Questions for PMAA

A. General Cost Estimate Questions

1) Can you please confirm that the annualized cost of $6,100 per year you state on pages 2 and 11 of your 

comments is a per-facility annual cost?

a) For this per-facility cost, can you provide a list of assumptions regarding the typical UST 

facility that you consider a “facility”, especially with regards to the standard number of 

components therein? (e.g., how many tanks per facility, length of piping associated with each 

tank or facility, number of underground dispensers per tank or facility, number of fill pipes 

per tank , number of spill prevention equipment per fill pipe, number of turbine sumps per 

tank)

b) On page 6, it appears you assume four dispenser sumps and four tank sumps at each facility. 

Can you provide a data source for this assumption?

2) Can you provide an itemized list of the costs, per proposed requirement, that you used to estimate the 

annualized cost of $6,100?

a) Can you provide all assumptions, supporting estimates, and sources used to estimate the costs 

associated with each regulatory requirement? For example:

 Who do you assume perform the activities (e.g., owner/operator, 3rd party)?

 What steps are included in the requirement?

 How long does the activity take to complete?

 What ancillary or subsequent costs are incurred (travel time, repairs)?

b) How do you factor in annualization and/or discounting factors into this cost? (e.g., what is the 

time frame for annualization and percent discount rate used)

d) How do you account for depreciation in your cost estimates?

c) Can you provide the specific input that you solicited and received from UST equipment and 

service vendors?

e) Does the $6,100 take into account the retrofits/replacements you believe the rule will impose? 

If so, can you provide separate detail regarding the costs of these retrofits and/or replacements?

4) As we understand, given your estimates of walkthrough inspection costs and annualized total 

compliance costs, walkthrough inspections ($3,600) are approximately 59% of total compliance costs

($6,100) (see page 11). Does this mean that the remaining requirements total to $2,500 per facility?

(Answers to the prior questions may answer this)

5) Does your $6,100 annualized cost estimate take into account states that already require or have 

implemented similar requirements as those being proposed by the EPA (e.g., some states already require 

walkthrough inspections in their regulations)?

B. Specific Cost Questions

1) On page 6, you estimate the cost associated with the storage, handling, and disposal of potentially 

contaminated water used to conduct integrity testing on secondary containment sumps:

a) From what source is the $2 per gallon to dispose contaminated wastewater based on?
b) It appears you assume dispenser sumps are 4 x 2 x 3 feet deep and tank sumps are 4 x 4 x 4 

feet deep. Are these your assumptions regarding the average size of sumps and if so, what 

are they based on?

2) Can you provide the costs you ascribe to interstitial integrity testing requirement when estimating 

$6,100 in compliance costs, given your statement that there is no existing standard for interstitial integrity 

testing?

a) Did you include this requirement in your cost estimate?

b) If so, can you provide the data sources and/or assumptions you used to estimate costs for this 

requirement?

3) Can you provide a list of states that mandate third-party and/or contractor walkthrough inspections, 

rather than UST system owner/operator employees? 

4) Do you use third-party and/or contractor costs for estimating the $3,600 annually for walkthrough 

inspections per facility?

a) Can you provide an itemized list of sub-requirements for walkthrough inspections, and the data 

sources and calculations used to estimate the cost associated with each of these requirements?

(e.g., two employees as one must direct traffic, etc.)

5) Do you believe facilities with UST systems that have a B-level operator on-site could perform the tasks 

required for walkthrough inspections?

6) Can you provide a data source for the claim that drop tubes are not designed to be removed for 

inspection, as well as their cost of $700 per unit?