**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 I CR Number 1985.0 5, OMB Control Number 2060

- 0478 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Leather Finishing Operations wer e 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. Le ather finishing is defined as a single process or group of processes used to adjust and improve the phy sical 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 o r collectively a major source of HAP emissions. A major source emits or has the potential to emit any s ingle HAP at the rate of 10 tons (9.07 megagrams) or more per ye ar , or any

combination of HAP at a rate of 25 tons (22.68 megagrams) or more per ye ar. In general, all NESHAP standards require initial notifications, p erformance 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 fini shing 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 b y 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 f inishing 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 ye ar. Any owner or operator subject to the provisio ns 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,2

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 ye ars. 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 directl y 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 ye ar will become subject to the regulation in the next three ye ars. There are approximately ten leather finishing operations facilities in the United States , which are owned and operated b y the leather finishing industry . N one of the se ten facilities are owned b y state, local, tribal or the Federal government. In stead, they are all privately

- owned and operated by

f or -profit businesses. Y ou can find the burden to the “Affected Public” listed in Table 1: Annual Industry

B urden 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 ) (Ren ewal)

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

When this I CR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs and ensure these estimates have been updated.
EPA has addressed ea ch item of concern in the TOC. The respondent burden, universe , labor rates, and capital cost have been thoroughl y 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 n ew 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, durin g such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data3 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 reasonabl y require.
Inthe Administrator's judgment, HAP emissions from leather finishing operations cause or contribute to air pollution that may reaso nabl y b e 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 i nitial 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 paramete rs 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 subjec t to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y 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 I CR is used by the A gency

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 directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists.4

**3(b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this IC R 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) Consultation s**  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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all co mpliance 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 associ ations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In dev eloping this ICR, we contacted the Alliance Leather Incorporated at (978) 531

- 6771, and Collier S hannon Scott (202) 342

- 8400. It is our polic y to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. **3(d) Effects of Less Frequent Collection** Less frequ ent 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 b y these standards was collected less frequentl y, 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 notifi cations for at least five years. This is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitati ons 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 p attern of non - compliance, and to determine the appropriate level of enforcement action. E PA has found that the most flagrant violators have violations extending beyond the five years. In5

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 Agenc y fo r which a claim of confidentiality i s 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 b y 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 Infor mation Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are leather finishing operations. The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standard is 3111 which correspond to the North American Industry Classification Sy stem (NAI CS) 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 T TTT). 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 o f 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)6

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 respondent s 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 sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approxi mately 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the pur

pose of disclosing and providing information. Adjust the existing way s 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 info rmation. Currently , sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring s ys tem.) Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipm ent has significantly reduced the burden associated with monitoring and recordkeeping.7

**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, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **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 properl y installed and operational. Performance test reports are used b y 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.
In formation contained in the reports i s entered into OTI S 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. E PA use s OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve , and analyze the data. The records required b y this regul ation must be retained by the owner or operator for five ye ars. **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 con sideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes 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. T o the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.8

**5(d) Collection Schedule** The specific frequency

f or each information collection activity w ithin 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 I CR. The individual burdens are e xpressed 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

knowledg e and experience with the NESHAP program, the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $118.92 ($56.63 + 110%) Technical $9 7.78 ($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, "Tot al 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 indu stry resulting from information collection activities required b y 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 special9

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 anal ys is of th e 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 hourl y 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 p ackages 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 ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR. **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)10 **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

- ye ar period of this ICR is 10. The total number of annual responses per ye ar 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

. D etail s regarding these estimates may b e 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, respectivel y, and summarized below. **(i) Respondent Tally**11

The total annual labor costs are $ 31,495

. D etails regarding these estimates may b e found in Tab le 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 hour s 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 I CR as compared to the previous I CR. This situation is due to two considerations: 1) the regulations have not changed over the past three ye ars 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 chan ge in the overall burden. There is, however, an increase in the estimated burden cost as currentl y 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 mos t 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 b y 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 s ys tems for the purposes of collecting, val idating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 info rmation 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0 206

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of12

information, submit or view public comments, access the index listing of the content of the docket, and to ac cess those documents in the public docket that are available electronically . When in the sy stem, 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 Comp liance Docket and In formation 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 le gal 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, yo u can send comments to the Office of Information and Re gulatory 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

- 20 11

- 0 206 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)**

**(Renew al)** 

**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)** 

**Managem ent**  **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 Ty pe 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 1 2 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 ,430.1014

**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)** 

**Managem ent**  **person hours per year**  **( Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

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

**Assu mptions:**  a We h ave assumed that there are approximately ten sources that are subject to the standard, and no additional ne w so urces will be come 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, Decembe r, 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 respond ent twelve hours once per year to com plete 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 compl iance ratio determination on a monthly basis. f We have assumed that it will take each respondent five hours once per year to train personnel.15

**Table 2:**  **A verage**  **Annual EPA**  **Burden**
**- NESHAP**  **for Leather**  **Fi nishing**  **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)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Activity Revie w 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

**Assu mptions:**  a We have assumed that there are approximately ten s ources 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 deviat ion report.