
SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1189.16
"
RECYCLING
OF
CATHODE
RAY
TUBES
(
CRTS):
CHANGES
TO
HAZARDOUS
WASTE
REGULATIONS
(
FINAL
RULE)"

March
29,
2004
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Practical
Utility
and
Users
of
the
Data
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2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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4
3(
g)
Sensitive
Questions
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4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4
4(
a)
Respondents
and
SIC/
NAICS
Codes
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4
4(
b)
Information
Requested
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7
5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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9
5(
a)
Agency
Activities
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10
5(
b)
Collection
Methodology
and
Management
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11
5(
c)
Small
Entity
Flexibility
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11
5(
d)
Collection
Schedule
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11
6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
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12
6(
a)
Estimating
Respondent
Burden
Hours
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12
6(
b)
Estimating
Respondent
Costs
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12
6(
c)
Estimating
Agency
Hour
and
Cost
Burden
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13
6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
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13
6(
e)
Bottom
Line
Hour
and
Cost
Burden
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16
6(
f)
Reasons
for
Change
In
Burden
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17
6(
g)
Public
Burden
Statement
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17
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Recycling
of
Cathode
Ray
Tubes
(
CRTs):
Changes
to
Hazardous
Waste
Regulations
(
Final
Rule),"
EPA
ICR
Number
1189.16.

1(
b)
Short
Characterization
Section
3001
of
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
requires
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
identify
substances
that
must
be
managed
as
hazardous
waste
during
treatment,
storage,
or
disposal.
Under
this
authority,
EPA
has
established
four
hazardous
waste
characteristics
(
i.
e.,
toxicity,
reactivity,
ignitability,
and
corrosivity),
and
has
listed
specific
wastes
that
must
be
managed
as
hazardous.
Waste
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,
many
CRTs
are
subject
to
controls
under
RCRA
hazardous
waste
regulations.

To
encourage
greater
reuse,
recycling,
and
better
management
of
this
growing
waste
stream,
EPA
is
amending
the
RCRA
hazardous
waste
regulations
by
establishing
a
conditional
exclusion
for
used
CRTs.
Under
the
conditional
exclusion,
used
CRTs
and
glass
removed
from
CRTs
sent
for
recycling
are
excluded
from
the
definition
of
solid
waste,
if
they
meet
specified
conditions.

In
Sections
1
through
5
of
this
ICR,
EPA
presents
a
comprehensive
description
of
the
new
information
collection
requirements
resulting
from
the
conditional
exclusion
for
used
CRTs.
In
Section
6,
EPA
estimates
the
total
annual
hour
and
cost
burden
to
respondents
associated
with
these
new
information
collection
requirements.
In
addition,
EPA
estimates
in
Section
6(
d)
the
total
annual
hour
and
cost
savings
to
generators
and
subsequent
waste
handlers
for
no
longer
complying
with
existing
RCRA
information
collection
requirements
in
managing
their
excluded
CRTs.

In
the
following
paragraphs,
EPA
briefly
describes
the
new
information
collection
requirements
contained
in
the
final
rule.

(
1)
Labels
Under
40
CFR
261.39(
a)(
2),
generators
of
used
CRTs
destined
for
recycling
must
label
or
mark
clearly
each
container
in
which
used,
broken
CRTs
are
contained
with
one
of
the
following
phrases:
"
Used
cathode
ray
tube(
s)
­
contains
leaded
glass"
or
"
Used
cathode
ray
tube(
s)
­
contains
leaded
glass
from
televisions
or
computers."
Generators
also
must
label
each
container
with
the
words:
"
Do
not
mix
with
other
glass
materials."
2
(
2)
Export
Notification
for
Used
CRTs
Destined
for
Recycling
Under
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.
Upon
request
by
EPA,
the
exporter
must
furnish
to
EPA
any
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.
Exporters
must
keep
copies
of
notifications
and
consents
for
a
period
of
three
years
following
receipt
of
the
consent.

Under
40
CFR
261.40,
exporters
of
used,
intact
CRTs
destined
for
recycling
must
meet
the
conditions
of
section
261.39(
a)(
5).

(
3)
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Under
40
CFR
261.41,
exporters
of
used,
intact
CRTs
for
reuse
must
send
a
one­
time
notification
to
EPA.
In
addition,
they
must
keep
copies
of
normal
business
records
(
e.
g.,
contracts)
demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused.
This
documentation
must
be
retained
for
a
period
of
at
least
three
years
from
the
date
the
CRTs
were
exported.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
EPA
is
establishing
a
conditional
exclusion
from
the
definition
of
solid
waste
for
used
CRTs
and
glass
removed
from
CRTs
sent
for
recycling
under
the
authority
of
Sections
2002(
a),
3001,
3002,
3004,
and
3006
of
RCRA,
as
amended.
EPA
believes
the
information
collection
requirements
covered
in
this
ICR
are
needed
to
ensure
that
the
excluded
CRTs
are
properly
managed,
and
to
facilitate
enforcement
of
the
regulations.

In
particular,
the
labeling
requirement
is
necessary
to
alert
anyone
handling
the
containers
with
the
used,
broken
CRTs
of
what
is
enclosed
in
the
container
so
that
proper
handling
(
or
inspection)
may
occur.
The
notification
requirements
are
necessary
to
assist
the
Agency
in
identifying
and
tracking
exporters
of
used
CRTs.

2(
b)
Practical
Utility
and
Users
of
the
Data
EPA
will
use
the
collected
information
to
ensure
that
excluded
CRTs
are
being
managed
in
a
protective
manner.
Information
marked
on
CRT
containers
will
assist
generators,
processors,
and
transporters
ensure
proper
handling
during
storage
and
shipment.
Notifications
submitted
to
EPA
will
aid
the
Agency
in
identifying
and
tracking
exporters
of
used
CRTs.
In
addition,
information
kept
in
facility
records
will
help
exporters
of
used
CRTs
demonstrate,
and
on­
site
inspectors
ensure,
that
the
excluded
CRTs
are
being
properly
managed.
3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
Most
of
the
information
required
by
the
regulations
covered
in
this
ICR
is
not
available
from
any
source
but
the
respondents.
Therefore,
this
information
does
not
duplicate
other
Federal
program
requirements.
In
addition,
the
regulations
relieve
generators
and
subsequent
handlers
of
used
CRTs
from
some
of
RCRA's
information
collection
requirements,
as
specified.

3(
b)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
on
June
12,
2002
(
67
FR
40508).
The
public
comment
period
extended
through
August
12,
2002.
EPA
reviewed
public
comments
received
in
response
to
the
notice
and
has
addressed
comments
received,
as
appropriate.

3(
c)
Consultations
For
over
two
years,
EPA
worked
on
a
collaborative
basis
with
the
Computers
and
Electronics
Sector
of
the
Common
Sense
Initiative
(
CSI)
Council
in
developing
the
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.
Recommendations
provided
by
this
workgroup
were
considered
in
establishing
the
information
collection
requirements
under
the
final
rule.

In
addition,
a
proposed
ICR
was
published
in
conjunction
with
the
proposed
rule
and
the
public,
including
potential
respondents,
had
the
opportunity
to
provide
comment
and
input
on
the
assumptions
and
cost
estimates
provided
in
the
proposed
ICR.
Any
information
provided
to
EPA,
or
OMB,
in
response
to
the
proposed
ICR
and/
or
the
Economics
Background
Document
developed
for
the
proposed
rule
was
reviewed
by
the
Agency
in
developing
this
ICR
for
the
final
rule.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
has
carefully
considered
the
information
collection
burden
imposed
upon
the
regulated
community
by
the
final
rule.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
the
Agency
has
attempted
to
minimize
the
burden
imposed.
EPA
believes
strongly
that,
if
the
minimum
information
collection
requirements
of
the
final
rule
are
not
met,
neither
the
respondents
(
e.
g.,
generators,
processors,
exporters)
nor
4
EPA
can
ensure
that
excluded
CRTs
are
being
properly
managed,
and
do
not
pose
a
serious
threat
to
human
health
and
the
environment.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
EPA's
ICR
Handbook,
and
other
applicable
OMB
guidance.

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA;
40
CFR
part
2,
subpart
B;
and
40
CFR
260.2
contain
provisions
for
confidentiality.
If
a
business
asserts
a
claim
of
confidentiality
covering
any
of
the
information
collection
requirements
covered
in
this
ICR,
EPA
must
and
will
treat
the
information
in
accordance
with
the
regulations
cited
above.
EPA
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
(
SIC)
codes
and
corresponding
North
American
Industry
Classification
System
(
NAICS)
codes
associated
with
industries
most
likely
affected
by
the
information
collection
requirements
covered
in
this
ICR.

Industry
SIC
Code
NAICS
Code
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,
114
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
5
Industry
SIC
Code
NAICS
Code
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,
532
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,
488,
562
6
Industry
SIC
Code
NAICS
Code
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
541
Educational
services
82
514,
611
Social
services
83
623,
624,
813,
922
Museums,
botanical,
zoological
gardens
84
712
Membership
organization
86
561,
813,
912
7
Industry
SIC
Code
NAICS
Code
Engineering
&
management
service
87
233,
234,
541,
561,
611
Private
household
services
88
81
Services
89
512,
541,
711
4(
b)
Information
Requested
(
1)
Labels
Under
40
CFR
261.39(
a)(
2),
generators
of
used,
broken
CRTs
destined
for
recycling
must
label
or
mark
clearly
each
container
in
which
the
CRTs
are
contained.

(
i)
Data
Items:

°
Label
or
mark
with
the
phrase:
"
Used
cathode
ray
tube(
s)
­
contains
leaded
glass"
or
"
Used
cathode
ray
tube(
s)
­
contains
leaded
glass
from
televisions
or
computers."

°
Label
or
mark
with
the
words:
"
Do
not
mix
with
other
glass
materials."

(
ii)
Respondent
Activity:

°
Label
or
mark
clearly
each
container,
as
specified.

(
2)
Export
Notification
for
Used
CRTs
Destined
for
Recycling
Under
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.
Upon
request
by
EPA,
the
exporter
must
furnish
to
EPA
any
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.
Exporters
must
keep
copies
of
notifications
and
consents
for
a
period
of
three
years
following
receipt
of
the
consent.

Under
40
CFR
261.40,
exporters
of
used,
intact
CRTs
destined
for
recycling
must
meet
the
conditions
of
section
261.39(
a)(
5).

(
i)
Data
Items:

°
Notification
of
intent
to
export
that
includes
the
following
information:

­
Name,
mailing
address,
telephone
number,
and
EPA
ID
number
(
if
any)
of
the
exporter;
8
­
The
estimated
frequency
or
rate
at
which
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
to
and
departure
from
each
foreign
country
through
which
the
CRTs
will
pass;

­
A
description
of
the
means
by
which
each
shipment
of
the
CRTs
will
be
transported
(
e.
g.,
air,
highway,
rail,
water);

­
Name
and
address
of
the
recycler;

­
A
description
of
the
manner
in
which
the
CRTs
will
be
recycled
in
the
receiving
country;

­
The
name
of
any
transit
country
through
which
the
CRTs
will
be
sent
and
a
description
of
the
approximate
length
of
time
the
CRTs
will
remain
in
such
country;
and
­
Signature
of
the
exporter.

°
On
the
front
of
the
envelope
used
to
submit
the
written
notification,
the
words:
"
Attention:
Notification
of
Intent
to
Export."

°
Additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.

°
Receiving/
transit
country's
written
consent
to
the
receipt
of
the
CRTs.

°
Notification
of
receiving/
transit
country's
objection
to
the
receipt
of
the
CRTs,
if
applicable.

°
Notification
of
receiving/
transit
country's
withdrawal
of
a
prior
consent
to
the
receipt
of
CRTs,
if
applicable.

(
ii)
Respondent
Activities:

°
Prepare
and
submit
written
notification.

°
Prepare
and
submit
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.
9
°
Keep
copies
of
notifications
and
consents.

(
3)
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Under
40
CFR
261.41,
exporters
of
used,
intact
CRTs
for
reuse
must
send
a
one­
time
notification
to
EPA.
In
addition,
they
must
keep
copies
of
normal
business
records
(
e.
g.,
contracts)
demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused.
This
documentation
must
be
retained
for
a
period
of
at
least
three
years
from
the
date
the
CRTs
were
exported.

(
i)
Data
Items:

°
Notification
that
includes
the
following
information:

­
A
statement
that
the
notifier
plans
to
export
used,
intact
CRTs
for
reuse;

­
Notifier's
name,
address,
and
EPA
ID
number
(
if
applicable);
and
­
Contact
person's
name
and
phone
number.

°
Normal
business
records
(
e.
g.,
contracts)
demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused.

(
ii)
Respondent
Activities:

°
Prepare
and
submit
a
one­
time
notification.

°
Keep
copies
of
normal
business
records
(
e.
g.,
contracts)
demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused.

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.
10
5(
a)
Agency
Activities
(
1)
Labels
There
are
no
Agency
activities
associated
with
the
labeling
requirements
under
40
CFR
261.39(
a)(
2).

(
2)
Export
Notification
for
Used
CRTs
Destined
for
Recycling
Agency
activities
associated
with
the
conditional
exclusion
for
used
CRTs
exported
for
recycling
include:

°
Receive
and
review
notification
submitted
by
an
exporter
of
used
CRTs
to
determine
whether
or
not
the
notification
is
complete.
A
notification
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
receiving
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.

(
3)
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Agency
activities
associated
with
the
conditional
exclusion
for
used
CRTs
exported
for
reuse
include:

°
Receive
and
review
notification
submitted
by
exporter
of
used
CRTs.

°
Keep
copy
of
notification.
11
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
submitted
under
40
CFR
261.39(
a)(
5),
261.40,
and
261.41,
EPA
will
use
equipment
such
as
personal
computers
and
applicable
database
software,
where
appropriate.
EPA
will
ensure
the
accuracy
and
completeness
of
the
collected
information
by
reviewing
each
submittal.

5(
c)
Small
Entity
Flexibility
In
establishing
the
conditional
exclusion
for
used
CRTs,
EPA
considered
the
reporting
and
recordkeeping
burden
for
small
businesses.
In
addition,
the
conditional
exclusion
is
a
regulatory
relief
initiative
that
should
reduce
hour
and
cost
burden
for
generators
and
subsequent
handlers
of
excluded
CRTs,
but
should
particularly
benefit
small
entities.

5(
d)
Collection
Schedule
(
1)
Labels
Generators
of
used,
broken
CRTs
destined
for
recycling
must
label
or
mark
clearly
each
container
in
which
the
CRTs
are
contained,
as
specified.
EPA
believes
that
each
container
should
be
labeled
or
marked
to
ensure
proper
management
and
handling.

(
2)
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.
A
complete
notification
must
be
submitted
60
days
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
by
EPA,
exporters
must
furnish
to
EPA
any
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.

(
3)
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Exporters
of
used
CRTs
destined
for
reuse
must
send
a
one­
time
notification
to
EPA.
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.
12
6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Hours
In
Exhibit
1,
EPA
estimates
the
respondent
hourly
burden
associated
with
the
new
information
collection
requirements
covered
in
this
ICR.
Exhibit
1
includes
burden
hours
(
total
and
by
labor
type)
per
respondent,
as
well
as
the
overall
burden
hours
for
all
respondents.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
the
annual
respondent
costs
associated
with
the
new
information
collection
requirements
in
Exhibit
1.
These
costs
are
based
on
the
cost
of
labor,
capital,
and
operation
and
maintenance
(
O&
M).

(
1)
Labor
Costs
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
fringe
and
overhead)
of
$
126.19
for
legal
staff,
$
120.15
for
managerial
staff,
$
65.94
for
technical
staff,
$
30.08
for
workman
staff,
and
$
47.05
for
clerical
staff.
These
hourly
labor
costs
were
obtained
from
the
economics
background
document
developed
for
this
rulemaking.

Using
the
total
burden
hours
discussed
in
Section
6(
a)
and
the
hourly
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
the
new
information
collection
requirements
covered
in
this
ICR.

(
2)
Capital
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
EPA
does
not
anticipate
that
respondents
will
incur
capital
costs
in
carrying
out
the
information
collection
requirements
covered
in
this
ICR.

(
3)
Operation
&
Maintenance
Costs
O&
M
costs
are
those
costs
associated
with
an
information
collection
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
Paperwork
Reduction
Act
of
1995
as
"
the
recurring
dollar
amount
of
costs
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
include
mailing
costs
($
0.37
for
postage
and
$
0.01
for
a
standard
size
envelope).
These
O&
M
costs
are
shown
in
Exhibit
1.
13
1
The
universe
estimates
and
assumptions
in
this
ICR
are
based
on
the
economics
background
document
developed
for
this
rulemaking.
6(
c)
Estimating
Agency
Hour
and
Cost
Burden
EPA
estimates
the
Agency
hour
and
cost
burden
associated
with
the
new
information
collection
requirements
covered
in
this
ICR
in
Exhibit
2.
As
shown
in
the
exhibit,
EPA
estimates
an
average
hourly
labor
cost
of
$
66.26
for
legal
staff
(
GS­
15,
Step
1),
$
47.66
for
managerial
staff
(
GS­
13,
Step
1),
$
33.44
for
technical
staff
(
GS­
11,
Step
1),
and
$
20.34
for
clerical
staff
(
GS­
06,
Step
1).
To
derive
these
hourly
estimates,
EPA
referred
to
the
General
Schedule
(
GS)
Salary
Table
2004.
This
publication
summarizes
the
unloaded
(
base)
hourly
rate
for
various
labor
categories
in
the
Federal
Government.
EPA
then
applied
the
standard
government
overhead
factor
of
1.6
to
the
unloaded
rate
to
derive
these
loaded
hourly
rates.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
In
this
section,
EPA
first
describes
the
respondent
universe
affected
by
the
new
information
collection
requirements
covered
in
this
ICR.
EPA
then
estimates
the
annual
incremental
burden
to
respondents
under
the
final
rule
and
the
annual
burden
savings
to
respondents
for
no
longer
managing
their
excluded
CRTs
under
existing
RCRA
information
collection
requirements.

(
1)
Respondent
Universe
Table
1
presents
the
annual
number
of
respondents
subject
to
the
new
information
collection
requirements
covered
in
this
ICR.
1
It
shows
that
EPA
expects
3,775
facilities
to
generate
and/
or
manage
used
CRTs
each
year.
Of
these
3,775
facilities,
3,482
are
original
users,
288
are
collectors,
and
five
are
processors.

Table
1
Annual
Number
of
Respondents
Subject
to
the
New
Information
Collection
Requirements
Covered
in
this
ICR
Type
of
Respondent
Number
of
Respondents
Original
Users
3,482
Collectors
288
Processors
5
Total
3,775
14
2
The
universe
estimates
and
assumptions
in
this
ICR
are
based
on
the
economics
background
document
developed
for
this
rulemaking.
Table
2
presents
the
annual
number
of
exporters
of
used
CRTs,
as
well
as
the
annual
number
of
export
shipments.
2
It
shows
that
EPA
expects
29
facilities
(
i.
e.,
15
+
14
=
29)
to
export
a
total
of
500
shipments
of
used
CRTs
(
i.
e.,
256
+
244
=
500)
each
year.
Of
these
500
shipments,
256
will
be
destined
for
recycling
and
244
will
be
destined
for
reuse.

Table
2
Annual
Number
of
Exporters
and
Export
Shipments
of
Used
CRTs
Subject
to
the
New
Information
Collection
Requirements
Covered
in
this
ICR
Type
of
CRT
Number
of
Exporters
Number
of
Export
Shipments
Used
CRTs
destined
for
Recycling
15
256
Used
CRTs
destined
for
Reuse
14
244
(
2)
Total
Hour
and
Cost
Burden
(
a)
Hour
and
Cost
Burden
under
the
Final
Rule
Based
on
the
universe
data
presented
in
Tables
1
and
2,
EPA
estimated
the
respondent
burden
associated
with
all
of
the
new
information
collection
requirements
covered
in
this
ICR
in
Exhibit
1.
A
discussion
of
the
assumptions
used
in
developing
these
burden
estimates
follows.

(
a1)
Reading
the
Regulations
EPA
estimates
that
3,775
respondents
will
be
subject
to
the
new
information
collection
requirements
covered
in
this
ICR.
EPA
assumes
that
all
these
respondents
will
read
the
regulations
once
during
the
three­
year
life
of
the
ICR.
In
estimating
the
annual
respondent
hour
and
cost
burden
over
the
three­
year
period
covered
by
this
ICR,
EPA
annualized
the
hour
and
cost
burden
of
this
one­
time
activity
by
dividing
the
number
of
respondents
by
three.
Thus,
EPA
estimates
that
1,258
respondents
(
i.
e.,
3,775
respondents
/
3
years),
on
average,
will
read
the
regulations
each
year.

(
a2)
Labels
Under
40
CFR
261.39(
a)(
2),
generators
of
used,
broken
CRTs
destined
for
recycling
must
label
or
mark
clearly
each
container
(
e.
g.,
"
gaylord"
box)
in
which
used,
broken
CRTs
are
contained,
as
specified.
EPA
estimates
that,
each
year,
respondents
will
use
32,423
containers.
EPA
assumes
that
these
respondents
will
mark
each
of
these
containers
by
writing
the
specified
words
on
them.
EPA
also
assumes
that
each
container
will
be
used
only
once.
15
(
a3)
Export
Notification
for
Used
CRTs
Destined
for
Recycling
Under
40
CFR
261.39(
a)(
5),
exporters
of
used
CRTs
must
notify
EPA
of
the
intended
shipment
before
the
CRTs
are
scheduled
to
leave
the
U.
S.
The
notification
may
cover
export
activities
extending
over
a
12­
month
or
lesser
period.
In
addition,
upon
EPA's
request,
exporters
must
furnish
any
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification.

EPA
estimates
that,
each
year,
256
shipments
of
used
CRTs
will
be
exported
for
recycling.
EPA
expects
that
these
exporters
will
notify
the
Agency
of
their
intent
to
export
the
used
CRTs.
In
addition,
the
Agency
estimates
that
approximately
26
exporters
will
furnish
additional
information.

(
a4)
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Under
40
CFR
261.41,
exporters
of
used
CRTs
destined
for
reuse
must
send
a
one­
time
notification
to
EPA.
In
addition,
they
must
keep
copies
of
normal
business
records
(
e.
g.,
contracts)
demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused.

EPA
estimates
that,
each
year,
14
respondents
will
export
used
CRTs
for
reuse.
EPA
assumes
that
all
these
respondents
will
notify
the
Agency
once
during
the
three­
year
life
of
the
ICR.
In
estimating
the
annual
respondent
hour
and
cost
burden
over
the
three­
year
period
covered
by
this
ICR,
EPA
annualized
the
hour
and
cost
burden
of
this
one­
time
activity
by
dividing
the
number
of
respondents
by
three.
Thus,
EPA
estimates
that
5
respondents
(
i.
e.,
14
respondents
/
3
years),
on
average,
will
submit
the
one­
time
notification
each
year.

The
total
number
of
responses
under
the
reporting
and
recordkeeping
requirements
for
CRTs
exported
for
recycling
and
reuse
described
in
paragraphs
(
a)(
3)
and
(
a)(
4)
is
557.

(
b)
Hour
and
Cost
Burden
under
Existing
Information
Collection
Requirements
In
addition
to
estimating
the
incremental
burden
from
the
new
information
collection
requirements,
EPA
also
estimated
the
hour
and
cost
savings
to
generators
and
subsequent
handlers
for
no
longer
complying
with
existing
RCRA
information
collection
requirements
in
managing
excluded
CRTs.
These
costs
are
presented
in
Exhibit
3,
broken
out
by
the
existing
EPA
ICRs
affected
by
the
final
rule.

In
developing
Exhibit
3,
EPA
reviewed
each
of
the
affected
ICRs
to
identify
the
existing
information
collection
activities
that
will
be
undertaken
by
generators
and
handlers
of
used
CRTs,
calculated
the
associated
hour
and
cost
burden,
and
presented
the
totals
in
the
exhibit.
Following
are
the
affected
ICRs,
along
with
a
description
of
relevant
capital
and
O&
M
costs:
16
°
Manifest
ICR
(
EPA
ICR
Number
801):
there
are
no
capital
costs;
O&
M
costs
are
associated
with
sending
and
returning
copies
of
the
manifest
forms;

°
Generator
Standards
ICR
(
EPA
ICR
Number
820):
there
are
no
capital
or
O&
M
costs;

°
Biennial
Report
ICR
(
EPA
ICR
Number
976):
there
are
no
capital
costs;
O&
M
costs
are
associated
with
submitting
report
to
State
or
EPA
Regional
Office
and
maintaining
copies
of
Site
Identification,
Waste
Generation
and
Management
(
GM),
and
Waste
Received
from
Off­
Site
(
WR)
Forms;
and

Land
Disposal
Restrictions
ICR
(
EPA
ICR
Number
1442):
there
are
no
capital
costs;
O&
M
costs
are
associated
with
transmittal
and
recordkeeping
of
one­
time
LDR
notifications
and
certifications.

6(
e)
Bottom
Line
Hour
and
Cost
Burden
(
1)
Respondent
Tally
EPA
presents
the
total
annual
respondent
hour
and
cost
burden
for
the
new
information
collection
requirements
associated
with
the
final
rule
in
Exhibit
1.
In
Exhibit
3,
EPA
tallies
respondents'
incremental
burden
under
the
rule
and
their
burden
savings
for
no
longer
complying
with
existing
RCRA
information
collection
requirements,
in
order
to
derive
net
impacts.

Exhibit
3
shows
that
the
burden
under
the
final
rule
is
estimated
to
be
5,419
hours
and
$
269,099
annually.
EPA
estimates
that
the
burden
savings
under
existing
program
requirements
will
be
22,725
hours
and
$
1,147,133
per
year.
Thus,
the
net
burden
savings
under
the
rule
is
estimated
to
be
17,306
hours
and
$
878,034
per
year.
The
three­
year
bottom­
line
net
burden
is
estimated
to
be
51,918
hours
and
$
2.63
million.

(
2)
Agency
Tally
Exhibit
2
summarizes
the
total
annual
Agency
hour
and
cost
burden
associated
with
all
the
requirements
covered
in
this
ICR.
As
shown
in
the
exhibit,
EPA
estimates
the
annual
Agency
burden
to
be
371
hours,
at
an
annual
cost
of
$
11,173.
The
bottom
line
burden
to
the
Agency
over
three
years
is
1,113
hours,
at
a
cost
of
$
33,519.
17
6(
f)
Reasons
for
Change
In
Burden
EPA
believes
the
labeling
requirement
is
necessary
to
alert
anyone
handling
the
containers
with
the
used,
broken
CRTs
of
what
is
enclosed
in
the
container
so
that
proper
handling
(
or
inspection)
may
occur.
EPA
also
believes
the
notification
requirements
are
necessary
to
assist
the
Agency
in
identifying
and
tracking
exporters
of
used
CRTs.
As
shown
in
the
exhibits,
EPA
estimates
that
the
labeling
and
notification
requirements
will
impose
a
minor
burden
on
generators
of
excluded
CRTs.
This
burden
is
greatly
offset
by
the
savings
that
generators
and
subsequent
handlers
will
see
in
no
longer
managing
their
excluded
CRTs
under
existing
information
collection
requirements.

6(
g)
Public
Burden
Statement
The
public
reporting
burden
associated
with
the
new
requirements
is
estimated
to
range
between
3.40
and
4.10
hours
per
respondent
per
year.
This
burden
includes
time
for
preparing
and
submitting
export
notifications,
and
providing
additional
notification
information
upon
EPA's
request.
The
public
recordkeeping
burden
associated
with
the
new
requirements
is
estimated
to
range
between
3.60
and
3.70
hours
per
respondent
per
year.
This
burden
includes
time
for
reading
the
regulations,
labeling
containers
of
used
CRTs,
and
keeping
copies
of
CRT
documentation,
as
specified.

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
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
RCRA
2004­
0010,
which
is
available
for
public
viewing
at
the
RCRA
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
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
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
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.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
18
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
RCRA
2004­
0010.
19
EXHIBIT
1
Hours
and
Costs
per
Respondent
Legal
Managerial
Technical
Workman
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
126.19/
Hr
$
120.15/
Hr
$
65.94/
Hr
$
30.08/
Hr
$
47.05/
Hr
Read
the
regulations
0.00
0.50
0.50
0.00
0.00
1.00
$
93.05
$
0.00
$
0.00
1,258
1,258
$
117,057
Label
or
mark
clearly
each
container,
as
specified
0.00
0.00
0.00
0.10
0.00
0.10
$
3.01
$
0.00
$
0.00
32,423
3,242
$
97,593
Prepare
and
submit
written
notification
0.00
0.10
1.80
0.00
1.50
3.40
$
201.28
$
0.00
$
0.38
256
870
$
51,625
Prepare
and
submit
additional
information
that
a
receiving
country
requests
in
order
to
respond
to
a
notification
0.00
0.10
0.50
0.00
0.10
0.70
$
49.69
$
0.00
$
0.38
26
18
$
1,302
Keep
copies
of
notifications
and
consents
0.00
0.00
0.00
0.00
0.10
0.10
$
4.71
$
0.00
$
0.00
256
26
$
1,206
Subtotal
0.00
varies
varies
varies
varies
varies
varies
varies
varies
varies
914
$
54,133
Prepare
and
submit
a
one­
time
notification
0.00
0.10
0.50
0.00
0.10
0.70
$
49.69
$
0.00
$
0.38
5
4
$
250
Keep
copies
of
normal
business
records
(
e.
g.,
contracts)

demonstrating
that
each
shipment
of
exported
CRTs
will
be
reused
0.00
0.00
0.00
0.00
0.10
0.10
$
4.71
$
0.00
$
0.00
14
1
$
66
Subtotal
0.00
varies
varies
varies
varies
varies
varies
varies
varies
varies
5
$
316
TOTAL
0.00
varies
varies
varies
varies
varies
varies
varies
varies
varies
5,419
$
269,099
CONDITIONAL
EXCLUSION
FOR
USED
CATHODE
RAY
TUBES
Total
Hours
and
Costs
Labels
Number
of
Respondents
or
Containers
Total
Hours/

Year
Total
Cost/

Year
Respon.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Reading
the
Regulations
O&
M
Cost
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Export
Notification
for
Used
CRTs
Destined
for
Recycling
20
EXHIBIT
2
Hours
and
Costs
per
Respondent
Legal
Managerial
Technical
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
66.256/
Hr
$
47.664/
Hr
$
33.44/
Hr
$
20.336/
Hr
Receive
and
review
notification
submitted
by
an
exporter
of
used
CRTs
to
determine
whether
or
not
the
notification
is
complete
0.00
0.00
1.00
0.00
1.00
$
33.44
$
0.00
$
0.00
256
256
$
8,561
Solicit,
from
exporter,
additional
information
requested
by
the
receiving
country
0.00
0.00
0.50
0.10
0.60
$
18.75
$
0.00
$
0.38
26
16
$
497
Provide,
in
conjunction
with
the
Department
of
State,
the
complete
notification
to
the
receiving
country
0.00
0.00
0.00
0.16
0.16
$
3.25
$
0.00
$
0.38
256
41
$
929
Forward
the
receiving/
transit
country's
written
consent
to
the
receipt
of
the
used
CRTs
to
the
exporter
0.00
0.00
0.00
0.16
0.16
$
3.25
$
0.00
$
0.38
0
0
$
0
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
0.00
0.00
0.50
0.10
0.60
$
18.75
$
0.00
$
0.38
0
0
$
0
Keep
copies
of
notifications,
consents,
and
other
related
documents
0.00
0.00
0.00
0.10
0.10
$
2.03
$
0.00
$
0.00
538
54
$
1,092
Subtotal
0.00
varies
varies
varies
varies
varies
varies
varies
varies
367
$
11,079
Receive
and
review
notification
submitted
by
exporter
of
used
CRTs
0.00
0.00
0.50
0.00
0.50
$
16.72
$
0.00
$
0.00
5
3
$
84
Keep
copy
of
notification
0.00
0.00
0.00
0.10
0.10
$
2.03
$
0.00
$
0.00
5
1
$
10
Subtotal
0.00
0.00
0.50
0.10
0.60
$
18.75
$
0.00
$
0.00
5
4
$
94
TOTAL
0.00
varies
varies
varies
varies
varies
varies
varies
varies
371
$
11,173
Export
Notification
for
Used
CRTs
Destined
for
Reuse
Total
Hours
and
Costs
Agency
Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
O&
M
Cost
Number
of
Agency
Activities
Total
Hours/

Year
ESTIMATED
ANNUAL
AGENCY
HOUR
AND
COST
BURDEN
Total
Cost/

Year
CONDITIONAL
EXCLUSION
FOR
USED
CATHODE
RAY
TUBES
Export
Notification
for
Used
CRTs
Destined
for
Recycling
21
EXHIBIT
3
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
SUMMARY
a
(
INCLUDING
SAVINGS
IN
PAPERWORK
BURDEN
IN
EXISTING
ICRs)

CRT
Recycling
[
ADD
#]
5,419
$
268,990
$
0
$
109
$
269,099
Manifest
801
(
17,022)
($
786,241)
$
0
($
7,216)
($
793,457)

Generator
Standards
820
(
3,421)
($
285,894)
$
0
($
43)
($
285,937)

Biennial
Report
976
(
2,074)
($
59,706)
$
0
($
278)
($
59,986)

Land
Disposal
Restrictions
1442
(
208)
($
7,579)
$
0
($
174)
($
7,753)

Subtotal
N/
A
(
22,725)
($
1,139,420)
$
0
($
7,711)
($
1,147,133)

TOTAL
N/
A
(
17,306)
($
870,430)
$
0
($
7,602)
($
878,034)

a
Exhibit
contains
rounding
error.

Existing
Paperwork
Requirements
Capital
Cost/
Year
O&
M
Cost/
Year
Total
Cost/
Year
New
Paperwork
Requirements
ICR
Name
ICR
Number
Hours/
Year
Labor
Cost/
Year
