Burden Tables

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Overview

Cover
Inputs
Current ICR
Att 1_TBL1-YR1
Att 1_TBL2-YR2
Att 1_TBL3-YR3
Att 1_TBL4-SUMMARY
Att 2_TBL5-EPA-YR1
Att 2_TBL6-EPA-YR2
Att 2_TBL7-EPA-YR3
Att 2_TBL8-EPA SUMMARY

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Sheet 1: Cover

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
National Emission Standards for Hazardous Air Pollutants for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT) (Amendments)
ATTACHMENT 1
	TABLES 1, 2, 3, and 4
Tables 1 - 3:	Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP – Years 1-3 (Amendments)
Table 4:	Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP (Amendments)
ATTACHMENT 2
	TABLES 5, 6, 7, and 8
Tables 5 - 7:	Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 1-3 (Amendments)
Table 8:	Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP (Amendments)

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Sheet 2: Inputs

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.
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.

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Sheet 3: Current ICR

https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201412-2060-001
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)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)	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 determinationc	1	12	12	0	0	0	0	$0
Actual HAP loss determinationc	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 certificationd	12	1	12	10	120	6	12	$13,510.56
Deviation report e	5	1	5	0	0	0	0	$0
Subtotal for Reporting Requirements					138			$13,510.56
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 f	1	12	12	10	120	6	12	$13,510.56
E. Time to train personnel g	5	1	5	10	50	2.5	5	$5,629.40
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					196
TOTAL LABOR BURDEN AND COST (rounded)						334		$32,651
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: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March, 2014, 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 the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D.
d We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report.
e We have assumed that no respondent will submit a deviation report.
f We have assumed that each respondent is required to record compliance ratio determination on a monthly basis.
g We have assumed that it will take each respondent five hours once per year to train personnel.
Table 2: Average Annual EPA Burden and Cost – NESHAP for Leather Finishing Operations (40 CFR Part 63, Subpart TTTT)
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	Plants per year a	Technical person- hours per year	Management person-hours per year	Clerical person-hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)
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	20	1	20	10	200	10	20	$10,468.00
certification c
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 ANNUAL BURDEN AND COST (rounded)					230			$10,468
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 have been increased by 60 percent to account for the benefit package available to government employees: $62.90 Managerial rate (GS-13, Step 5, $39.31 + 60%), $46.67 Technical rate (GS-12, Step 1, $29.17 + 60%), and $25.25 Clerical rate (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) 2014 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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Sheet 4: Att 1_TBL1-YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 1 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(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 Hours per Year (F + G + H)	Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions and rule revisions
Read instructions	4	1	4	0	0	0	0	0	0	$0
Read and understand rule revisionsc	2	1	2	4	4	8	0.4	0.8	9.2	$832.31
B. Required activities
Leather production determination	1	12	12	0	0	0	0	0	0	$0
Type of Product process determination	2	4	8	0	0	0	0	0	0	$0
Allowable HAP loss determinationd	1	12	12	0	0	0	0	0	0	$0
Actual HAP loss determinationd	1	12	12	0	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	$0
Notification of intent to construct	2	1	2	0	0	0	0	0	0	$0
Notification of startup	2	1	2	0	0	0	0	0	0	$0
Notification of site-specific test plan	2	1	2	0	0	0	0	0	0	$0
Notification of compliance statuse	12	1	12	0	0	0	0	0	0	$0
Annual compliance status certificationf	12	1	12	4	4	48	2.4	4.8	55.2	$4,993.83
Deviation reportg	6	1	6	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements					8	56	2.8	5.6	64.4	$5,826
4. Recordkeeping requirements
A. Read instructions and rule revisions	See 3A
B. Develop compliance plan	50	1	50	0	0	0	0	0	0	$0
C. Enter information
Finish inventory	1	12	12	0	0	0	0	0	0	$0
HAP content of finish	1	12	12	0	0	0	0	0	0	$0
Leather subcategory production levels	1	12	12	0	0	0	0	0	0	$0
D. Record compliance ratioh	1	12	12	4	48	48	2.4	4.8	55.2	$4,993.83
E. Train personnel i	5	1	5	4	4	20	1.0	2.0	23.0	$2,080.76
F. Audits	N/A
G. Record Deviation Reportg	1	1	1	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					52	68	3.4	6.8	78.2	$7,075
TOTAL LABOR BURDEN AND COST (rounded)					60	124	6.2	12.4	142.6	$12,901
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: $106.70 per hour for Executive, Administrative, and Managerial labor; $79.17 per hour for Technical labor, and $36.73 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 2016 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 Burden item was added due to the 2017 proposed amendments.
d We have assumed that the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D.
e 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.
f We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report.
g We have assumed that no respondent will submit a deviation report. Due to the 2017 amendments, the person hours per occurance for writing the deviation report are increased from 5 to 6, and 1 hour is added to prepare records associated with the deviation report.
h We have assumed that each respondent is required to record compliance ratio determination on a monthly basis.
i We have assumed that it will take each respondent five hours once per year to train personnel.

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Sheet 5: Att 1_TBL2-YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 2 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(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 Hours per Year (F + G + H)	Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions and rule revisions
Read instructions	4	1	4	0	0	0	0	0	0	$0
Read and understand rule revisionsc	2	1	2	0	0	0	0	0	0	$0
B. Required activities
Leather production determination	1	12	12	0	0	0	0	0	0	$0
Type of Product process determination	2	4	8	0	0	0	0	0	0	$0
Allowable HAP loss determinationd	1	12	12	0	0	0	0	0	0	$0
Actual HAP loss determinationd	1	12	12	0	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	$0
Notification of intent to construct	2	1	2	0	0	0	0	0	0	$0
Notification of startup	2	1	2	0	0	0	0	0	0	$0
Notification of site-specific test plan	2	1	2	0	0	0	0	0	0	$0
Notification of compliance statuse	12	1	12	0	0	0	0	0	0	$0
Annual compliance status certificationf	12	1	12	4	4	48	2.4	4.8	55.2	$4,993.83
Deviation report g	6	1	6	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements					4	48	2.4	4.8	55.2	$4,994
4. Recordkeeping requirements
A. Read instructions and rule revisions	See 3A
B. Develop compliance plan	50	1	50	0	0	0	0	0	0	$0
C. Time to enter information
Finish inventory	1	12	12	0	0	0	0	0	0	$0
HAP content of finish	1	12	12	0	0	0	0	0	0	$0
Leather subcategory production levels	1	12	12	0	0	0	0	0	0	$0
D. Record compliance ratioh	1	12	12	4	48	48	2.4	4.8	55.2	$4,993.83
E. Train personnel i	5	1	5	4	4	20	1.0	2.0	23.0	$2,080.76
F. Audits	N/A
G. Record Deviation Reportg	1	1	1	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					52	68	3.4	6.8	78.2	$7,075
TOTAL LABOR BURDEN AND COST (rounded)					56	116	5.8	11.6	133.4	$12,068
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: $106.70 per hour for Executive, Administrative, and Managerial labor; $79.17 per hour for Technical labor, and $36.73 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 2016 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 Burden item was added due to the 2017 proposed amendments.
d We have assumed that the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D.
e 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.
f We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report.
g We have assumed that no respondent will submit a deviation report. Due to the 2017 amendments, the person hours per occurance for writing the deviation report are increased from 5 to 6, and 1 hour is added to prepare records associated with the deviation report.
h We have assumed that each respondent is required to record compliance ratio determination on a monthly basis.
i We have assumed that it will take each respondent five hours once per year to train personnel.

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Sheet 6: Att 1_TBL3-YR3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 3 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(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 Hours per Year (F + G + H)	Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions and rule revisions
Read instructions	4	1	4	0	0	0	0	0	0	$0
Read and understand rule revisionsc	2	1	2	0	0	0	0	0	0	$0
B. Required activities
Leather production determination	1	12	12	0	0	0	0	0	0	$0
Type of Product process determination	2	4	8	0	0	0	0	0	0	$0
Allowable HAP loss determinationd	1	12	12	0	0	0	0	0	0	$0
Actual HAP loss determinationd	1	12	12	0	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	$0
Notification of intent to construct	2	1	2	0	0	0	0	0	0	$0
Notification of startup	2	1	2	0	0	0	0	0	0	$0
Notification of site-specific test plan	2	1	2	0	0	0	0	0	0	$0
Notification of compliance statuse	12	1	12	0	0	0	0	0	0	$0
Annual compliance status certificationf	12	1	12	4	4	48	2.4	4.8	55.2	$4,993.83
Deviation report g	6	1	6	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements					4	48	2.4	4.8	55.2	$4,994
4. Recordkeeping requirements
A. Read instructions and rule revisions	See 3A
B. Develop compliance plan	50	1	50	0	0	0	0	0	0	$0
C. Time to enter information
Finish inventory	1	12	12	0	0	0	0	0	0	$0
HAP content of finish	1	12	12	0	0	0	0	0	0	$0
Leather subcategory production levels	1	12	12	0	0	0	0	0	0	$0
D. Record compliance ratioh	1	12	12	4	48	48	2.4	4.8	55.2	$4,993.83
E. Train personnel i	5	1	5	4	4	20	1.0	2.0	23.0	$2,080.76
F. Audits	N/A
G. Record Deviation Reportg	1	1	1	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					52	68	3.4	6.8	78.2	$7,075
TOTAL LABOR BURDEN AND COST (rounded)					56	116	5.8	11.6	133.4	$12,068
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: $106.70 per hour for Executive, Administrative, and Managerial labor; $79.17 per hour for Technical labor, and $36.73 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 2016 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 Burden item was added due to the 2017 proposed amendments.
d We have assumed that the burden associated with monthly recording of actual and allowable HAP loss values are included in burden item 4D.
e 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.
f We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report.
g We have assumed that no respondent will submit a deviation report. Due to the 2017 amendments, the person hours per occurance for writing the deviation report are increased from 5 to 6, and 1 hour is added to prepare records associated with the deviation report.
h We have assumed that each respondent is required to record compliance ratio determination on a monthly basis.
i We have assumed that it will take each respondent five hours once per year to train personnel.

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Sheet 7: Att 1_TBL4-SUMMARY

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP (Amendments)
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Annualized Capital/Startup and O&M) Costs	Total Costs
1	124.0	12.4	6.2	142.6	$12,901	$0.00	$12,901
2	116.0	11.6	5.8	133.4	$12,068	$0.00	$12,068
3	116.0	11.6	5.8	133.4	$12,068	$0.00	$12,068
Total	356.0	35.6	17.8	409.4	$37,038	$0	$37,038
Average	118.7	11.9	5.9	136.5	$12,346	$0	$12,346
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	4	60.0	64.4	78.2	142.6	2.4	35.7
2	4	56.0	55.2	78.2	133.4	2.4	33.4
3	4	56.0	55.2	78.2	133.4	2.4	33.4
Total	4	172.0	174.8	234.6	409.4	N/A	102
Average	4.0	57.3	58.3	78.2	136.5	2	34
	BURDEN DUE TO PROPOSED REVISIONS
Year	Number of Respondents	Total Hours	Labor	Non-Labor	Total Costs	Hours Per Respondent
1	4	9.2	$832.31	$0.00	$832.31	2.3
2	4	0.0	$0.00	$0.00	$0.00	0.0
3	4	0.0	$0.00	$0.00	$0.00	0.0
Total	4	9.2	$832.31	$0.00	$832	2.3
Average	4.0	3.1	$277.44	$0.00	$277	0.8

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Sheet 8: Att 2_TBL5-EPA-YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 1 (Amendments)
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 statusc	20	1	20	4	80	4	8	$4,374.08
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 ANNUAL BURDEN AND COST (rounded)					80	4	8	$4,374.08
Assumptions:
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: $64.16 Managerial rate (GS-13, Step 5, $40.10 + 60%), $47.62 Technical rate (GS-12, Step 1, $29.76 + 60%), and $25.76 Clerical rate (GS-6, Step 3, $16.10 + 60%). These rates are from the Office of Personnel Management (OPM) 2016 General Schedule which excludes locality rates of pay. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf or https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/
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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Sheet 9: Att 2_TBL6-EPA-YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 2 (Amendments)
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	20	1	20	4	80	4	8	$4,374.08
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 ANNUAL BURDEN AND COST (rounded)					80	4	8	$4,374.08
Assumptions:
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: $64.16 Managerial rate (GS-13, Step 5, $40.10 + 60%), $47.62 Technical rate (GS-12, Step 1, $29.76 + 60%), and $25.76 Clerical rate (GS-6, Step 3, $16.10 + 60%). These rates are from the Office of Personnel Management (OPM) 2016 General Schedule which excludes locality rates of pay. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf or https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/
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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Sheet 10: Att 2_TBL7-EPA-YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP - Year 3 (Amendments)
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	20	1	20	4	80	4	8	$4,374.08
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 ANNUAL BURDEN AND COST (rounded)					80	4	8	$4,374.08
Assumptions:
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: $64.16 Managerial rate (GS-13, Step 5, $40.10 + 60%), $47.62 Technical rate (GS-12, Step 1, $29.76 + 60%), and $25.76 Clerical rate (GS-6, Step 3, $16.10 + 60%). These rates are from the Office of Personnel Management (OPM) 2016 General Schedule which excludes locality rates of pay. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf or https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/
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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Sheet 11: Att 2_TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Leather Finishing Operations NESHAP (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	80	4	8	92	$4,374.08	$0.00	$4,374.08
2	80	4	8	92	$4,374.08	$0.00	$4,374.08
3	80	4	8	92	$4,374.08	$0.00	$4,374.08
Total	240	12	24	276	$13,122.24	$0.00	$13,122
Average	80	4	8	92	$4,374.08	$0.00	$4,374
			BURDEN DUE TO PROPOSED REVISIONS
			Year	Total Hours	Labor Costs
			1	0	$0
			2	0	$0
			3	0	$0