**SUPPORTING STATEMENT FOR EPA INFORMATION COLLECTION REQUEST NUMBER**  **2 493.01**  **REPORTING AND RECORDKEEPING REQUIREMENTS**

**For the Proposed Rule: CATEGORICAL NON**  **- WASTE DETERMINATION FOR SELECTED NON** 

**HAZARDOUS SECONDARY MATERIALS (NHSMs): CONSTRUCTION AND DEMOLITION WOOD,**  **PA PER**  **RECYCLING RESIDUALS,**

**and CREOSOTE -**  **TREATED RAILROAD TIES (** **Addition s to List of**  **Section 241.4 Categorical Non -** **Waste Fuels )** 

August 2 7

, 201 3 (revised 10/30/2013)i **TABLE OF CONTENTS** 1. ID ENTIFICATION OF THE INFORMATION COLLECTION
................................ ........ 1 1(a) Title and Number of the Information Collection
................................ ..................... 1 1(b) Background and Short Characterization
................................ ................................ .. 1 2. NEED FOR AND USE OF THE COLLECTION
................................ ............................... 2 2(a) Need and Authority for the Collection
................................ ................................ ..... 2 2(b) Practical Utility

and Users of the Data
................................ ................................ .... 2 3. NONDUPLICATION, CONSUL TATIONS, AND OTHER COLLECTION CRITERIA
................................ ................................ ................................ 2 3(a) Nonduplication
................................ ................................ ................................ ......... 2 3(b) Public Notice
................................ ................................ ................................ ............ 3 3(c) Consultations
................................ ................................ ................................ ............ 3 3(d) Effects of Less Frequent Collection
................................ ................................ ......... 3 3(e) General Guidelines
................................ ................................ ................................ ... 3 3(f) Confidentiality
................................ ................................ ................................ ......... 3 3(g) Sensitive Questions
................................ ................................ ................................ .. 4 4. THE RESPONDENTS AND THE INFORMATION REQUESTED
................................ . 4 4(a) Respondents and NAICS Codes
................................ ................................ .............. 4 4(b) In formation Req

uested
................................ ................................ ............................. 4 5. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIES, COLLECTI ON METHODOLOGY, AND INFORMATION MANAGEMENT
................................ ......... 5 5(a) Agency

Activities
................................ ................................ ................................ ..... 5 5(b) Small Entity

Flexibility
................................ ................................ ............................ 5 6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION
................. 5 6(a) Estimating Respondent Burden
................................ ................................ ................ 6 6(b) Estimating Respondent Costs
................................ ................................ .................. 6 6(c) Estimating Agency Burden and Cos ts ................................ ................................ ..... 7 6( d) Estimating the Respondent Universe and Total Burden and Costs
......................... 7 6( e ) Bottom Line Burden Hours and Costs
................................ ................................ ..... 8 6( f ) Reason for Change in Burden
................................ ................................ .................. 9 6( g ) Burden Statement
................................ ................................ ................................ ..... 9ii **EXHIBITS** Exhibit 1: Estimat ed Respondent Burden and Cost
................................ ................................ ...... 1 0 Exhibit 2: Estimated Agency Burden and Cost
................................ ................................ ............ 11 Exhibit 3 : Estimated Average Burden per Respondent
................................ ................................ 121

**1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title and Number of the Information Collection**  This information Collection Request (ICR) is entitled “ C ategorical N on - W aste D etermination for S elected N on H azardous S econdary M aterials (NHSM ): C onstruction and D emolition W ood, Paper R ecycling R esiduals, and C reosote - Treated Railroad T ies (Additions to List of Section 241.4 Categorical Non
- Waste Fuels) (Proposed Rule) ,” IC R Number 2493.01
. **1(b) Background and**  **Short Characterization** Section 129 of the Clean Air Act (CAA) directs EPA to promulgate regulations to control emissions of nine specified pollutants from “solid waste incineration units.” EPA did so in December 2000 with the publication of the final Standards of Performance for New Stationary Sources and Emission Guidelines for Ex isting Sources: Commercial and Industrial Solid Waste In cineration Units (the “CI SWIRule”). In September 2004, under section 112(d) of the CAA, the Agency

promulgated the National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters (the “Boilers Rule”). This rule established Maximum Achievable Control Technology (MACT) standards for this source category . Units regulated under section 129 cannot be subject to any rule promulgated under section 112. 1 Responding to a petition for reconsideration, EPA amended the CISWIRule in September 2005 with a rule that revised definitions for “solid waste,” “commercial or industrial waste,” and “commercial and industrial solid waste incineration unit” (the “CI SWIDefinitions Rule”). As part of the CISWIDefinitions Rule, EPA made a distinction between solid waste incinerators and boilers, characterizing the former as units that are designed and operated to discard materials through high temperature combustion. However, EPA excluded from the definition of a solid waste incinerator those units designed to recover energy for “useful purposes such as steam generation or process heating.” In July 2007, the Court of Appeals for the District of Columbia Circuit vacated and remanded to EPA both the CI SWIDefinitions Rule and the Boilers Rule. In vacating the Definitions Rule, the Court noted that, despite the potential reasonableness of the functional distinction between boilers and incinerators, the CAA i s unambiguous in its requirement that EPA regulate as a solid waste incineration unit any commercial or industrial incinerator that combusts any

solid waste material, regardless of whether the waste is burned as a “fuel.” The Court also concluded that EPA erred in excluding from the CI SWIDefinitions Rule units that combust solid waste for the purposes of energy recovery and including these units in the Boilers Rule.

1 However, sources have the option to switch back and forth between CAA section s 112 and 1 29 applicability
.2

In partial response to the Court’s decision, EPA published the Non - Hazardous Secondary Materials (NHSM) Rule on March 21, 2011. Amendments to this rule were published in the Federal Register on February 7, 2013. These amendments provided clarification on certain issues on which EPA received new information, as well as specific targeted rev isions. In addition, these amendments listed several NHSMs as categorical non
- wastes when used as fuels. The Agency also indicated that we would consider adding additional materials to the categorical listings as more information became available. Th e rule associated with this I CR Supporting Statement proposes to add three additional materials to the list of categorical non
- waste fuels: (1) construction and demolition (C&D) wood processed b y trained workers from construction and demolition debris acco rding to best management practices ; (2) paper recycling residuals (PRRs), including old corrugated cardboard (OCC) rejects, generated from the recycling of recovered paper and paperboard products and burned on
- site by

paper recycling mills whose boilers are designed to burn solid fuel, and (3) creosote - treated railroad ties that are processed and combusted in units designed to burn both biomass and fuel oil
. This I CR is a description of the indirect information collection requirements associated with the p roposed rule. **2. NEED FOR AND USE OF THE COLLECTION**  **2(a) Need and Authority for the Collection**  The requirements covered in this I CR are necessary for the EPA to identify appropriatel y processed non - hazardous secondary materials that are solid waste when combusted and to enforce Sections 112 and 129 of the Clean Air Act. The EPA is proposing the establishment of these information collection requirements under the authority of the Clean Air Act, su

bject to the non solid waste characterization established under the Resource Conservation and Recovery Act (RCRA). **2(b) Practical Utility and Users of the Data**  The EPA will use the collected information , if any, to ensure that non
- hazardous secondary materials that are solid wastes are managed as such and that combustion units that use these materials are regulated under the appropriate Section (s) of the Clean Air Act. **3. NONDUPLICATION, CONSULTATIONS, AND OTH**  **ER COLLECTION CRITERIA**  **3(a) Non**  **duplication** None of the information required b y the r ule , as proposed, would duplicate information required b y existing RCRA or CAA regulations. No other Federal agency or department is known to collect this information.3

**3(b) Public Notice**  In compliance with the Paperwork Reduction Act of 1995, the EPA plans to open a public comment period at the time that th e Proposed Rule is published in the Federal Register
. As part of the Federal Register notice on the proposed regulation, the EPA is soliciting comments on this information collection and the estimates in this I CR. The EPA will solicit comments on specific aspects of the proposed information collection, as de scribed below: 1) Whether the Agency ’s burden estimate is accurate ; and 2 ) How to minimize the burden on respondents, including use of appropriate automated electronic, mechanical, or other forms of information technology
. **3(c) Consultations**  The EPA consulted with and collected information from various interested parties throughout the development of the proposed rule. The EPA met and communicated with industry associations, generators and users of the materials potentially a ffected by

the rule, as well as other interested parties. The estimates in th is IC R reflect the data and assumptions that EPA has developed. The documents and data provided, summaries of the meetings , and /or telephone conversations with interested partie s are available in the docket for the r ule. Presented below is a representative sample of contacts that provided data and information that contributed in some way to the development of the proposed rule , and this I CR:

 American Forest and Paper Association (202
- 463
- 2700, info@afandpa.org)  Broad Run Construction Waste Recycling (571
- 292
- 5333, kherb1956@aol.com)  Bays hore Recycling (732
- 738
- 6000, gsondermeyer@bay shorerecycling.com)  Industrial Economics, Inc. (EPA contractor) (617
- 354
- 0074)  Association of American Railroads (202
- 639
- 2100)  Treated Wood Council (202
- 463
- 2045) **3(d) Effects of**  **Less Frequent Collection** The EPA has carefully

considered the burden imposed upon the regulated community by the r ule , as proposed . EPA is confident that the activities required of respondents are necessary , and to the extent possible, the Agency has attempted to minimize the burden imposed. The Agency strongl y believes that, if the minimum information al requirements of the r ule are not met, neither industry

nor the EPA will be able to ensure that non
- hazardous secondary materials that are solid wastes are managed in a manner that is protective of human health and the environment.4

**3(e) General Guidelines**  This I CR adheres to the guidelines stated in the Paperwork Reduction Act of 1995, OMB’s implementing regulations, EPA’s ICR Handbook, and other applicable OMB guidance. Any information collections performed under this clearance will follow all of OM B’s General Guidelines regarding data collection. **3(f) Confidentiality**  Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which defines EPA’s general policy on public disclosure of information, contain provisions for conf identiality . However, the Agency does not anticipate that businesses will assert a claim of confidentiality covering all or part of the r

ule. However, i f such a claim is asserted, the EPA must , and will treat the information in accordance with the regulations cited above. The Agency will also en sure that this information collection complies with the Privacy Act of 1974 and OMB Circular A
- 130. 2 **3(g) Sensitive Questions**  No questions of a sensitive nature are included in the information collection requirements associated with the r

ule. **4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents and NAICS**  **Codes** The following is a list of North American Industrial Classification Sy stem (NAICS) codes associated with the facilities potentially affected by this I CR.

**Industry Category or Sub Category NAICS**  Utilities 221 Construction of Buildings 236 Site Preparation Contractors 238910 Manufacturing 31, 32, 33 Wood Product Manufacturing 321 Sawmills 321113 Cement M anufacturing 32731 Waste Management and Remediation Services 562 This table is not intended to be exhaustive, but rather provides a guide for readers regarding entities likely

to be impacted by

this action.

2 OMB Circular A
- 130 rescinded OMB Circular A
- 108.5

**4(b) Information Requested**  This section describes information collection requirements applicable to entities th at would be affected b y the r ule , as proposed
. **Petition Process** The r ule does not contain a petition process. 3 **Notification** The r ule does not contain any

notification requirements. **Rule Familiarization (Reading the Regulations)** (i) Data items : None. (ii) Respondent activities : It is expected that entities potentially affected (indirectl y) by

the r ule will need to read it to assess how it may

affect their operations. **Title V Permitting** Under the r

ule, as proposed, some combustion units that are currentl y regulated under Section 1 29 of the Clean Air Act may have the opportunity to be newl y regulated under Section 1 1 2. For a limited number of units, this change in regulatory status could potentially trigger reduced permitting requirements. This would be an indirect impact of the rule, and would not represent any direct burden change under this RCRA action, as proposed. **5. THE INFORMATION COLLECTED** 
**— AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities** Because the rule, as proposed, contains no notification requirements, the Agency will not engage in notification review.

3 The EPA previously made final a rulemaking process in §241.4(b) that provides persons an opportunity to submit a rulemaking petition to the Administrator, seeking a determination for additional NHSMs to be categorically listed in §241.4(a) as non
- waste fu els
.6

**5(b) Collection Methodology and Management**  This is not a survey

I CR that requires primary (first hand) data collection. The data used in this I CR were collected from secondary sources and past EPA anal ys es that employed quality controlled data. **5(c) Small Entity Flexibility**  The self
- implementin g approach for non
- waste determinations would provide small entities with flexibility

to minimize any

burden indirectly

associated with the r

ule , as proposed
. Under this approach, small entities would not be required to submit any paperwork to EPA or stat e agencies
. **5(d) Collection Schedule**  There are two burden categories associated with this action: reading and understanding the rule, and certification statements for affected facilities. Reading and understanding the rule is a one - time burden expected to occur to affected facilities within one month following final rule publication. The schedule for preparation and submission of certification statements for affected facilities is not possible for the Agency to determine and will occur based on each facility ’s needs and production schedule. **6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION**  This section provides information on the cost and burden associated with the information collection for both the respondents and the Agency . It presents these cost and burden estimates as indi vidual costs per respondent, and as an aggregate cost for the entire respondent universe and the Agency

on an annual basis and over the entire period covered b y the I CR. **6(a) Estimating Respondent Burden**  In Exhibit 1, we estimate the respondent burden a ssociated with the proposed r ule. As shown in the Exhibit, we estimate that the one - time respondent burden for rule familiarization is one hour per facility (respondent) , recognizing that rule familiarization would occur on a per facility basis. In additi on to rule familiarization , construction and demolition (C&D) wood processing facilities would incur a one
- time burden associated with the preparation of a certification statement necessary to assure the burners that the C&D wood received from such process ing facilities is clean, and has been processed according to best management practices. We estimate that C&D wood processors would need approximately 4.1 hours to prepare the certification statement. This certification statement is an indirect requirement of the proposed rule. **6(b) Estimating Respondent Costs**  **Labor Costs**7

Exhibit 1 summarizes the total costs of the burden associated with the proposed r ule. As indicated in the exhibit, the rule familiarization cost is estimated at $ 74.20 per facility (respondent). C&D wood processing facilities are also estimated to incur an indirect burden
related cost of $298.65 per facility for preparation of the certification statement. These cost estimates reflect s the total cost of labor (base wage rat e plus benefits plus labor related overhead). For purposes of this analy sis, we have estimated an average hourly respondent total labor cost of $ 92 for legal personnel , $ 76 for managerial, $ 66 for technical staff, and $ 2 9 for clerical staff. **Capital a nd Operation & Maintenance Costs**  Capital costs usually

include any

produced ph ys ical good necessary to provide the required information, such as machinery , computers, and other equipment. The Agency does not anticipate that respondents will incur capital costs associated with this action. O&M costs are those costs associated with materials and services procured for the information collection requirements included in the I CR. For this ICR, O& M costs may include the costs of supplies used in the preparation of each C&D wood certification statement (e.g., paper, photocopies , postage ). These O&M costs are believed to be negligible (less than $1 per certification) and have not been incorporated into Exhibit 1. **Capital/Start -**  **up Operating and Maintenance (O&M) Costs** There are no operating and maintenance capital or start
- up costs associated with this action. **Annualizing Capital Costs** There are no capital costs associated with this action, thus there are no capital costs to annualize. **6(c) Estimating Agency Burden and Costs**  As indicated in Exhibit 2 , there is no Agency burden or cost associated with this RCRA action. **6( d**  **) Estimating the Respondent Universe and Total Burden and**  **Costs Respondent Universe**  The number of affected entities varies by information collection activity , as summarized below:8

Rule Familiarization: We estimate that a total of 605 facilities will incur rule familiarization costs under the Proposed Rule. This estimate is based upon information compiled by the EPA on the number of potentiall y affected generators/processors and burners of the non - hazardous secondary materials addressed in this action. Our sources indicated there may be any where from 300 to 500 C&D wood processing facilities operating in the U.S. who may be impacted by

this action. We use the high estimate of 500 facilities in this I CR. Inaddition, there may be up to 20 different paper recycling mills that may

be impacted by

this actio n , and approximately 15 Creosote Treated Railroad Tie recovery companies operating in North America
. Based on the information presented in Table 5 of the Boiler MACT Preamble (40 CFR Part 63. January 31, 2013), we estimate there may be as many

as 70 bioma ss capable section 112 facilities in the U.S., operating boilers or process heaters that may burn the non waste material that goes off

- site. Exhibit 1 presents the sources for these estimates. Certification Statement: We estimate that there may be approx imately

500 C&D wood processing facilities that may need to prepare the certification statement indirectly required b y this rule, as proposed. **Respondent Burden and Cost** Based on the universe data presented above, the EPA estimates the aggregate respondent burden associated with all of the new information collection requirements covered in this I CR. A discussion of the assumptions used in developing these burden estimates follows.

**Rule Familiarization** As shown in Exhibit 1, we estimate that a total of 605 potentially affected facilities will need to read and understand the rule. W e estimate that the per
- facility burden for rule familiarization is one hour , with a cost of approximately $ 74
. 20 per facility
.

**Certification Statement** As shown in Exhibit 1, we estimate that as many as 500 potentially affected C&D wood processors facilities may

need to prepare the certification statement. The estimated per facility burden of this certification statement is 4.1 hours, and the estimated cost per f acility is $ 298.65
. **6( e**  **) Bottom Line Burden Hours and Costs**  **Respondent Burden and Costs** In Exhibit 1, we present the total respondent burden and cost for the rule familiarization and the certification statement . The total respondent burden and costs f or these requirements are as follows:9 **Rule Familiarization** All potentially

affected facilities will incur the one
- time cost of reading the rule. EPA estimates that the total burden for rule familiarization is 605 hours . At the cost of $74.20 per hour , the associated aggregate cost is estimated at $ 44,891. Averaged over the three ye ar period of this I CR the total annual cost is estimated at $14,964.

**Certification Statement** Affected C&D wood processing f acilities are expected to incur a one - time c ost of preparing the certification statement . The estimated (one
- time) aggregate burden for respondents is 2 ,050 hours and the estimated (one
- time) aggregate cost is approximately $ 149,325. 4 Averaged over the three year period of this I CR the total annual cost is estimated at $49,775. There is a total of 605 estimated annual respondents. All 605 respondents will read the rule. Of the 605 respondents, it is anticipated that only 500 of them will prepare a certification statement. **Agency Burden and Costs**  There is no total Agency

burden and cost associated with the paperwork requirements for the r ule. **Variations In The Annual Bottom Line** We do not expect a significant variation (>25%) in the annual respondent reporting/recordkeeping burden or co st over the course of the clearance period for this I CR. **6( f**  **) Reasons for Change in Burden**  As described in this ICR, the EPA expects that the r ule , as proposed, will result in an increase of 2,655 burden hours (885 annual hours) to selected entities. Th is increase in burden reflects the specific paperwork requirement indirectly established in association with the C&D wood processor certification statement. The Agency has determined that th is requirement is necessary for informed assessments of the waste status of certain secondary materials, and to ensure that non
- hazardous secondary materials are managed in a manner that is consistent with their status as a waste or non
- waste. **6( g** **) Burden Statement** 

4 An e cdotal information from selected C&D wood processors indicates that an undetermined number of processors currently prepare and submit to burners a “best practices” certification statement as part of their standard business practice. In addition, contractual arrangements between some burners and processors often require “clean wood” processed according to best practices. Thus, the actual incremental aggregate cost for this burden activity may be considerably lower than the estimate presented here
.10

Exhibit 3 summarizes the average burden associated with each of the paperwork requirements associated with the r ule, presented separately

for regulated entities and the EPA. The paperwork requirements reflected in the exhibit include one
- time activities f or (1) the certification statement for C&D wood processors, and (2) rule familiarization. As indicated in Exhibit 3 , we estimate the total burden associated with one
- time activities as a range for regulated entities and EPA. This is because the burden per respondent depends on whether the respondent files a petition for non
- waste determination. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respond ent burden, including the use of automated collection techniques, the EPA has established a public docket for this ICR under Docket ID Number EPA
- HQ
- RCRA
- 20 13
- 0 110 , which is available for online viewing at www.regulations.gov , or in person viewing at the RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Frid ay , excluding legal holiday s. The telephone number for the Reading Room is (202) 566
- 1744, and the telephone number for the RCRA Docket is (202) 566
- 0270. An electronic version of the public docket is available at www.regulations.gov. This site can be u sed 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 electronicall y. When in the system, select “search,” then key

in the Docket ID Numb er 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 E PA
- HQ
- RCRA
- 20 13
- 0 110 and the OMB Control Number in any correspondence.11

**Source s**  **:**  Additions to List of Section 241.4 Categorical Non
- Waste Fuels , Proposed Rule  U.S. EPA, Office of Resource Conservation and Recovery. Assessment of the Potential Costs, Benefits, and Other Impacts for the P roposed Rule: Categorical Non
- Waste Determination for Selected Non Hazardous Secondary Materials (NHSM): C onstruction and Demolition Wood, Recycling Process Residuals, and Creosote
- Treated Railroad Ties (Additions to List of Section 241.4 Categorical Non
- Waste Fuels).  National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters; Final Rule (40 CFR Part 63. January 31, 2013 )
.  U.S. EPA, Office o f Resource Conservation and Recovery. August 24, 20 0 9. Waste and Materials
- Flow Benchmark Sector Report: Beneficial Use of Secondary Materials
- Construction & Demolition Materials
.  Franklin Associates
. June 1998. Characterization of Building
- Related Construction and Demolition Debris in the United States.  Generation, Management, and Processing of Paper Processing Residuals . Industrial Economics Corporation (IEc.) October 26, 2012. **Assu mptions:**  1. Based on the information presented in Table 5 of the Preamble (40 CFR Part 63. January 31, 2013 ) , we estimate there are approximately 60 to **70** biomass capable section 112 facilities in the U.S., operating boilers or process heaters. We assume that facilities with exclusive non biomass capable units (e.g., gas 1, light or heavy liquid units, coal units ) would have no interest in taking the time to read the rule. An unknown number of CISWI facilities and other interested parties may read the rule. 2. EPA (August 24, 2009) estimates there are 3,300 C&D materials recycling facilities operating nationwide. This includes appro ximately 3,000 concrete and asphalt recyclers, which leaves about 300 mixed debris (including wood processing) facilities. Franklin Associates (June 1998) estimates there were about **500** wo od waste processing facilities operating in the U.S. in the late 1990’s. We use the high estimate of 500 facilities in thi s ICR. 3. Based on IEc. paper referenced above, there are approximately 15 to **20** different paper recycling mills that may be impacted by this action. 4. Information submitted to the Agency indicates there are approximately **15** C reosote Treated Railroad Tie recovery companies operating in North America (see Preamble to the Proposed Rule). **Exhibit 1 -**  **Estimated Respondent Burden and Cost** Hours and Costs /hour per Respondent Total Hours and Cost AC TIVITY Legal

$ 92 Managerial

$ 76 Technical

$ 66 Clerical

$ 2 9 Respondent

Hours Labor

Cost Capital/

Startup Cost O&M

Cost Cost per

Respondent Number of

Respondents Total

Hours Total

Cost **RULE FAMILIARIZATION**
**– Read the rule (one**  **- time burden and cost)**  Affected Facilities 0.2 0.3 0.5 0.0 1.0 $ 74.20 $0.0 $0.0 $ 74.20 605 605 $ 4 4,891
**CERTIFICATION STATEMENT FOR AFFECTED FACILITIES:** Affected Facilities 1.00 1.50 1.25 0.35 4.10 $ 298.65 $0.0 $0.0 $ 298.65 500 2,050 $1 49 , 325 Note : Wage rates are loaded estimates.12 **Exhibit 2 -**  **Estimated Agency Burden and Cost** Hours and Costs per Respondent Total Hours and Costs INFORMATION COLLECTION ACTIVITY Leg al Mgr. Tech. Cler
. Respon. Hours Labor

Cost Capital/

Startup Cost O & M

Cost Total Cost

per Respondent Number of

Respondents Total

Hours Total

Cost
There is no estimated Agency burden or cost associated with th e RCRA action. Enforcement of the C&D wood processing certification statement falls under the Clean Air Act.13 **Exhibit 3**  **Estimated Average Burden per Respondent (hours)**

**Regulated Entities EPA**  **Burden for one -** **time activities** Rule Familiarization (one
- time burden) 1 .0 N/A Certification Statement (one
- time burden) 4.1 N/A