**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, c an 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 provi de 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, 3 rd 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 requirement s 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., so me states already require walkthrough inspection s 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) Itappears 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 insp ections, 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 walkth rough inspections, and the data sources and calculations used to estimate the cost associated with each of th ese 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 o n - 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?