**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? Yes , this is an estimated cost per facility for the additional testing and compliance requirements that have been proposed. 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, numb er of turbine sumps per tank) The costs are based on Conventional UST Systems consisting of three USTs per system, three tank sumps and four dispenser sumps. Industry costs assume a total of 223,157 facilities. b ) On page 6 , it appears you assume four di spenser sumps and four tank sumps at each facility. Can you provide a data source for this assumption ?

– The data comes from several sources; Personal experience of the 12 member UST operators on the PMAA UST task force who represent hundreds of retail outlets from all regions of the country; a survey of the 48 state petroleum marketing association members that make up the PMAA federation
. 2) Can you provi de an itemized list of the costs , per proposed requirement, that you used to estimate the annual ized 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)? T hird Party Vendor
.  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)
. c ) How do you account for depreciation in your cost estimates?

– There is no depreciation in our assumptions. Our costs are testing and maintenance costs. Thos e costs will only rise over time.d) Can you provide the specific input that you solicited and received from UST equipment and service vendors? The three vendors have over 50 years combined experience in the installation, testing, inspection maintenance and removal of UST systems 1. D ependable Petroleum Service in Plymouth, M assachusetts
. 2. Georgia Oilmen’s Services , Lawrenceville, Georgia 3. Cochise Contractors, Inc., Phoenix Arizona. 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 ?

– No the estimate is for testing/inspection only. Any repairs needed would be an additional cost. 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) See prior answers and attached data. 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 inspections in their regulations ) ? No
. **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? T his is based on typical vacuum truck rental and disposal costs of $150 per hour, $.68 per gallon and various transportation and tax costs. A typical station will need to dispose of 1390 gallons which will take an 8 hour day to pick up and bring to a disposal facility. 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 ? Information collected by PMAA UST Task Force from equipment testers, inspectors, installers and UST operators. The size of some dispenser sumps and tank sumps may vary slightly but not enough to significantly change the costs associated with contaminated water disposal contained in PMAA comments.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? W e have assumed hydrostatic te sting. b) If so, can you provide the data sources and/or assumptions you used to estimate costs for this requirement ? W e have based our costs assuming that the interstitial UST space and the sumps for piping would require testing every three years. Th e cost for interstitial testing would total $2,500 every three years. The cost assumes $1,700 for water disposal and $800 for testing. 3) Can you provide a list of states that mandate third
-party and/or contractor walkthrough inspections, rather than UST system owner/operator employees?

– No, this is not useful data for cost assumptions because the proposed component inspection requirements drive the need to outsource the walkthrough inspections, not a state mandate. These inspections cannot be handle d in house by small petroleum marketers due to high employee turnover rates at c - store/stations. In many cases the technical requirements of the walkthrough inspections are beyond both the skill level and physical capabilities of the majority of c
- store/st ation employees even with training. Assuming that walkthrough training was effective for in
-house employees , turnover rates would require on
- going and continual training that would further increase compliance costs for small business petroleum marketers. Moreover, the cost to hire a trained in
-house employee to conduct the walk through inspections would be far greater than the cost to outsource for the service. 4) Do you use third
-party and/or contractor costs for estimating the $3,600 annually for walkthrough inspections per facility? Y es. Please see attached data for monthly walk through inspections. 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 ass ociated with each of th ese requirements? (e.g., two employees as one must direct traffic, etc.) See attached data. 5) Do you believe facilities with UST systems that have a B
- level operator on
- site could perform the tasks required for walkthrough inspections? Not in most cases. Many of the inspection requirements will require heavy manholes to be lifted and inspection of equipment in high traffic areas. T hese activities will require additional insurance for employees, because these activities are signifi cantly different than typical convenience store employee duties. The cost to outsource has been estimated at $300

- $400 per inspection. Requiring in
-house employees to conduct walkthrough inspections creates a greater risk of personal injury from traffic, and performing inspection tasks such as removing heavy sump covers which all drives the ultimate cost for insurance premiums and worker compensation payments . In addition, removing two employees from the store to conduct the walkthrough creates a greater security risk for th ose left inside, another factor that increases compliance costs. The DOL consistently lists c
- store employees at the top of the list for on thejob injury or death due to criminal activity

– i.e. armed robbery. Creating greater risk req uires higher insurance premiums which in this case would be substantial. 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
. The cost of a OPW EVR coaxial overfill drop tube is $686.25 and the labor to install would be $ 150
- $200
.