	SF tc \l2 "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), and promulgated on February 27, 2002.  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 source 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 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
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 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.



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:



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.



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

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

(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: 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



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 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 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.

Table 1: Annual Respondent Burden and Cost - NESHAP for Leather
Finishing Operations (Renewal)(40 CFR part 63, subpart TTTT)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year	

(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)

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



       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	

10b	

120	

6	

12	

$8,805.00



 E.  Time to train personnel f	

5	

1	

5	

10b	

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 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.

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

Occurrence	

(B)   

Number  of

Occurrences

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.

c  We have assumed that there are ten existing sources.

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


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