SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT)
(Renewal) 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT)
(Renewal), 

EPA ICR Number 1985.05, OMB Control Number 2060-0478

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Leather Finishing Operations were proposed (65 FR 58702) on October
2, 2000, 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 subject to the regulation only 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, 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 a 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.

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.

There are approximately ten leather finishing operations facilities in
the United States, which are owned and operated by the leather finishing
industry.  None of these ten facilities are owned by state, local,
tribal or the Federal government.  Instead, they are all privately-owned
and operated by for-profit businesses.  You can find the burden to the
“Affected Public” listed in Table 1: Annual Industry Burden and Cost
- NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT)
(Renewal).  The Federal government burden associated with the review of
reports submitted by the respondent is shown in Table 2: Average Annual
EPA Burden - NESHAP for Leather Finishing Operations (40 CFR Part 63,
Subpart TTTT) (Renewal).

In the development of the ICR, we addressed the Office of Management and
Budget (OMB) “Terms of Clearance (TOC)” on the active ICR.  The TOC
are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, labor rates, and capital costs and ensure these estimates have
been updated.

EPA has addressed each item of concern in the TOC.  The respondent
burden, universe, labor rates, and capital cost have been thoroughly
checked, and all estimates updated.

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 HAP.  These standards are
applicable to new or existing sources of HAP and shall require the
maximum degree of emission reduction.  In addition, section 114(a)
states that the Administrator may require any owner or operator subject
to any requirement of this Act to:

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

In the Administrator's judgment, 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 where 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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

The information generated by the monitoring, recordkeeping, and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.

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

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart TTTT.

3(a)  Non-duplication

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 their own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, 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 (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts. 
Approximately 10 respondents will be subject to the standard over the
three-year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed.  In developing this ICR, we contacted the
Alliance Leather Incorporated at (978) 531-6771, and Collier Shannon
Scott (202) 342-8400. 

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

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

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
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance, and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to either the destruction or
nonexistence of essential records.

3(f)  Confidentiality

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

3(g)  Sensitive Questions

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 United States Standard Industrial
Classification (SIC) code for the respondents affected by the standard
is 3111 which correspond to the North American Industry Classification
System (NAICS) code 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

In this ICR, all the data recorded or reported is required by the
National Emission Standards for Hazardous Air Pollutants for Leather
Finishing Operations (40 CFR Part 63, Subpart TTTT).

A source must make the following reports:

Notifications

Initial notification	63.5415(b), 63.5415(d), 63.9(b)

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

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

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

Notification of compliance status	63.5415(f), 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), 63.5335(b)

Maintain records of HAP content	63.5430(e), 63.5390

Maintain records of leather inventory	63.5430(f), 63.5400

Record 12 months compliance ratio	63.5330, 63.5430



Electronic Reporting

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

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

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 monitoring equipment that provides
parameter data in an automated way (e.g., continuous parameter
monitoring system.)  Although personnel at the source still need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

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

5(a)  Agency Activities

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

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  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 OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA delegated Authorities can
edit, store, retrieve, and analyze the data.

The records required by this regulation must be retained by the owner or
operator for five years.

5(c)  Small Entity Flexibility

The majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  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 to be the minimum
requirements 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
Leather Finishing Operations (40 CFR Part 63, Subpart TTTT) (Renewal).

6.  Estimating the Burden and Cost of the Collection

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

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
(see 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	$118.92 ($56.63 + 110%)   

Technical	$97.78 ($46.56 + 110%)

Clerical	$48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2010, "Table 2. Civilian Workers, by
Occupational and Industry group."  The rates are from column 1, "Total
Compensation."  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

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

The only costs to the regulated industry resulting from information
collection activities required by the subject standards are labor costs.
 There are no capital/startup or operation and maintenance 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 is labor costs.  There are no
capital/startup or operation and maintenance costs.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $10,365.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  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) (Renewal).

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

	Based on our research for this ICR, on average over the next three
years, approximately 10 respondents will be subject to the standard.  It
is estimated that no additional sources per year will become subject. 
The overall average number of respondents, as shown in the table below
is 10 per year. 

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

Number of Respondents

Year	(A)

Number of New Respondents 1	(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	0	0	10

2	0	10	0	0	10

3	0	10	0	0	10

Average	0	10	0	0	10

1 New respondents include sources with constructed, reconstructed, and
modified affected facilities.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 10.

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	N/A	0

Notification of intent to construct or reconstruct	0	1	N/A	0

Notification of actual startup	0	1	N/A	0

Notification of site-specific test plant	0	1	N/A	0

Notification of compliance status	0	1	N/A	0

Annual compliance status certification	10	1	N/A	10

Deviation report	0	1	N/A	0



	Total	10



The number of Total Annual Responses is 10.

The total annual labor costs are $31,495.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT)
(Renewal).

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,
and summarized below. 

(i)  Respondent Tally

The total annual labor costs are $31,495.  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)
(Renewal).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 33
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $0.

(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 $10,365.  See Table 2:
Annual Agency Burden and Cost: NESHAP for Leather Finishing Operations
(40 CFR Part 63, Subpart TTTT) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR as compared to the
previous ICR.  This situation is due to two considerations: 1) the
regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for the industry is very low, negative, or non-existent, so there is no
significant change in the overall burden.

There is, however, an increase in the estimated burden cost as currently
identified in the OMB Inventory of approved Burdens.  The increase is
not due to any program changes.  The change in burden cost is due to the
use of the most updated labor rates.  

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
EPA-HQ-OECA-2011-0206.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
http://www.regulations.gov/  which may be used to obtain a copy of the
draft collection of information, submit or view public comments, access
the index listing of the content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than key in the docket ID number
identified in this document.  The documents are also available for
public viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301
Constitution Avenue, N.W., 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 Docket is (202) 566-1927. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, N.W.,
Washington, DC 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0206 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 (40 CFR Part 63, Subpart TTTT) (Renewal)

Burden item	(A)

Person hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours per year

(Ex0.1)	(H)

Total Cost 

Per year b



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	See 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 certification c	12	1	12	10	120
6	12	$13,032.24

          Deviation report d		5	1	5	0	0	0	0	$0

Subtotal for Reporting Requirements





138



4.  Recordkeeping requirements









     A.  Read instructions 	See 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	120	6	12	$13,032.24

     E.  Time to train personnel f	5	1	5	10	50	2.5	5	$5,430.10

     G.  Time for audits	N/A







	Subtotal for Recordkeeping Requirements





195.5



Subtotals Labor Burden and cost  



	290	14.5	29	$31,494.58

TOTAL LABOR BURDEN AND COST (rounded)





333.5

334 (rounded)

$31,495



Assumptions:

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

  b This ICR uses the following labor rates:  $118.92 per hour for
Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December, 2010, Table 2. Civilian Workers, by Occupational
and Industry group.  The rates are from column 1, Total Compensation. 
The rates have been increased by 110 percent to account for the benefit
packages available to those employed by private industry.

c  We have assumed that it will take each respondent twelve hours once
per year to complete the compliance status certification report.

d  We have assumed that no respondent will submit a deviation report.

e  We have assumed that each respondent is required to record compliance
ratio determination on a monthly basis.

f  We have assumed that it will take each respondent five hours once per
year to train personnel.

	

Table 2:  Average Annual EPA Burden - NESHAP for Leather Finishing
Operations (40 CFR Part 63, Subpart TTTT) (Renewal)

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant per year	(C)

EPA person- hours per plant per year

(C=AxB)	(D)

Plants per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person-hours per year

(Ex0.05)

	(G)

Clerical person-hours per year

(Ex0.1)	(H)

Cost, $ b

Activity









Review reports









     a.  Initial notification 	4	1	4	0	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 c	20	1	20	10	200	10	20	$10,364.90

     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

Subtotals Labor Burden and cost



	200	10	20	$10,364.90

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	230	$10,365



 	Assumptions:

    a  We have assumed that there are approximately ten  sources that
are subject to the standard, and no additional new sources will become
subject to the rule over the next

    three years.

         b This cost is based on the following labor rates which
incorporates a 1.6 benefits multiplication factor to account for
government overhead expenses: $62.27                       Managerial
rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step
1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6).
 These rates are from the Office of Personnel Management (OPM) 2011
General Schedule which excludes locality rates of pay.

c  We have assumed that each respondents will take 20 hours to review
the annual compliance status certification report.

d  We have assumed that no respondent will submit a deviation report.

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