### SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.17

“2015 HAZARDOUS WASTE REPO RT, NOTIFICATION OF

REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS

WASTE PERMIT APPLICATIO N AND MODIFICATION”

January 22, 2015

Office of Resource Conservation and Recovery United States Environmental Protection Agency Washington, D.C. 20460

### TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION ....................................................... 3 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 .............................................................................. 5 2(a) NEED AND AUTHORITY FOR THE COLLECTION ........................................................... 5 2(b) PRACTICAL UTILITY AND USERS OF THE DATA .......................................................... 6

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ................ 9 3(a) NONDUPLICATION ........................................................................................................... .... 9 3(b) PUBLIC NOTICE ............................................................................................................ ......... 9 3(c) CONSUL TATIONS ............................................................................................................ ...... 9 3(d) EFFECTS OF LESS FREQUENT COLLECTION ................................................................ 15 3(e) GENERAL GUIDELINES ...................................................................................................... 16 3(f) CONFIDENTIALITY .......................................................................................................... ... 17 3(g) SENSITIVE QUESTIONS ...................................................................................................... 17

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .............................................. 18 4(a) RESPONDENTS AND NAICS CODES ................................................................................ 18 4(b) INFORMATION REQUESTED ............................................................................................. 18

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT ...................................................... 34 5(a) AGENCY ACTIVITIES ........................................................................................................ . 34 5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................ 37 5(c) SMALL ENTITY FLEXIBILITY ........................................................................................... 37 5(d) COLLECTION SCHEDULE .................................................................................................. 38

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION .............................. 42 6(a) ESTIMATING RESPONDENT BURDEN HOURS .............................................................. 42 6(b) ESTIMATING RESPONDENT COSTS ................................................................................ 47 6(c) ESTIMATING AGENCY HOUR AND COST BURDEN .................................................... 49 6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR

AND COST BURDEN ............................................................................................................ 50 6(e) BOTTOM LINE HOUR AND COST BURDEN ................................................................... 62 6(f) REASONS FOR CHANG E IN BURDEN .............................................................................. 63 6(g) PUBLIC BURDEN STATEMENT ......................................................................................... 663 1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF TH E INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification,” EPA ICR Number 0976.17.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

This is a request to renew a currently appr oved ICR of the U.S. Environmental Protection Agency (EPA): “2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Applicati on and Modification,” EPA ICR Number 0976.16 (OMB Control Number 2050-0024). The ICR addresses the following requirements:

 Hazardous Waste Report requirements of Sections 3002 and 3004 of the Resource Conservation and Recovery Act (RCRA), as amended, which require reporting to

EPA or to authorized States at least ev ery two years. The Hazardous Waste Report [EPA Form 8700-13 Form A/B], or comparable State report, is used by generators and treatment, storage, and disposal facili ties (TSDFs) to satisfy this requirement.

 Notification requirements of Section 3010 of RCRA, as amended; 40 CFR 260.42 (hazardous secondary material activity) ; 40 CFR Part 262, Subpart K (alternative generator standards for academic labor atories); 40 CFR Part 273, Subpart C (universal waste activity); and 40 CFR Pa rt 279 (used oil activity). EPA Form 8700-12 is used by facilities to satisfy this requirement.

 Permit application requirements of Sections 3004 and 3005 of RCRA, as amended,

which require anyone who owns or operates a facility where hazardous waste is treated, stored, or disposed to have a RCRA hazardous waste permit issued by EPA. There are two parts to a RCRA hazardous wa ste permit application: Part A and

Part B. Part A consists of EPA Form 8700-23, or comparable State form, along with maps, drawings, and photographs, as requi red by 40 CFR 270.13. Part B contains detailed, site-specific information. Th ere is no form for the Part B Permit Application; rather, the Part B Permit A pplication must be submitted in narrative

form and contain the information describe d in applicable se ctions of 40 CFR 270.14 through 270.27. This ICR addresses the information collection requirements associated with completing and submitting a Part A Permit Applic ation, or modifying a hazardous waste permit by submitting a re vised application. The information collection requirements associated with th e Part B Permit Application are covered under a separate ICR.

EPA integrated the above requirements into th is ICR to ensure consistency and minimize duplication in its burden assumptions and estimate s, given that all three requirements address some of the same reporting elements. In particul ar, all three requirements address the use of the RCRA Subtitle C Site Identification Form (i.e., th e Site ID Form). Specifically, the Hazardous4 Waste Report addresses the requirement for large quantity generators (LQGs) 1 and TSDFs to prepare and submit the Site ID Form as part of their Hazardous Waste Report. The notification addresses the requirement for all regulated entiti es to submit the Site ID Form (or alternative document, if specified) to notify EPA or the aut horized State of regulated waste activity. The Part A Permit Application addre sses the requirement for all owner/operators of TSDFs to submit the Site ID Form as part of their Part A Perm it Applications or Part A Permit Modifications. Incorporating these three requirements into this ICR has allowed EPA to more comprehensively

estimate the burden of the Site ID Form a nd other collections, ensure consistency and nonduplication in its analysis, and addr ess changes to the Site ID Form.

1 An LQG is a facility that generates 1,000 kilogram s (2,200 pounds) or more of hazardous waste in any single calendar month, or more than 1 kilogram (2.2 pounds) of acute hazardous waste in any single calendar month, or more than 100 kilograms (220 pounds) of acute hazardous waste spill cl ean-up material in any single calendar

month.5 2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORIT Y FOR THE COLLECTION

(1) Hazardous Waste Report

RCRA Sections 3002 and 3004 authorize the Ha zardous Waste Report. Both sections require EPA to establish standards for recordkeep ing and reporting of hazardous waste. Section 3002 applies to hazardous waste generators and Section 3004 applies to hazardous waste TSDFs. The implementing regulations are found at 40 CF R 262.40(b) and (d); 262.41(a)(1)-(5), (a)(8), and (b); 264.75(a)-(e) and (j); 265.75(a)-(e) and (j); and 270.30( l)(9). This is mandatory reporting by the respondents.

Section 3002(a)(6) requires subm ission of reports to EPA or th e States at least every two years on the: (1) quantities and nature of hazardo us wastes that have been generated during the year and (2) disposition of these hazardous wastes.

Section 3004(a) requires EPA to issue regula tions establishing performance standards applicable to owners and operators of facilities for the treatment, storage, or disposal of hazardous waste that include reporting and maintain ing records of all hazardous wastes treated, stored, or disposed and the manner in which su ch wastes were treated, stored, or disposed.

There are a number of uses of the Hazardous Waste Report data. EPA uses these data for planning and developing regulations. In a ddition, Hazardous Waste Report data allow the Agency to determine whether its regulations ar e having the desired effect on the generation and management of hazardous waste. For ex ample, Hazardous Waste Report data provide

information on whether wastes have shifted from one method of dis posal to another. Some State uses of Hazardous Waste Report data include: support of planning, fee assessment, compliance monitoring, and enforcement.

(2) Notification of Regulated Waste Activity

Section 3010 of Subtitle C of RCRA, as amended, requires any person who generates, transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal of regulated wastes to not ify EPA of their activities, including the location and general description of the activities and the regulated wast es handled. As required by statute, EPA promulgated regulations to implem ent these notification requirements at 40 CFR Parts 262, 263, 264, 265, 266, 270, 273, and 279. EPA needs this information to determine the universe of persons who generate, handle, and manage these regulated wastes; assign EPA Identification Numbers; and ensure that these regulated wastes are managed in a way that protects human health and the environm ent, as required by RCRA, as amended.

(3) Part A Hazardous Waste Permit Application and Modification

EPA promulgated regulations at 40 CFR 270.1 requiring owners or operators of TSDFs to submit a Part A Permit Application. EPA need s information contained in the Part A Permit6 Application to identify the person(s) legall y responsible for hazardous waste activity, to determine which facilities require permits under more than one program, to assess potential for the facility to pollute nearby ground and surface waters, to identif y the time frame available for EPA to process permit applications, and to define th e specific wastes a facility is legally allowed to handle for different purposes.

EPA promulgated regulations at 40 CFR 270.72 ou tlining changes that require owners or operators to submit revised Part A Permit A pplications. Section 270.72(a)(1)-(3) requires owner/operators to submit both a re vised Part A Permit Application and a written justification for changes in the design capacity of processes used at the facility, and/or ch anges or additions in a facility's hazardous waste treatment, storage, or disposal processes. Under Section 270.72(a)(4), if an owner or operator changes ownership, or oper ational control of a faci lity, the new owner or operator is required to submit a revised Part A Permit Application, and a Subpart H compliance demonstration. EPA needs revised permit a pplications, justifications, and compliance

demonstrations to determine whether desired ch anges are acceptable or should be more closely reviewed as part of a full permit issuance process.

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Hazardous Waste Report

Implementation of the RCRA program require s the collection of information on the characteristics of the regulated community genera lly (e.g., number of generators and TSDFs), as well as the specific characteristics of individual sites (e.g., waste ha ndling activities undertaken).

This information is used for waste activit y monitoring, compliance monitoring, technical assistance, program planning, waste minimizatio n, and other program activities taken by EPA

and the States. The information also is used by public interest groups (such as the Right-toKnow Network) and industry.

The Hazardous Waste Report also provides info rmation to States for tracking shipments of waste. Many States do not collect or track manifests, which provide, information on off-site shipments of hazardous waste; therefore, the Hazardous Waste Report serves as the only source

of this information.

EPA compiles and publishes the National Biennial RCRA Hazardous Waste Report based on the data for each odd number reporting year . The reports for 1991 to 2013 are available on

the Internet at http://www.epa.gov/waste/inforesour ces/data/biennialreport/index.htm

.

EPA and the States have many uses for Hazardous Waste Report information, including:

 Describing the various source activities th at generate hazardous waste and the generated waste type s and quantities.

 Describing the management methods by whic h the waste is treated, disposed, or recycled and the quantities managed by each method.7  Providing information for analysis of tre nds in waste generation, waste treatment and disposal, recycli ng, and source reduction.

 Understanding how much waste a State receives from out of State or sends out of

State.

 Estimating available capacity for treati ng, recycling, and disposing hazardous

wastes.

Additionally, EPA utilizes th e Hazardous Waste Report information for planning and developing regulations; regulati on development depends on desc riptions and quantities of generated hazardous waste and management methods used for treatment, recycling, and disposal. The information allows the Agency to determ ine whether regulations are having the desired effect on the generation and management of haza rdous waste; for example, the report provides

information on whether the treatment of wastes has shifted from one method to another. EPA also uses the information for conducting technical assistance, planning f acility inspections, and carrying out regulatory enforcement. States use the information for many of the same purposes as EPA; other State uses include planning, se tting waste minimization goals, assessing fees, monitoring compliance, and carrying out enforcement.

EPA and States receive requests for the information from many public and private organizations, including government agencies, busi nesses, public interest groups, and interested citizens. Many requests come from businesses that supply chemicals, equipment, and services to hazardous waste generators and TSDFs.

(2) Notification of Regulated Waste Activity

EPA enters notification information submitte d by respondents into an EPA national data system and assigns EPA Identification Numbers. EPA uses the information primarily for tracking purposes, and secondarily for a variety of enforcement and inspection purposes. In addition, EPA uses this informa tion to identify the universe of regulated waste generators, handlers, and managers and their specific regulated waste activi ties. Finally, EPA uses this information to ensure that regulated waste is managed properly, that st atutory provisions are upheld, and that regulations are adhered to by facili ty owners or operators.

(3) Part A Hazardous Waste Permit Application and Modification

EPA uses information in the Part A Permit A pplication to define which processes can be used and which wastes can be handled at newly regulated facilities subject to permitting requirements for the first time and permitted facilit ies with newly regulated units. This includes defining allowable changes in facility operations and applies to new facilities not yet constructed; newly regulated f acilities subject to RCRA permitti ng requirements for the first time; permitted facilities with newly regulated un its; and interim status facilities. EPA uses information in the Part A Permit Application to:

 Set priorities for processing permit applications;8  Respond to requests from hazardous waste generators for the names and locations of facilities where they can send their wast e for storage, treatment, or disposal;

 Respond to public and Congressional inqui ries regarding part icular hazardous waste management facilities; and

 Ensure that facilities are not operating in a manner unprotective of human health

and the environment.

EPA uses information from revised Part A Permit Applications and associated justifications and Subpart H compliance demonstr ations to determine whether desired changes are acceptable under interim status or whether the change should be more closely reviewed as part of a full permit issuance process. In a ddition, modifying the Pa rt A Permit Application allows inspectors to have up-to-date informati on on major aspects of th e facility, including the size of the operation, the hazardous wastes handle d, and the types of processes used. Without this documentation, EPA would be unable to determ ine the owner or operat or's compliance with the management standards of 40 CFR Parts 264 or 265 or the rules governing changes during

interim status. This documentation also is usef ul for both EPA and the owner or operator in an

enforcement action.9 3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) NONDUPLICATION

The information collected under this ICR is not available from any source other than respondents. EPA’s Office of Resource Conserva tion and Recovery (ORCR) is the only office within the Agency requiring th e recordkeeping or reporting of this information. No other Federal agency or department collects this information.

The RCRA site identification informa tion is collected on one common form

― the Site ID

Form

― for the Hazardous Waste Report, the Notifica tion of Regulated Waste Activity, and the RCRA Hazardous Waste Part A Permit Applicat ion. A respondent may submit a copy of a previously reported Site ID Form and note any changes; this verifies and updates the site

identification information.

3(b) PUBLIC NOTICE

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

the Federal Register on June 18, 2014 (79 FR 34733). The notice indicated that EPA was planning to submit an ICR, “ 2015 Hazardous Waste Report, Notif ication of Regulated Waste Activity, and Part A Hazardous Waste Permit A pplication and Modifica tion” (EPA ICR No. 0976. 17, OMB Control No. 2050–0024), to the Office of Management and Budget (OMB) for review and approval in accordance with th e Paperwork Reduction Act. The notice also requested comments on the information collection a nd burden estimates covered in the ICR. The public comment period extended through August 18, 2014. EPA received no comments on this ICR in response to the Federal Register notice.

3(c) CONSULTATIONS

Most of the data and assumptions in th is ICR are based on EPA consultations with industry and States, or data from the Resource Conservation and Recovery Act Information (RCRAInfo) system 2 . In developing this current ICR, EP A carefully reviewed all of the ICR’s data and assumptions and determined that a few should be strengthe ned based on additional consultations. Specifically, EPA conducted consu ltations on the ICR’s assumptions regarding respondents’ hourly burden for completi ng and submitting Hazardous Waste Reports, Notifications of Regulated Waste Activit y, and Part A Permit Applications.

Table 1 identifies the orga nizations contacted.

2 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA (i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.10 Table 1 Organizations EPA Contacted during the Development of this ICR (September-October 2014)

Organization Contact Name Phone Number Email Address

Industry

Clean Harbors Stephen Bley (513 ሻ 823

‐ 2284 bleys@cleanharbors.com

Ineos USA Chad Ulm Not Available chad.ulm@ineos.com

Milestone AV Technologies Jason Showell (513) 489-3222 jason.showell@milestone.com

Retriev Technologies Annabella Troiano (740 ሻ 653

‐ 6290 atroiano@retrievtech.com

Ross Incineration Services Susan Kaiser ( 440) 748-5847 skaiser@rossenvironmental.com

Rush-Presbyterian-St. Luke's

Medical Center Eric Sondergaard (312) 942

‐ 7233 Not Available

Safety Clean Kelly Dale Taylor (608) 298-6420 kelly.d.taylor@safety-kleen.com

US Ecology Noel Bailey (208) 834.2275

Ext. 2314 noel.bailey@usecology.com

US Ecology (Envirite) Colletta Campbell (708) 596

‐ 7040 Not Available

State Agencies

Idaho Department of Environmental Quality Rene Anderson (208) 373-021 0 Rene.Anderson@deq.idaho.gov

Illinois Environmental Protection Agency Hope Wright (217) 785-2361 Hope.Wright@Illinois.gov

Ohio Environmental Protection Agency Paula Canter (614) 644-2917 paula.canter@epa.ohio.gov

South Dakota Department of

Environment & Natural Resources Dustin Witt (605) 773-3153 Dustin.Witt@state.sd.us

The following paragraphs summarize the f eedback obtained on the burden associated

with various information collection activities.

(1) Hazardous Waste Report

(a) Industry

 Prepare Site ID Form of the Haza rdous Waste Report using blank form. EPA was informed by the majority of consultants that the ICR’s original bur den for preparing the Site ID Form of the Hazardous Waste Report using a blank form (i.e., 1 hour per facility) was a reasonable estimate. However, some consultants provided a longer duration for the burden estimate, which ranged from 2 to 3 hour s. Based on the consultation information,11 EPA re-estimated the burden for preparing the Site ID Form of the Hazardous Waste Report using a blank form to 1.26 hours per facility.

 Prepare Site ID Form of the Hazardou s Waste Report using pre-populated form. EPA was informed by the majority of consultants th at the ICR's original burden for preparing

the Site ID Form of the Hazardous Waste Report using a pre-populated form (i.e., 20 minutes per facility) was a reasonable estima te. However, some consultants provided a longer duration for the burden estimate, whic h ranged from 1 to 2.5 hours. Based on the consultation information, EPA re-estimated the burden for preparing th e Site ID Form of the Hazardous Waste Report using a pre-populat ed form to be 0.61 hours per facility.

(b) State Agencies

 Distribute and collect Hazardous Waste Report forms and instructions. EPA

received mixed feedback about the ICR's or iginal burden for dist ributing and collecting the Hazardous Waste Report forms and instructio ns (i.e., 46 minutes per facility) from the four State agencies contacted. Two State ag encies indicated that the ICR’s original

burden estimate was a realistic national aver age, while the other two State agencies disagreed with the burden estimate. Suggest ed burden estimates ranged from less than

one minute to 1.53 hours. Based on the State information, EPA re-estimated the burden for distributing and collecting the Hazardous Wa ste Report forms and instructions to be 0.77 hour per facility.

 Assisting respondents. EPA received mixed feedback about the ICR's original burden for assisting respondents (i.e., 1 hour and 1 minute per facility) from the four State agencies contacted. Two State agencies indi cated that the ICR’s original burden estimate was a realistic national average, while the ot her two State agencies disagreed with the burden estimate. Suggested burden estimat es ranged from one minute to 1.08 hours. Based on the State information, EPA re-estimat ed the burden for assisting respondents to be 0.78 hour per facility.

 Key entry of report submissions that were not submitted electronically. EPA was informed by the majority of consultants that the ICR's original bur den for key entering report submissions that were not submitted el ectronically (i.e., 21 minutes per facility) was a reasonable estimate. However, some consultants provided a shorter duration. The suggested burden estimate was 6.9 minutes. Based on the consultation information, EPA re-estimated the burden for key entering report submissions that were not submitted electronically to be 0.31 hour per facility.

 Perform quality assurance. EPA was informed by some of the consultants that the ICR's original burden for performing quality a ssurance (i.e., 20 minut es per facility) was a reasonable estimate. However, one consultant provided a longer duration. The suggested burden estimate was 25 minutes. Based on the consultation information, EPA re-estimated the burden for performing quality assurance to be 0.37 hour per facility.12 (2) Notification of Regulated Waste Activity

(a) Industry

 Complete and submit initial notifica tion using a blank Site ID Form. EPA was informed by some of the consultants that the ICR’s original burden for completing and submitting an initial notification using a blank Site ID Form (i.e., 1 hour per facility) was a realistic industry average. However, some consultants provided a longer duration. The suggested burden estimate was 2 hours. Based on the consultation information, EPA reestimated the burden for completing and subm itting an initial notification using a blank Site ID Form to be 1.09 hours per facility.

 Complete and submit subsequent notification using a blank Site ID Form. EPA was informed by some consultants that the ICR’s original burden for completing and submitting a subsequent notification using a blank Site ID Form (i.e., 40 minutes per facility) was a realistic indus try average. However, some consultants provided longer durations. Suggested burden estimates ra nged from 1 hour to 2 hours. Based on the consultation information, EPA re-estimated the burden for completing and submitting a subsequent notification using a blank Site ID Form to be 0.83 hour per facility.

 Complete and submit subsequent notificatio n using a previously submitted Site ID

Form. EPA was informed by some consultant s that the ICR’s original burden for completing and submitting a subsequent notification using a previously submitted Site ID Form (i.e., 20 minutes per facility) was a re alistic industry average. However, some consultants provided longer duration times. Suggested burden estimates ranged from 40

minutes to 1 hour. Based on the consultati on information, EPA re-e stimated the burden for completing and submitting an initial notific ation using a blank Site ID Form to be 0.45 hour per facility.

(b) State Agencies

 Review initial notification s ubmitted using Site ID Form. EPA was informed by all State agencies contacted that the ICR’s original burden for reviewing an initial notification submitted using a Site ID Form (i .e., 15 minutes per facility) was a realistic national average. Based on the consulta tion information, the average burden for reviewing an initial notification submitted us ing a Site ID Form remained at 0.25 hour per facility.

 Enter initial notification information into RCRAInfo. EPA received mixed feedback about the ICR's original burden for enteri ng initial notification information into RCRAInfo (i.e., 2 hours and 15 minutes per fa cility) from the four State agencies contacted. Two State agencies indicated that the ICR’s original burden estimate was a realistic national average, while the other tw o State agencies disagreed with the burden estimate. Suggested burden estimates ra nged from 15 minutes to 1.25 hours. Based on the consultation information, EPA re-estimated the burden for enteri ng initial notification information into RCRAInfo to be 1.50 hours per facility.13  Generate EPA Identification Number and send EPA Identification Number to facility. EPA was informed by most States that the ICR’s original burden for generating an EPA Identification Number and sending the EPA Identification Number to a facility (i.e., 30 minutes per facility) was a realistic national average. However, one State provided a revision to this burden estimate . The suggested burden estimate was

7 minutes. Based on the consultation info rmation, EPA re-estimated the burden for generating an EPA Identification Number a nd sending the EPA Identification Number to a facility to be 0.42 hour per facility.

 Review subsequent notification submitted using Site ID Form. EPA was informed by all State agencies contacted that the ICR’s original burden for reviewing a subsequent notification submitted using a Site ID Form (i .e., 15 minutes per facility) was a realistic national average. Based on the consulta tion information, the average burden for reviewing a subsequent notification submitte d using a Site ID Form remained at 0.25 hour per facility.

 Enter subsequent notification information into RCRAInfo. EPA received mixed feedback about the ICR's original burden fo r entering subsequent notification information into RCRAInfo (i.e., 2 hours and 15 minutes per facility) from the f our State agencies contacted. Two State agencies indicated that the ICR’s original burden estimate was a realistic national average, while the other tw o State agencies disagreed with the burden estimate. Suggested burden estimates ra nged from 10 minutes to 1.25 hours. Based on the consultation information, EPA re-estim ated the burden for entering subsequent

notification information into RCRAInfo to be 1.49 hours per facility.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Industry

 Read the regulations and instructions. EPA was informed by most of the industry consultants that the ICR’s original burden for reading the regulations and instructions (i.e., 6 hours per facility) was a realistic industry average. However, some consultants provided revisions to this bur den estimate, ranging from 10 hours to 15 hours. Based on the consultation information, EPA re-estimated the burden for readi ng the regulations and instructions to be 7.13 hours per facility.

 Prepare Hazardous Waste Permit Information Form. EPA was informed by most industry consultants that the ICR’s origin al burden for prepari ng the Hazardous Waste Permit Information Form (i.e., 12 hours and 30 minutes per facility) was a realistic industry average. However, one consultant prov ided a revision to this burden estimate. The suggested burden estimate was 30 hours. Based on the consultation information, EPA re-estimated the burden for preparing a Hazardous Waste Permit Information Form to be 15.45 hours per facility.14  Obtain signatures and certifications for Part A Permit Application, reports, and other information requested by EPA. EPA was informed by all organizations contacted that the ICR’s original burden for obtaining signa tures and certifications for Part A Permit Application, reports, and other informa tion requested by EPA (i.e., 2 hours and 30 minutes per facility) was a realistic industry average. Based on the consultation information, the average burden for obtaining si gnatures and certifications for Part A Permit Application, reports, and other info rmation requested by EPA remained at 2.5 hours per facility.

 Obtain a new authorization for invalid authorizations. EPA was informed by all organizations contacted that the ICR’s origin al burden for obtaining a new authorization for invalid authorizations (i.e., 2 hours per facility) was a realistic industry average. Based on the consultation information, the average burden for obtaining a new

authorization for invalid au thorizations remained at 2 hours per facility.

 Submit Part A Permit Application and reports. EPA was informed by all organizations contacted that the ICR’s original burden fo r submitting a Part A Permit Application and reports (i.e., 3 hours per facility) was a re alistic industry average. Based on the consultation information, the average burden for submitting a Part A Permit Application and reports remained at 3 hours per facility.

 Explain or cure an alleged deficiency in Part A Permit Application, if required. EPA was informed by most industry consultants that the ICR’s original burden for explaining or curing an alleged deficiency in a Part A Permit Application (i.e., 3 hours and 30 minutes per facility) was a rea listic industry average. Howeve r, some of the consultants provided longer durations, which ranged from 10 hours to 40 hours. Based on the consultation information, EPA re-estimated the burden for explaining or curing an alleged deficiency in a Part A Permit A pplication to be 5.37 hour s per facility.

(b) State Agencies

 Review Part A Permit Applications. EPA was informed by all State agencies contacted that the ICR’s original burden for review ing a Part A Permit Application (i.e., 3 hours and 15 minutes per facility) was a realistic na tional average. Based on the consultation information, the average burden for reviewing a Part A Permit Application remained at 3.25 hour per facility.

 Ensure that Part A Permit Application and reports have been signed by appropriate

person. EPA was informed by all State agenci es contacted that the ICR’s original burden for ensuring that a Part A Permit App lication and reports have been signed by the appropriate person (i.e., 15 minut es per facility) was a realis tic national average. Based on the consultation information, the average burden for ensuring that a Part A Permit Application and reports have been signe d by the appropriate person remained at 0.25 hour per facility.15  Review newly authorized signatures when a different individual or position gains responsibility for the overall operation of a facility. EPA was informed by some consultants that the ICR’s original burden for reviewing newly authorized signatures

when a different individual or position gains responsibility for the overall operation of a facility (i.e., 15 minutes per facility) was a realistic nati onal average. However, one consultant provided a revision to this burden estimate. The suggested burden estimate

was 30 minutes. Based on the consultation in formation, EPA re-estimated the burden for reviewing newly authorized signatures when a different individual or position gains responsibility for the overall operation of a facility to be 0.32 hour per facility.

 Review signature certifications. EPA was informed by all State agencies contacted that the ICR’s original burden for reviewing si gnature certifications (i.e., 15 minutes per facility) was a realistic nati onal average. Based on the consultation information, the average burden for reviewing signature certif ications remained at 0.25 hour per facility.

 Enter Part A Permit Applicat ion information into RCRAInfo. EPA was informed that the ICR's original burden for entering Part A Permit Application information into RCRAInfo (i.e., 1 hour per facility) was a re alistic national average. Based on the consultation information, the average burde n for entering Part A Permit Application information into RCRAInfo remained at 1 hour per facility.

 Notify applicant of deficiency in the Part A Permit Application. EPA received mixed feedback about the ICR's original burden for notifying an applicant of a deficiency in the Part A Permit Application (i.e., 36 minutes pe r facility) from the four State agencies contacted. Two State agencies indicated that the ICR’s original burden estimate was a realistic national average, while the other tw o State agencies disagreed with the burden estimate. The suggested burden estimate was1 hour. Based on the consultation information, EPA re-estimated the burden for no tifying an applicant of a deficiency in the Part A Permit Application to be 0.81 hour per facility.

The above feedback is reflected in the burden assumptions of this ICR, as appropriate. Detailed information on EPA’s assumptions re garding these and other activities are fully

discussed in Section 6 of this document.

3(d) EFFECTS OF LESS FREQUENT COLLECTION

EPA has carefully considered the information collection burden imposed by the information collection requirements covered in this ICR. EPA is confident that those activities required of respondents are necessary and, to the extent possible, the Agency has attempted to minimize the burden imposed. A number of the required activities, for example, will be performed once (e.g., one-time notifications). EPA believes strongly that, if the minimum information collection requirements are not met, EPA will not be able to ensure that hazardous waste and hazardous secondary material is being properly managed and do not pose a threat to

human health and the environment.

(1) Hazardous Waste Report16 For the Hazardous Waste Report, the two-ye ar cycle is statutorily required. Although

some States collect information on an annual or quarterly basis, EPA does not require more frequent data collection.

(2) Notification of Regulated Waste Activity

New hazardous waste generators, transpor ters, or TSDFs must submit EPA Form 8700-12 (i.e., the Site ID Form) and obtain an EPA Identification Number prior to treating (including recycling), storing, tr ansporting, offering for transport, or disposing of hazardous waste. Existing hazardous waste generators, tr ansporters, or TSDFs ar e required to notify the Agency of their hazardous waste activity(ies) not later than 90 days af ter the promulgation or revision of regulations in 40 CFR Part 261 (ide ntification and listing of hazardous wastes). Owners or operators of smelting, melting, and refi ning furnaces that process hazardous waste either solely for metals recovery or for recove ry of economically signifi cant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site bu rner exemption under section 266.108(d) must provide a written, one-time notification of th eir hazardous waste activ ities. Under Section 273.32(a), large quantity handlers of universal waste must submit a written, one-time notification of universal waste management to the Regional Administrator and obtain an EPA Identification Number before meeting or exceeding the 5,000 kilogr am storage limit, unless they already have notified EPA, as provided by section 273.32(a) (2) or 273.32(a)(3). Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who have not previously complied with the notification requirement (under 40 CFR Part 266, Subpart E) must submit a written, one-time notification of used oil manage ment activities and obtain an EP A Identification Number. Any reduction in the frequency of this information co llection would prevent the Agency from meeting the statutory requirement s of RCRA Section 3010.

(3) Part A Hazardous Waste Permit Application and Modification

A respondent's provision of information on a Part A Permit Application is essentially a one-time exercise that must occur when a facility is new or if an existing facility becomes subject to new permitting requirements. Subsequent re visions to the Part A Permit Application are necessary only if an interim stat us facility changes its ownershi p and/or process or management of wastes. EPA strongly believes that if the minimum requirements specified under the regulations are not met, neither the facilities nor EPA can ensure that hazardous wastes are being properly managed, and do not pose a serious threat to human hea lth and the environment.

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stat ed in the Paperwork Reduction Act of 1995, OMB’s implementing regulations, applicable OMB guidance, and EP A’s ICR Handbook. In addition, this information collection complies with EPA’s Data Standards and Information Quality Guidelines.17 3(f) CONFIDENTIALITY

(1) Hazardous Waste Report

The Hazardous Waste Report requires businesses to provide information on various aspects of hazardous waste generation and manageme nt. Some businesses consider some of their

hazardous waste information to be Confidential Business Informati on (CBI). A business may, if it desires, protect its Hazardous Waste Report in formation from public disclosure by asserting a claim of confidentiality c overing all or part of its informati on. If a confidentiality claim were asserted, EPA will treat the information in accord ance with the confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also will ensure that the information collection procedures comply with the Privacy Act of 1974 and the OMB Circular 108.

(2) Notification of Regulated Waste Activity

The Agency does not anticipate that busine sses will assert a claim of confidentiality covering all or part of the information submitted as part of their notifications. However, if a confidentiality claim were asserted, EPA will treat the information in accordance with the confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also will ensure that the information collection procedures comply with the Privacy Act of 1974 and the OMB

Circular 108.

(3) Part A Hazardous Waste Permit Application and Modification

All information submitted in a Part A Permit Application or revision will be subject to public disclosure, without notice to the facility, in accordance with the Freedom of Information Act (5 U.S.C. Section 552) and EPA Freedom of Information Regulations at 40 CFR Part 2. Because of the general nature of the info rmation requested, only a few Part A Permit Applications to date have qualif ied for exemption to disclosure under the business confidentiality exception. Claims of confidentiality must be clea rly indicated on the forms and attachments, and must be accompanied, at the time of filing, by a written substantiation of the claim in accordance with 40 CFR Part 2, Subpart B (particularly th e information described at 40 CFR 2.204(e)).

Information that is determined to be confidentia l is placed in a secured "confidential file" for future use. Only persons with special clearance for confidential information have access to these

files.

3(g) SENSITIVE QUESTIONS

No questions of a sensitive nature are in cluded in any of the information collection requirements covered in this ICR.18 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

The following is a list of North American Industry Classification System (NAICS) codes associated with industries most likely affect ed by the information collection requirements

covered in this ICR.

NAICS Code Description NAICS Code

Agriculture, Forestry, Fishing, and Hunting 11

Mining 21

Utilities 22

Construction 23

Manufacturing 31-33

Wholesale Trade 42

Retail Trade 44-45

Transportation and Warehousing 48-49

Information 51

Finance and Insurance 52

Real Estate, Rental, Leasing 53

Professional, Scientific, and Technical Services 54

Management of Companies and Enterprises 55

Administrative Support, Waste Management, and Remediation 56

Educational Services 61

Health Care and Social Assistance 62

Arts, Entertainment, Recreation 71

Accommodation and Food Services 72

Other Services 81

Public Administration 92

4(b) INFORMATION REQUESTED

(1) Hazardous Waste Report

The Hazardous Waste Report consists of four forms: RCRA Subtitle Site Identification Form (Site ID Form), Waste Generation and Ma nagement (Form GM), Waste Received from Off-Site (Form WR), and Off-Site Identificati on (Form OI; used only by States). Only LQGs and TSDFs are required to comple te the Hazardous Waste Report.

As with most of the RCRA program, the Hazar dous Waste Report data collection process is delegated to the States. States provide res pondents with either the Federal form or a State equivalent, collect the responses, contact non-resp ondents, enter the data (or load files if the19 State employs electronic methods for preparati on and submittal of reports by regulated entities) into RCRAInfo using off-the-shelf software pack ages which have been developed to support the collection of Hazardous Waste Report data, assure data quality, and forward the data to EPA.

States have discretion on the methods used to identify entities to whom they distribute forms and the subsequent tracking of reports rece ived. Most States gene rate mailing lists based on previous report submittals, augmented by recent notifications of regulated activity. Many States levy fees based on the natu re and extent of regulated activit y identified in the report. EPA makes all reported data (except any that may be claimed as CBI) available to the public on the Internet. This provides further incentive for sites (and also for States and EPA) to ensure the information is complete and accurate because th e public regularly accesses this information.

(i) Data Items:

 Site ID Form - RCRA Subtitle C Site Identification Form. The Site ID Form must be submitted by all sites re quired to file the Hazardous Waste Report. This form collects information such as site name, EPA Identification Number, address, co ntact, and type of hazardous waste generation and management activities ta king place at the site; it verifies their information, especially the site’s generator status as the date of submission of the report. It requir es a certification signature for the submission of the report.

 Form GM - Waste Generation and Management

. Form GM must be submitted by all respondents that generated or shipped large quantity generator amounts of RCRA hazardous waste during the reporting year. This form collects information on each generated waste, including a narrative waste description, a waste characterization (waste codes, source, and form), quantity generated, and the method of waste management (whether managed on-site or shipped off-site).

 Form WR - Waste Received From Off-Site

. Form WR must be submitted by all sites that received RCRA hazardous waste from off-site during the reporting year. This form collects information on each waste received from off-site, including a narrative desc ription of the waste, a brief waste characterization (e.g., waste codes), th e EPA Identification Number of the off-site generator, the quantity of waste received, and the method of waste

management.

 Form OI - Off-Site Identification

. Form OI is not required by EPA; rather, it is provided as an option for States to collect the names and addresses of transporters, generators that ship waste, and receivers of waste reported on Forms GM and WR where only the EPA Identification

Number is listed.20 (ii) Respondent Activities:

Facilities (i.e., LQGs and TSDFs) must perf orm the following activities, as applicable:

 Read the Hazardous Waste Report instructions.

 Gather information and complete Site ID Form.

 Gather information and complete Form GM.

 Gather information and complete Form WR.

 Gather information and complete FormOI if required by the State (Stateoptional form, not a Federal form).

 Submit the report to the State (or EP A Regional Office for some States and Territories).

 Maintain a copy of each form for three years.

State agencies must perform the following activities:

 Distribute Hazardous Waste Report forms and instructions.

 Assist respondents.

 Key entry of report submissions.

 Perform quality assurance.

(2) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

40 CFR 260.42(a) provides that hazardous secondary material generators, tolling contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous secondary materials which are excluded from re gulation under section 261.2( a)(2)(ii) or section 261.4(a)(23), (24), or (25) must send a notificatio n prior to operating unde r the exclusion(s) and by March 1 of each even numbered year thereaf ter to the Regional Administrator using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12) that includes the specified information at section 260.42(a)(1)-(10).

Section 260.42(b) provides that, if a hazardous secondary material generator, tolling contractor, toll manufacturer, recl aimer or intermediate facility has submitted a notification, but then subsequently stops managing hazardous se condary materials in accordance with the21 exclusion(s), the facility must notify the Regional Administrator w ithin thirty (30) days using EPA Form 8700-12. For purposes of this secti on, a facility has stopped managing hazardous secondary materials if the facility no longer ge nerates, manages and/or reclaims hazardous secondary materials under the ex clusion(s) and does not exp ect to manage any amount of hazardous secondary materials for at least one year

(i) Data Items:

 Notification using EPA Form 8700- 12, which includes the following

information:

- The name, address, and EPA ID number (if applicable) of the facility;

- The name and telephone number of a contact person;

- The NAICS code of the facility;

- The exclusion under which the hazardous secondary materials will be managed (e.g., section 261.2(a)(2)(ii ), section 261.4(a)(23), (24), and/or (25));

- For reclaimers and intermediate facilities managing hazardous secondary materials in accordance wi th section 261.4(a)(24) or (25),

whether the reclaimer or intermediate facility has financial assurance (not applicable for persons managing hazardous secondary materials generated and reclaimed under the control of the generator);

- When the facility expects to be gin managing the hazardous secondary materials in accordance with the exclusion;

- A list of hazardous secondary ma terials that will be managed according to the exclusion (reported as the EPA hazardous waste numbers that would apply if the h azardous secondary materials were managed as hazardous wastes);

- For each hazardous secondary material, whether the hazardous secondary material, or any portion th ereof, will be managed in a landbased unit;

- The quantity of each hazardous secondary material to be managed annually; and

- The certification (included in EP A Form 8700-12) signed and dated by an authorized representative of the facility.

(ii) Respondent Activities:

Facilities must perform the following activities, as applicable:

 Complete and submit EPA Form 8700-12 prior to operating under exclusion(s).

 Complete and submit EPA Form 8700-12 by March 1 of each even numbered year thereafter.22  Complete and submit EPA Form 870 0-12 indicating that the hazardous secondary materials are no longer managed in accordance with the exclusion, if applicable.

State agencies must perform the following activities:

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.

(b) Notification of Hazardous Was te Activity under RCRA Section 3010

Facilities that generate , transport, recycle, treat, store, or dispose of hazardous waste as defined by 40 CFR Part 261 must notify EPA of th eir hazardous waste ac tivities and obtain an

EPA Identification Number. These notification requirements are codified at 40 CFR Parts 262, 263, 264, 265, 266, 270, and 273. In order to comply w ith these requirements, facilities must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12).

(i) Data Item:

 Notification using EPA Form 8700- 12, which includes the following

information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be contacted regarding information on the form;

- Ownership information, including the legal status of the current owner of the facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the in itial notification or a subsequent notification;

- A description of the hazardous wast es handled at the facility; and

- A certification signed by the facility owner, ope rator, or authorized representative.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700-12.23 State agencies must perform the following activities:

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.

 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

(c1) Intent to Comply with Subpar t K and Recordkeeping of Agreements

40 CFR 262.203(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subj ect to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG a nd does not have an EPA Identification Number must notify that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity th at are on-site. An eligible academic entity must submit a separate notification (Site ID Fo rm) for each EPA Identification Number (or site, for CESQGs) that is electing to be subj ect to the requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill

out the fields on the form that are specified at section 262.203(b)(1)-(11).

Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laborat ories are subject to Subpart K.

Section 262.203(d) provides that a teaching hos pital that is not ow ned by a college or university must keep a copy of its formal wr itten affiliation agreement with a college or university on file at the teach ing hospital while its laboratorie s are subject to Subpart K.

Section 262.203(e) provides th at a non-profit research inst itute that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the non- profit research institute while its laboratories are subject to Subpart K.

(i) Data Items:

 Notification, using EPA Form 8700-12, with the following fields filled out, at a minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;24 - Site land type;

- North American Industry Classifica tion System (NAICS) code(s) for the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

 A copy of the formal written affili ation agreement with a college or university, as specified under section 262.203(d).

 A copy of the formal written affili ation agreement with a college or university, as specified under section 262.203(e).

(ii) Respondent Activities:

Facilities must perform the following activities, as applicable:

 Eligible academic entities electing to be subject to the requirements of Subpart K must perform the following:

- Complete and submit EPA Form 8700-12; and

- Keep a copy of the notification on file.

 Teaching hospitals that are not owned by a college or university must:

- Keep a copy of their formal written affiliation agreement with college or university on file while its laborat ories are subject to Subpart K.

 Non-profit research institutes that ar e not owned by a college or university

must:

- Keep a copy of the formal written affiliation agreement with a college or university on file at the non-pr ofit research institute while its laboratories are subject to Subpart K.

State agencies must perform the following activities:

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.

(c2) Withdrawal from 40 CFR Part 262, Subpart K

40 CFR 262.204(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all the laboratories owned by the eligible ac ademic entity under the same EPA Identification25 Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify that it is withdrawing from the requireme nts of Subpart K for all the laboratories owned by the eligible academic entity th at are on-site. An eligible academic entity must submit a separate notification (Site ID Fo rm) for each EPA Identification Number (or site, for CESQGs) that is withdrawing fr om the requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill

out the fields on the form that are specified at section 262.204(b)(1)-(11).

Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the

notification.

(i) Data Items:

 A Site ID Form with the following fi elds filled out, at a minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

- North American Industry Classifica tion System (NAICS) code(s) for the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700-12.

 Keep a copy of the withdrawal notice on file.

State agencies must perform the following activities:

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.26 (d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Large quantity handlers of uni versal waste must notify EP A of their universal waste

activities and obtain an EPA Identification Nu mber. These notification requirements are codified at 40 CFR Part 273, Subpart C. In or der to comply with these requirements, large quantity handlers of universal waste must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), or comp lete and submit a letter to EPA requesting an

EPA Identification Number.

(i) Data Items:

 Notification (EPA Form 8700-12) that includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be contacted regarding information on the form;

- Ownership information, including the legal status of the current owner of the facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the in itial notification or a subsequent notification;

- A description of the hazardous wast es handled at the facility; and

- A certification signed by the facility owner, ope rator, or authorized representative.

Or

 A letter that includes:

- The universal waste handler’s name and mailing address;

- Name and business telephone number of the person who should be contacted regarding the universal waste management activities;

- Address or physical location of the universal waste management activities;

- A list of all of the t ypes of universal waste managed by the handler;

and

- A statement indicating that the handler is accumulating more than 5,000 kilograms of universal waste at one time and the types of universal waste (e.g., batteries, pestic ides, thermostats) the handler is accumulating above this quantity.27 (ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700- 12 or a letter requesting an EPA

Identification Number.

State agencies must perform the following activities:

 EPA Form 8700-12

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.

 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

Or

 Letter

 Review letter requesting EPA Identification Number.

 Enter letter information into RCRAInfo.

 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

(e) Notification of Used Oil Activity under 40 CFR Part 279

Used oil handlers must notify EPA of th eir used oil activitie s and obtain an EPA

Identification Number. These no tification requirements are codifi ed at 40 CFR Part 279. In order to comply with these requirements, used oil handlers must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), or complete and submit a letter to EPA requesting an EPA Identification Number.

(i) Data Items:

 Notification using EPA Form 8700- 12, which includes the following

information:

 Name of the facility;

 Facility mailing address;

 Facility location;

 Name, title, and business telephone number of the person who should be contacted regarding information on the form;

 Ownership information, including the legal status of the current owner of the facility;

 Information on the type of hazardous waste activity;

 Information on whether this is the in itial notification or a subsequent notification;

 A description of the hazardous wast es handled at the facility; and28  A certification signed by the facility owner, ope rator, or authorized representative.

Or

 A letter that includes:

- Company name;

- Owner of company;

- Mailing address of company;

- Name and telephone number of company contact;

- Type of used oil management activity(ies);

- Location of facility(ies ) (except for used oil fuel marketers); and

- Name and telephone number of each cont act at each transfer facility, if applicable (for used oil transporte rs and transfer facilities only).

(ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700- 12 or a letter requesting an EPA

Identification Number.

State agencies must perform the following activities:

 EPA Form 8700-12

 Review completed EPA Form 8700-12.

 Enter EPA Form 8700-12 information into RCRAInfo.

 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

Or

 Letter

 Review letter requesting EPA Identification Number.

 Enter letter information into RCRAInfo.

 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).29 (3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

(a1) Contents of the Part A Permit Application

40 CFR 270.1 requires owners or operators of newly regulated f acilities subject to permitting requirements for the first time and permitted facilities with newly regulated units to prepare and submit a Part A Permit Application (EPA Form 8700-23).

(i) Data Items:

 A list of the activities co nducted by the applicant that require the owner or operator to obtain a RCRA permit.

 Name, mailing address, and location, in cluding latitude and longitude of the facility for which the application is submitted.

 Up to four NAICS codes that best refl ect the principal products or services provided by the facility.

 Operator's name, address, telephone nu mber, ownership status, and status as Federal, State, privat e, public or other entity.

 Name, address, and phone number of the owner of the facility.

 Whether the facility is located on Indian lands.

 An indication of whether the facility is new or existing and whether it is a first or revised application.

 For existing facilities, the following information:

 A scale drawing of the facility showing the location of all past, present, and future treatment, st orage, and disposal areas and

 Photographs of the facility clearl y delineating all existing structures; existing treatment, storage and disposal areas; and sites of future treatment, storage, and disposal areas;

 A description of the processes to be used for treating, storing, and disposing of hazardous waste, and th e design capacity of these items.

 A specification of the hazardous wastes listed or designated under 40 CFR Part 261 to be treated, stored, or dispos ed of at the facili ty; an estimate of the quantity of such wastes to be tr eated, stored, or disposed annually; and a general description of the processes to be used for such wastes.30  A listing of all permits or construction approvals received or applied for under any of the following programs:

 Hazardous Waste Management program under RCRA

 Underground Injection Control (UIC) Program under the Safe Drinking Water Act (SDWA)

 National Pollutant Discharge Elim ination System (NPDES) program under the Clean Water Act (CWA)

 Prevention of Significant Deteri oration (PSD) program under the Clean Air Act (CAA)

 Nonattainment program under the CAA

 National Emission Standards for Hazardous Air Pollutants (NESHAPS) preconstructi on approval under the CAA

 Ocean dumping permits under the Marine Protection Research and

Sanctuaries Act

 Dredge or fill permits unde r section 404 of the CWA

 Other relevant environmental pe rmits, including State permits.

 A topographic map (or other map if a topographic map is unavailable) extending one mile beyond the property boundaries of the source, depicting the following as pects of the facility:

 Each of its intake and discharge structures;

 Each of its hazardous waste treatment, storage, or dispos al facilities;

 Each well where fluids from the facility are injected underground; and

 Wells, springs, other surface water bodies, and drinking water wells listed in public records or otherwis e known to the applicant within 1/4 mile of the facility property boundary.

 A brief description of the nature of the business.

 For hazardous debris, a description of the debris category(ies) and containment category(ies) to be trea ted, stored, or disposed of at the facility.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Read the regulations and instructions.

 Prepare the Site ID Form.

 Prepare the Hazardous Waste Permit Information Form and reports.31 (a2) Signatories to Permit Applicati ons and Permit Application Reports

40 CFR 270.11(a) requires operators of faciliti es to obtain the necessary signatures and certifications for the Part A Permit Applicati on, reports, and other information requested by EPA. Additionally, operators must obtain new aut horization for authorizations deemed invalid.

(i) Data Items:

 Signatures required on Part A Permit Applications:

 For a corporation, the signature of a responsible corporate officer as defined at 40 CFR 270.11(a)(1).

 For a partnership or sole proprieto rship, the signature of a general partner or proprietor as de fined at 40 CFR 270.11(a)(2).

 For a municipality, State, Federal, or other public agency, the signature of either a principal executive offi cer or ranking elected official as defined at 40 CFR 270.11(a)(3).

 Signatures for reports required by permits and other information requested by the Director:

 For a corporation, the signature of a responsible corporate officer as defined at 40 CFR 270.11(a)(1).

 For a partnership or sole proprieto rship, the signature of a general partner or proprietor as de fined at 40 CFR 270.11(a)(2).

 For a municipality, State, Federal, or other public agency, the signature of either a principal executive offi cer or ranking elected official as defined at 40 CFR 270.11(a)(3).

 Signature of a duly authorized repr esentative of one of the persons

listed above as define d at 40 CFR 270.11(b).

 New authorization satisfying the requ irements of 40 CFR 270.11(b) if an authorization under 40 CFR 270.11(b) is no longer accurate because a different individual or position has responsibility for the overall operation of the facility. Data items for this requirement are the same as those under 40 CFR 270.11(b).

 Certification:

I certify under penalty of law that this document a nd all attachments were prepared under my direction or supe rvision in accordance with a system designed to assure that qualified pe rsonnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to be the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including possibility of fine and impr isonment for knowing violations.32 (ii) Respondent Activities:

Facilities must perform the following activities:

 Obtain signatures and certifications for the Part A Permit Application, reports, and other inform ation requested by EPA.

 Obtain a new authorization for invalid authorizations.

(a3) Submittal of Part A Permit Application

40 CFR 270.70(b) requires owners and operato rs who submit a Part A Permit Application to EPA, to explain or cure an alleged deficiency in the Part A Permit Application, if EPA notifies the applicant that the application fails to meet the requirements of 40 CFR 270.13.

(i) Data Items:

 Part A Permit Application and reports.

 Explanation of alleged deficiency in the Part A Permit Application.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Submit the Part A Permit Application and reports.

 Explain or cure an alleged deficiency in the Part A Pe rmit Application, if required.

State agencies must perform the following activities:

 Review information contai ned in the application.

 Ensure that the Part A Permit Application and associated reports are signed by the appropriate person.

 Review newly authorized signatures when a different individual or position gains responsibility for the overall operation of a facility.

 Review signature certifications.

 Enter information into RCRAInfo.

 Notify applicant of deficiency in the Part A Permit Application.33 (b) Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

Under 40 CFR 270.72, interim status facilities mu st prepare and submit a revised Part A Permit Application if the Agency promulgates a ru lemaking that affects the facility, or if the owner/operator otherwise modifies the facility. In terim status facilities who modify their Part A Permit Application are required to submit a revised Part A Permit Application.

(i) Data Items:

 Part A application us ing EPA Form 8700-23.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Read the regulations and instructions in preparation for revising a Part A Permit Application in response to an Agency rulemaking or a facility

modification.

 Prepare and submit a revised Part A Pe rmit Application in response to an Agency rulemaking or facility modification.

 Prepare and submit justificati ons for changes, if needed.

 Submit Subpart H compliance demonstrations, if needed.

State agencies must perform the following activities:

 Review information revised Part A Permit Application.

 Enter revised Part A Permit Application information into RCRAInfo.

 Review justifications for changes.

 Review Subpart H compliance demonstrations.34 5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Hazardous Waste Report

As discussed in Section 4(b) of this document, the Hazardous Waste Report data collection process is delegated to the States. Ho wever, EPA is involved throughout this process. The extent of EPA’s involvement depends on the activities performed by th e States in the data collection process. The following paragraphs brie fly describe EPA’s part icipation in the data collection process.

In some cases, the EPA Region performs all of the State roles. That is, EPA Regions VII and IX, where the Region implements the RCRA hazardous waste program for a Iowa and Alaska respectively, provide res pondents with the Federal form, collect the responses, contact non-respondents, enter the data into RCRAInfo us ing off-the-shelf software packages which have been developed to support the collection of Hazardous Waste Report data, assure data quality, and forward the da ta to EPA Headquarters.

In other cases, the EPA Region provides dire ct processing support for some, but not all,

of the collection activit ies. For example, the EPA Regi on may support the State in data gathering and data quality assessment.

In still other cases, the EPA Regions provide additional resources to the States. For example, the EPA Region may provide technical suppor t to States for the transfer of their files to EPA for incorporation into RCRAInfo.

EPA Headquarters produces and distribute s the Federal forms and related guidance, defines the data and file format for data, esta blishes the schedule for submitting data, manages the incorporation of State data into RCRAIn fo, coordinates national data quality review, maintains RCRAInfo, and prepares a national report listing major facts about the national picture of hazardous waste generation and management for the reporting year.

EPA activities for the Hazardous Waste Report include the following:

 Develop Hazardous Waste Report forms and instructions.

 Distribute Hazardous Waste Re port forms and instructions. EPA Headquarters

distributes the form and instruction bookl ets to the States and Regions. Regions prepare mailing lists, mail forms and instructions, record receipt of completed forms, and contact sites that fail to re spond within the specified time period.35  Develop computer capabilities required to compile national data. EPA Headquarters develops the computer capab ilities required to load data into RCRAInfo, the reports which support da ta quality assessment and other programmatic use of the data, and pr eparation of the national report.

 Assist respondents. EPA Regions and Headquart ers provide assistance to respondents. States are, however, the first point of contact for answering respondent questions and assi stance, where applicable.

 Key entry of report submissions. EPA Regions and the regulated entities, key enter or electronically load the data into RCRAInfo they select and maintain. The data entry function was privatized for the 1999 Hazardous Waste Report process. Many States, Regions, and the regulate d community use one of the private vendor’s software packages for data entr y and recordkeeping. Some reports are entered directly on State or vendor hosted Internet sites and some are submitted

on diskettes.

 Perform quality assurance. EPA Regions and Headquarters perform data quality assurance. This includes: follow-up to non-respondents, det ection and correction of unacceptable responses (e.g., in cases where the respondent misunderstood the instructions); verification of excepti onal responses (e.g., data reported by a respondent that differ significantly from data reported by the rest of the respondent universe) and id entification of significant response changes between reporting years. The national software s upports these activities with a variety of data editing functions.

Once reports are received, the QA/QC procedures include a hierarchy of assessments. First, system procedures en sure the data has fundamental internal consistency (e.g., required data fields are populated and the values are of the correct data type and within allowed ranges).

Second, the information content of the data for individual sites is evaluated to identify any potential over or unde r reporting (exception reports support identification of extremes and significant variance from one cycle to another).

Third, assessment reports support evalua tion of intra-Stat e and inter-State shipments of wastes to identify potential discrepancies between reports submitted by generators and the TSDF’s who were identified by the generator as receivers

of the waste.

Based on the assessments, EPA Regions identify cases where accuracy may be questionable. For those cases, they gene rally contact the site to review the information received; and site respondent confirms that th e data are correct or that

the site intends to submit an amended report to correct discrepancies.36  Prepare the national report. EPA Headquarters will prepare The National Biennial RCRA Hazardous Waste Report that will be made available to the Congress and the public by December 2014.

 Store the data. The Hazardous Waste Reports wi ll be stored by the EPA Regions for three years and may be maintained by each Region. RCRAInfo is maintained by EPA Headquarters.

(2) Notification of Regulated Waste Activity

EPA activities are the same for all of the notification requirements covered in this ICR.

These activities include:

 For initial notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.

- Entering information into the EPA national data system.

- Generating an EPA Identification Numb er and sending the EPA Identification Number to the facility.

 For subsequent notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.

- Entering information into the EPA national data system.

(3) Part A Hazardous Waste Permit Application and Modification

EPA activities associated with Part A Pe rmit Applications include the following:

 For Part A Permit Applications:

 Reviewing information contained in the application.

 Ensuring that the Part A Permit Applicat ion and associated reports are signed by the appropriate person.

 Reviewing newly authorized signatures wh en a different individual or position gains responsibility for the ove rall operation of a facility.

 Reviewing signature certifications.

 Entering information into RCRAInfo.

 Notifying applicant of deficiency in the Part A Permit Application.

 For revised Part A Permit Applicatio ns, justifications, and compliance

demonstrations:

 Review information revised Part A Permit Application.

 Enter revised Part A Permit Application information into RCRAInfo.

 Review justifications for changes.

 Review Subpart H compliance demonstrations.37 5(b) COLLECTION METHODOLOGY AND MANAGEMENT

In collecting and analyzing the information asso ciated with this ICR, EPA and authorized States may use a telephone system, personal com puters, and applicable RCRAInfo software. They will ensure the accuracy and completene ss of collected information by reviewing the submittals. They will keep records of this inform ation in file cabinets and/or computer systems.

5(c) SMALL ENTITY FLEXIBILITY

(1) Hazardous Waste Report

EPA uses the quantity of waste generated per month to determine the extent to which a firm should be regulated. EPA categorizes generators of less than 1,000 kilograms of non-acute hazardous waste per month as small quantity gene rators (SQGs) and relieves them of specific requirements.

SQGs are not required to file the Hazar dous Waste Report. A SQG who is sent the Hazardous Waste Report booklet due to a change in generator status or error need not respond. They must return a completed RCRA Subtitle C Site Identification Form to update their generator status to ensure they are not subj ect to follow-up contact for biennial reporting.

(2) Notification of Regulated Waste Activity

Some respondents will be indi viduals or small organizations. However, EPA believes

that the information to be collected is the minimum amount necessary to fulfill the statutory requirements of RCRA.

(3) Part A Hazardous Waste Permit Application and Modification

Interim status is statutorily conferred without regard to facility size. Therefore, EPA believes that requirements regarding Part A subm issions and revisions mu st apply equally to large and small businesses. Although the legal requirements for Part A Permit Application information are the same for large and small busine sses, the Agency believes that in practice the

small entities will find it easier to provide the required info rmation. In many instances, a small organization will be able to complete or revise the Part A Permit Application in less time than larger organizations because they use fewer proc esses for the management of hazardous wastes and they manage fewer types of wastes. As a ru le of thumb, the complexity of preparing a Part A Permit Application depends upon the complexity of the processes of a hazardous waste facility and the wastes managed at the facility. Theref ore, if a small organization operates a complex facility (e.g., a chemical landfill that manages a very large number of waste streams), then the time to complete the Part A Permit Application will necessarily be greater. Again, EPA has taken steps to minimize the burden on all res pondents by providing detailed instructions for completion of the Part A Permit Application fo rm and by requiring short answer responses to most of the items of the application.38 It also should be noted that the reporting requi rements for changes are brief. Therefore, owners or operators can easily comply with th ese requirements. In addition, most of the revisions to Part A Permit Appli cations will entail merely chec king boxes or filling in numbers to indicate the type of new activ ity or new waste to be handled at the facility. Any written justification entails a short letter from the owner or operator. EP A, therefore, estimates that the potential burden on small businesses caused by this information collection is minimal.

5(d) COLLECTION SCHEDULE

(1) Hazardous Waste Report

EPA’s 2015 Hazardous Waste Report national imp lementation schedule is outlined in

Table 2.

Table 2 2015 Hazardous Waste Report National Implementation Schedule

Activity Tentative Completion Date

Facilities submit completed forms to Regions/States March 2016

Regions/States begin loading the data into RCRAInfo April 2016

Regions/States complete data loads July 2016

EPA Headquarters publishes Preliminary 2015 Natio nal Biennial data summaries August 2016

Last day to request a State Summary Report from EPA Headquarters October 2016

Regions/States complete loading corrected (if necessary) data into RCRAInfo November 2016

EPA Headquarters makes Final 2015 Nationa l Biennial data available on RCRAInfo Web (public Web site) December 2016

(2) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

A claimant must prepare and submit a notif ication to EPA prior to operating under the exclusion(s). In addition, the claimant must update and submit notification to EPA by March 1 of each even numbered year thereafter. A cl aimant that submitted a notification but then subsequently stops managing hazardous secondary materials in accordance with the exclusion(s) must submit notification to EPA within 30 days.

(b) Notification of Hazardous Was te Activity under RCRA Section 301039 Under sections 262.12, 263.11, 264.11 and 265.11, all new hazardous waste generators, transporters, and TSDFs must notify EPA of thei r hazardous waste activities and obtain an EPA

Identification Number before tr eating, storing, transporting, offeri ng for transport, or disposing of hazardous waste. Under section 270.1(b), thes e hazardous waste generators, transporters, and TSDFs, are also subject to newly promulgate d or revised regulations at 40 CFR Part 261 (identification and listing of hazardous wastes) a nd must notify EPA of new or revised hazardous waste activities no later than 90 days after promulgation or revision. In addition, other generators; transporters; recyclers; and treatment, storage and disposal fa cilities that are subject to notification requirements under sectio ns 266.21, 266.22, 266.23, 266.70(b)(1 ), 266.80(b)(1)(i), 266.80(b)(2)(i), 266.101(a), 266.101(b), 266.101(c), 266.102(a)(2)(ii), 266.103(a)(4)(ii), and 273.60(a) must notify EPA of their hazardous waste activities within the same time frame. Under section 273.54, universal waste transporters who determine that any material resulting

from a release of universal waste is a hazardous waste are subject to 40 CFR Part 262. As a result, these transporters may also be subjec t to, under these circum stances, the section 262.12 notification requirements and procedures. As suc h, these transporters must, at that time, notify

EPA of their hazardous waste activities and ob tain an EPA Identification Number before treating, storing, transporting, offering for transpor t, or disposing of hazardous waste. Finally, owners or operators of smelting, melting, and re fining furnaces that process hazardous waste either solely for metals recovery or for recove ry of economically signifi cant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site bu rner exemption under section 266.108(d) must provide a written, one-time notificati on of their hazardous waste activities.

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

(c1) Intent to Comply with Subpar t K and Recordkeeping of Agreements

Under 40 CFR 262.203(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Iden tification Form (EPA Form 8700-12), that it is electing to be subject to the requirem ents of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG a nd does not have an EPA Identification Number must notify for all the laboratories owned by the eligible academic entity that are on-site. An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is electing to be subject to the requirements of Subpart K. This is a one-time notification.

Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laborator ies are subject to Subpart K.

Section 262.203(d) provides that a teaching hos pital that is not ow ned by a college or university must keep a copy of its formal wr itten affiliation agreement with a college or university on file at the teachi ng hospital while its la boratories are subject to Subpart K.

Section 262.203(e) provides th at a non-profit research inst itute that is not owned by a college or university must keep a copy of the formal written affiliation agreement with a college40 or university on file at the non- profit research institute while its laboratories are subject to Subpart K.

(c2) Withdrawal from 40 CFR Part 262, Subpart K

Under 40 CFR 262.204(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Iden tification Form (EPA Form 8700-12), that it is electing to no longer be subject to the re quirements of Subpart K for all the laboratories owned by the eligible academ ic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all the laboratories owne d by the eligible academic entity that are onsite. An eligible academic entity must subm it a separate notification (Site ID Form) for each EPA Identification Number (or si te, for CESQGs) that is withdr awing from the requirements of Subpart K. This is a one-time notification.

Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the

notification.

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Under Section 273.32(a)(1), larg e quantity handlers of universal waste must submit a written, one-time notification of universal waste activity to the Regional Administrator and

obtain an EPA Identification Number before m eeting or exceeding the 5,000 kilogram storage limit, unless they already have notified EP A, as provided by section 273.32(a)(2) or 273.32(a)(3).

(e) Notification of Used Oil Activity under 40 CFR Part 279

Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who were not previously required to comply with the no tification requirements (under 40 CFR Part 266, Subpart E) must submit a written, one-time notifi cation of their used oil management activities

and obtain an EPA Identification Number.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

Owners or operators of new hazardous waste management facilities that are not yet constructed are required to submit their Part A Permit Application, in cluding signatures and certifications at least 180 days before physical construction is expected to commence. For existing facilities newly subject to RCRA perm itting requirements due to promulgation of a new regulation or listing of hazardous waste, the new regulation typically spec ifies the date by which Part A Permit Applications, including signatures and certifications, must be submitted.41 (b) Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

The time frame in which owners or operators must submit a revised Part A Permit Application varies according to the nature of cha nges at the facility. Fo r the following types of changes, the owner or operator must submit revise d Part A Permit Applications and justifications prior to making the changes:

 Treating, storing, or disposing of hazardous wastes not previously identified in the Part A Permit Application.

 Increasing the design capacity of pr ocesses used at the facility.

 Changing or adding processes for treati ng, storing, or dispos ing of hazardous

wastes.

For changes in ownership or operational cont rol of a facility, the new owner or operator must submit a revised Part A Permit Application no later than 90 days prior to the scheduled change. Subpart H compliance demonstrations must be submitted within six months of the date of the change in ownership or ope rational control of the facility.42 6. ESTIMATING THE HO UR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibits 1 through 3 provide es timates of the respondent hou rly burden associated with the information collection requirements covered in this ICR. The exhibits include burden hours (total and by labor type) per res pondent, as well as the overall burden hours for all respondents. The majority of the hour estimates in Exhib its 1 through 3 are based on consultations with industry and States.

In the following paragraphs, EPA describe s the methodologies used to estimate the hourly burden associated with the informa tion collections covered in this ICR.

(1) Hazardous Waste Report

(a) Methodology for Accounting for Site Identification Forms Pre-Populated by

States

In estimating the hourly burden for preparing the Site ID Form of the Hazardous Waste Report, EPA assumes that 65 percent of all the Site ID Forms will be pre-populated by States prior to distribution to responde nts or by vendor software used by the respondents. EPA also assumes that the remaining 35 percent of all the Site ID Forms will be completed manually.

EPA estimates the burden for updating a pre- populated Site ID Form to be about 37 minutes (0.61 hour) per respondent and the burd en for completing a Site ID Form in its entirety (i.e., completing a blank form manually) to be 1.26 hour per respondent.

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 3 below. EPA multiplied the percentage of pre-populated Site ID Forms by the average burd en for updating the information contained in the form. EPA also multiplied the percentage of blank Site ID Forms by the average burden for completing the blank form. Then, EPA added up these two products to

derive an overall wei ghted-average burden.

Table 3 Assumptions and Weighted-Average Equati on Used in Estimating Burden to Complete the Site Identification Fo rm of the Hazardous Waste Report

Assumptions Weighted-Average Equation

0.61 hours to complete pre-populated form; 65 percent of the forms are pre-populated (0.61 hr x 0.65) + (1.26 hrs x 0.35)

= 0.84 hours 1.26 hour to complete blank form; 35 percent of the forms are blank43 (b) Methodology for Accounting for Form GM and Form WR Electronic Reporting

During consultations conducted dur ing the development of previ ous versions of this ICR, State and facility representatives indicated that Forms GM and WR often can be completed from

RCRAInfos that track manifest s or other information for billing purposes. Based on these consultations, EPA estimated the hourly burden for the Forms GM and WR submitted electronically to be significantly le ss than for forms submitted on paper.

To estimate the percentage of facilities th at submit Forms GM and WR electronically, EPA used information gained from consultations and 2011 Hazardous Waste Report data. For Form GM submissions, EPA estimated that, ba sed on consultations a nd best professional judgment, facilities submitting five (5) or mo re Forms GM for the Hazardous Waste Report are likely to do so electronically. Using 2011 Hazardous Waste Report data 3 , EPA identified sites submitting Forms GM, counted their Forms GM su bmitted, and calculated the percentage that their Forms GM represented of the total number of Forms GM. Based on this methodology, EPA estimates that 94 percent of Forms GM are submitted electronically, while the remaining 6 percent are sent manually.

For Forms WR, EPA believes that TSDFs recei ving large numbers of off-site shipments are more likely to have systems in place to track waste stream data, and as a consequence, to submit Hazardous Waste Report data electronica lly. Using 2011 Hazardous Waste Report data 4

, EPA reviewed the list of Forms WR reporte d to the Hazardous Waste Report by facility and, based on its own professional judgm ent and consultations, estimate s that 100 percent of Forms WR are submitted electronically.

To estimate the average burden per respondent in preparing a Fo rm GM or WR, EPA used the weighted-average calculations in Table 4. EPA multiplied the percentage of both forms submitted electronically by their respective burden fo r electronic reporting and the percentage of both forms submitted manually by their respective burden for manual reporting. Then, EPA added the two products for each form, respectivel y, to calculate an overall weighted-average

burden for both forms.

3 2011 Hazardous Waste Report (i.e., 2011 Biennial Report ) data used in this analys is are current as of July 10-14, 2014.

4 Ibid.44 Table 4 Assumptions and Weighted-Average Equati ons Used in Estimating Burden to Complete Form GM and Form WR of the Hazardous Waste Report

Activity Assumptions Weighted-Average Equation

Complete

Form GM 0.27 hour to complete electronically; 94 percent of the forms are completed electronically

1.19 hours to complete manually; 6 percent of the forms are completed manually (0.27 hr x 0.94) + (1.19 hrs x 0.06)

= 0.32 hour

Complete

Form WR 0.12 hour to complete electronically; 100% of the forms are completed electronically 0.12 hr x 1

= 0.12 hour

(2) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

For purposes of this ICR, EPA anticipates th at all of the facilities electing to operate under the hazardous secondary material excl usion under 40 CFR 260.42 during the two-year period covered by this ICR have already submitted the Site ID Form at least once. Of these facilities, EPA estimates that 50 percent will comp lete a blank Site ID Form to notify EPA or the State prior to operating under the exclusion and by March 1 of each even numbered year. EPA estimates that the other 50 percent will use th eir most recently submitted Site ID Form in complying with these notification requirements.

EPA estimates the burden for completing a blank Site ID Form under section 260.42 to be 1.33 hours per respondent and the burden for using a previously submitted form to be 0.95 hours per respondent. EPA notes that section 260.42 imposes several substantive requirements specific to the exclusions that must be completed (e.g., quantity of secondary material to be managed annually) in add ition to the rest of the Site ID Form.

For the notification submitted indicating that the hazardous secondary materials are no longer managed in accordance to the exclusion, EPA estimates the average hourly burden for completing the Site ID Form in its entirety (i.e ., a blank form) to be about 50 minutes (0.83 hour) per respondent. EPA also estimates the aver age hourly burden for updating the most recently submitted Site ID Form to be 27 minutes (0.45 hour) per respondent.45 The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 5 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 5 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete the Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Assumptions Weighted-Average Equation

Notification Prior to Operating under Exclusion AND Notification Submitted by March 1 of Each Even Numbered Year Thereafter

1.33 hours to complete blank form; 50 percent of the facilities (1.33 hrs x 0.50) + (0.95 hr x 0.50)

= 1.14 hours 0.95 hour to update most recently submitted form; 50 percent of the facilities

Notification Indicating that Hazardous S econdary Materials are no Longer Managed in

Accordance to the Exclusion

0.83 hour to complete blank form; 50 percent of the facilities (0.83 hr x 0.50) + (0.45 hr x 0.50)

= 0.64 hour 0.45 hour to update most recently submitted form; 50 percent of the facilities

(b) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

For purposes of this ICR, EPA anticipates that all of the facilities opting into Subpart K during the two-year period covered by this ICR have already submitted the Site ID Form at least once. Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form in opting into Subpart K and in w ithdrawing from Subpart K. EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

EPA estimates the burden for completing a bla nk Site ID Form under Subpart K to be 50 minutes (0.83 hour) per respondent and the burden fo r using a previously submitted form to be 27 minutes (0.45 hour) per respondent.46 The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 6 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 6 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete the Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Assumptions Weighted-Average Equation

0.83 hour to complete blank form; 50 percent of the facilities (0.83 hr x 0.50) + (0.45 hr x 0.50)

= 0.64 hour 0.45 hour to update most recently submitted form; 50 percent of the facilities

(c) Other Notifications Covered in this ICR

For purposes of this ICR, EPA anticipates th at 50 percent of the facilities submitting subsequent notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 will complete a blank Site ID Form. EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

EPA estimates the burden for completing a blank Site ID Form to be 50 minutes (0.83 hour) per respondent and the burden for using a previously submitted form to be 27 minutes (0.45 hour) per respondent.

The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 7 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.47 Table 7 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete Oth er Notifications Covered in this ICR

Assumptions Weighted-Average Equation

0.83 hour to complete blank form; 50 percent of the facilities (0.83 hr x 0.50) + (0.45 hr x 0.50)

= 0.64 hour 0.45 hour to update most recently submitted form; 50 percent of the facilities

(3) Part A Hazardous Waste Permit Application and Modification

In estimating the hourly burden for preparing the Site ID Form of the Part A Permit Application, EPA assumes that all of the faci lities submitting a Part A Permit Application or Modification during the two-year period covered by this ICR have already submitted the Site ID Form at least once. Of these facilities, EPA esti mates that 50 percent will complete a blank Site ID Form and the remaining 50 percent will use th eir most recently submitt ed Site ID Form.

EPA estimates the burden for completing a blank Site ID Form to be 1.26 hour per respondent and the burden for using a previously submitted form to be37 minutes (0.61 hour) per respondent.

The above burden estimates are reflected in Exhibit 3 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 8 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 8 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete the Site Identification Form of the Part A Permit Application

Assumptions Weighted-Average Equation

1.26 hour to complete blank form; 50 percent of the facilities (1.26 hrs x 0.50) + (0.61 hr x 0.50)

= 0.94 hour 0.61 hour to update most recently submitted form; 50 percent of the facilities48 6(b) ESTIMATING RESPONDENT COSTS

Exhibits 1 through 3 provide estim ates of the annual responden t costs associated with the information collection requirements covered in this ICR. These costs are based on the cost of labor, capital, and operation and maintenance (O&M).

(1) Labor Costs

Using the total burden hours discussed in S ection 6(a) and the hourly labor costs outlined in this section, Exhibits 1 thr ough 3 illustrate the labor costs as sociated with the information collection requirements covered in this ICR.

(a) Private Sector Facilities

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $129.82 for legal staff, $76.73 for managerial staff, $57.16 for technica l staff, and $34.39 for clerical staff. These respondent labor costs we re obtained from the pr eviously approved ICR (i.e., EPA ICR Number 0976.16, dated Septembe r 19, 2012), and updated to 2014 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics. 5

(b) State and Local Government Facilities and Agencies

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $60.57 for legal staff, $56.86 for managerial staff, $34.02 for technica l staff, and $21.70 for clerical staff. These respondent labor costs we re obtained from the pr eviously approved ICR (i.e., EPA ICR Number 0976.16, dated Septembe r 19, 2012), and updated to 2014 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics. 6

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, and ot her equipment. EPA doe s not anticipate that respondents will incur ca pital costs in carrying out the information collection requirements

covered in this ICR.

5 Bureau of Labor Statistics, “Table 4. Employment Cost Index for total compensation, for civilian workers, by occupational and industry,” Employment Cost Index Historical Listing – Volume V , April 2014.

Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on July 14, 20 14. Civilian Workers, All Workers, June 2012=116.8 March 2014=120.5.

6 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation, for State and local government workers, by occupational and industry,” Employment Cost Index Historical Listing – Volume V , April

2014. Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on July 14, 2014. State and Local Government Workers, All Workers, June 2012=118.6 and March 2014=122.8.49 (3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement incurred continually over the life of the ICR. For this ICR, O&M costs include mailing costs:

 EPA estimates that facilities submitting a Hazardous Waste Report or a Part A Permit Application to EPA or States w ill incur a cost of $6.51 to mail an 11-ounce large envelope by certified mail ($3.08 fo r postage, $3.30 for the certified-mail fee, and $0.13 for a catalog envelope). 7, 8, 9

 EPA estimates that facilities submitting a notification to EPA will incur a cost of $3.82 to mail a one-ounce letter by certifie d mail (i.e., $0.49 for first-class letter postage, $3.30for the certified-mail f ee, and $0.03 for standard business envelope). 10, 11, 12

 EPA estimates that State agencies dist ributing the Hazardous Waste Report to facilities will incur a cost of $3.21 to mail an 11-ounce large envelope ($3.08for postage and $0.13 for a catalog envelope). 13, 14

The above O&M costs are shown in Exhibits 1 through 3 for all ap plicable respondent

activities.

6(c) ESTIMATING AGEN CY HOUR AND COST BURDEN

EPA estimates the Agency hour and cost burden associated with the information collection requirements covered in this ICR in E xhibits 4 through 6. As shown in the exhibits, EPA estimates an average hourly labor cost of $87.42 for legal staff (GS15, Step 5), $77.14 for managerial staff (GS-15, Step 1), $55.50 for technical staff (GS-13, Step 1), and $23.68 for clerical staff (GS-06, Step 1). To derive these hourly estimat es, EPA referred to the General

7 U.S. Postal Service, “First-Class Mail.” Available online at: https://www.usps.com/business/prices.htm ?, last accessed on July 14, 2014.

8 U.S. Postal Service, “Add Extra Servi ces for Business.” Av ailable online at: https://www.usps.com/busines s/add-extra-services.htm ?, last accessed on July 14, 2014.

9 Catalog envelope cost based on current market price, as of July 14, 2014 (i.e., box of 100 catalog envelopes with gummed closure at $13.29).

10 U.S. Postal Service, “First-Class Mail.” Available online at: https://www.usps.com/business/prices.htm ?, last accessed on July 14, 2014.

11 U.S. Postal Service, “Add Extra Serv ices for Business.” Available online at: https://www.usps.com/busines s/add-extra-services.htm ?, last accessed on July 14, 2014.

12 Standard business envelope cost based on current market price, as of July 14, 2014 (i.e., box of 500 standard business envelopes with gummed closure at$14.89).

13 U.S. Postal Service, “First-Class Mail.” Available online at: https://www.usps.com/business/prices.htm ?, last accessed on July 14, 2014.

14 Catalog envelope cost based on current market price, as of July 14, 2014 (i.e., box of 100 catalog envelopes with gummed closure at$13.29).50 Schedule (GS) Salary Table 2014. 15 This publication summarizes the unloaded (base) hourly rate for various labor categories in the Federa l Government. EPA then applied the standard government overhead factor of 1.6 to the unloa ded rate to derive loaded hourly rates.

EPA does not anticipate that the Agency will incur capital costs in carrying out the information collection requirements covered in this ICR.

O&M costs are associated with Hazardous Wa ste Report activities. In particular, EPA estimates that the Agency will incur a cost of $22,019 in printing paper and CD copies of the Hazardous Waste Report forms and instructions , $275,237 in developing computer capabilities required to compile national data, $55,047 in preparing the National Report, and $38,534 in storing the national data. Thes e O&M costs were obtained from the previously approved ICR (i.e., EPA ICR Number 0976.16, dated Septembe r 19, 2012), and updated to 2014 levels using Consumer Price Indexes developed by the Bureau of Labor Statistics. 16 EPA O&M costs are

shown in Exhibit 4 for al l applicable activities.

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then estimates the annual burden to respondents under the information co llection requirements

covered in this ICR.

EPA notes that, as used in this do cument, the term “respondent” includes:

 Hazardous waste facilities complyi ng with the Hazardous Waste Report, notification, and Part A Permit Applicati on requirements covered in this ICR.

This includes:

 Private sector entities; and

 State and local government agenci es that are regulated entities 17

.

 State agencies administering the RCRA hazardous waste program 18

.

15 U.S. Office of Personnel Management, “2014 General Schedule (Base),” Hourly Rate. Available online at: http://www.opm.gov/policy-data-overs ight/pay-leave/salaries-wages/salar y-tables/pdf/2014/GS_h.pdf, last accessed on July 14, 2014.

16 Bureau of Labor Statistics, “Table 24. Historical Consumer Price Index for All Urban Consumers (CPIU): U. S. city average, all.” May 2014. Available online at: http://www.bls .gov/cpi/cpid 1405.pdf, last accessed on July 14, 2014. All items, July 2012=229.104 and May 2014=237.900.

17 Addressing State and local g overnment agencies as “respondents” is consistent with EPA’s interpretation of the definition of respondent in the Paperwork Reduction Act of 1995.

18 Ibid.51 (1) Respondent Universe

(a) Hazardous Waste Report

Based on 2011 Hazardous Waste Report data 19 , EPA estimates that the total number of respondents to the 2015 Hazardous Waste Report wi ll be 20,536, which annualized over the twoyear report cycle equals 10,268 pe r year (i.e., 20,536/2). Table 9 presents information on the

total number of forms associated with the 2015 Hazardous Waste Report. In estimating annual respondent burden and cost, EPA annualized thes e numbers over the two- year report cycle.

Table 9 Total Number of 2015 Hazardous Waste Report Forms

Hazardous Waste Report Form Number of Forms a

Private

Sector State and

Local

Government Total

Site Identification (Site ID) Form 18,402 2,134 20,536

Form GM - Generation and Mana gement 239,327 17,271 256,598

Form WR - Waste Received from Of fsite 1,262,520 7,075 1,269,595
Total 1,520,249 26,480 1,546,729

a Based on 2011 Hazardous Waste Report (i.e., 2011 Biennial Report) data current as of July 10-14, 2014. At the time this ICR was developed, 2013 H azardous Waste Report data were not available

The number of respondents and forms for each respondent activity is presented in

Exhibit 1. These estimates assume that all forms are submitted in accordance with the Hazardous Waste Report instructions. Exhibit 1 al so estimates the annual respondent burden and

cost for the activities examined.

(b) Notification of Regulated Waste Activity

In estimating the number of respondents subj ect to the notificati on requirements covered in this ICR, EPA referred to RCRAInfo. EPA estimated the annual num ber of notifications tracked by RCRAInfo. EPA then averaged the number of notifications submitted in 2012 and 2013. These estimates are presented in Table 10 and used to estimate the total respondent burden and costs per information collection ac tivity shown in Exhibit 2 of this ICR.

19 2011 Hazardous Waste Report (i.e., 2011 Biennial Re port) data used in this analysis are current as of July 10-14, 2014. At the time this ICR was devel oped, 2013 Hazardous Waste Repor t data were not available.52 (c) Part A Hazardous Waste Permit Application and Modification

In estimating the number of respondents s ubject to the Part A Permit Application requirements covered in this ICR, EPA referre d to the RCRAInfo system. EPA estimated the annual number of Part A Permit Applications tracked by RCRAInfo. EPA then averaged the number of applications submitted in 2012 and 2013. These estimates are presented in Table 11 and used to estimate the total respondent burde n and costs per information collection activity

shown in Exhibit 3 of this ICR.53Table 10Annual Number of Respondents Subject to the Notification Requirements Covered in this ICRaRespondent UniverseYear 2012 Year 2013 Average of Years 2012 and 2013PrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalNotification of Hazardous SecondaryMaterial Activity under 40 CFR 260.42Number of facilities submitting notification priorto operating under exclusion20 0 20 16 0 16 18 0 18Number of small quantity generators (SQGs) andconditionally-exempt small quantity generators(CESQGs) submitting notification by March 1 ofeach even numbered year thereafter14 0 14 4 0 4 9 0 9Number of facilities submitting notificationindicating that they will no longer managehazardous secondary materials in accordancewith the exclusion21 0 21 9 0 9 15 0 15Notification of Hazardous Waste Activity under RCRA Section 3010Number of facilities submitting initial notification 10,303 928 11,231 8,010 1,191 9,201 9,157 1,060 10,216Number of facilities submitting subsequentnotification34,086 2,043 36,129 34,025 1,877 35,902 34,056 1,960 36,016Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KNumber of eligible academic entities submittingnotification of intent to comply with Subpart Kand recordkeeping of agreements2 4 6 5 16 21 4 10 14Number of teaching hospitals not owned by acollege or university opting into Subpart K0 1 1 0 1 1 0 1 1Number of non-profit research institutes notowned by a college or university opting intoSubpart K1 01 1 0 1 1 0 1Number of eligible academic entities submittingnotification of withdrawalfrom 40 CFR Part 262,Subpart K691 14 705 137 0 137 414 7 421Table 10 (continued)Annual Number of Respondents Subject to the Notification Requirements Covered in this ICRa54Respondent UniverseYear 2012 Year 2013 Average of Years 2012 and 2013PrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalNotification of Universal Waste Activity under 40 CFR Part 273, Subpart CNumber of facilities submitting initial notification 79 13 92 61 13 74 70 13 83Number of facilities submitting subsequentnotification80 11 91 97 12 109 89 12 100Notification of Used Oil Activity under 40 CFR Part 279Number of facilities submitting initial notification 92 2 94 63 5 68 78 4 81Number of facilities submitting subsequentnotification227 4 231 157 8 165 192 6 198aBased on data from the following RCRAInfotables: (1) “Hhandler,” (2) “Howner_operator,” (3) “Huniversal_waste,” and (4) “Hhsm_basic.” All tables contain data current as of July10,2014.bIncludes facilities owned and/or operatedby “private” or “other.” Note that, in order to qualify as “private,” the facilitycannot be owned or operated bya Federal, State, or localgovernment. For example, a facility owned bya State government and operated by a private entity would qualify as a “State andlocal government” facility, notas a “private” facility.cIncludes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in orderto qualify as “State and localgovernment,” the facility cannotbe owned or operated by the Federal government. For example, afacility owned by the Federal government and operated by a Municipal government would qualify as a “Federalgovernment” facility, not a “State and local government” facility.55Table 11Annual Number of Respondents Subject to the Part A Permit Application Requirements Covered in this ICRaRespondentUniverseYear 2012 Year 2013 Average of Years 2012 and 2013PrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalPrivateSectorbState andLocalGovernmentcTotalNumber of facilities submittinginitial Part A Permit Application2 0 2 5 0 5 4 0 4Number of facilities submittingPart A Permit Modification23 2 25 23 1 24 23 2 25aBased on data from the following RCRAInfo tables: (1) “Hhandler” and (2) “Howner_operator.” Both tables contain data current as of July 10, 2014.bIncludes facilities owned and/or operatedby “private” or “other.” Note that, in order to qualify as “private,” the facilitycannot be owned or operated by a Federal, State,or local government. For example, a facilityowned by a State government and operated by a private entity would qualify as a “State and local government” facility, not asa “private” facility.cIncludes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in orderto qualify as “State and local government,” thefacility cannot be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Municipal government wouldqualify as a “Federal government” facility, nota “State and localgovernment” facility.56 (2) Annual Respondent Burden

(a) Hazardous Waste Report - Fa cilities (Exhibits 1A and 1B)

(a1) Read the Hazardous Wa ste Report Instructions

EPA estimates that all 20,536 respondents will read the Hazardous Waste Report

instructions. Annualized over th e two-year report cycle, this results in 10,268 respondents reading the instructions each y ear (i.e., 9,201 private se ctor facilities and 1,067 State and local government facilities).

(a2) Revise In-House or Commercial Data System

EPA estimates that all 9,135 electronic report ers will revise their in-house or commercial data system to include new Hazardous Waste Report da ta items that are not part of the facility’s general business operations. A nnualized over the two-year repor t cycle, this results in 4,568 respondents revising their in-house or commercia l data systems each year (i.e., 4,349 private

sector facilities and 219 State and local government facilities).

(a3) Gather Information and Comp lete Site Identification Form

EPA estimates that all 20,536 respondents will complete and submit a Site ID Form with the Hazardous Waste Report. Annualized over th e two-year report cycle, this results in 10,268 respondents preparing and submitting a Site ID Form each year (i.e., 9,201 private sector facilities and 1,067 State and local government facilities).

(a4) Gather Information and Complete Form GM

EPA estimates that respondents will su bmit a total of 256,598 Forms GM with the Hazardous Waste Report. Annualized over the two- year report cycle, this results in 128,300 Forms GM each year (i.e., 119,664 forms from priv ate sector facilities and 8,636 forms from State and local govern ment facilities).

(a5) Gather Information and Complete Form WR

EPA estimates that respondents will su bmit a total of 1,269,595 Forms WR with the Hazardous Waste Report. Annualized over the two- year report cycle, this results in 634,798 Forms WR each year (i.e., 631,260 forms from pr ivate sector facilities and 3,538 forms from State and local governme nt facilities).

Note that the number of Form s WR represents the number of blocks on Form WR that have been completed; the paper form actually cont ains three blocks of th e same WR information (i.e., the same questions, repeated three times on the same page).57 (a6) Gather Information and Complete Form OI

Because this form is a State-optional form, EP A does not expect any facilities to submit

Form OI and therefore does not ca lculate the burden for this form.

(a7) Submit the Biennial Report to State/Region

EPA expects each respondent, 10,268 facilities per year (i.e., 9,201 private sector facilities and 1,067 State and local government facilities), to submit the report to the appropriate State or Region.

(a8) Maintain a Copy of Each Form

EPA expects facilities to retain an estimated 773,366 (i .e., 10,268 Site ID Forms + 128,300 Forms GM + 634,798 Forms WR) forms each year (i.e., 760,125 forms from private sector facilities and 13,241 forms from State and local government facilities).

(b) Hazardous Waste Report – State Agencies (Exhibit 1C)

(b1) Distribute Hazardous Wast e Report Forms and Instructions

EPA estimates that State agencies will distribute Hazardous Waste Report forms and instructions to 20,303 respondents. Annualized over the two-year report cycle, this results in 10,152 respondents each year.

(b2) Assist Respondents

EPA expects State agencies to provide assi stance to all 20,303 respondents. Annualized over the two-year report cycle, this re sults in 10,152 respondents each year.

(b3) Key Entry of Report Submissions

EPA estimates that State agencies will need to key enter data for 22,382 Hazardous Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) completed manually by the

facilities. Annualized over th e two-year report cycle, this results in 11,191 respondents each

year.

(b4) Perform Quality Assurance

EPA expects State agencies to perform da ta quality assurance on all 1,546,729 Hazardous Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) submitted by facilities. Annualized over the two-year report cycle, this results in 771,988 respond ents each year.58 (c) Notification of Regulated Waste Acti vity - Facilities (E xhibits 2A and 2B)

(c1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

EPA estimates that, each year, 18 entities (i.e., 18 private sector faci lities and 0 State and local government facility) will notify unde r 40 CFR 260.42 prior to operating under the exclusion and be required to complete the in formation laid out at section 260.42(a).

In addition, entities must re-notify using th e Site ID Form by March 1 of each even numbered year thereafter. Note that the Hazar dous Waste Report regulations already require the submittal of the Site ID Form by March 1 of eac h even numbered year by LQGs (40 CFR Part 262) and TSDFs (40 CFR Part 264 and 265). Hence, this section of the ICR estimates burden for SQG and CESQG re-notifications only. For purposes of this ICR, EPA estimates that, each year, a total of 9 SQGs and CESQGs will re-notify (i.e., 9 private sector facilities and 0 State and local government facilities).

EPA estimates that, each year, 15 entities wi ll re-notify because they stopped operating under the exclusion (i.e., 15 private sector facilities and 0 State a nd local government facilities).

(c2) Notification of Hazardous Wast e Activity under RCRA Section 3010

EPA estimates that, each year, 10,217 facilitie s (i.e., 9,157 private sector facilities and 1,060 State and local government fa cilities) will submit an initial notification of hazardous waste activity under RCRA Section 3010. EPA also es timates that, each year, 36,016 facilities (i.e., 34,056 private sector facil ities and 1,960 State and local gove rnment facilities) will submit a subsequent notification associat ed with these requirements.

(c3) Notification of Hazardous Waste Ac tivity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

An eligible academic entity must submit th e Site ID Form to notify EPA or the

authorized State that it is elec ting to be subject to Subpart K for all laboratories owned by the eligible academic entity under the same EPA Identif ication Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all laboratories that are owned or operated by the eligible academic entity that are on-site. EPA estimates that, each year, 14 forms will be completed, submitted, and retained (i.e., 4 forms from private sector entities and 10 forms from State and local government entities).

Teaching hospitals opting into Subpart K mu st keep a copy of their formal written affiliation agreement with a college or university on file if they are not owned by a college or university. EPA estimates that, each year, 1 si te will retain the agreement on file (i.e., 0 agreements from private sector entities a nd 1 agreement from Stat e and local government entities).59 Non-profit research institutes not owned by a college or university opting into Subpart K must keep a copy of the formal written affiliation agreement with a college or university on file. EPA estimates that, each year, 1 site will retain the agreement on file (i.e., 1 agreement from private sector entities and 0 agreements from State and local government entities).

Withdrawal from 40 CFR Part 262, Subpart K

EPA estimates that, each year, 421 eligible academic entities will subm it a notification of withdrawal from 40 CFR Part 262, Subpart K. (i.e., 414 notifications from private sector entities

and 7 notifications from State and local government entities).

(c4) Notification of Universal Wast e Activity under 40 C FR Part 273, Subpart C

EPA estimates that, each year, 83 facilities (i.e ., 70 private sector facilities and 13 State and local government facilities ) will submit an initial notifica tion of universal waste activity under 40 CFR Part 273, Subpart C. Of these fac ilities, 75 percent (i.e., 83 x 0.75 = 62) will use the Site ID Form and 25 percent (i.e., 83 x 0.25 = 21) will prepare and submit a letter requesting

an EPA Identification Number.

EPA also estimates that, each year, 101facilitie s (i.e., 89 private sector facilities and 12 State and local government facilities) will submit a subsequent notification of universal waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 perc ent (i.e., 101 x 0.75 =76)

will use the Site ID Form and 25 percent (i.e., 101 x 0.25 =25) will prepare and submit a letter requesting an EPA Identification Number.

(c5) Notification of Used Oil Activity under 40 CFR Part 279

EPA estimates that, each year, 82 facilities (i.e ., 78 private sector facilities and 4 State and local government facilities ) will submit an initial notifica tion of used o il activity under

40 CFR Part 279. Of these facil ities, 75 percent (i.e., 82 x 0.75 = 61) will use the Site ID Form and 25 percent (i.e., 82 x 0.25 = 21) will prepar e and submit a letter requesting an EPA

Identification Number.

EPA also estimates that, each year, 198 facili ties (i.e., 192 private sect or facilities and 6 State and local government facilities) will submit a subsequent notification of universal waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 per cent (i.e., 198 x 0.75 =148)

will use the Site ID Form and 25 percent (i.e., 198 x 0.25 = 50) will prepare and submit a letter requesting an EPA Identification Number.

(d) Notification of Regulated Waste Ac tivity – State Agencies (Exhibit 2C)

State agencies will conduct the informati on collection activities associated with the Notification of Regulated Waste Ac tivity in Authorized States.60 (d1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

EPA estimates that, each year, State agenci es will review and enter notification

information into RCRAInfo for 16 facilities that plan to operate under the exclusion at 40 CFR 260.42, 8 facilities that must re-notify by March 1 of each even numbered year, and 13 facilities that will re-notify because they st opped operating under the exclusion.

(d2) Notification of Hazardous Wast e Activity under RCRA Section 3010

EPA estimates that, each year, State agenci es will review and enter notification information into RCRAInfo for 10,217 facilities that will submit an in itial notification of hazardous waste activity under RCRA Section 3010 and for 36,016 facilities that will submit a subsequent notification associated with these requirements.

(d3) Notification of Hazardous Waste Ac tivity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

EPA estimates that, each year, State agenci es will review and enter notification information into RCRAInfo for 14 eligible academic entities that elect to be subject to Subpart K for all laboratories owned by the eligible academic entity under the same EPA Identification

Number.

Withdrawal from 40 CFR Part 262, Subpart K

EPA estimates that, each year, State agenci es will review and enter notification information into RCRAInfo for 421 eligible acad emic entities that withdraw from the 40 CFR Part 262, Subpart K requirements.

(d4) Notification of Universal Wast e Activity under 40 C FR Part 273, Subpart C

EPA estimates that, each year, State agencies will review and ente r initial notification

information into RCRAInfo for 83 facilities. Of th ese facilities, 62 will use the Site ID Form and 21 will prepare and submit a letter requesting an EPA Identification Number.

EPA also estimates that, each year, State ag encies will review and enter subsequent

notification information into RCRAInfo for 101faciliti es. Of these facilities, 76 will use the Site ID Form and 25 will prepare and submit a letter requesting an EPA Identification Number.

(d5) Notification of Used Oil Activity under 40 CFR Part 279

EPA estimates that, each year, State agencies will review and ente r initial notification

information into RCRAInfo for 82 facilities. Of th ese facilities, 61 will use the Site ID Form and 21 will prepare and submit a letter requesting an EPA Identification Number.61 EPA also estimates that, each year, State ag encies will review and enter subsequent

notification information for 198 faci lities. Of these f acilities, 148 will use the Site ID Form and 50 will prepare and submit a letter requesting an EPA Identification Number.

(e) Part A Hazardous Waste Permit App lication and Modification - Facilities (Exhibits 3A and 3B)

(e1) Part A Permit Application

EPA estimates that, each year, 4 facilities (i.e ., 4 private sector faci lities and 0 State and local government facility) will submit a new Part A Permit Application. A ll facilities will need to obtain signatures for the Part A Permit App lication, Part A Permit Application reports, and other information requested by th e Director. In addition, all f acilities will need to obtain certifications from persons signing permit documentation.

EPA also estimates that, each year, 10 percen t of the facilities submitting Part A Permit Applications will have authorizat ions that are no longer accurate because a different individual or position has responsibility for the overall opera tion of the facility. Therefore, each year, 1 facility will need to obtain a new authorization.

(e2) Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

EPA estimates that, each year, 25 facilities (i.e ., 23 private sector facilities and 2 State and local government facilities) will need to revise their Part A Permit Application. Of these, EPA expects that approximately one-third (8 facilities) will submit a revised Part A Permit Application in response to an EPA rulemaking, a nd two-thirds (17facilities) will submit a revised Part A Permit Application for a facility modification.

EPA further estimates that, each year, one-third of facilities submitting revised Part A Permit Applications (8 facilities) will need to su bmit justifications due to either changes in the design capacity of processes used at the facility and/or changes or additions in a facility's hazardous waste treatment, storage, or disposal processes. In addition, EPA estimates that, each year, one-third of facilities submitting revised Part A Permit Applications (8 facilities) will need to submit a Subpart H compliance demonstration due to changes in ownership or operational control of a facility.

(f) Part A Hazardous Waste Permit Application and Modification – State Agencies (Exhibit 3C)

(f1) Part A Permit Application

EPA estimates that, each year, State agencies will receive 4 Part A Permit Applications. State agencies will need to review the appli cations, review the signatories to the permit applications and reports, and en ter the Part A Permit Application information into RCRAInfo.

EPA also estimates that, each year, 10 per cent of the Part A Permit Applications will62 have authorizations that are no longer accurate because a different individual or position has responsibility for the overall opera tion of the facility. Therefore, each year, State agencies will need to notify1 applicant of a deficiency in the Part A Application and review the newly authorized signature.

(f2) Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

EPA estimates that, each year, State agenci es will receive 25 revised Part A Permit Applications. State agencies will need to revi ew the applications and enter the Part A Permit Application information into RCRAInfo.

EPA further estimates that, each year, one-third of the revised Part A Permit Applications (8 applications) will be accompanied by justifi cations due to either changes in the design capacity of processes used at the facility and/or changes or add itions in a facility's hazardous waste treatment, storage, or disposal processes. In addition, EPA estimates that, each year, onethird of the revised Part A Permit Applications (8applications) will be accompanied by a Subpart H compliance demonstration due to changes in ownership or opera tional control of a facility. State agencies will need to review all justifi cations and Subpart H compliance demonstrations.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibit 7 summarizes the tota l annual respondent hour and cost burden associated with all the requirements covered in this ICR. As shown in the ex hibit, EPA estimates the annual respondent burden to be 619,489 hours and $25,530,368. The bottom line burden to respondents over two years is estimated to be 1,238,978 hours and $51,060,736.

(2) Agency Tally

Exhibit 8 summarizes the total annual EPA hour and cost burden associated with all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual EPA burden to be 1,178 hours and $247,297. The bottom line burden to EPA over two years is estimated to be 2,356 hours and $494,594.63 6(f) REASONS FOR CHANGE IN BURDEN

Following is a discussion of reasons for cha nge in burden. Note that this ICR burden changed solely because of adjustments. There were no program changes.

(1) Hazardous Waste Report

(a) Facility Burden

For facilities, the annual burden estimat e for the 2013 Hazardous Waste Report (EPA ICR Number 0976.16) was 170,250 hours. The annual burden estimate for the 2015 Hazardous Waste Report is 195,725 hours. This repr esents an increase of 25,475 hours.

This increase in burden has occurred for two primary reasons. First, there was an increase in the number of Hazardous Waste Report forms projected for 2013 versus the number of forms projected for 2015. Table 12 compares the proj ected number of forms for the 2013 and the 2015 Hazardous Waste Reports.

Second, in developing this ICR, EPA caref ully reviewed the respondent activities associated with the Hazardous Waste Report requirements. Based on consultations with industry, EPA increased some of the hourly burde n estimates associated with the Hazardous Waste Report. EPA believes that the revised bu rden estimates included in this ICR reflect a realistic industry average.

Table 12 Comparison of Projected Number of Forms for the 2013 and 2015 Hazardous Waste Report

Hazardous Waste Report Form Projected Number of Forms

Difference a 2013

Hazardous Waste Report 2015

Hazardous Waste Report

Site ID Form - RCRA Subtitle C Site

Identification Form 21,066 20,536 -530

Form GM - Generation and Mana gement 206,032 256,598 50,566

Form WR - Waste Received from Offsite 1,036,999 1,269,595 232,596
Total 1,264,097 1,546,729 282,632

a Negative value indicates a decrease in the number of forms.64 (b) State Agency Burden

For State agencies, the annual burden estimate for the 2013 Hazardous Waste Report (EPA ICR Number 0976.16) was 228,337 hours. The annual burden estimate for the 2015 Hazardous Waste Report is 301,752 hours. This represents an increase of 73,415 hours.

This increase in burden has occurred for two primary reasons. First, there was an increase in the number of Hazardous Waste Report forms from 2013 to 2015. Refer to Table 12 for a comparison of the projected number of fo rms for the 2013 and the 2015 Hazardous Waste Reports.

Second, in developing this ICR, EPA caref ully reviewed the respondent activities associated with the Hazardous Waste Report requ irements. Based on consultations with States, EPA increased some of the hourly burden esti mates associated with the Hazardous Waste Report. EPA believes that the revised burden estim ates included in this ICR reflect a realistic national average.

(2) Notification of Regulated Waste Activity

(a) Facility Burden

For facilities, the annual burden estimate for the previously approved ICR (EPA ICR Number 0976.16) was 33,826 hours. The annual burden estimate for this current ICR (EPA ICR Number 0976.17 is 34,876 hours. This repres ents an increase of 1,050 hours.

This increase in burden has occurred for two primary reasons. First, there was an

increase in the total number of notifications covere d in the ICR. As shown in Table 13, the total

number of notifications incr eased from 46,035 in the previ ously approved ICR (EPA ICR Number 0976.16) to 47,176 in this ICR (EPA ICR Number 0976.17).

Second, in developing this ICR, EPA caref ully reviewed the respondent activities

associated with the notifica tion requirements. Based on c onsultations with industry, EPA increased some of the hourly burde n estimates associated with no tifications. EPA believes that

the revised burden estimates included in this ICR reflect a realistic industry average.65 Table 13 Comparison of Projected Number of Notifications in the Previously Approved ICR (EPA ICR Number 0976.16) and this ICR (EPA ICR Number 0976.17).

Type of Notification Projected Number of Notifications

Difference a EPA ICR

Number 0976.16 EPA ICR

Number 0976.17

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42 30 42 12

Notification of Hazardous Waste Activity

under RCRA Section 3010 45,520 46,233 713

Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K 9 437 428

Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C 154 184 30

Notification of Used Oil Activity under

40 CFR Part 279 322 280 -42

Total 46,035 47,176 1,141

a Negative value indicates a decrease in the number of forms.

(b) State Agency Burden

For State agencies, the annua l burden estimate for the prev iously approved ICR (EPA ICR Number 0976.16) was 0 hours. The annual burden estimate for this current ICR (EPA ICR Number 0976.17 is 86,538 hours. This repres ents an increase of 86,538 hours.

This increase in burden has occurred because , in the previously approved ICR (EPA ICR Number 0976.16), all implementing agency activiti es were allocated to EPA. However, Authorized States implement notification requi rements. Thus, the burden associated with

notification activities at Authorized States was allocated to State agencies. EPA believes that this revision more accurately reflects the burden to State agencies.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Facility Burden

For facilities, the annual burden estimate for the previously approved ICR (EPA ICR Number 0976.16) was 389 hours. The annual burden estimate for this current ICR (EPA ICR Number 0976.17 is 447 hours. This repres ents an increase of 58 hours.

The increase in hourly burden occurred for two primary reasons. First, there was an

increase in the number of modifications to Part A Permit Applications. The number of modifications increased from 22 in the previ ously approved ICR to 25 in this ICR.66 Second, in developing this ICR, EPA caref ully reviewed the respondent activities associated with the Part A Permit Applicati on requirements. Based on consultations with industry, EPA increased some of the hourly burde n estimates associated with Part A Permit Applications. EPA believes that the revised burden estimates included in this ICR reflect a realistic industry average.

(b) State Agency Burden

For State agencies, the annua l burden estimate for the prev iously approved ICR (EPA ICR Number 0976.16) was 101 hours. The annual burden estimate for this current ICR (EPA ICR Number 0976.17 is 150 hours. This repr esents an increase of 49 hours.

The increase in hourly burden occurred for two primary reasons. First, there was an

increase in the number of modifications to Part A Permit Applications. The number of modifications increased from 22 in the previ ously approved ICR to 25 in this ICR.

Second, in developing this ICR, EPA caref ully reviewed the respondent activities associated with the Part A Permit Application re quirements. Based on consultations with States, EPA increased some of the hourly burden estimate s associated with Part A Permit Applications.

EPA believes that the revised burden estimates in cluded in this ICR reflect a realistic national

average.

6(g) PUBLIC BURDEN STATEMENT

(1) Hazardous Waste Report

The reporting burden is estimated to be a bout 14 hours for a facility to gather data, complete and review the forms, and submit the Hazardous Waste Report. The recordkeeping

burden is estimated to be about 5 hours to read the instructions, and file and store the Hazardous Waste Report submission for three years.

The reporting burden is estimated to be about 30 hours per facility for a State agency to

distribute the Hazardous Waste Re port Instructions and Forms, assist respondents, key entry report submissions, and perform quality assurance. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

(2) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

The reporting burden associated with h azardous secondary material notification requirements is estimated to be about 1 hour for a facility to notify EPA under 40 CFR 260.42. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.67 The recordkeeping burden associated with hazardous secondary ma terial notification requirements (initial and subsequent) is estimate d to be 1.7 hours for State agencies to review

and enter notification information into RCR AInfo. There are no reporting requirements associated with this requirement, and as such, there is no reporting burden.

(b) Notification of Hazardous Was te Activity under RCRA Section 3010

The reporting burden associated with RCR A Section 3010 notification requirements (initial and subsequent) is estimated to be about 44 minutes for a facility to complete and submit the form. There are no recordkeeping requirement s associated with this requirement, and as such, there is no recordkeeping burden.

The recordkeeping burden associated with RCRA Section 3010 notification requirements (initial and subsequent) is estimated to be about 1.8 hours for State agencies to review and enter

notification information into RCRAInfo. There are no reporting requirements associated with this requirement, and as suc h, there is no reporting burden.

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

The reporting burden associated with notif ication requirements under 40 CFR Part 262, Subpart K is estimated to be about 38 minutes for a fac ility to prepare and s ubmit a Site ID Form to opt into or withdraw from Subpart K. Th e recordkeeping burden is estimated to be about 5 minutes to keep copies of notificat ion and affiliation agreements on-site.

The recordkeeping burden associated with 40 CFR Part 262, Subpart K notification requirements (initial and subsequent) is estima ted to be about 1.7 hours for State agencies to

review and enter notification in formation into RCRAInfo. Ther e are no reporting requirements associated with this requirement, and as such, there is no reporting burden.

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

The reporting burden associated with 40 CFR Part 273, Subpart C notification requirements (initial and subsequent) is estima ted to be about 45 minutes for a facility to complete the Site ID Form or prepare a lette r requesting an EPA Identification Number, and submit the completed Site ID Form or lette r. There are no recordkeeping requirements associated with this requirement, and as such, there is no recordkeeping burden.

The recordkeeping burden associated with 40 CFR Part 273, Subpart C notification requirements (initial and subsequent) is estima ted to be about 1.9 hours for State agencies to

review and enter notification in formation into RCRAInfo. Ther e are no reporting requirements associated with this requirement, and as such, there is no reporting burden.

(e) Notification of Used Oil Activity under 40 CFR Part 279

The reporting burden associated with 40 CFR Part 279 notification re quirements (initial and subsequent) is estimated to be about 42 minutes for a facility to comp lete the Site ID Form68 or prepare a letter requesting an EPA Identification Number, and submit the completed Site ID Form or letter. There are no recordkeeping require ments associated with this requirement, and as such, there is no recordkeeping burden.

The recordkeeping burden associated with 40 CFR Part 279 notification requirements (initial and subsequent) is estimated to be about 1.9 hours for State agencies to review and enter

notification information into RCRAInfo. There are no reporting requirements associated with this requirement, and as suc h, there is no reporting burden.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

The reporting burden associated with the Pa rt A Permit Application requirements is estimated to be about 24 hours for a facility to prepare and submit a Part A Permit Application. The recordkeeping burden is estimated to be about 7 hours to read the regulations.

The reporting burden associated with the Pa rt A Permit Application requirements is estimated to be about 12 minutes for a State agency to notify an applicant of a deficiency in the Part A Permit Application. The r ecordkeeping burden is estimated to be about 5 hours to review an application and signatories to the permit applications and repor ts, and enter the Part A Permit Application information into RCRAInfo.

(b) Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

The reporting burden associated with revising a Part A Permit Applications is estimated to be 10 hours for facilities to prepare and s ubmit a revised Part A Permit Application, prepare and submit justifications for changes, and prepare and submit Subpart H compliance demonstrations. The recordkeeping burden is es timated to be 3 hours to read the regulations.

The recordkeeping burden associated with revising a Part A Permit Applications is estimated to be 5 hours for State agencies to re view a Part A Permit Application, justification, and Subpart H compliance demonstration, and ente r the Part A Permit A pplication information into RCRAInfo. There are no reporting requirement s associated with this requirement, and as such, there is no reporting burden.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct69 or sponsor, and a person is not required to re spond 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.

To comment on EPA 's need for this information, the accuracy of the provided burden estimates, and any suggested methods for mini mizing respondent burden, including the use of automated collection techniques, EPA has establis hed a public docket for this ICR under Docket ID Number EPA-HQ-RCRA–2014–0296, 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 Building, 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 numbe r for the RCRA Docket is (202) 566-0270, and the fax number is (202) 566 -9744. 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 conten ts of the public docke t, and to access those documents in the public docket that are availabl e 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 Affair s, 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–2014–0296 and O MB Control Number 2050-0024 in any correspondence.70EXHIBIT 1A2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $178.90 $0.00 $0.00 9,201 25,394.76 $1,646,058.90Revise in-house or commercial data system to includenew Hazardous Waste Report data items that are notpart of the facility’sgeneral business operations0.00 0.33 0.67 0.00 1.00 $63.62 $0.00 $0.00 4,349 4,349.00 $276,683.38Gather information and prepare Site ID Form 0.00 0.08 0.60 0.16 0.84 $45.94 $0.00 $0.00 9,201 7,728.84 $422,693.94Gather information and prepare Form GM 0.00 0.13 0.15 0.04 0.32 $19.92 $0.00 $0.00 119,664 38,292.48 $2,383,706.88Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $7.77 $0.00 $0.00 631,260 75,751.20 $4,904,890.20Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0.00Submit report to the State or EPA Regional Office 0.00 0.82 0.32 0.20 1.34 $88.09 $0.00 $6.51 9,201 12,329.34 $870,414.60Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $1.26 $0.00 $0.00 760,125 22,803.75 $957,757.50TOTAL varies varies varies varies varies varies varies varies varies 186,649.37 $11,462,205.40aExhibit includes rounding.Hazardous Waste Report71EXHIBIT 1B2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $118.56 $0.00 $0.00 1,067 2,944.92 $126,503.52Revise in-house or commercial data system to includenew Hazardous Waste Report data items that are notpart of the facility’s general business operations0.00 0.33 0.67 0.00 1.00 $41.56 $0.00 $0.00 219 219.00 $9,101.64Gather information and prepare Site ID Form 0.00 0.08 0.60 0.16 0.84 $28.43 $0.00 $0.00 1,067 896.28 $30,334.81Gather information and prepare Form GM 0.00 0.13 0.15 0.04 0.32 $13.36 $0.00 $0.00 8,636 2,763.52 $115,376.96Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $5.43 $0.00 $0.00 3,538 424.56 $19,211.34Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0.00Submit report to the State or EPA Regional Office 0.00 0.82 0.32 0.20 1.34 $61.85 $0.00 $6.51 1,067 1,429.78 $72,940.12Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $0.77 $0.00 $0.00 13,241 397.23 $10,195.57TOTAL varies varies varies varies varies varies varies varies varies 9,075.29 $383,663.96aExhibit includes rounding.Hazardous Waste Report72EXHIBIT 1C2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIESaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearDistribute Hazardous Waste Report forms and instructions 0.00 0.02 0.25 0.50 0.77 $20.49 $0.00 $3.21 10,152 7,817.04 $240,602.40Assist respondents 0.00 0.02 0.38 0.38 0.78 $22.31 $0.00 $0.00 10,152 7,918.56 $226,491.12Key entry of report submissions 0.00 0.02 0.07 0.22 0.31 $8.29 $0.00 $0.00 11,191 3,469.21 $92,773.39Perform quality assurance 0.00 0.02 0.17 0.18 0.37 $10.60 $0.00 $0.00 771,988 282,547.61 $8,183,072.80TOTAL varies varies varies varies varies varies varies varies varies 301,752.42 $8,742,939.71aExhibit includes rounding.Hazardous Waste Report73EXHIBIT 2ANOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearComplete and submit EPA Form 8700-12 prior to operatingunder exclusion(s)0.00 0.10 0.94 0.10 1.14 $64.84 $0.00 $3.82 18 20.52 $1,235.88Complete and submit EPA Form 8700-12 by March 1 ofeach even numbered year thereafter0.00 0.10 0.94 0.10 1.14 $64.84 $0.00 $3.82 9 10.26 $617.94Complete and submit EPA Form 8700-12 indicating that thehazardous secondary materials are no longer managed inaccordance w ith the exclusion0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 15 9.60 $601.20Subtotal varies varies varies varies varies varies varies varies varies 40.38 $2,455.02Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 9,157 9,981.13 $603,171.59Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 34,056 21,795.84 $1,364,964.48Subtotal varies varies varies varies varies varies varies varies varies 31,776.97 $1,968,136.07Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 4 2.56 $160.32Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 4 0.32 $11.00Keep a copy of their formal w ritten affiliation agreementw ith college or university on file w hile its laboratories aresubject to Subpart K0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 0 0.00 $0.00Keep a copy of the formal w ritten affiliation agreementw ith a college or university on file at the non-profitresearch institute w hile its laboratories are subject toSubpart K0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 1 0.08 $2.75Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 414 264.96 $16,593.12Keep a copy of the w ithdraw al notice on file 0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 414 33.12 $1,138.50Subtotal varies varies varies varies varies varies varies varies varies 301.04 $17,905.69aExhibit includes rounding.Notification of Hazardous Waste Activity under 40 CFR Part 262, SubpartKIntent to Comply with Subpart K and Recordkeeping of AgreementsWithdrawal from 40 CFR Part 262, SubpartKTeaching HospitalsNon-Profit Research InstitutesNotification of Hazardous Secondary Material Activity under 40 CFR 260.42Notification of Hazardous Waste Activity under RCRA Section 3010Eligible Academic EntitiesInitial NotificationSubsequent Notification74EXHIBIT 2A (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearComplete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 53 57.77 $3,491.11Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 18 9.00 $578.52Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 67 42.88 $2,685.36Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 22 11.00 $707.08Subtotal varies varies varies varies varies varies varies varies varies 120.65 $7,462.07Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 59 64.31 $3,886.33Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 20 10.00 $642.80Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 144 92.16 $5,771.52Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 48 24.00 $1,542.72Subtotal varies varies varies varies varies varies varies varies varies 190.47 $11,843.37TOTAL varies varies varies varies varies varies varies varies varies 32,429.51 $2,007,802.22aExhibit includes rounding.LetterNotification of Universal Waste Activity under 40 CFR Part 273, Subpart CLetterEPA Form 8700-12Initial NotificationSubsequent NotificationEPA Form 8700-12EPA Form 8700-12LetterSubsequent NotificationNotification of Used Oil Activity under 40 CFR Part 279Initial NotificationEPA Form 8700-12Letter75EXHIBIT 2BNOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearComplete and submit EPA Form 8700-12 prior to operatingunder exclusion(s)0.00 0.10 0.94 0.10 1.14 $39.83 $0.00 $3.82 0 0.00 $0.00Complete and submit EPA Form 8700-12 by March 1 ofeach even numbered year thereafter0.00 0.10 0.94 0.10 1.14 $39.83 $0.00 $3.82 0 0.00 $0.00Complete and submit EPA Form 8700-12 indicating that thehazardous secondary materials are no longer managed inaccordance w ith the exclusion0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 1,060 1,155.40 $44,244.40Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 1,960 1,254.40 $52,214.40Subtotal varies varies varies varies varies varies varies varies varies 2,409.80 $96,458.80Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 10 6.40 $266.40Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 10 0.80 $17.40Keep a copy of their formal w ritten affiliation agreementw ith college or university on file w hile its laboratories aresubject to Subpart K0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 1 0.08 $1.74Keep a copy of the formal w ritten affiliation agreementw ith a college or university on file at the non-profitresearch institute w hile its laboratories are subject toSubpart K0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 0 0.00 $0.00Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 7 4.48 $186.48Keep a copy of the w ithdraw al notice on file 0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 7 0.56 $12.18Subtotal varies varies varies varies varies varies varies varies varies 12.32 $484.20aExhibit includes rounding.Eligible Academic EntitiesNotification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KIntent to Comply with Subpart K and Recordkeeping of AgreementsNotification of Hazardous Waste Activity under RCRA Section 3010Initial NotificationSubsequent NotificationTeaching HospitalsNon-Profit Research InstitutesWithdrawal from 40 CFR Part 262, Subpart KNotification of Hazardous Secondary Material Activity under 40 CFR 260.4276EXHIBIT 2B (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearComplete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 9 9.81 $375.66Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 3 1.50 $65.01Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 9 5.76 $239.76Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 3 1.50 $65.01Subtotal varies varies varies varies varies varies varies varies varies 18.57 $745.44Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 2 2.18 $83.48Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 1 0.50 $21.67Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 4 2.56 $106.56Prepare and submit letter requesting an EPA IdentificationNumber0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 2 1.00 $43.34Subtotal varies varies varies varies varies varies varies varies varies 6.24 $255.05TOTAL varies varies varies varies varies varies varies varies varies 2,446.93 $97,943.49aExhibit includes rounding.LetterEPA Form8700-12EPA Form8700-12Initial NotificationLetterSubsequent NotificationLetterEPA Form8700-12LetterSubsequent NotificationNotification of Used Oil Activity under 40 CFR Part 279Initial NotificationEPA Form8700-12Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C77EXHIBIT 2CNOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIESaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 16 3.96 $134.80Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 16 23.60 $769.82Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 8 1.98 $67.40Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 8 11.80 $384.91Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 13 3.30 $112.33Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 13 19.67 $641.52Subtotal varies varies varies varies varies varies varies varies varies 64.31 $2,110.78Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 10,217 2,554.25 $86,946.67Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 10,217 15,325.50 $500,019.98Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $9.36 $0.00 $0.52 10,217 4,291.14 $100,943.96Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 36,016 9,004.00 $306,496.16Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 36,016 53,663.84 $1,750,377.60Subtotal varies varies varies varies varies varies varies varies varies 84,838.73 $2,744,784.37Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 14 3.50 $119.14Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 14 20.86 $680.40Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 421 105.25 $3,582.71Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 421 627.29 $20,460.60Subtotal varies varies varies varies varies varies varies varies varies 756.90 $24,842.85aExhibit includes rounding.Eligible Academic EntitiesNotification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KIntent to Comply with Subpart K and Recordkeeping of AgreementsWithdrawal from 40 CFR Part 262, Subpart KNotification of Hazardous Secondary Material Activity under 40 CFR 260.42Notification of Hazardous Waste Activity under RCRA Section 3010Initial NotificationSubsequent NotificationNotification prior to operating under exclusion(s)Notification by March 1 of each even numbered year thereafterNotification indicating that the hazardous secondary materials are no longer managed in accordance with the exclusion78EXHIBIT 2C (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIESaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 62 15.50 $527.62Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 62 93.00 $3,034.28Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $9.36 $0.00 $0.52 62 26.04 $612.56Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 21 5.25 $178.71Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 21 31.50 $1,027.74Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $9.36 $0.00 $0.52 21 8.82 $207.48Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 76 19.00 $646.76Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 76 113.24 $3,693.60Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 25 6.25 $212.75Enter letter information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 25 37.25 $1,215.00Subtotal varies varies varies varies varies varies varies varies varies 355.85 $11,356.50Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 61 15.25 $519.11Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 61 91.50 $2,985.34Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $9.36 $0.00 $0.52 61 25.62 $602.68Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 21 5.25 $178.71Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 21 31.50 $1,027.74Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $9.36 $0.00 $0.52 21 8.82 $207.48Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 148 37.00 $1,259.48Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 148 220.52 $7,192.80Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 50 12.50 $425.50Enter letter information into database0.00 0.00 1.32 0.171.49 $48.60 $0.00 $0.00 50 74.50 $2,430.00Subtotal varies varies varies varies varies varies varies varies varies 522.46 $16,828.84TOTAL varies varies varies varies varies varies varies varies varies 86,538.25 $2,799,923.34aExhibit includes rounding.EPA Form8700-12Initial NotificationInitial NotificationNotification of Universal Waste Activity under 40 CFR Part 273, Subpart CEPA Form8700-12LetterSubsequent NotificationEPA Form8700-12Subsequent NotificationEPA Form8700-12LetterLetterLetterNotification of Used Oil Activity under 40 CFR Part 27979EXHIBIT 3APART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the regulations and instructions 2.38 1.18 3.57 0.00 7.13 $603.57 $0.00 $0.00 4 28.52 $2,414.28Prepare the Site Identification Form 0.00 0.08 0.69 0.17 0.94 $51.43 $0.00 $0.00 4 3.76 $205.72Prepare the Hazardous Waste Permit Information Form andreports1.67 3.28 8.83 1.67 15.45 $1,030.63 $0.00 $0.00 4 61.80 $4,122.52Obtain signatures and certifications for Part A permitapplications, reports, and other information requested byEPA0.00 0.50 1.00 1.00 2.50 $129.92 $0.00 $0.00 4 10.00 $519.68Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $112.72 $0.00 $0.00 1 2.00 $112.72Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $147.11 $0.00 $6.51 4 12.00 $614.48Explain or cure an alleged deficiency in Part A application,if required0.00 0.77 3.07 1.53 5.37 $287.18 $0.00 $0.00 1 5.37 $287.18Subtotal varies varies varies varies varies varies varies varies varies 123.45 $8,276.58Read the regulations and instructions (for Agencyrulemaking)0.00 1.00 2.00 0.00 3.00 $191.05 $0.00 $0.00 8 24.00 $1,528.40Read the regulations and instructions (for facilitymodification)0.00 1.00 2.00 0.00 3.00 $191.05 $0.00 $0.00 15 45.00 $2,865.75Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $498.94 $0.00 $6.51 8 54.00 $4,043.60Prepare and submit revised Part A (for facility modification) 1.75 1.40 1.78 1.82 6.75 $498.94 $0.00 $6.51 15 101.25 $7,581.75Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $355.26 $0.00 $6.51 8 40.00 $2,894.16Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $355.26 $0.00 $6.51 8 40.00 $2,894.16Subtotal varies varies varies varies varies varies varies varies varies 304.25 $21,807.82TOTAL varies varies varies varies varies varies varies varies varies 427.70 $30,084.40aExhibit includes rounding.Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance DemonstrationsSubmittal of Part A Permit ApplicationPart A Permit ApplicationSignatories to Permit Applications and Permit Application ReportsContents of the Part A Permit Application80EXHIBIT 3BPART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIESaHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the regulations and instructions 2.38 1.18 3.57 0.00 7.13 $332.70 $0.00 $0.00 0 0.00 $0.00Prepare the Site Identification Form 0.00 0.08 0.69 0.17 0.94 $31.71 $0.00 $0.00 0 0.00 $0.00Prepare the Hazardous Waste Permit Information Form andreports1.67 3.28 8.83 1.67 15.45 $624.29 $0.00 $0.00 0 0.00 $0.00Obtain signatures and certifications for Part A permitapplications, reports, and other information requested byEPA0.00 0.50 1.00 1.00 2.50 $84.15 $0.00 $0.00 0 0.00 $0.00Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $73.30 $0.00 $0.00 0 0.00 $0.00Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $95.00 $0.00 $6.51 0 0.00 $0.00Explain or cure an alleged deficiency in Part A application,if required0.00 0.77 3.07 1.53 5.37 $181.42 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00Read the regulations and instructions (for Agencyrulemaking)0.00 1.00 2.00 0.00 3.00 $124.90 $0.00 $0.00 0 0.00 $0.00Read the regulations and instructions (for facilitymodification)0.00 1.00 2.00 0.00 3.00 $124.90 $0.00 $0.00 2 6.00 $249.80Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $285.65 $0.00 $6.51 0 0.00 $0.00Prepare and submit revised Part A (for facility modification) 1.75 1.40 1.78 1.82 6.75 $285.65 $0.00 $6.51 2 13.50 $584.32Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $207.17 $0.00 $6.51 0 0.00 $0.00Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $207.17 $0.00 $6.51 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 19.50 $834.12TOTAL varies varies varies varies varies varies varies varies varies 19.50 $834.12aExhibit includes rounding.Submittal of Part A Permit ApplicationRevised Part A Permit Applications and Associated Justifications and Subpart H Compliance DemonstrationsContents of the Part A Permit ApplicationPart A Permit ApplicationSignatories to Permit Applications and Permit Application Reports81EXHIBIT 3CPART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIESaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $107.49 $0.00 $0.00 4 13.00 $429.96Ensure that Part A Permit Application and Reports havebeen signed by appropriate person0.00 0.00 0.25 0.000.25 $8.51 $0.00 $0.00 4 1.00 $34.04Review new ly authorized signatures w hen a differentindividual or position gains responsibility for the overalloperation of a facility0.00 0.00 0.32 0.00 0.32 $10.89 $0.00 $0.00 1 0.32 $10.89Review signature certifications 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 4 1.00 $34.04Enter Part A Application information into RCRAInfoDatabase0.00 0.00 0.00 1.001.00 $21.70 $0.00 $0.00 4 4.00 $86.80Notify applicant of deficiency in the Part A PermitApplication0.00 0.00 0.63 0.180.81 $25.34 $0.00 $0.00 1 0.81 $25.34Subtotal varies varies varies varies varies varies varies varies varies 20.13 $621.07Review revised Part A Permit Application 0.00 0.00 3.00 0.25 3.25 $107.49 $0.00 $0.00 25 81.25 $2,687.25Enter revised Part A Permit Application information intoRCRAInfo Database0.00 0.00 0.00 1.001.00 $21.70 $0.00 $0.00 25 25.00 $542.50Review justifications for changes 0.5 0.25 0.75 0 1.50 $70.02 $0.00 $0.00 8 12.00 $560.16Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $70.02 $0.00 $0.00 8 12.00 $560.16Subtotal varies varies varies varies varies varies varies varies varies 130.25 $4,350.07TOTAL varies varies varies varies varies varies varies varies varies 150.38 $4,971.14aExhibit includes rounding.Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance DemonstrationsPart A Permit Application82EXHIBIT 42015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL EPA HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearDevelop Hazardous Waste Report forms and instructions 0.00 8.00 80.00 20.00 108.00 $5,530.72 $0.00 $22,019.00 0.50 54.00 $13,774.86Distribute Hazardous Waste Report forms and instructions 0.00 0.02 0.25 0.50 0.77 $27.26 $0.00 $0.00 143 110.11 $3,898.18Develop computer capabilities required to compile nationaldata0.00 8.00 80.00 0.00 88.00 $5,057.12 $0.00 $275,237.00 0.50 44.00 $140,147.06Assist respondents 0.00 0.02 0.38 0.38 0.78 $31.63 $0.00 $0.00 143 111.54 $4,523.09Key entry of report submissions 0.00 0.02 0.07 0.22 0.31 $10.64 $0.00 $0.00 100 31.00 $1,064.00Perform quality assurance 0.00 0.02 0.17 0.18 0.37 $14.93 $0.00 $0.00 1,377 503.98 $20,558.61Prepare the National Report 0.00 8.00 200.00 40.00 248.00 $12,664.32 $0.00 $55,047.00 0.50 124.00 $33,855.66Store the data 0.00 0.00 80.00 0.00 80.00 $4,440.00 $0.00 $38,534.00 0.50 40.00 $21,487.00TOTAL varies varies varies varies varies varies varies varies varies 1,018.63 $239,308.46aExhibit includes rounding.Hazardous Waste Report83EXHIBIT 5NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL EPA HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 2 0.54 $29.98Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 2 3.22 $166.95Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 1 0.27 $14.99Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 1 1.61 $83.47Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 2 0.45 $24.98Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 2 2.68 $139.12Subtotal varies varies varies varies varies varies varies varies varies 8.77 $459.49Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 0.00 $0.00Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $10.58 $0.00 $0.52 0 0.00 $0.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00aExhibit includes rounding.Notification of Hazardous Secondary Material Activity under 40 CFR 260.42Notification prior to operating under exclusion(s)Notification by March 1 of each even numbered year thereafterNotification indicating that the hazardous secondary materials are no longer managed in accordance with the exclusionNotification of Hazardous Waste Activity under RCRA Section 3010Initial NotificationSubsequent NotificationNotification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KIntent to Comply with Subpart K and Recordkeeping of AgreementsEligible Academic EntitiesWithdrawal from 40 CFR Part 262, Subpart K84EXHIBIT 5 (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 0.00 $0.00Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $10.58 $0.00 $0.52 0 0.00 $0.00Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 0.00 $0.00Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $10.58 $0.00 $0.52 0 0.00 $0.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter letter information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 0.00 $0.00Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $10.58 $0.00 $0.52 0 0.00 $0.00Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 0.00 $0.00Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.02 0.400.42 $10.58 $0.00 $0.52 0 0.00 $0.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 0 0.00 $0.00Enter letter information into database0.00 0.00 1.32 0.171.49 $77.29 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.00TOTAL varies varies varies varies varies varies varies varies varies 8.77 $459.49aExhibit includes rounding.Notification of Universal Waste Activity under 40 CFR Part 273, Subpart CInitial NotificationEPA Form8700-12LetterSubsequent NotificationEPA Form8700-12LetterNotification of Used Oil Activity under 40 CFR Part 279Initial NotificationEPA Form8700-12LetterSubsequent NotificationEPA Form8700-12Letter85EXHIBIT 6PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL EPA HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $172.42 $0.00 $0.00 4 13.00 $689.68Ensure that Part A Permit Application and Reports havebeen signed by appropriate person0.00 0.00 0.25 0.000.25 $13.88 $0.00 $0.00 4 1.00 $55.52Review new ly authorized signatures w hen a differentindividual or position gains responsibility for the overalloperation of a facility0.00 0.00 0.32 0.00 0.32 $17.76 $0.00 $0.00 1 0.32 $17.76Review signature certifications 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 4 1.00 $55.52Enter Part A Application information into RCRAInfoDatabase0.00 0.00 0.00 1.001.00 $23.68 $0.00 $0.00 4 4.00 $94.72Notify applicant of deficiency in the Part A Application 0.00 0.00 0.63 0.18 0.81 $39.23 $0.00 $0.00 1 0.81 $39.23Subtotal varies varies varies varies varies varies varies varies varies 20.13 $952.43Review revised Part A Permit Application 0.00 0.00 3.00 0.25 3.25 $172.42 $0.00 $0.00 25 81.25 $4,310.50Enter revised Part A Permit Application information intoRCRAInfo Database0.00 0.00 0.00 1.001.00 $23.68 $0.00 $0.00 25 25.00 $592.00Review justifications for changes 0.5 0.25 0.75 0 1.50 $104.62 $0.00 $0.00 8 12.00 $836.96Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $104.62 $0.00 $0.00 8 12.00 $836.96Subtotal varies varies varies varies varies varies varies varies varies 130.25 $6,576.42TOTAL varies varies varies varies varies varies varies varies varies 150.38 $7,528.85aExhibit includes rounding.Part A Permit ApplicationRevised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations86EXHIBIT 72015 HAZARDOUS WASTE REPORT, NOTIFICATION OF REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONTOTAL ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN SUMMARYaTotal Total Annual Annual TotalHours per Labor Cost per Capital/Startup O & M Cost perInformation Collection Requirement Year Year Costs Costs YearHazardous Waste Report (Exhibit 1A) 186,649.37 $11,402,306.89 $0.00 $59,898.51 $11,462,205.40Notification of Regulated Waste Activity (Exhibit 2A) 32,429.51 $1,839,324.94 $0.00 $168,477.28 $2,007,802.22Part A Hazardous Waste Permit Application and Modification (Exhibit 3A) 427.70 $29,804.47 $0.00 $279.93 $30,084.40Subtotal 219,506.58 $13,271,436.30 $0.00 $228,655.72 $13,500,092.02Hazardous Waste Report (Exhibit 1B) 9,075.29 $376,717.79 $0.00 $6,946.17 $383,663.96Notification of Regulated Waste Activity (Exhibit 2B) 2,446.93 $86,216.09 $0.00 $11,727.40 $97,943.49Part A Hazardous Waste Permit Application and Modification (Exhibit 3B) 19.50 $821.10 $0.00 $13.02 $834.12Subtotal 11,541.72 $463,754.98 $0.00 $18,686.59 $482,441.57Hazardous Waste Report (Exhibit 1C) 301,752.42 $8,710,351.79 $0.00 $32,587.92 $8,742,939.71Notification of Regulated Waste Activity (Exhibit 2C) 86,538.25 $2,794,524.70 $0.00 $5,398.64 $2,799,923.34Part A Hazardous Waste Permit Application and Modification (Exhibit 3C) 150.38 $4,971.14 $0.00 $0.00 $4,971.14Subtotal 388,441.05 $11,509,847.63 $0.00 $37,986.56 $11,547,834.19Hazardous Waste Report 497,477.08 $20,489,376.47 $0.00 $99,432.60 $20,588,809.07Notification of Regulated Waste Activity 121,414.69 $4,720,065.73 $0.00 $185,603.32 $4,905,669.05Part A Hazardous Waste Permit Application and Modification 597.58 $35,596.71 $0.00 $292.95 $35,889.66Total 619,489 $25,245,039 $0 $285,329 $25,530,3682-Year Total 1,238,978 $50,490,078 $0 $570,658 $51,060,736aExhibit includes rounding.Private FacilitiesState and Local Government FacilitiesAll RespondentsState Agencies87EXHIBIT 82015 HAZARDOUS WASTE REPORT, NOTIFICATION OF REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONTOTAL ESTIMATED ANNUAL EPA HOUR AND COST BURDEN SUMMARYaTotal Total Annual Annual TotalHours per Labor Cost per Capital/Startup O & M Cost perInformation Collection Requirement Year Year Costs Costs YearHazardous Waste Report (Exhibit 4) 1,018.63 $43,889.96 $0.00 $195,418.50 $239,308.46Notification of Regulated Waste Activity (Exhibit 5) 9 $459.49 $0.00 $0.00 $459.49Part A Hazardous Waste Permit Application and Modification (Exhibit 6) 150.38 $7,528.85 $0.00 $0.00 $7,528.85Total 1,178 $51,878 $0 $195,419 $247,2972-Year Total 2,356 $103,757 $0 $390,837 $494,594aExhibit includes rounding.