	SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY

NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal),                           EPA ICR Number 0997.10, OMB Control Number 2060-0079.

	1(b)  Short Characterization/Abstract

      The New Source Performance Standards (NSPS) for the Petroleum Dry Cleaners (40 CFR part 60, subpart JJJ) were proposed on December 14, 1982, promulgated on September 21, 1984, and amended on October 17, 2000.  These regulations apply to existing and new petroleum dry cleaning facilities that have a total manufacturers' rated dryer capacity equal to or greater than 38 kilograms (84 pounds).  New facilities include those that commenced construction, modification, or reconstruction after the data of proposal. A dryer installed between December 14, 1982, and September 21, 1984, in a plant with an annual solvent consumption level of less than 17,791 liters (4,700 gallons), is exempt from the requirements of this subpart.  This information is being collected to assure compliance with 40 CFR part 60, subpart JJJ.

	In general, all NSPS standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities.  They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in     the operation of an affected facility, or any period during which the monitoring system is inoperative.  These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.

	Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records.  All reports are sent to the delegated state or local authority.   In the event that there is no such delegated authority, the reports are sent directly to the U. S. Environmental Protection Agency (EPA) regional office.

	Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

	There are approximately 1,000 existing sources that currently are associated with the rule, and over the next three years an average of 20 respondents per year will become subject to the standard.  The rule stipulates that only new sources with one-time-only requirements are subject to this subpart.  Therefore, we concluded that the number of respondents for this renewal ICR is 20 sources per year.

      The Office of Management and Budget (OMB) approved the currently active Information Collection Request (ICR) with the following "Terms of Clearance (TOC)":

            This request is approved.  Prior to resubmission of this information
            collection for renewal, the agency should reassess estimated of
            burden taking into account most recent experience with the program.

      EPA has addressed each item of concern in the TOC.  The respondent universe and burden hours have been thoroughly checked and all estimates updated; industry consultations and updated labor rates were utilized to reassess the burden and cost associated with the ICR.

      The respondents to this ICR (the "Affected Public) are publicly owned and operated petroleum dry cleaning facilities.  None of the facilities are owned by either state, local and tribal agencies or the Federal government.  The burden to the "Affected Public" may be found below in Table 1: Annual Respondent Burden and Cost  -  NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).  The burden to the "Federal Government" is attributed entirely to work performed by either Federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden and Cost  -  NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

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      The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:
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            . . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated.  Section 111(a)(l).
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The Agency refers to this charge as selecting the best demonstrated technology (BDT).     Section 111 also requires that the Administrator review and, if appropriate, revise such   standards every four years.
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      In addition, section 114(a) states that the Administrator may require any owner or operator subject to any requirement of this Act to:

            (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions    (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3);  and (G) provide such other information as the Administrator may reasonably require.

      In the Administrator's judgment, pollutant emissions from petroleum dry cleaning facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare.  Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart JJJ.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act.  The collected information also is used for targeting inspections and as evidence in legal proceedings.

      Performance tests are required in order to determine an affected facility's initial capability to comply with the emission standards.  Continuous emission monitors are used to ensure compliance with the standards at all times.  During the performance test, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

	The notifications required in the standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations.  The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standards are  being met.  The performance test may also be observed.

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

	The requested recordkeeping and reporting are required under 40 CFR part 60, subpart JJJ.

	3(a)  Non-duplication

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      If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office.  Otherwise, the information is sent directly to the delegated state or local agency.  If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards.  Therefore,  duplication does not exist.
	3(b)  Public Notice Required Prior to ICR Submission to OMB

      An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (76 FR 26900) on May 9, 2011.  No comments were received on the burden published in the Federal Register.

	3(c)  Consultations

      The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years.  The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard is the Online Tracking Information System (OTIS), which is operated and maintained by EPA's Office of Compliance.  OTIS is EPA's database for the collection, maintenance, and retrieval of all compliance data.

      Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed.  In developing this ICR, we contacted: 1) the National Cleaners Association, at<PHONE_NUMBER>; 2) the Drycleaning and Laundry Institute (DLI), at<PHONE_NUMBER>; 3) Highland Cleaners, at<PHONE_NUMBER>; 4) Yale Cleaners, at<PHONE_NUMBER>; and 5) Young Cleaners, at<PHONE_NUMBER>.

      It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice.

      3(d)  Effects of Less Frequent Collection

      Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards.  Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met.  If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

	3(e)  General Guidelines

	These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB at 5 CFR part 1320, section 1320.5.

	3(f)  Confidentiality

      Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
	3(g)  Sensitive Questions

	The reporting, or recordkeeping, requirements in the standard do not include any sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

      The respondents to the recordkeeping and reporting requirements are owners or operators of petroleum dry cleaning facilities. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, and the corresponding North American Industry Classification System (NAICS) codes, are listed in the following table.

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Standard (40 CFR Part 60, Subpart JJJ)
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SIC Codes
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NAICS Codes
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Coin-Operating Laundry and Drycleaning
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7215
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812310
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Drycleaning Plants, Except Rug Cleaning
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7216
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812320
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Industrial Launderers
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7218
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812332

	4(b)  Information Requested

		(i)  Data Items

      In this ICR, all the data that are recorded or reported are required by NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ).

	A source must make the following reports:

                                 Notifications
Notification of construction/reconstruction
60.7(a)(1)
Notification of actual startup
60.7(a)(3)
Notification of initial performance test
60.8(d)
Notification of physical or operational change
60.7(a)(4)

                                    Reports
Initial performance test results
60.8(a)
Repeat performance test results
60.8(a)

	A source must keep the following records:

                                Recordkeeping
Record of startup, shutdown, and malfunctions
60.7(b)
Initial and repeat of performance tests
60.625
Records are required to be retained for two years
60.7(f)

Electronic Reporting

	Some of the respondents are using monitoring equipment that automatically records parameter data.  Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

	Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically.  However, electronic reporting systems still are not widely used.  At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

		(ii)  Respondent Activities

                             Respondent Activities
Read instructions.
Perform initial performance test, and repeat performance tests if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.
Train personnel to be able to respond to a collection of information.
Transmit, or otherwise disclose the information.

	Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring system.  Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping

5.  The Information Collected: Agency Activities, Collection Methodology, and Information Management

	5(a)  Agency Activities

	EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

                               Agency Activities
Observe initial performance tests and repeat performance tests if necessary.
Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.
Audit facility records.
Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

	5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operated.  Performance test reports are used by the Agency to discern a source's initial capability to comply with the emission standard.  Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.

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      Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance.  OTIS is EPA's database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities.  EPA uses the OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.  EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

	The records required by this regulation must be retained by the owner/operator for two years.

	5(c)  Small Entity Flexibility

      A majority of the respondents are large entities (i.e., large businesses).  However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation.  The exact number of small entities affected by this rule could not be determined, based on review of the following sources: the promulgated rule notice in the Federal Register; the Petroleum Dry Cleaners  -  Background Information for Proposed Standards (1982); and a search of publicly available current data sources.  The petroleum dry cleaning industry comprises both commercial facilities (most of which are small entities) and industrial facilities (most of which are large entities).  Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities.  The Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities.  To the extent that larger businesses can use economies of scale  to reduce their burden, the overall burden will be reduced.

      5(d)  Collection Schedule

      The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Costs − NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR.  The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act.  Wherever appropriate, specific tasks and major assumptions have been identified.  Responses to this information collection are mandatory.

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      The Agency may not conduct or sponsor, and a person is not required to respond to,        a collection of information unless it displays a currently valid OMB Control Number.

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1,849 hours (Total Labor Hours from Table 1).  This estimate is based on Agency studies and background documents from the development of this regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs

	This ICR uses the following labor rates:

		Managerial	$121.42  per hour  ($57.82 + 110%)
		Technical	$99.14  per hour    ($47.21 + 110%)
		Clerical	$49.81  per hour    ($23.72 + 110%)

	These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, "Table 2: Civilian Workers, by Occupational and Industry group."  The rates are from column 1, "Total Compensation."  The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs.  There are no capital/startup or operation and maintenance (O&M) costs.
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            (iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

      The only type of industry costs associated with the information collection activity in the regulations is labor costs.  There are no capital/startup or operation and maintenance costs.
	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis of the reported information.  EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is estimated to be $32,337.  This cost is based on the average hourly labor rate as follows:

		Managerial	$62.27   per hour    (GS-13, Step 5, $38.92 x 1.6)
		Technical	$46.21   per hour    (GS-12, Step 1, $28.88 x 1.6)
		Clerical	$25.01   per hour    (GS-6, Step 3, $15.63 x 1.6)

      These rates are from the Office of Personnel Management (OPM) "2011 General Schedule" which excludes locality rates of pay.  Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost − NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).

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

	Based on our research for this ICR, on average over the next three years, approximately 20 respondents per year will be subject to the standard.  The rule stipulates that only new sources with one-time-only requirements are subject to this subpart.

	The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

                             Number of Respondents

                        Respondents That Submit Reports
                  Respondents That Do Not Submit Any Reports

                                     Year
                                      (A)
                           Number of New Respondents
                                      (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 Also New Respondents
                                      (E)
                             Number of Respondents
                                  (E=A+B+C-D)
                                       1
                                      20
                                       0
                                       0
                                       0
                                      20
                                       2
                                      20
                                       0
                                       0
                                       0
                                      20
                                       3
                                      20
                                       0
                                       0
                                       0
                                      20
Average
                                      20
                                       0
                                       0
                                       0
                                      20

	Column D is subtracted to avoid double-counting respondents.  As shown above, the average Number of Respondents over the three-year period of this ICR is 20 per year.

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

                            Total Annual Responses
                                      (A)
                        Information Collection Activity
                                      (B)
                             Number of 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
Notification of construction/reconstruction
                                      20
                                       1
                                       0
                                      20
Notification of actual startup
                                      20
                                       1
                                       0
                                      20
Notification of initial performance test
                                      20
                                       1
                                       0
                                      20
Report of performance test
                                      20
                                       1
                                       0
                                      20
Report of repeat of performance test
                                       4
                                       1
                                       0
                                       4

                                     Total
                                      84

	The number of Total Annual Responses is 84.

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      The total annual labor costs are $177,191.  Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost  -  NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).

	6(e)  Bottom Line Burden Hours Burden and Cost Tables

	The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2, respectively, and summarized below.

		(i) Respondent Tally

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      The total annual labor costs are $177,191.  Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost  -  NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).
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      Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours per response.

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      The total annual capital/startup and O&M costs to the regulated entity are $0.  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 the next three years is estimated to be 718 labor hours at a cost of $32,337.  See below Table 2: Average Annual EPA Burden and Cost − NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal).

6(f)  Reasons for Change in Burden

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      There is an increase in labor hours for both the respondents and the Agency in this ICR compared to the previous ICR. The adjustment increase is due to an increase in the number of new or modified sources. This increase is not due to any program changes.
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      There is also an increase in the total labor and Agency costs as currently identified in the OMB Inventory of Approved Burdens.  The change in cost estimates reflects the changes in respondent numbers (described above) and updated labors rates available from the Bureau of Labor Statistics.

	6(g)  Burden Statement

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      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours per response.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.
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      An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number.  The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2011-0270.  An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the docket ID number identified in this document.  The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is<PHONE_NUMBER>, and the telephone number for the docket center is<PHONE_NUMBER>.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0270 and OMB Control Number 2060-0079 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1:  Annual Respondent Burden and Cost  -  NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal)

                                  Burden item

                                      (A)
                                    Person-
                                   hours per
                                  occurrence

                                      (B)
                                    No.  of
                                  occurrences
                                per respondent
                                   per year

                                      (C)
                                    Person-
                                   hours per
                                  respondent
                                   per year
                                    (C=AxB)

                                      (D)
                                  Respondents
                                 per year  [a]

                                      (E)
                                   Technical
                                    person-
                                   hours per
                                     year
                                    (E=CxD)

                                      (F)
                                  Management
                                 person-hours
                                   per year
                                   (Ex0.05)

                                      (G)
                                   Clerical
                                    person-
                                hours per year
                                    (Ex0.1)

                                      (H)
                                 Cost, $  [b]
1.  Applications
                                      N/A

2.  Survey and Studies
                                      N/A

3.  Reporting Requirements

   A.  Read instructions
                                Included in 4E

   B.  Required activities

       Initial performance test [c, d]
                                      61
                                       1
                                      61
                                      20
                                     1,220
                                      61
                                      122
                                                                    $134,435.83
       Repeat of performance test [c, d, e]
                                      61
                                       1
                                      61
                                       4
                                      244
                                     12.2
                                     24.4
                                                                     $26,887.17
   C.  Create information
                                    See 3B

   D.  Gather existing information
                                    See 3B

   E.   Write report

       Notification of construction/                     modification [c, f]
                                       2
                                       1
                                       2
                                      20
                                      40
                                       2
                                       4
                                                                      $4,407.73
       Notification of actual startup [c, f]
                                       2
                                       1
                                       2
                                      20
                                      40
                                       2
                                       4
                                                                      $4,407.73
       Notification of initial performance  test [c] [,] [f]
                                       2
                                       1
                                       2
                                      20
                                      40
                                       2
                                       4
                                                                      $4,407.73
       Report of performance test
                                Included in 3B

Subtotal for Reporting Requirements

                                    1,821.6

4.  Recordkeeping requirements

   A.  Read instructions
                                Included in 3A

   B.  Plan activities
                                Included in 4C

   C.  Implement activities
                                Included in 3B

   D.  Develop record system
                                      N/A

   E.  Time to enter information

       Record of all performance tests [c, g]
                                       1
                                      1.2
                                      1.2
                                      20
                                      24
                                      1.2
                                      2.4
                                                                      $2,644.64
   F. Time for audits
                                      N/A

Subtotal for Recordkeeping Requirements

                                     27.6

TOTAL LABOR BURDEN AND COST (rounded)

                                     1,849
                                                                       $177,191
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Assumptions:
a  We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years.  The rule stipulates that only new sources with one-time-only requirements are subject to this subpart.  We therefore, concluded that the number of respondents for this renewal ICR is 20 sources per year.
    b  This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per hour for Clerical labor.  These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, "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 the benefit packages available to those employed by private industry.
    [c]  This is a one-time only activity.
    [d]  We have assumed that it will take 61 hours for each respondent to complete the required activity.
    [e]  We have assumed that 20 percent of respondents will have to repeat initial performance tests due to failure.
    [f]  We have assumed that it will take 2 hours for respondents to write report.
    g  We have assumed that it will take each respondent one hour to enter information on all performance tests.

Table 2:  Average Annual EPA Burden and Cost - NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ)  (Renewal)

	Activity

                                      (A)
                                  EPA person-
                                   hours per
                                  occurrence

                                      (B)
                                    No. of
                                  occurrences
                                   per plant
                                   per year

                                      (C)
                                  EPA person
                                   hours per
                                plant  per year
                                    (C=AxB)

                                      (D)
                             Plants per year  [a]

                                      (E)
                                   Technical
                                 person-hours
                                   per year
                                    (E=CxD)

                                      (F)
                                  Management
                                 person-hours
                                   per year
                                   (Ex0.05)

                                      (G)
                                   Clerical
                                    person-
                                hours per year
                                    (Ex0.1)

                                      (H)
                                  Cost, $ [b]
1.   Initial performance test
                                      16
                                       1
                                      16
                                      20
                                      320
                                      16
                                      32
                                                                     $16,583.17
2    Repeat performance test [c, d]
                                      16
                                       1
                                      16
                                       4
                                      64
                                      3.2
                                      6.4
                                                                      $3,316.63
3.   Report review

        Notification of  construction/                  reconstruction [c]
                                       2
                                       1
                                       2
                                      20
                                      40
                                       2
                                       4
                                                                      $2,072.90
        Notification of actual startup [c]
                                       1
                                       1
                                       1
                                      20
                                      20
                                       1
                                       2
                                                                      $1,036.45
        Initial performance test [c, e]
                                      7.5
                                       1
                                      7.5
                                      20
                                      150
                                      7.5
                                      15
                                                                      $7,773.36
        Repeat performance test [c, f]
                                      7.5
                                       1
                                      7.5
                                       4
                                      30
                                      1.5
                                       3
                                                                      $1,554.67
Subtotals Labor Burden and Cost

                                      624
                                     31.2
                                     62.4
                                                                     $32,337.18
TOTAL ANNUAL BURDEN AND COST (rounded)

                                      718
                                                                        $32,337

--------------------------------------------------------------------------------
Assumptions:
a  We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years.  The rule stipulates that only new sources with one-time-only requirements are subject to this subpart.  We therefore, concluded that the number of respondents for this renewal ICR is 20 sources per year.
b  This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses:  Managerial rate of $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of Personnel Management (OPM) "2011 General Schedule" which excludes locality rates of pay.
[c]  This is a one-time only activity.
[d]  We have assumed that 20 percent of respondents will have to repeat performance test
[e]  We have assumed that each respondent will take 7.5 hours to review the initial performance test report.
[f]  We have assumed that 20 percent of respondents will have to review the repeat performance test report.


 ADVANCE \y63

	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	REGION III

1650 Arch Street

	Philadelphia, Pennsylvania  19103-2029

January 26, 2011

Ms. Joyce E. Epps, Director

Pennsylvania Department of Environmental Protection

Bureau of Air Quality

Rachel Carson State Office Building

P.O. Box 2063

Harrisburg, PA  17105-2063

Dear Ms. Epps:

On January 4, 2011, the U.S. Environmental Protection Agency (EPA)
received a revision to the Pennsylvania State Implementation Plan (SIP)
from the Pennsylvania Department of Environmental Protection (PADEP).
This revision pertains to amendments to 25 Pa. Code Chapters 121 and
129, which amends the existing regulations at §§ 121.1, 129.51,
129.52, and adds new § 129.52b for control of volatile organic compound
(VOC) emissions from paper, film, and foil surface coating processes.
EPA has determined that the submittal is administratively and
technically complete, and is reviewing it to prepare a Notice of
Proposed Rulemaking (NPR).

If members of your staff have any questions, they may direct them to
Irene Shandruk, Office of Air Program Planning, at<PHONE_NUMBER>.  She
is the principal contact for this rulemaking.

		Sincerely,

							/s/

   		Diana Esher, Director

                          		   		Air Protection Division

cc:   Arleen Shulman, PADEP

	Customer Service Hotline: 1-800-438-2474