SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.17 

“2015 HAZARDOUS WASTE REPORT, NOTIFICATION OF 

REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS 

WASTE PERMIT APPLICATION 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) CONSULTATIONS .................................................................................................................. 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 CHANGE IN BURDEN .............................................................................. 63 

6(g) PUBLIC BURDEN STATEMENT ......................................................................................... 66 
3

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

 1(a) TITLE AND NUMBER OF THE 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 approved ICR of the U.S. Environmental Protection 

Agency (EPA): “2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and 

Part A Hazardous Waste Permit Application 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 every 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 facilities (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 laboratories); 40 CFR Part 273, Subpart C 

(universal waste activity); and 40 CFR Part 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 waste 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 required by 40 CFR 270.13. Part B contains 

detailed, site-specific information. There is no form for the Part B Permit 

Application; rather, the Part B Permit Application must be submitted in narrative 

form and contain the information described in applicable sections of 40 CFR 270.14 

through 270.27. This ICR addresses the information collection requirements 

associated with completing and submitting a Part A Permit Application, or modifying 

a hazardous waste permit by submitting a revised application. The information 

collection requirements associated with the Part B Permit Application are covered 

under a separate ICR. 

EPA integrated the above requirements into this ICR to ensure consistency and minimize 

duplication in its burden assumptions and estimates, given that all three requirements address 

some of the same reporting elements. In particular, all three requirements address the use of the 

RCRA Subtitle C Site Identification Form (i.e., the Site ID Form). Specifically, the Hazardous 
4

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 entities to submit the Site ID Form (or alternative 

document, if specified) to notify EPA or the authorized State of regulated waste activity. The 

Part A Permit Application addresses the requirement for all owner/operators of TSDFs to submit 

the Site ID Form as part of their Part A Permit 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 and other collections, ensure consistency and 

nonduplication in its analysis, and address changes to the Site ID Form. 

 1

 An LQG is a facility that generates 1,000 kilograms (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 clean-up material in any single calendar 

month. 
5

2. NEED FOR AND USE OF THE COLLECTION 

2(a) NEED AND AUTHORITY FOR THE COLLECTION 

(1) Hazardous Waste Report 

RCRA Sections 3002 and 3004 authorize the Hazardous Waste Report. Both sections 

require EPA to establish standards for recordkeeping 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 CFR 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 submission of reports to EPA or the States at least every two 

years on the: (1) quantities and nature of hazardous wastes that have been generated during the 

year and (2) disposition of these hazardous wastes. 

Section 3004(a) requires EPA to issue regulations establishing performance standards 

applicable to owners and operators of facilities for the treatment, storage, or disposal of 

hazardous waste that include reporting and maintaining records of all hazardous wastes treated, 

stored, or disposed and the manner in which such 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 addition, Hazardous Waste Report data allow the 

Agency to determine whether its regulations are having the desired effect on the generation and 

management of hazardous waste. For example, Hazardous Waste Report data provide 

information on whether wastes have shifted from one method of disposal 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 notify EPA of their activities, including the location 

and general description of the activities and the regulated wastes handled. As required by 

statute, EPA promulgated regulations to implement 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 environment, 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 needs information contained in the Part A Permit 
6

Application to identify the person(s) legally 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 identify the time frame available for 

EPA to process permit applications, and to define the specific wastes a facility is legally allowed 

to handle for different purposes. 

EPA promulgated regulations at 40 CFR 270.72 outlining changes that require owners or 

operators to submit revised Part A Permit Applications. Section 270.72(a)(1)-(3) requires 

owner/operators to submit both a revised Part A Permit Application and a written justification for 

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. Under Section 270.72(a)(4), 

if an owner or operator changes ownership, or operational control of a facility, 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 applications, justifications, and compliance 

demonstrations to determine whether desired changes 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 requires the collection of information on the 

characteristics of the regulated community generally (e.g., number of generators and TSDFs), as 

well as the specific characteristics of individual sites (e.g., waste handling activities undertaken). 

This information is used for waste activity monitoring, compliance monitoring, technical 

assistance, program planning, waste minimization, 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 information 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/inforesources/data/biennialreport/index.htm. 

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

 Describing the various source activities that generate hazardous waste and the 

generated waste types and quantities. 

 Describing the management methods by which the waste is treated, disposed, or 

recycled and the quantities managed by each method. 
7

 Providing information for analysis of trends in waste generation, waste treatment 

and disposal, recycling, and source reduction. 

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

State. 

 Estimating available capacity for treating, recycling, and disposing hazardous 

wastes. 

Additionally, EPA utilizes the Hazardous Waste Report information for planning and 

developing regulations; regulation development depends on descriptions and quantities of 

generated hazardous waste and management methods used for treatment, recycling, and disposal. 

The information allows the Agency to determine whether regulations are having the desired 

effect on the generation and management of hazardous 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 facility inspections, and 

carrying out regulatory enforcement. States use the information for many of the same purposes 

as EPA; other State uses include planning, setting 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, businesses, 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 submitted 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 information to identify the universe of regulated waste generators, 

handlers, and managers and their specific regulated waste activities. Finally, EPA uses this 

information to ensure that regulated waste is managed properly, that statutory provisions are 

upheld, and that regulations are adhered to by facility owners or operators. 

(3) Part A Hazardous Waste Permit Application and Modification 

EPA uses information in the Part A Permit Application 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 facilities with newly regulated units. This includes 

defining allowable changes in facility operations and applies to new facilities not yet 

constructed; newly regulated facilities subject to RCRA permitting requirements for the first 

time; permitted facilities with newly regulated units; 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 waste for storage, treatment, or disposal; 

 Respond to public and Congressional inquiries regarding particular 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 demonstrations 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 addition, modifying the Part A Permit Application 

allows inspectors to have up-to-date information on major aspects of the facility, including the 

size of the operation, the hazardous wastes handled, and the types of processes used. Without 

this documentation, EPA would be unable to determine the owner or operator'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 useful for both EPA and the owner or operator in an 

enforcement action. 
9

3. NONDUPLICATION, CONSULTATIONS, 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 Conservation and Recovery (ORCR) is the only office 

within the Agency requiring the recordkeeping or reporting of this information. No other 

Federal agency or department collects this information. 

The RCRA site identification information is collected on one common form―the Site ID 

Form―for the Hazardous Waste Report, the Notification of Regulated Waste Activity, and the 

RCRA Hazardous Waste Part A Permit Application. 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, Notification of Regulated Waste 

Activity, and Part A Hazardous Waste Permit Application and Modification” (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 the Paperwork Reduction Act. The notice also 

requested comments on the information collection and 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 this ICR are based on EPA consultations with 

industry and States, or data from the Resource Conservation and Recovery Act Information 

(RCRAInfo) system2

. In developing this current ICR, EPA carefully reviewed all of the ICR’s 

data and assumptions and determined that a few should be strengthened based on additional 

consultations. Specifically, EPA conducted consultations on the ICR’s assumptions regarding 

respondents’ hourly burden for completing and submitting Hazardous Waste Reports, 

Notifications of Regulated Waste Activity, and Part A Permit Applications. 

Table 1 identifies the organizations 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 (513ሻ	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 (740ሻ	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) 373-0210 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 feedback obtained on the burden associated 

with various information collection activities. 

(1) Hazardous Waste Report 

(a) Industry 

 Prepare Site ID Form of the Hazardous Waste Report using blank form. EPA was 

informed by the majority of consultants that the ICR’s original burden 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 hours. 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 Hazardous Waste Report using pre-populated form. EPA 

was informed by the majority of consultants that 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 estimate. However, some consultants provided a 

longer duration for the burden estimate, which ranged from 1 to 2.5 hours. Based on the 

consultation information, EPA re-estimated the burden for preparing the Site ID Form of 

the Hazardous Waste Report using a pre-populated 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 original burden for distributing and collecting 

the Hazardous Waste Report forms and instructions (i.e., 46 minutes per 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 two State agencies 

disagreed with the burden estimate. Suggested 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 Waste 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 indicated that the ICR’s original burden estimate 

was a realistic national average, while the other two State agencies disagreed with the 

burden estimate. Suggested burden estimates ranged from one minute to 1.08 hours. 

Based on the State information, EPA re-estimated 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 burden for key entering 

report submissions that were not submitted electronically (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 assurance (i.e., 20 minutes 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 notification 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 submitting 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 industry average. However, some consultants provided longer 

durations. Suggested burden estimates ranged 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 notification using a previously submitted Site ID 

Form. EPA was informed by some consultants 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 realistic industry average. However, some 

consultants provided longer duration times. Suggested burden estimates ranged from 40 

minutes to 1 hour. Based on the consultation information, EPA re-estimated the burden 

for completing and submitting an initial notification using a blank Site ID Form to be 

0.45 hour per facility. 

(b) State Agencies 

 Review initial notification submitted 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 consultation information, the average burden for 

reviewing an initial notification submitted using 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 entering initial notification information into 

RCRAInfo (i.e., 2 hours and 15 minutes per 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 two State agencies disagreed with the burden 

estimate. Suggested burden estimates ranged from 15 minutes to 1.25 hours. Based on 

the consultation information, EPA re-estimated the burden for entering 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 information, EPA re-estimated the burden for 

generating an EPA Identification Number and 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 consultation information, the average burden for 

reviewing a subsequent notification submitted 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 for entering subsequent notification information 

into RCRAInfo (i.e., 2 hours and 15 minutes per 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 two State agencies disagreed with the burden 

estimate. Suggested burden estimates ranged from 10 minutes to 1.25 hours. Based on 

the consultation information, EPA re-estimated 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 burden estimate, ranging from 10 hours to 15 hours. Based on 

the consultation information, EPA re-estimated the burden for reading 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 original burden for preparing the Hazardous Waste 

Permit Information Form (i.e., 12 hours and 30 minutes per facility) was a realistic 

industry average. However, one consultant provided 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 signatures and certifications for Part A Permit 

Application, reports, and other information 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 signatures and certifications for Part A 

Permit Application, reports, and other information 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 original 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 authorizations 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 for submitting a Part A Permit Application and 

reports (i.e., 3 hours per facility) was a realistic 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 realistic industry average. However, 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 Application to be 5.37 hours 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 reviewing a Part A Permit Application (i.e., 3 hours 

and 15 minutes per facility) was a realistic national 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 agencies contacted that the ICR’s original 

burden for ensuring that a Part A Permit Application and reports have been signed by the 

appropriate person (i.e., 15 minutes per facility) was a realistic national average. Based 

on the consultation information, the average burden for ensuring that a Part A Permit 

Application and reports have been signed 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 national average. However, one 

consultant provided a revision to this burden estimate. The suggested burden estimate 

was 30 minutes. Based on the consultation information, 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 signature certifications (i.e., 15 minutes per 

facility) was a realistic national average. Based on the consultation information, the 

average burden for reviewing signature certifications remained at 0.25 hour per facility. 

 Enter Part A Permit Application 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 realistic national average. Based on the 

consultation information, the average burden 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 per 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 two State agencies disagreed with the burden 

estimate. The suggested burden estimate was1 hour. Based on the consultation 

information, EPA re-estimated the burden for notifying 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 regarding 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 Report 
16

For the Hazardous Waste Report, the two-year 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, transporters, 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, transporting, offering for transport, or disposing of hazardous 

waste. Existing hazardous waste generators, transporters, or TSDFs are required to notify the 

Agency of their hazardous waste activity(ies) not later than 90 days after the promulgation or 

revision of regulations in 40 CFR Part 261 (identification and listing of hazardous wastes). 

Owners or operators of smelting, melting, and refining furnaces that process hazardous waste 

either solely for metals recovery or for recovery of economically significant 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 burner exemption under section 266.108(d) must 

provide a written, one-time notification of their hazardous waste activities. 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 kilogram 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 management activities and obtain an EPA Identification Number. Any 

reduction in the frequency of this information collection would prevent the Agency from meeting 

the statutory requirements 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 revisions to the Part A Permit Application are 

necessary only if an interim status facility changes its ownership 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 health and the environment. 

3(e) GENERAL GUIDELINES 

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

OMB’s implementing regulations, applicable OMB guidance, and EPA’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 management. Some businesses consider some of their 

hazardous waste information to be Confidential Business Information (CBI). A business may, if 

it desires, protect its Hazardous Waste Report information from public disclosure by asserting a 

claim of confidentiality covering all or part of its information. 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. 

(2) Notification of Regulated Waste Activity 

The Agency does not anticipate that businesses 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 information requested, only a few Part A Permit 

Applications to date have qualified for exemption to disclosure under the business confidentiality 

exception. Claims of confidentiality must be clearly 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 the information described at 40 CFR 2.204(e)). 

Information that is determined to be confidential 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 included 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 affected 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 Management (Form GM), Waste Received from 

Off-Site (Form WR), and Off-Site Identification (Form OI; used only by States). Only LQGs 

and TSDFs are required to complete the Hazardous Waste Report. 

As with most of the RCRA program, the Hazardous Waste Report data collection process 

is delegated to the States. States provide respondents with either the Federal form or a State 

equivalent, collect the responses, contact non-respondents, enter the data (or load files if the 
19

State employs electronic methods for preparation and submittal of reports by regulated entities) 

into RCRAInfo using off-the-shelf software packages 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 received. Most States generate mailing lists based 

on previous report submittals, augmented by recent notifications of regulated activity. Many 

States levy fees based on the nature and extent of regulated activity 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 the 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 required to file the Hazardous Waste 

Report. This form collects information such as site name, EPA 

Identification Number, address, contact, and type of hazardous waste 

generation and management activities taking place at the site; it verifies 

their information, especially the site’s generator status as the date of 

submission of the report. It requires 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 description of the waste, a brief waste 

characterization (e.g., waste codes), the 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 perform 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 Form OI if required by the State (Stateoptional form, not a Federal form). 

 Submit the report to the State (or EPA 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 regulation under section 261.2(a)(2)(ii) or section 

261.4(a)(23), (24), or (25) must send a notification prior to operating under the exclusion(s) and 

by March 1 of each even numbered year thereafter 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, reclaimer or intermediate facility has submitted a notification, but 

then subsequently stops managing hazardous secondary materials in accordance with the 
21

exclusion(s), the facility must notify the Regional Administrator within thirty (30) days using 

EPA Form 8700-12. For purposes of this section, a facility has stopped managing hazardous 

secondary materials if the facility no longer generates, manages and/or reclaims hazardous 

secondary materials under the exclusion(s) and does not expect 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 with 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 begin managing the hazardous secondary 

materials in accordance with the exclusion; 

- A list of hazardous secondary materials that will be managed 

according to the exclusion (reported as the EPA hazardous waste 

numbers that would apply if the hazardous secondary materials were 

managed as hazardous wastes); 

- For each hazardous secondary material, whether the hazardous 

secondary material, or any portion thereof, will be managed in a landbased unit; 

- The quantity of each hazardous secondary material to be managed 

annually; and 

- The certification (included in EPA 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 8700-12 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 Waste 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 their hazardous waste activities 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 with 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 initial notification or a subsequent 

notification; 

- A description of the hazardous wastes handled at the facility; and 

- A certification signed by the facility owner, operator, 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 Subpart K and Recordkeeping of Agreements 

40 CFR 262.203(a) provides that an eligible academic 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 subject 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 and 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 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. 

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 laboratories are subject to Subpart K. 

Section 262.203(d) provides that a teaching hospital 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 teaching hospital while its laboratories are subject to Subpart K. 

 Section 262.203(e) provides that a non-profit research institute 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 Classification 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 affiliation agreement with a college or 

university, as specified under section 262.203(d). 

 A copy of the formal written affiliation 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 laboratories are subject to Subpart K. 

 Non-profit research institutes that are 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-profit 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 academic 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 academic entity under the same EPA Identification 
25

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 requirements of Subpart K 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 withdrawing from 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 fields 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 Classification 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 universal waste must notify EPA of their universal waste 

activities and obtain an EPA Identification Number. These notification requirements are 

codified at 40 CFR Part 273, Subpart C. In order 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 complete 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 initial notification or a subsequent 

notification; 

- A description of the hazardous wastes handled at the facility; and 

- A certification signed by the facility owner, operator, 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 types 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, pesticides, 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 their used oil activities and obtain an EPA 

Identification Number. These notification requirements are codified 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 initial notification or a subsequent 

notification; 

 A description of the hazardous wastes handled at the facility; and 
28

 A certification signed by the facility owner, operator, 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 contact at each transfer facility, if 

applicable (for used oil transporters 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 facilities 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 conducted by the applicant that require the owner or 

operator to obtain a RCRA permit. 

 Name, mailing address, and location, including latitude and longitude of 

the facility for which the application is submitted. 

 Up to four NAICS codes that best reflect the principal products or services 

provided by the facility. 

 Operator's name, address, telephone number, ownership status, and status 

as Federal, State, private, 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, storage, and disposal areas and 

 Photographs of the facility clearly 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 the design capacity of these items. 

 A specification of the hazardous wastes listed or designated under 40 CFR 

Part 261 to be treated, stored, or disposed of at the facility; an estimate of 

the quantity of such wastes to be treated, 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 Elimination System (NPDES) program 

under the Clean Water Act (CWA) 

 Prevention of Significant Deterioration (PSD) program under the 

Clean Air Act (CAA) 

 Nonattainment program under the CAA 

 National Emission Standards for Hazardous Air Pollutants 

(NESHAPS) preconstruction approval under the CAA 

 Ocean dumping permits under the Marine Protection Research and 

Sanctuaries Act 

 Dredge or fill permits under section 404 of the CWA 

 Other relevant environmental permits, 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 aspects of the facility: 

 Each of its intake and discharge structures; 

 Each of its hazardous waste treatment, storage, or disposal 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 otherwise 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 treated, 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 Applications and Permit Application Reports 

40 CFR 270.11(a) requires operators of facilities to obtain the necessary signatures and 

certifications for the Part A Permit Application, reports, and other information requested by 

EPA. Additionally, operators must obtain new authorization 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 proprietorship, the signature of a general 

partner or proprietor as defined at 40 CFR 270.11(a)(2). 

 For a municipality, State, Federal, or other public agency, the signature 

of either a principal executive officer 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 proprietorship, the signature of a general 

partner or proprietor as defined at 40 CFR 270.11(a)(2). 

 For a municipality, State, Federal, or other public agency, the signature 

of either a principal executive officer or ranking elected official as 

defined at 40 CFR 270.11(a)(3). 

 Signature of a duly authorized representative of one of the persons 

listed above as defined at 40 CFR 270.11(b). 

 New authorization satisfying the requirements 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 and all attachments were 

prepared under my direction or supervision in accordance with a system 

designed to assure that qualified personnel 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 imprisonment 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 information 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 operators 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 Permit Application, if 

required. 

State agencies must perform the following activities: 

 Review information contained 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 must prepare and submit a revised Part A 

Permit Application if the Agency promulgates a rulemaking that affects the facility, or if the 

owner/operator otherwise modifies the facility. Interim 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 using 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 Permit Application in response to an 

Agency rulemaking or facility modification. 

 Prepare and submit justifications 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. However, EPA is involved throughout this process. 

The extent of EPA’s involvement depends on the activities performed by the States in the data 

collection process. The following paragraphs briefly describe EPA’s participation 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 respondents with the Federal form, collect the responses, contact 

non-respondents, enter the data into RCRAInfo using off-the-shelf software packages which 

have been developed to support the collection of Hazardous Waste Report data, assure data 

quality, and forward the data to EPA Headquarters. 

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

of the collection activities. For example, the EPA Region 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 support to States for the transfer of their files to 

EPA for incorporation into RCRAInfo. 

 

EPA Headquarters produces and distributes the Federal forms and related guidance, 

defines the data and file format for data, establishes the schedule for submitting data, manages 

the incorporation of State data into RCRAInfo, 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 Report forms and instructions. EPA Headquarters 

distributes the form and instruction booklets to the States and Regions. Regions 

prepare mailing lists, mail forms and instructions, record receipt of completed 

forms, and contact sites that fail to respond within the specified time period. 
35

 Develop computer capabilities required to compile national data. EPA 

Headquarters develops the computer capabilities required to load data into 

RCRAInfo, the reports which support data quality assessment and other 

programmatic use of the data, and preparation of the national report. 

 Assist respondents. EPA Regions and Headquarters provide assistance to 

respondents. States are, however, the first point of contact for answering 

respondent questions and assistance, 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 regulated community use one of the private 

vendor’s software packages for data entry 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, detection and correction 

of unacceptable responses (e.g., in cases where the respondent misunderstood the 

instructions); verification of exceptional responses (e.g., data reported by a 

respondent that differ significantly from data reported by the rest of the 

respondent universe) and identification of significant response changes between 

reporting years. The national software supports 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 ensure 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 under reporting (exception reports support 

identification of extremes and significant variance from one cycle to another). 

Third, assessment reports support evaluation of intra-State 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 generally contact the site to review the 

information received; and site respondent confirms that the 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 will 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 Number 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 Permit Applications include the following: 

 For Part A Permit Applications: 

 Reviewing information contained in the application. 

 Ensuring that the Part A Permit Application and associated reports are signed 

by the appropriate person. 

 Reviewing newly authorized signatures when a different individual or position 

gains responsibility for the overall 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 Applications, 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 associated with this ICR, EPA and authorized 

States may use a telephone system, personal computers, and applicable RCRAInfo software. 

They will ensure the accuracy and completeness of collected information by reviewing the 

submittals. They will keep records of this information 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 generators (SQGs) and relieves them of specific 

requirements. 

SQGs are not required to file the Hazardous 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 subject to follow-up contact for biennial reporting. 

(2) Notification of Regulated Waste Activity 

Some respondents will be individuals 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 submissions and revisions must apply equally to 

large and small businesses. Although the legal requirements for Part A Permit Application 

information are the same for large and small businesses, the Agency believes that in practice the 

small entities will find it easier to provide the required information. 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 processes for the management of hazardous wastes 

and they manage fewer types of wastes. As a rule 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. Therefore, 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 respondents by providing detailed instructions for 

completion of the Part A Permit Application form and by requiring short answer responses to 

most of the items of the application. 
38

It also should be noted that the reporting requirements for changes are brief. Therefore, 

owners or operators can easily comply with these requirements. In addition, most of the 

revisions to Part A Permit Applications will entail merely checking boxes or filling in numbers 

to indicate the type of new activity or new waste to be handled at the facility. Any written 

justification entails a short letter from the owner or operator. EPA, 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 implementation 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 National 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 National 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 notification 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 claimant 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 Waste Activity under RCRA Section 3010 
39

Under sections 262.12, 263.11, 264.11 and 265.11, all new hazardous waste generators, 

transporters, and TSDFs must notify EPA of their hazardous waste activities and obtain an EPA 

Identification Number before treating, storing, transporting, offering for transport, or disposing 

of hazardous waste. Under section 270.1(b), these hazardous waste generators, transporters, and 

TSDFs, are also subject to newly promulgated or revised regulations at 40 CFR Part 261 

(identification and listing of hazardous wastes) and 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 facilities that are subject 

to notification requirements under sections 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 subject to, under these circumstances, the section 262.12 

notification requirements and procedures. As such, these transporters must, at that time, notify 

EPA of their hazardous waste activities and obtain an EPA Identification Number before 

treating, storing, transporting, offering for transport, or disposing of hazardous waste. Finally, 

owners or operators of smelting, melting, and refining furnaces that process hazardous waste 

either solely for metals recovery or for recovery of economically significant 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 burner exemption under section 266.108(d) must 

provide a written, one-time notification of their hazardous waste activities. 

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

(c1) Intent to Comply with Subpart 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 Identification Form (EPA 

Form 8700-12), that it is electing to be subject 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 and 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 laboratories are subject to Subpart K. 

Section 262.203(d) provides that a teaching hospital 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 teaching hospital while its laboratories are subject to Subpart K. 

 Section 262.203(e) provides that a non-profit research institute that is not owned by a 

college or university must keep a copy of the formal written affiliation agreement with a college 
40

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 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 academic 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 owned by the eligible academic entity that are onsite. An eligible academic entity must submit a separate notification (Site ID Form) for each 

EPA Identification Number (or site, for CESQGs) that is withdrawing 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), large 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 meeting or exceeding the 5,000 kilogram storage 

limit, unless they already have notified EPA, 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 notification requirements (under 40 CFR Part 266, 

Subpart E) must submit a written, one-time notification 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, including signatures and 

certifications at least 180 days before physical construction is expected to commence. For 

existing facilities newly subject to RCRA permitting requirements due to promulgation of a new 

regulation or listing of hazardous waste, the new regulation typically specifies 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 changes at the facility. For the following types of 

changes, the owner or operator must submit revised 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 processes used at the facility. 

 Changing or adding processes for treating, storing, or disposing of hazardous 

wastes. 

 For changes in ownership or operational control 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 operational control of the facility. 
42

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION 

6(a) ESTIMATING RESPONDENT BURDEN HOURS 

Exhibits 1 through 3 provide estimates of the respondent hourly burden associated with 

the information collection requirements covered in this ICR. The exhibits include burden hours 

(total and by labor type) per respondent, as well as the overall burden hours for all respondents. 

The majority of the hour estimates in Exhibits 1 through 3 are based on consultations with 

industry and States. 

 In the following paragraphs, EPA describes the methodologies used to estimate the 

hourly burden associated with the information 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 respondents 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 burden 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 calculations in Table 3 below. EPA multiplied the 

percentage of pre-populated Site ID Forms by the average burden 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 weighted-average burden. 

Table 3 

Assumptions and Weighted-Average Equation Used in Estimating Burden to 

Complete the Site Identification Form 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 blank 
43

(b) Methodology for Accounting for Form GM and Form WR Electronic 

Reporting 

During consultations conducted during the development of previous versions of this ICR, 

State and facility representatives indicated that Forms GM and WR often can be completed from 

RCRAInfos that track manifests 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 less than for forms submitted on paper. 

To estimate the percentage of facilities that 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, based on consultations and best professional 

judgment, facilities submitting five (5) or more Forms GM for the Hazardous Waste Report are 

likely to do so electronically. Using 2011 Hazardous Waste Report data3

, EPA identified sites 

submitting Forms GM, counted their Forms GM submitted, 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 receiving 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 electronically. Using 2011 Hazardous Waste Report data4

, 

EPA reviewed the list of Forms WR reported to the Hazardous Waste Report by facility and, 

based on its own professional judgment and consultations, estimates that 100 percent of Forms 

WR are submitted electronically. 

To estimate the average burden per respondent in preparing a Form 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 for 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, respectively, to calculate an overall weighted-average 

burden for both forms. 

 3

 2011 Hazardous Waste Report (i.e., 2011 Biennial Report) data used in this analysis are current as of July 

10-14, 2014. 

4

 Ibid. 
44

Table 4 

Assumptions and Weighted-Average Equations 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 that all of the facilities electing to operate 

under the hazardous secondary material exclusion 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 complete 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 their 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 addition 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 average 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 calculations 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 these 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 Secondary 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 withdrawing 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 blank Site ID Form under Subpart K 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. 
46

The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA 

derived the weighted averages using the calculations 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 these 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 that 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 calculations 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 these two products to derive an overall weightedaverage burden. 
47

Table 7 

Assumptions and Weighted-Average Equation Used in 

Estimating Burden to Complete Other 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 facilities 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 estimates that 50 percent will complete a blank Site 

ID Form and the remaining 50 percent will use their most recently submitted 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 calculations 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 these 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 facilities 
48

6(b) ESTIMATING RESPONDENT COSTS 

Exhibits 1 through 3 provide estimates of the annual respondent 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 Section 6(a) and the hourly labor costs outlined 

in this section, Exhibits 1 through 3 illustrate the labor costs associated 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 technical staff, and $34.39 for 

clerical staff. These respondent labor costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.16, dated September 19, 2012), and updated to 2014 levels using 

Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.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 technical staff, and $21.70 for 

clerical staff. These respondent labor costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.16, dated September 19, 2012), and updated to 2014 levels using 

Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.6

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. EPA does not anticipate that 

respondents will incur capital costs in carrying out the information collection requirements 

covered in this ICR. 

 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, 2014. 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 will incur a cost of $6.51 to mail an 11-ounce 

large envelope by certified mail ($3.08 for 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 certified mail (i.e., $0.49 for first-class letter 

postage, $3.30for the certified-mail fee, and $0.03 for standard business 

envelope).10, 11, 12

 EPA estimates that State agencies distributing 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 applicable respondent 

activities. 

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN 

EPA estimates the Agency hour and cost burden associated with the information 

collection requirements covered in this ICR in Exhibits 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 estimates, 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 Services for Business.” Available online at: 

https://www.usps.com/business/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 Services for Business.” Available online at: 

https://www.usps.com/business/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 Federal Government. EPA then applied the standard 

government overhead factor of 1.6 to the unloaded 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 Waste 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. These O&M costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.16, dated September 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 all 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 collection requirements 

covered in this ICR. 

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

 Hazardous waste facilities complying with the Hazardous Waste Report, 

notification, and Part A Permit Application requirements covered in this ICR. 

This includes: 

 Private sector entities; and 

 State and local government agencies that are regulated entities17. 

 State agencies administering the RCRA hazardous waste program18. 

 15 U.S. Office of Personnel Management, “2014 General Schedule (Base),” Hourly Rate. Available online 

at: http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-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/cpid1405.pdf, last accessed on 

July 14, 2014. All items, July 2012=229.104 and May 2014=237.900. 

17 Addressing State and local government 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 data19, EPA estimates that the total number of 

respondents to the 2015 Hazardous Waste Report will be 20,536, which annualized over the twoyear report cycle equals 10,268 per 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 these 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 Management 239,327 17,271 256,598 

Form WR - Waste Received from Offsite 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 Hazardous 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 also estimates the annual respondent burden and 

cost for the activities examined. 

(b) Notification of Regulated Waste Activity 

In estimating the number of respondents subject to the notification requirements covered 

in this ICR, EPA referred to RCRAInfo. EPA estimated the annual number 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 activity shown in Exhibit 2 of this ICR. 

 19 2011 Hazardous Waste Report (i.e., 2011 Biennial Report) data used in this analysis are current as of 

July 10-14, 2014. At the time this ICR was developed, 2013 Hazardous Waste Report data were not available. 
52

(c) Part A Hazardous Waste Permit Application and Modification 

In estimating the number of respondents subject to the Part A Permit Application 

requirements covered in this ICR, EPA referred 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 burden and costs per information collection activity 

shown in Exhibit 3 of this ICR. 
Table 10 

Annual Number of Respondents Subject to the Notification Requirements Covered in this 

Respondent Universe 

Year 2012 Year 2013 A

Private 

Sector b

State and 

Local 

Government c

Total Private Sector b State and Local Government c Total Pri

Sec

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42 Number of facilities submitting notification prior to operating under exclusion 20 0 20 16 0 16 1Number of small quantity generators (SQGs) and conditionally-exempt small quantity generators (CESQGs) submitting notification by March 1 of each even numbered year thereafter 

14 0 14 4 0 4 

Number of facilities submitting notification indicating that they will no longer manage hazardous secondary materials in accordance with the exclusion 

21 0 21 9 0 9 1

Notification of Hazardous Waste Activity under RCRA Section 3010 Number of facilities submitting initial notification 10,303 928 11,231 8,010 1,191 9,201 9,Number of facilities submitting subsequent notification 34,086 2,043 36,129 34,025 1,877 35,902 34,Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KNumber of eligible academic entities submitting notification of intent to comply with Subpart K and recordkeeping of agreements 

2 4 6 5 16 21 

Number of teaching hospitals not owned by a college or university opting into Subpart K 0 1 1 0 1 1 Number of non-profit research institutes not owned by a college or university opting into Subpart K 

1 0 1 1 0 1 

Number of eligible academic entities submitting notification of withdrawal from 40 CFR Part 262, Subpart K 

691 14 705 137 0 137 4
Table 10 (continued) 

Annual Number of Respondents Subject to the Notification Requirements Covered in this 

Respondent Universe 

Year 2012 Year 2013 A

Private 

Sector b

State and 

Local 

Government c

Total Private Sector b State and Local Government c Total Pri

Sec

Notification of Universal Waste Activity under 40 CFR Part 273, Subpart CNumber of facilities submitting initial notification 79 13 92 61 13 74 7Number of facilities submitting subsequent notification 80 11 91 97 12 109 8Notification of Used Oil Activity under 40 CFR Part 279Number of facilities submitting initial notification 92 2 94 63 5 68 7Number of facilities submitting subsequent notification 227 4 231 157 8 165 1

a Based on data from the following RCRAInfo tables: (1) “Hhandler,” (2) “Howner_operator,” (3) “Huniversal_waste,” and (4) “Hhsm_basic.” All tables co

10,2014. 

b Includes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facility cannot be owned or operated by a F

government. For example, a facility owned by a State government and operated by a private entity would qualify as a “State and local government” facility, n

c Includes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in order to qualify as “State and local gov

be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Municipal government would government” facility, not a “State and local government” facility. 
Table 11 

Annual Number of Respondents Subject to the Part A Permit Application Requirements Covered 

Respondent 

Universe 

Year 2012 Year 2013 Average of 

Private 

Sector b

State and 

Local 

Government c

Total Private Sector b State and Local Government c Total Private Sector b 

G

Number of facilities submitting initial Part A Permit Application 2 0 2 5 0 5 4 Number of facilities submitting Part A Permit Modification 23 2 25 23 1 24 23 

a Based on data from the following RCRAInfo tables: (1) “Hhandler” and (2) “Howner_operator.” Both tables contain data current as of July 10b Includes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facility cannot be owned or op

or local government. For example, a facility owned by a State government and operated by a private entity would qualify as a “State and local goa “private” facility.

c Includes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in order to qualify as “State a

facility cannot be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Mu

qualify as a “Federal government” facility, not a “State and local government” facility. 
56

(2) Annual Respondent Burden 

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

(a1) Read the Hazardous Waste Report Instructions 

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

instructions. Annualized over the two-year report cycle, this results in 10,268 respondents 

reading the instructions each year (i.e., 9,201 private sector facilities and 1,067 State and local 

government facilities). 

(a2) Revise In-House or Commercial Data System 

EPA estimates that all 9,135 electronic reporters will revise their in-house or commercial 

data system to include new Hazardous Waste Report data items that are not part of the facility’s 

general business operations. Annualized over the two-year report cycle, this results in 4,568 

respondents revising their in-house or commercial data systems each year (i.e., 4,349 private 

sector facilities and 219 State and local government facilities). 

(a3) Gather Information and Complete 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 the 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 submit 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 private sector facilities and 8,636 forms from 

State and local government facilities). 

(a5) Gather Information and Complete Form WR 

EPA estimates that respondents will submit 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 private sector facilities and 3,538 forms from 

State and local government facilities). 

Note that the number of Forms WR represents the number of blocks on Form WR that 

have been completed; the paper form actually contains three blocks of the 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, EPA does not expect any facilities to submit 

Form OI and therefore does not calculate 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 Waste 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 assistance to all 20,303 respondents. Annualized 

over the two-year report cycle, this results 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 the two-year report cycle, this results in 11,191 respondents each 

year. 

 

(b4) Perform Quality Assurance 

EPA expects State agencies to perform data 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 respondents each year. 
58

(c) Notification of Regulated Waste Activity - Facilities (Exhibits 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 facilities and 0 State and 

local government facility) will notify under 40 CFR 260.42 prior to operating under the 

exclusion and be required to complete the information laid out at section 260.42(a). 

In addition, entities must re-notify using the Site ID Form by March 1 of each even 

numbered year thereafter. Note that the Hazardous Waste Report regulations already require the 

submittal of the Site ID Form by March 1 of each 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 will re-notify because they stopped operating 

under the exclusion (i.e., 15 private sector facilities and 0 State and local government facilities). 

(c2) Notification of Hazardous Waste Activity under RCRA Section 3010 

EPA estimates that, each year, 10,217 facilities (i.e., 9,157 private sector facilities and 

1,060 State and local government facilities) will submit an initial notification of hazardous waste 

activity under RCRA Section 3010. EPA also estimates that, each year, 36,016 facilities 

(i.e., 34,056 private sector facilities and 1,960 State and local government facilities) will submit 

a subsequent notification associated with these requirements. 

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

Intent to Comply with Subpart K and Recordkeeping of Agreements 

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

authorized State that it is electing to be subject to Subpart K for all laboratories owned by the 

eligible academic 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 

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 must 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 site will retain the agreement on file (i.e., 0 

agreements from private sector entities and 1 agreement from State 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 submit 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 Waste Activity under 40 CFR 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 notification of universal waste activity 

under 40 CFR Part 273, Subpart C. Of these facilities, 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, 101facilities (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 percent (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 notification of used oil activity under 

40 CFR Part 279. Of these facilities, 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 prepare and submit a letter requesting an EPA 

Identification Number. 

EPA also estimates that, each year, 198 facilities (i.e., 192 private sector 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 percent (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 Activity – State Agencies (Exhibit 2C) 

 State agencies will conduct the information collection activities associated with the 

Notification of Regulated Waste Activity in Authorized States. 
60

(d1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42 

EPA estimates that, each year, State agencies 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 stopped operating under the exclusion. 

(d2) Notification of Hazardous Waste Activity under RCRA Section 3010 

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

information into RCRAInfo for 10,217 facilities that will submit an initial 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 Activity under 40 CFR Part 262, Subpart K 

Intent to Comply with Subpart K and Recordkeeping of Agreements 

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

information into RCRAInfo for 421 eligible academic entities that withdraw from the 40 CFR 

Part 262, Subpart K requirements. 

(d4) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C 

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

information into RCRAInfo for 83 facilities. Of these 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 agencies will review and enter subsequent 

notification information into RCRAInfo for 101facilities. 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 enter initial notification 

information into RCRAInfo for 82 facilities. Of these 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 agencies will review and enter subsequent 

notification information for 198 facilities. Of these facilities, 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 Application and Modification - Facilities 

(Exhibits 3A and 3B) 

(e1) Part A Permit Application 

EPA estimates that, each year, 4 facilities (i.e., 4 private sector facilities and 0 State and 

local government facility) will submit a new Part A Permit Application. All facilities will need 

to obtain signatures for the Part A Permit Application, Part A Permit Application reports, and 

other information requested by the Director. In addition, all facilities will need to obtain 

certifications from persons signing permit documentation. 

EPA also estimates that, each year, 10 percent of the facilities submitting Part A Permit 

Applications will have authorizations that are no longer accurate because a different individual 

or position has responsibility for the overall operation 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, and 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 submit 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 applications, review the signatories to the permit 

applications and reports, and enter the Part A Permit Application information into RCRAInfo. 

EPA also estimates that, each year, 10 percent of the Part A Permit Applications will 
62

have authorizations that are no longer accurate because a different individual or position has 

responsibility for the overall operation 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 agencies will receive 25 revised Part A Permit 

Applications. State agencies will need to review 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 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, onethird of the revised Part A Permit Applications (8applications) will be accompanied by a Subpart 

H compliance demonstration due to changes in ownership or operational control of a facility. 

State agencies will need to review all justifications and Subpart H compliance demonstrations.

 6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibit 7 summarizes the total annual respondent hour and cost burden associated with 

all the requirements covered in this ICR. As shown in the exhibit, 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 change 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 estimate 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 represents 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 projected number of forms for the 2013 and the 2015 

Hazardous Waste Reports. 

 Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the Hazardous Waste Report requirements. Based on consultations with 

industry, EPA increased some of the hourly burden estimates associated with the Hazardous 

Waste Report. EPA believes that the revised burden 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 2013 a

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 Management 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 forms for the 2013 and the 2015 Hazardous Waste 

Reports. 

 Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the Hazardous Waste Report requirements. Based on consultations with States, 

EPA increased some of the hourly burden estimates associated with the Hazardous Waste 

Report. EPA believes that the revised burden estimates 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 represents 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 covered in the ICR. As shown in Table 13, the total 

number of notifications increased from 46,035 in the previously approved ICR (EPA ICR 

Number 0976.16) to 47,176 in this ICR (EPA ICR Number 0976.17). 

 Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the notification requirements. Based on consultations with industry, EPA 

increased some of the hourly burden estimates associated with notifications. 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 annual burden estimate for the previously 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 represents 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 activities were allocated to EPA. However, 

Authorized States implement notification requirements. 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 represents 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 previously approved ICR to 25 in this ICR. 
66

 Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the Part A Permit Application requirements. Based on consultations with 

industry, EPA increased some of the hourly burden 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 annual burden estimate for the previously 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 represents 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 previously approved ICR to 25 in this ICR. 

 Second, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the Part A Permit Application requirements. Based on consultations with States, 

EPA increased some of the hourly burden estimates associated with Part A Permit Applications. 

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

average. 

6(g) PUBLIC BURDEN STATEMENT 

(1) Hazardous Waste Report 

 The reporting burden is estimated to be about 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 Report 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 hazardous 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 material notification 

requirements (initial and subsequent) is estimated to be 1.7 hours for State agencies to review 

and enter notification information into RCRAInfo. There are no reporting requirements 

associated with this requirement, and as such, there is no reporting burden. 

(b) Notification of Hazardous Waste Activity under RCRA Section 3010 

The reporting burden associated with RCRA 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 requirements 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 such, there is no reporting burden. 

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

The reporting burden associated with notification requirements under 40 CFR Part 262, 

Subpart K is estimated to be about 38 minutes for a facility to prepare and submit a Site ID Form 

to opt into or withdraw from Subpart K. The recordkeeping burden is estimated to be about 

5 minutes to keep copies of notification and affiliation agreements on-site. 

The recordkeeping burden associated with 40 CFR Part 262, Subpart K notification 

requirements (initial and subsequent) is estimated to be about 1.7 hours for State agencies to 

review and enter notification information into RCRAInfo. There 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 estimated to be about 45 minutes for a facility to 

complete the Site ID Form or prepare a letter requesting an EPA Identification Number, and 

submit the completed Site ID Form or letter. 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 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 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 requirements (initial 

and subsequent) is estimated to be about 42 minutes for a facility to complete the Site ID Form 
68

or prepare a letter requesting an EPA Identification Number, and submit the completed Site ID 

Form or letter. 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 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 such, 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 Part 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 Part 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 recordkeeping burden is estimated to be about 5 hours to review 

an application and signatories to the permit applications and reports, 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 submit a revised Part A Permit Application, prepare 

and submit justifications for changes, and prepare and submit Subpart H compliance 

demonstrations. The recordkeeping burden is estimated 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 review a Part A Permit Application, justification, 

and Subpart H compliance demonstration, and enter the Part A Permit Application information 

into RCRAInfo. There are no reporting requirements 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 disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 
69

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

To comment on EPA 's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number 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 number 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 contents of the public docket, and to access those 

documents in the public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA-HQ-RCRA–2014–0296 and OMB Control Number 2050-0024 in any 

correspondence.
EXHIBIT 1A2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total Ho

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Read the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $178.90 $0.00 $0.00 9,201 Revise in-house or commercial data system to include new Hazardous Waste Report data items that are not part of the facility’s general business operations

0.00 0.33 0.67 0.00 1.00 $63.62 $0.00 $0.00 4,349 

Gather information and prepare Site ID Form 0.00 0.08 0.60 0.16 0.84 $45.94 $0.00 $0.00 9,201 Gather information and prepare Form GM 0.00 0.13 0.15 0.04 0.32 $19.92 $0.00 $0.00 119,664 Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $7.77 $0.00 $0.00 631,260 Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 Submit 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 Maintain 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 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Hazardous Waste Report
EXHIBIT 1B2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total 

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Read the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $118.56 $0.00 $0.00 1,067 Revise in-house or commercial data system to include new Hazardous Waste Report data items that are not part of the facility’s general business operations

0.00 0.33 0.67 0.00 1.00 $41.56 $0.00 $0.00 219 

Gather information and prepare Site ID Form 0.00 0.08 0.60 0.16 0.84 $28.43 $0.00 $0.00 1,067 Gather information and prepare Form GM 0.00 0.13 0.15 0.04 0.32 $13.36 $0.00 $0.00 8,636 Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $5.43 $0.00 $0.00 3,538 Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 Submit 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 Maintain 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 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Hazardous Waste Report
EXHIBIT 1C2015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total 

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Distribute Hazardous Waste Report forms and instructions 0.00 0.02 0.25 0.50 0.77 $20.49 $0.00 $3.21 10,152 Assist respondents 0.00 0.02 0.38 0.38 0.78 $22.31 $0.00 $0.00 10,152 Key entry of report submissions 0.00 0.02 0.07 0.22 0.31 $8.29 $0.00 $0.00 11,191 Perform quality assurance 0.00 0.02 0.17 0.18 0.37 $10.60 $0.00 $0.00 771,988 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Hazardous Waste Report
EXHIBIT 2ANOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total H

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Complete and submit EPA Form 8700-12 prior to operating under exclusion(s) 0.00 0.10 0.94 0.10 1.14 $64.84 $0.00 $3.82 18 Complete and submit EPA Form 8700-12 by March 1 of each even numbered year thereafter 0.00 0.10 0.94 0.10 1.14 $64.84 $0.00 $3.82 9 Complete and submit EPA Form 8700-12 indicating that the hazardous secondary materials are no longer managed in accordance w ith the exclusion

0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 15 

Subtotal varies varies varies varies varies varies varies varies varies 

Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 9,157 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 34,056 

Subtotal varies varies varies varies varies varies varies varies varies 

Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 4 Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 4 Keep a copy of their formal w ritten affiliation agreement w ith college or university on file w hile its laboratories are subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 0 

Keep a copy of the formal w ritten affiliation agreement w ith a college or university on file at the non-profit research institute w hile its laboratories are subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $2.75 $0.00 $0.00 1 

Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 414 Keep 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 

Subtotal varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Notification 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 KTeaching 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 Notification
EXHIBIT 2A (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total H

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 53 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 18 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 67 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 22 

Subtotal varies varies varies varies varies varies varies varies varies 

Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $62.05 $0.00 $3.82 59 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 20 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $36.26 $0.00 $3.82 144 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $28.32 $0.00 $3.82 48 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit 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 8700-12Letter
EXHIBIT 2BNOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total 

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Complete and submit EPA Form 8700-12 prior to operating under exclusion(s) 0.00 0.10 0.94 0.10 1.14 $39.83 $0.00 $3.82 0 Complete and submit EPA Form 8700-12 by March 1 of each even numbered year thereafter 0.00 0.10 0.94 0.10 1.14 $39.83 $0.00 $3.82 0 Complete and submit EPA Form 8700-12 indicating that the hazardous secondary materials are no longer managed in accordance w ith the exclusion

0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 0 

Subtotal varies varies varies varies varies varies varies varies varies 

Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 1,060 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 1,960 

Subtotal varies varies varies varies varies varies varies varies varies 

Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 10 Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 10 Keep a copy of their formal w ritten affiliation agreement w ith college or university on file w hile its laboratories are subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 1 

Keep a copy of the formal w ritten affiliation agreement w ith a college or university on file at the non-profit research institute w hile its laboratories are subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $1.74 $0.00 $0.00 0 

Prepare and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 7 Keep 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 

Subtotal varies varies varies varies varies varies varies varies varies 

a Exhibit 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 260.42
EXHIBIT 2B (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total 

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 9 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 3 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 9 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 3 

Subtotal varies varies varies varies varies varies varies varies varies 

Complete and submit EPA Form 8700-12 0.00 0.08 0.93 0.08 1.09 $37.92 $0.00 $3.82 2 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 1 Complete and submit EPA Form 8700-12 0.00 0.10 0.44 0.10 0.64 $22.82 $0.00 $3.82 4 Prepare and submit letter requesting an EPA Identification Number 0.00 0.08 0.34 0.08 0.50 $17.85 $0.00 $3.82 2 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

LetterEPA Form 8700-12EPA Form 8700-12Initial NotificationLetterSubsequent NotificationLetterEPA Form 8700-12LetterSubsequent NotificationNotification of Used Oil Activity under 40 CFR Part 279Initial NotificationEPA Form 8700-12Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C
EXHIBIT 2CNOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total H

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 16 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 16 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 8 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 8 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 13 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 13 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 10,217 Enter 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 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $9.36 $0.00 $0.52 10,217 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 36,016 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 36,016 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 14 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 14 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 421 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 421 

Subtotal varies varies varies varies varies varies varies varies varies 

a Exhibit 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 exclusion
EXHIBIT 2C (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total Hou

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number T

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ H

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. YReview completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 62 Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 62 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $9.36 $0.00 $0.52 62 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 21 Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 21 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $9.36 $0.00 $0.52 21 Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 76 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 76 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 25 Enter letter information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 25 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 61 Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 61 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $9.36 $0.00 $0.52 61 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 21 Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $48.94 $0.00 $0.00 21 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $9.36 $0.00 $0.52 21 Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 148 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 148 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 50 Enter letter information into database 0.00 0.00 1.32 0.17 1.49 $48.60 $0.00 $0.00 50 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 8

a Exhibit includes rounding.

EPA Form 8700-12Initial NotificationInitial NotificationNotification of Universal Waste Activity under 40 CFR Part 273, Subpart CEPA Form 8700-12LetterSubsequent NotificationEPA Form 8700-12Subsequent NotificationEPA Form 8700-12LetterLetterLetterNotification of Used Oil Activity under 40 CFR Part 279
EXHIBIT 3APART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total 

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $129.82/ $76.73/ $57.16/ $34.39/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Read the regulations and instructions 2.38 1.18 3.57 0.00 7.13 $603.57 $0.00 $0.00 4 Prepare the Site Identification Form 0.00 0.08 0.69 0.17 0.94 $51.43 $0.00 $0.00 4 Prepare the Hazardous Waste Permit Information Form and reports 1.67 3.28 8.83 1.67 15.45 $1,030.63 $0.00 $0.00 4 Obtain signatures and certifications for Part A permit applications, reports, and other information requested by EPA

0.00 0.50 1.00 1.00 2.50 $129.92 $0.00 $0.00 4 

Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $112.72 $0.00 $0.00 1 Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $147.11 $0.00 $6.51 4 Explain or cure an alleged deficiency in Part A application, if required 0.00 0.77 3.07 1.53 5.37 $287.18 $0.00 $0.00 1 

Subtotal varies varies varies varies varies varies varies varies varies 

Read the regulations and instructions (for Agency rulemaking) 0.00 1.00 2.00 0.00 3.00 $191.05 $0.00 $0.00 8 Read the regulations and instructions (for facility modification) 0.00 1.00 2.00 0.00 3.00 $191.05 $0.00 $0.00 15 Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $498.94 $0.00 $6.51 8 Prepare 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 Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $355.26 $0.00 $6.51 8 Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $355.26 $0.00 $6.51 8 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit 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 Application
EXHIBIT 3BPART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total 

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Read the regulations and instructions 2.38 1.18 3.57 0.00 7.13 $332.70 $0.00 $0.00 0 Prepare the Site Identification Form 0.00 0.08 0.69 0.17 0.94 $31.71 $0.00 $0.00 0 Prepare the Hazardous Waste Permit Information Form and reports 1.67 3.28 8.83 1.67 15.45 $624.29 $0.00 $0.00 0 Obtain signatures and certifications for Part A permit applications, reports, and other information requested by EPA

0.00 0.50 1.00 1.00 2.50 $84.15 $0.00 $0.00 0 

Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $73.30 $0.00 $0.00 0 Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $95.00 $0.00 $6.51 0 Explain or cure an alleged deficiency in Part A application, if required 0.00 0.77 3.07 1.53 5.37 $181.42 $0.00 $0.00 0 

Subtotal varies varies varies varies varies varies varies varies varies 

Read the regulations and instructions (for Agency rulemaking) 0.00 1.00 2.00 0.00 3.00 $124.90 $0.00 $0.00 0 Read the regulations and instructions (for facility modification) 0.00 1.00 2.00 0.00 3.00 $124.90 $0.00 $0.00 2 Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $285.65 $0.00 $6.51 0 Prepare 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 Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $207.17 $0.00 $6.51 0 Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $207.17 $0.00 $6.51 0 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit 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 Reports
EXHIBIT 3CPART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total 

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $60.57/ $56.86/ $34.02/ $21.70/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Review Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $107.49 $0.00 $0.00 4 Ensure that Part A Permit Application and Reports have been signed by appropriate person 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 4 Review new ly authorized signatures w hen a different individual or position gains responsibility for the overall operation of a facility

0.00 0.00 0.32 0.00 0.32 $10.89 $0.00 $0.00 1 

Review signature certifications 0.00 0.00 0.25 0.00 0.25 $8.51 $0.00 $0.00 4 Enter Part A Application information into RCRAInfo Database 0.00 0.00 0.00 1.00 1.00 $21.70 $0.00 $0.00 4 Notify applicant of deficiency in the Part A Permit Application 0.00 0.00 0.63 0.18 0.81 $25.34 $0.00 $0.00 1 

Subtotal varies varies varies varies varies varies varies varies varies 

Review revised Part A Permit Application 0.00 0.00 3.00 0.25 3.25 $107.49 $0.00 $0.00 25 Enter revised Part A Permit Application information into RCRAInfo Database 0.00 0.00 0.00 1.00 1.00 $21.70 $0.00 $0.00 25 Review justifications for changes 0.5 0.25 0.75 0 1.50 $70.02 $0.00 $0.00 8 Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $70.02 $0.00 $0.00 8 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance DemonstrationsPart A Permit Application
EXHIBIT 42015 HAZARDOUS WASTE REPORTESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Tot

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Develop 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 Distribute Hazardous Waste Report forms and instructions 0.00 0.02 0.25 0.50 0.77 $27.26 $0.00 $0.00 143 Develop computer capabilities required to compile national data 0.00 8.00 80.00 0.00 88.00 $5,057.12 $0.00 $275,237.00 0.50 Assist respondents 0.00 0.02 0.38 0.38 0.78 $31.63 $0.00 $0.00 143 Key entry of report submissions 0.00 0.02 0.07 0.22 0.31 $10.64 $0.00 $0.00 100 Perform quality assurance 0.00 0.02 0.17 0.18 0.37 $14.93 $0.00 $0.00 1,377 Prepare the National Report 0.00 8.00 200.00 40.00 248.00 $12,664.32 $0.00 $55,047.00 0.50 Store the data 0.00 0.00 80.00 0.00 80.00 $4,440.00 $0.00 $38,534.00 0.50 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Hazardous Waste Report
EXHIBIT 5NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total H

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 2 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 2 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 1 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 1 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 2 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 2 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $10.58 $0.00 $0.52 0 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 

Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 

Subtotal varies varies varies varies varies varies varies varies varies 

a Exhibit 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 K
EXHIBIT 5 (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours an

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total 

 $87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ Hours

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $10.58 $0.00 $0.52 0 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $10.58 $0.00 $0.52 0 Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter letter information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 

Subtotal varies varies varies varies varies varies varies varies varies 

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter EPA Form 8700-12 information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $10.58 $0.00 $0.52 0 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter letter information into database 0.00 0.00 1.33 0.17 1.50 $77.84 $0.00 $0.00 0 Generate EPA Identification Number and send EPA Identification Number to facility 0.00 0.00 0.02 0.40 0.42 $10.58 $0.00 $0.52 0 Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter EPA Form 8700-12 information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 0 Enter letter information into database 0.00 0.00 1.32 0.17 1.49 $77.29 $0.00 $0.00 0 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Notification of Universal Waste Activity under 40 CFR Part 273, Subpart CInitial NotificationEPA Form 8700-12LetterSubsequent NotificationEPA Form 8700-12LetterNotification of Used Oil Activity under 40 CFR Part 279Initial NotificationEPA Form 8700-12LetterSubsequent NotificationEPA Form 8700-12Letter
EXHIBIT 6PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATIONESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total 

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number 

 $87.42/ $77.14/ $55.50/ $23.68/ Hours/ Cost/ Startup O & M Respon./ 

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Review Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $172.42 $0.00 $0.00 4 Ensure that Part A Permit Application and Reports have been signed by appropriate person 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 4 Review new ly authorized signatures w hen a different individual or position gains responsibility for the overall operation of a facility

0.00 0.00 0.32 0.00 0.32 $17.76 $0.00 $0.00 1 

Review signature certifications 0.00 0.00 0.25 0.00 0.25 $13.88 $0.00 $0.00 4 Enter Part A Application information into RCRAInfo Database 0.00 0.00 0.00 1.00 1.00 $23.68 $0.00 $0.00 4 Notify 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 

Subtotal varies varies varies varies varies varies varies varies varies 

Review revised Part A Permit Application 0.00 0.00 3.00 0.25 3.25 $172.42 $0.00 $0.00 25 Enter revised Part A Permit Application information into RCRAInfo Database 0.00 0.00 0.00 1.00 1.00 $23.68 $0.00 $0.00 25 Review justifications for changes 0.5 0.25 0.75 0 1.50 $104.62 $0.00 $0.00 8 Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $104.62 $0.00 $0.00 8 

Subtotal varies varies varies varies varies varies varies varies varies 

TOTAL varies varies varies varies varies varies varies varies varies 

a Exhibit includes rounding.

Part A Permit ApplicationRevised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations
EXHIBIT 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 SUMMARY a

Total Total Annual Annual 

Hours per Labor Cost per Capital/Startup O & M 

Information Collection Requirement Year Year Costs Costs Hazardous Waste Report (Exhibit 1A) 186,649.37 $11,402,306.89 $0.00 $59,898.51 Notification of Regulated Waste Activity (Exhibit 2A) 32,429.51 $1,839,324.94 $0.00 $168,477.28 Part A Hazardous Waste Permit Application and Modification (Exhibit 3A) 427.70 $29,804.47 $0.00 $279.93 

Subtotal 219,506.58 $13,271,436.30 $0.00 $228,655.72 

Hazardous Waste Report (Exhibit 1B) 9,075.29 $376,717.79 $0.00 $6,946.17 Notification of Regulated Waste Activity (Exhibit 2B) 2,446.93 $86,216.09 $0.00 $11,727.40 Part A Hazardous Waste Permit Application and Modification (Exhibit 3B) 19.50 $821.10 $0.00 $13.02 

Subtotal 11,541.72 $463,754.98 $0.00 $18,686.59 

Hazardous Waste Report (Exhibit 1C) 301,752.42 $8,710,351.79 $0.00 $32,587.92 Notification of Regulated Waste Activity (Exhibit 2C) 86,538.25 $2,794,524.70 $0.00 $5,398.64 Part A Hazardous Waste Permit Application and Modification (Exhibit 3C) 150.38 $4,971.14 $0.00 $0.00 

Subtotal 388,441.05 $11,509,847.63 $0.00 $37,986.56 

Hazardous Waste Report 497,477.08 $20,489,376.47 $0.00 $99,432.60 Notification of Regulated Waste Activity 121,414.69 $4,720,065.73 $0.00 $185,603.32 Part A Hazardous Waste Permit Application and Modification 597.58 $35,596.71 $0.00 $292.95 

Total 619,489 $25,245,039 $0 $285,329 

2-Year Total 1,238,978 $50,490,078 $0 $570,658 

a Exhibit includes rounding.

Private FacilitiesState and Local Government FacilitiesAll RespondentsState Agencies
EXHIBIT 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 SUMMARY a

Total Total Annual Annual 

Hours per Labor Cost per Capital/Startup O & M 

Information Collection Requirement Year Year Costs Costs Hazardous Waste Report (Exhibit 4) 1,018.63 $43,889.96 $0.00 $195,418.50 Notification of Regulated Waste Activity (Exhibit 5) 9 $459.49 $0.00 $0.00 Part A Hazardous Waste Permit Application and Modification (Exhibit 6) 150.38 $7,528.85 $0.00 $0.00 

Total 1,178 $51,878 $0 $195,419 

2-Year Total 2,356 $103,757 $0 $390,837 

a Exhibit includes rounding.