1
PART
A
OF
THE
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83­
I
Leather
Finishing
Operations
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection
"
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Leather
Finishing
Operations"

(
b)
Short
Characterization
Respondents
are
owners
or
operators
of
any
existing,

reconstructed,
or
new
leather
finishing
operation,
which
is
defined
as
an
individual
process
or
group
of
processes
used
for
the
finishing
of
leather.
Leather
finishing
is
defined
as
a
single
process
or
group
of
processes
used
to
adjust
and
improve
the
physical
and
aesthetic
characteristics
of
the
leather
surface
through
the
multistage
application
of
a
coating
comprised
of
dyes,
pigments,
film­
forming
materials,
and
performance
modifiers
dissolved
or
suspended
in
liquid
carriers.
A
leather
finishing
operation
is
only
subject
to
the
regulation
if
it
is
a
major
source
of
HAP
emissions,
or
is
collocated
with
other
sources
that
are
individually
or
collectively
a
major
source
of
HAP
emissions.

"
Major
source"
means
that
the
process
used
to
finish
the
leather
and
any
supporting
equipment
used
in
finishing
operations
at
a
facility
emit
or
have
the
potential
to
emit
10
tons
per
year
or
more
of
a
single
HAP
or
25
tons
per
year
or
more
of
any
combination
of
HAP.

Owners
or
operators
of
leather
finishing
operations
must
submit
a
number
of
notifications
and
reports
to
demonstrate
compliance
with
the
Leather
Finishing
Operations
NESHAP.
Each
existing
leather
finishing
operation
that
is
a
major
source
must
submit
an
initial
notification
which
includes:
the
name
and
address
of
the
owner
or
operator,
the
physical
address
of
the
source,
and
a
brief
description
of
the
source
including
the
types
2
of
leather
product
process
operations
performed
and
nominal
operating
capacity.
Any
leather
finishing
operation
that
starts
up
after
proposal
but
before
promulgation
must
submit
an
initial
notification,
similar
to
the
one
submitted
by
existing
sources.

Each
new
or
reconstructed
source
that
starts
up
after
promulgation
must
submit
a
series
of
notifications
in
addition
to
the
initial
notification
which
include:
notification
of
intent
to
construct
or
reconstruct
and
notification
of
startup.

Both
new
and
existing
leather
finishing
operations
must
develop
a
plan
for
demonstrating
compliance
which
specifies
procedures
to
measure
finish
amounts
used,
HAP
content
of
finishes,
and
production
levels
for
each
leather
product
process
operation.
The
plan
for
demonstrating
compliance
must
be
completed
by
the
compliance
date
and
kept
on
site
and
available
for
inspection.
The
source
must
follow
the
specific
procedures
in
the
plan
for
demonstrating
compliance
to
document
the
finish
amount
used,
the
HAP
content
of
the
finish,
and
the
production
levels
for
each
leather
product
process
operation.

Once
a
leather
finishing
operation
has
collected
12
months
of
leather
production
data
after
the
date
of
initial
notification,
the
leather
finishing
operation
must
submit
an
annual
compliance
status
certification
report.
This
report
includes:
the
name
and
address
of
the
owner
or
operator,
the
physical
address
of
the
source,
each
product
process
operation
type
performed
during
the
previous
12
months,
each
HAP
identified
in
finishes
applied
during
the
previous
12
months,
and
a
compliance
status
certification
indicating
whether
the
source
complied
with
all
of
the
requirements
of
these
NESHAP
during
the
previous
12
months.
Each
subsequent
year,
the
source
must
submit
an
annual
compliance
status
certification
report.

All
reports
are
submitted
to
the
U.
S.
EPA
Administrator.
If
the
Administrator
has
delegated
authority
to
your
State,
then
the
State
has
the
primary
authority
to
administer
and
enforce
these
NESHAP.
If
the
Administrator
has
not
delegated
authority
to
your
3
State,
then
the
EPA
Regional
Office
has
the
primary
authority
to
administer
and
enforce
these
NESHAP.

The
information
collection
involves
19
respondents,
which
includes
18
existing
and
1
new
sources
over
the
3­
year
period.

The
total
respondent
cost
is
estimated
to
be
$
64,705.
The
Agency
cost
is
estimated
to
be
$
7,673.

(
c)
Deviation
from
the
standard
If
the
owner
or
operator
reports
a
compliance
ratio
greater
than
1.00
resulting
from
a
known
or
unknown
cause
for
which
no
Federally­
approved
or
promulgated
exemption
from
an
emission
limitation
or
standard
applies,
then
a
deviation
report
must
be
written
and
submitted
to
the
Administrator
by
the
fifteenth
of
the
following
month
in
which
you
determined
the
deviation
from
the
compliance
ratio.
The
deviation
report
must
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
the
compliance
ratio
was
reported
to
be
greater
than
1.00.

(
d)
Record
retention
Owners
or
operations
of
a
leather
finishing
operation
must
maintain
a
copy
of
all
NESHAP
related
records
for
a
period
of
five
years
after
each
occurrence,
measurement,
maintenance
action,
or
corrective
action.
These
records
must
be
kept
onsite
for
a
minimum
of
two
years
after
each
occupance,
measurement,

maintenance
action,
or
corrective
action.
All
reports
are
to
be
submitted
upon
request
to
EPA
or
the
respondent's
state
or
local
agency,
which
ever
has
been
delegated
enforcement
authority
by
EPA.
The
information
will
be
used
to
determine
whether
or
not
leather
finishing
operations
subject
to
the
NESHAP
are
achieving
the
standards.
4
2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
Environmental
Protection
Agency
is
charged
under
section
112
of
the
Clean
Air
Act
(
CAA),
as
amended
in
1990,
to
establish:

.
.
.
emission
standards
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants
listed
for
regulation...

A
revised
list
of
source
categories
was
published
in
the
Federal
Register
on
June
4,
1996
(
61
FR
28207)
which
added
the
source
category
of
leather
tanning
and
finishing
operations.

However,
these
proposed
NESHAP
modifies
the
listing
of
this
source
category
by
deleting
tanning
facilities
from
the
definition
and
renaming
the
source
category
Leather
Finishing
Operations.
In
addition,
section
114(
a)(
1)
of
the
CAA
states
that:

.
.
.
the
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source
or
who
is
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
or
methods,
(
D)
sample
such
emissions
(
in
accordance
with
such
methods,
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),

and
(
E)
provide
such
other
information,
as
he
may
reasonably
require.

Certain
reports
are
necessary
to
enable
the
Administrator
to
identify
leather
finishing
operations
subject
to
these
NESHAP
and
to
determine
if
the
standards
are
being
achieved.

(
b)
Use/
Users
of
the
Data
5
The
information
will
be
used
by
Agency
enforcement
personnel
to
identify
sources
subject
to
the
standards
and
ensure
that
the
emission
standard
is
being
met.

In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
leather
finishing
operations
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,

the
EPA
can
decide
which
leather
finishing
operations
and
what
records
should
be
inspected.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Duplication
in
the
reporting
of
leather
finishing
operations
emission
data
is
not
anticipated.
These
NESHAP
are
the
only
federal
emission
standards
to
be
applied
to
leather
finishing
operations
at
this
time.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
This
section
does
not
apply
since
public
notice
will
be
given
as
part
of
the
proposal
process
for
the
Leather
Finishing
Operations
NESHAP.

(
c)
Consultations
The
EPA
advised
interested
parties
in
1996
of
additional
categories
considered
as
major
sources
of
HAP.
Several
meetings
were
also
held
with
affected
sources
during
development
of
the
proposed
standards
to
solicit
comments
on
the
requirements.
The
EPA
received
a
total
of
seven
letters
commenting
on
the
proposed
standard.
The
comments
were
summarized
and
addressed
in
the
EPA
document
"
Public
Comments
and
EPA
Responses
to
the
Proposed
NESHAP
for
Leather
Finishing
Operations
(
Docket
No.
A­
99­
38)."

Changes
made
to
the
rule
as
a
result
of
addressing
these
comments
did
not
affect
the
estimate
of
burden
for
the
standard.

(
d)
Effects
of
Less
Frequent
Data
Collection
The
Leather
Finishing
Operations
NESHAP
requires
the
reports
described
in
1(
b)
of
this
supporting
statement.
6
If
the
relevant
information
were
collected
less
frequently,
the
EPA
would
not
be
reasonably
assured
that
a
facility
is
in
compliance
with
the
standard.

(
e)
General
Guidelines
This
rule
requires
that
owners
and
operators
of
leather
finishing
operations
retain
compliance
records
for
a
minimum
period
of
5
years,
thus
exceeding
general
guidelines
for
records
to
be
kept
for
3
years.
The
longer
time
period
is
necessary
for
the
NESHAP
to
be
consistent
with
the
5­
year
recordkeeping
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
Since
each
leather
finishing
operation
is
required
to
obtain
an
operating
permit,
the
5­
year
recordkeeping
requirement
of
the
NESHAP
does
not
increase
the
recordkeeping
burden.
This
collection
does
not
violate
any
of
the
other
general
guidelines
for
information
collections.

(
f)
Confidentiality
Most
data
submitted
will
not
be
confidential.
If
any
information
is
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made,
the
information
would
be
safeguarded
according
to
the
Agency
policies
set
forth
in
title
40,
chapter
1,
part
2,
subpart
B.

(
g)
Sensitive
Questions
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAICS
(
SIC
codes)

Respondents
are
owners
or
operators
of
any
existing,

reconstructed,
or
new
leather
finishing
operation.
The
North
American
Industrial
Classification
System
(
NAICS)
codes
for
the
leather
finishing
operations
affected
by
the
NESHAP
include
Code
3161
­­
Leather
and
Hide
Tanning
and
Finishing.
Under
the
old
SIC
reference
system,
leather
finishing
operations
affected
by
7
the
NESHAP
are
classified
as
Code
3111
­­
Leather
Tanning
and
Finishing.

(
b)
Information
Requested
(
i)
Data
items
Attachment
1,
entitled
Source
Data
and
Information
Requirements,
summarizes
the
section
of
the
regulation
that
contain
the
requirements.

(
ii)
Respondent
Activities
The
activities
that
will
allow
the
respondent
to
meet
the
reporting
and
recordkeeping
requirements
of
the
Leather
Finishing
Operations
NESHAP
are
provided
under
the
first
column
of
Tables
1,
2,
and
3.

Respondent
activities
that
will
allow
the
respondent
to
meet
the
reporting
and
recordkeeping
requirements
of
the
Leather
Finishing
Operations
NESHAP
are
provided
under
the
first
column
of
Tables
1,
2,
and
3.

5.
The
Information
Collected
­
­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
A
list
of
Agency
activities
is
provided
in
Tables
4,
5,

and
6.

(
b)
Collection
Methodology
and
Management
Respondents
for
existing
leather
finishing
operations
will
submit
an
initial
notification
to
EPA
as
described
in
1(
b).
8
From
the
Excel
spreadsheet,
insert
Table
1
9
From
the
Excel
spreadsheet,
insert
Table
2
10
From
the
Excel
spreadsheet,
insert
Table
3
11
From
the
Excel
spreadsheet,
insert
Table
4
12
From
the
Excel
spreadsheet,
insert
Table
5
13
From
the
Excel
spreadsheet,
insert
Table
6
14
These
respondents
must
also
develop
a
plan
for
demonstrating
compliance
by
the
compliance
date.
The
plan
for
demonstrating
compliance
must
be
kept
on
site
and
available
for
inspection.

The
plan
for
demonstrating
compliance
will
detail
how
the
source
will
record
and
report
the
finish
inventory,
HAP
content
of
the
finishes,
and
the
production
level
in
each
type
of
leather
product
process
operation.
Since
this
information
request
includes
only
the
first
three
years
after
promulgation
of
the
rule,
recordkeeping
and
compliance
status
reports
for
existing
sources
are
not
included.
A
few
new
sources
will
report
as
discussed
below.

Respondents
for
new
or
reconstructed
sources
must
submit
a
series
of
notifications
associated
with
construction
and
startup
of
the
process.
A
new
source
must
develop
and
implement
a
plan
for
demonstrating
compliance
upon
startup.
Within
60
days
of
its
first
compliance
ratio
determination,
a
source
must
submit
a
compliance
status
notification.
The
source
then
submits
an
annual
compliance
status
certification
every
12
calendar
months
following
the
compliance
status
notification.

Respondents
will
most
likely
submit
hard
copy
reports,

although
some
may
submit
electronic
versions.
The
rule
allows
records
to
be
retained
in
hard
copy
or
electronic
format
to
allow
flexibility
and
minimize
burden.
The
EPA
will
review
the
submitted
information
to
determine
whether
a
source
is
in
compliance
with
the
rule.
Files
of
the
hard
copy
reports
will
be
kept
by
Regional
Offices.
The
EPA
will
use
location
and
facility
information
submitted
in
the
reports
to
update
the
Aerometric
Information
Retrieval
System
(
AIRS)
facility
subsystem
operated
by
the
Office
of
Air
Quality
Planning
and
Standards.
Data
in
AIRS
can
be
publicly
accessed
via
the
Internet
from
Envirofacts
at
http://
www.
epa.
gov/
enviro/
index_
java.
html
or
through
a
Freedom
of
Information
Act
request
to
EPA.
As
part
of
EPA's
ongoing
enforcement
program,
compliance
inspections
will
be
conducted
to
verify
compliance.
Data
obtained
during
such
inspections
will
be
15
tabulated
and
published
for
EPA
internal
use
in
enforcement
programs.

(
c)
Small
Entity
Flexibility
For
these
NESHAP,
the
EPA
defines
a
small
entity
as
a
leather
finishing
operation
that
does
not
meet
the
major
source
definition.
These
sources
are
exempt
from
the
rule.

(
d)
Collection
Schedule
Schedules
for
the
initial
and
periodic
reports
are
described
in
section
6(
a).

6.
Estimating
The
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
Tables
1,
2,
and
3
present
an
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
with
the
annual
cost
and
labor
requirements
for
the
respondents
subject
to
these
NESHAP
for
the
three
year
period
following
promulgation
that
is
required
to
be
included
on
OMB
form
83­
I.
Table
1
presents
the
annual
cost
and
labor
respondent
burden
estimates
for
the
first
year
after
promulgation.
Tables
2
and
3
present
the
burden
estimates
for
years
2
and
3,
respectively.

The
cost
and
burden
estimates
were
derived
from
EPA's
experience
with
other
standards
and
from
discussions
with
industry
representatives.
There
are
approximately
18
sources
currently
operating
that
will
have
to
comply
with
the
NESHAP.

These
sources
will
submit
an
initial
notification
report,
and
develop
a
plan
for
demonstrating
compliance
within
the
first
three
years
after
promulgation.

It
is
estimated
that
one
leather
finishing
operation
will
be
constructed
or
reconstructed
following
proposal
of
the
Leather
Finishing
Operations
NESHAP.
This
new
or
reconstructed
source
must
submit
the
following:
notification
of
intent
to
construct
or
reconstruct,
notification
of
startup,
and
notification
of
actual
emission
data.
By
the
startup
date,
the
new
leather
16
finishing
operation
must
develop
and
implement
a
plan
for
demonstrating
compliance
that
specifies
how
the
source
will
measure
and
record
finish
usage,
HAP
content
of
the
finishes,
and
the
production
level
in
each
leather
product
process
operation.

New
sources
that
startup
after
the
effective
date
of
these
NESHAP
must
be
in
compliance
upon
startup.
A
new
source
must
also
submit
a
initial
notification
no
later
than
60
days
after
its
initial
start­
up
of
production
equipment.
The
source
then
submits
an
annual
compliance
certification
report
every
12
months
following
the
initial
notification.

The
reporting
and
recordkeeping
requirements
differ
in
each
of
the
first
3
years
after
promulgation
of
the
NESHAP.
During
the
first
year,
initial
notifications
will
be
required
from
all
18
leather
finishing
facilities.
During
the
second
year,
only
one
new
or
modified
source
will
submit
any
notifications,

reports,
or
plans.
During
the
third
year,
all
18
existing
sources
must
develop
a
plan
for
demonstrating
compliance.

The
majority
of
burden
items
are
one­
time
only
requirements.

The
only
recurring
burden
items
are
the
annual
compliance
certification
report
and
monthly
compliance
ratio
determinations.

The
time
required
to
document
finish
usage,
to
document
HAP
content
of
finishes,
and
to
document
production
levels
of
leather
product
process
operations
are
nominal
and
in
most
cases
are
already
being
performed
for
other
purposes
such
as
business
accounting,
state
reporting
requirements,
or
local
reporting
requirements.
Therefore,
the
recordkeeping
can
be
performed
by
existing
personnel.

(
b)
Estimating
Respondent
Costs
The
total
cost
for
each
respondent
activity
which
includes
operating
and
maintenance
(
O&
M)
costs,
labor
costs,
capital
costs,
and
startup
costs
are
presented
in
Tables
1,
2,
and
3.

(
i)
Estimating
Labor
Costs
Labor
costs
were
estimated
using
available
labor
rates
(
March
1999)
posted
on
the
Internet
under
the
Private
Industry
17
Employment
Cost
Trends
reported
by
the
Bureau
of
Labor
Statistics
at
http://
stats.
bls.
gov.
The
total
compensation
hourly
rate
which
includes
wages,
salaries
and
benefits
for
the
private
and
civilian
sector
for
technical
workers
is
$
45,
managerial
workers
is
$
67
and
clerical
workers
at
$
28.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
Leather
Finishing
Operations
NESHAP
does
not
require
any
special
monitoring
or
recordkeeping
equipment.
Therefore,
no
capital
and
operations
and
maintenance
costs
are
associated
with
recordkeeping
or
reporting
for
the
Leather
Finishing
Operations
NESHAP.

(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
burden
and
cost
estimates
include
only
those
items
where
the
government
would
incur
additional
costs
as
a
result
of
the
information
collection.
These
costs
include
user
costs
associated
with
the
review
and
analysis
of
the
reported
information.
These
are
presented
in
Tables
4,
5,
and
6.
Labor
rates
and
associated
costs
are
assumed
to
be
the
same
as
those
used
for
the
respondent
burden
estimate:
$
45/
technical
hour,

$
67/
management
hour,
and
$
28/
clerical
hour.

Items
of
cost
that
have
or
would
already
be
incurred
because
of
other
ongoing
programs
were
not
included.
It
will
take
the
agency
no
additional
time
to
collect
the
information
from
respondents
because
the
NESHAP
requires
respondents
to
submit
the
required
reports.
EPA
will
publish
the
NESHAP
in
the
Federal
Register,
making
it
available
on
the
EPA
Technology
Transfer
Network
(
TTN)
via
the
Internet
at
http://
www.
epa.
gov/
ttn/.

The
EPA
will
notify
states,
trade
associations,
etc.
as
part
of
EPA's
normal
rule
communication
procedures,
so
there
will
be
no
additional
costs
for
notifying
respondents
of
information
collection
requirements.
There
will
be
no
costs
for
database
development
or
distribution
of
collected
information
because
the
information
will
be
used
to
update
the
existing
AIRS
facility
subsystem
database.
There
will
be
no
additional
costs
for
18
examining
records
that
are
maintained
by
the
respondent
(
rather
than
submitted).
This
examination
would
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program
and,
therefore,

would
not
be
incurred
as
a
result
of
NESHAP
requirements.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
The
burden
is
estimated
for
18
existing
and
1
new
or
reconstructed
source.
The
18
existing
sources
will
submit
the
initial
notification,
and
develop
a
plan
for
demonstrating
compliance.
The
1
new
or
reconstructed
source
must
submit
a
notification
of
intent
to
construct
or
reconstruct
and
notification
of
startup.
This
new
or
reconstructed
source
must
also
develop
a
plan
for
demonstrating
compliance
upon
startup.

The
total
three
year
cost
for
all
the
respondents
is
$
64,705.
Dividing
the
three
year
total
by
three
yields
an
annual
average
burden
of
$
21,568.
This
total
is
presented
in
Table
7.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
A
breakdown
for
each
of
the
respondents
collection,

reporting,
and
recordkeeping
activities
required
by
the
NESHAP
is
presented
in
Tables
1,
2,
and
3.
The
estimate
of
total
annual
hours
and
the
annualized
cost
requested
from
the
respondents
provided
in
13(
c)
and
14(
c)
of
OMB
form
83­
I
is
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
supporting
statement.
The
EPA
estimates
the
respondent
burden
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff,

for
the
first
3
years
after
promulgation
and
then
dividing
that
total
by
three.
The
results
are
summarized
in
Table
7.
The
EPA
estimates
that
in
each
of
the
three
years
after
promulgation,
the
leather
finishing
industry
would
expend
485
hours
(
422
technical,

21
managerial
and
42
clerical)
at
a
cost
of
$
21,568
to
meet
the
monitoring,
recordkeeping,
and
reporting
requirements.

(
ii)
The
Agency
Tally
19
Tables
4,
5,
and
6
provides
a
breakdown
for
each
of
the
Agency
activities
required
for
the
NESHAP.
The
review
activities
and
the
labor
costs
vary
each
year
according
to
respondent
submittals.
The
bottom
line
Agency
burden
hours,
presented
in
20
From
the
Excel
spreadsheet,
insert
Tables
7
and
8
21
Table
8,
are
calculated
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff
(
as
specified
for
respondents),
and
then
dividing
each
by
three.
The
estimated
average
annual
burden
for
the
Agency
would
be
58
hours
(
50
technical,
3
managerial
and
5
clerical)
annually
at
a
cost
of
$
2,558
per
year.

(
iii)
Variations
in
the
Annual
Bottom
Line
The
respondent
costs
for
year
3
are
greater
than
year
1
and
year
2
because
the
18
existing
leather
finishing
operations
are
required
to
develop
and
implement
a
plan
for
demonstrating
compliance.
During
the
first
year,
existing
sources
must
also
read
related
directions
and
submit
an
initial
notification.

During
the
second
year,
only
1
new
or
modified
source
is
required
to
submit
or
develop
reports,
plans,
or
notifications.
An
itemized
list
of
variations
for
year
1
through
year
3
are
provided
in
Tables
1,
2,
and
3,
respectively.
A
summary
of
the
respondent
burden
and
labor
estimate
including
the
year
totals
and
annual
averages
is
provided
in
Table
7.

The
Agency
burden
does
not
vary
as
widely
each
year
for
the
first
three
years
after
promulgation.
Tables
4,
5,
and
6
itemize
the
variation
in
burden
each
year.

A
summary
of
the
annual
burden
and
the
three
year
averages
are
provided
in
Table
8.
The
costs
in
year
one
are
the
highest
because
the
18
existing
sources
will
submit
initial
notifications.
The
cost
in
year
2
is
the
lowest,
because
only
1
new
or
reconstructed
leather
finishing
operation
is
required
to
submit
a
notification.
Review
of
the
plan
for
demonstrating
compliance
is
optional
and
unlikely
for
the
Government
to
review
until
the
annual
compliance
certification
report
indicates
a
problem.

(
f)
Reasons
for
Change
In
Burden
This
is
the
first
submittal
of
this
burden
estimate;

therefore,
this
section
is
not
applicable.

(
g)
Burden
Statement
22
Table
7
presents
a
summary
of
the
annual
burden
and
cost
for
leather
finishing
operations.
The
total
respondent
burden
is
estimated
to
average
26.9
hours
per
respondent
per
year.
This
estimate
includes
time
for
reporting
and
recordkeeping
activities
required
by
the
Leather
Finishing
Operations
NESHAP.
Table
8
presents
a
summary
of
the
annual
burden
and
cost
for
the
Federal
Government.
The
total
burden
for
the
Federal
Government
is
estimated
to
average
3.2
hours
per
respondent
per
year.
This
estimate
includes
time
for
recordkeeping
and
support
activities
required
by
the
Leather
Finishing
Operations
NESHAP.

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.

An
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.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
U.
S.
Environmental
Protection
Agency,
Office
of
Environmental
Information,

Collection
Strategies
Division
(
2822),
1200
Pennsylvania
Avenue,
23
NW,
Washington,
DC
20460;
and
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.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
24
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
25
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
Reference
Recordkeeping
Finish
Inventory
HAP
Content
Leather
Inventory
63.5335
and
63.5430
63.5390
and
63.5430
63.5400
and
63.5430
12
month
Compliance
Ratio
63.5330
and
63.5430
Reporting
Existing
Sources
Initial
Notification
63.5415
New
Sources
Notification
of
intent
to
construct
or
reconstruct
Notification
of
Startup
All
Sources
Notification
of
intent
to
conduct
a
Site­
Specific
Test
63.5415
63.5415
63.5415
Notification
of
Compliance
Status
63.5415
Annual
Compliance
Certification
63.5420
Deviation
Report
63.5420
