SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 1442.22

“LAND DISPOSAL RESTRICTIONS” 

February 2014
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1 (a) TITLE AND NUMBER OF THE INFORMATION COLLECTION................................ 3

1 (b) CHARACTERIZATION OF THE INFORMATION COLLECTION .............................. 3

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION .................................................... 4

2(b) USE AND USERS OF THE DATA................................................................................... 8

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION....................................................................................................... 10

3(b) PUBLIC NOTICE............................................................................................................. 11

3(c) CONSULTATIONS ......................................................................................................... 11

3(d) EFFECTS OF LESS FREQUENT COLLECTION.......................................................... 11

3(e) GENERAL GUIDELINES ............................................................................................... 12

3(f) CONFIDENTIALITY ...................................................................................................... 12

3(g) SENSITIVE QUESTIONS ............................................................................................... 12

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND SIC/NAICS CODES .................................................................. 12

4(b) INFORMATION REQUESTED ...................................................................................... 12

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES................................................................................................... 31

5(b) COLLECTION METHODOLOGY AND MANAGEMENT.......................................... 35

5(c) SMALL ENTITY FLEXIBILITY .................................................................................... 35

5(d) COLLECTION SCHEDULE............................................................................................ 35

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT HOURS......................................................................... 38

6(b) ESTIMATING RESPONDENT COSTS.......................................................................... 38

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN.............................................. 40

6(d) RESPONDENT UNIVERSE AND TOTAL RESPONDENT 

HOUR AND COST BURDEN......................................................................................... 40

6(e) BOTTOM LINE HOUR AND COST BURDEN............................................................. 47

6(f) REASONS FOR CHANGE IN BURDEN ....................................................................... 48

6(g) BURDEN STATEMENT ................................................................................................. 48

EXHIBITS .............................................................................................................................................50-63
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1 (a) TITLE AND NUMBER OF THE INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “Land Disposal Restrictions (Renewal),” 

EPA ICR Number 1442.22, OMB ICR Number 2050-0085. 

1 (b) CHARACTERIZATION OF THE INFORMATION COLLECTION

The Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous 

and Solid Waste Amendments of 1984 (HWSA), regulates hazardous waste management activities, 

including generation, treatment, storage, and disposal of hazardous wastes. Section 3004(d), (e), and (g) 

of RCRA authorizes the U.S. Environmental Protection Agency (EPA) to promulgate regulations that 

prohibit the land disposal of hazardous waste unless it meets specified treatment standards or is disposed 

of in a land disposal unit that satisfies the “no-migration” standard. The statute specifies dates when 

particular groups of hazardous wastes are prohibited from land disposal (except in no-migration units).

Under this authority, EPA’s Office of Resource Conservation and Recovery (ORCR) has 

developed the land disposal restrictions (LDR) program. The LDR program is codified at 40 CFR Part 

268. Under Part 268, OSW has established treatment standards for hazardous wastes. It has established 

minimum technical standards for managing restricted wastes, such as requirements for waste 

characterization and waste tracking (i.e., notifications/certifications). It also has established variances, 

case-by-case extensions to the effective date, and other mechanisms that provide flexibility in 

administering the LDR program.

To receive a variance from the hazardous waste land disposal prohibitions, owner/operators of 

hazardous waste storage or disposal facilities may petition EPA to allow land disposal of a specific 

restricted waste at a specific site. If EPA grants the variance, the waste is no longer prohibited from land 

disposal in that particular unit. If the owner/operator fails to make this demonstration, or chooses not to 

petition for the variance, best demonstrated available technology (BDAT) requirements of 40 CFR 268.40 

et seq must be met before the hazardous wastes are placed in a land disposal unit.
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2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

This section describes the need and authority for each type of information collection included in 

this ICR.

(1) Treatment Surface Impoundment Exemption

RCRA Section 3005(j)(1) provides that, except as provided in RCRA Section 3005(j)(2)-(4), each 

interim-status surface impoundment shall not receive, store, or treat hazardous waste after the date four 

years after such date of enactment unless such surface impoundment is in compliance with the 

requirements of Section 3004(o)(1)(A), which would apply to such impoundment if it were new. Under 

this section, EPA promulgated 40 CFR 268.4, which provides that wastes that would otherwise be 

prohibited from one or more methods of land disposal may be treated in a surface impoundment that 

meets certain technological requirements as long as treatment residuals that do not meet the applicable 

treatment standard (or statutory prohibition levels where no treatment standards are established) are 

removed for subsequent management within one year of entry into the impoundment and the wastes are 

not placed into any other surface impoundment. The owner/operator must certify to EPA that the 

technical requirements have been met and must also submit a copy of the waste analysis plan. EPA 

believes the information collection requirements in section 268.4 are essential in certifying to EPA that 

treatment surface impoundments meet minimum technical standards and that wastes are characterized and 

managed in accordance with the approved waste analysis plan and accepted methods.

(2) Procedures for Case-by-Case Extension

Under RCRA Section 3004(h), EPA can grant case-by-case extensions of the prohibition 

effective dates for up to one year beyond the applicable deadlines; extensions are renewable once for up 

to one additional year. [Under section 268.5, the Agency will consider granting up to a one-year 

extension (renewable only once) of a prohibition effective date on a case-by-case basis. The requirements 

outlined in section 268.5 must be satisfied, including, among other things, a demonstration that adequate 

alternative treatment, recovery, or disposal capacity for the petitioner’s waste cannot reasonably be made 

available by the effective date due to circumstances beyond the applicant’s control and that the petitioner 

has entered into a binding contractual commitment to construct or otherwise provide such capacity.] EPA 

needs the information in section 268.5 to ensure that the extension is justified and that the applicant is 

taking appropriate steps in obtaining needed capacity and in managing the waste. 
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(3) Waste Analysis and Recordkeeping

(a) Generator Waste Analysis and Recordkeeping

RCRA Section 3002(a) authorizes EPA to establish requirements for generators respecting, 

among other things, recordkeeping practices that accurately identify the quantities of hazardous wastes 

generated, the constituents thereof, and the disposition of such wastes. EPA is also authorized to develop 

standards for the use of a manifest system and any other reasonable means necessary to assure that all 

such hazardous waste generated is designated for treatment, storage or disposal. EPA believes that the 

one-time LDR tracking requirement is essential in tracking restricted hazardous wastes from cradle to 

grave, thereby ensuring that threats are minimized. The notices and certifications ensure that the shipper 

and receiving facility are held accountable for proper characterization and management of the waste. 

Because the notification and, if applicable, certifications are required only for the initial shipment of 

waste from the generator, and only must be updated when specified, EPA further believes that its LDR 

tracking requirements place a minimal burden on generators.

As of the November 22, 1989 proposed Third Third rule, treatment of prohibited wastes 

conducted in so-called 90-day tanks, containers, and containment buildings regulated under section 

262.34 had not been subject to a waste analysis plan requirement. Thus, there was no regulatory vehicle 

for determining testing frequency in such circumstances. In contrast, under section 268.7(b), treatment 

facilities treating prohibited wastes were required to test the treatment residues that they generate at a 

frequency determined by their waste analysis plan in order to ascertain compliance with all applicable 

standards. In order to close the gap, EPA promulgated section 268.7(a)(5) in the Third Third final rule 

(55 FR 22687). Section 268.7(a)(5) requires that generators treating prohibited wastes in tanks, 

containers, and containment buildings must prepare a plan which describes the procedures to be carried 

out to comply with the treatment standards. Section 268.7(a)(5) assists generators in verifying whether 

their wastes meet appropriate treatment levels.

(b) Treatment Facility Waste Analysis and Recordkeeping

RCRA Section 3004(a) authorizes EPA to develop standards for owner/operators of TSDFs 

respecting (but not limited to) treatment of all such waste received by the facility pursuant to such 

operating methods, techniques, and practices as may be satisfactory to EPA. EPA believes it is important 

for treatment and disposal facilities to periodically test their waste in order to, among other things, 

corroborate information provided by the off-site facility delivering the waste and to ensure that the treated 

waste meets the applicable treatment standards. As required under section 268.7(b)(1)-(2), treatment 

facilities must conduct periodic detailed physical and chemical analyses of their waste streams to assure 

that the appropriate 40 CFR Part 268 treatment standards are being met. 

RCRA Section 3004(a) also authorizes EPA to develop standards for owner/operators of TSDFs 

respecting (but not limited to) maintaining records of all hazardous waste that is treated, stored, or 

disposed of, as the case may be, and the manner in which such wastes were treated, stored or disposed of. 

EPA believes it is essential that generators and TSDFs conduct one-time LDR tracking in order to track 

hazardous wastes from cradle to grave to ensure that threats are minimized. The notices and certifications 

ensure that the shipper and receiving facility are held accountable for proper characterization and 

management of the waste. Because the notifications and certifications are required only for the initial 

shipment, and only must be updated when specified, EPA believes that the LDR tracking requirements 

place a minimal burden on treaters.
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(c) Land Disposal Facility Waste Analysis and Recordkeeping

RCRA Section 3004(a) authorizes EPA to develop standards for owner/operators of TSDFs 

respecting (but not limited to) maintaining records of all hazardous waste that is treated, stored, or 

disposed of, as the case may be, and the manner in which such wastes were treated, stored or disposed of. 

As required under section 268.7(c)(1), land disposal facilities must keep records of one-time notices and 

certifications transmitted from generators and treatment facilities. As required under section 268.7(c)(2), 

land disposal facilities must conduct periodic detailed physical and chemical analyses of their waste 

streams to assure that the appropriate 40 CFR Part 268 treatment standards are being met. EPA believes 

such requirements are needed to ensure that the land disposal facility is notified of the applicable 

treatment standards and corroborates generator and treater information through periodic testing.

(d) Hazardous Debris Requirements

RCRA Sections 3002 and 3004 authorize EPA to promulgate regulations establishing standards 

applicable to hazardous waste generators and TSDFs, respectively, respecting (among other things) 

recordkeeping practices for their hazardous waste. Under this authority, EPA promulgated section 

268.7(d), requiring generators or treaters who first claim that hazardous debris is excluded from the 

definition of hazardous waste under section 261.3(f) to submit a one-time notification to EPA or the 

authorized State. The notification must be updated if the debris is shipped to a different facility, and, for 

debris excluded under section 261.3(f)(1), if a different type of debris is treated or if a different 

technology is used to treat the debris. Such requirements are needed to ensure that the generator or treater 

notifies EPA or authorized State of the claim and to hold the generator or treater accountable for proper 

management of the debris.

(e) Contaminated Soil Requirements

Under RCRA Section 3004, EPA established LDR treatment standards for contaminated soil. 

EPA also created provisions at section 268.7(e) under which generators and treaters who first receive 

from EPA or an authorized State a determination that a given contaminated soil subject to the LDRs as 

provided in section 268.49(a) no longer contains a listed hazardous waste and generators and treaters who 

first determine that a contaminated soil no longer exhibits a characteristic of hazardous waste must 

prepare a one-time only documentation of these determinations. They also must maintain this 

information in their files and other records for a minimum of three years. EPA believes such 

recordkeeping is needed for generators and treaters to demonstrate (e.g., to on-site inspectors) that their 

soils no longer contain the listed waste or exhibit a characteristic.

(f) Special Rules for Characteristic Wastes

In the Third Third final rule (55 FR 22688), EPA amended the tracking requirements for 

characteristic wastes that no longer exhibit a characteristic. EPA believed that, under the previous 

tracking system, sending the tracking forms to Subtitle D facilities could have counterproductive effects, 

and determined that the tracking forms should not accompany shipments from the generator to the 

Subtitle D facility. Because of this, EPA amended section 268.9, providing that a one-time notification 

and certification should be placed in the generator’s or treater’s files, sent to EPA or authorized State, and 

updated as needed. This simplified tracking system reduces the burden to the generators and treaters, 

while at the same time provides a self-regulating mechanism to track these wastes.

(4) Demonstration for Alternative Treatment Technology
7

RCRA Section 3004(m) provides that, if a hazardous waste has been treated to the applicable 

treatment level or by a specified method, such waste or residue shall not be subject to any prohibition 

promulgated under subsections (d), (e), (f), or (g) and may be disposed of in a land disposal unit that 

meets certain requirements. EPA acknowledges that, in special situations, a specified method may not be 

the most appropriate technology for treating the waste. Therefore, 40 CFR 268.42 provides that any 

person may submit an application to EPA demonstrating that an alternative treatment method can achieve 

a measure of performance equivalent to that achievable by methods specified in section 268.40. The 

contents of the application, as required by section 268.42, are essential for allowing EPA to evaluate the 

treatment effectiveness of the technology and whether it is protective of human health and the 

environment.

(5) Demonstration for a Variance from a Treatment Standard

RCRA Section 3004(m) provides that, simultaneously with the promulgation of regulations under 

subsections (d), (e), (f), and (g) prohibiting one or more methods of land disposal of a particular 

hazardous waste, EPA shall promulgate regulations specifying those levels or methods of treatment, if 

any, which substantially diminish the toxicity of the waste or substantially reduce the likelihood of 

migration. Although EPA believes that most types and amounts of hazardous waste can be treated to

appropriate concentration levels, EPA recognizes that there may be cases where the levels cannot be 

achieved for a particular hazardous waste. In particular, in the Phase II final rules, EPA reinforced its 

position that hazardous soils would continue to be subject to the LDR treatment standards that apply to 

the hazardous wastes with which the soils are contaminated. However, the Agency acknowledges that the 

treatment standards for as-generated wastes are generally inappropriate or unachievable for soils

contaminated with these wastes, within the meaning of 40 CFR 268.44(a). For this reason, the Agency 

has indicated that treatability variances may be warranted for many hazardous soils. Therefore, 40 CFR

268.44 provides that, where the treatment standard is expressed as a concentration in a waste or waste 

extract and a waste cannot be treated to the specified level, or where the treatment technology is not 

appropriate to the waste, the generator or treatment facility may petition EPA for a variance from the 

treatment standard. The contents of the petition, as required by section 268.44, are essential for allowing 

EPA to evaluate if: (1) it is not physically possible to treat the waste to the specified level or by the 

specified method; (2) it is inappropriate to require the waste to be treated to the specified level or by the 

specified method, even though such treatment is technically possible; (3) for contaminated soil, treatment 

to the specified level or by the specified method would result in concentrations of hazardous constituents 

that are below protective levels; (4) for contaminated soil only, treatment to the specified level or by the 

specified method would result in concentrations of hazardous constituents that are below natural 

background concentrations at the site where the soil will be land disposed.

(6) Recordkeeping for Storage Prohibition

RCRA Section 3004(j) requires that, in the case of any hazardous waste which is prohibited from 

one or more methods of land disposal, the storage of such hazardous waste is prohibited unless such 

storage is solely for the purpose of the accumulation of such quantities of hazardous waste as are 

necessary to facilitate proper recovery, treatment, or disposal. 40 CFR 268.50(a) requires that, except as 

provided in section 268.50, the storage of hazardous wastes restricted from land disposal under Subpart C 

of Part 268 or RCRA Section 3004 is prohibited, unless the conditions of section 268.50(a) are met. 

Section 268.50(a)(2) requires that an owner/operator of a hazardous waste treatment, storage, or disposal 

facility must store such wastes in tanks, containers, or containment buildings solely for the purpose of the 

accumulation of such quantities of hazardous waste as necessary to facilitate proper recovery, treatment, 
8

or disposal. Under section 268.50(a)(2), an owner/operator of a tank must clearly mark it with a 

description of its contents, the quantity of each hazardous waste received, and the date each period of 

accumulation begins, or keep such information in the operating record at the facility, so that the facility 

(and EPA, if it desires), can track how long the waste has been in storage. These records are essential to 

hold the owner/operator accountable for legitimately storing the waste for accumulation in accordance 

with section 268.50.

(7) No-Migration Variances

40 CFR 268.6 allows owner/operators of hazardous waste storage or disposal facilities to petition 

the EPA to allow land disposal of a specific restricted waste at a specific site. The EPA Regional Offices 

review these petitions to determine if they successfully demonstrate "no migration." The applicant must 

demonstrate that hazardous wastes can be managed safely in a particular land disposal unit, so that "no 

migration" of any hazardous constituents occurs from the unit for as long as the waste remains hazardous. 

If EPA grants the variance, the waste is no longer prohibited from land disposal in that particular unit. 

2(b) USE AND USERS OF THE DATA

(1) Treatment Surface Impoundment Exemption

Under 40 CFR 268.4, wastes which are otherwise prohibited from land disposal under Part 268 

may be treated in a surface impoundment or series of impoundments provided that surface impoundment 

meets certain technological requirements and that the treatment residuals that do not meet the applicable 

treatment standard are removed for subsequent management within one year of entry and the wastes are 

not placed into any other surface impoundment. The owner/operator must also comply with the other 

section 268.4 requirements. Section 268.4(a)(3) provides that the impoundment must meet the design 

requirements of section 264.221(c) or 265.221(a), except if the unit is exempted pursuant to section 

264.221(d) or (e) or to section 265.221(c) or (d) or if the owner/operator applies to EPA for a waiver or 

modification of the requirements. EPA will review and evaluate the application based on the criteria 

outlined in the section (e.g., minimum technical design standards). EPA examines the application’s 

contents to evaluate if the design and operation of the surface impoundments, along with other relevant 

factors, will be protective of human health and the environment.

(2) Procedures for Case-by-Case Extension

Under 40 CFR 268.5, the Agency will consider granting up to a one-year extension (renewable 

only once) of a prohibition effective date on a case-by-case basis. The requirements outlined in section 

268.5 must be satisfied, including, among other things, a demonstration that adequate alternative 

treatment, recovery, or disposal capacity for the petitioner’s waste cannot reasonably be made available 

by the effective date due to circumstances beyond the applicant’s control and that the petitioner has 

entered into a binding contractual commitment to construct or otherwise provide such capacity. EPA 

examines the information in the petition to determine if the extension is truly warranted, that the 

owner/operator has taken appropriate steps in obtaining needed capacity, and that the waste will be 

managed in accordance with approved standards. 
9

(3) Waste Analysis and Recordkeeping

(a) Generator Waste Analysis and Recordkeeping

The waste determination and waste tracking requirements for generators under section 268.7(a) 

ensure that generators properly characterize their waste under Part 268 and notify treaters and land 

disposal facilities on the restricted waste (e.g., whether it meets the applicable standards). Generators 

must also certify to the land disposal facility, if applicable, that the waste meets the applicable treatment 

levels. Generators must keep records of all notices, certifications, demonstrations, and waste analysis 

data for their own purposes. In this regard, generators use the notices and certifications to inform the 

receiving facility whether the waste meets applicable treatment standards. EPA may request the waste 

characterization and/or tracking information during an on-site inspection to verify the generator’s 

compliance with the LDR requirements.

(b) Treatment Facility Waste Analysis and Recordkeeping

Treatment facilities use the waste analysis data and waste tracking documents to ensure that the 

treated waste meets applicable treatment standards, to notify the land disposal facility of the waste (e.g., 

waste type) and, if applicable, to certify to the land disposal facility that the waste meets applicable 

treatment standards.

(c) Land Disposal Facility Waste Analysis and Recordkeeping

Land disposal facilities use the waste analysis data and waste tracking documents to corroborate 

the information sent from generators and treatment facilities. Land disposal facilities must keep records 

of notices and certifications for their own purposes, although EPA may also want to review the facilities’ 

files.

(d) Hazardous Debris Requirements

Facilities managing hazardous waste (including debris) use notifications and certifications to 

ensure that wastes are properly shipped, treated, disposed of, and tracked. Although the facilities 

themselves are the primary users of these records, EPA may review the files during a facility inspection to 

make sure that proper records of wastes are being kept.

(e) Contaminated Soil Requirements

On-site EPA or State inspectors use the information kept in the generator’s or treater’s files, 

pursuant to section 268.7(e), to verify that the generator’s or treater’s soil no longer contains the listed 

waste or exhibits a characteristic, as determined by EPA (for listed waste) or the generator or treater (for 

characteristic waste). 

(f) Special Rules for Characteristic Wastes

Section 268.9(d) provides that generators or treaters need only keep records of and submit to EPA 

a one-time notification and certification for characteristic wastes that no longer exhibit a characteristic. 

These records must be updated as needed. These records are used by facilities and EPA to track wastes 

that are sent to Subtitle D facilities.
10

(4) Demonstration for Alternative Treatment Technology

40 CFR 268.42 provides that any person may submit an application to EPA demonstrating that an 

alternative treatment method can achieve a measure of performance equivalent to that achievable by 

methods specified in section 268.42(a), (c), and (d). This provision provides flexibility for generators or 

treaters who wish to propose an alternative treatment method. EPA reviews the contents of the 

application to evaluate the treatment effectiveness of the technology and whether it is protective of human 

health and the environment.

(5) Demonstration for a Variance from a Treatment Standard

40 CFR 268.44 provides that, where the treatment standard is expressed as a concentration in a 

waste or waste extract and the waste cannot be treated to the specified level, or where the treatment 

technology is not appropriate to the waste, the generator or treatment facility may petition EPA for a 

variance from the treatment standard. This provision provides flexibility for generators or treaters who 

cannot meet the standard to petition EPA for a variance. EPA reviews the contents of the petition to 

evaluate if: (1) it is not physically possible to treat the waste to the specified level or by the specified 

method; (2) it is inappropriate to require the waste to be treated to the specified level or by the specified 

method, even though such treatment is technically possible; (3) for contaminated soil, treatment to the 

specified level or by the specified method would result in concentrations of hazardous constituents that 

are below protective levels; (4) for contaminated soil only, treatment to the specified level or by the 

specified method would result in concentrations of hazardous constituents that are below natural 

background concentrations at the site where the soil will be land disposed.

(6) Recordkeeping for Storage Prohibition

40 CFR 268.50(a) requires that, except as provided in section 268.50, the storage of hazardous 

wastes restricted from land disposal under Subpart C of Part 268 or RCRA Section 3004 is prohibited, 

unless the conditions of section 268.50(a) are met. Section 268.50(a)(2) requires that an owner/operator 

of a hazardous waste treatment, storage, or disposal facility must store such wastes in tanks, containers, 

and containment buildings, solely for the purpose of the accumulation of such quantities of hazardous 

waste as necessary to facilitate proper recovery, treatment, or disposal. Under section 268.50(a)(2), an 

owner/operator of a tank must clearly mark it with a description of its contents, the quantity of each 

hazardous waste received, and the date each period of accumulation begins, or keep such information in 

the operating record at the facility. Such information is used by the facility and EPA (if EPA requests 

such information) in order to keep track of the amount and type of waste and the duration of storage for 

each tank.

(7) No-Migration Variances

The EPA Regional Offices will review the petitions and determine if they successfully 

demonstrate "no migration" as specified at 40 CFR 268.6.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION
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The information collected under this ICR is not available from any source other than respondents. 

EPA’s Office of Solid Waste is the only office within the Agency requiring the recordkeeping or 

reporting of this information. No other Federal agency or department collects this information. 

3(b) PUBLIC NOTICE

In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the 

Federal Register on December 10, 2013 (78 FR 74127). The public comment period extended through 

February 10, 2014. EPA received 10 comments on this ICR in response to the Federal Register notice.

3(c) CONSULTATIONS/RESPONSE TO COMMENTS

In renewing this ICR, EPA felt its burden estimates were sound, however, the comments received 

indicated the lab pack estimates were too low. The American Chemical Society’s Task Force on 

Laboratory Chemical and Waste Management commented on the burden estimates in the ICR with 

regards to lab packs. The other nine comments were in support of ACS’s comments. 

ACS was concerned that the burden estimates for the ICR did not include lab packs from 

academic laboratories, since the NAICs code is not listed among the top 50 for hazardous waste 

generation. The universe estimates for this ICR were derived from the RCRAInfo database. The data in 

RCRAInfo comes from permit information; from the biennial Hazardous Waste Report (BR), which is a 

comprehensive survey of all hazardous waste generators that are large quantity generators; and the 

Notification form (Site ID), which every generator of hazardous waste (large or small) is required to fill 

out. However, EPA acknowledges that only BR data was used to generate the number of lab packs. 

According to the estimates developed for the “Alternative Requirements for Hazardous Waste 

Determination and Accumulation of Unwanted Material at Laboratories Owned by Colleges and 

Universities and Other Eligible Academic Entities Formally Affiliated With Colleges and Universities”

final rule, (December 1, 2008 (73 FR 72912)), there are 1,183 non-LQG academic laboratories that 

generate hazardous waste.

Based on consultations with industry, this ICR assumed that there would be one LDR notification 

required for 15 lab packs. The ACS’s comment, and consultations with other commenters, indicate that 

for academic labs there is a separate LDR notification for each lab pack. EPA acknowledges that the 

initial consultations were with industrial labs, and did not include academic labs. ACS’s comment 

verified the burden estimates for amount of time to prepare the form, review, sign and make copies.

EPA considered ACS’s comments, and after consultation with the Environmental Technology 

Council, has increased the estimated number of lab packs treated each year, as well as the cost. These 

burden estimates can be found in exhibit 3.

3(d) EFFECTS OF LESS FREQUENT COLLECTION

The vast majority of the paperwork under the LDR program is collected on a one-time basis; 

hence, the frequency of these collections cannot be reduced. For example, EPA modified the LDR 

regulations to decrease the frequency by which LDR notices and certifications are transmitted. This 

decrease in the collection frequency was accomplished by requiring that respondents only send one-time 

notices and certifications with their initial shipment and that these documents be updated only as needed. 

Previously, EPA had required that respondents send appropriate notifications and certifications for each 
12

shipment. EPA believes that these modifications allow for proper tracking and record keeping of 

hazardous waste while protecting human health and the environment. 

On April 4, 2006, EPA published a final rulemaking that reduced the recordkeeping and reporting 

burden RCRA imposes on the States, the public, and the regulated community (71 FR 16863). This rule 

did not substantially reduce the burden for this ICR, but it did eliminate obsolete terms and clarified 

certain aspects of the LDR regulations.

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the Paperwork Reduction Act of 1995, OMB’s 

implementing regulations, applicable OMB guidance, and EPA’s ICR Handbook.

3(f) CONFIDENTIALITY

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which define EPA’s general policy on 

the public disclosure of information, contain provisions for confidentiality that EPA follows under the 

RCRA program. EPA also ensures that the information collection procedures comply with the Privacy 

Act of 1974 and OMB Circular 108.

3(g) SENSITIVE QUESTIONS

No questions of a sensitive nature are included in any of the LDR information collection 

requirements.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

Hazardous waste generators, treaters, and disposers must comply with the LDR program’s 

paperwork requirements, as applicable. Following is a list of North American Industry Classification 

System (NAICS) codes associated with waste handlers that may be affected by information collection 

requirements covered in this ICR:

Industrial Sector NAICS Code(s)

Agriculture, Forestry, Fishing, and Hunting 11

Mining 21

Utilities 22

Construction 23

Manufacturing 31-33

Wholesale Trade 42

Retail Trade 44-45
13

Industrial Sector NAICS Code(s)

Transportation and Warehousing 48-49

Information 51

Waste Management and Remediation Services 562

Public Administration 92

4(b) INFORMATION REQUESTED

(1) Treatment Surface Impoundment Exemption (Section 268.4)

(a) Recordkeeping (Section 268.4(a)(2)(iv)) 

40 CFR 268.4(a) provides that wastes which are otherwise prohibited from land disposal under 

Part 268 may be treated in a surface impoundment or series of impoundments provided that the 

owner/operator complies with section 268.4(a). Section 268.4(a)(2)(iv) requires that the procedures and 

schedule for the following items must be specified in the facility’s waste analysis plan as required under 

section 264.13 or section 265.13: (1) sampling of impoundment contents, (2) the analysis of test data, (3) 

the annual removal of residues which are not delisted under section 260.22 or which exhibit a 

characteristic of hazardous waste and either do not meet the applicable treatment standards of Part 268, 

Subpart D, or where no treatment standards have been established. Such residues are prohibited from 

land disposal under section 268.32, RCRA Section 3004(d), or under section 268.33(f). [The section 

268.4(a)(2)(iv) recordkeeping requirement and associated burden hours are addressed in the “General 

Hazardous Waste Facility Standards,” EPA ICR Number 1571 for interim-status facilities and the “Part B 

Permit Application, Permit Modifications, and Special Permits,” EPA ICR Number 1573 for permitted 

facilities and facilities seeking initial permits.] 

(b) Application for Exemption (Section 268.4(a)(3)(ii) and (iii)) 

Section 268.4(a)(3) requires that a surface impoundment must meet the design requirements of 

section 264.221 (c) or section 265.221 (a), regardless of whether the unit is new, expanded, or a 

replacement, and be in compliance with applicable ground-water monitoring requirements of Subpart F of 

40 CFR Part 264 or 265, unless the owner/operator makes a demonstration in accordance with section 

268.4(a)(3)(i)-(iii).
14

(i) Data Item:

 A demonstration showing that either:

- Under section 268.4(a)(3)(i), the unit is exempted pursuant to section 264.221 (d) 

or (e), or to section 265.221 (c) or (d). [Development and delivery of the 

demonstration referenced in section 268.4(a)(3)(i) and associated burden hours 

are contained in the “Part B Permit Application, Permit Modifications, and 

Special Permits,” EPA ICR Number 1573, for facilities seeking a permit or 

permit renewal and in “Hazardous Waste Specific Unit Requirements,” EPA ICR 

Number 1572, for interim-status facilities.]

or

- Under section 268.4(a)(3)(ii), the unit meets the following criteria:

-- Has at least one liner, for which there is no evidence that such liner is 

leaking;

-- Is located more than one-quarter mile from an underground source of 

drinking water; and

-- Is in compliance with generally applicable ground-water monitoring 

requirements for facilities with permits.

or

-- Under section 268.4(a)(3)(iii), the unit is located, designed, and operated 

so as to assure that there will be no migration of any hazardous 

constituent into ground water or surface water at any future time.

(ii) Respondent Activities:

In order to comply with section 268.4(a)(3)(ii) or (iii), the owner/operator must:

 Develop and submit the application to EPA or the authorized State; and

 Maintain on-site files of the application.

(c) Certification (Section 268.4(a)(4)) 

Section 268.4(a)(4) requires that the owner/operator submit a written certification that the 

requirements of section 268.4(a)(3) have been met. The certification must include the statement 

described in section 268.4(a)(4).

(i) Data Item:

 Under section 268.4(a)(4), a written certification that the requirements of section 

268.4(a)(3) have been met. The certification must include the statement included in 

section 268.4(a)(4).
15

(ii) Respondent Activities:

In order to comply with section 268.4(a)(4), the owner/operator must:

 Complete and submit to EPA or the authorized State, a written certification that the 

requirements of section 268.4(a)(3) have been met.

(2) Procedures for Case-by-Case Extension (Section 268.5)

(a) Application for Extension (Section 268.5(a)-(c))

40 CFR 268.5(a)-(c) provides that any person who generates, treats, stores, or disposes of a 

hazardous waste may submit an application to EPA for an extension to the effective date of any 

applicable restriction established under Subpart C of Part 268. An authorized representative signing an 

application described under section 268.5(a) must make the certification as written in section 268.5(b). 

After receiving an application for an extension, EPA may request any additional information which it 

deems necessary to evaluate the application.

(i) Data Items:

 Under section 268.5(a)-(b), a signed, certified application for an extension to the effective 

date of any applicable restriction established under Subpart C of Part 268. The 

application must demonstrate the following:

– A good faith effort to locate and contact with treatment, recovery, or disposal 

facilities nationwide to manage waste in accordance with the effective date of the

applicable restriction established under Subpart C of Part 268;

– Binding contractual commitment to construct or otherwise provide alternative 

treatment, recovery, or disposal capacity;

– Demonstration that, due to circumstances beyond the applicant’s control, such 

alternative capacity cannot reasonably be made available by the applicable 

effective date;

– The capacity being constructed or otherwise provided by the applicant will be 

sufficient to manage the entire quantity of waste that is the subject of the 

application;

– A detailed schedule for obtaining required operating and construction permits or 

an outline of how and when alternative capacity will be available;

– Arrangements for adequate capacity to manage waste during an extension and 

documentation as to the location of all sites at which the waste will be managed; 

and

– Demonstration that any waste managed in a surface impoundment or landfill 

during the extension period will meet the requirements of section 268.5(h)(2).

 Under section 268.5(c), any additional information which EPA deems as necessary to 

evaluate the application.
16

(ii) Respondent Activities:

In applying for an extension to the effective date of any applicable restriction established under 

Subpart C of Part 268, the applicant must undertake the following activities in compliance with section 

268.5(a)-(c):

 Complete and submit a signed, certified application for an extension to the effective date 

of any applicable restriction established under Subpart C of Part 268; and

 Develop and submit any additional information as requested by EPA which it deems as 

necessary to evaluate the application.

(b) Renewal of Extension (Section 268.5(e))

Section 268.5(e) also provides that the owner/operator may request an extension of up to one

additional year, if the demonstration required in section 268.5(a) can be made. In no event will an 

extension extend beyond 24 months from the applicable effective date specified in Subpart C of Part 268.

(i) Data Item:

 Under section 268.5(e), a request for renewal of the extension for up to one additional 

year if the demonstration required in section 268.5(a) can still be made.

(ii) Respondent Activities:

In order to comply with section 268.5(e), the owner/operator must:

 Develop and submit to EPA a request for renewal of the extension for up to one 

additional year if the demonstration required in section 268.5(a) can still be made.

(c) Notifications and Progress Reports (Section 268.5(f)-(g)) 

Section 268.5(f)-(g) requires that any person granted an extension under section 268.5 must 

immediately notify EPA as soon as he or she has knowledge of any change in the conditions certified to 

in the application. Any person granted an extension under the section must submit written progress 

reports at intervals designated by EPA.

(i) Data Items:

 Under section 268.5(f), immediate notification to EPA of any change in the conditions 

certified to in the application.

 Under section 268.5(g), written progress reports describing:

– Overall progress made toward constructing or otherwise providing alternative 

treatment, recovery, or disposal capacity;

– Identification of any event which may cause or has caused a delay in 

development of the capacity; and

– Summary of the steps taken to mitigate the delay.
17

(ii) Respondent Activities:

In order to comply with section 268.5(f)-(g), any person granted an extension under section 268.5 

must:

 Immediately notify EPA of any change in the conditions certified to in the application; 

and

 Provide written progress reports to EPA at intervals designated by EPA.

(3) Waste Analysis and Recordkeeping (Sections 268.7 and 268.9)

(a) Generator Waste Analysis and Recordkeeping (Section 268.7(a))

Generator Waste Analysis (Section 268.7(a)(1))

Under 40 CFR 268.7(a)(1), a generator of hazardous waste must determine if the waste has to be 

treated before it can be land disposed. This is done by determining if the hazardous waste meets the 

treatment standards in section 268.40, section 268.45, or section 268.49. This determination can be made 

in either of two ways: testing the waste or using knowledge of the waste. Note that some hazardous 

wastes must be treated by particular treatment methods before they can be land disposed and some soils 

are contaminated by such hazardous wastes. These treatment standards are also found in section 268.40, 

and are described in detail in section 268.42, Table 1. These wastes, and solids contaminated with such 

wastes, do not need to be tested (however, if they are in a waste mixture, other wastes with concentration 

level treatment standards would have to be tested). If a generator determines he or she is managing a 

waste or soil contaminated with a waste, that displays a hazardous characteristic of ignitability, 

corrosivity, reactivity, or toxicity, he or she must comply with the special requirements of section 268.9 in 

addition to any applicable requirements in this section.

(i) Data Items:

 Testing results or data used to support process knowledge determination.

(ii) Respondent Activities:

In order to comply with section 268.7(a)(1), generators must:

 Test the waste; or

 Use process knowledge. 
18

Generator Notification and Certification Requirements (Section 268.7(a)(2)-(4)) 

Section 268.7(a)(2) requires that, if a generator determines that the waste or contaminated soil 

does not meet the treatment standard (including hazardous debris that will be treated to meet the treatment 

standards for the contaminating wastes in section 268.40), with the initial shipment of waste or soil the 

generator must send a one-time written notice to each treatment or storage facility receiving the waste, 

and place a copy in the file. For soil, the notice must also include a certification. If the waste, soil or 

TSDF changes, the generator must send a new notice to the receiving facility and place a copy in their 

files. The notice must include the information in column 268.7(a)(2) of the Generator Paperwork 

Requirements Table in section 268.7(a)(4). For contaminated soil, an authorized representative must 

make a certification as written in section 268.7(a)(2)(i).

Section 268.7(a)(3) requires that, if the waste or contaminated soil meets the treatment standard at 

the original point of generation, the generator must submit to the TSDF receiving the waste or soil a onetime written notice with the initial shipment. For waste only, the generator must submit with the notice a 

certification that the waste complies with CFR Part 268, Subpart D. If the waste changes, the generator 

must send a new notice and certification to the receiving facility and place a copy in their files. The 

notice must include the information in column 268.7(a)(3) of the Generator Paperwork Requirements 

Table in section 268.7(a)(4).

Section 268.7(a)(4) requires that, if a generator’s waste or contaminated soil can be land disposed 

without meeting the treatment standards (e.g., under a case-by-case extension under section 268.5, an 

exemption under section 268.6, or a nationwide capacity variance under 40 CFR Part 268, Subpart C), the 

generator must send to the land disposal facility a one-time notice with the initial shipment. If the waste 

or soil changes, the generator must send a new notice to the receiving facility, and place a copy in the 

files. The notice must include the information in column 268.7(a)(4) of the Generator Paperwork 

Requirements Table in section 268.7(a)(4).

(i) Data Items:

 For waste and contaminated soil that does not meet the applicable treatment standards set forth in 

Subpart D of Part 268, a one-time notification. The notice must include the information in 

column 268.7(a)(2) of the Generator Paperwork Requirements Table in section 268.7(a)(4). A 

signed certification must also be included for contaminated soil.

 For waste and contaminated soil that can be land disposed without further treatment, a one-time 

notification and a certification stating that the waste meets the applicable treatment standards set 

forth in Subpart D of Part 268. The notice must include the information in column 268.7(a)(3) of 

the Generator Paperwork Requirements Table in section 268.7(a)(4).

 For waste or contaminated soil that is exempt from a prohibition on the type of land disposal 

method utilized for the waste (such as, but not limited to, a case-by-case extension under section 

268.5, an exemption under section 268.6, or a nationwide capacity variance under Subpart C), a 

one-time notice. The notice must include the information in column 268.7(a)(4) of the Generator 

Paperwork Requirements Table in section 268.7(a)(4).
19

(ii) Respondent Activities:

In order to comply with section 268.7(a)(2)-(4), the generators must:

 For waste or contaminated soil that does not meet the applicable treatment standards set forth in 

Subpart D of Part 268, complete and transmit a one-time written notification (and also a 

certification for contaminated soil only) to the treatment or storage facility with the first shipment 

and when the waste soil, or receiving facility changes;

 For waste or contaminated soil that can be land disposed without further treatment, complete and 

transmit a one-time notice (and also a certification for waste) to the disposal facility with the first 

shipment and when the waste, soil or receiving facility changes; or 

 For waste or contaminated soil that is exempt from a prohibition on the type of land disposal 

method utilized for the waste (such as, but not limited to, a case-by-case extension under section 

268.5, an exemption under section 268.6, or a nationwide capacity variance under Subpart C), 

complete and transmit to the disposal facility a one-time notice.

Generator Waste Analysis Plan (Section 268.7(a)(5))

Under section 268.7(a)(5), if a generator is managing and treating a prohibited waste or 

contaminated soil in tanks, containers, or containment buildings regulated under 40 CFR 262.34 to meet 

applicable treatment standards under Subpart D of Part 268, the generator must develop and follow a 

written waste analysis plan which describes the procedures the generator will must comply with the 

treatment standards. However, generators treating hazardous debris under the alternative treatment 

standards of 40 CFR 268.45, Table 1 are not subject to the waste analysis standards. EPA requires that 

the waste analysis plan be kept on site in the generator’s records. Wastes shipped off site pursuant to 

section 268.7(a)(5) must comply with the notification and certification requirements of section 

268.7(a)(3).

(i) Data Items:

 Under section 268.7(a)(5), a waste analysis plan which describes the procedures the 

generator will carry out to comply with the treatment standards. The waste analysis plan 

must be based on a detailed chemical and physical analysis of a representative sample of 

the prohibited waste(s) being treated, and contain all information necessary to treat the 

waste(s) in accordance with the requirements of Part 268, including the selected testing 

frequency.

 Under section 268.7(a)(5)(iii), notifications and certifications for wastes shipped off site.
20

(ii) Respondent Activities:

In order to comply with section 268.7(a)(5), generators must:

 Develop and follow waste analysis plan; 

 Maintain the waste analysis plan on site; and

 Complete and transmit to the receiving facility a one-time notification and certification.

Generator Recordkeeping Requirements (Section 268.7(a)(6)-(8))

Section 268.7(a)(6) requires that, if a generator determines whether the waste or contaminated 

soil is restricted based solely on the generator’s knowledge of the waste, all supporting data used to make 

this determination must be retained in on-site files. If a generator determines whether the waste is 

restricted based on testing the waste or an extract developed using test method 1311 in “Test Methods for 

Evaluating Solid Waste, Physical/Chemical Methods,” EPA publication SW-846, as referenced in section 

260.11, all waste analysis data must be retained on site in the generator’s files.

Section 268.7(a)(7) requires that, if a generator determines that he or she is managing a prohibited 

waste that is excluded from the definition of hazardous or solid waste or exempt from Subtitle C 

regulations under 40 CFR 261.2-261.6 subsequent to the point of generation, the generator must place a 

one-time notice stating such generation, subsequent exclusion from the definition of hazardous or solid 

waste or exemption from Subtitle C regulation, and the disposition of the waste, in the facility’s file.

Section 268.7(a)(8) requires that generators retain on site a copy of all notices, certifications, 

demonstrations, waste analysis data, and other documentation produced pursuant to section 268.7 for at 

least three years from the date that the waste that is the subject of such documentation was last sent to onsite or off-site treatment, storage, or disposal. The three year record retention period is automatically 

extended during the course of any unresolved enforcement action regarding the regulated activity or as 

requested by EPA.

(i) Data Items:

 For a generator who determines whether the waste is restricted based solely on knowledge of the 

waste, all supporting data used to make this determination.

 For a generator who determines whether the waste is restricted based on testing, the waste 

analysis data.

 For a generator who determines that he or she is managing a restricted waste that is excluded 

from the definition of hazardous or solid waste or exempt from Subtitle C regulation under 40 

CFR 261.2 through 261.6 subsequent to the point of generation, a one-time notice stating such 

generation, subsequent exclusion from the definition of hazardous or solid waste or exemption 

from Subtitle C regulation, and the disposition of the waste.

 Copies of all notices, certifications, demonstrations, and other documentation produced pursuant 

to section 268.7.
21

(ii) Respondent Activities:

In order to comply with the section 268.7(a)(6)-(8) requirements, a generator must:

 For a generator who determines whether the waste or contaminated soil is restricted based solely 

on knowledge of the waste, keep records of all supporting data used to make this determination in 

the generator’s files;

 For a generator who determines whether the waste or contaminated soil is restricted based on 

testing this waste or an extract developed using test method 1311 in “Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods,” EPA publication SW-846, keep records of all waste 

or contaminated soil analysis data in the generator’s files;

 For a generator who determines that he or she is managing a restricted waste that is excluded 

from the definition of hazardous or solid waste or exempt from Subtitle C regulation under 40 

CFR 261.2 through 261.6 subsequent to the point of generation, develop and place a one-time 

notice stating such generation, subsequent exclusion from the definition of hazardous or solid 

waste or exemption from Subtitle C regulation, and the disposition of the waste, in the facility’s 

file; and

 Keep records of all notices, certifications, waste analysis data, and other documentation produced 

pursuant to section 268.7(a) for at least three years from the date that the waste that is the subject 

of such documentation was last sent to on-site or off-site treatment, storage, or disposal. The 

three year record retention period is automatically extended during the course of any unresolved 

enforcement action regarding the regulated activity or as requested by EPA.

Lab Pack and Toll Agreement Generator Requirements (Section 268.7(a)(9)-(10))

Section 268.7(a)(9) requires that, if a generator is managing a lab pack waste and wishes to use 

the alternative treatment standard under section 268.42(c), with the initial shipment of waste, the 

generator must submit a notice to the treatment facility that provides the EPA Hazardous Waste Codes, 

manifest number, and a signed certification. The facility must also keep a copy of the notification in its 

files. As long as the contents of the lab pack and the receiving facility do not change, no further 

notification is necessary. If the waste or receiving facility changes, the generator must submit a new 

notice and certification to EPA. The generator must also comply with the requirements of section 

268.7(a)(6)-(7).

Section 268.7(a)(10) requires that small quantity generators (SQGs) with tolling agreements 

pursuant to 40 CFR 262.20(e) must comply with the applicable notification and certification requirements 

of section 268.7(a) for the initial shipment of the waste subject to the agreement. Such generators must 

retain on site a copy of the notification and certification, together with the tolling agreement, for at least 

three years after termination or expiration of the agreement. The three-year record retention period is 

automatically extended during the course of any unresolved enforcement action regarding the regulated 

activity or as requested by EPA.
22

(i) Data Items:

 For a generator who is managing a lab pack waste and who wishes to use the alternate treatment 

standards under section 268.42, a signed notification and certification; and

 For a SQGs with a tolling agreement pursuant to 40 CFR 262.20(e), a copy of the notification and 

certification, together with the tolling agreement. 

(ii) Respondent Activities:

In order to comply with section 268.7(a)(9)-(10), the generator must:

 For a generator who is managing a lab pack waste and who wishes to use the alternate treatment 

standards under section 268.42, submit a signed notification and certification to the treatment 

facility with the first shipment or when the waste or receiving facility changes; and

 For a SQG with a tolling agreement pursuant to 40 CFR 262.20(e), transmit and retain on site a 

copy of the notification and certification, together with the tolling agreement, for at least three 

years after termination or expiration of the agreement.

 

(b) Treatment Facility Waste Analysis and Recordkeeping (Section 268.7(b))

Treatment Facility Waste Analysis (Section 268.7(b)(1)-(2))

Section 268.7(b)(1)-(2) requires that treatment facilities test their wastes and contaminated soils 

according to the frequency specified in their waste analysis plans (as required by section 264.13 or section 

265.13). Such testing must be done to assure that the wastes and contaminated soils meet the applicable 

treatment standards. [These testing requirements are addressed in the “General Hazardous Waste Facility 

Standards,” EPA ICR Number 1571, for permitted and interim-status facilities.]

Treatment Facility Notifications and Certifications (Section 268.7(b)(3)-(6))

Section 268.7(b)(3) requires that a one-time notification be sent with the initial waste shipment to 

the land disposal facility, except for shipments of debris excluded from the definition of hazardous waste 

under 40 CFR Part 261.3(e), which must only comply with section 268.7(d). The notification should 

include the information described in the Treatment Facility Paperwork Requirements Table in section 

268.7(b)(3)(ii).

Section 268.7(b)(4) requires the treatment facility to submit a one-time signed certification with 

the initial shipment of waste or treatment residue of restricted waste to the land disposal facility stating 

that the waste or treatment residue has been treated in compliance with the applicable treatment standards 

specified in Subpart D of Part 268. If the waste or treatment residue changes or the receiving facility 

changes, the treater must send a new notice and certification to the receiving facility. A copy of all 

notifications and certifications must be placed in the facility files.

Section 268.7(b)(5) requires that, if the waste or treatment residue will be further managed at a 

different TSDF, the facility sending the waste or treatment residue off site must comply with the 

notification and certification requirements applicable to generators.
23

Section 268.7(b)(6) provides that, where the wastes are recyclable materials used in a manner 

constituting disposal subject to the provisions of section 266.20(b) regarding treatment standards and 

prohibition levels, the owner/operator of a treatment facility (i.e., the recycler) is not required to notify the 

receiving facility, pursuant to section 268.7(b)(3). With each shipment of such wastes, the 

owner/operator of the recycling facility must submit a certification described in section 268.7(b)(4), and a 

notice which includes the information listed in section 268.7(b)(3) (except the manifest number) to EPA, 

or its delegated representative. The recycling facility also must keep records of the name and location of 

each entity receiving the hazardous waste-derived product.

(i) Data Items:

 Under section 268.7(b)(3) and (6), a notice which includes the information listed in the Treatment 

Facility Paperwork Requirements Table in section 268.7(b)(3)(ii). (Where the wastes are 

recyclable materials used in a manner constituting disposal subject to the provisions of section 

266.20(b) regarding treatment standards and prohibition levels, the notice must include the 

information listed in the Treatment Facility Paperwork Requirements Table in section 268.7(b), 

except for the manifest number.);

 Under section 268.7(b)(4), a signed certification stating that the waste or treatment residue has 

been treated in compliance with the applicable treatment standards specified in Subpart D of Part 

268. The certification must be worded as described in section 268.7(b)(4);

 Under section 268.7(b)(5), notifications and certifications for generated waste;

 Under section 268.7(b)(6), for wastes that are recyclable materials, a signed certification that 

must be worded as described in section 268.7(b)(4), and a notice with the information listed in 

section 268.7(b)(3) (except manifest number) to EPA or the authorized State; and

 Under section 268.7(b)(6), records of the name and location of each entity receiving the 

hazardous waste-derived product.

(ii) Respondent Activities:

In order to comply with section 268.7(b)(3)-(6), the treatment or recycling facility must:

 Complete, submit, and keep a copy of the notice and certification sent with the initial shipment to 

the land disposal facility. If the waste or treatment residue changes or the receiving facility 

changes, the treater must send a new notice and certification to the receiving facility;

 Comply with the notification and certification requirements applicable to generators;

 For recyclable materials, complete and submit a notice and certification to EPA or the authorized 

State with each shipment; and

 For recycling facilities, keep records of the name and location of each entity receiving the 

hazardous waste-derived products.
24

(c) Land Disposal Facility Waste Analysis and Recordkeeping (Section 268.7(c))

Land Disposal Facility Recordkeeping (Section 268.7(c)(1))

Section 268.7(c)(1) provides that, except where the owner/operator is disposing of any waste that 

is a recyclable material used in a manner constituting disposal pursuant to 40 CFR 266.20(b), the 

owner/operator of any land disposal facility disposing any waste subject to restrictions under Part 268 

must have copies of the notice and certification specified in section 268.7(a) or (b). 

(i) Data Item:

 Under section 268.7(c)(1), copies of all notices and certifications specified in section 268.7(a) or 

(b).

(ii) Respondent Activity:

In order to comply with section 268.7(c)(1), the owner/operator must:

 Keep copies of all notices and certifications specified in section 268.7(a) or (b).

Land Disposal Facility Waste Analysis (Section 268.7(c)(2))

Section 268.7(c)(2) requires that, except for an owner/operator who is disposing of any waste that 

is a recyclable material used in a manner constituting disposal pursuant to 40 CFR 266.20(b), the 

owner/operator of any land disposal facility disposing any waste subject to restrictions under Part 268 

must test the waste, or an extract of the waste or treatment residue, using the test method described in 

“Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846 as 

incorporated by reference in section 260.11. Such testing must be performed according to the frequency 

specified in the facility’s waste analysis plan as required by section 264.13 or section 265.13. [The 

section 268.7(c)(2) requirement is burdened in the “General Hazardous Waste Facility Standards,” EPA 

ICR Number 1571, for permitted and interim-status facilities.”]

(d) Hazardous Debris Requirements (Section 268.7(d)) 

Pursuant to section 268.7(d), generators or treaters who first claim that hazardous debris is 

excluded from the definition of hazardous waste under section 261.3(f) (i.e., debris treated by an 

extraction or destruction technology provided by Table 1, section 268.45, and debris that EPA has 

determined does not contain hazardous waste) must submit a one-time notification to EPA or the 

authorized State. The notification must be updated if the debris is shipped to a different facility, and, for 

debris excluded under section 261.3(f)(1), if a different type of debris is treated or if a different 

technology is used to treat the debris. For debris excluded under section 261.3(f)(1), the owner/operator 

of the treatment facility must document and certify compliance with the treatment standards of Table 1, 

section 268.45.
25

(i) Data Items:

 Under section 268.7(d), a one-time notification, including:

– The name and address of the Subtitle D facility receiving the treated debris;

– A description of the hazardous debris as initially generated, including the EPA 

Hazardous Waste Number(s); and

– For debris excluded under section 261.3(f)(1), the technology from Table 1, 

section 268.45 used to treat the debris.

 For debris excluded under section 261.3(f)(1), a certification of compliance with the treatment 

standards of Table 1, section 268.45, including:

– Records of all inspections, evaluations, and analyses of treated debris made to 

determine compliance;

– Records of data or information the treater obtains during treatment of the debris 

that identifies key operating parameters of the treatment unit; and

– For each shipment of treated debris, a certification of compliance with the 

treatment standards, signed by an authorized representative. The certification 

must state the following: “I certify under penalty of law that the debris has been 

treated in accordance with the requirements of 40 CFR 268.45. I am aware that 

there are significant penalties for making a false certification, including the 

possibility of fine and imprisonment.”

(ii) Respondent Activities:

In order to comply with section 268.7(d), the owner/operator must:

 Prepare and submit to EPA or authorized State a one-time notification;

 Update the notification if the debris is shipped to a different facility, and, for debris excluded 

under section 261.3(f)(1), if a different type of debris is treated or if a different technology is used 

to treat the debris; and 

 For debris excluded under section 261.3(f)(1), document and certify compliance with the 

treatment standards of Table 1, section 268.45, as follows: 

- Keep records of all inspections, evaluations, and analyses of treated debris that 

are made to determine compliance with the treatment standards;

- Keep records of data or information obtained during treatment, if debris is 

excluded under section 261.3(e)(1); and

- Keep a certification of compliance for each shipment of treated debris, if debris is 

excluded under section 261.3(e)(1).

(e) Contaminated Soil Requirements (Section 268.7(e)) 
26

Pursuant to section 268.7(e), generators and treaters who first receive from EPA or an authorized 

State a determination that a given contaminated soil subject to LDRs as provided in section 268.49(a) no 

longer contains a listed hazardous waste and generators and treaters who first determine that a 

contaminated soil subject to LDRs as provided in section 268.49(a) no longer exhibits a characteristic of 

hazardous waste must prepare and maintain for three years one-time only documentation of these 

determinations.

(i) Data Items:

 One-time only documentation of the determinations.

 All supporting documentation for this determination.

(ii) Respondent Activities:

In order to comply with section 268.7(e), the owner/operator must:

 Prepare a one-time only documentation of the determinations including all supporting 

information; and

 Maintain that information in the facility files and other records for a minimum of three years.

(f) Special Rules for Characteristic Wastes (Section 268.9(d))

Pursuant to section 268.9(d), wastes that exhibit a characteristic are also subject to section 268.7 

requirements, except that once the waste is no longer hazardous, a one-time notification and certification 

must be placed in the generator’s or treater’s files and sent to EPA or the authorized State. The 

notification and certification that is placed in the generator’s or treater’s files must be updated if the 

process or operation generating the waste changes and/or if the Subtitle D facility receiving the waste 

changes. The generator or treater must notify EPA or the authorized State of any changes on an annual 

basis only, but no later than December 31. If treatment removes the characteristic but does not treat 

underlying hazardous constituents, then the certification found in section 268.7(b)(5)(iv) applies.

(i) Data Item:

 A notification that includes the following information:

– Name and address of the RCRA Subtitle D facility receiving the waste shipment; 

and

– A description of the waste as initially generated, including the applicable EPA 

Hazardous Waste Code(s), treatability group(s), and underlying hazardous 

constituents (as defined in section 268.2(i)), unless the waste will be treated and 

monitored for all underlying hazardous constituents. If all underlying 

constituents will be treated and monitored there is no requirement to list any of 

the constituents on the notice.

 A signed certification that states the language found in section 268.5(b)(5).
27

(ii) Respondent Activities:

In order to comply with section 268.9(d), the owner/operator must:

 Prepare and submit to EPA a one-time notification and certification;

 Maintain files of notification and certification in facility files;

 Update and submit to EPA the notification and certification annually, if any changes occur; and

 Maintain updated certification and notification.

(4) Demonstration for Alternative Treatment Technology (Section 268.42)

40 CFR 268.42(b) provides that any person may submit an application to EPA demonstrating that 

an alternative treatment method can achieve a measure of performance equivalent to that achievable by 

methods specified in section 268.42(a), (c), and (d) or specified in Table 1 of 268.45 for hazardous debris. 

The applicant must submit information demonstrating that his treatment method is in compliance with 

Federal, State, and local requirements and is protective of human health and the environment. On the 

basis of such information, EPA may approve the use of the alternative treatment method if it finds that the 

alternative treatment method provides a measure of performance equivalent to that achieved by methods 

specified in section 268.42(a), (c), and (d) or specified in Table 1 of 268.45 for hazardous debris. Any 

approval must be stated in writing and may contain such provisions and conditions as EPA deems 

appropriate. The person to whom such approval is issued must comply with all limitations contained in 

such a determination.

(i) Data Item:

 Under section 268.42(b), an application demonstrating that an alternative treatment method can 

achieve a measure of performance equivalent to that achievable by methods specified in section 

268.42(a), (c), and (d) or specified in Table 1 of 268.45 for hazardous debris. The application 

should include information demonstrating that the treatment method is in compliance with 

Federal, State, and local requirements and is protective of human health and the environment.

(ii) Respondent Activities:

In order to comply with section 268.42(b), the applicant must:

 Develop and submit to EPA an application demonstrating that an alternative treatment method 

can achieve a measure of performance equivalent to that achievable by methods specified in 

section 268.42(a), (c), and (d) or specified in Table 1 of 268.45 for hazardous debris.
28

(5) Demonstration for a Variance from a Treatment Standard (Section 268.44) 

(a) Demonstration for a Variance (Section 268.44(a)-(d)) 

40 CFR 268.44(a)-(d) provides that, where the treatment standard is expressed as a concentration 

in a waste or waste extract and a waste cannot be treated to the specified level, or where the treatment 

technology is not appropriate to the waste, the generator or treatment facility may petition EPA for a 

variance from the treatment standard. The petitioner must demonstrate that because the physical or 

chemical properties of the waste differ significantly from wastes analyzed in developing the treatment 

standard, the waste cannot be treated to specified levels or by the specified methods. Each petition must 

be submitted in accordance with the procedures in section 260.20. Each petition must include the 

statement as described in section 268.44(c). The statement must be signed by the petitioner or an 

authorized representative. After receiving the petition for a variance from a treatment standard, EPA may 

request any additional information or samples which it may require to evaluate the petition. Additional 

copies of the complete petition may be requested as needed to send to affected States and EPA Regional 

offices.

(i) Data Items:

 Under section 268.44(a) and (c), a demonstration that because the physical or chemical properties 

of the waste differ significantly from wastes analyzed in developing the treatment standard, the 

waste cannot be treated to specified levels or by the specified methods. Each petition must 

include a signed statement as described in section 268.44(c).

 Under section 268.44(d), any additional information or samples which EPA may require to 

evaluate the petition. Additional copies of the complete petition may be requested as needed to 

send to affected States and EPA Regional offices.

(ii) Respondent Activities:

In order to comply with section 268.44(a)-(d), the applicant must:

 Develop and submit to EPA a demonstration and any additional information or samples as 

requested by EPA.

(b) Demonstration for a Site-Specific Variance (Section 268.44(h)-(m))

Section 268.44(h)-(m) provides that, where the treatment standard is expressed as a concentration 

in a waste or waste extract and a waste generated under conditions specific to only one site cannot be 

treated to the specified level, or where the treatment technology is not appropriate to the waste, the 

generator or treatment facility may apply to EPA, or its delegated representative, for a site-specific 

variance from the treatment standard. The applicant for a site-specific variance must demonstrate that 

because the physical or chemical properties of the waste differ significantly from the waste analyzed in 

developing the treatment standard, the waste cannot be treated to specified levels by the specified method. 

Each application for a site-specific variance from a treatment standard must include the information in 

section 260.20(b)(1)-(4). After receiving an application for a site-specific variance from a treatment 

standard, EPA, or its delegated representative, may request any additional information or samples which 

may be required to evaluate the application.
29

(i) Data Items:

 Under section 268.44(h), a demonstration that because the physical or chemical properties of the 

waste differ significantly from the waste analyzed in developing the treatment standard, the waste 

cannot be treated to specified levels or by the specified method. Each application for a sitespecific variance from a treatment standard must include the information in section 260.20(b)(1)-

(4).

 Under section 268.44(j), any additional information or samples which may be required to 

evaluate the application.

(ii) Respondent Activity:

In order to comply with section 268.44(h)-(m), the applicant must:

 Develop and submit to EPA a demonstration and any other information requested by EPA.

(6) Recordkeeping for Storage Prohibition (Section 268.50) 

40 CFR 268.50(a) prohibits the storage of hazardous wastes restricted from land disposal under 

Subpart C of Part 268, unless the conditions of section 268.50(a) are met. Section 268.50(a)(2) allows an 

owner/operator of a hazardous waste treatment, storage, or disposal facility to store such wastes in tanks, 

containers, and containment buildings if (1) the waste is stored solely for the purpose of the accumulation 

of such quantities of hazardous waste as necessary to facilitate proper recovery, treatment, or disposal; (2) 

each container is clearly marked to identify its contents and the date each period of accumulation begins; 

and (3) each tank is clearly marked with a description of its contents, the quantity of each hazardous 

waste received, and the date each period of accumulation begins; or such information for each tank is 

recorded and maintained in the operating record at that facility. [Note that the operating record 

requirements are covered in the “General Hazardous Waste Facility Standards,” EPA ICR Number 1571, 

for permitted and interim-status facilities.]

(i) Data Items:

 Under section 268.50(a)(2), records of the contents, the quantity of each hazardous waste 

received (for tanks), and the date that accumulation begins.

(ii) Respondent Activities:

In order to comply with section 268.50(a)(2), the owner/operator must:

 For each tank, container, or containment building, develop and keep records of the unit contents, 

and the date that accumulation begins; for each tank, owners and operators must also keep records 

of the quantity of each hazardous waste received.

(7) No-Migration Variances

Under 40 CFR 268.6, a facility may apply for a no-migration variance to the prohibitions on land 

disposal of untreated hazardous waste. This section describes the data items and respondent activities 
30

associated with such an application.

(i) Data Items

 Petitioner's name and address;

 Name, address, and EPA identification number of the facility storing or disposing of the 

waste;

 Name and phone number of contact at the facility;

 Description of the specific waste and specific unit for which the demonstration will be 

made;

 Waste analyses to describe the chemical and physical characteristics of all wastes 

managed in the unit;

 Comprehensive characterization of storage or disposal unit, including an analysis of 

background air, soil, and water quality;

 Historic and current saturated and unsaturated zone monitoring data;

 Saturated and unsaturated zone modeling results;

 Saturated and unsaturated zone monitoring plans;

 Air modeling and monitoring results;

 Quality assurance/quality control plans;

 Certification that disposal unit is in compliance with other Federal, State, and local 

requirements;

 Uncertainty analyses required under 40 CFR 268.6(b)(5) - includes an analysis of the 

consequences of predictable future events, such as earthquakes, floods, severe storm 

events, droughts, or other natural phenomena; and

 Certification of truth and accuracy required under 40 CFR 268.6(g).

(ii) Respondent Activities

 Read the regulations and guidance manual;

 Prepare and gather information and present it in written form. EPA estimates that each 

petitioner will perform the following activities. The activities correspond to the data 

items listed above, including:

 - Compiling administrative information;
31

 - Description of the specific waste and specific unit for which the demonstration 

will be made;

 - Performing waste analyses to describe the chemical and physical characteristics 

of the waste;

 - Preparing a comprehensive characterization of storage or disposal unit, including 

an analysis of background air, soil, and water quality;

 - Presentation of historical and current saturated and unsaturated zone monitoring 

results;

 - Performing saturated and unsaturated zone modeling and presentation of results;

 - Preparation of saturated and unsaturated zone monitoring plans;

 - Performing air modeling and monitoring and presentation of results;

 - Evaluating modeling/monitoring results;

 - Providing quality assurance/quality control plans;

 - Certifying that disposal unit is in compliance with other Federal, State, and local 

requirements;

 - Performing uncertainty analyses;

 - Certifying truth and accuracy, as required under 40 CFR 268.6(g); and

 - Compiling and transmitting three copies of the no-migration petition to EPA.

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Treatment Surface Impoundment Exemption (Section 268.4) 

Under section 268.4(a)(3)-(4), the Agency will:

 Review the demonstration or request for modification and approve/deny the exemption;

 Review written certification; and

 Keep records of the demonstration and written certification.
32

(2) Procedures for Case-by-Case Extension (Section 268.5)

(a) Application for Extension (Section 268.5(a)-(c)) 

Under section 268.5(a)-(c), the Agency will:

 Review and keep records of the certified application for an extension to the effective date of any 

applicable restriction established under Subpart C of Part 268;

 Request, review, and keep records of any additional information which it deems as necessary to 

evaluate the application;

 Provide notice and opportunity for comment;

 Consult with appropriate State agencies in all affected States; and

 Approve or deny extension and publish the decision in the Federal Register.

(b) Renewal of Extension (Section 268.5(e)) 

Under section 268.5(e), the Agency will:

 Receive, review, and keep records of the request for renewal;

 Consult with appropriate State agencies in all affected States; and

 Provide notice and opportunity for public comment;

 Approve or deny renewal of extension and publish the decision in the Federal Register.

(c) Notifications and Progress Reports (Section 268.5(f)-(g))

Under section 268.5(f)-(g), the Agency will:

 Receive and keep records of notification of any change in the conditions certified to in the 

application; and

 Receive, review, and keep records of written progress reports.

(3) Waste Analysis and Recordkeeping (Sections 268.7 and 268.9) 

(a) Generator Waste Analysis and Recordkeeping (Section 268.7(a))

Under section 268.7(a)(5)(ii), the Agency will:

 Inspect the waste analysis plan in the facilities’ on-site files.
33

(b) Treatment Facility Waste Analysis and Recordkeeping (Section 268.7(b))

Under section 268.7(b)(6), the Agency will:

 Receive, review, and keep records of the certification and notice submitted from the recycling 

facility.

(c) Land Disposal Facility Waste Analysis and Recordkeeping (Section 268.7(c))

There are no Agency activities associated with the information collection requirements under 40 

CFR 268.7(c).

(d) Hazardous Debris Requirements (Section 268.7(d))

Under section 268.7(d)(1)-(2), the Agency will:

 Receive, review, and keep records of one-time notification submitted by owner/operator; and

 Receive, review and keep records of update sent from owner/operator.

(e) Contaminated Soil Requirements (Section 268.7(e))

Under section 268.7(e), the Agency will:

 If necessary, make a determination if specified soil is subject to the land disposal restrictions as 

provided in section 268.49(a).

(f) Special Rules for Characteristic Wastes (Section 268.9(d))

Under section 268.9(d), the Agency will:

 Receive, review, and keep records of one-time notification submitted by owner/operator; and

 Receive, review and keep records of update sent annually from owner/operator if the process or 

operation generating the waste changes and/or if the Subtitle D facility receiving the waste 

changes.

(4) Demonstration for Alternative Treatment Technology (Section 268.42)

Under section 268.42(b), the Agency will:

 Receive, review and keep records of the application for approval of alternative treatment method;

 Approve or deny the application; and

 For approved applications, develop a written approval that may contain such provisions and 

conditions as EPA deems appropriate.
34

(5) Demonstration for a Variance from a Treatment Standard (Section 268.44)

(a) Demonstration for a Variance (Section 268.44(a)-(d))

Under section 268.44(a)-(d), the Agency will:

 Receive, review, and keep records of the petition;

 Request any additional information or samples which it may require to evaluate the petition;

 Send additional copies of the petition to the States, if appropriate;

 Provide notice and provide an opportunity for public comment; and

 Approve or deny the petition and publish decision in the Federal Register.

(b) Demonstration for a Site-Specific Variance (Section 268.44(h)-(m))

Under section 268.44(h)-(m), the Agency will:

 Receive, review, and keep records of the petition;

 Request any additional information or samples which it may require to evaluate the petition; and

 Provide notice and provide an opportunity for public comment; and

 Approve or deny the petition.

(6) Recordkeeping for Storage Prohibition (Section 268.50)

There are no Agency activities associated with the information collection requirements under 40 

CFR 268.50.

(7) No-Migration Variances (Section 268.6)

Agency activities include reviewing the no-migration petition and evaluating it in terms of 

demonstrating "no migration" as specified at 40 CFR 268.6. The Agency may also conduct site visits for 

each facility from which it receives a petition. Finally, EPA notifies the petitioner of a tentative decision 

to approve or deny, and publishes the proposed decision in the Federal Register. After analysis of public 

comments, final decisions are also published in the Federal Register.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

In collecting and analyzing the information obtained from generators, treaters, and disposers, 

EPA uses electronic equipment such as personal computers and applicable database software, where 

appropriate. EPA ensures the accuracy and completeness of collected information by reviewing each 

submittal.
35

5(c) SMALL ENTITY FLEXIBILITY

EPA expects that, in many cases, respondents of small organizations will be able to complete 

certain recordkeeping, reporting, and application requirements in less time than large organizations 

because such activities may not be as burdensome. For example, EPA expects that many SQGs (and 

some large quantity generators (LQGs)) will use process knowledge, instead of testing, to characterize 

their waste under the treatment standards. Use of process knowledge is generally less burdensome than 

testing. In addition, EPA has revised the requirements for transmitting LDR notices and certifications to 

TSDFs. Formerly, generators and treaters were required to transmit paperwork with each shipment to the 

receiving facility. However, EPA has revised these requirements so that generators and treaters must now 

transmit only one-time paperwork with the initial shipment and update the documents as specified. EPA 

believes these one-time requirements will greatly benefit all generators and treaters. 

5(d) COLLECTION SCHEDULE

(1) Treatment Surface Impoundment Exemption (Section 268.4)

 There is no collection schedule for the information collection requirements under section 

268.4(a)(3)-(4). 

(2) Procedures for Case-by-Case Extension (Section 268.5)

 There is no collection schedule for the information collection requirements under section 

268.5(a)-(d).

 Section 268.5(f) requires that any person granted an extension must immediately notify EPA as 

soon as he has knowledge of any change in the conditions certified to in the application for a 

case-by-case extension.

 Section 268.5(g) requires that any person granted an extension must submit written progress 

reports at intervals designated by EPA.

(3) Waste Analysis and Recordkeeping (Sections 268.7 and 268.9)

(a) Generator Waste Analysis and Recordkeeping (Section 268.7(a))

 Section 268.7(a)(2) requires that, with the initial shipment of waste or contaminated soil, 

generators must send one-time notifications to the treatment or storage facility. A new 

notification must be sent if the waste or the receiving facility changes. [Note: this is a third-party 

information submittal.]

 Section 268.7(a)(3)-(4) requires that with the initial shipment of waste or contaminated soil, 

generators must send one-time notifications and certifications to the disposal facility. A new 

notification must be sent to the receiving facility if the waste or receiving facility changes. [Note: 

this is a third-party information submittal.]
36

 Section 268.7(a)(9) requires that, if a generator is managing a lab pack waste and wishes to use 

the alternative treatment standard under section 268.42(c), with the initial shipment of waste the 

generator must submit a notice and certification to the treatment facility. A new notification and 

certification must be sent if the lab pack waste or the receiving facility changes. [Note: this is a 

third-party information submittal.]

 Section 268.7(a)(10) requires that SQGs with tolling agreements pursuant to 40 CFR 262.20(e) 

must comply with the applicable notification and certification requirements of section 268.7(a) 

for the initial shipment of the waste subject to the agreement. A new notification must be sent if 

the waste changes or the receiving facility changes. [Note: this is a third-party information 

submittal.]

(b) Treatment Facility Waste Analysis and Recordkeeping (Section 268.7(b))

 Section 268.7(b)(3)-(4) requires that, with the initial waste or contaminated soil shipment, the 

treatment facility must send a one-time certification and notification to the land disposal facility. 

A new notification and certification must be sent if the waste changes or the receiving facility 

changes. [Note: this is a third-party information submittal.]

 Section 268.7(b)(6) requires that where the wastes are recyclable materials used in a manner 

constituting disposal subject to the provisions of section 268.20(b) regarding treatment standards 

and prohibition levels, with each shipment of such wastes, the owner/operator of the recycling 

facility must submit a certification described in section 268.7(b)(4), and a notice which includes 

the information listed in the Notification Requirements Table in section 268.7(b)(3) to EPA, or its 

delegated representative.

(c) Land Disposal Facility Waste Analysis and Recordkeeping (Section 268.7(c))

 Section 268.7(c)(1) provides that, except where the owner/operator is disposing of any waste that 

is a recyclable material used in a manner constituting disposal pursuant to 40 CFR 266.20(b), the 

owner/operator of any land disposal facility disposing any waste subject to restrictions under Part 

268 must have copies of the notice and certification specified in section 268.7(a) or (b). [Note: 

this is a third-party information submittal.]

(d) Hazardous Debris Requirements (Section 268.7(d))

 Section 268.7(d) requires that generators or treaters who first claim that hazardous debris is 

excluded from the definition of hazardous waste under section 261.3(f) (i.e., debris treated by an 

extraction or destruction technology provided by Table 1, section 268.45, and debris that the 

Regional Administrator or authorized State has determined does not contain hazardous waste) 

must submit a one-time notification to EPA or the authorized State. The notification must be 

updated if the debris is shipped to a different facility, and, for debris excluded under section 

261.3(f)(1), if a different type of debris is treated or if a different technology is used to treat the 

debris.

(e) Contaminated Soil Requirements (Section 268.7(e))

 There is no collection schedule for the information collection requirements of section 268.7(e).
37

(f) Special Rules for Characteristic Wastes (Section 268.9(d))

 Section 268.9(d) requires that wastes that exhibit a characteristic are also subject to section 268.7 

requirements, except that once the waste is no longer hazardous, a one-time notification and 

certification must be placed in the generator’s or treater’s files and sent to the EPA Region or 

authorized State. The notification and certification that is placed in the generator’s or treater’s 

files must be updated if the process or operation generating the waste changes and/or if the 

Subtitle D facility receiving the waste changes. However, the generator or treater need only 

notify the EPA Region or an authorized State on an annual basis if such changes occur. Such 

notification and certification should be sent to EPA or the authorized State by the end of the 

calendar year, but no later than December 31.

(4) Demonstration for Alternative Treatment Technology (Section 268.42)

 There is no collection schedule for the information collection requirements of section 268.42. 

(5) Demonstration for a Variance from a Treatment Standard (Section 268.44) 

 There is no collection schedule for the information collection requirements of section 268.44.

(6) Recordkeeping for Storage Prohibition (Section 268.50) 

 There is no collection schedule for the information collection requirements of section 268.50.

(7) No-Migration Variances (Section 268.6)

 Because submittal of a no-migration petition is voluntary, no collection schedule is applicable.

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT HOURS

EPA estimates respondent hourly burden for all the information collection requirements covered 

in this ICR in Exhibits 1 through 7, broken down by private sector respondents versus State government 

respondents. The burden estimates for each activity presented in Exhibits 1 through 7 include the burden 

hours (total and by labor type) per respondent, as well as the overall burden hours for all respondents per 

activity. The majority of the hour estimates in Exhibits 1 through 7 are based on industry consultations 

that EPA performed in renewing previous LDR ICRs. Exhibit 10 presents the total aggregate annual hour 

burden to all respondents under the LDR program. 

6(b) ESTIMATING RESPONDENT COSTS

EPA estimates respondent costs for all activities covered in this ICR in Exhibits 1 through 7. 

These costs are based on the cost of labor, capital, and operation and maintenance (O&M). Exhibit 10 

presents the total aggregate annual cost burden to all respondents under the LDR program. 
38

(1) Labor Costs

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $128.93 for 

legal staff, $76.21 for managerial staff, $56.77 for technical staff, and $34.15 for clerical staff. These 

respondent labor costs were obtained from a previously approved ICR (i.e., “2013 Hazardous Waste 

Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and 

Modification”, EPA ICR Number 0976.16., dated September 19, 2012), and updated to 2014 levels using 

Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.

For the State respondent labor rates, EPA estimates an average hourly State labor cost (including 

fringe and overhead) of $59.51 for legal staff, $55.87 for managerial staff, $33.43 for technical staff, and 

$21.33 for clerical staff. These State labor costs were obtained from a previously approved ICR 

(i.e., “2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous 

Waste Permit Application and Modification”, EPA ICR Number 0976.16., dated September 19, 2012),

and updated to 2014 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor 

Statistics.

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. For this ICR, EPA estimates that 

respondents will incur capital costs associated with the purchase of file storage systems for maintaining 

LDR records, including applications, reports, notifications, certifications, LDR waste determinations, and 

waste analysis plans, as applicable. EPA realizes that respondents will likely use different and various 

file storage systems (e.g., file cabinets, CD-ROM, off-site storage) and store their files on different media 

(e.g., paper, microfiche, electronic files). For purposes of estimating these capital costs across all 

facilities, EPA has made the conservative assumption that every respondent will store their files in paper 

form in file cabinets.

EPA took the following steps to derive the annual capital costs associated with the purchase of 

file cabinets:

 Estimate the total annual volume of LDR records required to be retained by all waste 

handlers. Under the LDR program, hazardous waste handlers must keep LDR records for a 

period of three years. Thus, at any given time during the effective period of this ICR, the 

hazardous waste industry is keeping copies of three years’ worth of LDR records. Based on 

the assumptions presented in Section 6(d) of this document, EPA estimates that waste 

handlers (i.e., generators, treaters, and disposers) will need to keep copies of approximately 

3,047,739 pieces of paper annually. [Based on its best judgment, EPA estimates that the 

average application consists of 50 pages, the average documentation on LDR waste 

determinations consists of five pages, and the average LDR notification and certification 

consists of one page. Further based on the EPA publication, Waste Analysis at Facilities That 

Generate, Treat and Store, and Dispose of Hazardous Waste (OSWER 9938.4-03), EPA 

estimates that the typical generator’s waste analysis plan consists of 25 pages.]
39

 Ascertain the annual number of standard-size file cabinets that would provide the needed 

capacity for the industry, collectively, and estimate annual cost. EPA estimates that a 

standard-size, five-drawer, lateral file cabinet holds approximately 16,000 documents. Thus, 

for storing 3,047,739 pieces of paper, waste handlers would need 190 file cabinets (i.e., 

3,047,739 / 16,000) each year. These 190 file cabinets represent the total capacity needed by 

the industry, collectively, to store all of its LDR records. EPA estimates that the cost of one 

file cabinet is $869.99, and for all 190 file cabinets is $165,298. 

 Annualize the aggregate cost of standard-size file cabinets. EPA annualized the aggregate 

cost of $165,298 over three years at a seven percent annual discount rate.1

In total, EPA estimates an annual capital cost of $62,987 for the 190 file cabinets needed by the 

hazardous waste industry, under the LDR program. 

(3) Operation and Maintenance Costs

O&M costs are those costs associated with a paperwork requirement incurred continually over the 

life of the ICR. They are defined by the Paperwork Reduction Act of 1995 as “the recurring dollar 

amount of costs associated with O&M or purchasing services.” For this ICR, O&M costs include:

 Mailing costs: EPA estimates that respondents will incur a cost of $0.53 to mail a one-ounce 

package ($0.49 for postage and $0.04 for standard-size envelope). EPA also estimates that 

respondents will incur a cost of $5.25 for mailing a larger package (i.e., a five-ounce package) by 

certified mail ($1.82 for postage, $3.30 for the certified-mail fee, and $0.12 for a manila 

envelope). 

 Photocopying costs: EPA estimates that respondents will incur a cost of $0.11 for each 

photocopy they make. 

 Waste analysis costs: EPA estimates that each generator testing his/her waste will incur a cost of 

$2,185 per year in commercial laboratory testing costs. These costs were obtained from the 

previously approved LDR ICR (i.e., EPA ICR Number 1442.21) and updated to 2014 levels using 

a Consumer Price Index developed by the U.S. Bureau of Labor Statistics.

These O&M costs are shown in Exhibits 1 through 7 for all applicable respondent activities. 

 

1

 Based on an OMB-approved discount rate of seven percent (OMB Circular A-94) and a required 

three-year retention period for LDR records.
40

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN

EPA estimates the Federal agency average hourly labor cost to be $76.38 for legal staff (GS-15, 

Step 1), $54.94 for managerial staff (GS-13, Step 1), $38.56 for technical staff (GS-11, Step 1), and 

$23.44 for clerical staff (GS-06, Step 1). To derive these hourly estimates, EPA referred to the General 

Schedule (GS) Salary Table 2012. This publication summarizes the unloaded (base) hourly rate for 

various labor categories in the Federal Government. EPA then applied the standard government overhead 

factor of 1.6 to the unloaded rate to derive loaded hourly rates.

6(d) RESPONDENT UNIVERSE AND TOTAL RESPONDENT HOUR AND COST 

BURDEN

In estimating the number of respondents and associated waste streams subject to the LDR 

program, EPA referred to the Resource Conservation and Recovery Act Information (RCRAInfo) from 

the 2011 Biennial Report data. The total respondent universe is 90,500 (16,000 LQGs, 73,000 SQGs, and 

1,500 TSDFs)
41

Table 1

Annual Number of Respondents Subject to this ICR

Type of Respondent Number of 

Respondents

Number of LQGs 16,000

Number of SQGs 73,000

Number of Treatment Facilities 1,400

Number of Land Disposal Facilities 100

Number of waste streams sent directly to treatment facilities 297,000

Number of waste streams sent directly to land disposal 

facilities 18,500

Number of lab pack waste streams 103,000

Number of LQG-only that treat waste on site 1,350

Number of SQG-only that treat waste on site 0

Number of Recycling Facilities 1,000

Number of TSDFs 1,400

Following is a discussion of the estimates presented in the Exhibits.

(1) Treatment Surface Impoundment Exemption (Exhibit 1A &1B) 

Based on its best judgment, EPA estimates that, each year, one facility will seek a treatment 

surface impoundment exemption. This facility is expected to read the regulations at 40 CFR 268.4. The 

facility also is expected to prepare, submit, and keep copies of its treatment surface impoundment 

exemption application and certification.

(2) Procedures for Case-by-Case Extension (Exhibit 2A & 2B) 

EPA expects that few new LDR treatment standards will be published during the three-year 

period covered by this ICR. Based on its best judgment, the Agency estimates that, each year, one facility 

will petition EPA for an extension to an effective date for a treatment standard. This facility is expected 

to read the regulations at 40 CFR 268.5. The facility also is expected to prepare, submit, and keep copies 

of the application, any additional information requested by EPA in order to evaluate the application, and 

written progress reports.

EPA does not expect any facility to request a renewal of an extension to an effective date for a 

treatment standard or to notify the Agency of changes in the conditions in its application for an extension 

during the three-year period covered by this ICR.
42

(3) Waste Analysis and Recordkeeping (Exhibit 3A & 3B)

(a) Reading the Regulations - All Waste Handlers

EPA estimates that 90,500 LQGs, SQGs, TSDFs will be subject to waste analysis and 

recordkeeping requirements. Based on its consultations with industry, EPA expects these facilities to read 

the applicable LDR regulations each year.

(b) Generator Waste Analysis and Recordkeeping

Generator Waste Analysis (Section 268.7(a)(1))

EPA believes that waste testing will be performed to a greater extent by LQGs than SQGs, 

because LQGs generate greater hazardous waste volumes requiring characterization. EPA also believes 

such wastes are often complex and difficult to characterize solely through process knowledge. On the 

other hand, because many SQGs are small businesses that generate fewer waste streams and lower 

volumes of hazardous waste, EPA believes that many SQGs will be able to adequately characterize their 

waste streams using process knowledge. 

For purposes of this analysis, EPA estimates that approximately 50 percent of LQGs will test 

their waste and the other 50 percent will use process knowledge to determine if their waste is restricted 

from land disposal. EPA also estimates that 20 percent of SQGs will test their waste and 80 percent will 

use process knowledge. 

Generator Notification and Certification Requirements (Section 268.7(a)(2)-(4))

Section 268.7(a)(2) Notification Requirements

Based on RCRAInfo data, EPA estimates that, annually, 297,000 waste streams generated by 

LQGs and SQGs will not meet the existing applicable treatment standards. EPA derived this estimate by 

identifying all waste streams sent directly to the treatment facilities and assuming these streams did not 

meet applicable treatment standards. Based on industry consultations, EPA estimates that, each year, five 

percent of the LQG and SQG waste streams will require completion and delivery of a new or updated 

one-time notification. EPA’s consultations also indicate that, on average, each notification contains four 

waste streams. Thus, the annual number of notifications prepared and submitted by LQGs and SQGs 

with waste streams not meeting the treatment standards is estimated to be 3,700.

Section 268.7(a)(3) Notification and Certification Requirements

In reviewing RCRAInfo data on waste shipments meeting the LDR treatment standards, EPA was 

unable to distinguish between generator-initiated shipments versus treater-initiated shipments of wastes 

meeting the treatment standards. Rather, EPA’s query of RCRAInfo resulted in a single aggregate, 

annual estimate of all waste streams that meet the treatment standards (i.e., streams shipped from 

generators and treaters collectively). Because of this, the burden associated with the section 268.7(a)(3) 

requirement for generators is estimated along with the 268.7(b)(3) and (4) requirements for treaters. 

Refer to the subsection of this ICR entitled, “Treatment Facility Waste Analysis and Recordkeeping: 

Treatment Facility Notifications and Certifications: Section 268.7(b)(3)-(4) Notifications and 

Certification Requirements,” for a discussion of this burden estimate. 
43

Section 268.7(a)(4) Notification Requirements

Based on its best judgment, EPA estimates that no generators will submit a notice, under 40 CFR

268.7(a)(4), for hazardous waste or contaminated soil subject to an exemption from prohibition on the 

type of land disposal method utilized for the waste (e.g., waste under a national capacity variance). 

Generator Waste Analysis Plan (Section 268.7(a)(5))

Based on RCRAInfo data, EPA estimates that 1,350 LQGs treat waste on site to meet the 

applicable treatment standards. EPA derived this estimate by identifying all LQGs that treated waste on 

site and were not subject to RCRA permitting requirements. Based on its best judgment, EPA estimates 

that one percent of these LQGs will need to develop and follow a waste analysis plan each year. In 

addition, EPA estimates all LQGs will keep the waste analysis plan on site. Industry representatives 

contacted by the Agency believe that no SQGs treat prohibited waste on site under these conditions. 

[This ICR estimates the burden associated with the section 268.7(a)(5)(iii) requirement for notices and 

certifications in “Treatment Facility Waste Analysis and Recordkeeping: Treatment Facility Notifications 

and Certifications: Section 268.7(b)(3)-(4) Notifications and Certification Requirements.”]

Generator Recordkeeping Requirements (Section 268.7(a)(6)-(8))

Section 268.7(a)(6) Generator Recordkeeping Requirements

As discussed, EPA estimates that 22,600 generators will test their waste and that 66,400

generators will use process knowledge to determine if the wastes are restricted under Part 268 each year. 

These generators must keep records of their process knowledge determinations or analytical testing 

results, as required under section 268.7(a)(6). 

Section 268.7(a)(7) Generator Recordkeeping Requirements

Based on its best judgment, EPA estimates that, each year, 20 facilities will determine that they 

are managing a prohibited waste that is excluded from the definition of hazardous or solid waste or is 

exempted from Subtitle C regulation under 40 CFR 261.2 through 261.6 subsequent to the point of 

generation. These facilities are expected to place a one-time notice in their on-site files.

Section 268.7(a)(8) Generator Recordkeeping Requirements

Under 40 CFR 268.7(a)(8), generators are required to keep copies of all documentation produced 

pursuant to section 268.7(a) for at least three years. Thus, EPA estimates that generators will keep on site

106,700 notifications each year (i.e., 3,700 notifications for waste streams that do not meet treatment 

standards + 103,000 notifications for lab pack waste streams). 
44

Lab Pack and Toll Agreement Generator Requirements (Section 268.7(a)(9)-(10))

Lab Pack Generator Requirements (Section 268.7(a)(9))

Based on RCRAInfo data, EPA estimates that 103,000 lab pack waste streams are generated by 

LQGs and SQGs annually. EPA assumes that all generators producing these waste streams will wish to 

use the alternate treatment standards under 40 CFR 268.42(c). Pursuant to section 268.7(a)(9), with the 

initial shipment, these generators must send a notice and certification to the treatment facility. Generators 

must also send a new notification and certification if the waste or receiving facility changes. 

Based on industry consultations, EPA believes that the contents of lab pack shipments normally 

vary from shipment to shipment. Because of this, EPA estimates that each lab pack shipment requires 

completion and transmittal of a new or updated notification. Thus, the annual number of notifications and 

certifications prepared and submitted by LQGs and SQGs for lab packs is estimated to be 103,000.

Toll Agreement Generator Requirements (Section 268.7(a)(10))

EPA estimates that there are approximately 20,000 SQGs with tolling agreements.2 As required 

under section 268.7(a)(10), SQGs with a tolling agreement pursuant to 40 CFR 262.20(e) are required to 

comply with the applicable notification and certification requirements of section 268.7(a) for the initial 

shipment of waste subject to the agreement. This information collection requirement and associated 

burden hours are contained in the sections of this ICR entitled “Generator Waste Analysis and 

Recordkeeping: Generator Notification and Certification Requirements (Section 268.7(a)(2)-(4))” and 

“Generator Waste Analysis and Recordkeeping: Generator Recordkeeping Requirements (Section 

268.7(a)(6)-(8)).” 

(c) Treatment Facility Waste Analysis and Recordkeeping

Treatment Facility Notifications and Certifications

Section 268.7(b)(3)-(4) Notifications and Certification Requirements

Based on RCRAInfo data, EPA estimates that, each year, 18,500 as-generated wastes and treated 

wastes/residues meet the LDR treatment standards and are shipped to disposal facilities. EPA derived this 

estimate by identifying all waste streams sent directly to land disposal facilities and assuming these 

streams met applicable treatment standards. 

As mentioned, EPA was unable to distinguish between the as-generated streams versus the treated 

streams for purposes of this analysis; and thus, the Agency examines both types of streams in this 

subsection of the ICR. Specifically, generators and treaters shipping such wastes must send a one-time 

notice and certification with the initial shipment to the disposal facility. They also must send an updated 

notification and certification if the waste or receiving facility changes. 

Based on industry consultations, EPA assumes that, each year, 10 percent of the waste streams 

will require a new or updated notification and certification because of a change in the waste stream or the 

 

2

 Based on the supporting statement entitled, “Modifications of the Hazardous Waste Manifest 

System,” EPA ICR Number 801.
45

receiving facility. EPA’s consultations also indicate that, on average, each notification contains six waste 

streams.

Section 268.7(b)(5) Notification and Certification Requirements

Section 268.7(b)(5) requires that, if the waste or treatment residue will be further managed at a 

different treatment or storage facility, the treatment, storage, or disposal facility sending the waste or 

treatment residue off site must comply with the notice and certification requirements applicable to 

generators under section 268.7(a)(2)-(4). This information collection requirement and associated burden 

hours are contained in the section of this ICR entitled “Generator Waste Analysis and Recordkeeping: 

Generator Notification and Certification Requirements (Section 268.7(a)(2)-(4)).”

Section 268.7(b)(6) Notification and Certification Requirements

Based on RCRAInfo data and consultations with industry, EPA estimates that approximately 

1,000 facilities recycle hazardous waste each year. Based on its best judgment, EPA estimates that five 

percent of these facilities will ship recyclable materials that will be used in a manner that constitutes 

disposal under 40 CFR 266.20. These recyclers are expected to transmit a notice and certification to EPA 

with each shipment in accordance with section 268.7(b)(6). EPA estimates that, on average, each of the 

50 recyclers will perform this task 75 times per year, or 3,500 submittals in total. 

In addition, these 50 recyclers are expected to keep records of the name and location of each 

entity receiving the hazardous waste-derived product.

(d) Land Disposal Facility Waste Analysis and Recordkeeping

As described earlier, EPA estimates that, each year, generators and treaters will transmit 130

notices and certifications to the land disposal facility. Thus, EPA estimates that land disposal facilities 

will be required to keep copies of 130 notices and certifications annually, as required under section 

268.7(c)(1).

(e) Hazardous Debris Requirements

Based on industry consultations, EPA estimates that, each year, a tenth of one percent of LQGs 

treating waste on site and a tenth of one percent of treatment facilities will claim that their hazardous 

debris is excluded from the definition of hazardous waste under section 261.3(f) (i.e., debris treated by a 

specified extraction or destruction technology). Section 268.7(d)(1) requires these four facilities to 

submit a one-time notification when claiming the exclusion. 

In addition, based on industry consultations, EPA estimates that one percent of LQGs treating 

waste on site and one percent of treatment facilities have claimed that their hazardous debris is excluded 

from the definition of hazardous waste under section 261.3(f). EPA’s consultations also indicate that, 

each year, a tenth of one percent of these facilities will need to update their notifications because: (1) a 

different type of debris is treated, (2) a different treatment technology is employed, or (3) the treater ships 

the excluded waste to a different Subtitle D facility. 

EPA acknowledges that all facilities operating under the exclusion will have to maintain the 

records required in 40 CFR 268.7(d)(3) and that information will have to be recorded more frequently 

than once per year. The Agency has taken the frequency of activities into account in formulating its 
46

estimates of the number of hours taken for each activity. EPA expects that inspections, evaluations, and 

analyses of treated debris will be recorded four times per year. EPA expects that treatment data will be 

recorded quarterly. EPA expects that certifications of compliance for shipments will be recorded and 

placed on the facility’s files monthly.

(f) Contaminated Soil Requirements

Based on its best judgment, EPA estimates that, each year, one percent of LQGs and one percent 

of SQGs will determine that a contaminated soil subject to LDRs no longer contains a listed hazardous 

waste or exhibits a characteristic of hazardous waste and therefore, comply with 40 CFR 268.7(e). These 

generators are expected to prepare and maintain documentation of these determinations, including all 

supporting documentation.

(g) Special Rules for Characteristic Wastes

EPA queried RCRAInfo to estimate that 1,350 LQGs are treating their hazardous waste on site in 

90-day units. Based on industry consultations, EPA estimates that, each year, 10 percent of these LQGs

will de-characterize their waste and prepare, submit, and maintain an initial notification and certification 

under section 268.9(d). On the other hand, industry representatives contacted by the Agency believe that 

treatment facilities generally have been in existence for some time and have already submitted their initial 

notification and certification. Hence, this ICR assumes no treatment facilities will submit an initial notice 

and certification under this requirement during the period covered by this ICR

Based on industry consultations, EPA estimates that, each year, 10 percent of LQGs treating 

waste on site in 90-day units and 10 percent of treatment facilities will need to update their notification 

and certifications because of a change in the waste or the receiving facility. 

(4) Demonstration for Alternative Treatment Technology (Exhibit 4A & 4B)

Based on its best judgment, EPA estimates that, each year, four facilities will seek a variance 

from a specified treatment method. These facilities are expected to read the regulations at 40 CFR

268.42. In addition, these facilities are expected to prepare and submit a demonstration and any other 

information requested by EPA.

(5) Demonstration for a Variance from a Treatment Standard (Exhibit 5A & 5B)

(a) Reading the Regulations

Based on its best judgment, EPA estimates that, each year, ten facilities will seek a variance from 

a treatment standard. These facilities are expected to read the regulations at 40 CFR 268.44. 

(b) Demonstration for a Variance from a Treatment Standard

Demonstration for a Variance (Section 268.44(a)-(d))

EPA estimates that seven facilities will seek a variance from a treatment standard, as provided 

under section 268.44(a)-(d). These seven facilities are expected to develop and submit a demonstration 

and any other information requested by EPA.
47

Demonstration for a Site-Specific Variance (Section 268.44(h)-(m))

EPA estimates that three facilities will seek a site-specific variance from a treatment standard, as 

provided under section 268.44(h)-(m). These three facilities are expected to develop and submit a 

demonstration and any other information requested by EPA.

(6) Recordkeeping for Storage Prohibition (Exhibit 6A & 6B)

(a) Reading the Regulations

Based on RCRAInfo, EPA estimates that there are 1,500 TSDFs in operation. Based on its best 

judgment, EPA estimates that, each year, 10 percent of these facilities will store restricted hazardous 

wastes under 40 CFR 268.50. These facilities are expected to read the regulations at section 268.50.

(b) Recordkeeping for Storage Prohibition

EPA expects that the 150 TSDFs will develop and keep records of the contents of storage units, 

quantity of each hazardous waste received, and the date that accumulation begins for each tank and 

container, as applicable. EPA estimates that each of these 150 TSDFs will perform these tasks four times 

per year, or 600 times.

(7) Recordkeeping for No-Migration Variances (Exhibit 7)

EPA does not expect to receive a no-migration petition during the three-year effective life of this 

ICR renewal, however, this ICR costs out the burden of one no-migration variance petition.

6(e) Bottom Line Burden Hours and Costs

Table 2 below summarizes the annual hour and cost burden for respondents in both the private 

sector and State governments. The bottom line hourly burden for the Federal government (found in 

exhibits 8 and 9) is 3,814 hours. The bottom line cost burden for the Federal government is $142,298 per 

year.
48

Table 2

Bottom Line Annual Hour and Cost Burden

Number of 

Respondents

Total 

Annual 

Hour 

Burden

Total 

Annual 

Labor Cost

Total 

Annual 

Capital/

Startup 

Costs

Total 

Annual 

O&M Costs

Total Annual 

O&M & 

Capital/Startup 

Costs

Total Annual 

Cost

Private 82,942 599,490 $32,341,419 $34,146

$48,797,002

$48,831,148 $81,172,567

State 7,558 46,965 $1,587,545 $2,652

$3,905,753

$3,908,405 $5,495,950

Total 90,500 646,455 $33,928,964 $36,798

$52,702,755

$52,739,553 $86,668,517

6(f) Reasons for Change in Burden

The total annual hour burden in this ICR decreased by 561,927 hours, from 1,208,382 hours to 

646,455 hours. The total cost of this ICR decreased by approximately $45,157,550, from $161,734,819

to $86,668,517. This decrease is due to a better estimate in the number of small quantity generators 

(SQGs). Unlike large quantity generators that have to fill out a Hazardous Waste Report every 2 years, 

SQGs do not need to report. Therefore the total count of SQGs does not fluctuate with time, like the 

LQG count, rather it only increases. EPA felt the SQG universe estimate in this ICR was over-inflated 

because SQGs that no longer exist were still being counted. EPA developed a new methodology for 

counting SQGs which only includes those SQGs still in business as far back as 2007. This methodology, 

and the number it produced, was vetted and verified through several State hazardous waste agencies. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 7.14 hours per response. 

Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time 

needed to review instructions; develop, acquire, install, and utilize technology and systems for the 

purposes of collecting, validating, and verifying information, processing and maintaining information, 

and disclosing and providing information; adjust the existing ways to comply with any previously 

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and transmit or 

otherwise disclose the information. 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 are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
49

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 Number EPAHQ-RCRA-2013-0737, which is available for online viewing at www.regulations.gov, or in person 

viewing at the RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open 

from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for 

the Reading Room is (202) 566-1744, and the telephone number for the RCRA Docket is (202) 566-0270. 

An electronic version of the public docket is available at www.regulations.gov. This site can be used 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. When 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, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA-HQ-RCRA-2013-0737 and OMB Control Number 2050-0085 in any correspondence.
50

EXHIBIT 1A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.25 0.25 0.50 0.00 1.00 $78.67 $0.00 $0.00 1 1.00 $79

Develop and submit application to EPA 0.00 1.00 8.00 2.00 11.00 $582.67 $0.00 $5.24 1 11.00 $588

Maintain files of the application 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.33 1 0.10 $4

Complete and submit certification to EPA 0.25 0.25 1.00 0.50 2.00 $123.13 $0.00 $0.53 1 2.00 $124

TOTAL 0.50 1.50 9.50 2.60 14.10 $787.89 $0.00 $6.10 1 14.10 $794

TREATMENT SURFACE IMPOUNDMENT EXEMPTION

Reading the Regulations (268.4)

Application for Exemption (268.4(a)(3))

Certification (268.4(a)(4))

EXHIBIT 1B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.25 0.25 0.50 0.00 1.00 $45.56 $0.00 $0.00 1 1.00 $46

Develop and submit application to EPA 0.00 1.00 8.00 2.00 11.00 $365.97 $0.00 $5.24 1 11.00 $371

Maintain files of the application 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.33 1 0.10 $2

Complete and submit certification to EPA 0.25 0.25 1.00 0.50 2.00 $72.94 $0.00 $0.53 1 2.00 $73

TOTAL 0.50 1.50 9.50 2.60 14.10 $486.60 $0.00 $6.10 1 14.10 $493

TREATMENT SURFACE IMPOUNDMENT EXEMPTION

Reading the Regulations (268.4)

Application for Exemption (268.4(a)(3))

Certification (268.4(a)(4))
51

EXHIBIT 2A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.25 0.25 0.50 0.00 1.00 $78.67 $0.00 $0.00 1 1.00 $79

Complete and submit certified application to EPA 0.50 1.00 8.00 2.00 11.50 $647.14 $0.00 $5.24 1 11.50 $652

Develop and submit additional information to EPA 0.00 0.25 1.00 0.50 1.75 $90.90 $0.00 $0.53 1 1.75 $91

Develop and submit renew al request to EPA 0.25 0.25 2.00 0.50 3.00 $177.90 $0.00 $0.53 0 0.00 $0

Notify EPA of any changes 0.00 0.25 0.50 0.50 1.25 $63.51 $0.00 $0.53 0 0.00 $0

Provide w ritten progress reports to EPA 0.00 0.25 0.50 0.50 1.25 $63.51 $0.00 $0.53 1 1.25 $64

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 15.50 $887

Notifications and Progress Reports (268.5(f)-(g))

PROCEDURES FOR CASE-BY-CASE EXTENSION

Reading the Regulations (268.5)

Application for Extension (268.5(a)-(c))

Renewal of Extension (268.5(e))

EXHIBIT 2B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.25 0.25 0.50 0.00 1.00 $45.56 $0.00 $0.00 1 1.00 $46

Complete and submit certified application to EPA 0.50 1.00 8.00 2.00 11.50 $395.73 $0.00 $5.24 1 11.50 $401

Develop and submit additional information to EPA 0.00 0.25 1.00 0.50 1.75 $58.06 $0.00 $0.53 1 1.75 $59

Develop and submit renew al request to EPA 0.25 0.25 2.00 0.50 3.00 $106.37 $0.00 $0.53 0 0.00 $0

Notify EPA of any changes 0.00 0.25 0.50 0.50 1.25 $41.35 $0.00 $0.53 0 0.00 $0

Provide w ritten progress reports to EPA 0.00 0.25 0.50 0.50 1.25 $41.35 $0.00 $0.53 1 1.25 $42

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 15.50 $547

Notifications and Progress Reports (268.5(f)-(g))

PROCEDURES FOR CASE-BY-CASE EXTENSION

Reading the Regulations (268.5)

Application for Extension (268.5(a)-(c))

Renewal of Extension (268.5(e))
52

EXHIBIT 3A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the regulations - LQGs 0.00 0.25 0.75 0.00 1.00 $60.13 $0.00 $0.00 15,401 15,401.00 $926,062

Read the regulations - SQGs 0.00 0.25 0.75 0.00 1.00 $60.13 $0.00 $0.00 66,091 66,091.00 $3,974,052

Read the regulations - Treatment Facilities 0.00 0.25 0.75 0.00 1.00 $60.13 $0.00 $0.00 1,349 1,349.00 $81,115

Read the regulations - Land Disposal Facilities 0.00 0.25 0.75 0.00 1.00 $60.13 $0.00 $0.00 101 101.00 $6,073

Test the w aste 0.00 0.00 20.00 0.00 20.00 $1,095.40 $0.00 $2,331.00 20,919 418,380.00 $71,676,862

Use process know ledge 0.00 0.00 0.50 0.00 0.50 $27.39 $0.00 $0.00 60,574 30,287.00 $1,659,122

For w aste or contaminated soil that does not meet the 

applicable treatment standards, complete and transmit 

notification and certifications, as applicable 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.00 3,713 1,670.85 $72,366

For w aste or contaminated soil that can be land 

disposed w ithout further treatment, complete and 

transmit notice and certification, as applicable 0.00 0.00 0.20 0.35 0.55 $22.91 $0.00 $0.00 0 0.00 $0

For w aste or contaminated soil subject to an 

exemption, complete and transmit notice and 

certification, as applicable 0.00 0.00 1.20 0.25 1.45 $74.26 $0.00 $0.00 0 0.00 $0

Develop and follow w aste analysis plan 0.00 0.25 4.00 0.50 4.75 $255.21 $0.00 $0.00 13 61.75 $3,318

Maintain the w aste analysis plan on site 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.00 1,329 132.90 $4,545

Complete and transmit to the receiving facility a onetime notification and certification 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.00 0 0.00 $0

Keep records of all supporting data used to make LDR 

w aste or contaminated soil determination - testing 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.00 20,919 2,091.90 $71,543

Keep records of all supporting data used to make LDR 

w aste or contaminated soil determination - process 

know ledge 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.00 60,574 6,057.40 $207,163

Develop and keep records of notice of generation, 

exclusion from regulation, and disposition of excluded 

w aste 0.00 0.00 0.50 0.10 0.60 $30.80 $0.00 $0.00 20 12.00 $616

Keep records of all other documentation 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.11 103,226 10,322.60 $364,388

For generators of lab packs, submit notification and 

certification 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.22 99,513 44,780.85 $1,961,401

For SQGs in a tolling agreement, transmit and retain 

copy of notification and certification 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.00 0 0.00 $0

Toll Agreement Generator Requirements (268.7(a)(10))

Section 268.7(a)(7) Generator Recordkeeping Requirements

Section 268.7(a)(8) Generator Recordkeeping Requirements

Section 268.7(a)(2) Notification Requirements

Section 268.7(a)(3) Notification and Certification Requirements

Section 268.7(a)(4) Notification Requirements

Section 268.7(a)(6) Generator Recordkeeping Requirements

Reading the Regulations - All Waste Handlers (268.7 and 268.9)

Generator Waste Analysis (268.7(a)(1))

WASTE ANALYSIS AND RECORDKEEPING

Generator Notification and Certification Requirements (268.7(a)(2)-(4))

Generator Waste Analysis and Recordkeeping

Generator Recordkeeping Requirements (268.7(a)(6)-(8))

Lab Pack and Toll Agreement Generator Requirements (268.7(a)(9)-(10))

Lab Pack Generator Requirements (268.7(a)(9))

Generator Waste Analysis Plan (268.7(a)(5))
53

EXHIBIT 3A (cont.)

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Complete, submit, and keep a copy of the notice and 

certification sent to land disposal facility 0.00 0.00 0.20 0.35 0.55 $22.91 $0.00 $0.11 308 169.40 $7,090

Comply w ith the notification and certification 

requirements applicable to generators 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.00 0 0.00 $0

For recyclable materials, complete and submit a notice

and certification to EPA w ith each shipment 0.00 0.00 0.20 0.25 0.45 $19.49 $0.00 $0.53 1,950 877.50 $39,039

For recycling facilities, keep records of entities

receiving hazardous w aste-derived products 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.11 26 2.60 $92

Keep copies of notices and certifications 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.00 308 30.80 $1,053

Prepare and submit one-time notification to EPA 0.00 0.50 0.50 0.25 1.25 $74.03 $0.00 $0.53 2 2.50 $149

Update and submit to EPA notification w ith changes 0.00 0.00 0.25 0.00 0.25 $13.69 $0.00 $0.53 0 0.00 $0

Keep records of all inspections, evaluations, and 

analyses of treated debris 0.00 0.00 0.17 0.10 0.27 $12.73 $0.00 $0.11 112 30.24 $1,438

Keep records of data or information obtained during 

treatment 0.00 0.00 0.17 0.10 0.27 $12.73 $0.00 $0.11 112 30.24 $1,438

Keep a certification of compliance for each shipment 

of treated debris 0.00 0.00 0.17 0.10 0.27 $12.73 $0.00 $0.11 336 90.72 $4,314

Prepare one-time documentation 0.00 0.00 0.25 0.00 0.25 $13.69 $0.00 $0.11 815 203.75 $11,247

Maintain supporting documentation on site 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.00 815 81.50 $2,787

Prepare and submit a one-time notification and 

certification to EPA 0.00 0.00 0.40 0.50 0.90 $38.98 $0.00 $0.53 133 119.70 $5,255

Maintain files of notification and certification on site 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.11 133 13.30 $469

Update and submit to EPA the notification and 

certification annually, if changes occur 0.00 0.00 0.40 0.50 0.90 $38.98 $0.00 $0.53 268 241.20 $10,589

Maintain updated certification and notification 0.00 0.00 0.00 0.10 0.10 $3.42 $0.00 $0.11 268 26.80 $946

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 598,660 $81,094,533

Hazardous Debris Requirements (268.7(d))

Special Rules for Characteristic Wastes (268.9(d))

Contaminated Soil Requirements (268.7(e))

Section 268.7(b)(3)-(4) Notification and Certification Requirements

Section 268.7(b)(5) Notification and Certification Requirements

Land Disposal Facility Waste Analysis and Recordkeeping (268.7(c)(1))

Treatment Facility Notifications and Certifications (268.7(b)(3)-(6))

Section 268.7(b)(6) Notification and Certification Requirements

WASTE ANALYSIS AND RECORDKEEPING

Treatment Facility Waste Analysis and Recordkeeping (268.7(b))
54

EXHIBIT 3B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the regulations - LQGs 0.00 0.25 0.75 0.00 1.00 $39.04 $0.00 $0.00 590 590.00 $23,034

Read the regulations - SQGs 0.00 0.25 0.75 0.00 1.00 $39.04 $0.00 $0.00 6,900 6,900.00 $269,376

Read the regulations - Treatment Facilities 0.00 0.25 0.75 0.00 1.00 $39.04 $0.00 $0.00 30 30.00 $1,171

Read the regulations - Land Disposal Facilities 0.00 0.25 0.75 0.00 1.00 $39.04 $0.00 $0.00 6 6.00 $234

Test the w aste 0.00 0.00 20.00 0.00 20.00 $668.60 $0.00 $2,331.00 1,675 33,500.00 $5,024,330

Use process know ledge 0.00 0.00 0.50 0.00 0.50 $16.72 $0.00 $0.00 5,815 2,907.50 $97,227

For w aste or contaminated soil that does not meet the 

applicable treatment standards, complete and transmit 

notification and certifications, as applicable 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.00 0 0.00 $0

For w aste or contaminated soil that can be land 

disposed w ithout further treatment, complete and 

transmit notice and certification, as applicable 0.00 0.00 0.20 0.35 0.55 $14.15 $0.00 $0.00 0 0.00 $0

For w aste or contaminated soil subject to an 

exemption, complete and transmit notice and 

certification, as applicable 0.00 0.00 1.20 0.25 1.45 $45.45 $0.00 $0.00 0 0.00 $0

Develop and follow w aste analysis plan 0.00 0.25 4.00 0.50 4.75 $158.35 $0.00 $0.00 0 0.00 $0

Maintain the w aste analysis plan on site 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.00 30 3.00 $64

Complete and transmit to the receiving facility a onetime notification and certification 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.00 0 0.00 $0

Keep records of all supporting data used to make LDR 

w aste or contaminated soil determination - testing 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.00 1,675 167.50 $3,568

Keep records of all supporting data used to make LDR 

w aste or contaminated soil determination - process 

know ledge 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.00 5,815 581.50 $12,386

Develop and keep records of notice of generation, 

exclusion from regulation, and disposition of excluded 

w aste 0.00 0.00 0.50 0.10 0.60 $18.85 $0.00 $0.00 20 12.00 $377

Keep records of all other documentation 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.11 3,600 360.00 $8,064

For generators of lab packs, submit notification and 

certification 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.22 3,600 1,620.00 $44,064

For SQGs in a tolling agreement, transmit and retain 

copy of notification and certification 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.00 0 0.00 $0

Toll Agreement Generator Requirements (268.7(a)(10))

Section 268.7(a)(7) Generator Recordkeeping Requirements

Section 268.7(a)(8) Generator Recordkeeping Requirements

Section 268.7(a)(2) Notification Requirements

Section 268.7(a)(3) Notification and Certification Requirements

Section 268.7(a)(4) Notification Requirements

Section 268.7(a)(6) Generator Recordkeeping Requirements

Reading the Regulations - All Waste Handlers (268.7 and 268.9)

Generator Waste Analysis (268.7(a)(1))

WASTE ANALYSIS AND RECORDKEEPING

Generator Notification and Certification Requirements (268.7(a)(2)-(4))

Generator Waste Analysis and Recordkeeping

Generator Recordkeeping Requirements (268.7(a)(6)-(8))

Lab Pack and Toll Agreement Generator Requirements (268.7(a)(9)-(10))

Lab Pack Generator Requirements (268.7(a)(9))

Generator Waste Analysis Plan (268.7(a)(5))
55

EXHIBIT 3B (cont.)

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Complete, submit, and keep a copy of the notice and 

certification sent to land disposal facility 0.00 0.00 0.20 0.35 0.55 $14.15 $0.00 $0.11 0 0.00 $0

Comply w ith the notification and certification 

requirements applicable to generators 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.00 0 0.00 $0

For recyclable materials, complete and submit a notice

and certification to EPA w ith each shipment 0.00 0.00 0.20 0.25 0.45 $12.02 $0.00 $0.53 75 33.75 $941

For recycling facilities, keep records of entities

receiving hazardous w aste-derived products 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.11 1 0.10 $2

Keep copies of notices and certifications 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.00 0 0.00 $0

Prepare and submit one-time notification to EPA 0.00 0.50 0.50 0.25 1.25 $49.98 $0.00 $0.53 0 0.00 $0

Update and submit to EPA notification w ith changes 0.00 0.00 0.25 0.00 0.25 $8.36 $0.00 $0.53 0 0.00 $0

Keep records of all inspections, evaluations, and 

analyses of treated debris 0.00 0.00 0.17 0.10 0.27 $7.82 $0.00 $0.11 0 0.00 $0

Keep records of data or information obtained during 

treatment 0.00 0.00 0.17 0.10 0.27 $7.82 $0.00 $0.11 0 0.00 $0

Keep a certification of compliance for each shipment 

of treated debris 0.00 0.00 0.17 0.10 0.27 $7.82 $0.00 $0.11 0 0.00 $0

Prepare one-time documentation 0.00 0.00 0.25 0.00 0.25 $8.36 $0.00 $0.11 75 18.75 $635

Maintain supporting documentation on site 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.00 75 7.50 $160

Prepare and submit a one-time notification and 

certification to EPA 0.00 0.00 0.40 0.50 0.90 $24.04 $0.00 $0.53 3 2.70 $74

Maintain files of notification and certification on site 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.11 3 0.30 $7

Update and submit to EPA the notification and 

certification annually, if changes occur 0.00 0.00 0.40 0.50 0.90 $24.04 $0.00 $0.53 6 5.40 $147

Maintain updated certification and notification 0.00 0.00 0.00 0.10 0.10 $2.13 $0.00 $0.11 6 0.60 $13

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 46,747 $5,485,874

Hazardous Debris Requirements (268.7(d))

Special Rules for Characteristic Wastes (268.9(d))

Contaminated Soil Requirements (268.7(e))

Section 268.7(b)(3)-(4) Notification and Certification Requirements

Section 268.7(b)(5) Notification and Certification Requirements

Land Disposal Facility Waste Analysis and Recordkeeping (268.7(c)(1))

Treatment Facility Notifications and Certifications (268.7(b)(3)-(6))

Section 268.7(b)(6) Notification and Certification Requirements

WASTE ANALYSIS AND RECORDKEEPING

Treatment Facility Waste Analysis and Recordkeeping (268.7(b))
56

EXHIBIT 4A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 1.00 0.00 1.50 $92.88 $0.00 $0.00 4 6.00 $372

Develop and submit application to EPA 0.00 1.00 8.00 2.00 11.00 $582.67 $0.00 $5.24 4 44.00 $2,352

TOTAL 0.00 1.50 9.00 2.00 12.50 $675.55 $0.00 $5.24 4 50.00 $2,723

DEMONSTRATION FOR ALTERNATIVE TREATMENT TECHNOLOGY

Reading the Regulations (268.42)

Demonstration for Alternative Treatment Technology (268.42(b))

EXHIBIT 4B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 1.00 0.00 1.50 $61.37 $0.00 $0.00 4 6.00 $245

Develop and submit application to EPA 0.00 1.00 8.00 2.00 11.00 $365.97 $0.00 $5.24 4 44.00 $1,485

TOTAL 0.00 1.50 9.00 2.00 12.50 $427.34 $0.00 $5.24 4 50.00 $1,730

DEMONSTRATION FOR ALTERNATIVE TREATMENT TECHNOLOGY

Reading the Regulations (268.42)

Demonstration for Alternative Treatment Technology (268.42(b))
57

EXHIBIT 5A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 0.00 1.00 1.50 $72.26 $0.00 $0.00 10 15.00 $723

Develop and submit demonstration and additional

information to EPA 0.00 1.00 8.00 2.00 11.00 $582.67 $0.00 $5.24 7 77.00 $4,115

Develop and submit demonstration and additional

information to EPA 0.00 1.00 8.00 2.00 11.00 $582.67 $0.00 $5.24 3 33.00 $1,764

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 125.00 $6,602

Demonstration for a Site-Specific Variance (268.44(h)-(m))

DEMONSTRATION FOR A VARIANCE FROM A TREATMENT STANDARD

Reading the Regulations (268.44)

Demonstration for a Variance (268.44(a)-(d))

EXHIBIT 5B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 0.00 1.00 1.50 $49.27 $0.00 $0.00 10 15.00 $493

Develop and submit demonstration and additional

information to EPA 0.00 1.00 8.00 2.00 11.00 $365.97 $0.00 $5.24 7 77.00 $2,598

Develop and submit demonstration and additional

information to EPA 0.00 1.00 8.00 2.00 11.00 $365.97 $0.00 $5.24 3 33.00 $1,114

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 125.00 $4,205

Demonstration for a Site-Specific Variance (268.44(h)-(m))

DEMONSTRATION FOR A VARIANCE FROM A TREATMENT STANDARD

Reading the Regulations (268.44)

Demonstration for a Variance (268.44(a)-(d))
58

EXHIBIT 6A

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $128.93/ $76.21/ $54.77/ $34.15/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 1.00 0.00 1.50 $92.88 $0.00 $0.00 139 208.50 $12,910

Develop and keep records of data 0.00 0.00 0.50 0.25 0.75 $35.92 $0.00 $0.00 556 417.00 $19,972

TOTAL 0.00 0.50 1.50 0.25 2.25 $128.80 $0.00 $0.00 Varies 625.50 $32,882

RECORDKEEPING FOR STORAGE PROHIBITION

Reading the Regulations (268.50)

Recordkeeping for Storage Prohibition (268.50(a)(2))

EXHIBIT 6B

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $59.51/ $55.87/ $33.43/ $21.33/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Regulations 0.00 0.50 1.00 0.00 1.50 $61.37 $0.00 $0.00 3 4.50 $184

Develop and keep records of data 0.00 0.00 0.50 0.25 0.75 $22.05 $0.00 $0.00 12 9.00 $265

TOTAL 0.00 0.50 1.50 0.25 2.25 $83.42 $0.00 $0.00 Varies 13.50 $449

RECORDKEEPING FOR STORAGE PROHIBITION

Reading the Regulations (268.50)

Recordkeeping for Storage Prohibition (268.50(a)(2))
59

EXHIBIT 7

ANNUAL RESPONDENT BURDEN FOR NO-MIGRATION VARIANCES

Legal Managerial Technical Clerical Respondent Labor Cost Capital O & M Number of Total Hours Total Cost

Hours Hours Hours Hours Hours per 3 years 3 per years Startup Costs Costs Respondent per year per year

ACTIVITY $128.93 $76.21 $54.77 $34.15 Activities

Read Regulations and Guidance Manual 0 10 80 0 90 $5,143.70 $0.00 $0.00 0.333 30 $1,713

Legal Counsel 300 0 0 0 300 $38,679.00 $0.00 $0.00 0.333 100 $12,880

Compiling Administrative Information 0 40 350 0 390 $22,217.90 $0.00 $0.00 0.333 130 $7,399

Description of Specific w astes and Units 0 80 500 0 580 $33,481.80 $0.00 $0.00 0.333 193 $11,149

Performing Waste Analyses 0 140 1300 0 1440 $81,870.40 $0.00 $0.00 0.333 480 $27,263

Performing Unsaturated and Saturated 

Zone Monitoring 0 150 1300 0 1450 $82,632.50 $0.00 $0.00 0.333 483 $27,517

Comprehensive Characterization of Site 0 80 550 0 630 $36,220.30 $0.00 $0.00 0.333 210 $12,061

Presentation of Waste Analyses,

Monitoring, and QA/QC Results 0 25 200 0 225 $12,859.25 $0.00 $0.00 0.333 75 $4,282

Preparing Monitoring Plans (Waste and 

unsaturated/Saturated Zones) 0 35 200 0 235 $13,621.35 $0.00 $0.00 0.333 78 $4,536

Performing Unsaturated/Saturated Zone 

Modeling 0 40 300 0 340 $19,479.40 $0.00 $0.00 0.333 113 $6,487 Interpretation & Presentation of

Unsaturated and Saturated Zone 

Modeling and Monitoring Results and 

Conclusions 0 20 150 0 170 $9,739.70 $0.00 $0.00 0.333 57 $3,243

Performing Air Modeling 0 40 370 0 410 $23,313.30 $0.00 $0.00 0.333 137 $7,763

Preparing Air Monitoring Plan 0 20 150 0 170 $9,739.70 $0.00 $0.00 0.333 57 $3,243

Performing Air Monitoring Program 0 200 1600 0 1800 $102,874.00 $0.00 $0.00 0.333 599 $34,257

Interpretation & Presentation of Air

Modeling and Monitoring Results and 

Conclusions 0 40 370 0 410 $23,313.30 $0.00 $0.00 0.333 137 $7,763

Performing Uncertainty Analyses 0 20 150 0 170 $9,739.70 $0.00 $0.00 0.333 57 $3,243

Preparing Quality Assurance and 

Quality Control Plans 0 30 250 0 280 $15,978.80 $0.00 $0.00 0.333 93 $5,321

Certifying Compliance w ith all Applicable 

Law s 0 5 50 0 55 $3,119.55 $0.00 $0.00 0.333 18 $1,039

Certification of Truth and Accuracy 0 1 10 0 11 $623.91 $0.00 $0.00 0.333 4 $208

Compilation/Transmittal of Three Copies

of the Petition 0 0 0 350 350 $11,952.50 $0.00 $121.00 0.333 117 $4,020

Total 300 976 7880 350 9506 $556,600.06 $0.00 $121.00 0.333 3,168 $185,387

No-Migration Variance Petitions -- Prepare and Gather Information/ Present in Written Form
60

EXHIBIT 8

ANNUAL AGENCY BURDEN FOR NO-MIGRATION VARIANCES

Legal Managerial Technical Clerical Respondent Labor Cost Capital O & M Number of Total Hours Total Cost

Hours Hours Hours Hours Hours per year per year Startup Costs Costs Respondent per year per year

ACTIVITY $76.38 $54.94 $38.56 $23.44 Activities

Preliminary Evaluation of Petition 0 25 225 0 250 $10,049.50 $0.00 $0.00 0.333 83 $3,346

Site Visit 0 25 25 0 50 $2,337.50 $0.00 $0.00 0.333 17 $778

Technical Review 0 150 600 0 750 $31,377.00 $0.00 $0.00 0.333 250 $10,449

Tentative Decision/Notice 0 100 200 50 350 $14,378.00 $0.00 $0.00 0.333 117 $4,788

Final Review and Decision 0 100 200 50 350 $14,378.00 $0.00 $0.00 0.333 117 $4,788

Total 0 400 1250 100 1750 $72,520.00 $0.00 $0.00 0.333 584 $24,149

No-Migration Variance Petition
61

EXHIBIT 9

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL AGENCY HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $76.38/ $54.94/ $38.56/ $23.44/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review demonstration or request for modification and 

approve/deny exemption 0.00 0.50 4.00 0.00 4.50 $181.71 $0.00 $0.00 1 4.50 $182

Review w ritten certification 0.00 0.00 0.50 0.00 0.50 $19.28 $0.00 $0.00 1 0.50 $19

Keep records of demonstration and w ritten certification 0.00 0.00 0.00 0.10 0.10 $2.34 $0.00 $0.00 1 0.10 $2

Subtotal 0.00 0.50 4.50 0.10 5.10 $203.33 $0.00 $0.00 1 5.10 $203

Review and keep records of application 1.00 0.50 6.00 0.25 7.75 $341.07 $0.00 $0.00 1 7.75 $341

Request, review , and keep records of any additional 

information 1.00 0.25 4.00 0.50 5.75 $256.08 $0.00 $0.00 1 5.75 $256

Issue notice and provide opportunity for comment 1.50 0.50 0.00 1.00 3.00 $165.48 $0.00 $0.00 1 3.00 $165

Consult w ith State agencies 0.25 0.25 2.00 0.00 2.50 $109.95 $0.00 $0.00 1 2.50 $110

Approve/deny extension and publish decision 1.00 0.50 32.00 1.00 34.50 $1,361.21 $0.00 $0.00 1 34.50 $1,361

Receive, review , and keep records of the renew al request 1.00 0.25 4.00 0.25 5.50 $250.22 $0.00 $0.00 0 0.00 $0

Consult w ith State agencies 1.00 0.25 1.50 0.00 2.75 $147.96 $0.00 $0.00 0 0.00 $0

Issue notice and provide opportunity for comment 1.50 0.50 32.00 1.00 35.00 $1,399.40 $0.00 $0.00 0 0.00 $0

Approve/deny extension and publish decision 1.00 0.50 32.00 1.00 34.50 $1,361.21 $0.00 $0.00 0 0.00 $0

Receive and keep records of any changes 0.00 0.25 0.00 0.10 0.35 $16.08 $0.00 $0.00 0 0.00 $0

Receive, review , and keep records of progress reports 0.00 0.25 0.50 0.10 0.85 $35.36 $0.00 $0.00 1 0.85 $35

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 54.35 $2,269

Application for Exemption and Certification (268.4)

Notifications and Progress Reports (268.5(f)-(g))

TREATMENT SURFACE IMPOUNDMENT EXEMPTION

PROCEDURES FOR CASE-BY-CASE EXTENSION

Application for Extension (268.5(a)-(c))

Renewal of Extension (268.5(e))
62

EXHIBIT 9 (cont.)

LAND DISPOSAL RESTRICTIONS ICR

ESTIMATED ANNUAL AGENCY HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $76.38/ $54.94/ $38.56/ $23.44/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Inspect w aste analysis plan in the facility's on-site files 0.00 0.00 0.50 0.25 0.75 $25.14 $0.00 $0.00 13 9.75 $327

Receive, review , and keep records of the notification 

and certification submitted by the recycling facility 

w ith each shipment 0.00 0.00 0.50 0.25 0.75 $25.14 $0.00 $0.00 1,950 1,462.50 $49,023

Receive, review , and keep records of one-time 

notification 0.00 0.00 0.25 0.25 0.50 $15.50 $0.00 $0.00 2 1.00 $31

Receive, review , and keep records of updates sent 

from ow ner/operator 0.00 0.00 0.25 0.25 0.50 $15.50 $0.00 $0.00 0 0.00 $0

Make determination that contaminated soil does not 

contain hazardous w aste 0.00 0.25 0.50 0.25 1.00 $38.88 $0.00 $0.00 815 815.00 $31,687

Receive, review , and file notification and certification 0.00 0.25 0.50 0.25 1.00 $38.88 $0.00 $0.00 133 133.00 $5,171

Receive, review , and keep records of update 

notification and certification w ith annual changes 0.00 0.00 0.50 0.25 0.75 $25.14 $0.00 $0.00 268 201.00 $6,738

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 2,622.25 $92,977

Receive, review , and keep records of the application 0.00 0.50 4.00 0.25 4.75 $187.57 $0.00 $0.00 4 19.00 $750

Approve/deny application 0.00 0.25 1.00 0.50 1.75 $64.02 $0.00 $0.00 4 7.00 $256

Develop w ritten approval 0.00 0.25 2.00 0.50 2.75 $102.58 $0.00 $0.00 4 11.00 $410

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 4 37.00 $1,417

Receive, review , and keep records of the petition 1.00 0.50 6.00 0.25 7.75 $341.07 $0.00 $0.00 7 54.25 $2,387

Request additional information or samples if required 1.00 0.25 4.00 0.50 5.75 $256.08 $0.00 $0.00 7 40.25 $1,793

Send additional copies to the States 0.00 0.00 0.00 0.25 0.25 $5.86 $0.00 $0.53 7 1.75 $45

Issue notice and provide opportunity for comment 1.50 0.50 0.00 1.00 3.00 $165.48 $0.00 $0.00 7 21.00 $1,158

Approve/deny petition and publish decision 1.00 0.50 32.00 1.00 34.50 $1,361.21 $0.00 $0.00 7 241.50 $9,528

Receive, review , and keep records of the petition 1.00 0.50 6.00 0.25 7.75 $341.07 $0.00 $0.00 3 23.25 $1,023

Request additional information or samples if required 1.00 0.25 4.00 0.50 5.75 $256.08 $0.00 $0.00 3 17.25 $768

Issue notice and provide opportunity for comment 1.50 0.50 0.00 1.00 3.00 $165.48 $0.00 $0.00 3 9.00 $496

Approve/deny petition 1.00 0.50 32.00 1.00 34.50 $1,361.21 $0.00 $0.00 3 103.50 $4,084

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 511.75 $21,283

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 3,230.45 $118,149

Hazardous Debris Requirements (268.7(d))

WASTE ANALYSIS AND RECORDKEEPING

Generator Waste Analysis Plan (268.7(a)(5))

Treatment Facility Notifications and Certifications (268.7(b)(6))

Demonstration for Alternative Treatment Technology (268.42(b))

DEMONSTRATION FOR A VARIANCE FROM A TREATMENT STANDARD

Contaminated Soil Requirements (268.7(e))

Demonstration for a Site-Specific Variance (268.44(h)-(m))

Demonstration for a Variance (268.44(a)-(d))

DEMONSTRATION FOR ALTERNATIVE TREATMENT TECHNOLOGY

Special Rules for Characteristic Wastes (268.9(d))
63

EXHIBIT 10A

LAND DISPOSAL RESTRICTIONS ICR

TOTAL ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN SUMMARY

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Year Year Costs Costs Year

Treatment Surface Impoundment Exemption (Exhibit 1A) 14 $788 $0 $6 $794

Procedures for Case-By-Case Extension (Exhibit 2A) 16 $880 $0 $6 $887

Waste Analysis and Recordkeeping (Exhibit 3A) 598,660 $32,297,618 $0 $48,796,916 $81,094,533

Demonstration for Alternative Treatment Technology (Exhibit 4A) 50 $2,702 $0 $21 $2,723

Demonstration for a Variance from a Treatment Standard (Exhibit 5A) 125 $6,549 $0 $52 $6,602

Recordkeeping for Storage Prohibition (Exhibit 6A) 626 $32,882 $0 $0 $32,882

Annual Capital Costs of File Cabinets NA NA $34,146 NA $34,146

TOTAL 599,490 $32,341,419 $34,146 $48,797,002 $81,172,567

EXHIBIT 10B

LAND DISPOSAL RESTRICTIONS ICR

TOTAL ESTIMATED ANNUAL STATE RESPONDENT HOUR AND COST BURDEN SUMMARY

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Year Year Costs Costs Year

Treatment Surface Impoundment Exemption (Exhibit 1B) 14 $487 $0 $6 $493

Procedures for Case-By-Case Extension (Exhibit 2B) 16 $541 $0 $6 $547

Waste Analysis and Recordkeeping (Exhibit 3B) 46,747 $1,580,207 $0 $3,905,667 $5,485,874

Demonstration for Alternative Treatment Technology (Exhibit 4B) 50 $1,709 $0 $21 $1,730

Demonstration for a Variance from a Treatment Standard (Exhibit 5B) 125 $4,152 $0 $52 $4,205

Recordkeeping for Storage Prohibition (Exhibit 6B) 14 $449 $0 $0 $449

Annual Capital Costs of File Cabinets NA NA $2,652 NA $2,652

TOTAL 46,965 $1,587,545 $2,652 $3,905,753 $5,495,950
64