                EPA ICR No. 1139.11; OMB Control No. 2070-0033
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                 ATTACHMENT 3
                                       
                           Economic Analysis Tables

Table A: Burden and Cost, per Activity 
                              Collection Activity
                              Per Activity Labor
                  Per-Activity Supply Costs              (y)
                           Total per-Activity Costs 

                                   Type [a]
                                     Hours
                                     Rate
                                   Cost (x)

                                     (x+y)
CDX REGISTRATION
CDX Registration
                                       T
                                     0.180
                                                                        $72.22 
                                                                        $13.00 
                                                                          $0.00
                                                                        $13.00 
CDX Electronic Signature
                                       T
                                     0.350
                                                                        $72.22 
                                                                        $25.28 
                                                                          $0.00
                                                                        $25.28 
CDX Registration and e-Signature Total
 
                                     0.530
                                   $144.44 
                                    $38.28 
                                    $0.00 
                                    $38.28 
TEST RULES AND TESTING AGREEMENT:
Interim Reports
Letter of Intent with Study Plans
                                       T
                                      40
                                                                        $72.22 
                                                                     $2,888.80 
                                                                         $0.00 
                                                                     $2,888.80 
Prepare Progress Report
                                       T
                                       8
                                                                        $72.22 
                                                                       $577.76 
                                                                         $0.00 
                                                                       $577.76 
Final Reports
Short-term Studies
Record and Prepare Test for Submission
                                       T
                                      40
                                                                        $72.22 
                                                                     $2,888.80 
                                                                          $0.00
                                                                     $2,888.80 
Laboratory Review
                                       T
                                       6
                                                                        $72.22 
                                                                       $433.32 
                                                                          $0.00
                                                                       $433.32 
Corporate Review
                                       M
                                       6
                                                                        $80.22 
                                                                       $481.32 
                                                                          $0.00
                                                                       $481.32 
Recordkeeping
                                       C
                                      0.5
                                                                        $31.26 
                                                                        $15.63 
                                                                         $0.00 
                                                                        $15.63 
Short-term Studies' Final Reports Total
                                     52.5
                                                                              
                                                                     $3,819.07 
                                                                         $0.00 
                                                                     $3,819.07 
 
                                       
                                                                              
                                                                              
                                                                              
                                                                               
                                                                              
Long-term Studies
Record and Prepare Test for Submission
                                       T
                                      80
                                                                        $72.22 
                                                                     $5,777.60 
                                                                          $0.00
                                                                     $5,777.60 
Corporate Review
                                       M
                                       9
                                                                        $80.22 
                                                                       $721.98 
                                                                          $0.00
                                                                       $721.98 
Recordkeeping
                                       C
                                      0.5
                                                                        $31.26 
                                                                        $15.63 
                                                                         $0.00 
                                                                        $15.63 
Long-term Studies' Final Reports Total
                                     89.5
                                                                              
                                                                     $6,515.21 
                                                                         $0.00 
                                                                     $6,515.21 
 
                                       
                                                                              
                                                                              
                                                                              
                                       
                                                                              
Robust Summaries
                                       T
                                      12
                                                                        $72.22 
                                                                       $866.64 
                                                                          $0.00
                                                                       $866.64 
VOLUNTARY SUBMISSIONS:[b]
Robust Summaries
                                       T
                                                                             12
                                                                        $72.22 
                                                                       $866.64 
                                                                          $0.00
                                                                       $866.64 
Submission of Final Reports
                                       C
                                                                             10
                                                                        $31.26 
                                                                       $312.60 
                                                                          $8.41
                                                                       $321.01 
Recordkeeping
                                       C
                                                                              1
                                                                        $31.26 
                                                                        $31.26 
                                                                         $0.00 
                                                                        $31.26 
EXEMPTION APPLICATIONS:
Prepare Exemption Applications
                                       T
                                       2
                                                                        $72.22 
                                                                       $144.44 
                                                                           0.00
                                                                       $144.44 
Corporate Review
                                       M
                                       6
                                                                        $80.22 
                                                                       $481.32 
                                                                           0.00
                                                                       $481.32 
Recordkeeping
                                       C
                                      0.5
                                                                        $31.26 
                                                                        $15.63 
                                                                         $0.00 
                                                                        $15.63 
Exemption Applications, Total
                                       
                                      8.5
                                                                              
                                                                       $641.39 
                                                                         $0.00 
                                                                       $641.39 
a Labor Type Codes are as follows: T = Technical; M = Managerial; C = Clerical
b Voluntary Submissions are the only type of TSCA Section 4 submission that not required to be submitted electronically. Paper and postage costs are estimated under "Per-Activity Supply Cost." These costs assumed that a voluntary submission contains: ten final reports averaging 35 pages, plus a cover letter and robust summary, totaling 362 pages. Paper costs at $.0092 per page total $3.30 (Staples 2015). Postage via 2 day FedEx Ground for the .4 lb package totals $8.41 (FedEx 2015).   Unit supply costs for "Robust Summaries" and "Recordkeeping" were removed from voluntary submissions (compared to the estimates in the last IC period) because the costs are accounted for under "Submission of Final Reports."

Table B: Industry Wage Rates (Dec 2014)
 
                                Labor Category
                                       
                          Fringe Benefits ($/hour)[1]
                               Fringes as % Wage
                              Overhead % Wage[2]
                           Fringe + Overhead Factor
                             Loaded Wages ($/hour)

                               Wage ($/hour)[1]






                                      (a)
                                      (b)
                                 (c) = (b)/(a)
                                      (d)
                                (e)=(1)+(c)+(d)
                                (f) = (a) x (e)
Managerial
                                    $47.90 
                                    $24.18 
                                      50%
                                      17%
                                     1.67
                                    $80.22 
Technical
                                    $42.19 
                                    $22.86 
                                      54%
                                      17%
                                     1.71
                                    $72.22 
Clerical
                                    $18.68 
                                    $9.40 
                                      50%
                                      17%
                                     1.67
                                    $31.26 
Notes:
[1]Source: Employer Costs for Employee Compensation Supplementary Tables: December 2006  -  December 2014 (U.S. Bureau of Labor Statistics, 2015).
[2]An overhead rate of 17% is used based on assumptions in Wage Rates for Economic Analysis of the Toxics Release Inventory Program (Rice, 2002), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report  (US EPA, 2002).

Table C: Agency Wage Rate (Jan 2015)
 
                                Labor Category
                       Data Source for Wage Information
                                 Wage ($/hour)
                                Fringe Benefit
                               Fringes as % wage
                              Overhead as % wage
                           Fringe + Overhead Factor
                                Loaded Wage ($)


                                      (a)
                                      (b)
                                (c) = (b) / (a)
                                      (d)
                              (e) = (c) + (d) + 1
                                (f) = (a) * (e)
EPA staff
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-13 Step 1 pay rates [a]
                                    $43.52
Included in 60% overhead
                                      N/A
                                    60% [b]
                                      1.6
                                    $69.63








[a] Source: U.S. Office of Personnel Management. (2014). Salary Table 2014-DCB. Retrieved March 19, 2015 from Pay & Leave: Salaries & Wages: www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/14Tables/html/DCB_h.aspx.
[b]The 60 percent fringes-and-overhead rate is from an EPA guide, Instructions for Preparing ICRs (US EPA, 2009).

Table D: Comparison of Burden: Previous ICR Versus Current e-Reporting, Per Activity
 
                                 Previous ICR
                             Post e-Reporting Rule
                              Collection Activity
                              Per Activity Labor
                         Per-Activity Supply Costs (y)
                              Per Activity Labor
                         Per-Activity Supply Costs (y)

                                   Type [a]
                                     Hours

                                   Type [a]
                                     Hours

CDX REGISTRATION
 
 
 
 
 
 
CDX Registration
                                      N/A
                                      N/A
                                                                            N/A
                                       T
                                     0.18
                                                                          $0.00
CDX Electronic Signature
                                      N/A
                                      N/A
                                                                            N/A
                                       T
                                     0.35
                                                                          $0.00
CDX Registration and e-Signature Total
 
 
 
                                     0.53
                                    $0.00 
TEST RULES AND TESTING AGREEMENTS:
 
 
 
Interim Reports
 
 
 
Letter of Intent with Study Plans
                                       T
                                      40
                                                                        $21.91 
                                       T
                                      40
                                                                          $0.00
Prepare Progress Report
                                       T
                                       8
                                                                         $5.48 
                                       T
                                       8
                                                                          $0.00
Final Reports
 
                                       
 
Short-term Studies
 
                                       
 
Record and Prepare Test for Submission
                                       T
                                      40
                                                                          $0.00
                                       T
                                      40
                                                                          $0.00
Laboratory Review
                                       T
                                       6
                                                                          $0.00
                                       T
                                       6
                                                                          $0.00
Corporate Review
                                       M
                                       6
                                                                          $0.00
                                       M
                                       6
                                                                          $0.00
Type and Print Results
                                       C
                                      20
                                                                          $0.00
                                      N/A
                                       0
                                                                          $0.00
Recordkeeping
                                       C
                                       1
                                                                         $5.48 
                                       C
                                      0.5
                                                                         $0.00 
Short-term Studies Total
                                       
                                      73
                                                                         $5.48 
 
                                     52.5
                                     $0.00
Long-term Studies
 
                                       
 
Record and Prepare Test for Submission
                                       T
                                      80
                                                                          $0.00
                                       T
                                      80
                                                                          $0.00
Corporate Review
                                       M
                                       9
                                                                          $0.00
                                       M
                                       9
                                                                          $0.00
Type and Print Results
                                       C
                                      40
                                                                          $0.00
                                      N/A
                                       0
                                                                          $0.00
Recordkeeping
                                       C
                                       1
                                                                         $5.48 
                                       C
                                      0.5
                                                                         $0.00 
Long-term Studies Total
                                       
                                      130
                                                                         $5.48 
 
                                     89.5
                                                                         $0.00 
Robust Summaries
                                       T
                                      12
                                                                          $0.00
                                       T
                                      12
                                                                          $0.00
VOLUNTARY SUBMISSIONS:
 
                                       
 
Robust Summaries
                                       T
      12
                                                                          $0.00
                                       T
                                      12
                                                                          $0.00
Submission of Final Reports
                                       C
      10
                                                                          $0.00
                                       C
                                      10
                                                                          $8.41
Recordkeeping
                                       C
       1
                                                                         $5.48 
                                       C
                                       1
                                                                         $0.00 
EXEMPTION APPLICATIONS:
 
                                       
 
Prepare Exemption Applications
                                       T
                                       2
                                                                           0.00
                                       T
                                       2
                                                                           0.00
Corporate Review
                                       M
                                       6
                                                                           0.00
                                       M
                                       6
                                                                           0.00
Recordkeeping
                                       C
                                       1
                                                                         $5.48 
                                       C
                                      0.5
                                                                         $0.00 
Exemption Application Total 
                                       
                                       9
                                                                         $5.48 
                                       
                                      8.5
                                                                         $0.00 
a Labor Type Codes are as follows: T = Technical; M = Managerial; C = Clerical

