| Respondent Wages ($2020) |
| Category (1) |
Hourly Mean Wage (2) |
Loaded Wage (3) |
| Technical |
$58.41 |
$122.66 |
| Clerical |
$28.99 |
$60.88 |
| Managerial |
$71.35 |
$149.84 |
| Footnotes: |
|
|
| (1) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2. Civilian Workers, by occupational and industry group.” |
| (2) The rates are from column 1, “Total compensation.” |
| (3) Loaded Wage is the 2020 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry. |
|
|
|
|
|
|
| EPA Wages ($2021) |
| Category (1) |
Hourly Mean Wage |
Wage With Fringe & Overhead (2) |
| (GS- 12, step 1) - Technical |
$32.02 |
$51.23 |
| (GS- 13, step 5) - Managerial |
$43.15 |
$69.04 |
| (GS-6, step 3) - Clerical |
$17.33 |
$27.73 |
| Footnotes: |
|
|
| (1) These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. |
| (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) |
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (AxB) |
Respondents per year a |
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 |
|
|
|
|
|
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
| A. Familiarize with regulatory requirements c |
1 |
1 |
1 |
4 |
4 |
0.2 |
0.4 |
$545 |
| 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 d |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
| Actual HAP loss determination d |
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 intent to conduct a performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of site-specific test plan e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of performance test results f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of compliance status |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
$0 |
| Annual compliance status certification e |
12 |
1 |
12 |
4 |
48 |
2.4 |
4.8 |
$6,539.55 |
| Deviation report g |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
| Subtotal for Reporting Requirements |
60 |
$7,085 |
| 4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
| A. Read instructions and rule revisions |
See 3A |
|
|
|
|
|
|
|
| B. Develop compliance plan |
50 |
1 |
50 |
0 |
0 |
0 |
0 |
$0 |
| C. 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 h |
1 |
12 |
12 |
4 |
48 |
2.4 |
4.8 |
$6,539.55 |
| E. Train personnel i |
5 |
1 |
5 |
4 |
20 |
1.0 |
2.0 |
$2,724.81 |
| F. Audits |
N/A |
|
|
|
|
|
|
|
| G. Record Deviation Report g |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
78 |
$9,264 |
| TOTAL LABOR BURDEN AND COST (rounded) j |
|
|
|
|
138 |
$16,300 |
| TOTAL CAPITAL AND O&M COST j |
|
|
|
|
|
|
|
$0 |
| GRAND TOTAL (rounded) j |
|
|
|
|
|
|
|
$16,300 |
|
|
|
|
|
|
|
|
|
| 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: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c We have assumed that all respondents will have to familiarize with the regulatory requirements each year. |
|
|
|
|
|
|
|
|
| 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 We have assumed that it will take each respondent twelve hours once per year to complete the compliance status certification report. For new respondents, the notification of a site-specific test plan is included in the notification of compliance status. |
| f This notification does not apply to existing respondents who do not comply with the NESHAP using a control device. This notification must be developed using the EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI). |
| g We have assumed that no respondent will submit a 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. |
|
|
|
|
|
|
|
|
| j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| 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 intent to conduct a performance test |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| e. Notification of site-specific test plan |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| f. Notification of performance test results c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
| Periodic reports |
|
|
|
|
|
|
|
|
|
|
|
|
| a. Review annual compliance status d |
20 |
1 |
20 |
4 |
80 |
4 |
8 |
$4,596.54 |
|
|
|
|
| b. Review deviation reports e |
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) f |
92 |
$4,600 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 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: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay. |
|
|
|
|
| c We have assumed it will take 4 hours to review each submission of performance test results. This notification does not apply to existing respondents who do not comply with the NESHAP using a control device. |
|
|
|
|
| d We have assumed that each respondent will take 20 hours to review the annual compliance status certification report. |
|
|
|
|
|
|
|
|
|
|
|
|
| e We have assumed that no respondent will submit a deviation report. |
|
|
|
|
|
|
|
|
|
|
|
|
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|