responses - Private Sector
(A)

Information Collection Activity

(B)

Number of
Respondents

(C)

(D)

(E)

Number of
Responses

Number of
Existing
Respondents That
Keep Records But
Do Not Submit
Reports

Total Annual
Responses
E=(BxC)+D

Write Initial Notification Report

2,330

25,683

28,013

Compliance Method Report

1,631

Solvent Consumption Report

699

Report Exceed Consumption
Cutoff

117

Total

30,460

ate Sector

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

(A)

Total O&M,
(E X F)

Continuous
Monitoring Device

$1,235
$280,000

(B)
Capital/Startup
Cost for One
Respondent

PID
HHD
Initial notification
& compliance
report
Report exceed
consumption
cutoff
Photocopying
Total
Total (rounded)

$14,842
$702
$67,231
$364,010
$364,000
$947,000

(C)

(D)
Total
Capital/Startup
Cost, (B X C)

Number of New
Respondents

$3,300
$250

0
0
-

$0
$0

Total Annual Responses - Public Sector
(A)

Information
Collection Activity

(B)

Number of
Respondents

(C)

Number of
Responses

$0
$0

(D)

(E)

Number of Existing
Respondents That
Total Annual
Keep Records But Responses E=(BxC)
Do Not Submit
+D
Reports

Write Initial
Notification
Report
Compliance
Method Report
Solvent
Consumption
Report
Report Exceed
Consumption
Cutoff

Total

Maintenance (O&M) Costs - Public Sector
(E)
Annual O&M
Costs for One
Respondent

(F)
Number of
Respondents with
O&M

(G)
Total O&M,
(E X F)

$95
$14

7
0

$665
$0

$6.37

$2.40

$17
$682

Total (rounded)

$680
$680