MEMORANDUM February 1 2 , 2014

TO: Mark Seltzer, Chemical Control Division, OPPT

FROM: Lynne Blake

- Hedges, Economics, Exposure, and Technology Division, OPPT

SUBJECT: Estimates of Burden and Costs for the Siloxanes Enforceable Consent Agreement

General
The following provides the approach, assumptions, and results for estimating the public burden and costs associated with performing the testing program outlined in the Enforceable Consent Agreement (ECA) for Testing for Octamethylcyclotetrasilox ane (D4) (CASRN 556

- 67

- 2). Detailed r esults are presented in the attached spreadsheet entitled: ECA Cost Spreadsheet 2

- 12

- 2013 final.
The cost and burden estimates are for the testing program described in the Enforceable Consent Agreement For Environmental Testing for Octamethylcyclotetrasiloxane (D4) (CASRN 556

- 67

- 2) dated Dec. 18, 2013(U.S.EPA, 2013a). E PA assumes that the signatories of the ECA, who are the parties responsible for providing the testing, will contract out certain activities t o a single contract laboratory and perform some activities themselves as a consortium. Because EPA anticipates that the signatories will attempt to minimize the cost of the testing program, it is reasonable to make this assumption as involving other labora tories will necessarily increase the costs for some of the testing.
Burden estimates represent only the hourly burden estimated for the signatories to perform activities related to the ECA and does not include time that it takes for the contract laborator y to conduct any parts of the testing program for which they have been hired. The contract laboratory is compensated for the hours spent conducting the program and this is considered a cost to the signatories.

Burden
Burden estimates for the signatories i nclude preparation of a Quality Assurance Project Plan (QAPP) site plans, recordkeeping and reporting. EPA developed an estimate of the number of hours involved in each activity that the signatories are expected to perform. The estimated number of hours to develop the QAPP, site plan, recordkeeping, and reporting are based on similar estimates from the EPA’s Supporting Statement from the Information Collection Request for the NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal) , EP A ICR Number 2096.05, OMB Control Number 2060

- 0543 (U.S. EPA, 2013b) (QAPP estimates) and the Information Collection Request for theT oxic S ubstances C ontrol A ct (TSCA) Section 4 Test Rules, Consent Orders, Enforceable Consent Agreements, Voluntary Testing Agreements, Voluntary Data Submissions, and Exemptions from Testing Requirement EPA ICR No.: 1139.09 OMB Control No.: 2070

- 0033 (U.S. EPA, 2013c) (Site plans, recordkeeping, reporting).

Costs
Costs to the signatories include hiring a contract laboratory to perform certain tasks. EPA assumes that the contract laboratory will perform acti vities includ ing sample collection, sample preparation and analysis, analytical methodology and validation, travel to and from sites (including lodging and food) to collec t samples, shipping of samples, and acquisition of field blanks. In addition, the overall cost of the testing program includes the costs to the signatories for their time to develop the QAPP, develop site plans, keep p records, and prepare and send report s to the Agency.
To estimate costs of activities performed by a contract research laboratory, EPA contacted contracted research laboratories for estimates of costs of testing and additionally used estimates from a consultant with expertise in chemical test ing programs when necessary (SciReg, 2013)

. Costs for travel were based on EPA estimates (U.S. EPA, 2012).
These costs were added to the costs for the development of the QAPP and site plans and for recordkeeping and reporting. These costs were calculated by taking the burden hours estimated for each of these activities and multiplying those by appropriate wage rates. The wage rates were calculated following methodology found in the Revised Economic Analysis for the Amended Inventory Update Rule: Final Repo rt (EPA, 2002a) and in Wage Rates for Economic Analyses of the Toxics Release Inventory Program (2002b)

. Wage rates were inflated to $2012 using the Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Statistics, March 18, 2013 (BLS, 2013)

.
Results
The estimated burden hours for the signatories of the ECA are estimated to be 1,000 hours 1 . The estimated costs of the testing program are $1 million (low) and $1.2 million (high) 2 . Low cost estimates

as sume that no “retained” samples will be analyzed and high cost estimates assume that all “retained” samples will be analyzed.

1 Burden	hours	rounded	to	the	nearest	1,000. 2 Costs	are	rounded	to	the	nearest	hundred	thousand.References

BLS, 2013. Employer Costs for Employee Compensation Supplementary Tables December 2012, U.S. Bureau of Labor Stati stics, March 18, 2013

. SciReg, 2013 . Analytic Method Validation Costs and Testing Costs.
US EPA, 2013 a

. Enforceable Consent Agreement For Environmental Testing for Octamethylcyclotetrasiloxane (D4) (CASRN 556

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- 2) Dec. 18 , 2013

. U.S. EPA, 2013 b

. Supporting Statement from the Information Collection Request for the NESHAP for Iron and Steel Fo undries (40 CFR Part 63, Subpart EEEEE) (Renewal) , EPA ICR Number 2096.05, OMB Control Number 2060

- 0543

. August, 2013.
U.S. EPA, 2013 c

. Information Coll ection Request for the T oxic S ubstances C ontrol A ct (TSCA) Section 4 Test Rules, Consent Orders, Enforceable Consent Agreements, Voluntary Testing Agreements, Voluntary Data Submissions, and Exemptions from Testing Requirement EPA ICR No.: 1139.09 OMB Control No.: 2070

- 0033 . August, 2013

. U.S. EPA, 2012. Cost Estimates for Siloxane Monitoring. Slides by David Tobias. December 6 , 2012.
U.S. EPA, 2002a. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report

. U.S. EPA, 2002b. Wage Rates for Economic Analyses of the Toxics Release Inventory Program

.Tab Description
Total	Costs	-	Low Provides	a	summary	of	all	costs	associated	with	the	ECA	(low	cost estimate,	where	no	retained	samples	are	tested) Total	Costs	-	High Provides	a	summary	of	all	costs	associated	with	the	ECA	(high	cost estimate,	where	all	retained	samples	are	tested) Derivation	of	2012	Wage	Rates	and	CPI	Inflation	Factor

Deliverables A	table	with	all	the	physical	deliverables	required	by	the	ECA	and	a tally	of	the	number	of	days	the	member	companies	have	to complete	each	deliverable Number	of	Sites	&	Study	Samples Calculates	the	number	of	study	samples	gathered	for	each	test media Num	of	Tests	per	Study	Sample Calculates	the	number	of	analysis	tests	completed	for	each	test media Number	QA	Samples	and	Tests Calculates	the	number	of	samples	and	tests	conducted	for	QA testing	for	each	test	media Total	num	of	Tests	(study+QA) Calculates	the	total	number	of	tests	for	each	test	media	(QA	testing +	analysis	testing) Sampling	Travel	and	Labor	Costs Cost	estimates	of	the	travel	and	labor	costs	associated	with sampling Sampling	Shipment	Costs Cost	estimates	of	shipping	the	samples	from	the	sample	sites	to	a lab Testing	Costs Cost	of	analytic	method	validation	and	analytic	testing
Reporting	Costs Costs	of	completing	study	plans,	interim	reports,	and	final	reports

QAPP	Costs Cost	of	completing	the	QAPP

Section	4	ICR	Costs Costs	from	the	TSCA	Section	4	ICR	which	are	used	to	derive	the reporting	costs