SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1189.10
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
PROPOSED
RULE
ON
CATHODE
RAY
TUBES
November
2001
Table
of
Contents
1.
IDENTIFICATIONOFTHE
INFORMATIONCOLLECTION
.............
Page2
1(
a)
Title
and
Number
of
Information
Collection
.......................
Page2
1(
b)
Characterization
of
the
Information
Collection
.....................
Page2
2.
NEEDFORANDUSE
OFTHECOLLECTION
........................
Page3
2(
a)
Need
and
Authority
for
the
Collection
...........................
Page3
2(
b)
Use
and
Users
of
the
Data
....................................
Page3
3.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
..............
Page3
3(
a)
Respondents
and
SIC
Codes
...................................
Page3
3(
b)
Information
Requested
.......................................
Page6
4.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
..............
Page7
4(
a)
Agency
Activities
...........................................
Page8
4(
b)
Small
Entity
Flexibility
.......................................
Page8
5.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
..............................................................
Page8
5(
a)
Non­
duplication
............................................
Page8
5(
b)
Consultations
..............................................
Page8
5(
c)
Effects
of
Less
Frequent
Collection
.............................
Page8
5(
d)
General
Guidelines
..........................................
Page9
5(
e)
Confidentiality
.............................................
Page9
5(
f)
Sensitive
Questions
..........................................
Page9
6.
ESTIMATINGTHE
BURDENANDCOSTOFCOLLECTION
............
Page9
6(
a)
Estimating
Respondent
Burden
.................................
Page9
6(
b)
Number
of
Respondents
......................................
Page9
6(
c)
Estimating
Respondent
Costs
.................................
Page13
6(
d)
Reasons
for
Change
in
Burden
................................
Page13
6(
e)
Burden
Statement
..........................................
Page16
LIST
OF
TABLES
Table1
EstimatedNumber
ofCRTShipments
..............................
11
Table
2
Reporting
and
Recordkeeping
Requirements
for
Used
CRT
Regulated
Entities:
AnnualEstimatedRespondentBurdenandCost
.......................
12
Table
3
Reporting
and
Recordkeeping
Requirements
for
Used
CRT
Generators
and
Processors:
Annual
Respondent
Burden
and
Cost
Summary
(All
Respondents)
14
Table4
AverageandTotalAnnualAvoidedRespondentBurden(
Hours)
..........
15
Table5
AverageAnnualBurdenper
Respondent(
Hours)
......................
16
i
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
A.
Background
1(
a)
Title
and
Number
of
Information
Collection
This
Information
Collection
Request
(ICR)
is
entitled
"Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Cathode
Ray
Tubes,
Number
1189.10.
.

1(
b)
Characterization
of
the
Information
Collection
Section
3001
of
the
Resource
Conservation
and
Recovery
Act
(RCRA)
of
1976,
as
amended,
requires
the
Environmental
Protection
Agency
(EPA)
to
identify
substances
that
must
be
managed
as
hazardous
waste
during
treatment,
storage,
or
disposal.
Under
this
authority,
EPA
established
four
hazardous
waste
characteristics
(toxicity,
reactivity,
ignitability,
and
corrosivity),
and
listed
specific
wastes
that
must
be
managed
as
hazardous.
Used
cathode
ray
tube
(CRT)
glass
often
is
hazardous
because
it
exhibits
the
characteristic
of
toxicity
by
exceeding
the
regulatory
level
for
lead.
As
a
result,
currently
many
CRTs
are
subject
to
controls
under
RCRA
Subtitle
C
hazardous
waste
regulations.

From
1994
through
1998,
EPA's
Common
Sense
Initiative
(CSI)
Council
explored
the
environmental
regulation
of
six
industry
sectors
and
looked
for
ways
to
make
environmental
regulation
"cleaner,
cheaper,
and
smarter."
EPA
established
the
CSI
Council
as
an
advisory
committee
under
the
Federal
Advisory
Committee
Act.
The
CSI
Council
included
representatives
from
each
of
the
industry
sectors,
from
non­
government
environmental
and
community
organizations,
from
state
government,
and
from
academia.
EPA
also
established
a
subcommittee
of
the
Council
for
each
of
the
industry
sectors
that
included
representatives
of
the
various
stakeholders
represented
in
the
CSI
Council.
One
of
the
industry
sectors
selected
for
this
initiative
was
the
computer
and
electronics
industry.
The
CSI
Computers
and
Electronics
Subcommittee
(CES)
set
up
a
workgroup
to
address
regulatory
barriers
to
pollution
prevention
and
recycling.
The
"Overcoming
Barriers
Workgroup,"
explored
the
problems
of
managing
mounting
volumes
of
outdated
computer
and
electronics
equipment.

One
of
the
concerns
investigated
by
the
Overcoming
Barriers
Workgroup
and
the
CES
Subcommittee
was
the
barrier
to
CRT
glass
recycling
created
by
some
existing
hazardous
waste
management
regulations.
The
Subcommittee
stated
that
removing
this
barrier
was
essential
to
fostering
CRT
recycling,
especially
glass­
to­
glass
recycling.
As
a
result
of
the
finding
of
the
CES
Subcommittee,
the
CSI
Council
issued
a
document
titled
Recommendation
on
Cathode
Ray
Tube
(CRT)
Glass­
to­
Glass
Recycling.
Page
2
To
encourage
CRT
glass
recycling
and
improve
the
management
of
hazardous
waste
CRTs,
EPA
is
excluding
used
CRTs
and
processed
CRT
glass
sent
for
recycling
from
the
definition
of
solid
waste,
subject
to
certain
minimal
conditions.
The
Agency
believes
these
materials
resemble
articles
in
commerce
more
than
wastes
when
handled
appropriately.
By
excluding
used
CRTs
and
processed
CRT
glass
that
are
to
be
recycled
from
the
definition
of
solid
waste,
the
proposal
streamlines
management
requirements
for
these
materials.
The
streamlined
requirements
will
lead
to
better
management
and
more
recycling
while
affording
full
protection
to
human
health
and
the
environment.

B.
Introduction
Most
of
the
proposal's
information
collection
requirements
consist
of
recordkeeping.
EPA
is
not
proposing
any
permitting
requirements
for
entities
recycling
used
CRTS
or
processed
CRT
glass.
Following
is
a
brief
description
of
the
proposal's
information
collection
requirements.
It
should
be
noted
that
this
ICR
does
not
examine
the
burden
or
cost
associated
with
the
generation
and
management
of
hazardous
waste
CRTs
or
processed
CRT
glass
that
is
destined
for
disposal.
This
category
of
CRTs
continues
to
be
considered
hazardous
waste
and
must
be
managed
in
accordance
with
the
existing
Subtitle
C
requirements.

Marking
Broken
used
CRTs
destined
for
recycling
must
be
clearly
labeled
or
marked.
Processed
CRT
glass
need
not
be
labeled
and
marked,
unless
it
is
going
to
a
recycler
other
than
a
glass­
toglass
manufacturer
or
a
lead
smelter.
These
requirements
are
necessary
in
order
to
identify
and
distinguish
used
CRTs
and
processed
CRT
glass
from
other
materials
and
to
prevent
inadvertent
mixing
with
other
wastes.

Storage
Time
Limits
Broken
used
CRTs
and
processed
CRT
glass,
in
order
to
be
excluded
from
the
definition
of
solid
waste,
may
not
be
speculatively
accumulated.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
requirements
covered
in
this
ICR
are
necessary
for
EPA
to
ensure
proper
management
of
used
CRTs
and
processed
CRT
glass
and
to
facilitate
enforcement
of
the
regulations.
Page
3
2(
b)
Use
and
Users
of
the
Data
EPA
will
use
the
collected
information
to
ensure
that
used
CRTs
and
processed
CRT
glass
are
being
managed
in
a
protective
manner.
Information
marked
on
containers
with
broken
used
CRTs
or
processed
CRT
glass
will
assist
handlers,
processors,
and
transporters
in
ensuring
proper
management
during
storage
and
shipment.

3.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents
and
SIC
Codes
The
following
is
a
list
of
Standard
Industrial
Classification
(SIC)
codes
associated
with
entities
handling
CRTs
likely
to
be
affected
by
the
information
collection
requirements
covered
under
this
ICR:

SIC
Code
*
Industry
*

AGRICULTURE
7
Agricultural
services
8
Forestry
9
Fishing,
hunting,
trapping
­
Administrative
&
auxiliary
MINING
10
Metal
mining
12
Coal
mining
13
Oil
&
gas
extraction
14
Non­
metallic
minerals,
except
fuels
­
Administrative
&
auxiliary
CONSTRUCTION
15
General
contractors
16
Heavy
construction
17
Special
trade
contractors
1
Administrative
&
auxiliary
MANUFACTURING
20
Food
&
kindred
products
21
Tobacco
products
22
Textile
mill
products
23
Apparel
&
other
textile
products
24
Lumber
&
wood
products
25
Furniture
&
fixtures
SIC
Code
*
Industry
*

Page
4
26
Paper
&
allied
products
27
Printing
&
publishing
28
Chemicals
&
allied
products
29
Petroleum
and
coal
products
30
Rubber
&
miscellaneous
plastics
products
31
Leather
&
leather
products
32
Stone,
clay,
and
glass
products
33
Primary
metal
industries
34
Fabricated
metal
products
35
Industrial
machinery
&
equipment
36
Electronic
&
other
electronic
equipment
37
Transportation
equipment
38
Instrument
&
related
products
39
Miscellaneous
manufacturing
1
Administrative
&
auxiliary
TRANSPORTATION
41
Local
&
interurban
passenger
transit
42
Trucking
&
warehousing
44
Water
transportation
45
Transportation
by
air
46
Pipelines,
except
natural
gases
47
Transportation
services
48
Communication
49
Electronic,
gas,
&
sanitary
services
1
Administrative
&
auxiliary
WHOLESALE
TRADE
50
Wholesale
trade­
durable
goods
51
Wholesale
trade­
nondurable
goods
52
Bldg.
materials
&
garden
supplies
1
Administrative
&
auxiliary
RETAIL
TRADE
53
General
merchandise
store
54
Food
stores
55
Auto
dealers
&
service
station
56
Apparel
&
accessory
stores
57
Furniture
&
home
furnishing
stores
SIC
Code
*
Industry
*

Page
5
58
Eating
&
drinking
places
59
Miscellaneous
retail
1
Administrative
&
auxiliary
FINANCE,
INSURANCE,
AND
REAL
ESTATE
60
Depository
institution
61
Nondepository
institution
62
Security
&
commodity
brokers
63
Insurance
carriers
64
Insurance
agents,
brokers,
&
servicers
65
Real
estate
67
Holding
&
other
investment
offices
1
Administrative
&
auxiliary
SERVICES
70
Hotels
&
other
lodging
places
72
Personal
services
73
Business
services
75
Auto
repair,
services,
&
parking
76
Misc.
repair
services
78
Motion
picture
79
Amusement
&
recreation
services
80
Health
services
81
Legal
services
82
Educational
services
83
Social
services
84
Museums,
botanical,
zoological
gardens
86
Membership
organization
87
Engineering
&
management
service
89
Services
1
Administrative
&
auxiliary
1
Unclassified
*
Source:
U.
S.
Bureau
of
the
Census
(1992).
Includes
County
Business
Patterns
data
and
data
from
the
Enterprise
Statistics
Program.
Page
6
3(
b)
Information
Requested
This
section
describes
information
collection
requirements
applicable
to
CRT
regulated
entities
that
would
be
affected
by
the
proposed
rule.

Marking
(i)
Data
items:

Generators
of
broken
used
CRTs
sent
for
recycling,
and
generators
of
processed
CRT
glass
sent
for
any
kind
of
recycling
other
than
a
glass­
to­
glass
manufacturer
or
a
lead
smelter,
must
mark
or
label
their
broken
used
CRTs
and
processed
CRT
glass
in
accordance
with
the
following
procedures:


Each
container
or
package
with
broken
used
CRTs
must
be
labeled
or
marked
clearly
with
one
of
the
following
phrases:
"Used
cathode
ray
tube(
s)
­
contains
leaded
glass,"
or
"Used
cathode
ray
tube(
s)
­
contains
leaded
glass."
In
addition,
it
must
also
be
labeled:
"Do
not
mix
with
other
glass
or
materials."

(ii)
Respondent
Activities:


Generators
and
processors
must
mark
or
label
containers
with
broken
used
CRTs
or
processed
CRT
glass.

Storage
Time
Limits
(i)
Data
items:

Broken
used
CRTs
and
processed
CRT
glass
may
not
be
accumulated
speculatively.
Generators
and
processors
are
required
to
demonstrate
the
length
of
time
that
the
CRT
materials
have
been
accumulated
from
the
date
it
was
received
or
became
a
waste.
The
demonstration
may
be
made
by
using
any
of
the
following
methods:


Placing
the
broken
used
CRTs
in
a
container
and
marking
the
container
with
the
earliest
date
that
any
CRT
in
the
container
became
a
waste
or
was
received.


Marking
each
individual
broken
CRT
with
the
date
it
became
a
waste
or
was
received.


Maintaining
an
inventory
system
on
site
that
identifies
the
date
the
broken
CRTs
being
accumulated
became
wastes
or
were
received.


Maintaining
an
inventory
system
on
site
that
identifies
the
earliest
date
any
broken
CRT
in
a
group
of
CRT
items
or
a
group
of
containers
of
CRTs
became
a
waste
or
was
received.


Placing
the
broken
CRTs
in
a
specific
accumulation
area
and
identifying
the
Page
7
earliest
date
that
any
CRT
material
in
the
area
became
a
waste
or
was
received.


Any
other
method
which
clearly
demonstrates
the
length
of
time
that
the
broken
CRTs
has
been
accumulated
from
the
date
it
became
a
waste
or
was
received.

(ii)
Respondent
Activities:


Generators
and
processors
must
demonstrate
the
length
of
time
that
broken
CRTs
has
been
accumulated
since
it
became
a
waste
or
was
received.

4.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
section
discusses
how
EPA
and
implementing
agencies
would
collect
and
manage
the
information
received
from
respondents.
This
section
also
includes
a
discussion
of
the
steps
EPA
will
take
to
ensure
that
the
information
collection
is
not
overly
burdensome
on
small
entities.

4(
a)
Agency
Activities
The
information
that
is
required
of
CRT
generators
and
processors
would
be
kept
on
site
and
not
submitted
to
EPA
formally.
Therefore,
there
are
no
follow­
up
activities
by
the
Agency
in
response
to
this
information.

4(
b)
Small
Entity
Flexibility
By
excluding
hazardous
waste
CRTs
and
processed
CRT
glass
intended
for
recycling
from
the
definition
of
solid
waste
under
certain
minimal
conditions,
the
proposed
rule
provides
regulatory
relief
from
the
full
Subtitle
C
management
requirement
for
all
entities
involved
in
CRT
management
and
willing
to
recycle
CRT
glass.
These
entities
include
generators,
CRT
recycling
facilities,
and
CRT
glass
manufacturers.

EPA
believes
this
exclusion
will
encourage
small
businesses
to
safely
manage
broken
CRTs
or
processed
CRT
glass
in
compliance
with
the
proposed
rule.
In
addition,
EPA
allows
conditionally
exempt
small
quantity
generators
(CESQGs)
to
manage
their
hazardous
waste
CRTs
either
under
the
existing
CESQG
exemption
in
40
CFR
261.5
or
under
the
specific
provisions
of
the
proposed
rule.
Page
8
5.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
Non­
duplication
Most
of
the
information
required
by
the
proposed
regulations
covered
by
this
ICR
is
not
available
from
any
source
but
the
respondents.
Some
of
the
respondents
may
be
able
to
use
current
facility
records
and
practices
to
comply
with
the
labeling,
marking
and
storage
requirements.
In
addition,
the
proposal
relieves
affected
CRT
entities
from
RCRA's
current
information
collection
requirements.

5(
b)
Consultations
For
more
than
two
years,
EPA
has
worked
on
a
collaborative
basis
with
the
Computers
and
Electronics
Sector
of
the
CSI
Council
in
developing
the
proposed
CRT
standards.
This
workgroup
consisted
of
representatives
of
environmental
groups,
industry
trade
associations,
CRT
glass
manufacturers,
CRT
glass
recyclers,
electronics
Original
Equipment
Manufacturers
(OEMs),
academic
experts,
States
(California,
Massachusetts,
Minnesota,
and
New
Jersey),
EPA,
and
expert
consultants
in
the
environmental,
legal/
regulatory,
worker
health
and
safety,
and
environmental
justice
issues.
In
addition,
EPA
will
consider
public
comments
submitted
in
response
to
the
proposed
rulemaking
prior
to
promulgating
the
final
rule.

5(
c)
Effects
of
Less
Frequent
Collection
EPA
will
consider
carefully
the
burden
imposed
upon
the
regulated
community
by
the
proposed
regulations,
and
to
the
extent
possible,
will
attempt
to
minimize
the
burden
imposed.
EPA
believes
strongly
that
if
the
minimum
requirements
specified
under
the
proposed
regulations
are
not
met,
neither
the
facilities
nor
EPA
will
be
able
to
ensure
that
used
CRTs
are
being
managed
in
a
manner
protective
of
human
health
and
the
environment.

5(
d)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act,
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

5(
e)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
define
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
The
information
provided
by
the
entities
regulated
under
the
proposed
regulations
will
be
treated
in
accordance
with
these
provisions,
as
appropriate.
Page
9
5(
f)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
ICR
presents
a
comprehensive
characterization
of
the
reporting
and
recordkeeping
burden
and
costs
to
CRT
generators
and
processors
under
the
proposed
rule.

6(
b)
Number
of
Respondents
The
number
of
facilities
that
would
be
covered
by
the
proposed
rule
was
obtained
from
EPA's
"Draft
Economic
Analysis
of
Cathode
Ray
Tube
Management,
Notice
of
Proposed
Rulemaking,"
dated
August
24,
2001.
EPA
estimates
that
2,
116
small
quantity
handlers/
collectors,
311
large
quantity
handlers/
collectors
and
5
processors
will
generate
CRTs
or
processed
CRT
glass
that
is
exempt
from
the
definition
of
solid
waste
under
this
rule.
Further,
EPA
expects
that
each
year
one
percent
of
the
generators
will
be
new
generators.

Reading
the
Regulations
EPA
expects
that
regulated
CRT
entities
will
read
the
applicable
waste
CRT
regulations
as
a
one­
time
activity
in
order
to
familiarize
themselves
with
the
new
rule.

Marking
EPA
expects
that
all
generators
and
processors
will
label
packages
or
containers
containing
broken
CRTs.
Generators
and
processors
are
not
expected
to
mark
each
individual,
broken
CRT,
but
rather
accumulate
them
in
clearly
marked
containers
or
vehicles,
thus
minimizing
the
recordkeeping
burden.

Storage
Time
Limits
EPA
expects
that
some
CRT
entities
will
keep
records
on
their
storage
time
according
to
procedures
specified
in
the
regulations.
EPA
believes
the
remaining
entities
will
use
standard
business
practices.
EPA
estimates
that
75
percent
of
CRT
regulated
entities
will
keep
records
by
marking
storage
containers
or
storage
areas
with
the
earliest
date
that
broken
CRTs
became
a
waste
or
were
received.
EPA
estimates
that
the
remaining
25
percent
of
CRT
regulated
entities
will
use
standard
business
practices
which
account
for
storage
time
and
satisfy
the
proposed
rule
requirements;
these
entities
therefore
are
not
burdened
in
this
ICR.

EPA
expects
that
the
burden
imposed
by
the
proposed
rule
is
associated
with
rule
Page
10
familiarization
and
marking
and
labeling
packages
or
containers
with
broken
CRTs.
Table
1
provides
background
data
on
the
number
of
used
CRT
entities
and
shipments.
Shipments
are
based
on
two
per
small
quantity
handler/
collector
and
four
for
large
quantity
handlers/
collectors
per
year.
Table
2
shows
the
one
time
rule
familiarization
cost
and
the
average
annual
burden
and
costs
for
generators,
collectors,
and
processors
to
comply
with
each
CRT
requirement.
The
table
includes
estimated
labor
costs
and
operation
and
maintenance
(O&
M)
costs.
Table
3
summarizes,
by
respondent
type,
the
total
annual
burden
and
costs.

Table
1
Estimated
Number
of
CRT
Shipments
Type
of
Regulated
Entity
Number
of
Regulated
Entities
Total
#
of
Shipments
Sent
Off
Site
Small
Quantity
Handlers/
Collectors
2,116
4,232
Large
Quantity
Handlers/
Collectors
311
1,244
Processors
5
128
Total
2,432
5,604
Page
11
TABLE
2
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
CRT
REGULATED
ENTITIES:
ONE
TIME
COST
PER
ENTITY
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
per
Respondent
Cost
Per
Respondent
Total
Cost
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@

$80.00/
hr
@
$116.53/
hr
@
$110.95/
h
r
@
$60.89/
hr
@
$43.44/
hr
CRT
RULE
FAMILIARIZATION
Small
Quantity
Handlers/
Collectors
2,116
0.0
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
2.5
$202.28
$428,024.48
Large
Quantity
Handlers/
Collectors
311
0.5
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
3.0
$260.56
$81,034.16
Processors
5
0.
0
1.0
1.
5
0.0
$0.00
$0.00
$0.00
2.5
$202.28
$1,011.40
SUBTOTAL
2,432
0.5
3.
0
4.5
0.
0
$0.00
$0.00
$0.00
8.0
$665.12
$510,070.04
REPORTING
AND
RECORDKEEPING
REQUIREMENT
FOR
CRT
REGULATED
ENTITIES
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
Per
Year
Per
Respondent
Cost
Per
Year
Per
Respondent
Total
Cost
Per
Year
Per
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@

$80.00/
hr
@
$116.53/
hr
@
$110.95/
h
r
@
$60.89/
hr
@
$43.44/
hr
Mark
the
broken
CRTs
or
containers
Small
Quantity
Handlers/
Collectors
2,116
0.0
0.
0
0.5
0.
0
$0.00
$0.00
$0.00
0.5
$30.45
$64,432.20
Large
Quantity
Handlers/
Collectors
311
0.0
0.
0
2.0
0.
5
$0.00
$0.00
$0.00
2.5
$143.50
$44,628.50
Processors
5
0.
0
0.0
0.
5
0.0
$0.00
$0.00
$0.00
0.5
$30.45
$152.25
Page
12
SUBTOTAL
2,432
0.0
0.
0
3.0
0.
5
$0.00
$0.00
$0.00
3.5
$204.39
$109,212.95
Page
13
REPORTING
AND
RECORDKEEPING
REQUIREMENT
FOR
CRT
REGULATED
ENTITIES
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
Per
Year
Per
Respondent
Cost
Per
Year
Per
Respondent
Total
Cost
Per
Year
Per
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@

$80.00/
hr
@
$116.53/
hr
@
$110.95/
h
r
@
$60.89/
hr
@
$43.44/
hr
Mark
storage
container
or
area
used
to
store
CRTs
or
CRT
glass
with
the
date
the
waste
was
received
or
became
a
waste
Small
Quantity
Handlers/
Collectors
2116
0.0
0.
0
0.25
0.25
$0.00
$0.00
$0.00
0.5
$26.08
$55,185.28
Large
Quantity
Handlers/
Collectors
311
0.0
0.
0
0.50
0.25
$0.00
$0.00
$0.00
0.75
$41.31
$12,847.41
Subtotal
2427
0.0
0.
0
0.75
0.50
$0.00
$0.00
$0.00
1.25
$67.39
$68,032.69
TOTAL
ONE
TIME
COST
PER
FACILITY
SQH/

Collectors
2116
0.0
1.
0
1.50
0.00
$0.00
$0.00
$0.00
6.0
$202.28
$428,024.48
LQH/

Collectors
311
0.5
1.
0
1.50
0.00
$0.00
$0.00
$0.00
3.0
$260.56
$81,034.16
Processors
5
0.
0
1.0
1.

50
0.

00
$0.00
$0.00
$0.00
2.5
$202.28
$1,011.40
TOTAL
2432
0.5
3.
0
4.50
0.00
$0.00
$0.00
$0.00
11.5
$665.12
$510,070.04
TOTAL
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SQH
Total
2116
0.0
0.
0
0.75
0.25
$0.00
$0.00
$0.00
1.00
$56.53
$119,617.48
LQH
Total
311
0.0
0.
0
2.50
0.75
$0.00
$0.00
$0.00
3.25
$184.81
$57,475.91
Processors
5
0.
0
0.0
0.

50
0.

00
$0.00
$0.00
$0.00
0.50
$30.45
$152.25
TOTAL
2432
0.0
0.
0
3.75
1.00
$0.00
$0.00
$0.00
4.75
$271.79
$177,245.64
Page
14
6(
c)
Estimating
Respondent
Costs
Labor
The
average
annual
salaries
of
the
professionals
listed
in
Table
2
are
based
on
data
found
in
the
U.
S.
Department
of
Labor
Statistics
(BLS)
"National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
1997."
Wages
were
calculated
using
the
BLS
rate
with
the
labor
multiplier.
The
labor
rates
are
based
on
a
full­
time
employee
with
a
40­
hour
work
week.
Total
annual
respondent
labor
costs,
summarized
in
the
3
rd
column
of
Table
3,
are
estimated
to
be
$510,070
for
the
initial
one
time
cost
and
$177,245.64
for
the
annual
variable
costs.

Operation
and
Maintenance
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
1995
Paperwork
Reduction
Act
as
"the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
EPA
estimates
that
there
are
no
respondent
O&
M
costs.

Capital
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
or
keep
records
of
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
For
this
ICR,
EPA
estimates
that
there
are
no
respondent
capital
costs.

TABLE
3:
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
HANDLERS,
COLLECTORS
AND
PROCESSORS:
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
(ALL
RESPONDENTS)

Respondent
Type
Total
Hours
for
Annual
Variable
Costs
Labor
Costs
Capital
Costs
O&
M
Costs
Total
Costs
Small
quantity
handlers/
collectors
14,812
$119,617
$0
$0
$119,617
Large
quantity
handlers/
collectors
1,011
$57,476
$0
$0
$57,476
Processors
33
$152
$0
$0
$152
TOTAL
15,855
$177,245
$0
$0
$177,245
Page
15
6(
d)
Reasons
for
Change
in
Burden
EPA
expects
that
the
proposed
rule
will
result
in
a
reduction
in
burden
to
the
regulated
waste
CRT
community.
CRT
entities
sending
broken
CRTs
or
CRT
glass
for
recycling
would
no
longer
be
subject
to
full
Subtitle
C
requirements.
Following
is
a
list
of
primary
RCRA
reporting
and
recordkeeping
requirements
that
CRT
entities
may
be
relieved
of:


Reporting
waste
generation
data
for
the
EPA's
Biennial
Report,
as
covered
in
ICR
No.
976,
Biennial
Report
ICR;


EPA
notification
of
hazardous
waste
activity;


Reporting
and
recordkeeping
under
the
land
disposal
restrictions
(LDRs)
program
of
40
CFR
Part
268,
as
covered
in
ICR
No.
1442,
Land
Disposal
Restrictions
ICR;


Reporting
and
recordkeeping
under
the
hazardous
waste
manifest
requirements,
as
covered
in
ICR
No.
801,
Manifest
ICR;
and

Recordkeeping
and/
or
reporting
of
personnel
training,
contingency
plan,
and
emergency
procedures
under
the
generator
standards
of
40
CFR
Part
262,
as
covered
in
ICR
No.
820,
Hazardous
Waste
Generator
Standards
ICR.

Table
4
presents
the
average
and
the
total
avoided
respondent
burden
resulting
from
the
proposed
rule.
This
avoided
burden
is
based
on
the
average
annual
burden
per
respondent
as
estimated
in
the
ICRs
listed
above.
Table
4
also
presents
the
total
estimated
avoided
entity
burden
by
multiplying
the
average
avoided
burden
per
respondent
by
the
total
number
of
CRT
entities
expected
to
be
affected
by
the
proposed
rule.
Page
16
Table
4
Average
and
Total
Annual
Avoided
Respondent
Burden
(Hours)
Primary
RCRA
Requirements
No
Longer
Applicable
to
CRT
Glass­
toglass
Regulated
Entities
Average
Annual
Respondent
Burden
Savings
per
Regulated
Entity
(in
hours)
Small
Quantity
Handler
Large
Quantity
Handler
Processor
Prepare
and
Submit
Notification
of
Hazardous
Waste
Activity
1
(RP)

1.
5
(RP)

N/
A
Prepare
and
submit
Hazardous
Waste
Biennial
Report
Forms
N/
A
12
(RP)

12
(RP)
Prepare
and
transmit
LDR
notifications
to
treatment
and
disposal
facilities
and
keep
records
1
(RP)

2(

RP)

6
(RP)
0.5
(RK)

1(

RK)

2
(RK)
Prepare
and
transmit
manifests
and
keep
records
1
(RP)

2(

RP)

8
(RP)
0.5
(RK)

1(

RK)

2
(RK)
Personnel
training
0.5
(RK)

4
(RK)

8
(RK)
Contingency
plan
N/
A
3
(RK)

6
(RK)
Emergency
procedures
0
2
(RK)

2
(RK)
Total
Avoided
Burden
per
Regulated
Entity
3
(RP)

17.5
(RP)

26
(RP)
1.5
(RK)

11
(RK)

20
(RK)
Number
of
Regulated
Entities
Affected
by
the
Proposed
Rule
2116
311
5
Total
Avoided
Burden
6,348
(RP)

5,443
(RP)

130
(RP)
3,174
(RK)

3,421
(RK)

100
(RK)
RP:

Reporting;

RK:

Recordkeeping
Page
17
6(
e)
Burden
Statement
Table
5
presents
the
estimated
average
burden
hours
per
respondent
per
year
for
the
reporting
and
recordkeeping
requirements
covered
by
this
ICR.
The
reporting
burden
includes
time
to
comply
with
the
proposed
notification,
environmental
justice,
and
exporting
requirements.
The
recordkeeping
burden
includes
time
to
follow
the
proposed
labeling/
marking
and
storage
time
limit
requirements.

Table
5
Average
Annual
Burden
per
CRT
Respondent
(Hours)

Type
of
Regulated
Entity
Estimated
Annual
Reporting
Burden
Estimated
Annual
Recordkeeping
Burden
Estimated
Number
of
Each
Entity
Estimated
Total
Burden
Small
Quantity
Generators/
Collectors
0
1
2,116
2,116
Large
Quantity
Generators/
Collectors
0
3.
25
311
1011
Processors
0
0.
5
5
2.
5
As
shown
in
Table
5,
the
total
annual
burden
is
estimated
to
be
1
hour
for
small
quantity
handlers,
3.25
hours
for
large
quantity
handlers,
and
0.5
hour
for
processors.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
numbers
for
EPA's
regulation
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
regarding
these
burden
statements
or
any
other
aspect
of
this
collection,
including
suggestions
for
reducing
the
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Office
of
Policy,
U.
S.
Environmental
Protection
Agency
(2822),
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
D.
C.
20460
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
Attention:
Desk
Officer
for
EPA,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503.
Include
the
OMB
control
number
in
any
correspondence.
