| Table 1 - Annual Respondent Burden and Cost - NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT) (Renewal) |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(J) |
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| 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 |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting requirements |
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| 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. |
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| B. Required activities |
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| Leather production determination |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Type of Product process determination |
2 |
4 |
8 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Allowable HAP loss determination c |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Actual HAP loss determination c |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| C. Create information |
N/A |
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| D. Gather existing information |
See 4E |
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| E. Write Report |
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| Initial notification |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of intent to construct |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status d |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| 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 |
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| Deviation report f |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Subtotal for Reporting Requirements |
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60 |
$5,410 |
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| 4. Recordkeeping requirements |
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| A. Read instructions and rule revisions |
See 3A |
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| B. Develop compliance plan |
50 |
1 |
50 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| C. Enter information |
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| Finish inventory |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| HAP content of finish |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| Leather subcategory production levels |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
0 |
$0 |
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| 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 |
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| 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 |
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| F. Audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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78 |
$7,075 |
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| TOTAL LABOR BURDEN AND COST (rounded) i |
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138 |
$12,500 |
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| TOTAL CAPITAL AND O&M COST i |
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$0 |
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| GRAND TOTAL (rounded) i |
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$12,500 |
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| Assumptions: |
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| 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. |
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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. |
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| c We have assumed that the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D. |
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| 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. |
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| 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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| f We have assumed that no respondent will submit a deviation report. |
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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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| 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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