1



## Econom **ic Impacts Assessment for Proposed Revisions to the**  **Export Provisions of the Cathode Ray Tube (CRT) Rule**

**Office of Resource Conservation and Recovery Office of Solid Waste and Emergency Response**  **U.S. Environmental Protection Agency**

**November 2011**2 **EXECUTIVE SUMMARY** The Environmental Protection Agency (EPA or the Agency) is proposing to revise the export provisions of the C athode R ay T ube (CRT) final rule published on July 28, 2006 (71 FR 42928). The purpose of these proposed revisions is to address certain implementation concerns with the current export provisions of the rule. These changes will facilitate compliance with the require ments and will enable the Agency to obtain additional information on the export of this class of used electronics. T he proposed rule would affect only the export provisions of the CRT rule. It would not affect any requirements applicable to domestic management of used CRTs. Nor does this proposed action affect households or conditionally exempt small quantity generators (CESQGs). Therefore, e ntities potentially affected by

today ’s action are limited to those persons or companies who export used CRTs and CRT glass for reuse or recycling. EPA is proposing to add a definition of “CRT exporter” to the CRT rule. This proposed definition will clarify

the responsibilities of brokers and other intermediaries in fulfilling the export notice requirements. E PA is also proposing to revise the notifications that must be submitted to EPA when CRTs are exported for reuse or recycling, and to require annual reports from exporters of CRTs for recycling. This document assesses the potential economic impacts of the proposed CRT Rule revisions. **Summary of Results** G iven the minor changes being imposed b y this r ule, the results of our cost assessment reveal v ery modest cost impacts

. 1) All e xporters of CRTs (regardless of whether they are sending CRTs for Recycling or Reuse), will face a new o ne - t ime up

- front c ost to familiarize themselves with the proposed CRT r ule r evisions. This o ne - t ime c ost is expected to be incurred b y 138 CRT e xporter s . The total cost of this provision equals approximately $39,000 in the fir st ye ar following promulgation of the r ule

. 2) Exporters of CRTs sent for r ecycling will face a new requirement to produce and submit an Annual Report regarding their actual r ecycling e xports. However, because the new proposed requirement is expected to result in only 12 new reports each ye ar, the total costs to e xporters and EPA are very

low and equal a total of approximately $ 2,5 00 per y ear. 3) Added to these costs are additional annual c osts to all 138 CRT Exporters ranging from $2,386 to $4,453 for adhering to the additional information requirements proposed for both of the current Recycling & Reuse Notices. These costs, in combination with the added costs for EPA's review of these notices (estimated to be between $2,449 and $4,572 ) , brings the total annual c ost for this feature of the proposed rule to a range of approximately $4,835 t o $9,025

. In conclusion, the total estimated cost impacts from this rule are estimated to be $39,000 in year one onl y , plus annual costs in the range of $7,300 to $ 11,500 starting in ye ar one and continuing each ye ar thereafter

.3 **TABLE OF CONTENTS**

1.0 IN TRODUCTION 1.1 Background on Existing Cathode Ray Tube ( CRT ) Rule 1.2 Need for Proposed Regulatory Action 2. 0 OVERVIEW OF PROPOSED REGULATORY REQUIREMENTS 2.1 Definition of “CRT Exporter” 2.2 Proposed Rule Changes Specific to the “ Export of CRTs for Recycling ” 2. 2 .1 New Annual Report Required from Exporters of CRTs Sent for Recycling 2. 2

. 2 Additional Destination Data Requested as Part of the Recycling Notice 2. 3 Proposed Changes Specific to the “Export of CRTs for Reuse” 2. 3 .1 Proposed Changes to Notification Requirements 3.0 METHODOLOGY AND ASSUMPTI ONS 3 .1 Estimate d Number of Potentially Impacted CRT Exporters 3 .2 Lab or Rate Estimates and Assumptions 3.3 Burden Hour Estimates and Assumptions 3.4 Material Cost Estimates and Assumptions 4.0 ASSESSMENT OF POTENTIAL COSTS 4 .1 Estimated Costs for R eading the Rule 4 .2 Estimated Costs for New Annual Reporting by CRT Export Recyclers 4.3 Estimated Costs for Additional Reuse and Recycling Notification Requirements 4.4 Total Cost Impact of the Proposed CRT Rule Revisions 5.0 QUALITAT IVE D IS CUSSI ON OF BENEFITS
A. ATTACHMENTS Supporting Documentation For Assessment of Costs4

**1.0 INTRODUCTION**  1.1 Background on Existing Cathode Ray Tube (CRT) Rule The Agency

promulgated the CRT rule on July 28, 2006 (71 FR 42928). Inthat rule, EPA amended its regulations under the Resource Conservation and Recovery Act (RCRA) to streamline management requirements for used CRTs and glass removed from CRTs , with the intent of encourag ing their recycling and reuse

. Under 40 CFR 261.39, these mate rials are excluded from the definition of solid waste if certain conditions are met. Used CRTs (intact or broken) sent for reuse and recycling are subject to the speculative accumulation requirements of 261.1(c)(8). Used, broken CRTs sent for recycling are subject to packaging and labeling requirements, as are CRT glass processors. CRT glass processors are also subject to speculative accumulation requirements and may not use temperatures high enough to volatilize lead. In addition to these domestic requi rements, the CRT rule also contains requirements at 40 CFR 261.39(a)(5) for used CRTs exported for recycling. Exporters of used CRTs for recycling must notify

EPA of an intended shipment 60 day s before the shipment. Notifications may cover exports extend ing over a 12

- month or shorter period. The notification must include contact information about the exporter and recycler, and an alternate recycler. It must also include a description of the recycling, frequency and rate of export, means of transport, tota l quantity of CRTs, and information about transit countries. With respect to used intact CRTs that are exported for reuse, 40 CFR 261.41 requires exporters to submit a one

- time notification to EPA with contact information and a statement that they are exporting the CRTs for reuse. They must keep copies of normal bus iness records demonstrating that each shipment will be reused. Records must be retained for three ye ars from the date of export. 1.2 Need for Proposed Regulatory Action Since promulgation of the CRT rule in 2006, exports of CRTs and CRT glass have continu ed , whether for reuse or recycling. As EPA implemented the rule, two principal concerns became apparent. The first was that when CRTs and CRT glass are exported for recycling or reuse, several parties may be involved in the transaction. This multi

- party i nvolvement has sometimes led to confusion about which party is responsible for fulfilling the export notice requirements. The second concern involves CRTs that are ostensibl y exported for reuse but that are actuall y disassembled and recycled when they rea ch the receiving country , sometimes under unsafe conditions. To address these concerns, EPA is proposing minor changes to the current CRT Rule as described in Section 2.0 below.5

**2.0 OVERVIEW OF PROPOSED REGULATORY REQUIREMENTS**  2.1 Definition of “CRT Exporter” (applicable to both CRTs for Reuse or Recycling) When CRTs are exported for recycling or reuse, there are often several parties involved and this can cause considerable confusion over exactly who must file the export notices required under 40 C FR 261.39(a)(5)(for CRTs exported for recycling) and 40 CFR 261.41(for CRTs exported for reuse). To reduce this confusion, th e Agency is proposing to add a definition of “CRT exporter” to 40 CFR 260.10 , which st ates that a CRT exporter is “any person who d ecides that CRTs will be sent outside the United States or its territories for recycling or reuse (including reuse after refurbishment in the receiving country) , and an y intermediary arranging for the export”. The reference to “an y intermediary arranging for the export” is modeled on the definition of “primary

exporter” of hazardous waste in 40 CFR 260.10. As described above, there may be multiple parties who participate in the export ing of CRTs

. To avoid duplicative submissions, the Agency

expects only

one part y to perform the exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41 Lastly , EPA emphasizes that this proposed definition would clarify rather than change current liability for vio lations of the CRT export requirements. [Note: EPA considers there to be no economic costs associated with this definitional change.] 2.2 Proposed Rule Changes Specific to the “Export of CRTs for Recycling” Under the provisions of this proposed rule, parties that “E xport CRTs for purposes of R ecycling ” shall face the following additional requirements

.

2. 2 .1 New Annual Report Required from Exporters of CRTs Sent for Recycling Per the existing CRT Rule, parties that export CRTs for recycling currently have notification requirements regarding the ir projected exports, but are not required to submit any retrospective documentation regarding the amount of the ir actual exports in a given year. To help ensure that CRTs exported for recycling are handled as commodities and not otherwise discarded, EPA is proposing that such parties submit Annual Reports of the ir exports. [Note: This annual r eport requirement has been modeled after th e annual r eporting require ment for exporters of spent lead

- acid batteries under 40 CFR 262 Subpart E (See cited reference in Footnote 1 on page 7 )

. ]

2.2.2 Additional Destination Data Requested as Part of the Recycling Notice Per the current CRT Rule (40 CFR 261.39(a)(5)(F), exporters of CRTs sent for recy cling are required to state the name and address of the recycler and any alternate recycler. Because CRTs are sometimes exported to more than one recycler in the receiving country , EPA is proposing to require that the exporter state the name and address of the recycler or recyclers and the estimated quantity

of CRTs to be sent to each facility , as well as the names of an y alternate recyclers. In this way

EPA will be able to provide the receiving country with the most accurate information available about the ultimate fate of the CRTs when they reach that country

.6

2. 3 Proposed Changes Specific to the “Export of CRTs for Re use ” Under the provisions of this proposed rule, parties that “E xport CRTs for Reuse ” shall face the following additional requirements.

2.3.1 Proposed Changes to Notification Requirements Per the current CRT Rule, exporters of CRTs sent for reuse are alread y required to submit a one - time notice to EPA with minimal information under 40 CFR 261.41. Since original promulgation of this requirement, the Agency has become aware that some CRTs , ostensibly exported for reuse , are actually recycled in the receiving country , sometimes under unsafe conditions. EPA is proposing to expand the current reuse notice to provide more complete information about the potential reuse of the exported CRTs. The added items to the reuse noti ce are modeled on those required in the notice for CRTs exported for recycling, and will help the Agency determine whether exported CRTs are actually products which are ultimately sent for reuse. [Note: For more detail on the additional data elements that are being proposed for the CRT Reuse Notice, please see the appropriate section of the preamble for the Proposed Rule.] [Note: The Agency

expects only

one part y to perform the exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41 (notifications to EPA, and the annual reports as proposed and described above).]

**3.0 METHODOLOGY AND ASSUMPTIONS**  Described below are the key data and assumptions underlying the cost analy ses conducted for this rule. In assessing the cost impacts, we estimated the incr emental annual costs of this proposed rule to U.S. exporters and to EPA. In estimating these costs, EPA first reviewed the provisions under the existing regulations and under the proposed rule to determine what new requirements were being proposed in this rule

. We estimated the costs of these new requirements using the following inputs:

 Number of affected entities  Hourly

labor rates  B urden hours  Materials costs  Number of Annual Reuse/Recyclin g Notifications Section 3.1 describes the sources used in identifying the “ number of entities ” involved in the exporting of CRTs who will be directly a ffected by

the proposed rule changes. Section 3.2 describes the “ hourl y labor rates ” that are used in our calculations. Section 3.3 describes the “burden hour s” (e.g. staff hours) assumptions that EPA utilized in its analy sis. Section 3.4 outlines the “ material ” costs that EPA envision s may be incurred in association with the7

proposed C RT Rule revisions. Lastl y, Section 3.5 details the total “number of reuse and recycling notices” the EPA projects will be submitted per y ear.
3.1 Estimated Number of Potentially Impacted CRT Exporters The Agency

estimates that a total of approximately 12 entities exported CRTs for r ecycling during 2011 (i.e., per EPA data on the number of approved exporters and the number of export notices that were submitted during 2011). However, far more entities are on record as being exporters of CRTs for purposes of r euse. Based on the number of CRT Reuse Notifications submitted during 2011, there exists approximately 126 such entities in the U.S. (i.e., according to data from Sept. 14 th , 2011 published on EPA’s CRT informational website at [ http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm ]).

3.2 Labor Rate Estimates and Assumptions Exhibit 3

- 1 presents the hourly labor rates used in this analy sis. As shown in the exhibit, for U.S. exporters, EPA estimated an average hourly labor rate (including fringe and overhead) of $ 103.84 for managerial staff, $64.71 for technical staff, and $33.85 for cle rical staff. These labor rates were originally obtained by

rel yi ng on prior EPA Cost Assessments and then updated to 2011 using Employ

ment Cost Indices developed by the U.S. Bureau of Labor Statistics. 1 For EPA ’s involvement and review/approval responsib ilities , we estimated an average hourly labor rate of $ 74 .6 7 for manageri al staff (GS

- 14, Step 1), $63.20 for technical s taff (GS

13, Step 1), and $36.64 for clerical staff (GS

- 9, Step 1). To derive these hourly estimates, we referred to the General Sched ule (GS) Salary Table 2011 . This publication summarizes the unloaded (base) hourl y rate for various labor categories in the Federal Government. We then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly la bor rates.

1 To obtain hourly labor rates for this proposal, we relied on readily available cost analyses conducted for the SLAB Rule (which in turn also relied on labor rates from an earlier relevant EPA Cost Assessment from September 27, 2004 (re vised February 24, 2005) titled, “ Cost Assessment in Support of the Proposed Rule on exports and Imports of Hazardous Waste Destined for Recovery among OECD Countries”). To update the 2007 hourly rates (used in the SLAB Rule Cost Assessment) to 2011 levels, EPA referred to Table 9. Employment Cost Index for Wages and Salaries, for Private Industry Workers by Occupation Group and Industry (Not seasonally adjusted) of Employment Cost Index: Historical Listing (December 2005 = 100) , U.S. Bureau of Labor Statistics (Oct. 28, 2011). This table presents employment cost indices for private industry workers, by annual quarter (i.e., for March, June, and September). EPA used the June 2007 Index (105.1) from the SLAB Rule Cost Analyses, in combination with the June 2011 Index (113.8) to develop an adjustment factor of 1.083 (i.e., 113.8 / 105.1 = 1.083 ). Available at: http://www.bls.gov/ncs/ect/home.htm

.8 **Exhibit 3 -**  **1 Average Hourly Labor Rates Used to Assess the Cost Impacts of the Rule** 

**Labor Category Exporters**  **(2011 dollars)**  **EPA (2011**  **dollars)** Managerial $ 107.06 $74.67 Technical $70.08 $63.20 Clerical $36.60 $36.64
3.3 Burden Hour Estimates and Assumptions As with other components of the methodology underlying our anal ys es, to estimate the total number of hours (“burden hours”) required to meet the annual notification and reporting requirements of this rule, EPA relied heavil y upon previous cost anal ys es conducted for the 2009 SLAB Rule (See Footnote 1). S ince the proposed CRT annual r eporting and n otification requirements are virtually the same as those called for in the Agency ’s 2009 SLAB r ule , we used the same burden hour es timates in our cost assumptions for this proposal. 3.4 Materials Cost Estimates and Assumptions Minimal material costs were assumed to be associated with the production and submission of new Annual Reports and Notification requirements proposed for this revision of the CRT Rule. These costs are described below:

 Mailing costs : The Agency estimate d that affected entities w ould incur a cost of approximately $ 5.20 to mail a five ounce package by certified mail ($ 2.20 for postag e, $2. 8 5 for the certified mail fee, and $0.1 5 for a 9 x 12 manila envelope). Affected entities are expected to incur a cost of $0.4 9 for each standard letter mailed ($0.4 4 for first class postage and $0.0 5 for a standard envelope).

 Copying Costs : The agency estimate d that affected entities w ould incur a cost of $0.11 per page for cop yi ng.

 Faxing costs : The Agency estimated that affected entities would incur a cost of $0.15 for each international fax they send. This cost was derived from the ave rage revenues per minute for a telephone call from the U.S. to an OECD Country (excluding Canada and Mexico). Revenue figures were obtained from the 2005 International Telecommunications Data Report issued by the Federal Communications Commission on April 24, 2007. The cost estimate assumes that the fax transmission will take one

- minute.

 Domestic telephone call costs : The Agency estimates that affected entities will incur a cost of $ 0.90 for eac h domestic telephone call they make. This cost was derived by9 averaging the advertised rates of a 15

- minute State

- to
- State telephone call from four large U.S. long distance carriers.
3.5 Notification Estimates and Assumptions The numbe r of e xport n otifications used in our cost assessment was based on EPA’s professional experience , in combination with historical records associated with the submission of r euse/r ecycling n otices by CRT e xporters
. In EPA’s experience , most CRT recyclers seldom have ca use to submit more than 1 notice per ye ar . T he number of Recycling Notices has never exceeded 60% of the number of Recycling Exporters themselves. This means that the ratio of Recycling Notices to CRT Recycling Exporters is less than 2 to 1. So , while the number of notices may increase subsequent to the proposed rule, EPA assumed for the purposes of this analy ses that each CRT recycler would submit only 1 to 2 notices annually . Accordingl y , this result s in approximately 12 to 24 Notices being sub mitted per year for this category of exporters

. E xporters that send CRTs abroad for purposes of r euse tend to have a broader list of potential destinations for their CRTs. For instance, one r euse e xporter may ship their CRT s to schools, charit able organizations, and resale facilities, or any combination thereof. Therefore, for purposes of this anal ys i s, EPA made the following assumptions:

 75% of reuse exporters (95) would submit 2

- 4 reuse notifications per ye ar ; and  25% of reuse exporters (31) wo uld submit 1 reuse notification per year . When added together with the projected r ecycling n otices, the total estimated number of notices ranges from as low as 233 to as man y as 435.

**4.0 ASSESSMENT OF POTENTIAL COSTS**  D iscussed below is the Agency ’s best projection of the costs associated with this proposed rule. Since the subject provisions currently being proposed appl y only to the export of CRTs , U.S. importer s will not experience an y costs from these revisions. 4. 1 Estimated Costs for Reading the Rule As noted above, the Agency estimates that during 2011 a total of approximately 12 entities exported CRTs for r ecycling and 126 entities exported CRTs for reuse . Therefore, we estimated that 138 U.S. exporters will need to read the rule in order to understand and comply with the new requirements. For purposes of this analy sis, we assumed that the hours required for reading/reviewing this new rule would be similar to the hours used in EPA’s assess ment of the impacts associated with reading/reviewing the 2009 SLAB rule. The one - time cost for of reading/reviewing this new rule w as then estimated to be $282.26

. ( S ee Exhibit A

- 1 in10

Attachment A ). 2 Thus, U.S. exporters may experience a one - time cost of approximately $ 3 8,952 (i.e., 1 38 entities x $2 82.26 /entity ) for this activity

. 4. 2 Estimated Costs for New Annual Reporting b y C RT Export Recyclers Under this proposed rule, U.S. entities who export CRTs for the purpose of recycling must now submit detailed annual reports on their CRT exports to EPA. This annual reporting is in addition to the current notice requirements and represents a new requirement for CRT Recycling Exporters not called for in the current CRT Rule. The following paragraphs disc uss the estimated costs associated with this newly required annual report. U.S. Exporters As noted above, EPA estimate s that approximately 12 U.S. exporters of CRTs sent for r ecycling will be required to prepare and submit an annual report in accordance with this provision of the proposed rule. Furthermore, this new annual report for CRT Export Recyclers has been fashioned after other existing annual reporting requirements recently codified in the 2009 Final Rule governing the Exporting of Spent L ead

- Ac id Batteries (SLAB) from the U.S. Therefore , EPA used the cost estimates for annual r eporting already available in the May 2009 Cost Assessment prepared for the “SLAB Rule”, as the best and most recent relevant reference (See Footnote 1)

. Based on these figures, EPA estimate s that the cost for a CRT Exporter to prepare and submit an annual report ranges from $ $156.07 to $203.36 , depend ing upon whether the size of the e xporter is l arge vs. s mall . For purposes of anal ys is, EPA assumed a 50/50 distribution of these exporters (e.g. with half considered large and half considered small). Thus, EPA estimate d that the total cost of the annual reporting requirement for export ing CRTs for recycling is $2,158.32 (i.e., $203.36/ annual report x 6 L arge Recycling Exporters , plus $156.07 / annual report x 6 Small Recycling Exporters ) (See Exhibit A

- 2 in Attachment A)

. EPA EPA estimate s that it will receive 12 annual reports per year. EPA e stimate s that it will incur $24.64 to receive and record each annual report ( S ee Exhibit A

- 2 in Attachment A ). Thus, EPA estimate s that the Agency will e xperience an annual cost of $295.68 (i.e. , 12 annual reports/y ear x $24.64 /report) to meet this requirement of the proposed rule. In total , the estimated costs to CRT Exporters and the EPA for the new annual reporting requirement for recyclers are $ 2,454 per year (See Exhibit A

- 2 in Attachment A).

2 Estimated costs for Re ading the Rule were drawn from the May 2009 Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exports of Spent Lead

Acid Batteries from the U.S., and Import Consent Documentation.11

4.3 Estimated Costs for Additional Reuse and Recycling Notification Requirements Under the current CRT R ule, exporters alread y must submit notification s to EPA indicating their intent to export CRTs

. As noted above, the proposed CRT Rule revisions call for very minor additional reporting elements to the cur rent CRT rule requirements. The following paragraphs discuss the estimated costs associated with these added notification elements. U.S. Exporters To calcu late the notification

- related cost impacts, EPA start ed by rel yi ng on the original burden hour estimates associated with the current notification requirements . EPA then adjusted these burden hour estimates to reflect our best estimate of the potential burden associated with the proposed changes in the notification requirements. Our best estimate i s that these burden estimates would not exceed 10% of the burden attributable to the current notification requirements. Then EPA utilized the adjusted burden estimates and labor rates in combination with the projected quantity of CRT Notices to derive cos ts associated with the relevant proposed changes to the CRT notification process. Based on the calculations above , EPA estimate d that CRT exporters submit between 233 and 435 notices each ye ar. We estimated that each notice will cost an additional $10.26 (See Exhibit A

- 3 in Attachment A). In total, EPA estimates that the additional costs to Exporters will be in the range of $2,386 to $4,453 (i.e., 233 to 435 notices per ye ar x $10.26 per notice) under the proposed rule. EPA We estimate that EPA will in cur an additional cost of $10.51 per notice to receive and process these notices (S ee Exhibit A

- 3 in Attachment A ). Thus, we estimate th at the Agency will experience a total incremental annual cost in the range of $2,449 to $4,572 (i.e., 233 to 435 notices per ye ar x $ 10.51 per notice) under the proposed rule. In total , the estimated costs to CRT Exporters and the EPA for meeting the proposed reuse and recycling notification changes are $ 4,835 to $9 , 025 per year (See Exhibit A

- 3 in Attachment A). 4.4 Total Cost Impact of the Proposed CRT Rule Revisions In total, EPA estimate s that the costs of the proposed CRT Rule revisions include approximate ly $39,000 in year one of the Rule, as well as annual costs in the range of $7,300 to $11,500 in year one an d beyond

. Based on the methodology and cost calculations described above in Sections 3.0 and 4.0, the results of our cost assessment reveal very modest cost impacts. Furthermore, man y of the assumptions used in the anal ys es could be characterized as “conservative” assumptions, resulting in cost estimates that may be higher than those that would actuall y be incurred.12

**5.0 QUALITATIVE DISCUSSION OF BENEFITS**  Promulgati on of this rule will engender benefits , both internal and external to the U.S., incl uding : ( 1 ) increased regulatory efficiency ; ( 2 ) reduced storage cost for hazardous wastes destined for recovery ; ( 3 ) reduction of risks associated with treatment and disposal of hazardous wastes; ( 4 ) improved ability to acquire information regarding the quantities of CRTs exported from the U.S. and the destination facilities to which the CRT s are exported; ( 5 ) better tracking of returns and compliance with excepti on reporting requirements; and ( 6 ) better tracking of compliance with the terms of CRT export notices. More specificall y, the proposed CRT Rule Revisions will help determine that CRTs exported for recycling are handled as commodities and not inappropriatel y discarded. Such annual reports and notification enhancements improve the accuracy of our records and allow for proper d ocument ation of the total amount of CRTs being exported for recycling and reuse

. The improved data that is collected wi ll also enable EPA to compare actual vs. proposed shipments to ensure that the shipments occurred under the terms approved b y the receiving country. Finall y, such data will enable EPA to provide summary information, if requested by a receiving country , wh ich would a ssist the receiving country in better management of their CRTs imports

. In conclusion , while these benefits have not been expressly quantified as part of this Economic Assessment, the resultant improvements in information provision/transparency and CRT management practices from this Rule are believed to have benefits that outweigh the costs.13 **ATTACHMENT A**  **SUPPORTING DOCUMENTATION FOR**  **ASSESSMENT OF COSTS**14 **Exhibit A**  **- 1**  **Costs for Reading the Rule** 

**Cost per Entity Cost of All Entities**  **Activity** Managerial

Staff Hours a Technical Staff

Hours a Clerical Staff

Hours a Hours Labor Cost b Materials

Cost c Total Cost

per Entity Number of

Entities d Total Cost **Reading the Regulations** U.S. Exporters 1.00 2.50 0.00 3.50 $282.26 $0.00 $2 82.26 138 $38,952
NOTES:

a Based on hourly burden estimates discussed in Section 3.3 above. b Based on hourly labor rates discussed in Section 3.2 above.

c Based on materials costs discussed in Section 3.4 above. d Based on universe assumptions discussed in Section 3.1 above.15 **Exhibit A**  **- 2**  **Costs for New**  **Annual Report ing**  **by Exporters of CRTs for Recycling**

**Cost per Entity Cost for all Entities**  **Activity** Managerial

Staff Hours a Technical Staff

Hours a Clerical Staff

Hours a Total

Hours Total Labor

Cost b Material

Cost c Total

Cost Number of

Entities d Total Cost **Annual Report Large U.S. Exporters**  Research specific export information 0.00 1.00 1.00 2.00 $106.68 $0.00 $106.68 6 $640.08 Prepare and submit report 0.10 1.00 0.30 1.40 $91.77 $5.20 $96.97 6 $581.82

**Subtotal:** $1 98
. 45 $5.20 $ 203.65 6 $1,221.90 **Small U.S. Exporters**  Research specific export information 0.00 0.50 0.50 1.00 $70.08 $0.00 $70.08 6 $ 420.48 Prepare and submit report 0.10 0.50 0.50 1.10 $80.79 $ 5.20 $85.99 6 $ 515.94

**Subtotal:** $150.87 $5.20 $156.07 6 $936.42 **Total for Exporters:**  **$ 2,158.32**  **EPA** Receive and record report 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 $ 295.68

**T otal**  **for EPA:** 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 **$ 295.68**  **TOTAL: (for both Exporters & EPA)**  **$2,454** NOTES:

a Based on hourly burden estimates discussed in Section 3.3 above. b Based on hourly labor rates discussed in Section 3.2 above.

c Based on material costs discussed in Section 3.4 above. d Based on universe assumptions discussed in Section 3.1 above, which reveal a total of approximately 12 CRT Recycling Exporter s in the U.S. And, we assume there is a 50/50 Percent Ratio regarding the total number of Large vs. Small U.S. CRT Exporters, s uch that there are 6 of each type in the above calculations.16 **Exhibit A -**  **3 Costs for Meeting Proposed Reuse & Recycling**  **Notification Changes** 

**(calling for minor additional information)**

**Cost per Notice Cost of All Notices**  **Activity** Manage r Staff Hours a Technical

Staff Hours a Clerical

Staff Hours a Total Hours b (10% of Orig
. Hours) Total

Labor Cost c Total Material Cost s d Total Cost per Notice Number

of Entities e Estimated

Number of Notices f Total Cost

**U.S. Exporters** Prepare & submit notification **Subt otal**  **for Exporters:** 0.00 1.50 0.00 0 .15 $10.51 $0.00 $10.51 138 233 to 435 **$2,449 to $4,572 EPA**  Receive and process notification 0.00 1.00 0.00 0.10 $6.32 $0.00 $6.32 138 233 to 435 $1,473 to $2,749 Prepare and transmit confirmation of receipt to U.S. 0.00 0.00 0.25 0. 0 25 $0.92 $0.00 $0.92 138 233 to 435 $213 to $398 Forward notification to the competent authorities of the countries of import and transit 0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 13 8 233 to 435 $137 to $255 Receive and process Acknowledgement of Receipt from the competent authority of the country of import 0.00 0.00 0.25 0. 0 25 $0.92 $0.00 $0.92 13 8 233 to 435 $213 to $398 Receive and process consent/objection from the competent authorities of the countries of import and 0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 13 8 233 to 435 $137 to $255 Forward written Acknowledgement of Consent or objection to U.S. exporter 0.00 0.00 0.25 0. 0 25 $0.92 $0.00 $0.92 13 8 233 to 435 $213 to $398 **Subtotal for EPA:** 0.00 1.00 1.07 0.207 $10.26 $0.00 $10.26 138 233 to 435 **$2,386 to**  **$4,453 Total**  **for both Exporters & EPA** 0.00 2.5 0 1.07 0
. 35 7 $20.77 $0. 00 $20.77 138 233 to 435 **$4,835 to $9,025** Notes: a Staff level h ourly burden estimates are discussed in Section 3.3 above. b Total final hourly burden estimates are conservatively assume d to only involve an additional burden equal to 10% of the overall burden from the notification requirements under the current CRT Rule. c Based on hourly labor rates discussed in Section 3.2 above. d Since e ntities are already required to submit Recycling and Reuse Notices, the effected entities face no additional costs associated with mailings, copies, facsimiles, etc. due to the newly proposed modifications to the existing notices. e The projections for the total number of entities potentially impacted by the rule are discussed in Section 3.1 above. f The projections for the total number of notifications that may be submitted annually is discussed in Sectio n 3.5 above
.17