                                       
                                       
                                       
                                       
           Economic Impacts Assessment for Proposed Revisions to the
             Export Provisions of the Cathode Ray Tube (CRT) Rule
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                 Office of Resource Conservation and Recovery
                 Office of Solid Waste and Emergency Response
                     U.S. Environmental Protection Agency
                                       
                                 November 2011
                                       

                               EXECUTIVE SUMMARY
                                       
      The Environmental Protection Agency (EPA or the Agency) is proposing to revise the export  provisions of the Cathode Ray Tube (CRT) final rule published on July 28, 2006 (71 FR 42928).  The purpose of these proposed revisions is to address certain implementation concerns with the current export provisions of the rule.  These changes will facilitate compliance with the requirements and will enable the Agency to obtain additional information on the export of this class of used electronics.    The proposed rule would affect only the export provisions of the CRT rule.  It would not affect any requirements applicable to domestic management of used CRTs.   Nor does this proposed action affect households or conditionally exempt small quantity generators (CESQGs).  Therefore, entities potentially affected by today's action are limited to those persons or companies who export used CRTs and CRT glass for reuse or recycling.  
      EPA is proposing to add a definition of "CRT exporter" to the CRT rule.  This proposed definition will clarify the responsibilities of brokers and other intermediaries in fulfilling the export notice requirements.  EPA is also proposing to revise the notifications that must be submitted to EPA when CRTs are exported for reuse or recycling, and to require annual reports from exporters of CRTs for recycling.  This document assesses the potential economic impacts of the proposed CRT Rule revisions.
Summary of Results
      Given the minor changes being imposed by this rule, the results of our cost assessment reveal very modest cost impacts. 
1)  All exporters of CRTs (regardless of whether they are sending CRTs for Recycling or Reuse), will face a new one-time up-front cost to familiarize themselves with the proposed CRT rule revisions.  This one-time cost is expected to be incurred by 138 CRT exporters.  The total cost of this provision equals approximately $39,000 in the first year following promulgation of the rule.

2)   Exporters of CRTs sent for recycling will face a new requirement to produce and submit an Annual Report regarding their actual recycling exports.   However, because the new proposed requirement is expected to result in only 12 new reports each year, the total costs to exporters and EPA are very low and equal a total of approximately $2,500 per year.  

3)  Added to these costs are additional annual costs to all 138 CRT Exporters ranging from $2,386 to $4,453 for adhering to the additional information requirements proposed for both of the current Recycling & Reuse Notices.  These costs, in combination with the added costs for EPA's review of these notices (estimated to be between $2,449 and $4,572), brings the total annual cost for this feature of the proposed rule to a range of approximately $4,835 to $9,025.

      In conclusion, the total estimated cost impacts from this rule are estimated to be $39,000 in year one only, plus annual costs in the range of $7,300 to $11,500 starting in year one and continuing each year thereafter.  

                                       
                               TABLE OF CONTENTS

INTRODUCTION
       1.1 	Background on Existing Cathode Ray Tube (CRT) Rule
      1.2   	Need for Proposed Regulatory Action
       
       2.0	OVERVIEW OF PROPOSED REGULATORY REQUIREMENTS
       2.1	Definition of "CRT Exporter"
       2.2	Proposed Rule Changes Specific to the "Export of CRTs for Recycling"
            2.2.1	New Annual Report Required from Exporters of CRTs Sent for Recycling
      2.2.2	Additional Destination Data Requested as Part of the Recycling Notice
      2.3	Proposed Changes Specific to the "Export of CRTs for Reuse"
            2.3.1	Proposed Changes to Notification Requirements
       
 3.0	METHODOLOGY AND ASSUMPTIONS
       3.1   Estimated Number of Potentially Impacted CRT Exporters
       3.2   Labor Rate Estimates and Assumptions
       3.3   Burden Hour Estimates and Assumptions
       3.4   Material Cost Estimates and Assumptions
 
 4.0	ASSESSMENT OF POTENTIAL COSTS
 
       4.1   Estimated Costs for Reading the Rule
       4.2   Estimated Costs for New Annual Reporting by CRT Export Recyclers
       4.3   Estimated Costs for Additional Reuse and Recycling Notification Requirements
      4.4   Total Cost Impact of the Proposed CRT Rule Revisions 
 
 5.0	QUALITATIVE DISCUSSION OF BENEFITS
       

   A. ATTACHMENTS   Supporting Documentation For Assessment of Costs
   1.0 INTRODUCTION
    
      1.1  	Background on Existing Cathode Ray Tube (CRT) Rule

      The Agency promulgated the CRT rule on July 28, 2006 (71 FR 42928).   In that rule, EPA amended its regulations under the Resource Conservation and Recovery Act (RCRA) to streamline management requirements for used CRTs and glass removed from CRTs, with the intent of encouraging their recycling and reuse.  Under 40 CFR 261.39, these materials are excluded from the definition of solid waste if certain conditions are met. Used CRTs (intact or broken) sent for reuse and recycling are subject to the speculative accumulation requirements of 261.1(c)(8).   Used, broken CRTs sent for recycling are subject to packaging and labeling requirements, as are CRT glass processors.  CRT glass processors are also subject to speculative accumulation requirements and may not use temperatures high enough to volatilize lead.
      In addition to these domestic requirements, the CRT rule also contains requirements at 40 CFR  261.39(a)(5)  for used CRTs exported for recycling. Exporters of used CRTs for recycling must notify EPA of an intended shipment 60 days before the shipment. Notifications may cover exports extending over a 12-month or shorter period. The notification must include contact information about the exporter and recycler, and an alternate recycler. It must also include a description of the recycling, frequency and rate of export, means of transport, total quantity of CRTs, and information about transit countries.
      With respect to used intact CRTs that are exported for reuse, 40 CFR 261.41 requires exporters to submit a one-time notification to EPA with contact information and a statement that they are exporting the CRTs for reuse. They must keep copies of normal business records demonstrating that each shipment will be reused. Records must be retained for three years from the date of export. 
      1.2	Need for Proposed Regulatory Action
      Since promulgation of the CRT rule in 2006, exports of CRTs and CRT glass have continued, whether for reuse or recycling.  As EPA implemented the rule, two principal concerns became apparent. The first was that when CRTs and CRT glass are exported for recycling or reuse, several parties may be involved in the transaction. This multi-party involvement has sometimes led to confusion about which party is responsible for fulfilling the export notice requirements.  The second concern involves CRTs that are ostensibly exported for reuse but that are actually disassembled and recycled when they reach the receiving country, sometimes under unsafe conditions.  To address these concerns, EPA is proposing minor changes to the current CRT Rule as described in Section 2.0 below. 
                                       


2.0	OVERVIEW OF PROPOSED REGULATORY REQUIREMENTS
	2.1	Definition of "CRT Exporter" (applicable to both CRTs for Reuse or Recycling) 
      When CRTs are exported for recycling or reuse, there are often several parties involved and this can cause considerable confusion over exactly who must file the export notices required under 40 CFR 261.39(a)(5)(for CRTs exported for recycling) and 40 CFR 261.41(for CRTs exported for reuse). To reduce this confusion, the Agency is proposing to add a definition of "CRT exporter" to 40 CFR 260.10, which states that a CRT exporter is "any person who decides that CRTs will be sent outside the United States or its territories for recycling or reuse (including reuse after refurbishment in the receiving country), and any intermediary arranging for the export".  The reference to "any intermediary arranging for the export" is modeled on the definition of "primary exporter" of hazardous waste in 40 CFR 260.10.  As described above, there may be multiple parties who participate in the exporting of CRTs.  To avoid duplicative submissions, the Agency expects only one party to perform the exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41   Lastly, EPA emphasizes that this proposed definition would clarify rather than change current liability for violations of the CRT export requirements.    [Note: EPA considers there to be no economic costs associated with this definitional change.]
      2.2	Proposed Rule Changes Specific to the "Export of CRTs for Recycling"
      Under the provisions of this proposed rule, parties that "Export CRTs for purposes of Recycling" shall face the following additional requirements.
      
		2.2.1	New Annual Report Required from Exporters of CRTs Sent for Recycling
	Per the existing CRT Rule, parties that export CRTs for recycling currently have notification requirements regarding their projected exports, but are not required to submit any retrospective documentation regarding the amount of their actual exports in a given year.  To help ensure that CRTs exported for recycling are handled as commodities and not otherwise discarded, EPA is proposing that such parties submit Annual Reports of their exports.  [Note: This annual report requirement has been modeled after the annual reporting requirement for exporters of spent lead-acid batteries under 40 CFR 262 Subpart E (See cited reference in Footnote 1 on page 7).] 
      2.2.2	Additional Destination Data Requested as Part of the Recycling Notice
      Per the current CRT Rule (40 CFR 261.39(a)(5)(F), exporters of CRTs sent for recycling are required to state the name and address of the recycler and any alternate recycler.  Because CRTs are sometimes exported to more than one recycler in the receiving country, EPA is proposing to require that the exporter state the name and address of the recycler or recyclers and the estimated quantity of CRTs to be sent to each facility, as well as the names of any alternate recyclers.  In this way EPA will be able to provide the receiving country with the most accurate information available about the ultimate fate of the CRTs when they reach that country.
      2.3	Proposed Changes Specific to the "Export of CRTs for Reuse"
      Under the provisions of this proposed rule, parties that "Export CRTs for Reuse" shall face the following additional requirements.
      2.3.1	Proposed Changes to Notification Requirements 
      Per the current CRT Rule, exporters of CRTs sent for reuse are already required to submit a one-time notice to EPA with minimal information under 40 CFR 261.41.   Since original promulgation of this requirement, the Agency has become aware that some CRTs, ostensibly exported for reuse, are actually recycled in the receiving country, sometimes under unsafe conditions.  EPA is proposing to expand the current reuse notice to provide more complete information about the potential reuse of the exported CRTs.  The added items to the reuse notice are modeled on those required in the notice for CRTs exported for recycling, and will help the Agency determine whether exported CRTs are actually products which are ultimately sent for reuse.   [Note: For more detail on the additional data elements that are being proposed for the CRT Reuse Notice, please see the appropriate section of the preamble for the Proposed Rule.]
[Note:  The Agency expects only one party to perform the exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41 (notifications to EPA, and the annual reports as proposed and described above).]
       
3.0	METHODOLOGY AND ASSUMPTIONS
      Described below are the key data and assumptions underlying the cost analyses conducted for this rule.  
	In assessing the cost impacts, we estimated the incremental annual costs of this proposed rule to U.S. exporters and to EPA.  In estimating these costs, EPA first reviewed the provisions under the existing regulations and under the proposed rule to determine what new requirements were being proposed in this rule.  We estimated the costs of these new requirements using the following inputs:
         * Number of affected entities 
         * Hourly labor rates
         * Burden hours
         * Materials costs
         * Number of Annual Reuse/Recycling Notifications

	Section 3.1 describes the sources used in identifying the "number of entities" involved in the exporting of CRTs who will be directly affected by the proposed rule changes.  Section 3.2 describes the "hourly labor rates" that are used in our calculations.  Section 3.3 describes the "burden hours" (e.g. staff hours) assumptions that EPA utilized in its analysis.  Section 3.4 outlines the "material" costs that EPA envisions may be incurred in association with the proposed CRT Rule revisions.  Lastly, Section 3.5 details the total "number of reuse and recycling notices" the EPA projects will be submitted per year.
      
      3.1	Estimated Number of Potentially Impacted CRT Exporters
      
      The Agency estimates that a total of approximately 12 entities exported CRTs for recycling during 2011 (i.e., per EPA data on the number of approved exporters and the number of export notices that were submitted during 2011).  However, far more entities are on record as being exporters of CRTs for purposes of reuse.   Based on the number of CRT Reuse Notifications submitted during 2011, there exists approximately 126 such entities in the U.S. (i.e., according to data from Sept. 14[th], 2011 published on EPA's CRT informational website at 
[ http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm ]).


	3.2	Labor Rate Estimates and Assumptions

      Exhibit 3-1 presents the hourly labor rates used in this analysis.  As shown in the exhibit, for U.S. exporters, EPA estimated an average hourly labor rate (including fringe and overhead) of $103.84 for managerial staff, $64.71 for technical staff, and $33.85 for clerical staff.  These labor rates were originally obtained by relying on prior EPA Cost Assessments and then updated to 2011 using Employment Cost Indices developed by the U.S. Bureau of Labor Statistics. 
      For EPA's involvement and review/approval responsibilities, we estimated an average hourly labor rate of $74.67 for managerial staff (GS-14, Step 1), $63.20 for technical staff (GS-13, Step 1), and $36.64 for clerical staff (GS-9, Step 1).  To derive these hourly estimates, we referred to the General Schedule (GS) Salary Table 2011.  This publication summarizes the unloaded (base) hourly rate for various labor categories in the Federal Government.  We then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly labor rates.
      
                                  Exhibit 3-1
    Average Hourly Labor Rates Used to Assess the Cost Impacts of the Rule
                                Labor Category
                                   Exporters
                                (2011 dollars)
                                      EPA
                                (2011 dollars)
                                       
                                  Managerial
                                       
                                    $107.06
                                       
                                    $74.67
                                       
                                   Technical
                                       
                                    $70.08
                                       
                                    $63.20
                                       
                                   Clerical
                                       
                                    $36.60
                                       
                                    $36.64

      3.3	 Burden Hour Estimates and Assumptions
      As with other components of the methodology underlying our analyses, to estimate the total number of hours ("burden hours") required to meet the annual notification and reporting requirements of this rule, EPA relied heavily upon previous cost analyses conducted for the 2009 SLAB Rule (See Footnote 1).  Since the proposed CRT annual reporting and notification requirements are virtually the same as those called for in the Agency's 2009 SLAB rule, we used the same burden hour estimates in our cost assumptions for this proposal.  
      3.4	Materials Cost Estimates and Assumptions 
      Minimal material costs were assumed to be associated with the production and submission of new Annual Reports and Notification requirements proposed for this revision of the CRT Rule.  These costs are described below:
      * Mailing costs: The Agency estimated that affected entities would incur a cost of approximately $5.20 to mail a five ounce package by certified mail ($2.20 for postage, $2.85 for the certified mail fee, and $0.15 for a 9 x 12 manila envelope). 

         Affected entities are expected to incur a cost of $0.49 for each standard letter mailed ($0.44 for first class postage and $0.05 for a standard envelope).   

      * Copying Costs:  The agency estimated that affected entities would incur a cost of $0.11 per page for copying.  
         
      * Faxing costs: The Agency estimated that affected entities would incur a cost of $0.15 for each international fax they send.  This cost was derived from the average revenues per minute for a telephone call from the U.S. to an OECD Country (excluding Canada and Mexico).  Revenue figures were obtained from the 2005 International Telecommunications Data Report issued by the Federal Communications Commission on April 24, 2007.  The cost estimate assumes that the fax transmission will take one-minute. 

        
      * Domestic telephone call costs: The Agency estimates that affected entities will incur a cost of $0.90 for each domestic telephone call they make.  This cost was derived by averaging the advertised rates of a 15-minute State-to-State telephone call from four large U.S. long distance carriers. 

      3.5	Notification Estimates and Assumptions 
      The number of export notifications used in our cost assessment was based on EPA's professional experience, in combination with historical records associated with the submission of reuse/recycling notices by CRT exporters.  
      In EPA's experience, most CRT recyclers seldom have cause to submit more than 1 notice per year.   The number of Recycling Notices has never exceeded 60% of the number of Recycling Exporters themselves.  This means that the ratio of Recycling Notices to CRT Recycling Exporters is less than 2 to 1.  So, while the number of notices may increase subsequent to the proposed rule, EPA assumed for the purposes of this analyses that each CRT recycler would submit only 1 to 2 notices annually.  Accordingly, this results in approximately 12 to 24 Notices being submitted per year for this category of exporters.
      Exporters that send CRTs abroad for purposes of reuse tend to have a broader list of potential destinations for their CRTs.  For instance, one reuse exporter may ship their CRTs to schools, charitable organizations, and resale facilities, or any combination thereof.  Therefore, for purposes of this analysis, EPA made the following assumptions:
      * 75% of reuse exporters (95) would submit 2-4 reuse notifications per year; and 
      * 25% of reuse exporters (31) would submit 1 reuse notification per year.  

      When added together with the projected recycling notices, the total estimated number of notices ranges from as low as 233 to as many as 435.  

 4.0	ASSESSMENT OF POTENTIAL COSTS

      Discussed below is the Agency's best projection of the costs associated with this proposed rule. Since the subject provisions currently being proposed apply only to the export of CRTs , U.S. importers will not experience any costs from these revisions. 
      4.1	Estimated Costs for Reading the Rule
      
      As noted above, the Agency estimates that during 2011a total of approximately 12 entities exported CRTs for recycling and 126 entities exported CRTs for reuse.  Therefore, we estimated that 138 U.S. exporters will need to read the rule in order to understand and comply with the new requirements.  For purposes of this analysis, we assumed that the hours required for reading/reviewing this new rule would be similar to the hours used in EPA's assessment of the impacts associated with reading/reviewing the 2009 SLAB rule.  The one-time cost for of reading/reviewing this new rule was then estimated to be $282.26.  (See Exhibit A-1in Attachment A).   Thus, U.S. exporters may experience a one-time cost of approximately $38,952 (i.e., 138 entities x $282.26/entity) for this activity. 
      4.2	Estimated Costs for New Annual Reporting by CRT Export Recyclers
      
      Under this proposed rule, U.S. entities who export CRTs for the purpose of recycling must now submit detailed annual reports on their CRT exports to EPA. This annual reporting is in addition to the current notice requirements and represents a new requirement for CRT Recycling Exporters not called for in the current CRT Rule.  The following paragraphs discuss the estimated costs associated with this newly required annual report. 
      
U.S. Exporters 
      As noted above, EPA estimates that approximately 12 U.S. exporters of CRTs sent for recycling will be required to prepare and submit an annual report in accordance with this provision of the proposed rule.  Furthermore, this new annual report for CRT Export Recyclers has been fashioned after other existing annual reporting requirements recently codified in the 2009 Final Rule governing the Exporting of Spent Lead-Acid Batteries (SLAB) from the U.S.  Therefore, EPA used the cost estimates for annual reporting already available in the May 2009 Cost Assessment prepared for the "SLAB Rule", as the best and most recent relevant reference (See Footnote 1).  Based on these figures, EPA estimates that the cost for a CRT Exporter to prepare and submit an annual report ranges from $ $156.07 to $203.36, depending upon whether the size of the exporter is large vs. small.  For purposes of analysis, EPA assumed a 50/50 distribution of these exporters (e.g. with half considered large and half considered small).  Thus, EPA estimated that the total cost of the annual reporting requirement for  exporting  CRTs for recycling is  $2,158.32 (i.e.,$203.36/ annual report x 6 Large Recycling Exporters, plus $156.07 / annual report x 6 Small Recycling Exporters)  (See Exhibit A-2 in Attachment A). 
      
EPA 
      EPA estimates that it will receive 12 annual reports per year.  EPA estimates that it will incur $24.64 to receive and record each annual report (See Exhibit A-2 in Attachment A). Thus, EPA estimates that the Agency will experience an annual cost of $295.68 (i.e., 12 annual reports/year x $24.64/report) to meet this requirement of the proposed rule. 
      In total, the estimated costs to CRT Exporters and the EPA for the new annual reporting requirement for recyclers are $2,454 per year (See Exhibit A-2 in Attachment A).  
      

      
      4.3	Estimated Costs for Additional Reuse and Recycling Notification Requirements

      Under the current CRT Rule, exporters already must submit notifications to EPA indicating their intent to export CRTs.   As noted above, the proposed CRT Rule revisions call for very minor additional reporting elements to the current CRT rule requirements.  The following paragraphs discuss the estimated costs associated with these added notification elements. 
      
U.S. Exporters 
      To calculate the notification-related cost impacts, EPA started by relying on the original burden hour estimates associated with the current notification requirements.  EPA then adjusted these burden hour estimates to reflect our best estimate of the potential burden associated with the proposed changes in the notification requirements.  Our best estimate is that these burden estimates would not exceed 10% of the burden attributable to the current notification requirements.  Then EPA utilized the adjusted burden estimates and labor rates in combination with the projected quantity of CRT Notices to derive costs associated with the relevant proposed changes to the CRT notification process. 
      Based on the calculations above, EPA estimated that CRT exporters submit between 233 and 435 notices each year.  We estimated that each notice will cost an additional $10.26 (See Exhibit A-3 in Attachment A).  In total, EPA estimates that the additional costs to Exporters will be in the range of $2,386 to $4,453 (i.e., 233 to 435 notices per year x $10.26 per notice) under the proposed rule. 
EPA 
      We estimate that EPA will incur an additional cost of $10.51 per notice to receive and process these notices (See Exhibit A-3 in Attachment A). Thus, we estimate that the Agency will experience a total incremental annual cost in the range of $2,449 to $4,572 (i.e., 233 to 435 notices per year x $10.51 per notice) under the proposed rule. 
      In total, the estimated costs to CRT Exporters and the EPA for meeting the proposed reuse and recycling notification changes are $4,835 to $9,025 per year (See Exhibit A-3 in Attachment A).  
      4.4	Total Cost Impact of the Proposed CRT Rule Revisions 
      
      In total, EPA estimates that the costs of the proposed CRT Rule revisions include approximately $39,000 in year one of the Rule, as well as annual costs in the range of $7,300 to $11,500 in year one and beyond.  Based on the methodology and cost calculations described above in Sections 3.0 and 4.0, the results of our cost assessment reveal very modest cost impacts.   Furthermore, many of the assumptions used in the analyses could be characterized as "conservative" assumptions, resulting in cost estimates that may be higher than those that would actually be incurred.  

 
 
 5.0	QUALITATIVE DISCUSSION OF BENEFITS
                                       
      Promulgation of this rule will engender  benefits, both internal and external to the U.S., including: (1) increased regulatory efficiency; (2) reduced storage cost for hazardous wastes destined for recovery; (3) reduction of risks associated with treatment and disposal of hazardous wastes; (4) improved ability to acquire information regarding the quantities of CRTs exported from the U.S. and the destination facilities to which the CRTs are exported; (5) better tracking of returns and compliance with exception reporting requirements; and (6) better tracking of compliance with the terms of CRT export notices. 
      More specifically, the proposed CRT Rule Revisions will help determine that CRTs exported for recycling are handled as commodities and not inappropriately discarded.  Such annual reports and notification enhancements improve the accuracy of our records and allow for proper documentation of the total amount of CRTs being exported for recycling and reuse.  The improved data that is collected will also enable EPA to compare actual vs. proposed shipments to ensure that the shipments occurred under the terms approved by the receiving country.  Finally, such data will enable EPA to provide summary information, if requested by a receiving country, which would assist the receiving country in better management of their CRTs imports. 
      In conclusion, while these benefits have not been expressly quantified as part of this Economic Assessment, the resultant improvements in information provision/transparency and CRT management practices from this Rule are believed to have benefits that outweigh the costs.  


                                 ATTACHMENT A
                                       
                           SUPPORTING DOCUMENTATION
                            FOR ASSESSMENT OF COSTS
                                       
                                       


                                       
                                       
                                  Exhibit A-1
                          Costs for Reading the Rule

                                       
                                Cost per Entity
                             Cost of All Entities
                                   Activity
                          Managerial Staff Hours [a]
                           Technical Staff Hours [a]
                           Clerical Staff Hours [a]
                                     Hours
                               Labor   Cost [b]
                              Materials Cost [c]
                             Total Cost per Entity
                            Number of Entities [d]
                                  Total Cost 
Reading the Regulations 
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
U.S. Exporters
                                     1.00
                                     2.50
                                     0.00
                                     3.50
                                    $282.26
                                     $0.00
                                    $282.26
                                      138
                                       
                                    $38,952
                                                                               
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[NOTES:]
[a]   Based on hourly burden estimates discussed in Section 3.3 above.  
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[b]   Based on hourly labor rates discussed in Section 3.2 above.
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[c]   Based on materials costs discussed in Section 3.4 above.
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[d]   Based on universe assumptions discussed in Section 3.1 above.
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               


                                       
                                  Exhibit A-2
       Costs for New Annual Reporting by Exporters of CRTs for Recycling
                                       
                                Cost per Entity
                             Cost for all Entities
                                   Activity
                          Managerial Staff Hours [a]
                           Technical Staff Hours [a]
                           Clerical Staff Hours [a] 
                                 Total Hours 
                             Total Labor Cost [b]
                               Material Cost [c]
                                Total      Cost
                             Number of Entities d
                                  Total Cost 
Annual Report
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
Large U.S. Exporters
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Research specific export information
                                     0.00
                                     1.00
                                     1.00
                                     2.00
                                    $106.68
                                     $0.00
                                    $106.68
                                       6
                                    $640.08
Prepare and submit report
                                     0.10
                                     1.00
                                     0.30
                                     1.40
                                    $91.77
                                     $5.20
                                    $96.97
                                       6
                                    $581.82
                                                                      Subtotal:
                                       
                                       
                                       
                                       
                                    $198.45
                                     $5.20
                                    $203.65
                                       
                                       
6
                                   $1,221.90
Small U.S. Exporters
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Research specific export information
                                     0.00
                                     0.50
                                     0.50
                                     1.00
                                    $70.08
                                     $0.00
                                    $70.08
                                       6
                                    $420.48
Prepare and submit report
                                     0.10
                                     0.50
                                     0.50
                                     1.10
                                    $80.79
                                     $5.20
                                    $85.99
                                       6
                                    $515.94
                                                                      Subtotal:
                                       
                                       
                                       
                                       
                                    $150.87
                                     $5.20
                                    $156.07
                                       6
                                    $936.42
                                                           Total for Exporters:
                                       
                                       
                                       
                                       



                                       
                                   $2,158.32
EPA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Receive and record report
                                     0.00
                                     0.10
                                     0.50
                                     0.60
                                    $24.64
                                     $0.00
                                    $24.64
                                      12
                                    $295.68
                                                                 Total for EPA:
                                     0.00
                                     0.10
                                     0.50
                                     0.60
                                    $24.64
                                     $0.00
                                    $24.64
                                      12
                                    $295.68
                                    TOTAL:
                        (for both Exporters & EPA)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    $2,454
[NOTES:]
[a]   Based on hourly burden estimates discussed in Section 3.3 above.  
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[b]   Based on hourly labor rates discussed in Section 3.2 above.
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[c]   Based on material costs discussed in Section 3.4 above.

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[d]   Based on universe assumptions discussed in Section 3.1 above, which reveal a total of approximately 12 CRT Recycling Exporters in the U.S.  And, we assume there is a 50/50 Percent Ratio regarding the total number of Large vs. Small U.S. CRT Exporters, such that there are  6 of each type in the above calculations.
                                       

                                  Exhibit A-3
     Costs for Meeting Proposed Reuse & Recycling Notification Changes
                  (calling for minor additional information)
                                       
                                Cost per Notice
                                       
                              Cost of All Notices
                                   Activity
                           Manager Staff  Hours [a]
                           Technical Staff Hours [a]
                          Clerical    Staff Hours [a]
                     Total Hours [b] (10% of Orig. Hours)
                      Total         Labor       Cost [c]
                           Total Material Costs [d]
                          Total       Cost per Notice
                         Number       of Entities [e]
                        Estimated Number of Notices [f]
                                  Total Cost 

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
U.S. Exporters
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Prepare & submit notification  Subtotal for Exporters:  
                                     0.00
                                     1.50
                                     0.00
                                     0.15
                                    $10.51
                                     $0.00
                                    $10.51
                                      138
                                 233  to  435
                              $2,449  to  $4,572
                                                                               
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
EPA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Receive and process notification
                                     0.00
                                     1.00
                                     0.00
                                     0.10
                                     $6.32
                                     $0.00
                                     $6.32
                                      138
                                 233  to  435
                              $1,473  to  $2,749
Prepare and transmit confirmation of receipt to U.S. exporter
                                     0.00
                                     0.00
                                     0.25
                                     0.025
                                     $0.92
                                     $0.00
                                     $0.92
                                      138
                                 233  to  435
                                $213  to  $398
Forward notification to the competent authorities of the countries of import and transit 
                                     0.00
                                     0.00
                                     0.16
                                     0.016
                                     $0.59
                                     $0.00
                                     $0.59
                                      138
                                 233  to  435
                                $137  to  $255
Receive and process Acknowledgement of Receipt from the competent authority of the country of import
                                     0.00
                                     0.00
                                     0.25
                                     0.025
                                     $0.92
                                     $0.00
                                     $0.92
                                      138
                                 233  to  435
                                $213  to  $398
Receive and process consent/objection from the competent authorities of the countries of import and transit 
                                     0.00
                                     0.00
                                     0.16
                                     0.016
                                     $0.59
                                     $0.00
                                     $0.59
                                      138
                                 233  to  435
                                $137  to  $255
Forward written Acknowledgement of Consent or objection to U.S. exporter 
                                     0.00
                                     0.00
                                     0.25
                                     0.025
                                     $0.92
                                     $0.00
                                     $0.92
                                      138
                                 233  to  435
                                $213  to  $398
                                                              Subtotal for EPA:
                                     0.00
                                     1.00
                                     1.07
                                     0.207
                                    $10.26
                                     $0.00
                                    $10.26
                                      138
                                 233  to  435
                              $2,386  to  $4,453
                                                                               
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                            Total for both Exporters & EPA 
                                     0.00
                                     2.50
                                     1.07
                                     0.357
                                    $20.77
                                     $0.00
                                    $20.77
                                      138
                                 233  to  435
                              $4,835  to  $9,025
Notes:
[a]   Staff level hourly burden estimates are discussed in Section 3.3 above. 
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
[b]   Total final hourly burden estimates are conservatively assumed to only involve an additional burden equal to 10% of the overall  burden from 
the notification requirements under the current CRT Rule.  
[c]   Based on hourly labor rates discussed in Section 3.2 above.
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
d    Since entities are already required to submit Recycling and Reuse Notices, the effected entities face no additional costs associated with mailings, 
copies, facsimiles, etc. due to the newly proposed modifications to the existing notices.
[e]  The projections for the total number of entities potentially impacted by the rule are discussed in Section 3.1 above.

[f]   The projections for the total number of notifications that may be submitted annually is discussed in Section 3.5 above.

