Burden Calculation tables

---

Overview

Summary
Table 1a
Table 1b
Table 1c
Table 2
Capital O&M
Responses
Respondents

---

Sheet 1: Summary

ICR Summary Information
Hours per Response	52
Number of Respondents	28,020
Total Estimated Burden Hours	1,590,000
Total Estimated Costs	$198,000,000
Annualized Capital O&M	$948,000
Total Annual Responses	30,500
Form Number	Not Applicable

---

Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)
Burden Item	(A) Hours per occurrence	(B) Occurrences per respondent per year	(C) Hours per respondent per year (AxB)	(D) Respondents per yeara	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Total cost per year ($)b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$157.61
3. Reporting Requirements										Technical	$123.94
A. Familiarization with the regulatory requirements c	1	1	1	28,013	0	28,013	0	$4,414,989		Clerical	$62.52
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	$643,425
Solvent consumption	1	1	1	2,330	2,330	116.5	233	$321,712
Compliance method report d	1	1	1	1,631	1,631	81.55	163.1	$225,199
E. Write Report
Initial notification report	1	1	1	2,330	2,330	116.5	233	$321,712
Compliance method report c, d	1	1	1	1,631	0	1,631	0	$257,054
Solvent consumption report c, e	0.25	1	0.25	699	0	174.75	0	$27,541
Report-exceed consumption cutoff c, f	1	1	1	117	0	117	0	$18,361
Subtotal for Reporting Requirements					42,529			$6,229,993
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities g	1	1	1	2,330	2,330	0	0	$288,785
C. Implement activities
Above consumption cutoff: Weekly LDAR g, h, i	0.75	52	39	19,595	764,209	0	0	$94,717,579
Below consumption cutoff: Bi-weekly LDAR g, i, j	0.75	26	19.5	8,398	163,759	0	0	$20,296,624
Major: Monthly enhanced LDAR k, l	1	48	48	13	624	31.2	62.4	$86,158
Major: Weekly Carbon adsorber monitoring l, m	0.25	208	52	13	676	33.8	67.6	$93,338
Area: Monthly enhanced LDAR n, o	0.75	12	9	20,000	180,000	9,000	18,000	$24,853,311
D. Develop record system
Solvent consumption g	1	1	1	2,330	2,330	0	0	$288,785
Enhanced LDAR g	1	1	1	2,330	2,330	0	0	$288,785
Monitoring records d, g	1	1	1	1,631	1631	0	0	$202,149
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	28,013	84,039	9	0	$10,417,380
Above consumption cutoff: Records of weekly inspections h, i, s	0.25	52	13	19,595	254,736	39	0	$31,578,673
Below consumption cutoff: Records of bi-weekly inspections g, i, j	0.25	26	6.5	8,398	54,586	0	0	$6,765,541
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	$1,312,009
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					1,547,814			$191,189,118
Total Labor Burden and Cost (rounded) v					1,590,000			$197,000,000
Total Capital and O&M Cost (rounded) v								$947,000
Grand TOTAL (rounded) v								$198,000,000
Assumptions
a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources per year over the next three years. We assume that all existing and new area sources are private sector facilities. There are 20 existing major sources and 13 of these sources are private sector facilities. We assume that that no additional major sources will be subject to the NESHAP over the three-year period of this ICR.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This task requires management hours only.
d 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 PCE per year) and are 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 area source perchloroethylene dry cleaners, 19,600 (70 percent) will be above the per consumption cutoff, which will require that the cleaner conduct weekly leak detection and repair. The remaining 8,400 area source 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 consumption cutoff perform leak detection and repairs on a bi-weekly basis.
k 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 sources are subject to the NESHAP's enhanced LDAR program.
p No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbon adsorber monitoring record systems.
q Occurrences are based on twelve months rolling average of PCE consumption, determined once per month.
r This is based on 28,000 area sources and 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 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.
v Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Table 1b

Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)
Burden Item	(A) Hours per occurrence	(B) Occurrences per respondent per year	(C) Hours per respondent per year (AxB)	(D) Respondents per yeara	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Total cost per year ($)b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$70.56
3. Reporting Requirements										Technical	$52.37
A. Familiarization with the regulatory requirements c	1	1	1	7	0	7	0	$494		Clerical	$28.34
B. Required activities	N/A
C. Create Information	N/A
D. Gather existing information
Initial report information	2	1	2	0	0	0	0	$0
Solvent consumption	1	1	1	0	0	0	0	$0
Compliance method report	1	1	1	0	0	0	0	$0
E. Write Report
Initial notification report	1	1	1	0	0	0	0	$0
Compliance method report c	1	1	1	0	0	0	0	$0
Solvent consumption report c	0.25	1	0.25	0	0	0	0	$0
Report-exceed consumption cutoff c	1	1	1	0	0	0	0	$0
Subtotal for Reporting Requirements					7			$494
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	1	1	1	0	0	0	0	$0
C. Implement activities
Above consumption cutoff: Weekly LDAR	0.75	52	39	0	0	0	0	$0
Below consumption cutoff: Bi-weekly LDAR	0.75	26	19.5	0	0	0	0	$0
Major: Monthly enhanced LDAR d, e	1	48	48	7	336	17	34	$19,734
Major: Weekly Carbon adsorber monitoring e, f	0.25	208	52	7	364	18	36	$21,378
Area: Monthly enhanced LDAR	0.75	12	9	0	0	0	0	$0
D. Develop record system
Solvent consumption	1	1	1	0	0	0	0	$0
Enhanced LDAR	1	1	1	0	0	0	0	$0
Monitoring records	1	1	1	0	0	0	0	$0
Carbon adsorber monitoring records g	1	1	1	0	0	0	0	$0
E. Time to enter information
Monthly records of solvent consumption h, i, j	0.25	12	3	7	21	9	0	$1,735
Above consumption cutoff: Records of weekly inspections	0.25	52	13	0	0	0	0	$0
Below consumption cutoff: Records of bi-weekly inspections	0.25	26	6.5	0	0	0	0	$0
Major: Enhanced LDAR	See 4C
Major: Carbon adsorber monitoring	See 4C
Area: Enhanced LDAR	See 4C
F. Time to Train personnel
Leak detection	1	2	2	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					835			$42,847
Total Labor Burden and Cost (rounded) k					842			$43,300
Total Capital and O&M Cost (rounded) k								$680
Grand TOTAL (rounded) k								$44,000
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 NESHAP over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for the benefit packages available to government employees: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c This task requires management hours only.
d 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 carbon adsorber monitoring record systems.
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 only three major sources will require managerial review.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 4: Table 1c

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)
Affected Sector	Number of Responses	Labor Hours			Labor Cost	Capital and O&M Cost
		Reporting	Recordkeeping	Total
Private	7	42,529	1,547,814	1,590,343	$197,000,000	$947,000
Public (Federal)	30,460	7	835	842	$43,300	$680
Total	30,467	42,536	1,548,649	1,591,185	$197,043,300	$947,680
Total (rounded)				1,590,000	$197,000,000	$948,000
				52	hrs/response

---

Sheet 5: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal)
Burden Item	(A) EPA Technical hours per occurrence	(B) Occurrences per year a	(C) Technical hours per year (A x B)	(D) Management hours per year (C x 0.05)	(E) Clerical hours per year (C x 0.10)	(F) Total cost per year ($) b
1. Report review								Labor Rates:
A. Initial notification report	1	2,330	2,330	116.5	233	$136,839.97		Management	$70.56
B. Compliance method report c	1	1,631	1,631	81.55	163.1	$95,787.98		Technical	$52.37
C. Solvent consumption report d	1	699	699	34.95	69.9	$41,051.99		Clerical	$28.34
D. Report-exceed consumption cutoff e	1	117	117	5.83	11.7	$6,842.00
TOTAL (rounded) f			5,490			$281,000
Assumptions:
a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources per 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 the NESHAP over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for the benefit packages available to government employees: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c 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.
d 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 PCE per year) and are required to perform this task.
e We assume that five percent of new sources will have to report-exceed consumption cutoff.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 6: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs - Private Sector								Capital/Startup vs. Operation and Maintenance (O&M) Costs - Public Sector
(A)	(B)	(C)	(D)	(E)	(F)	(G)		(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)		Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
PID	$3,300	0	$0	$95	13	$1,235		PID	$3,300	0	$0	$95	7	$665
HHD	$250	2,330	$582,500	$14	20,000	$280,000		HHD	$250	0	$0	$14	0	$0
Initial notification & compliance report	-	-	-	$6.37	2,330	$14,842		Initial notification & compliance report	-	-	-	$6.37	0	$0
Report exceed consumption cutoff	-	-	-	$6	117	$702		Report exceed consumption cutoff	-	-	-	$6	0	$0
Photocopying	-	-	-	$2.40	28,013	$67,231		Photocopying	-	-	-	$2.40	7	$17
Total			$582,500			$364,010		Total			$0			$682
Total (rounded)			$583,000			$364,000		Total (rounded)			$0			$680
					Total (rounded)	$947,000							Total (rounded)	$680

---

Sheet 7: Responses

Total Annual Responses - Private Sector						Total Annual Responses - Public Sector
(A)	(B)	(C)	(D)	(E)		(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D		Information Collection Activity	Number of Respondents	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	1	25,683	28,013		Write Initial Notification Report	0	0	7	7
Compliance Method Report	1,631	1	0	1,631		Compliance Method Report	0	0	0	0
Solvent Consumption Report	699	1	0	699		Solvent Consumption Report	0	0	0	0
Report Exceed Consumption Cutoff	117	1	0	117		Report Exceed Consumption Cutoff	0	0	0	0
			Total	30,460					Total	7		30,467
			25,690

---

Sheet 8: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are No Longer Subject 2	Number of Respondents (E=A+B+C-D)
1	2,330	28,020	0	2,330	28,020
2	2,330	28,020	0	2,330	28,020
3	2,330	28,020	0	2,330	28,020
Average	2,330	28,020	0	0	28,020
1 New respondent include sources with constructed, reconstructed and modified affected facilities.
2 We assume that the overall number of facilities will remain constant due to retirement of old existing facilities.