ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Burden

To update the respondent burden for this ICR, the hourly burdens and the total number of respondents for each requirement were reviewed using a number of data and information sources and consultations with regulated entities.  The level of effort remains the same as the previous ICR, as respondent tasks have not changed.  In a number of cases, however, EPA has revised the total number of respondents or the total amount of equipment that must be tracked based on more recent information.

One data source used to revise this Consolidated ICR was Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors (U.S. EPA, 2004b).  This document includes estimates of PCB transformers and capacitors based on recent discussions with industry stakeholders.  Other data sources include EPA’s most up-to-date PADS database, the PCB annual report, and the EPA PCB website, which contain data about entities that generate, store, transport, dispose, research, and smelt PCB wastes and equipment (U.S. EPA, 2006, 2005a, 2005b, 2005c, 2004a, 2004b).  EPA PCB Regional Coordinators were also contacted to obtain information about the number of notifications that were submitted to the Agency over the past few years.  The number of notifications EPA Headquarters received was also tallied.

New hourly wage rates were included for managerial, professional and technical (e.g., engineers), and clerical staff.  Wages for these categories were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) data for private industry (BLS, 2006).  The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken from the same ECEC series.  An additional loading factor of 17 percent is applied to wages to account for overhead.  This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses (Rice, 2002).  This overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loaded wage. Fully loaded costs for managerial, profession/technical, and clerical labor are calculated as shown in Table 6-1.

Burden summary.  The total estimated time for respondents to comply with the reporting, third-party reporting, and recordkeeping requirements of this Consolidated ICR is 696,055 hours.  The annual burden associated with respondents complying with the reporting requirements of this Consolidated ICR is estimated to average 153,279 hours industry-wide.  The total third-party reporting burden is estimated to average 16,829 hours, industry-wide, and the total recordkeeping burden of this Consolidated ICR is estimated to average 525,947 hours, industry-wide.  The average hourly estimates and total number of respondents for each reporting, third-party reporting, and recordkeeping burden are explained on Tables 6-2 to 6-4, respectively.  Note that the burdens associated with requirement numbers 1, 2, 4, 6, 11, 19, 20, 26, 28-30, 32, 36, 38, 39, 47, 51, 53-55, 58, 59, 61, 64, 66, 72, and 73 will either have negligible impacts to the requirements or were costed with other requirements as indicated on the tables, and thus no estimates were included for these requirements.

TABLE 6-1

 DERIVATION OF LOADED RESPONDENT WAGE RATES

Labor Category	BLS Series	Wage

(a)	Fringe Benefit

(b)	Fringes as % wage

(c)=(b)/(a)	Over-head % wage

(d)	Fringe + overhead factor*

(e)=(c)+(d)

+1	Loaded Wages

(f)=(a)* (e)

Managerial	Management, business, and financial	$35.27	$15.34	  =d2/c2*100 \# "0%"  43% 	17%	  =e2+f2+1 \# "0.00"  1.60 	  =c2*g2 \# "$#,##0.00;($#,##0.00)"  $56.43

Professional/

Technical	Professional and related	$30.59	$11.94	  =d3/c3*100 \# "0%"  39% 	17%	  =e3+f3+1 \# "0.00"  1.56 	  =c3*g3 \# "$#,##0.00;($#,##0.00)"  $47.72

Clerical	Office and administrative support	$14.68	$6.93	  =d4/c4*100 \# "0%"  47% 	17%	  =e4+f4+1 \# "0.00"  1.64 	  =c4*g4 \# "$#0.00;($#,##0.00)"  $24.08

Methodology Source: Rice, 2002; Data Source: BLS, 2006.

To simplify the presentation of the numerous hourly burden and cost estimates, the data are arrayed according to reporting, third-party reporting, and recordkeeping requirements for each section of the regulation, consistent with the presentation of the information in the tables of Sections 2 and 5, rather than to rearrange and present the data by respondent type.  EPA anticipates that no one individual would be subject to all of the requirements 40 CFR Part 761.  Refer to Section 4 for a complete description of the activities listed on Tables 6-2 to 6-4.

6(b)	 Estimating Respondent Costs

Tables 6-5, 6-6, and 6-7 show the annual respondent hourly burden and cost estimates for the reporting, third-party reporting, and recordkeeping requirements of the Consolidated ICR.  Refer to Section 6(a), above, for an explanation of the wage rates used, which are as follows:

Managers—$56.43

Professional/technical—$47.72

Clerical—$24.08

There is one capital cost associated with this ICR.  For Item # 68, there is an estimated $50 per site cost to place a sign at a PCB contamination cleanup site.  For 252 sites, the total estimated annual capital cost would be $12,600 (not annualized).  There are no new training costs anticipated to the affected industries or the Federal government associated with responding to the information collections that are subject to renewal, nor have there been any Federal costs associated with printing or mailing.  Costs associated with reading the rules, providing training, and updating procedures to comply with the reporting and recordkeeping requirements are not included in this renewal as no new regulations have been promulgated that involve paperwork burdens.  One-time requirements remain annualized for a 3-year period, as indicated on Tables 6-5 to 6-7.  Because operations and maintenance costs for these information collections (i.e., costs associated with telephone calls, photocopying, and other general office overhead expenses) have been estimated to be relatively low and within the range of the estimation error, there are no added costs for these activities. Also note that variations in some of the totals on the tables are caused by rounding.TABLE 6-2

REPORTING BURDENS UNDER TSCA SECTION 6(e):  ICR 1446.09, SECTION 6(a)

Ref.  #	Regulatory Section(s)  	Collection Requirement 	Time Estimate Total #

Respondents

Per Year	Comments

40 CFR 761

Subpart A—General

1

§761.1(f)(1), (2), and (3)

Submit new reports or modifications to existing reports to qualify for manufacturing/ import exclusions, pursuant to compliance with the reporting requirements of Subpart J.

—

—

Burdens are reported under §§761.185 and §761.187.  See numbers 42 and 43.

Subpart B—Use

2

§§761.20(b) and

 (c)(1) and (3)

Submit an exemption petition as per TSCA Section 6(e)(3) to manufacture (import), process, or distribute in commerce (export) PCBs, unless otherwise authorized.

—

—

Burdens are reported under §§761.80(e) and (i).  See number 34.

3

§761.30(a)(1)(vi)

(A)(1), (xv)(D)

Register PCB Transformers, as appropriate, within 30 days of discovery.

1 hour

351 PCB Transformers

Only requirements for new disclosures are now applicable.  The revised number of disclosures was obtained from the recent analysis conducted for Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors (U.S. EPA, 2004b).  For this report, it was estimated that 1,324,560 transformers are assessed per year. Of these 0.53% (7,020) are PCB Transformers. EPA assumes that 95% (6,669) were disposed and 5% (351) were retained and would need to be reported to the Agency.

4

§§761.30(a)(2) (v)(C) and .30(h)(2)(v)(C)

Obtain EPA approval to use alternate method to reclassify PCB equipment.

20 hours

0 requests

The number of respondents decreased from 38, based on requests received by the Agency over the past few years.

5

§761.30(i)(1)(iii)

(A)(1)

Submit a description of a natural gas pipeline system that contains >50 ppm. PCBs, if requested by EPA.

20 hours

1 systems

EPA expects this to be a rare occurrence.  Only one description was submitted during the past few years, as tallied for this ICR renewal process.

6

§761.30(t)(3)

Obtain approval for the use of PCBs in other gas or liquid systems.

20 hours

0

No respondents anticipated.

7

§761.35(b)

Obtain approval for PCB Articles stored for reuse for >5 years in a facility that does not comply with §761.65(b).

0.166 hour (10 minutes per piece of equipment)

6,250

The approval for the latest 5-year storage period ends in 2008.  The 10-minute time estimate is based on public comment and EPA’s review of 2003 submissions.  During the previous approval period, EPA granted approximately 80 waivers covering 6,250 pieces of equipment; each request averaged about 75 items.  The same time and equipment estimates are used for this ICR.

Subpart D—Storage and Disposal

8

§§761.60(e) and (i)(2); .70(a), (b), and (d); .75(b) (7), (b)(8)(ii), and (c)

Submit permit application and, when applicable, a demo plan for obtaining approval to operate a PCB disposal facility (i.e., alternative method of disposal, incinerator, chemical waste landfill).  Submit requests for approval of R&D for PCB disposal for persons not following self-implementing requirements.

40 applications per year, as follows: 5 new incinerator applications (3,000 hrs to prepare); 15 applications for incinerator modifications and 15 new permit and modification applications for non-thermal (alternate and landfill) facilities (700 hrs to prepare); 15 renewal letters for all technologies, without modifications (8 hours to prepare).  Total number of applicants remains the same, based on the number of applications submitted to the Regions and EPA Headquarters over the past few years.

Revised weighted average burden is about 900 hours average per submission, decreased from 990 hours, based on a higher percentage of renewal applications compared to new applications.  [(3,000 x 5) + (700 x 30) + (8 x 15)]/40.

9

§761.60(j)(1)(i)

Notify EPA to obtain an identification number for conducting R&D on PCB disposal activities.

1.5 hours

5 facilities

The estimated total number of respondents decreased from 25 facilities, based on the number of notifications the Agency has received over the past few years.

10

§761.60(j)(1)(ii)

Notify EPA (as well as State, and local) officials prior to conducting R&D on PCB disposal activities.

6 hours

10 facilities

Burden reported here for both EPA and third-party notification at Table 6-3.  Estimated total number of respondents remained the same, based on the number of notifications the Agency has received over the past few years.

11

§761.60(j)(2)

Submit permit application and, when applicable, a demo plan for obtaining approval to operate a PCB disposal facility (i.e., alternative method of disposal, incinerator, chemical waste landfill).  Submit requests for approval of R&D for PCB disposal for persons not following self-implementing requirements, as per paragraph (j) of this section.

20 hours

0

No respondents anticipated.

12

§§761.61(a)(3)(i) and (ii).

Notify EPA (as well as State, Tribal, and local) officials of self-implementing remediation activity, including a summary of the procedures used to sample contaminated areas and sample collection and analysis data; submit additional information as requested; and certify that records of remediation activity are on file at the location designated in the certificate.

100 hours

58 sites

Number of respondents decreased slightly from 60 sites, based on the number of notifications received by the Agency over the past few years.  Burden is reported here for this requirement and is listed on Table 6-3.

13

§761.61(a)(3)(ii)

Notify EPA of changes to notification of self-implementing activities.

2 hours

13 sites

Number of respondents decreased slightly from 15 sites based on the number of notifications the Agency has received over the past few years.  The hourly estimate is based on the time estimate to prepare other notifications for the self-implementing remediation requirements.

14

§761.61(a)(3)(iii)

Request a waiver of the notification requirement for conducting cleanup of PCB remediation waste.

20 hours

17 sites

Number of respondents increased from 8 sites, based on number of notifications the Agency received over the past few years.

15

§761.61(a)(8)(i)

(B)

Submit certification of recording the deed notation required under paragraph (a)(8)(i)(A) of this section has been recorded.

4 hours

28 sites

Number of sites increased from 10 based on the number of notices the Agency has received in the past few years.

16

§761.61(c)(1)

Apply for risk-based disposal of PCB remediation wastes.  Submit additional information as requested.

1,600 hours

17

Number of respondents has decreased from 25 per year, based on the number of applications the Agency has received in the past few years.

17

§761.62(c)(1)

Obtain approval for risk-based disposal or storage of PCB bulk product waste.  Provide additional information.

1,600 hours

20

Number of respondents increased from 10, due to the increased familiarity with this provision and based on the number of applications the Agency has received in the past few years.

18

 §761.65(a)(2)

Notify of continuing attempts to secure disposal and to request a 1-year storage extension.

3 hours

5 waste storers

Combined for numbers 18, 19, and 20.  Estimated total notifications decreased from 20, based on number of notifications the Agency has received in the past few years.

19

§761.65(a)(3)

Submit request for additional extensions beyond the initial 1-year extension, including justification and information on measures taken to secure disposal.

—

—

See #18, above.

20

§761.65(a)(4)

Submit request for modifications to TSCA approval to allow for extended storage period.

—

—

See # 18, above.

21

§761.65(c)(6)(i)

(C)

Demonstrate that other containers for storage of PCB/radioactive wastes are protective of health and the environment.

40 hours

5

Number of demonstrations remained the same, based on the number conducted over the past few years.

22

§761.65(d); (e)(1), (6), and (8); and (f)

Prepare application for commercial storage approval, including qualifications of key employees, closure plan, and closure cost estimate.  Commercial storer must also notify EPA of facility modification, closure schedule, and completion of closure activities.

240 hours

12 new; 13 renewal applications

Number of new applications increased slightly from 10, based on the number the Agency has received in the past few years.  The weighted average to prepare new and renewal application is 240 hours [(392 hrs x 12 new) + (100 hrs x 13 approval)]/25.  Time to prepare notification of modification was estimated to be about one-fourth the time to prepare initial application.  (Also see # 25.)

23

§761.65(e)(4)

Submit a written request to the RA to modify a storage approval to amend the closure plan, when there are changes in ownership, changes in expected dates of closure, and/or unexpected events.

2 hours

10 times

Number of requests decreased from 17, based on the number the Agency has received in the past few years.

24

§761.65(g)(9)

Notify issuing authority of modifications to commercial storage facilities.

2 hours

7 storage facilities

Number of notifications decreased slightly from 10, based on the number the Agency has received in the past few years.

25

§§761.65(j)

Demonstrate that a new owner of a commercial storage facility has established financial assurance for closure.  Submit new or amended commercial storage application as a result of change in ownership.

120 hours

12 applications

Total number of respondents is consistent with the total number of applications for commercial storage approval, as per # 22, above.  Number of notifications slightly increased from 10, based on the number of applications the Agency has received in the past few years.

26

§§761.70(a)(8),

(9); and (d)(5)

Obtain approval of alternate measures when regulatory requirements cannot be met for operating a PCB incinerator.

1,910 hours

0

No respondents anticipated.  It was assumed that if a facility does not meet the performance criteria, it will not accept PCB waste.

27

§§761.70(d)(8);

761.75(c)(7)

Notify EPA of change in ownership of disposal facility (i.e., for incinerators and landfills).

8 hours

5 facilities

Note that the hourly estimate includes only a cursory review of the existing permits by the new owner, not a thorough review.  Number of notifications remained the same, based on the number of notifications the Agency has received over the past few years.

28

§§761.71(a)(2)

and (b)(2)

Notify EPA prior to initial use of a high efficiency boiler to burn mineral oil dielectric fluid.  Seek approval to burn liquids, other than mineral oil dielectric fluid in a HEB.

1.5 hours to notify EPA of HEB information; 40 hours to prepare approval request letter to the RA

0

respondents

Revised number of notifications and approvals remained at 0, based on the number EPA has received in the past few years.  Also see # 44.

29

§761.72(c)(2)

Notify EPA as a scrap metal recovery oven or smelter used to dispose of PCBs and comply with the reporting requirements of Subparts J and K.

1.5 hours

0

No requests anticipated.  Also see # 44.

30

§761.72(c)(3)

Request approval to dispose of PCBs in an oven or smelter based on site-specific risk assessments, in lieu of meeting requirements listed in §761.72.

1,600 hours

0

No requests anticipated.

31

§§761.77(a)(1)(i), (a)(1)(ii)(A)(1) and (C), and .77(a)(2)

Submit a notification to the RA for coordinated approval and additional information, as requested by EPA.  Submit an application for TSCA disposal approval, if the RA denies the request for a coordinated approval or determines that the conditions of the coordinated approval are not being met.

36 hours (notification); 480 hours (approval application)

6 notifications;

0 approval applications

Number of notifications remained the same, based on notifications the Agency has received in the past few years.

32

§761.77(a)(3)

Notify EPA of changes in waste management requirements in the non-TSCA waste management document used to obtain TSCA PCB coordinated approvals.

8 hours

0 waste disposers

No notifications were submitted in the past few years.

33

§761.79(h)

Prepare requests for decontamination approvals of alternative decontamination or sampling methods.  EPA may request additional information.

1,600 hours

20

Number of notifications remained the same.

Subpart E—Exemptions

34

§§761.80(e)(1) and (i)(1)

Submit R&D exemption petition to qualify for the class exemptions to mfg. PCBs for disposal R&D and to mfg., import, process, distribute, and export PCBs and analytical reference samples derived from PCB waste for the purpose of R&D.

40 hours

1 company

Number of respondents is based on recent Agency submissions.  Estimates are combined for numbers 2, 34, 36, and 38.

35

§761.80(e)(2) and (i)(2)

Submit requests for renewal of the exemptions as per §§750.11 and 31.  (Renewals to company-specific exemptions can be handled following the same procedures.)

1 hour

1 request

Number of respondents is based on recent Agency requests.

36

§§761.80(e)(3), (g)(2), and (i)(4)

Obtain approval from EPA to exceed limits of the exemption.

—

0 requests for approval

See # 34, above.

37

§761.80(e)(4)

Notify EPA before beginning R&D activities that include the manufacture of PCBs.

20 hours

1 notification

Number of respondents is based on recent Agency submissions.

38

§761.80(n)

Submit a petition for certain exemptions to address increases in the amount of PCBs to be processed and distributed, imported (manufactured), or exported, or changes in the manner of processing and distributing, importing (manufacturing), or exporting PCBs.  (See #35 for renewals.)

40 hours

0 requests

There have been no such requests in the past several years.  Total captured in Item # 34.

Subpart F—Transboundary Shipments of PCBs for Disposal

39

§§761.93(a) and .97(a)

Submit an exemption petition to import or export PCBs or PCB Items for disposal.

___

___

Burden is reported at §§761.20(b) and (c)(1) and (3).  See # 34.

Subpart G—PCB Spill Cleanup Policy

40

§§761.125(a)(1)

(i) to (iii)

Report certain spills of PCBs to the EPA.

0.167 hours (10 minutes)

100 calls

Number of calls remained the same, based on the amount the Agency received in the past few years.  Requirement also on Table 6-3.

Subpart J—General Records and Reports

41

§§761.180(b), (b)(3), and (c)(5)

Submit annual reports for the operation of PCB incinerators, chemical waste landfills, high efficiency boilers, and commercial storage facilities, including facilities that dispose of the PCB wastes they generate.  Report suspension of operations.

59 hours

151 facilities

The estimate for number of facilities was generated by using the total number of EPA-approved storage and disposal facilities (131), and increasing this number by 15 percent to reflect the additional facilities that also dispose of the wastes that they generate (U.S. EPA, 2005a and 2005b).

41a

§761.180(g)

Provide records of PCB equipment reclassification, if requested, by EPA.

0.25 hours

45 Transformers

Industry representatives indicated that only the very large, expensive transformers would likely be reclassified and only an insignificant number of voltage regulators, electromagnets, and switches would be reclassified  (Davis, 2003; U.S. EPA, 2003).  Thus, this ICR deals only with estimating the burden associated with the reporting requirements for Transformers.  EPA estimates that 58,457 PCB Transformers remain at the end of 2006 (U.S. EPA, 2004b; U.S. EPA, 2006). Assuming that 1.15% will be retrofilled and reclassified (U.S. EPA, 2004b,) the Agency estimates approximately 672 units may be reclassified during this ICR period. Of this total, Regional PCB Coordinators estimate requesting 45 records per year.  (See numbers 74c and d). The hourly estimate assumes it takes 15 minutes for equipment owners to provide requested records (ERG, 2000).

42

§761.185

Notify EPA and certify low level PCB product contamination to be exempt from the requirements of Subpart B, regarding processes inadvertently generating PCBs and imports of products containing inadvertently generated PCBs.  Certification must be repeated if the previous certification is no longer valid.

20 hours

3 companies

Submissions will report about new, modified, or import activities or about excess releases.  The number of notifications decreased from 10, based on the number the Agency has received in the past few years.  This number is declining because companies with exclusions have identified themselves in the initial group of submissions.

43

§761.187

Notify EPA when PCB releases exceed limits, to be exempt from the requirements of Subpart B, for products, manufactured or imported containing inadvertently generated PCBs.

20 hours

1 company

Number of notifications remained the same, based on the number received by the Agency in the past few years. Hourly estimate is based on time to review the monitoring log and compile information into the notification.

Subpart K—PCB Waste Disposal Records and Reports

44

§§761.202(a); 205(a) to (c)

Notify EPA of waste handling activities, for generators, commercial storers, transporters, or disposers of PCB waste.

1.5 hours

100 waste handlers

Roughly 9,100 notices have been received; relatively few “new” submissions are anticipated.  Also see numbers 9, 28, and 29, above.

45

§761.205(f)

Report changes in notifications previously submitted by PCB waste handlers.

1.5 hours

200 waste handlers

—

46

§761.208(a)(4)

and §§761.215(b) to (d).

Submit Exception Reports to EPA, as specified in §761.215(b) to (d), when PCB waste generators, disposers, and/or commercial storers do not receive confirmation that a shipment of a PCB waste has been properly disposed of.

2 hours

325 reports

Number of reports remained the same, based on the amount the Agency has received annually in the past few years.  Combined for numbers 46 and 47.

47

§761.210(b)

Submit Discrepancy Reports along with a copy of the manifest to EPA when the PCB waste received by a disposer is significantly different from the description on the manifest, and the discrepancy is not resolved after receiving the waste.

—

—

See # 46, above.

48

§761.211(b)

Notify RA of unmanifested PCB waste, for owners/operators of commercial storage facilities who cannot contact the generator of the PCB waste.

0.5 hours

17 notifications

Number of notifications decreased from 60 based on the number the Agency has received in the past few years.

49

§761.211(c)

Submit Unmanifested Waste Reports (e.g., waste description, volume, disposition; date received; ID numbers of waste handlers for that waste) to EPA when disposers accept a shipment of PCB waste without an accompanying manifest.

2 hours

57 reports

Number of reports decreased from 80 based on the number the Agency has received annually in the past few years.

Subpart T—Comparison Study for Validating a New Performance-Based Decontamination Solvent under §761.79(d)(4)

50

§§761.395 and 761.398

Submit results of analysis and validation study to the Director, National Program Chemicals Division (NPCD).

16 hours

5 studies

Estimate for the total number of respondents is 5 percent of the estimated 100 decontamination sites.  Also refer to # 93, Table 6-4.

TABLE 6-3

THIRD-PARTY REPORTING BURDENS UNDER TSCA SECTION 6(e):  ICR 1446.09, SECTION 6(a)

Ref.  #	Regulatory Section(s)  	Collection Requirement 	Time Estimate Total #

Respondents

Per Year	Comments

40 CFR 761

Subpart B—Use

51

§§761.20(e)(3)(ii); .30(i)(5)(ii); and .60(b)(5)(iv)(B)

Burner of used oil must provide a 1-time certification to the marketer that he is in compliance with notification requirement at §761.71(a)(2).

1 hour

—

No respondents anticipated.

52

§§761.30(a)(1)(xi) and (xv)(A); .30 (h)(1)(ii)(B)

Report PCB Transformers and Voltage Regulator fire incidents to the NRC.

0.167 hour (10 minutes)

27 calls

NRC data for 2004 to 2006 indicate the Center received a total of 769 PCB-related calls, or an average of 265 calls per year (U.S. Coast Guard, 2007).  An overview of these data indicates that a number of calls were to report transformer fire incidents.  It will be assumed for this ICR that 10 percent of all calls (27 calls) are to report fire-related incidents.

53

§761.30(a)(1)

(xiv)

Notify owner of PCB Transformer that equipment may pose risk of exposure to food or feed.

—

—

No burden.  All notifications were to have been made by October 1, 1985, although notification could occur if a mineral oil transformer in a location near food or feed is discovered to contain ≥500 ppm PCBs.

54

§761.30(a)(1)(xv)(D)

Register PCB Transformers with the building owner within 30 days of discovery

—

—

Burden reported on Table 6-1.

Subpart D—Storage and Disposal

55

§761.60(a)(3)(ii)

Provide information to chemical waste landfills that liquids do not exceed 500 ppm and are not ignitable.

20 hours

—

No respondents anticipated.

56

§761.60(b)(5)(i)

(A)(1)

Include abandoned natural gas pipes that contain PCBs in public service notification programs.

0.25 hour (15 minutes)

50 pipes

Industry representative indicated no change to this element (Lacey, 2003).

57

§761.60(f)(1)(i)

Provide State and local officials with notification prior to first use of an approved chemical waste landfill, incinerator, or alternate PCB disposal technology.

0.50 hour (30 minutes).

600 notifications

Since cleanup activities remain the same, the estimates for the use of mobile equipment at 300 unique sites remains the same, and will be used as follows:  200 substations per year will use mobile equipment to clean PCB Transformers; about 50 remediation sites will use solvent extraction units; 5 sites will use mobile incinerators, vitrification units, or physical separation units, and 45 sites will use other existing or newly permitted equipment.

58

§761.60(f)(1)(ii)

Provide annual notice of the quantities and description of the PCBs disposed of to State or local governments, at their request.

0.5 hour

—

Since the annual reporting requirement to State/local governments would be initiated at the State or local government level, EPA has no way of estimating this total burden.

59

§761.60(j)(1)(ii)

Notify State and local officials (as well as EPA) of PCB R&D disposal activities.

—

—

Total burden for EPA and third-party reporting requirements are reported on Table 6-1.

60

§761.60(j)(1)(vii)

Use manifests, pursuant to Subpart K, for all R&D PCB wastes being transported from the R&D facility to an approved PCB storage or disposal facility.

1 hour

39 facilities

Estimate is based on one shipment per year for each facility.  Total number of R&D facilities is listed on PADS database (U.S. EPA, 2006).

61

§§761.61(a)(3)(i)

Notify State and local officials (as well as EPA) of self-implementing remediation activity.

—

—

Total burden for EPA and third-party reporting requirements is reported on Table 6-1.

62

§761.61(a)(5)(i)

(B)(2)(iv)

Notify offsite non-TSCA facility of pending shipment of remediation waste.

2 hours

100 waste shippers

Combined for remediation and bulk product wastes (numbers 62 and 64).

63

§761.61(a)(8)(i)

(A)

Attach a notation to the deed for property at which remediation projects require a permanent fence or cap.

3 hours

100 sites

—

64

§§761.62(b)(4)(i) and (ii) (See also

§§761.357 and

 359)

Provide notification to a receiving facility that does not have a commercial PCB storage or disposal approval before the first shipment of a PCB bulk product waste stream.  In addition, for certain waste this notice must be provided with each shipment thereafter.

—

—

See # 62, above.

65

§§761.65(c)(1)

and (8)

Attach a notation to a PCB Item or PCB Container containing the item indicating the date the Item was removed from service for disposal, to be able to temporarily store the item/container in an area that does not comply with the storage requirements of paragraph (b) of this section.

0.083 hours

(5 minutes)

93,120

Items,

Containers,

and Article

Containers

The number of Items, Containers, and Article Containers based on  extensive analysis conducted for the Draft Analysis of the Cost Impacts of the Potential Amendments to the PCB Regulations at 40 CFR Part 761 (U.S. EPA, 2003).  This report indicates that 582,000 units that contain PCBs are removed from service for disposal each year (including PCB Transformers, Large Capacitors, Small Capacitors, and Voltage Regulators, as well as circuit breakers, reclosers, rectifiers, switches, electromagnets, and cables) and that 8 percent of these units contain ≥500 ppm. PCBs (46,560 PCB Items). There will be as many PCB Containers and Article Containers as Articles, making the total number of PCB Items 93,120.  For example, there may be instances where contaminated soil from one PCB Article spill may fill 50 containers or that the oil drained from one PCB Transformer fills 4 containers.  The estimate captures that some Articles will be combined into one Container.

The time estimate for these requirements considers that all Items must be dated when removed from service for disposal, whether or not the Item will be placed in temporary storage or not.

66

§761.65(i)(3)

Send information regarding the sample collector, the lab, date of shipment, quantity, and description of sample, when sending PCB samples to a laboratory for testing.

4 hours

—

Since EPA has no way of estimating the number of samples that would be sent off-site annually for testing, or the frequency with which the samples are sent to an off-site lab, EPA cannot estimate the total annual burden associated with this requirement.

Subpart G—PCB Spill Cleanup Policy

67

§761.125(a)(1)

Report certain spills of PCBs to the NRC.

0.167 hours (10 minutes)

265 incidences

New average based on the number of PCB-related incidences reported to the NRC from 2004 to 2006 (U.S. Coast Guard, 2007).  Related requirement to notify EPA is included on Table 6-1.

68

§761.125(c)

(2)(ii)

Place label or notice at PCB contamination cleanup sites at outdoor electrical substations that involved 1 lb or more PCBs by weight (270 gallons or more of untested mineral oil).

1 hour

252 sites

Revised estimate assumes that the > 1-lb spills at electrical substations are a large subset but not all of all the spills that must be reported to the NRC; 95 percent of the average annual 265 spills reported from 2004 to 2006 (U.S. Coast Guard, 2007).

The capital costs for placing the sign is assumed to be $50 per site (i.e., for posts, labels, etc.), for a total of $12,600.

Subpart J—General Records and Reports

68a

§761.180(g)

Provide records of PCB equipment reclassification, if requested, by recipients of equipment.

0.5 hours

336 units

Estimate assumes it takes 5 minutes for a manager to approve and delegate each request for records and 25 minutes for a clerk to copy and send a paper or electronic version of each complete record (ERG, 2000).

EPA estimates that 58,457 PCB Transformers remain at the end of 2006 (U.S. EPA 2004b; U.S. EPA 2006). Assuming that 1.15% will be retrofilled and reclassified (U.S. EPA 2004b,) the Agency estimates approximately 672 units of reclassified equipment during this ICR period.  Of this amount, 50 percent will be retained by owners (336), and 50 percent will be transferred to other entities (i.e., sold, loaned, leased, sent for servicing).

Subpart K—PCB Waste Disposal Records and Reports

69

§§761.207(a) and 208(a)(2) and (3)

Prepare manifests and provide generator-initiated manifests of PCB waste to each transporter or designated commercial storage or disposal facility.

0.083 (5  minutes) average

72,102 items

According to a compilation of the PCB Annual Reports, from 1998 to 2004, an annual average of 72,102 items (PCB Capacitors, Article Containers, Transformers, and PCB Containers) were transferred to another facility (i.e., a storer or disposer) (U.S. EPA, 2005b).  Each Item or container of items or waste transported from a generator either to a storer or disposer requires information included on a manifest.  To compile the original information for the first manifest that accompanies a piece of equipment or container would take about 10 minutes per item (0.167 hours).  It would take less time per item for storers to include information on a manifest (to send to a disposer) because the information is already available.  Thus it will be assumed that the time to include information on a manifest per item would average 5 minutes per item (0.083 hours).  Refer to numbers 101 and 102.

70

§§761.208(c)(1)(iv) and (c)(2)(iv)

Storer or disposer sends a copy of the manifest or shipping paper to the generator.

0.167 hours (10 minutes)

3,605 reports

The manifest information is already prepared at this point with a number of Items contained on the manifest or shipping paper.  A shipment can contain from 1 item (such as a large 20-ft x 20-ft transformer to about 40 drums that contain PCB Articles or bulk waste (Orton, 2003), with each Item or drum requiring a unique recordkeeping number.  It will be assumed for this report that the average number of items on a manifest is 20, so that of the 72,102 Items transferred, only 3,605 manifests or shipping papers need to be returned. Refer to # 101 and 102.

71

§§761.218(a) and (b)

Send Certificates of Disposal to generators of PCB waste when disposal of each item is complete for a manifested PCB waste shipment.

0.25 hour (15 minutes) average

 4,773 certificates

Based on the PCB Annual Report, the average annual total number of capacitors, Article containers, transformers, and PCB containers disposed of from 1996 to 2004 is 95,464 (U.S. EPA, 2005b).  Assuming that information regarding 20 items is included on one Certificate of Disposal, there are a total of 4,773 certificates.  This number is similar to the total reports in Item # 70, but assumes that the information on the Certificates is not necessarily the same as the items sent to the disposers by storers (i.e., some shipments could have included items from various generators, thus, this information could not be sent on the same Certificate, although it is based on the information from the manifest or shipping paper).  Even when a facility must input data for each Item, most of the required information is readily available for a majority of cases.  Also refer to # 101 and 102.

TABLE 6-4

RECORDKEEPING BURDENS UNDER TSCA SECTION 6(e): ICR 1446.09, SECTION 6(a)

Ref.  #	Regulatory Section(s)  	Collection Requirement 	Time Estimate Total #

Respondents

Per Year	Comments

40 CFR 761

Subpart A—General

72

§§761.1(f)

Comply with recordkeeping requirements of Subpart J [§§761.185(c)(2) and (d), and .193] as a condition of the exclusion from the PCB bans, for persons who inadvertently manufacture or import PCBs generated as unintentional impurities in excluded manufacturing processes or generate PCBs in excluded manufacturing process or products with recycled PCBs.

—

—

Burden is reported at §§761.185(c)(2) and (d), and .193(a).  See # 100.

Subpart B—Manufacturing, Processing, Distribution in Commerce, and Use of PCBs and PCB Items

73

§§761.20(e)(4)(i) and (ii); .30(i)(5) (ii); and .60(b)(5) (iv)(B)

Marketer who first claims used oil does not contain detectable PCBs must retain records supporting the claim and a copy of each certification notice received or prepared relating to transactions involving PCB-containing used oil.  Burners must include among the records a copy of each certification notice that has been provided to a marketer of PCB-containing used oil.

0.25 hours (15 minutes)

—

No significant burden anticipated.

74a,b

§§761.30(a)(1) (xii) and (xiv)

Maintain records of inspection and maintenance history for at least 3 years after the disposal of a PCB Transformer, including records of registration, as per §761.30(a)(1)(vi)(C).

0.05 hour (3 minutes) to track inspection data; 0.033 (2 minutes) to file and maintain data

58,457 PCB

Transformers

50 percent

(29,229) are

inspected

annually and

50 percent are inspected

quarterly

Revised estimate represents the approximately 58,457 PCB Transformers estimated to be in existence during the clearance period of this ICR (U.S. EPA, 2004, U.S. EPA, 2005b).  Time estimate remains the same and reflects the average time for a technician to track the data (3 minutes) and for a clerk to file and maintain the data (2 minutes).  This report does not account for actual inspection time.  The calculations for this estimate account for the differences in burden between annual and quarterly inspections.  It is assumed that the time to maintain records for the disposed transformers is insignificant.

74c,d

§§761.30(a)(1)

(xii) and (xiv)

Maintain records of inspection and maintenance history for at least 3 years after the disposal of a PCB Transformer, including records of registration, as per §761.30(a)(1)(vi)(C).  Accounts for the reduced number of Transformers that will be subject to this requirement based on the implementation of the Reclassification Rule, §§761.30(a)(2)(v) and (vi).

0.05 hour (3

minutes) to track

inspection data;

0.033 (2 minutes)

to file and

maintain data

-672 PCB Transformers; 50 percent

(-336) are

inspected

annually and

50 percent are

inspected

quarterly

An estimated 672 PCB Transformers will be reclassified each year during this reporting period (see #41a).

The Reclassification Rule (see #75a and b), reduces the total number of transformers subject to the inspection recordkeeping requirement.  Using the same calculation method as indicated above for #74 a and b, this requirement shows the estimated savings for the reduced number of Transformers that will be subject to this requirement.

75

§§761.30(a)(2)(v)(C) and (D); 761.30(h)(2)(vi)

(C) and (D); and 761.180(a)

Maintain records at the facility where electrical transformers, voltage regulators, electromagnets, and switches have been reclassified to a lower PCB concentration.

0.25 (15 minutes)

672 Transformers

Refer to #41a for an explanation of the number of transformers reclassified each year.  It is assumed that the burden associated with reclassified equipment other than transformers will be insignificant.  It was also assumed that it will take 15 minutes to maintain the records on pre-and post reclassification concentration of the transformer (EPA, 2000).

76

§§761.30(i)(1)

(iii)(B) and (C)

Keep records on certain natural gas pipeline systems with ≥50 ppm PCBs and records of actions taken to reduce PCB contamination for 3 years after PCBs reduced to <50 ppm.

4 hours

100 systems

It is not anticipated that new records will need to be developed; historical data can be used.

77

§761.35(a)(2)

Keep records of equipment stored for reuse.

0.15 hour

189,225 pieces of equipment

Total pieces of equipment that require recordkeeping is based on information reported in the cost analysis for the Final Rule, which was reviewed to generate the Draft Analysis of the Cost Impacts of the Potential Amendments to the PCB Regulations at 40 CFR Part 761 (U.S. EPA, 2003).  It was reported in the cost analysis that equipment owners will store 182,700 PCB Articles for <5 years in areas that do not comply with §761.35(b) and 6,525 PCB Articles for >5 years, with compliance with recordkeeping and reporting requirements, for a total of 189,225 pieces of equipment for this requirement.

Subpart C—Marking of PCBs and PCB Items

78

§761.40(c)(2)(ii) and (k)

Keep records of the protected location of PCB large capacitors where owner chooses not to mark individually (optional).

0.1 hour (6 minutes)

100,000 pieces of equipment

Based on analysis contained in the Draft Analysis of the Cost Impacts of the Potential Amendments to the PCB Regulations at 40 CFR Part 761 (U.S. EPA, 2003).

Subpart D—Storage and Disposal

79

§761.60(j)(1)(ix)

Keep records of R&D for disposal activities.

12 hours

39 facilities

Number of facilities based on data contained in the PADS database (U.S. EPA, 2006).

80

§§761.61(a)(3)(i)

(E); and (a)(6)

Retain records of the sampling plans, sample collection procedures, sample preparation procedures, extraction procedures, and instrumental/chemical analysis procedures used to assess or characterize the PCB contamination at the cleanup site, and certification that these records are on file at the location designated in the certificate.  Keep records of comparison studies for any alternate method used that meet or exceed the requirements of §761.326.  Keep records of sampling and sample analysis to verify cleanup and on-site disposal of bulk PCB remediation wastes and porous surfaces, as per Subpart O, §761.295.

1 hour

100 sites

Also see §761.295.

81

§761.61(a)(3)(iii)

Retain original waivers from the self-implementing remediation requirements received from the RA, State, and local agencies.

0.167 hour (10 minutes)

100 sites

This estimate remained the same.

82

§761.61(a)(9)

Keep records in accordance with §761.125 (c)(5) for (a)(3), (a)(4), and (a)(5) of this part.

20 hours

100 sites

This estimate remained the same.

83

§761.62(b)(5)

Maintain a written record of all sampling and analysis of PCBs or notifications made under this part and make available upon request.

4 hours

26 sites

Estimate is 15 percent of 170 total affected sites.

84

§§761.65(a)(2)(ii) and (a)(3)

Keep a written record of attempts to secure disposal capacity.  Records may be required for periods of extended storage.

4 hours

63 waste storers

Number of waste storers is 1 percent of the total number of waste generators and storers (6,316) listed in the PADS database (U.S. EPA, 2006).

85a,b

§761.65(c)(1)(iv)

Prepare/modify Spill Prevention, Control and Countermeasure (SPCC) Plans to address liquid PCBs >500 ppm, to be able to temporarily store PCB Containers containing liquid PCBs at ≥50 ppm in areas that do not comply with the storage requirements of §761.65.

60 hours/new plan; 2 hours/ adapted plan

5 new

respondents; 10 adapt existing plans

It is estimated that only 5 waste generation facilities will be required to prepare plans from scratch and 10 facilities will adapt existing plans.

86

§761.65(c)(7)(ii)

Prepare SPCC Plan, when using stationary storage containers, as per 29 CFR 1910.106, for liquid PCBs.

60 hours

5 facilities

It is not foreseen that many facilities will enter into the PCB storage business each year.

87

§761.65(c)(8)

Keep records of the quantity and the date of each batch added to the stationary storage container.

0.083 hours (5 minutes)

30,000

batches

Number of batches remained the same.

88

§§761.65(c)(10) and 761.180

Establish and maintain records as per §761.180 for storing for disposal PCBs and PCB Items ≥50 ppm.

843 hours

73

commercial

storers

The total number of storers was obtained from EPA’s list of Commercial Storage Approvals (U.S. EPA, 2005c).

89

§§761.70(a)(3), (4) and (7); (c); and 761.180(c)

Maintain for incinerators records of quantities, feed rates, temperatures, combustion products, and operations, and special records, as per §761.180(c).

843 hours

4 incinerators

From the EPA’s list of Commercially Permitted PCB Disposal Companies (U.S. EPA, 2005a).

90

§§761.71(a)(1)(vi) and (vii), (a)(4), (b)(1)(vi-vii), (b)(5);761.180(e)

Record and retain monthly HEB operation data.

12 hours

20 HEBs

Note that 5 of these HEBs (from EPA Region VI) are used intermittently, so that total hourly burden may actually be less than indicated in this report.  Also, total number of HEBs is based on EPA estimate of 2 per region.

91

§§761.72(a)(9) and (b)(6)

Record and retain records of temperature readings  from scrap metal recovery ovens.

3 hours

8 ovens

From EPA’s list of Commercially Permitted Scrap Metal Recovery Ovens (U.S. EPA, 2004).

92

§§761.75(b)(6)(iii) and (b)(8)(iv); 761.180(d)

Maintain records for all PCB disposal operations at chemical waste landfills, including PCB concentration in liquid wastes, the three-dimensional burial coordinates for PCBs and PCB Items, water sampling and analysis, and additional records as required in §761.180.

843 hours

10 landfills

From EPA’s list of Commercially Permitted Disposal Companies (U.S. EPA, 2005a).

93

§761.79(d)(4) and Subpart T

Retain test/validation results of PODFs and VADFs.

0.5 hour

5 facilities

Estimate is 5 percent of the 100 decontamination sites.

94

§§761.79(f)(1) and (2)

Keep records of confirmatory sampling and sampling locations/results for decontamination activities and compliance with self-implementing decontamination procedures.

2 hours

100 sites

No change.

Subpart E—Exemptions

95

§761.80(e)(5) and (i)(7)

Keep records of activities associated with manufacture/processing/distribution in commerce of PCBs or PCB reference samples derived from waste materials for R&D.

12 hours

39 facilities

Number of facilities based on PADS database (U.S. EPA, 2006).

96

§761.80(g)(1)

Keep records of PCB processing and distribution in commerce activities, for facilities that process and distribute small quantities of PCBs for R&D.

12 hours

15 facilities

Total number of facilities remained unchanged based on an Agency review of existing petitions.

Subpart G—PCB Spill Cleanup Policy

97

§§761.125(b)(3) and (c)(5); .61(a)(9)

Maintain records of cleanup and certification of decontamination.

8 hours

265 sets of records

Based on the average annual number of spills reported to the NRC from 2004 to 2006 (U.S. Coast Guard, 2007).

98

§761.125(c)(1)

Maintain records documenting delay in spill cleanup activities and areas of visible contamination.

0.5 hours

13 sites

It is anticipated that 5 percent of the total number of spills, as reported above, would face delays in cleanup.

Subpart J—General Records and Reports

99

§§761.180(a),(a) (4), (b) and (f);  761.65(c)(5)

Maintain annual records and document log for PCBs and PCB Items for 5 years after facility ceases, including manifests, CDs, records of inspections and cleanups, facility and Item ID information, number of Items, phone records, and Item transfer information, for owners/operators of storage and disposal facilities.  Collect and maintain documents, correspondence, and data pertaining to storage/disposal of PCBs that have been provided to as well as received from any State/local agency and any application/ correspondence submitted to permitting authorities.

52 hours

7,517 waste

handlers

The time to keep the annual log varies widely, based on the level of PCB activity taking place and the volume of PCBs and PCB Items handled.  To keep the annual log takes from 1 hour to over 40 hours each week.  Total number of facilities is the total number of PCB waste handlers (7,648) minus the total number of commercial storers and disposers (131 facilities).  (U.S. EPA, 2004a, 2005a, 2005c, and 2006).

100

§§761.185(c)(2), (d) and .193(a) and (b)

Maintain theoretical analysis or monitoring records by persons who import, manufacture, process, distribute in commerce, or use products containing inadvertently generated or recycled PCBs, pursuant to §761.1(f)(1) to (3).  Maintain letter certifying compliance with §761.1(f), for excluded manufacturing processes.

5 hours to file records; 5 hours to maintain previous reports

25 new respondents; 10 previous respondents

Number of respondents remained the same based on recent Agency records.

Subpart K—PCB Waste Disposal Records and Reports

101

§§761.208 and

 .209

File and maintain manifests initiated or received by the PCB generator and any subsequent PCB waste handler.

0.167 hour (10 minutes)

3,605 manifests

Total number of manifests is an average of 20 items per manifest for a total of 72,102 items (3,605).  Refer to numbers 69 and 70.

102

§761.218(c)

Maintain a copy of each Certificate of Disposal received from disposers, for generators and commercial storers of PCB waste.

0.167 hour (10 minutes)

3,605 certificates

Estimates are based on the estimates used for a similar requirement, # 101, above.  Refer to numbers 69 and 70.

		Subpart T—Comparison Study for Validating a New Performance-Based Decontamination Solvent under §761.79(d)(4)

103

§761.398(c)

Record testing parameters and experimental conditions in SOP.  Results of validation study are to be affixed in an appendix.

16 hours

5 facilities

No change.

TABLE 6-5 ANNUAL RESPONDENT HOURLY BURDEN AND COST ESTIMATE - REPORTING

Ref #	 Regulatory Citation	 Information Collection Activity	Hours and Costs Per Respondent	Total Hours and Costs

	Mgr. @	Tech. @	Cler. @	Hours/	Labor	Total	Total	Total

	$56.43	$47.72	$24.08	Respond./	Cost/Res.	# of	Hours/	Cost/

	/Hour	/Hour	/Hour	Year[a]	/Year[b]	Resp	Year[c]	Year[d, e]

 	 	Subpart B

3	761.30(a)(1)(vi),(vii), (xv)(D)	Register newly discovered PCB Transformers	1	 -	 -	1	$56	351	351	$7,548[e]

5	761.30(i)(1)(iii)(A)(1)	Submit descriptions of gas pipeline systems	8 10	2	20	$977	1	20	$372[e]

7	761.35(b)	Obtain approval for PCB Article storage in a facility that does not meet 761.65(b)	 	0.166	 	0.166	$8	6,250	1,038	$18,868[e]

 	 	Subpart D

8	761.60(e), (i)(2); .70(a), (b),(d)(2); .75(b)(7),(b) (8)(ii),(c) Submit disposal permit applications	 -	825	75	900	$41,175	40	36,000 $627,672[e]

9	761.60(j)(1)(i) 	Obtain identification number for R&D disposal	 -	1.5	 -	1.5	$72	5	8	$136[e]

10	761.60(j)(1)(ii)	Notify officials of R&D activities	 -	4	2	6	$239	10 60	$2,390

12	761.61(a)(3)(i),(ii)	Notify officials of self-imp. remediation	30	50 20	100	$4,561	58	5,800	$264,509

13	761.61(a)(3)(ii)	Notify EPA of self-imp. remed. changes	 -	2	 -	2	$95 13	26	$1,241

14	761.61(a)(3)(iii)	Request waiver of notification requirement	2	16	2 20	$925	17	340	$15,717

15	761.61(a)(8)(i)(B)	Certify recording of deed notation	 -	4	 	4	$191 28	112	$5,345

16	761.61(c)(1)	Apply for risk-based disposal approval for remediation waste	 -	1,480	120	1,600	$73,515	17	27,200	$476,283[e]

17	761.62(c)91)	Apply for risk-based disposal or storage approval for bulk PCB product waste 	 -	1,480	120	1,600	$73,515	20	32,000	$560,333[e]

18	761.65(a)(2),(3),(4)	Notify of attempts to secure disposal	 -	2	1	3 $120	5	15	$598

21	761.65(c)(6)(i)(C)	Demonstrate that storage containers for PCB/rad waste are protective of health/env	 -	32	8	40	$1,720	5	200	$3,277[e]

22	761.65(d),(e)(1),(e)(6-8),(f)	Prepare storage approval application	 - 240	 -	240	$11,453	25	6,000	$109,117[e]

23	761.65(e)(4)	Submit RA request to modify storage	1.5	 -	0.5	2	$97	10 20	$967

24	761.65(g)(9)	Notify EPA of changes to storage facilities	 -	1.5	0.5	2 $84	7	14	$585

25	761.65(j)	Demonstrate financial assurance for closure	20	80	20	120 $5,428	12	1,440	$24,822[e]

27	761.70(d)(8);.75(c)(7)	Notify EPA of changes in facility ownership	7	 -	1	8	$419	5	40	$2,095

31	761.77(a)(10(i),(a)(1)(ii) (A)(1),(C); (a)(2)	Request coordinated approval	8	20	8	36	$1,598	6	216	$3,655[e]

33	761.79(h)	Prepare requests for decontamination approvals of alternative decontamination sampling methods	 -	1,480	120	1,600	$73,515 20	32,000	$560,333[e]

 	 	Subpart E

 34	761.80(e)(1); (i)(1)	Qualify for R&D exemptions	32	 -	8	40	$1,998	1 40	$1,998

 35	761.80 (e)(2), and (i)(2)	Submit requests for renewal of the class exemptions	1	 -	 -	1	$56	1	1	$56

 37	761.80(e)(4)	Notify EPA of PCB mfg. before R&D activities	2	16	2	20 $925	1	20	$925

 	 	Subpart G

40	761.125(a)(1)(i) to (iii)	Report certain spill of PCBs to EPA	0.167	 -	 -	0.167	$9	100	17	$942

 	 	Subpart J

41	761.180(b), (b)(3),(c)(5)	Prepare/submit annual reports on storage/disposal	56	 -	3	59	$3,232	151	8,909	$488,080

41a	761.180(g)	Provide EPA with info on reclassified equipment 	0.25	 -	 -	0.25	$14	45	11	$635

42	761.185	Notify EPA for exclusion for inadvertent generation of PCBs	6 11	3	20	$411	3	60	$1,232

43	761.187	Notify EPA when exceed limits for inadvertent generation of PCBs	6	11	3	20	$411	1	20	$411

 	 	Subpart K

44	761.202(a), 205(a - e)	Notify EPA of PCB waste activity	1	 -	0.5	1.5 $68	100	150	$6,847

45	761.205(f)	Report changes in waste handler notifications	1	 -	0.5	1.5 $68	200	300	$13,694

 46	761.208(a)(4); 215 (b-d)	Submit Exception and Discrepancy Reports 	 -	1.5	0.5	2	$84	325	650	$27,177

48	761.211(b)	Notify EPA of unmanifested waste	 -	0.5	 -	0.5	$24	17	9 $406

49	761.211(c)	Submit Unmanifested Waste Reports	 -	1.5	0.5	2	$84	57	114 $4,766

 	 	Subpart T

50	761.395, .398	Submit results of validation study analysis	1	14	1	16 $749	5	80	$3,743

 	TOTALS	 	 	 	 	 	 	 	153,279	$3,236,776

Notes: [a] Sum of staff hours; [b] Sum of staff hours x labor rates; [c] Hours/respondent/year x total number of respondents; [d] Labor costs/respondent x total number of respondents.  Totals may not add due to rounding; [e] Total costs are annualized (x 0.3811) for the one-time requirements of numbers 3-9, 16, 17, 21, 22, 25, 31, and 33.

TABLE 6-6 ANNUAL RESPONDENT HOURLY BURDEN AND COST ESTIMATE - THIRD-PARTY REPORTING

 	 	 	 Hours and Costs Per Respondent	   Total Hours and Costs

 	 	 	Mgr. @	Tech. @	Cler. @	Hours/	Labor

Total	Total	Total

 	 	 	$56.43	$47.72	$24.08	Respond./	Cost/	Capital	# of	Hours/	Cost/

Ref #	Regulatory Citation	Information Collection Activity	/Hour	/Hour /Hour	Year[a]	 Year[b]	Costs[c] 	Respon.	Year[d]	Year[e, f]

 	 	Subpart B

52	761.30(a)(1)(xi),(xv)(A) (h)(1)((ii)(B)	Report PCB Transformer and Voltage regulator fires to NRC	 -	0.167	 -	0.167	$8	 -	27	5	$215

 	 	Subpart D

56	761.60(b)(5)(i)(A)(1)	Include gas pipes in notification programs	 - 0.25	 -	0.25	$12	 -	50	13	$597

57	761.60(f)(1)(i)	Notify State/local gov'ts of PCB disposal	 -	0.333 0.167	0.5	$20	 -	600	300	$11,947

60	761.60(j)(1)(vii)	Manifest R&D PCB wastes	 -	1	 -	1	$48	 -	39	39 $1,861

62	761.61(a)(5)(i)(B)(2) (iv)	Notify offsite non-TSCA facility of pending shipment of remediation/waste	 -	2	 -	2	$95	 -	100	200	$9,544

63	761.61(a)(8)(i)(A)	Certify deed notation recording	 -	3	 	3	$143	 - 100	300	$14,316

65	761.65(c)(1),(8)	Attach date notation on PCB Items and Containers	 - 0.083	 -	0.083	$4	 -	93,120	7,729	$368,826

 	 	Subpart G

67	761.125(a)1)	Report certain spills of PCBs to the NRC	0.167	 -	 - 0.167	$9	 -	265	44	$2,497

68	761.125(c)(2)(ii)	Place notice of PCB contamination at cleanup site	 -	1	 -	1	$48	$50	252	252	$9,385[f]

 	 	Subpart J

68a	761.180(g)	Provide records of reclassification, if requested, to recipients of reclassified equipment	0.083	 -	0.417	0.5	$15	 -	336	168 $4,948

 	 	Subpart K

69	761.207(a); .208(a)(2),(3)	Prepare manifests of each PCB waste for PCB waste transporters, storers, and disposers	0.083	 -	 -	0.083	$5	 - 72,102	5,984	$337,703

70	761.208(c)1)(iv), (c)(2)(iv)	Storer/disposer sends manifest to generator	0.167	 -	 -	0.167	$9	 -	3,605	602	$33,973

71	761.218(a),(b)	Send Certificates of Disposal to generators	 -	0.25	 - 0.25	$12	 -	4,773	1,193	$56,942

 	TOTALS	 	 	 	 	 	 	$50	 	16,829	$852,754

Notes: [a] Sum of staff hours; [b] Sum of staff hours x labor rates; [c] Capital cost calculated per respondent [d] Hours/respondent/year x total number of respondents; [e] Labor/respondent x total number of respondents.  Totals may not add due to rounding. [f] Total costs are annualized (x 0.3811) for the one-time requirements of number 68.

TABLE 6-7ANNUAL RESPONDENT HOURLY BURDEN AND COST ESTIMATE - RECORDKEEPING

 	 	 	Hours and Cost Per Respondent	Total Hours and Costs

 	 	 	Mgr @	Tech. @	Cler @	Hours/	Labor	Total	Total	Total

 	 	 	$56.43	$47.72	$24.08	Respon./	Cost/	# of	Hours/	Cost/

  Ref #	Reg. Citation	Information Collection Activity	Hour	Hour	Hour Year[a]	Year[b]	Respon.	Year[c]	Year[d, e]

 	 	Subpart B

74a	761.30(a)(1)(xii)	Maintain PCB Transformer inspection data (annual)	 -	0.05	0.033	0.083	$3	29,229	2,426	$92,967

74b	761.30(a)(1)(xii)	Maintain PCB Transformer inspect. data (quart.)	 - 0.2	0.133	0.333	$13	29,229	9,733	$372,572

74c	761.30(a)(1)(xii)	Maintain PCB Transformer inspection data (annual)	 -	0.05	0.033	0.083	$3	-336	-28	-$1,069

74d	761.30(a)(1)(xii)	Maintain PCB Transformer inspect. data (quart.)	 - 0.2	0.133	0.333	$13	-336	-112	-$4,283

75	761.30(a)(2)(v);    761.180(a)	Maintain records of retrofilled equipment	 -	0.167	0.083	0.25	$10	672	168	$6,698

76	761.30(i)(1)(iii)(B), (C)	Keep records of gas pipeline system data	1 2	1	4	$176	100	400	$17,595

77	761.35(a)(2)	Keep records of equipment stored for reuse	 -	0.15	 - 0.15	$7	189,225	28,384	$1,354,473

78	761.40(c)(2)(ii), (k)	Keep large capacitor records (optional)	 -	0.1	 -	0.1	$5	100,000	10,000	$477,200

 	 	Subpart D

79	761.60(j)(1)(ix)	Keep R&D for disposal records	 -	12	 -	12	$573	39 468	$22,333

80	761.61(a)(3)(i)(E); (a)(6); .295	Retain remediation sampling/analysis records	 -	1	 -	1	$48	100	100	$4,772

81	761.61(a)(3)(iii)	Retain waivers from self-impl. remed. projects	 - 0.167	 -	0.167	$8	100	17	$304[e]

82	761.61(a)(9)	Keep records accd to Spill Cleanup Policy	4	12	4	20	$895 100	2,000	$89,468

83	761.62(b)(5)	Maintain sampling/analysis records for bulk product wastes	1	3	 -	4	$200	26	104	$1,978[e]

84	761.65(a)(2)(ii), (a)(3)	Keep records of attempts to secure disposal  	4	 -	4	$191	63	252	$12,025

85a	761.65(c)(1)(iv)	Prepare SPCC plans	5	45	10	60	$2,670	5	300 $5,088[e]

85b

761.65(c)(1)(iv)	Modify SPCC  plans for liquid PCBs >500 ppm	0.5	1	0.5	2 $88	10	20	$880

86	761.65(c)(7)(ii)	Prepare SPCC plans for facilities using storage containers	5	45	10	60	$2,670	5	300	$5,088[e]

87	761.65(c)(8)	Keep records of the quantity/date of each batch added to a stationery storage container	 -	0.083	 -	0.083	$4	30,000	2,490 $118,823

88	761.65(c)(10)	Establish and maintain annual log records as per .180 for PCB storage facilities	24	 - 	819	843	$21,076	73	61,539	$1,538,536

89	761.70(a)(3),(4),(7); (c); .180	Maintain incinerator records	48	260 535	843	$27,999	4	3,372	$111,995

90	761.71(a)(a)(vi), (vii); (b)(1)(vi), (vii), (b)(5); .180(e)	Retain monthly HEB operating data	 -	12	 -	12	$573	20	240	$11,453

91	761.72(a)(9), (b)(6)	Retain scrap metal recovery oven  records	 -	3	 -	3	$143	8	24	$1,145

92	761.75(b)(6)(iii), (b)(8)(iv); .180(d)	Maintain chemical waste landfill records	24	 - 	819	843	$21,076	10	8,430	$210,758

93	761.79(d)(4)	Retain PODF/VADF validation results	 -	0.5	 -	0.5	$24	5 3	$45[e]

94	761.79(f)(1), (2)	Keep decontamination sampling records	 -	2	 -	2	$95 100	200	$3,637[e]

 	 	Subpart E

95	 761.80(e)(5), (i)(7)	Keep records of PCB mfg/ proc/dist. in commerce R&D activities	 -	12	 -	12	$573	39	468	$22,333

96	 761.80(g)(1)	Keep records of PCB proc/dist. in commerce of small quantities of PCBs for R&D activities	 -	12	 -	12	$573	15	180	$8,590

 	 	Subpart G

97	761.125(b)(3), (c)(5)	Maintain records of cleanup and certification of decontamination	1	5	2	8	$343	265	2,120	$90,945

98	761.125(c)(1)	Maintain records documenting delay in cleanup	 -	 -  0.5	0.5	$12	13	7	$157

 	 	Subpart J

99	761.180(a), (a)(4), (f); .65(c)(5)	Maintain annual records and log for PCBs and PCB Items	12	 - 	40	52	$1,640	7,517	390,884	$12,330,586

100a	761..185(c)(2) and .193(a), (b)	Maintain monitoring data of inadvertent  PCBs	 -	5	 -	5	$239	25	125	$5,965

100b	761..185(c)(2) and .193(a), (b)	Maintain previous records of monitoring data of inadvertent  PCBs	 -	 - 	5	5	$120	10	50	$1,204

101	761.208(a), (b), (c); .209(a-d)	File and maintain manifests	 -	 -  0.167	0.167	$4	3,605	602	$14,497

102	 761.218(c)	Maintain Certificates of Disposal	 -	 -	0.167	0.167	$4 3,605	602	$14,497

 	 	Subpart T

103	761.398(c)	Record test parameters and SOP conditions for decontamination validation studies	 -	16	 -	16	$764	5	80	$1,455[e]

 	TOTALS	 	 	 	 	 	 	 	525,947	$16,944,710

Notes: [a] Sum of staff hours; [b] Sum of staff hours x labor rates; [c] Hours/respondent/year x total number of respondents; [d] Labor/respondent x total number of respondents.  Totals may not add due to rounding; [e] Total costs are annualized (x 0.3811) for the one-time requirements of numbers 81, 83, 85, 86, 93, 94 and 103.

6(c)	Estimating Agency Burden and Cost

The estimated Agency burden associated with this Consolidated ICR is shown on Table 6-8 with comments indicated on the table.  The detailed costs associated with the Agency burden are shown in Table 6-9.  The hourly rates for EPA staff were based on a composite management level at GS-15/5 ($49.69); technical support at GS-12/5 ($30.06), and clerical support at GS-7/5 ($16.95), using the 2006 General Schedule Salary Table, effective January 2006 (U.S. OPM, 2006).  (Note that Tables 6-8 and 6-9 appear at the end of section 6(e)).

6(d)	Estimating the Respondent Universe and Total Burden and Costs

Refer to Tables 6-2 through 6-7 for this information.

6(e)	Bottom Line Burden and Costs

(i)	Respondent Tally

As indicated on Table 6-5, the total respondent reporting burden is 153,279 hours and $3,236,776.  As indicated on Table 6-6, the total respondent third-party reporting burden is 16,829 hours and $852,754.  As indicated on Table 6-7, the total respondent recordkeeping burden is 525,947 hours and $16,944,710.  Table 6-10 summarizes the respondent burdens and costs for each applicable subpart of 40 CFR 761.  As shown on the table, the total paperwork burden for this Consolidated ICR is 696,055 hours and $21,034,240.

(ii)	Agency Tally

As indicated on Table 6-9, the Agency annual burden is 54,081 hours and $1,601,465.

(iii)	Variations in the Annual Bottom Line

This section does not apply.  There are no anticipated significant variations in the annual respondent reporting or recordkeeping burden or cost over the course of the requested clearance period for either industry or the Federal Government.

TABLE 6-8 ANNUAL AGENCY HOURLY BURDEN FOR THE CONSOLIDATED ICR SUPPORTING STATEMENT COVERING THE PCB REGULATIONS AT 40 CFR 761

Collection Activities	Burden Hrs/Year	Respondents/Year	Comments

Review/analyze data submissions (i.e., new exemptions and renewal data); develop rulemakings in response to the petitions for exemption; publish rulemakings in the Federal Register; index and file the data in the public docket.

203 hours

5 renewal petitions: 2 new petitions

Federal Register publication costs add approximately $1,500 to the annual cost of this collection activity.

Review preliminary PCB Transformer inspection reports; input data; index/file data.

20 hours

500 inspections

The total time to conduct inspections equals 4 days.

Review exclusion submissions; record/enter submissions; analyze requests for confidentiality and provide appropriate protection; store data.

6 hours

8 submissions

—

Review technology-based disposal applications; attend demonstrations (EPA engineers and contractor analytical chemists); develop (i.e., grant/deny) approval; maintain files.

660 hours

15 submissions

Costs vary depending on number and type of applications received.  Number of §761.60 approvals has remained fairly constant over the last several years and is expected to remain so.

Review facility records, including annual reports.

2 hours per  review

1,100 inspections

Based on Compliance Monitoring Plan, maximum number of inspections for all 10 Regions combined is 1,100/year.

Review applications for commercial storage approval, with contractual support.

72-125 hours/

application; 98.5 hours, average, rounded to 100

3.3 applications/  year average, rounded to 3

Review time varies based on the number of deficiencies initially discovered and any supplemental information that is submitted to correct the deficiencies.  EPA uses contractual support to review applications.

Process PCB notification forms; update PADS; respond to inquires regarding these submissions; maintain hard-copy files of these submissions; and provide contractor oversight.

520 hours

—

These activities will be conducted at EPA Headquarters only.  The hourly figures represent the time allocation to handle all respondents.

Process PCB Transformer registrations.

520 hours

—

These activities will be conducted at EPA Headquarters only.  The hourly figures represent the time allocation to handle all respondents.

Maintain PCB Transformer database

260 hours

—

Respond to numerous requests for regulatory interpretations and inquiries regarding the PCB notification and Transformer Registration Programs.

1,850 hours

—

Maintain official files of all requests for approvals and EPA’s responses.

675 hours

—

See comment above.

Review requests for approval for PCB Articles stored for reuse >5 yrs.	2 hours/ submission	17 submissions	In 2008, the Storage for Reuse provision in Number 7, Table 6-5 will be up for renewal. Based the Agency’s historical experience, a total of 83 renewal requests, each one addressing about 75 pieces of equipment, will be submitted for 6,250 pieces of equipment total. Over 5 years, this is 17 applications per year.

Review requests for risk-based disposal and coordinated approvals and alternate decontamination or sampling methods; issue approvals or waivers; maintain files.

515 hours

55 submissions

Costs vary depending on number and types of applications received.  Respondents increased from 46 to 55.  Burden hrs/year figure corrects erroneous figure (23,675) in previous ICR supporting statement.

TABLE 6-9 ANNUAL AGENCY HOURLY BURDEN AND COST

Information Collection Activity	Hours and Costs Per Respondent	Total Hours and Costs

	GS-15/5 @ $49.69/

Hour	GS-12/5 @ $30.06/

Hour	GS-7/5 @ $16.95/

Hour

Agency Hours/

Year[a]

Labor Cost/

Year[b]

Cap.

Costs[c]

Total

# of

Resp.

Total

Hours/

Year[d]

Total

Cost/

Year[e, f]

PCB Manufacturing, Processing, and Distribution in Commerce Exemptions

Review/analyze new exemption petitions and renewal data	1	28	-	29	$891	 -	7	203	$6,237

Develop rulemakings	3	160	8	171	$5,094	 -	1	171	$5,094

Index/file data	-	-	2	2	$34	 -	1	2	$34

FR publication	1	24	8	33	$907	$1,500	1	33	$2,407

SUBTOTAL

409	$13,722

PCB Use in Electrical Equipment and Transformers

Review preliminary inspection report	-	8	-	8	$240	 -	500	4,000	$120,240

Review reformatted report	-	4	-	4	$120	 -	500	2,000	$60,120

Review/input data	-	4	-	4	$120	 -	500	2,000	$60,120

Index/file data	-	-	4	4	$68	 -	500	2,000	$33,900

SUBTOTAL

 	10,000	$274,380

PCB Exclusions, Exemptions, and Use Authorizations

Review exclusion request submissions	-	2	-	2	$60	 -	8	16	$481

Record/enter submissions	-	1	-	1	$30	 -	8	8	$240

Analyze requests for confidentiality and provide appropriate protection -	1	-	1	$30	 -	8	8	$240

Store data	-	2	-	2	$60	 -	8	16	$481

SUBTOTAL

 	48	$1,442

PCB Disposal Permitting Regulation

Review applications	-	312	-	312	$9,379	 -	15	4,680	$140,685

Attend demonstrations	-	156	-	156	$4,689	 -	15	2,340	$70,335

Contractor support for demonstrations	-	140	-	140	$4,208	 -	15	2,100 $63,120

Develop (grant/deny) approval	2	30	-	32	$1,001	 -	15	480	$15,015

Maintain files	-	1	-	1	$30	 -	15	15	$450

SUBTOTAL

9,615	$289,605

Notification and Manifesting for PCB Waste Activities

Record and retain scrap metal recovery oven 	-	2	-	2	$60	 -	1,100	2,200 $66,132

Maintain chemical waste landfill records	-	100	-	100	$3,006	 -	3	300 $9,018

SUBTOTAL

 	2,500	$75,150

Final Regulations Amending the PCB Regulations at 40 CFR 761

Process notification forms; update PADS	-	520	-	520	$15,631	 -	1	520 $15,631

Process PCB Transformer registrations	-	520	-	520	$15,631	 -	1	520 $15,631

Create PCB Transformer database	-	260	-	260	$7,816	 -	1	260	$7,816

Review requests for approval for PCB Articles stored for reuse >5  years  -	2	-	2	$60	 -	17	34	$1,022

Review requests for risk-based disposal and coordinated approvals and alternative decontamination or sampling methods; issue approvals, waivers or letters of approval; maintain files of requests for approval -	515	-	515	$15,481	 -	55	28,325	$851,455

Respond to requests for regulatory interpretations	-	1,850	-	1,850 $55,611	 -	1	1,850	$55,611

SUBTOTAL

 	31,509	$947,166

TOTALS

 	54,081	$1,601,465

Notes: [a] Sum of staff hours; [b] Sum of staff hours x labor rates; [c] EPA estimates; [d] Total number of respondents x Agency hours/year; [e] Labor x respondent x total number of respondents; [f] Totals may not add due to rounding.

TABLE 6-10 SUMMARY OF RESPONDENT BURDENS AND COSTS BY SUBPART

Subparts	Total # of Respondents	Total Hours Per Year	Total Hours Per Respondent[a] 	Total Cost Per Year	Total Cost Per Hour[b]

Reporting

Subpart B	6,602	1,409	0.213	$26,789	$19

Subpart D	283	141,491	500	$2,659,075	$19

Subpart E	3	61	20	$2,979	$49

Subpart G	100	17	0.167	$942	$56

Subpart J	200	9,000	45	$490,358	$54

Subpart K	699	1,223	2	$52,889	$43

Subpart T	5	80	16	$3,743	$47

Subtotal Reporting	7,892	153,279	 	$3,236,776	$21

Third-Party Reporting

Subpart B	27	5	0.167	$215	$48

Subpart D	94,009	8,580	0.091	$407,091	$47

Subpart G	517	296	0.573	$11,882	$40

Subpart J	336	168	0.500	$4,948	$29

Subpart K	80,480	7,780	0.097	$428,618	$55

Subtotal Third-Party Reporting	175,369	16,829	 	$852,754	$51

Recordkeeping

Subpart B	347,783	50,971	0.147	$2,316,153	$45

Subpart D	30,668	79,858	2.604	$2,138,329	$27

Subpart E	54	648	12	$30,923	$48

Subpart G	278	2,127	7.649	$91,102	$43

Subpart J	14,762	392,263	27	$12,366,749	$32

Subpart T	5	80	16	$1,455	$18

Subtotal Recordkeeping	393,550	525,947	 	$16,944,710	$32

Totals	576,811	696,055	 	$21,034,240

Notes: [a] Total hours per year/total number of respondents; [b] Total cost per year/total hours per year

6(f)	Reasons for Change in Burden

The total burden for this ICR is 696,055 hours and $21,034,240.  The previous burden in OMB’s inventory for the existing Consolidated ICR was 824,778 hours and $23,005,750.  This results in a cumulative decrease of 128,723 hours (824,778 - 696,055) and a decrease of $1,971,510 ($23,005,750 - $21,034,240).

In addition to revised wage rates, the changes in the total annual respondent reporting and recordkeeping burdens and costs over the course of the requested clearance period for many provisions were due to revisions to the total number of respondents.  In some cases, the total number of respondents was based on number of facilities; in other cases, the total number of respondents was calculated by estimating the total number of pieces of equipment that respondents must keep track of for a particular requirement.  The up-to-date wage rates and the change from the previous ICR are as follows:

Manager - new rate, $56.43; prior rate; $56.99 (negligible decrease)

Clerical - new rate, $24.08; prior rate, $21.18 (14 percent increase)

Professional/technical category was utilized to be consistent with other Agency economic analyses.  This replaced the previous labor categories of engineer/foreman ($53.87) and engineering technician ($32.85). The current rate for the professional/technical category is $47.72.

These burden and cost changes were the result of new data gathered for this ICR effort as well as another recent PCB regulatory analysis, estimate adjustments made for consistency with the more recent Agency report, and updated Agency data regarding total numbers of regulated entities.

The specific adjustments to this Consolidated ICR are explained on Tables 6-2 through 6-8 and are summarized on Table 6-11 and in the following discussion.

Item number 3 - The total number of newly discovered PCB Transformers that must be reported to EPA was increased from 85 to 351, based on the Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors (U.S. EPA, 2004b).  The change in EPA’s assumption regarding PCB Transformers increases the burden from 85 hours to 351 hours (+266 hour adjustment).

Item numbers 4, 9, 12 to 18, 23, 24, 42, and 46 to 49 - Adjustments have been made to the average number of notifications the Agency anticipates receiving during the clearance period for this ICR based on the average number of notifications the Agency has received annually over the past few years, as tallied by EPA PCB Regional Coordinators. A majority of these notifications have been decreasing, but regional offices have seen an increase in item #17, which are requests for risk-based disposal or storage of PCB bulk product waste. The additional 10 approval requests increased the burden by 16,000 hours. The cumulative adjustment, after accounting for decreasing submissions for other approval requests, is an increase of 2,186 hours.

Item number 7 - The approval for the latest 5-year storage period ends in 2008, which will occur during this ICR period. As such, the estimated annual burden of 1,038 hours has been added.

Item numbers 22 and 25 - The number of respondents submitting new applications for commercial storage approvals increased from 10 new applications to 12 based on the number of applications the Agency has received over the past few years.  The weighted average to prepare new and renewal application increases from 220 hours to 240 hours due to the increased time to prepare new applications compared to preparing paperwork for facility modifications [(392 hrs x 12) + (100 hrs x 13)]/25.  The increase ratio of new applications to modifications increased the burden by 740 hours.

Item numbers 41, 84, 88, 92, and 99 - The reduced estimate for the number of commercial storage facilities and increased number of chemical waste landfills was based on the most recent EPA data in PADS (U.S. EPA, 2006).  With the significant drop in companies, the total labor burden decreased by 86,459 hours.

Item numbers 52, 67, 68, 97, and 98 - An overview of NRC data indicates that the number of calls involving reports of fire incidents and PCB spills decreased slightly.  This resulted in a decreased burden of 204 hours.

Item numbers 60, 79, and 95 - The number of R&D facilities increased from 26 to 39 facilities. The cumulative hourly burden increase based on this change is +13 hours for #60; +156 hours for # 79; and +156 hours for # 95 (+325-hr adjustment).

Item number 65 - The total number of Items, Containers, and Article Containers increased by 2000 items to correct a typo in the previous ICR. This results in a burden increase of 166 hours.

Item numbers 68a, 74c, 74d, and 75 - Revised estimate for the total number of units reclassified is based on information gathered for Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors (U.S. EPA, 2004b).  The number of Transformers reclassified is reduced from 6,125 to 672 units, resulting in a decrease in the cumulative hourly burden of 2,803 hours.

Item numbers 69, 70, 71, 101, and 102 - The number of items that must be included on manifests, the number of consolidated manifests sent from storers to disposers, the number of Certificates of Disposal sent to generators, and the number of manifests and Certificates maintained on file have been revised based on new data compiled in the PCB Annual Report (U.S. EPA, 2005b). The total number of Certificates of Disposal sent to generators was reduced and is based on the average number of items disposed of (from the Annual Report) and assuming that each Certificate contains information on about 20 items.  The records that must be maintained are the same as the number of manifests or shipping papers and Certificates of Disposal.  The cumulative hourly burden decreased by 4,199 hours.

Item numbers 74a and 74b - The decreased estimated total for the number of transformers that need to be inspected is based on data compiled for Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors (U.S. EPA, 2004b) and the PCB Annual Report (U.S. EPA, 2005b), which results in a burden decrease of 39,841 hours.

TABLE 6-11

CHANGES IN BURDEN HOURS TO EXISTING PCB ICR TOTALS

Item

Numbers

Change in Burden Hours

Item

Numbers

Change in Burden Hours

3 and 7

+1,304 hours

60, 79 and 95

+325 hours

4, 9, 12 to 18, 23, 24, 42, and 46 to 49

+2,186 hours

65

+166 hours

22 and 25

+740 hours

68a, 74c, 74d, and 75

-2,803 hours

41, 84, 88, 92, and 99

-86,459 hours

69, 70, 71, 101, and 102

-4,199 hours

52, 67, 68, 97, and 98

-204 hours

74c and 74d

-39,841 hours

Total  -128,785 hours

There is a 62-hour difference between the change in the burden based on adjustments (128,785 hours, Table 6-11) compared with the difference between the OMB inventory and the total burden indicated on Table 6-10 (824,778 - 696,055 = 128,723 hours).  This difference can be attributed both to rounding off figures and the margin of error associated with the vast number of calculations that have been factored into this analysis.

6(g)	Burden Statement

The annual public burden for this collection of information, which is approved under OMB Control No. 2070-0112, is estimated to average 1.21 hours per response.  According to the Paperwork Reduction Act, “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.  For this collection it 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.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.

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. EPA-HQ-OPPT-2007-0273.  The docket is available for public viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC).  The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC.  The EPA/DC 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 EPA/DC Public Reading Room is<PHONE_NUMBER>, and the telephone number for the Pollution Prevention and Toxics Docket is<PHONE_NUMBER>.  An electronic version of the public docket is available through the Federal Docket Management System (FDMS) at   HYPERLINK "http://www.regulations.gov"  www.regulations.gov .  Use FDMS 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 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. EPA-HQ-OPPT-2007-0273 and OMB Control Number 2070-0112 in any correspondence.

REFERENCES

BLS, 2006.  Employer Costs For Employee Compensation: Table 9. Private Industry, Goods-Producing and Service-Producing Industries, by Occupation, September 2006. Bureau of Labor Statistics, U.S. Department of Labor: Washington, DC, December 13, 2006. http://www.bls.gov/news.release/ecec.t09.htm.

Davis, 2003.  Telephone conversation between Mary Davis, PCB Committee Chair.  Utility and Solid Waste Advisory Group (USWAG) and Carol Wendel, Eastern Research Group.  October 22.

Lacey, 2003.  Telephone conversation between Pamela Lacey, PCB Coordinator, American Gas Association, Washington, DC, and Carol Wendel, Eastern Research Group.  October 21.

Eastern Research Group (ERG), 2000.  Memorandum Regarding Revisions to PCB Consolidated ICR Statement, to Peggy Reynolds, U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics.  October 26.

ERG, 1993.  Assessment of the Benefits of the Proposed Standard on Electric Power Generation, Transmission, and Distribution.  Prepared for the Occupational Safety and Health Administration.

Orton, 2003.  Telephone conversation with Tim Orton, Environmental Manger, EnviroCare, Salt Lake City, UT, and Carol Wendel, Eastern Research Group.  October 24.

Rice, 2002.  Cody Rice. Wage Rates for Economic Analysis of the Toxics Release Inventory Program.  Washington, DC: U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, June 10.

U.S. Coast Guard, 2007.  National Response Center.  Query/Download NRC Data.  (http://www.nrc.uscg.mil/foia.html).  January 16.

U.S. EPA, 2006.  PCB Activity Database System (PADS).  (http://www.epa.gov/pcb/pubs/data.html).  November.

U.S. EPA, 2005a.  Commercially Permitted PCB Disposal Companies.  (http://www.epa.gov/pcb/pubs/stordisp.htm).  December.

U.S. EPA, 2005b.  PCB Annual Report 2004.  Environmental Protection Agency, Office of Pollution Prevention and Toxics, Washington, DC.  November 8.

U.S. EPA, 2005c.  Commercial Storage Approvals Issued under §761.65(d).  (http://www.epa.gov/pcb/pubs/comstor.html).  March.

U.S. EPA, 2004a. Supporting Statement. PCBs, Consolidated Reporting and Recordkeeping Requirements. OMB Control No: 2070-0112, EPA ICR No: 1446.08, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Washington, DC: November.

U.S. EPA, 2004b. Appendix A: Data Acquisitions Report for an Economic Analysis of Phasing Out PCB Transformers and Large Capacitors, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Washington, DC: December.

U.S. EPA, 2004c.  Scrap Metal Recovery Oven Notifications (§761.72(a)).  (http://www.epa.gov/pcb/pubs/oven.html).  May.

U.S. EPA, 2003.  Draft Analysis of the Cost Impacts of Potential Amendments to the PCB Regulations at 40 CFR 761, September.

U.S. EPA, 2000.  United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.  Reclassification of PCB and PCB-Contaminated Electrical Equipment Rule: Supporting Analysis for Small Entity, Environmental Justice, and Unfunded Mandates Certifications.  September 28.

U.S. EPA, 1998a.  United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.  Data Gathering Report for the Combined ICR Supporting Statement Covering the PCB Regulations at 40 CFR 750 and 761.  August 17.

U.S. EPA, 1998b.  United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.  Cost Impacts of the Final Regulations Amending the PCB Regulations at 40 CFR Part 761.  April 30.

U.S. EPA, 1998c.  United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.  ICR Supporting Statement for the Final Regulations Amending the PCB Regulations at 40 CFR 761 (ICR 1729).

U.S. EPA, 1998d.  United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.  PCB Reclassification Rule: Small Entity Impacts, Environmental Justice Impacts, and Unfunded Mandates Analysis.  March 3.

U.S. EPA, 1989.  U.S. Environmental Protection Agency, Office of Toxic Substances.  Regulatory Impact Analysis of Proposed Options for Notification and Manifesting of PCB-Containing Wastes.  EPA Contract No.  68-02-4235.  July 28.

U.S. EPA. Supporting Statement.  Polychlorinated Biphenyls (PCBs):   Manufacturing, Processing, and Distribution in Commerce Exemptions; ICR 857.

U.S. EPA. Supporting Statement.  PCB Use in Electrical Equipment and Transformers; ICR #1000; OMB Control No. 2070-0003.

U.S. EPA. Supporting Statement.  Polychlorinated Biphenyls (PCBs); Exclusions, Exemptions, and Use Authorizations; ICR #1001.06; OMB Control No. 2070-1001.

U.S. EPA. Supporting Statement.  PCB Disposal Permitting Regulation; EPA ICR #1012.

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U.S. EPA. Supporting Statement.  Combination/renewal of two existing ICRS: Polychlorinated Biphenyls (PCBs) Use, Storage, and Disposal Recordkeeping Requirements; EPA ICR #583 and PCBs: Notification and Manifesting for PCB Waste Activities; EPA ICR #1446.

U.S. EPA. Supporting Statement.  Import of PCB Wastes for Disposal, EPA ICR #1770.01; OMB Control No. 2070-0149.

U.S. OPM, 2006.  Salary table 2006-GS; 2006 General Schedule.  U.S. Office of Personnel Management, Washington, DC.  January. Available at www.opm.gov/oca/06tables/indexGS.asp

 PAGE

TABLE 6-2, continued

REPORTING BURDENS UNDER TSCA SECTION 6(e):  ICR 1446.09, SECTION 6(a)

TABLE 6-3, continued

THIRD-PARTY REPORTING BURDENS UNDER TSCA SECTION 6(e): ICR 1446.09, SECTION 6(a)

TABLE 6-4, continued

RECORDKEEPING BURDENS UNDER TSCA SECTION 6(e): ICR 1446.09, SECTION 6(a)

TABLE 6-4, continued

RECORDKEEPING BURDENS UNDER TSCA SECTION 6(e): ICR 1446.09, SECTION 6(a)

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