| Respondent Wages ($2017) |
| Category (1) |
Hourly Mean Wage (2) |
Loaded Wage (3) |
| Technical |
$45.29 |
$95.11 |
| Clerical |
$18.03 |
$37.86 |
| Managerial |
$48.98 |
$102.86 |
| Footnotes: |
|
|
| (1) The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2017 National Industry-Specific Occupational Employment and Wage Estimates NAICS 316100 - Leather and Hide Tanning and Finishing," found here: |
| https://www.bls.gov/oes/current/naics4_316100.htm |
| (2) Selected "mean hourly wage" in the table referenced in footnote 1. |
| (3) Loaded Wage is the 2016 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry. |
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| EPA Wages ($2018) |
| Category (1) |
Hourly Mean Wage |
Wage With Fringe & Overhead (2) |
| (GS- 12, step 1) - Technical |
$30.47 |
$48.75 |
| (GS- 13, step 5) - Managerial |
$41.07 |
$65.71 |
| (GS-6, step 3) - Clerical |
$16.49 |
$26.38 |
| Footnotes: |
|
|
| (1) The hourly mean wage for each category is found here: |
|
|
| https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/GS_h.pdf |
| (2) Wage with fringe and overhead is the hourly mean wage increased by 60 percent to account for the benefit packages available to government employees. |
| Table 1 - Annual Respondent Burden and Cost - NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT) (Renewal) |
|
|
|
|
| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(J) |
|
|
|
|
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (AxB) |
Respondents per year a |
Total Number of Responses per Year
(B X D) |
Technical person- hours per year
(CxD) |
Management person hours per year (Fx0.05) |
Clerical person hours per year (Fx0.1) |
Total Cost Per year b |
|
|
|
|
|
|
|
|
|
|
|
|
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
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|
|
|
|
|
|
|
|
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with regulatory requirements |
1 |
1 |
1 |
4 |
4 |
4 |
0.2 |
0.4 |
$416 |
<-- Updated to cover all respondents, but changed to 1 hr per occurance. |
|
|
|
| B. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Leather production determination |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Type of Product process determination |
2 |
4 |
8 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Allowable HAP loss determination c |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Actual HAP loss determination c |
1 |
12 |
12 |
0 |
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 |
$0 |
|
|
|
|
| Notification of intent to construct |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Notification of startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Notification of performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Notification of compliance status d |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Annual compliance status certification e |
12 |
1 |
12 |
4 |
4 |
48 |
2.4 |
4.8 |
$4,993.83 |
Reduced burden - RTR reduced # respondents from 10 to 4 |
|
|
|
| Deviation report f |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Subtotal for Reporting Requirements |
|
60 |
$5,410 |
|
|
|
|
| 4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions and rule revisions |
See 3A |
|
|
|
|
|
|
|
|
|
|
|
|
| B. Develop compliance plan |
50 |
1 |
50 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| C. Enter information |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Finish inventory |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| HAP content of finish |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Leather subcategory production levels |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| D. Record compliance ratio g |
1 |
12 |
12 |
4 |
48 |
48 |
2.4 |
4.8 |
$4,993.83 |
Reduced burden - RTR reduced # respondents from 10 to 4 |
|
|
|
| E. Train personnel h |
5 |
1 |
5 |
4 |
4 |
20 |
1.0 |
2.0 |
$2,080.76 |
Reduced burden - RTR reduced # respondents from 10 to 4 |
|
|
|
| F. Audits |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
|
78 |
$7,075 |
|
|
|
|
| TOTAL LABOR BURDEN AND COST (rounded) i |
|
|
|
|
|
138 |
$12,500 |
|
|
|
|
| TOTAL CAPITAL AND O&M COST i |
|
|
|
|
|
|
|
|
$0 |
|
|
|
|
| GRAND TOTAL (rounded) i |
|
|
|
|
|
|
|
|
$12,500 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
|
| a There are four respondents 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: $102.86 per hour for Executive, Administrative, and Managerial labor; $95.11 per hour for Technical labor, and $37.86 per hour for Clerical labor. The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2017 National Industry-Specific Occupational Employment and Wage Estimates
NAICS 316100 - Leather and Hide Tanning and Finishing.” found here: https://www.bls.gov/oes/current/naics4_316100.htm. 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 the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D. |
|
|
|
|
| d Moved this initial notification to a separate line. In Table 1 of the current ICR for the Leather Finishing Operations NESHAP, this notification is included with the Annual compliance status certification. |
|
|
|
|
| e We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report. |
|
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|
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| f We have assumed that no respondent will submit a deviation report. |
|
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|
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| g We have assumed that each respondent is required to record compliance ratio determination on a monthly basis. |
|
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|
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| h We have assumed that it will take each respondent five hours once per year to train personnel. |
|
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|
|
| i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
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|
|
|
|
|
|
|
|
|
|
| Table 2 - Annual EPA Burden and Cost - NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT) (Renewal) |
|
| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
| EPA person- hours per occurrence |
No. of occurrences per plant per year |
EPA person- hours per plant per year (AxB) |
Plants per year a |
Technical person- hours per year (CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
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 c |
20 |
1 |
20 |
4 |
80 |
4 |
8 |
$4,374.08 |
Reduced burden - RTR reduced # respondents from 10 to 4 |
| 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 COST (rounded) |
92 |
$4,370 |
|
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|
|
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|
|
|
| Assumptions: |
|
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|
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| a There are four 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 have been increased by 60 percent to account for the benefit package available to government employees: $65.71 Managerial rate (GS-13, Step 5, $41.07 + 60%), $48.75 Technical rate (GS-12, Step 1, $30.47 + 60%), and $26.38 Clerical rate (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule which excludes locality rates of pay. |
|
| c We have assumed that each respondent will take 20 hours to review the annual compliance status certification report. |
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| d We have assumed that no respondent will submit a deviation report. |
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|