




TECHNICAL MEMORANDUM

TO:	Bill Schrock, U.S. EPA/OAQPS/SPPD  -  Natural Resources Group

FROM:	Eastern Research Group, Inc.

DATE:	September 27, 2018

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SUBJECT:	Costs for the Leather Finishing Operations Source Category Risk and Technology Review  -  Final Amendments
INTRODUCTION
      This memorandum describes the methodologies for estimating costs to comply with the amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP): Leather Finishing Operations (40 CFR part 63, subpart TTTT) Risk and Technology Review. The EPA is revising the monitoring, recordkeeping, or reporting requirements for subpart TTTT, which will impose additional costs on leather finishing operations. We estimate that there will be costs for the four existing facilities associated with review of the promulgated standards, as discussed in section 2.0. The rule amendments include additional recordkeeping and reporting requirements for any leather operation that elects to comply with the standard using an emission control device; however, none of the four existing leather operations currently use an emission control device to comply with subpart TTTT, and we are not aware of any planned or potential new or reconstructed leather finishing operations. As a result, "0" leather finishing operations will comply with these new requirements, which will result in no added cost to the industry. Further, the rule amendments include revised recordkeeping and reporting requirements for any leather finishing operation that deviates from the standards; however, these revised records and reports add no additional burden because the EPA anticipates that no facilities will deviate from the standards during the three years of this information collection.

TOTAL COSTS
      The total national costs to comply with the rule are $832 (see "Leather Finishing RTR Cost Memo Workbook - Final Amendments," available in Docket ID No. EPA-HQ-OAR-2003-0194). We estimate that, in the first year following promulgation of these final amendments, each of the four existing affected facilities will spend 2 technical labor hours, 0.2 clerical labor hours, and 0.1 managerial labor hours to review the revised rule. United States Department of Labor rates of $45.29, $18.03, and $48.98 (labor rates are in 2017 dollars) were used for the technical, clerical, and managerial labor categories, respectively. For the purposes of this cost analysis, these rates were increased by 110 percent to account for the benefit packages available to those employed by private industry.  
REFERENCES
 United States Department of Labor, Bureau of Labor Statistics, table titled "May 2017 National Industry-Specific Occupational Employment and Wage Estimates NAICS 316100 - Leather and Hide Tanning and Finishing," available at: https://www.bls.gov/oes/current/naics4_316100.htm.   
 Eastern Research Group, Leather Finishing RTR Cost Memo Workbook  -  Final Amendments, September 2018.
