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Burden Calculation Tables
ICR 202112-2060-007 · OMB 2060-0478 · Object 117387200.
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Table 1
Table 2
# Responses
Overview
Labor RatesTable 1
Table 2
# Responses
Sheet 1: Labor Rates
| 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. | ||
Sheet 2: Table 1
| 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. | ||||||||
Sheet 3: Table 2
| 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. | ||||||||||||
Sheet 4: # Responses
| Total Annual Responses | ||||
| (A) | (B) | (C) | (D) | (E) |
| Information Collection Activity | Number of Respondents | Number of Responses | Number of Existing Respondents That Keep Records But Do Not Submit Reports | Total Annual Responses |
| Initial notification | 0 | 1 | 0 | 0 |
| Notification of intent to construct | 0 | 1 | 0 | 0 |
| Notification of startup | 0 | 1 | 0 | 0 |
| Notification of performance test | 0 | 1 | 0 | 0 |
| Notification of compliance statusd | 0 | 1 | 0 | 0 |
| Annual compliance status certificatione | 4 | 1 | 0 | 4 |
| Deviation reportf | 0 | 1 | 0 | 0 |
| Total | 4 | |||
| 138 | hrs | |||
| 35 | hr/response | |||
| File Type | application/vnd.openxmlformats-officedocument.spreadsheetml.sheet |
| File Title | Burden Calculation Tables |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |