### SUPPORTING STATEMENT FOR

**EPA INFORMATION COLLECTION REQUEST NUMBER 2455**  **. 01**  **“ REVISION TO THE EXPORT PROVISIONS OF THE**  **CATHODE**

**RAY TUBE (CRT) RULE**  **- PROPOSED RULE**  **”**

**FEBRU ARY**  **20 12** **TABLE OF CONTENTS**

1. ID ENTIFICATION OF THE INFORMATION COLLECTION

................................ ........ 4 1(a) Title and Number of the Information Collection

................................ ..................... 4 1(b) Short Characterization

................................ ................................ ............................. 4 2. NEED FOR AND USE OF THE COLLECTION

................................ ............................... 5 2(a) Need and Authority for the Collection

................................ ................................ ..... 5 2(b) Practical Utility

and Users of the Data

................................ ................................ .... 5 3. NONDUPLICATION, CONSUL TATIONS, AND OTHER COLLECTION CRI TERIA

................................ ................................ ................................ ........................... 6 3(a) Nonduplication

................................ ................................ ................................ ......... 6 3(b) Public Notice

................................ ................................ ................................ ............ 6 3(c) Consultations

................................ ................................ ................................ ............ 6 3(d) Effects of Less Frequent Collection

................................ ................................ ......... 6 3(e) General Guidelines

................................ ................................ ................................ ... 7 3(f) Confidentiality

................................ ................................ ................................ ......... 7 3(g) Sensitive Questions

................................ ................................ ................................ .. 7 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

................................ . 7 4(a) Respondents and SI C/NAI CS Codes

................................ ................................ ....... 7 4(b) In formation Requested

................................ ................................ ........................... 10 5. THE INFORMATION COLLECTED

— AGENCY ACTIVITIES, COLLECTI ON METHODOLOGY, AND INFORMATION M ANAGEMENT

................................ ....... 12 5(a) Agency

Activities

................................ ................................ ................................ ... 12 5(b) Collection Methodology and Management

................................ ............................ 13 5(c) Small Entity

Flexibility

................................ ................................ .......................... 13 5(d) Collection Schedule

................................ ................................ ............................... 13 6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

............... 14 6(a) Estimating Respondent Burden Hours

................................ ................................ ... 14 6(b) E stimating Respondent Costs

................................ ................................ ................ 14 6(c) Estimating Agency Burden and Cost s ................................ ................................ ... 15 6(d) Estimating the Respondent Universe and Total Burden and Cost s ....................... 16 6(e) Bottom Line Burden Hour s and Cost s ................................ ................................ ... 18 6(f) Reasons for Change In Burden

................................ ................................ .............. 18 6(g) Burden Statement

................................ ................................ ................................ ... 183 **EXHIBITS** Estimated Respondent Burden and Cost for Reading the Rule .........................................20 Costs for New Annual Reporting by Exporters of CRTs for Recycling ...............................21 Costs for Meeting Proposed Reuse & Recycling Notification Changes ..............................22 (Asking for minor additional information)4

**1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title and Number of the Information Collection**  This Information Collection Request (ICR) is entitled “ Revision to the Export Provisions of the Cathode Ray

Tube (CRT) Rule

– Proposed Rule ,” EPA I CR Number 2455

. 01

. **1(b) Short Characterization**  The U.S. Environmental Protection Agency (EPA) promulgated the CRT rule on July 28, 2006 (71 FR 42928). In that rule, EPA amended its regulations under the Resource Conservation and Recovery

A ct ( RCRA ) to streamline the management requirements for used CRTs in an effort to encourage recycling and reuse of these materials rather than landfilling or possible incineration. The CRT rule also contained requirements for used CRTs exported for reuse or recycling. Exporters of used CRTs for recycling must notify EPA of an intended shipment before the shipment occurs. Notifications may cover exports extending over a 12

- month or shorter period. The notification must include several items of information. When EPA receives this information, it notifies the receiving country

. When the receiving country consents in writing to receive the CRTs, EPA forwards an Acknowledgement of Consent (AOC) to the exporter. The exporter may not ship the CRTs until he receives the AOC. W ith respect to CRTs that are exported for reuse, the CRT rule requires exporters to submit a one

- time notification to EPA with contact information and a statement that they

are exporting the C RTs for reuse. They must keep copies of normal business records demonstrating that each shipment will be reused. (See 40 CFR 261.39 and 261.41 for existing notification and recordkeeping requirements about used CRTs exported for reuse or recycling. The burden associated with these requirements is approved under EPA ICR Number 1189.24, and the OMB control number for this I CR is 2050

- 0053. ) EPA is proposing to revise the expo rt provisions of the CRT rule. The purpose of these proposed revisions is to address certain implementation concerns with the current export provisions of the CRT rule. EPA is proposing a definition of “CRT exporter” that includes any intermediaries arranging for the export. Because CRTs are sometimes exported to more than one recyc ler in the receiving country, EPA is also 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 any alternate recyclers. In ad dition, EPA is proposing to expand the current reuse notice and model the notice on that required for CRTs exported for recycling. Instead of a one

- time notice, EPA is proposing to require that reuse notices be submitted to cover a twelve month or shorter period. EPA is also proposing to add additional items of information to the notice, including contact information about the exporter and the destination facility , the frequency or rate at which the CRTs would be exported, the quantity

of CRTs, transport information, and a description of the manner in which the CRTs will be reused in the receiving country

. Furthermore , EPA is proposing to require that the exporter sign a certification that the CRTs are fully functioning or capable of being functional after refurbishment. EPA believes that the proposed expanded notice will help the Agency5

determine whether the exported CRTs have been handled as products that are actuall y reused in the receiving country

. Finally , EPA is proposing to add a requirement that exporters of CRTs for recycling submit an annual report documenting the actual numbers of CRTs exported during the previous calendar year. This number may differ from the estimate submitted in the original notice. This information will help ensure that the shipments occurred under the terms approved by the receiving country , and would enable EPA to provide receiving countries with information that may help them to determine the quantity of CRTs that were received in a particular country for recycling. InSections 1 through 5 of this I CR, EPA presents a comprehensive description of the new information collection requirements in the proposed rule to revise the export provisions of the CRT rule

. In Section 6, EPA estimates the total annual hour and cost burden to respondents and the Agency associated with these new information collection requirements. In the following paragraphs, EPA briefly describes the new information collection requirements covered in this I CR

. **2. NEED FOR AND USE OF THE COLLECTI**  **ON 2(a)**  **Need and Authority for the Collection** EPA is proposing the information collection under the authority o f Sections 2002(a), 3001, 3002, 3004, and 30 06 of RCRA, as amended. The proposed rule revises the notification that must be submitted to EPA when CRTs are exported for reuse or recycling and adds a requirement that exporters of CRT s for recycling submit an annual report documenting the actual numbers of CRTs exported during the previous calendar year. EPA believes the information collection requirements covered in this I CR are needed to ensure that CRTs exported for reuse or recycling are managed in compliance with the regulations. **2(b) Practical Utility and Users of the Data**  Since promulgation of the CRT rule in 2006, it has become apparent that some CRTs ostensibly

e xported for reuse are actually disassembled and recycled when they reach the receiving country , sometimes under unsafe conditions. EPA will use the collected information to ensure exported CRTs have been handled as prod ucts that are actually

reused in the receiving country

. In addition, the collected information would enable EPA to provide receiving countries with information that may

help them to determine the quantity of CRTs that were received in a particular country for recycling

.6

**3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Nonduplication** None of the information requi red b y the proposed rule would duplicate information required b y existing RCRA regulations

. **3(b) Public Notice**  In compliance with the Paperwork Reduction Act of 1995, EPA has issued a public notice in the Federal Register

. The public comment period for this I CR is combined with the proposed rule, and it will run for 60 day s . To assist the public in commenting on the proposal, EPA raised a few issues in the preamble to the proposed rule and asked for the public to comment on them. At the end of the comment period, EPA will review public comments received in response to the notice and will address comments received, as appropriate. **3(c) Consultations**  The proposed revisions to the export provisions of the CRT rule were recommended by the Interagency

Task Force on Electronics Stewardship (the “Task Force”) in its report titled National Strategy for Electronics Stewardship (July 20, 2011). Several federal agencies participated in drafting the recommendations of the National Strategy for Electronics Stewardship , including the General Services Administration, Office of the US Trade Representative, and the Departments of Commerce, Defense, and Energy

. O n behalf of the Task Force, EPA solicited public comment from stakeholders through a Federal Register notice. A lso on behalf of the Task Force, the Council on Environmental Quality held three stakeholder listening sessions in March 2011 with state and local government agencies, non

- governmental organizations, and industry , respectivel y. Comments provided through both of these methods were evaluated b y the Task Force and considered in developing the National Strategy on Electronics Stewardship. **3(d) Effects of Less Frequent Collection**  EPA has carefull y considered the information collection burden imposed upon the regulated community b y the proposed rule. E PA is confident that those act ivities required of respondents are necessary , and to the extent possible, the Agency has attempted to minimize the burden imposed. E PA believes strongly that, if the minimum information collection requirements of the proposed rule are not met, neither th e respondents (e.g., exporters) nor EPA can ensure that CRTs exported for reuse or recycling are managed in compliance with the regulations. In addition, EPA would be unable to provide receiving countries the information that they would need to help ensure that CRTs are properly managed.7

**3(e) General Guidelines**  This IC R adheres to the guidelines stated in the Paperwork Reduction Act of 1995, OMB’s implementing regulations, EPA’s I CR Handbook, and other applicable OMB guid ance. **3(f) Confidentiality**  Section 3007(b) of RCRA; 40 CFR part 2, subpart B; and 40 CFR 260.2 contain provisions for confidentiality

. I f a business asserts a claim of confidentiality c overing any o f the information collection requirements covered in this I CR, EPA must and will treat the information in accordance with the regulations cited above. E PA also will assure that this information collection complies with the Privacy Act of 1974 and OMB Circular 108. **3(g) Sensitive**  **Questions** No questions of a sensitive nature are included in any of the information collection requirements. **4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents and SIC/NAICS Codes**  The following is a list of Standard Industrial Classification (SI C) codes and corresponding North American Industry Classif ication System (NAI CS) codes associated with industries most likely a ffected by

the information collection requirements included in the existing CRT rule

. The respondents for the proposed information collection requirements covered in this I CR are exporters of CRTs from these industries. The Agency estimates that a total of approximately 12 entities exported CRTs for recycling during 2011 (i.e., per EPA data on the number of approved exporters and the number of export notices that were submitted during 20 11). H owever, far more entities are on record as being exporters of CRTs for purposes of reuse. B ased 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 ])

.

**Industry SIC Code**  **NAICS Co de**  **AGRICULTURE** Agricultural crop production 01 111 Agricultural livestock production 02 112 Agricultural services 07 115, 311, 541, 561, 812 Forestry 08 111, 113, 115 Fishing, hunting, trapping 09 111, 112, 1148
**Industry SIC Code**  **NAICS Co de**  **MINING** Metal mining 10 212, 213 Coal mining 12 212, 213 Oil & gas extraction 13 211, 213 Non

- metallic minerals, except fuels 14 212, 213 **CONSTRUCTION** General contractors 15 233

- 235 Heavy construction 16 233

- 235 Special trade contractors 17 233

- 235 **MANUFACTURING** Food & kindred products 20 111, 311, 312 Tobacco products 21 312 Textile mill products 22 313

- 315 Apparel & other textile products 23 313

- 315, 336, 339 Lumber & wood products 24 113, 321, 333 Furniture & fixtures 25 336, 337, 339 Paper & allied products 26 322, 326 Printing & publishing 27 323, 511, 512 Chemicals & allied products 28 211, 311, 325, 331 Petroleum and coal products 29 324 Rubber & miscellaneous plastics products 30 316, 325, 326, 337, 339 Leather & leather products 31 315, 316, 321 Stone, clay, and glass products 32 212, 327 Primary metal industries 33 331 Fabricated metal products 34 332, 337, 339 Industrial machinery & equipment 35 331

- 335, 339 Electronic & other electronic equipment 36 332

- 336, 512 Transportation equipment 37 332, 333, 336, 488, 541, 811 Instrument & related products 38 322, 325, 333, 334, 339 Miscellaneous manufacturing 39 325, 336, 339, 488 **TRANSPORTATION** Local & inter

- urban passenger transit 41 485, 487 Trucking & warehousing 42 493, 484, 488, 492, 531 U.S. postal service 43 491 Water transportation 44 483, 487, 488, 5329
**Industry SIC Code**  **NAICS Co de**  Transportation by air 45 481, 488, 492, 561, 621 Pipelines, except natural gases 46 486 Transportation services 47 488, 532, 561, 722 Communication 48 513 Electronic, gas, & sanitary services 49 221, 4 88, 562 **WHOLESALE TRADE** Wholesale trade

- durable goods 50 421, 441

- 444, 446, 453 Wholesale trade

- nondurable goods 51 312, 313, 422, 444, 451, 454 Bldg. materials & garden supplies 52 444, 453 **RETAIL TRADE** General merchandise store 53 452 Food stores 54 311, 445, 447, 722 Auto dealers & service station 55 441, 447, 452 Apparel & accessory stores 56 315, 448 Furniture & home furnishing stores 57 337, 442, 451 Eating & drinking places 58 722 Miscellaneous retail 59 339, 443, 445, 446, 448, 451, 453, 454, 522, 722 **FINANCE, INSURANCE, AND REAL ESTATE** Depository institution 60 521, 522 Nondepository institution 61 522, 523 Security & commodity brokers 62 523, 525, 533, 551, 813 Insurance carriers 63 523

- 525 Insurance agents, brokers, & services 64 523

- 525 Real estate 65 233, 531, 711, 812 Holding & other investment offices 67 523, 525, 533, 551, 813 **SERVICES** Hotels & other lodging places 70 721 Personal services 72 512, 532, 561, 611, 811, 812 Business services 73 234, 313, 314, 323, 325, 334, 421, 443, 491, 511, 512, 514, 522, 532, 541, 561, 562, 711, 811, 812 Auto repair, services, & parking 75 326, 488, 532, 811, 812 Misc. repair services 76 115, 235, 335, 442, 443, 451, 488, 561, 562, 711, 811 Motion picture 78 334, 421, 512, 514, 532, 541, 561, 711 Amusement & recreation services 79 487, 532, 561, 611, 711, 712, 713 Health services 80 339, 541, 621 Legal services 81 54110
**Industry SIC Code**  **NAICS Co de**  Educational services 82 514, 611 Social services 83 623, 624, 813, 922 Museums, botanical, zoological gardens 84 712 Mem bership organization 86 561, 813, 912 Engineering & management service 87 233, 234, 541, 561, 611 Private household services 88 81 Services 89 512, 541, 711 **4(b) Information Requested**  **( 1**  **) Revised**  **Export Notification for Used CRTs Destined for Recycling** Under existing 40 CFR 261.39(a)(5), exporters of used, broken CRTs must provide written notification to EPA of an intended export before the CRTs are scheduled to leave the U.S. The existing notice (40 CFR 261.39(a)(5)(F) ) requires the exporter 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 replace this language with a requirement 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 any alternate recyclers. **(2) Annual**  **Report for CRTs Exported for Recycling** Under new 40 CFR 261.39 (a)(5) (x) , e xporters must file with EPA no later than March 1 of each year, a report summarizing the quantities (in kilograms), frequency of shipment, and ultimate destination(s) of all CRTs exported during the previous calendar ye ar. Such report s must also include the following:

 The name, EPA ID number (if applicable), and mailing and site address of the exporter;

 The calendar ye ar covered by the report;

 A certification signed b y the exporter which states:

“ I certify under penalty of law that I have personally examined and am familiar with the information submitted in this and all attached documents, and that based on my inquiry of those individuals immediately

responsible for obtaining the i nformation, I believe that the submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment. ”11

**(3) Revised**  **Export Notification fo r Used CRTs Destined for Reuse**  Under existing 40 CFR 261.41, exporters of used, intact CRTs for reuse must submit a one - time notification with minimal information to EPA. To require exporters to submit more complete information about the p urported reuse of the exported CRTs over a specific period of time, EPA is proposing to add items to the reuse noti fication that are modeled on those required in the noti fication for CRTs exported for recycling. This notification may cover export activities extending over a twelve (12) month or lesser period. The notification must be in writing, signed by the exporter, and include the following information:

 Name, mailing address, telephone number and EPA ID numb er (if applicable) of the exporter of the CRTs.
 The estimated frequency or rate at which the CRTs are to be exported and the period of time over which they

are to be exported.

 The estimated total quantity of CRTs specified in kilograms.

 All points of entry

t o and departure from each transit country through which the CRTs will pass, a description of the approximate length of time the CRTs will remain in such country and the nature of their handling while there.

 A description of the means by which each s hipment of the CRTs will be transported (e.g., mode of transportation vehicle (air, highway , rail, water, etc.), type(s) of container (drums, boxes, tanks, etc.)).

 The name and address of the ultimate destination facility or facilities and the estimated quantity of CRTs to be sent to each facility , as well as the name of any alternate destination facility

or facilities.

 A description of the manner in which the CRTs will be reused (including reuse after refurbishment) in the foreign country that will be receiving the CRTs.

 A certification signed b y the exporter which states:

“ I certify under penalty of law that the CRTs described in this notice are fully functioning or capable of being functional after refurbishment. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment. I certify under penalty

of law that I have personally examined and am familiar with the information submitted in this and all attached documents, and that base d on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment. ”12

**5. THE INFORMATION COLLECTED** 

**— AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT** The following section discusses how EPA or the implementing agency will collect and manage the information received from respondents. This section also includes a discussion of how EPA has taken steps to ensure that the information collections are not overly burdensome on small entities. **5(a) Agency Activities**  **( 1**  **) Export Notification for Used CRTs Destined for Recycling**  Per the existing CRT rule, Agency activities associated with the conditional exclusion for used CRTs exported for recycling will continue as described below. There will be only minor additional information received under the proposed revised export notification for the Agency to review and process.

· Receive and review notification submitted by an exporte r of used CRTs to determine whether or not the notification is complete. Anotification is complete when EPA determines that it satisfies the requirements of 40 CFR 261.39(a)(5)(i).

· Solicit, from exporter, additional information requested by the receivin g country
.

· Provide, in conjunction with the Department of State, the complete notification to the receiving country

.

· Forward the receiving/transit country ’s written consent to the receipt of the used CRTs to the exporter.

· Prepare and send written notification to the exporter if the receiving/transit country objects to the receipt of the used CRTs or withdraws a prior consent.

· Keep copies of notifications, consents, and other related documents. **(2) Annual Report for CRTs**  **Exported for Recycling** Agency activities associated with the new requirement for submission of an annual report for exporters of CRTs sent for recycling include the following:

· Receive and record the report

.13

**(3) Export Notification for Used CRTs**  **Destined for Reuse** Per the existin g CRT rule, Agency a ctivities associated with the conditional exclusion for used CRTs exported for reuse will continue as described below. There will be a dditional information received under the proposed revised export notification, similar to the information contained in the notice for CRTs exported for recycling, for the Agency t o review and process (see Exhibit 3)

.

· Receive and process notification submitted by exporter of used CRTs.

· Keep cop y of notification. **5(b) Collection Methodology and Management**  In collecting and anal yz ing the information submitted under 40 CFR 261.39(a)(5) and 261.41, EPA will use equipment such as personal computers and app licable database software, where appropriate. E PA will ensure the accuracy and completeness of the collected information by reviewing each submittal. **5(c) Small Entity**  **Flexibility** In establishing the existing condi tional exclusion for used CRTs, EPA considered the reporting and recordkeeping burden for small businesses. The conditional exclusion was a regulatory

relief initiative that reduce d hour and cost burden for generators and subsequent handlers of excluded C RTs, particularl y small entities. These reductions in hour and cost burden under the existing exclusion will not be significantly impacted as result of the newl y proposed information requirements. **5(d) Collection Schedule**  **( 1**  **) Export Notification for Used CRTs Destined for Recycling**  Exporters of used CRTs destined for recycling must provide written notification to EPA of an intended export before the CRTs are scheduled to leave the U.S. Ac omplete notification must be s ubmitted 60 day s before the initial shipment is intended to be shipped off site. This notification may

cover export activities extending over a 12

- month or lesser period. In addition, upon request b y EPA, exporters must furnish to EPA any additional info rmation that a receiving country requests in order to respond to a notification. **(2) Annual Report for CRTs Exported for Recycling**  Exporters must file with EPA no later than March 1 of each year, a report summarizing the quantities (in kilograms), frequency of shipment, and ultimate destination(s) of all CRTs exported during the previous calendar year.14

**(3) Export Notification for Used CRTs Destined for Reuse**  Exporters of used CRTs destined for reuse must send a notification to EPA. This notification may

cover export activities extending over a 12

- month or lesser period. In addition, they must keep, at the facility, copies of normal business records (e.g., contracts) demonstrating that each shipment of exported CRTs will be reused. **6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION**  **6(a) Estimating Respondent Burden Hours**  In Exhibit s 1, 2 and 3, EPA esti mates the respondent burden hours associated with the new information collection requirements in the proposed rule

. E xhibit 1 includes estimates of burden hours (total and b y labor type) per entity ( exporter or respondent) for reading the rule

. EPA estim ates 3.5 hours per respondent for reading the rule and a universe of 138 respondents. This would result in a total of 483 hours for all of the respondents reading the rule. For a one

- time activity like reading the rule, EPA annualize s the burden hours ov er a three year effective life of the I CR. This is done by dividing the number of respondents by three (138/3 = 46) and then calculating the total hours (46 x 3.5 = 161 hours). Exhibit 2 includes estimates of burden hours (total and by

labor type) per re spondent for the new annual reporting by exporters of CRTs for recycling. E PA estimates 3.4 hours per large exporter and 2.1 hours per small exporter. EPA also estimates 12 exporters of CRTs for recycling, and assumes that one

- half (6) of the exporters are large exporters and one

- half (6) are small exporters. This would result in a total of 33 hours for the new annual reporting b y all 12 exporters. E xhibit 3 includes estimates of burden hours (total and by

labor type) per notice prepared and submitted b y a respondent under the modified reuse and recycling notification requirement s . E PA estimates 0.15 hour per modified notice and a total of 233 to 435 reuse and recycling notices submitted by respondents each ye ar . This would result in a total of 35 hours to 65 hours for preparation and submission of the modified reuse and recycling notices by respondents

. Therefore, based on the above burden hour calculations, EPA estimates that the total annual respondent burden for the new information collection requi rements in the proposed rule ranges from 229 to 259 hours. **6(b) Estimating Respondent Costs**  EPA estimates that the total annual respondent cost for the new information collection requirements in the proposed rule to be $17,591 to $19,714

. Th e total annual cost includes the cost for reading the rule, cost for new annual reporting by e xporters of CRTs for recycling, and the cost for preparation and submission of the revised reuse and recycling notices by respondents. EPA’s estimates for costs to be incurred b y respondents for th e new information collection requirements in the proposed rule are included in Exhibits 1, 2 and 3. **Labor Costs** For purposes of this analy sis, EPA estimates an average hourl y respondent labor cost of15

$1 07.06 for mana gerial staff, $ 70.08 for technical staff, and $3 6.60 for clerical staff. These labor rates were originall y o btained by rel yi ng on prior EPA C ost A ssessments and then updated to 2011 using Employ

ment Cost Indices developed by the U.S. Bureau of Labor Stati stics. (See “Economic Impacts Assessment for Proposed Revisions to the Export Provisions of the Cathode Ray Tube (CRT) Rule,” which is available in the public docket identified under Section 6(g)). **Annual Capital and Operation & Maintenance Costs** Capital costs usually

include any

produced ph ys ical good needed to provide the needed information, such as machinery , computers, and other equipment. E PA does not anticipate that respondents will incur capital costs in carrying out the information collection re quirements in the proposed rule. O&M costs are those costs associated with paperwork requirements incurred continually over the life of the ICR. They are defined by

the EPA as “the recurring dollar amount of costs associated with O&M or purchasing servic es.” Minimal O&M costs were assumed to be associated with the preparation and submission of new Annual Reports and Notification requirements in the proposed rule. These costs are for mailing, cop yi ng, faxing, and for making telephone call s . **6(c) Estimating Agency Burden and Costs**  In Exhibits 2 and 3, EPA provides estimates of the Agency hour and cost burden associated with the new information collection requirements covered in this I CR. E PA estimates an average hourly

labor cost of $74.67 for managerial staff (GS

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

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

- 9, Step 1). T o derive these hourl y estimates, EPA referred to the General Schedule (GS) Salary Table 2011

. This publication summarizes the unloa ded (base) hourly rate for various labor categories in the Federal Government. E PA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive these loaded hourly rates. (See “Economic Impacts Assessment for Proposed Revisi ons to the Export Provisions of the Cathode Ray Tube (CRT) Rule,” which is available in the public docket identified under Section 6(g)). **Receive and Record Annual Reports Submitted by Exporters of CRTs for Recycling**  EPA estimates that it will receive 12 annual reports per year. E PA estimates that it will incur $24.64 to receive and record each annual report ( s ee Exhibit 2). Thus, EPA estimates that the Agency will experience an annual cost of $295.68 (i.e., 12 annual reports/year x $24.64/report) to me et this requirement of the proposed rule. **Receive and Process Revised Reuse and Recycling Notifications**  EPA estimate s that it will incur an additional cost of $10.51 per notice to receive and process these notices ( s ee Exhibit 3). Thus, EPA estimate s that the Agency will experience a total incremental16

annual cost in the range of $2,449 to $4,572 (i.e., 233 to 435 notices per year x $10.51 per notice) under the proposed rule. **6(d) Estimating the Respondent Universe and Total Burden and Costs**  The A genc y estimates that a total of approximately 12 entities exported CRTs for recycling during 2011 (i.e., per EPA data on the number of approved exporters and the number of export notices that were submitted during 2011). H owever, far more entities are on record as being exporters of CRTs for purposes of reuse. B ased 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 i nformational website at [ http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm ])

. Therefore, as shown below in Table 1, EPA estimates that 138 entities will be subject to the new information collection requirements covered in this I CR. **TABLE 1**

**NUMBER OF EXPORTER**  **ENTITIES (RESPONDENTS)**  **POTENTIALLY AFFECTED BY THE PROPOSED RULE**
**Type of Entity**  **Number of Ent** **ities** Exporter of CRTs for Recycling 12 Exporter of CRTs for Reuse 126

**Total 138** 
**Respondent Burden and Cost** In the following paragraphs, EPA discusses the assumptions used in developing the respondent burden estimates associated with the new information collection requirements covered in Exhibits 1, 2, and 3 of this I CR. **Reading the Regulations** EPA estimate s that 138 U.S. exporters will need to read the rule in order to understand and comply with the new requirement s. F or purposes of this analysis, we assumed that the hours required for reading/reviewing this new rule would be similar to the hours used in EPA’s assessment of the impacts associated with reading/reviewing the 2009 Final Rule governing the Exporting of Spent Lead

- Acid Batteries (SLAB)

. In Exhibit 1 , EPA estimates 3.5 hours per respondent for reading17

the rule for the 138 respondents. This would result in a total of 483 hours for all of the respondents reading the rule. As noted in Section 6(a), f or a one - time activity

like reading the rule, EPA annualize s the burden hours over a three year effective life of the ICR. This is done b y dividing the number of respondents by three (138/3 = 46) and then calculating the total hours (46 x 3.5 = 161 hours). **Ne w Annual Reporting by Exporters of CRTs for Recycling**  As noted above in Section 6(d), EPA estimated that approximately 1 2 U.S. exporters of CRTs sent for recycling will be required to prepare and submit an annual report in accordance with this provision of the proposed rule. F urthermore, this new annual report for these exporters has been fashioned after other existing annual reporting requirements recently codified in the 2009 Final Rule governing the Exporting of Spent Lead

- Acid Batteries (SLAB) from the U.S. Therefore, EPA used the cost estimates for annual reporting already available in the May 2009 Cost Assessment prepared for the “SLAB Rule”, as the best and most recent relevant reference ( s ee Footnote 1 in “Economic Impacts Assessment for Proposed Revisions to the Export Provisions of the Cathode Ray

Tube (CRT) Rule , ” which is available in the public docket identified under Section 6(g))

. B ased on these figures, EPA estimates that the cost for a CRT e xporter to prepare and submit an annual report ranges from $156.07 to $203.36, depending upon whether the size of the exporter is large vs. small. F or purposes of analy sis, EPA assumed a 50/50 distribution of these exporters (e.g. with half considered large and half considered small). Thus, EPA estim ated that the total cost of the annual reporting requirement for exporting CRTs for recycling is $2,158.32 (i.e., $203.36/annual report x 6 Large Recycling Exporters, plus $156.07/annual report x 6 Small Recycling Exporters)

. ( S ee Exhibit 2). **Revisions to**  **Reuse and Recycling Notifications (Asking for additional Information)** Under the current CRT Rule, exporters already must submit notifications to EPA indicating their intent to export CRTs. The proposed CRT Rule revisions call for very m inor additional reporting elements to the current CRT rule requirements. T o calculate the notification

- related cost impacts, EPA started b y rel yi ng on the original burden hour estimates associated with the current notification requirements. E PA then adjusted these burd en hour estimates to reflect our best estimate of the potential burden associated with the proposed changes in the notification requirements. O ur best estimate is that these burden estimates would not exceed 10% of the burden attributable to the current n otification requirements. Then EPA utilized the adjusted burden estimates and labor rates in combination with the projected quantity of CRT Notices to derive costs associated with the relevant proposed changes to the CRT notification process. Based on th e calculations above, EPA estimated that CRT exporters will submit between 233 and 435 notices each ye ar. W e estimated that each notice will cost an additional $10.26 ( s ee Exhibit 3). In total, EPA estimates that the additional costs to e xporters 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.18

**Total Respondent Burden and Cost** In Exhibit s 1, 2, and 3, EPA presents a summary o f the total annual respondent burden and costs associated with the new information collection requirements in the proposed rule. The specific information collection activities of the new paperwork requirements are described through out this I CR. **6(e) Bottom Line Burden Hours and Costs**  **Respondent Tally** In Exhibits 1, 2 and 3, EPA presents the total annual respondent burden s and cost s associated with the new information collection requirements in the proposed rule. As desc ribed specificall y in Section 6(d) above, there are 138 respondents (12 U.S. exporters of CRTs sent for recycling and 126 U.S. exporters of CRTs sent for reuse) that will be subject to the new information collection requirements covered in this I CR

. Based on the information in Exhibit s 1, 2, and 3, the total annual respondent burden for the new paperwork requirements will range from 229 to 259 hours, and the total annual respondent cost for the new paperwork requirements will be approximately

$17,600 to $1 9,700 **6(f) Reasons for Change in Burden**  EPA is proposing to revise certain export provisions of the CRT final rule published on July 2 8, 2006 (71 FR 42928) to ensure that CRTs are managed in compliance with the regulations. These revisions will require exporters of CRTs to provide some additional information to EPA (see Section 6(d))

. **6(g) Burden Statement**  The estimated annual burden for this collection of information range s from 0.15 to 3.5 hours per response for the 138 respondents. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency

. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently v alid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket19

ID Number EPA

- HQ

- RCRA

- 2011

- 1014 , which is available for online viewing at www.regulations.gov , or in person viewing at the RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excludin g legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the RCRA Docket is (202) 566

- 0270. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submi t or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically

. When in the sy stem, select “search,” then key in the Docket ID Number identifie d above. A lso, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. P lease include the EPA Docket ID Number EPA

- HQ

- RCRA

- 2 011

- 1014 and OMB Control Number 2050

-NEW in any

correspondence.20

**Exhibit 1 Estimated Respondent**  **Burden and Cost 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 $282.26 138 $38,952 NOTES:

a Based on hourly burden estimates discussed in Section 3.3 of EIA ( * )

. b Based on hourly labor rates discussed in Section 3.2 of EIA

.
c Based on materials costs discussed in Section 3.4 of EIA

. d Based on universe assumptions discussed in Section 3.1 of EIA

. (*) “Economic Impacts Assessment for Proposed Revisions to the Export Provisions of the Cathode Ray Tube (CRT) Rule. ”21 **Exhibit 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:** $198.45 $5.20 $203.65 6 $1,221.90 **Sm all**  **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

**Total 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 of EIA (*)

. b Based on hourly labor rates discussed in Section 3.2 of EIA

. c Based on material costs discussed in Section 3.4 of EIA

. d Based on universe assumptions discussed in Section 3.1 of EIA , which reveal a total of approximately 12 CRT Recycling Exporters 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, such that there are 6 of each type in the above calculations. (*) See Exhibit 1.22 **Exhibit 3 Costs for Meeting Proposed Reuse & Recycling**  **Notification Changes**

**( Asking**  **for minor additional information)**

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

Staff Hours a Clerical

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

Labor Cost c Total Material Costs 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 t o 435 **$2,449 t**  **o $**  **4,572 EPA**  Receive and process notification 0.00 1.00 0.00 0.10 $6.32 $0.00 $6.32 138 233 t o 435 $1,473 t o $ 2,749 Prepare and transmit confirmation of receipt to U.S. exporter 0.00 0.00 0.25 0. 0 25 $0.92 $0.00 $0.92 138 233 t o 435 $213 t o $ 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 t o 435 $137 t o $ 255 Receive and process Acknowledgement of Receipt from the competent authority of the country of im port 0.00 0.00 0.25 0. 0 25 $0.92 $0.00 $0.92 13 8 233 t o 435 $213 t o $ 398 Receive and process consent/objection from 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 t o 435 $137 t o $255
Forward w

ritten 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 t o 435 $213 t o $ 398 **Subtotal for EPA:** 0.00 1.00 1.07 0.207 $10.26 $0.00 $10.26 138 233 t o 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 t o 435 **$4,835 t**  **o $**  **9,025** Notes: a Sta ff level hourly burden estimates are discussed in Section 3.3 of EIA (*). b Total final hourly burden estimates are conservatively assumed to only involve an additional burden equal to 10% of the overa ll burden from the notification requirements under the current CRT Rule. c Based on hourly labor rates discussed in Section 3.2 of EIA

. d Since entities are already required to submit Recycling and Reuse Notices, the effected entities face no additional costs ass ociated 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 of EIA

. f The projections for the total number of notifications that may be submitted annually is discussed in Section 3.5 of EIA. (*) See Exhibit 1.23