SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Leather
Finishing
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
TTTT)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Leather
Finishing
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
TTTT)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Leather
Finishing
Operations
were
proposed
on
October
2,
2000
(
65
FR
58702).
This
standard
applies
to
each
existing,
reconstructed,
or
new
leather
finishing
operation.
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
comprising
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
hazardous
air
pollutant
(
HAP)
emissions,
or
is
collocated
with
other
sources
that
are
individually
or
collectively
a
major
source
of
HAP
emissions.
A
major
sources
emits
or
has
the
potential
to
emit
any
single
HAP
at
the
rate
of
10
tons
(
9.07
megagrams)
or
more
per
year
or
any
combination
of
HAP
at
a
rate
of
25
tons
(
22.68
megagrams)
or
more
per
year.

In
general,
all
NESHAP
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
NESHAP.

Owners
or
operators
of
new
or
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
the
site
and
available
for
inspection.
The
source
must
document
the
finish
amount
used,
the
HAP
content
of
the
finish,
and
the
production
level
for
each
leather
product
process
operation.
Once
a
leather
finishing
operation
has
collected
twelve
months
of
leather
production
data
after
the
date
of
initial
notification,
the
leather
finishing
operation
must
submit
an
annual
compliance
status
certification
report
each
year.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Each
file
will
be
on
the
site
for
at
least
two
years
after
the
date
2
of
each
occurrence,
measurement,
maintenance,
report
or
record,
and
off­
site
for
the
remaining
three
years.
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
United
States
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).

Approximately
ten
respondents
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
at
$
21,279.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner/
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,
HAP
emissions
from
leather
finishing
operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
3
TTTT.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
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
standard
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
and
leaks
are
being
detected
and
repaired
and
the
standard
is
being
met.
The
performance
test
may
also
be
observed.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
TTTT.

3(
a)
Nonduplication
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
a
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

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
(
69
FR
55430)
on
September
14,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
consulted
with
the
preparer
of
the
active
ICR,
and
used
several
different
resources
to
obtain
the
most
recent
data
4
available.
We
accessed
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
and
other
websites
covering
leather
finishing
operations.
We
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division,
Collier
Shannon
Scott,
John
Whittenbourne,
(
202)
342­
8400,
and
Alliance
Leather
Incorporated,
Michael
Listro,
(
978)
531­
6771.

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
is
useful
technique
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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

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
(
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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.
5
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
leather
finishing
operations.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
United
States
Standard
Industrial
Classification
(
SIC)
3111
which
corresponds
to
the
The
North
American
Industry
Classification
System
(
NAICS)
316110
for
Leather
and
Hide
Tanning
and
Finishing.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NESHAP
for
Leather
Finishing
Operations
(
40
CFR
part
63,
subpart
TTTT).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Initial
notification
63.5415(
b),
63.5415(
d)
and
63.9(
b)

Notification
of
intent
to
construct
or
reconstruct
63.5415(
d)
and
63.9(
b)

Notification
of
actual
startup
63.5415(
b)
and
63.9(
b)

Notification
of
site­
specific
test
plan
63.5415(
e)
and
63.7(
b)

Notification
of
compliance
status
63.5415(
f)
and
63.9(
h)

Annual
compliance
status
certification
63.5420(
a)

Deviation
report
63.5420(
b)

A
source
must
keep
the
following
records:
6
Recordkeeping
Maintain
records
of
finish
inventory
63.5430(
d)
and
63.5335(
b)

Maintain
records
of
HAP
content
63.5430(
e)
and
63.5390
Maintain
records
of
leather
inventory
63.5430(
f)
and
63.5400
Record
12
months
compliance
ratio
63.5330
and
63.5430
Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
temperature,
pressure
drop,
leaks
and
spills
of
mercury,
etc.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

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

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
leather
finishing
operations
processes.

Perform
initial
performance
test,
Reference
Methods
24,
311
tests,
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.
7
Respondent
Activities
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.

Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
sources
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
Air
Facility
System
(
AFS).

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.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
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
AFS
for
tracking
air
pollution
compliance
and
8
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
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
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
in
Table
1:
Annual
Industry
Burden
for
NESHAP
for
Leather
Finishing
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
TTTT).

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.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

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
334
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
9
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
96.41
($
45.91
+
110%)
Technical
$
82.74
($
39.40
+
110%)
Clerical
$
42.25
($
20.12
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September,
2004,
"
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.

(
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
costs,
because
the
leather
finishing
operations
does
not
require
any
special
monitoring
or
recordkeeping
equipment,
therefore,
no
capital
and
operations
and
maintenance
costs
are
associated
with
recordkeeping
or
reporting
to
the
rule.

(
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
are
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
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
9,067.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
10
Average
Annual
EPA
Burden
­
NESHAP
for
Leather
Finishing
Operations
(
40
CFR
part
63,
subpart
TTTT),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
ten
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
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
0
10
N/
A
0
10
2
0
10
N/
A
0
10
3
0
10
N/
A
0
10
Average
10
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
10.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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
Initial
notification
0
1
0
0
Notification
of
intent
to
construct
or
reconstruct
0
1
0
0
Notification
of
actual
startup
0
1
0
0
Notification
of
site­
specific
test
plan
0
1
0
0
11
Total
Annual
Responses
Notification
of
compliance
status
0
1
0
0
Annual
compliance
status
certification
10
1
0
10
Deviation
report
0
1
0
0
Total
10
The
number
of
Total
Annual
Responses
is
10.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
21,279.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Leather
Finishing
Operations
(
40
CFR
part
63,
subpart
TTTT),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
21,279.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Leather
Finishing
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
TTTT),
attached.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
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
next
three
years
is
estimated
to
be
230
labor
hours
at
a
cost
of
$
9,097.
See
Table
2.
Annual
Agency
Burden
and
Cost,
Average
Annual
EPA
Burden
­
NESHAP
for
Leather
Finishing
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
TTTT),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
the
burden
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
sources.
Our
data
indicates
that
there
are
approximately
ten
sources
12
subject
to
the
rule,
as
compared
to
the
active
ICR
that
shows
twelve
sources.
There
are
no
new
facilities
expected
to
be
constructed
in
the
next
three
years.
The
decline
in
the
number
of
sources
was
due
to
the
high
energy
cost
to
operate
the
machinery
and
foreign
competition.
Our
research
also
shows
that
since
the
removal/
delisting
of
the
compound
ethylene
glycol
butyl
ether
(
EGBE)
from
the
list
of
HAPs
that
the
Agency
regulates
under
the
Clean
Air
Act,
a
number
of
leather
finishing
facilities
that
use
EGBE
will
no
longer
be
subject
to
the
Clean
Air
Act
Amendments'
CAAA's
Maximum
Achievable
Control
Technology
(
MACT)
requirements,
thus
the
number
of
sources
would
be
decreased
even
more
over
the
next
three
years.

There
are
no
capital/
startup
or
operation
and
maintenance
costs,
because
NESHAP
for
Leather
Finishing
Operations
does
not
require
any
special
monitoring
or
recordkeeping
equipment;
therefore,
no
capital
and
operations
and
maintenance
costs
are
associated
with
recordkeeping
or
reporting
to
the
rule.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
33
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.

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's
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
OECA­
2004­
0032,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
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
above.
Also,
you
can
send
comments
to
13
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
OECA­
2004­
0032
and
OMB
Control
Number
2060­
0478
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
14
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Leather
Finishing
Operations
(
Renewal)(
40
CFR
part
63,
subpart
TTTT)

Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
requirements
A.
Read
Instructions
4
1
4
0
0
0
0
$
0
B.
Required
Activities
Leather
production
determination
1
12
12
0
0
0
0
$
0
Type
of
Product
process
determination
2
4
8
0
0
0
0
$
0
Allowable
HAP
loss
determination
1
12
12
0
0
0
0
$
0
Actual
HAP
Loss
Determination
1
12
12
0
0
0
0
$
0
C.
Create
information
N/
A
D.
Gather
existing
information
Included
in
4E
E.
Write
report
Initial
notification
2
1
2
0
0
0
0
$
0
Notification
of
intent
to
construct
2
1
2
0
0
0
0
$
0
Notification
of
startup
2
1
2
0
0
0
0
$
0
Notification
of
site­
specific
test
plan
2
1
2
0
0
0
0
$
0
15
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
a
Submit
annual
compliance
status
c
certification
12
1
12
10b
120
6
12
$
8,805.00
Deviation
report
d
5
1
5
0
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Develop
compliance
plan
50
1
50
0
0
0
0
$
0
C.
Time
to
enter
information
Finish
inventory
1
12
12
0
0
0
0
$
0
HAP
content
of
finish
1
12
12
0
0
0
0
$
0
Leather
subcategory
production
levels
1
12
12
0
0
0
0
$
0
D.
Record
compliance
ratio
e
1
12
12
10
b
120
6
12
$
8,805.00
E.
Time
to
train
personnel
f
5
1
5
10
b
50
2.5
5
$
3,668.75
F.
Time
for
audits
N/
A
Subtotal
Labor
Burden
290
14.5
29
$
21,278.75
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
334
$
21,279
Assumptions:

a
This
ICR
uses
the
following
labor
rates:
$
95.32
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.60
per
hour
for
Technical
labor,
and
$
40.09
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
16
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.

b
We
have
assumed
that
there
are
ten
existing
sources,
and
that
no
additional
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.

c
We
have
assumed
that
it
will
take
twelve
hours
to
complete
a
compliance
status
certification
report.

d
We
have
assumed
no
deviation
reports
will
be
submitted.

e
Recordkeeping
requirements
are
required
monthly
for
compliance
ratio
determinations.

f
We
have
assumed
that
it
will
take
five
hours
to
train
personnel.
17
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Leather
Finishing
Operations
(
Renewal)(
40
CFR
part
63,
subpart
TTTT)

Burden
item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost,

Per
Yeara
Activity
Report
review
a.
Initial
notification
4
1
4
0b
0
0
0
$
0
b.
Notification
of
intent
to
construct
4
1
4
0
0
0
0
$
0
c.
Notification
of
startup
4
1
4
0
0
0
0
$
0
d.
Notification
of
site­
specific
test
4
1
4
0
0
0
0
$
0
Periodic
Reports
a.
Review
annual
compliance
status
certification
20
1
20
10c
200
10
20
$
9,097.00
b.
Review
deviation
reports
d
10
1
10
0
0
0
0
$
0
Optional
Review
compliance
plan
20
1
20
0
0
0
0
$
0
TOTAL
LABOR
BURDEN
AND
COST
(
ROUNDED
230
$
9,097
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.66
for
Managerial
(
GS­
13,
Step
5,
$
34.16
x
1.6),
$
40.56
for
Technical
(
GS­
12,
Step
1,
$
25.35
x
1.6)
and
$
21.95
Clerical
(
GS­
6,
Step
3,
$
13.72
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

b
We
have
assumed
that
no
additional
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.
18
c
We
have
assumed
that
there
are
ten
existing
sources.

d
We
have
assumed
that
no
deviation
reports
will
be
submitted.
