| 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) |
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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 |
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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2019 Labor Rates |
| 1. Applications |
N/A |
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Managerial |
$163.17 |
| 2. Survey and Studies |
N/A |
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Technical |
$130.28 |
| 3. Reporting requirements |
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Clerical |
$65.71 |
| A. Familiarize with regulatory requirements c |
1 |
1 |
1 |
4 |
4 |
0.2 |
0.4 |
$580 |
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| B. Required activities |
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| Leather production determination |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| Type of Product process determination |
2 |
4 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Allowable HAP loss determination d |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| Actual HAP loss determination d |
1 |
12 |
12 |
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 |
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| Notification of intent to construct |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of intent to conduct a performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of site-specific test plan e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test results f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status |
12 |
1 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| Annual compliance status certification e |
12 |
1 |
12 |
4 |
48 |
2.4 |
4.8 |
$6,960 |
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| Deviation report g |
5 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
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| Subtotal for Reporting Requirements |
60 |
$7,540 |
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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 |
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| C. Enter information |
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| Finish inventory |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| HAP content of finish |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| Leather subcategory production levels |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| D. Record compliance ratio h |
1 |
12 |
12 |
4 |
48 |
2.4 |
4.8 |
$6,960 |
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| E. Train personnel i |
5 |
1 |
5 |
4 |
20 |
1.0 |
2.0 |
$2,900 |
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| F. Audits |
N/A |
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| G. Record Deviation Report g |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
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Reponses |
Hrs/Reponse |
| Subtotal for Recordkeeping Requirements |
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78 |
$9,861 |
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4 |
34.5 |
| TOTAL LABOR BURDEN AND COST (rounded) j |
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138 |
$17,400 |
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| TOTAL CAPITAL AND O&M COST j |
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$0 |
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| GRAND TOTAL (rounded) j |
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$17,400 |
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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: Managerial $163.17 ($77.70+ 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
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| c We have assumed that all respondents will have to familiarize with the regulatory requirements each year. |
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| d 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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| 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. |
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| 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). |
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| g We have assumed that no respondent will submit a deviation report. |
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| h We have assumed that each respondent is required to record compliance ratio determination on a monthly basis. |
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| i We have assumed that it will take each respondent five hours once per year to train personnel. |
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| j 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) |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| 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 |
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2022 Labor Rates |
| Activity |
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Managerial |
$73.46 |
| Review reports |
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Technical |
$54.51 |
| a. Initial notification |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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Clerical |
$29.50 |
| b. Notification of intent to construct |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| c. Notification of startup |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| d. Notification of intent to conduct a performance test |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| e. Notification of site-specific test plan |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| f. Notification of performance test results c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Periodic reports |
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| a. Review annual compliance status d |
20 |
1 |
20 |
4 |
80 |
4 |
8 |
$4,891 |
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| b. Review deviation reports e |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| Optional |
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| Review compliance plan |
20 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
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| TOTAL ANNUAL BURDEN AND COST (rounded) f |
92 |
$4,890 |
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| Assumptions: |
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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. |
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| b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
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| 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. |
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| d We have assumed that each respondent will take 20 hours to review the annual compliance status certification report. |
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| e We have assumed that no respondent will submit a deviation report. |
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| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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