Supporting Statement 

for

Collection of Information on Anaerobic Digestion Facilities Processing Wasted Food

to Support EPA’s Sustainable Food Management Program

EPA Information Collection Request Number 2533.01

June 14, 2016
Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION...............................................................................1

1(a) Title of the Information Collection ....................................................................................................1

1(b) Short Characterization/Abstract .........................................................................................................1

2. NEED FOR AND USE OF THIS COLLECTION.....................................................................................................3

2(a) Need/Authority for the Collection......................................................................................................3

2(b) Practical Utility/Users of the Data .....................................................................................................3

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ........................................4

3(a) Nonduplication..........................................................................................................................................4

3(b) Public Notice Required Prior to ICR Submission to OMB................................................................5

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ........................................................................6

4(a) Respondent NAICS Codes.................................................................................................................6

4(b) Information Requested .......................................................................................................................9

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT ..............................................................................................................11

5(a) Agency Activities.............................................................................................................................11

5(b) Collection Methodology and Management ......................................................................................11

5(c) Small Entity Flexibility ....................................................................................................................11

5(d) Collection Schedule .........................................................................................................................12

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION ..................................................................12

6(a) Estimating Respondent Burden........................................................................................................12

6(b) Estimating Respondent Costs...........................................................................................................13

6(c) Estimating Agency Burden and Costs..............................................................................................16

6(d) Estimating the Respondent Universe ...............................................................................................18

6(e) Bottom Line Burden Hours and Costs .............................................................................................19

6(f) Reasons for Change in Burden.........................................................................................................19

6(g) Burden Statement.............................................................................................................................20
1

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

This new information collection is entitled “Collection of Information on Anaerobic 

Digestion Facilities Processing Wasted Food to support EPA’s Sustainable Food Management 

Program (New),” ICR number 2533.01, OMB control number 2050-NEW.

1(b) Short Characterization/Abstract

EPA’s Office of Land and Emergency Management Sustainable Food Management (SFM) 

program is designed to advance sustainable food management practices throughout the United 

States by preventing and diverting wasted food from landfills. The focal point of the SFM program 

is the Food Recovery Challenge in which organizations pledge to improve their sustainable food 

management practices. The success of the SFM program efforts to divert wasted food from 

landfills requires sufficient capacity to process the diverted materials which includes composting 

and anaerobic digestion operations. In addition to increasing opportunity to process wasted food 

diverted from the municipal solid waste stream, anaerobic digesters achieve social, environmental

and economic benefits, such as generation of renewable energy, reduction of methane emissions, 

and opportunities to improve soil health through the production of soil amendments. The SFM 

program supports these efforts by educating state and local governments and communities about 

the benefits of wasted food diversion. The SFM program also builds partnerships with state 

agencies and other strategic partners interested in developing organics recycling capacity and 

provides tools to assist organizations in developing anaerobic digestion (AD) projects. 

The SFM Program informally tracks data on anaerobic digesters to quantify and monitor 

the capacity for processing diverted wasted food in the United States at AD facilities. This AD 
2

data consists of information compiled from publicly available sources only. The information

requested by this ICR is being formally collected for the first time and would exceed 10 nonFederal respondents. This information collection would allow the SFM program to document the 

capacity for processing wasted food at AD facilities, track the growth of this capacity and provide 

a better understanding of the factors affecting this growth. This knowledge will also help develop 

future activities designed to further increase capacity. Increasing capacity for digestion of wasted 

food will spur growth in the biogas sector as a whole, advance federal goals to reduce methane 

emissions, increase production of renewable energy and assist state and local governments with 

their solid waste diversion goals.

This information collection consists of a data collection request to gather details regarding 

AD facilities for enhancement of the existing data into an AD facility inventory for the SFM 

program (SFM AD Facility Inventory). This information collection will include annual updates to 

the data set. Respondents will be requested to complete an electronic survey for this effort.

A key objective of the SFM program is to support beneficial use of wasted food by 

decreasing barriers to diversion. Providing information on the location and capacity of AD 

facilities in the United States to receive wasted food and other organic materials can assist with 

this issue. In order to ensure that the existing AD data is complete and accurate, the SFM 

program needs to gather information from all stakeholders involved in the development and 

management of AD facilities accepting organic wastes. This includes state and local regulatory 

officials as well as industry representatives. Annual updates to the SFM AD Facility Inventory 

will be necessary to maintain accuracy over time. This information will allow EPA to estimate 

and communicate the total capacity and environmental benefits of these projects and enable the 

SFM program to strategically plan future activities to support sustainable food management 
3

practices. Additionally, stakeholders can use this information to encourage the diversion of 

wasted food and justify funding resources for AD projects. Respondents for this ICR are: 1) 

State Liaisons, 2) Industry Representatives, 3) Project Owners/Operators, and 4) Other 

Stakeholders (e.g. non-profits). 

This ICR provides a comprehensive description of information collection efforts to 

support EPA’s SFM program. Sections 1 through 5 describe the information collection with 

respect to need, use and respondent activities. Section 6 estimates the annual hour and cost 

burden to respondents and the Agency under this collection.

2. NEED FOR AND USE OF THIS COLLECTION

2(a) Need/Authority for the Collection

Information collected from respondents will allow EPA to track, facilitate and measure 

the increase in capacity to process wasted food (organics) via anaerobic digestion throughout the 

United States. The success of the Sustainable Food Management Program’s Food Recovery 

Challenge is dependent on a steady increase of processing capacity over time. At this time, EPA 

does not have the necessary data to demonstrate this growth or to document the current baseline 

processing capacity. As the practice of organics diversion gains momentum, the rate at which 

wasted food is diverted from landfills will rapidly increase. This data is essential for EPA to 

evaluate agency activities designed to build such capacity and to make adjustments to the overall 

Sustainable Materials Management (SMM) program, as needed. The importance of this type of 

data was recently emphasized in EPA’s SMM Strategic Plan (Fiscal Year 2017-2022).

2(b) Practical Utility/Users of the Data
4

EPA will use information submitted by respondents to update and expand its inventory 

of AD facilities. Data on processing capacity and end uses of AD products will be collected as 

part of the inventory expansion. Data on AD projects will serve as a source of information to 

inform the public and lawmakers about the environmental benefits, such as renewable energy, 

derived from anaerobic digesters. The quantitative and qualitative data captured will assist the 

SFM program with future resource planning. EPA will use information provided by state 

contacts involved in the review and approval of new or ongoing projects to update the 

inventory and to identify barriers and opportunities within the AD sector. Information from 

industry representatives, project owner/operators, and other stakeholders will increase EPA’s 

ability to provide technical assistance to states and municipalities related to project design, 

implementation, cost effectiveness, return on investment and successful business models.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

For non-federal respondents, the information to be collected has not been collected 

previously by EPA or any other federal agency from more than 9 respondents. Comprehensive 

information about existing and new AD projects is not available through any other mechanism. 

To avoid requesting information that has already been compiled, respondents will receive a 

spreadsheet, pre-populated with existing AD data. Respondents will be asked to review the 

information and to provide updates as well as missing or additional information.
5

The AD community often announces the planning or installation of digester operations, 

so some of the necessary data are available in publications. The information collection process 

will allow EPA to collect information from respondents related to the unpublished details of AD 

projects and projects not covered by existing publications.

3(b) Public Notice Required Prior to ICR Submission to OMB

The 1st Federal Register Notice was posted at 81 FR 10856 on March 2, 2016. Three

comments were received during the first 60-day public comment period. Two of the three 

comments were completely unrelated to the collection of data regarding anaerobic digestion 

facilities processing food waste. The third comment was supportive of the data collection effort, as 

long as the response remains voluntary. 

3(c) Consultations

SFM staff contacted three respondents to request information on the estimated amount of 

time required to respond to the SFM AD Facility Inventory electronic survey.

Table 1: List of Respondent Consultations for the SFM AD Facility Inventory Update

Contact Person, Organization Role Email Address

Brian Langolf, Director of Biogas 

Systems and Research Development, 

University of Wisconsin – Oshkosh

AD Operator

langolfb@uwosh.edu

Dana Kirk, Assistant professor in 

Biosystems and Agricultural 

Engineering, Michigan State 

University

AD Operator

Kirkdana@anr.msu.edu

Dave Baran, Quasar Energy Group, 

Project Development

AD Vendor/Consultant dbaran@quasareg.com

3(d) Effects of Less Frequent Collection

The SFM AD Facility Inventory electronic survey will be distributed to potential 

respondents annually. Any reduction in the frequency of this information collection would impede 

efforts to facilitate anaerobic digestion implementation and track the increased diversion of wasted 
6

food and expanded infrastructure capacity in the organics recycling sector. 

3(e) General Guidelines

Information collections performed under this clearance will follow all of OMB’s General 

Guidelines regarding federal data collection.

3(f) Confidentiality

Participation in this data collection effort is voluntary. Respondents are not required to 

reveal confidential business information. Additionally, respondents will be given specific 

instructions to not provide any information that they consider confidential.

3(g) Sensitive Questions

No questions of a sensitive nature are asked as part of this collection effort or included 

within the pre-populated project data spreadsheet. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondent NAICS Codes

This information collection will encompass a wide variety of respondents. State liaisons 

include staff from state agencies involved in energy, environment and solid waste management. 

Industry representatives include engineering firms, construction companies, environmental 

consultants, and other companies involved in the logistics of developing anaerobic digesters. 

Other stakeholders include non-profit groups or non-governmental organizations (NGOs), as well 

as universities that provide information or other support to the project owners or industry 

representatives. Table 4 provides a summary of the applicable North American Industry 

Classification System (NAICS) codes and relevant descriptions for each type of respondent. The 

NAICS description is followed by the relevant sector and Standard Occupational Classification 
7

(SOC) code. The SOC code will be used to determine the applicable labor rate for each type of 

respondent. 

Table 4: Respondents to Information Collection

Respondent 

Type

NAICS 

Code NAICS Description (Sector and SOC code)

State Liaison 999200 Public Administration; State Managers (Sector 99: Federal, State and Local 

government; SOC code 11-9041 – Architectural and Engineering Managers)

Industry 

Representatives

221100 Electric Power Generation, Transmission and Distribution (Sector 22: Utilities; SOC 

code 17-2081 – Environmental Engineers)

333100 Agriculture, Construction, and Mining Machinery Manufacturing (Sector 33: 

Manufacturing; SOC code 11-9041 – Architectural and Engineering Managers)

541300

Engineering Services (Sector 54: Professional, Scientific, and Technical Services; 

SOC code 17-2081 – Environmental Engineers)

Project Owners 

or Operators

541300 Engineering Services (Sector 54: Professional, Scientific, and Technical Services; 

SOC code 17-2081 – Environmental Engineers)

221300 SOC Code 51-8031: Water and Wastewater Treatment Plant and System Operators

611300 Colleges, Universities, and Professional Schools (Sector 61: Educational Services; 

SOC code 17-2081 – Environmental Engineers)

Other 

Stakeholders 813900

Business, Professional, Labor, Political, and Similar Organizations (Sector 81: Other 

Services; SOC codes 19-4091 – Environmental Science and Protection Technicians 

(for Conservation non-profit staff; university researchers) 

Table 5 below provides example respondents under each respondent type, the applicable 

NAICS codes, and the number of potential respondents for the program covered by this ICR. 

This table shows the number of potential respondents for each NAICS. 
8

Table 5: Number of Potential Respondents

Respondent Type NAICS 

Code Example Respondent(s) SFM AD 

Inventory

State Liaison 999200 State energy or natural resources official 60

Industry Representatives 221100 Electric cooperative engineer; Energy 

service providers 10

333100 Manufacturers or distributors of AD 

systems

20

541300 Consultants and system developers 25

541300 AD facility operator 75

Project Owners or 

Operators

221300 Water and Wastewater Treatment Plant and 

System Operator 200

611300 University digester operator 15

Other Stakeholders 813900 Conservation non-profits; University 

researchers 10

TOTAL (Year 1)1

415

TOTAL (Year 2) 458

TOTAL (Year 3) 508

Average Annual Respondents 460

 

1 Assuming 10% increase in Respondents per year. To calculate this increase, the number of estimated respondents 

in each category is multiplied by 1.1 then rounded to the nearest whole number. These estimates are then summed 

to get 458 and 508 respectively.
9

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

Information will be collected annually for the SFM AD Facility Inventory. Electronic 

surveys specific to respondent type will be used to collect information and track updates. As 

stated above in Section 1(b), collection of information on anaerobic digesters for the SFM AD 

Facility Inventory is intended to provide information on the capacity for recycling of food-based 

materials and the growth of this capacity over time. During the first year of data collection, 

respondents will be requested to respond to an electronic survey designed to obtain the 

following information on the facilities that are within their purview:

 Project name, type, location, and operational status;

 Feedstock type and volume processed;

 Digester characteristics and capacity, including design specifications; and

 Information on the end-use of by-products produced.

This information is needed to effectively track existing AD projects and their capacity for 

processing food and other organic wastes and to gain a better understanding of the market for AD 

by-products. Respondents will also be requested to review a list of existing facilities and identify 

any additional facilities that they might be aware of or have information about. This information 

will assist EPA in identifying facilities that are not currently part of the data set. To date, the 

SFM program has compiled preliminary AD facility data based on publicly available 

information. 

During subsequent year requests, respondents associated with the facilities that are 

already part of the SFM AD Facility Inventory, will receive a pre-populated electronic 

spreadsheet with the previous years’ data set. These respondents will be requested to review this 
10

data and provide new or revised information where appropriate. The number of respondents is 

expected to increase by 10% each year. For data collection during years 2 and 3 of this ICR, 

completion of the electronic survey will only be necessary for respondents associated with newly 

identified facilities not previously represented in the data set. 

Project owners and operators may choose to provide information to EPA more frequently 

than annually if there are changes to project status, capacity, processing rates etc. However, the 

SFM program will update information made available to the public on all projects on an annual 

basis. Participation does not require that any records be kept, although respondents will likely 

maintain file copies of information submitted to EPA. 

(ii) Respondent Activities

Respondents will provide detailed information only on the projects in which they are 

involved. 

For the initial data request respondents will:

 complete the electronic survey (provided by EPA);

 review the list of existing facilities (provided by EPA);

 identify additional facilities, if known; and

 maintain a filed copy of the information submitted electronically (optional).

To provide annual updates to the SFM AD Facility Inventory respondents will:

 review the spreadsheet with the pre-populated data set;

 provide updated information on the projects under the respondents’ purview by 

completing an electronic survey (provided by EPA); 

 identify additional facilities, if known; and
11

 maintain a file copy of the information submitted electronically (optional)

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

In requesting and receiving information under this ICR for development and 

maintenance of the SFM AD Facility Inventory, EPA will complete the following tasks:

 Maintain copy of all submitted data;

 Review information provided and follow up with respondent, if necessary;

 Use information collected to enhance the existing data into the SFM AD Facility 

Inventory (Year 1);

 Enter information into the SFM AD Facility Inventory file (Years 2 and 3); and

 Post facility information on the EPA website (annualy)

5(b) Collection Methodology and Management

EPA selected the methods for collecting this information to optimize efficiency and 

minimize the burden for respondents and EPA. The SFM program will notify respondents by email 

with a request to complete the electronic survey. Respondent is not required to email completed 

surveys to EPA. Data will be automatically submitted to EPA upon completion of the electronic 

survey. All information received from respondents will be reviewed by EPA before being 

finalized and posted on the EPA website.

5(c) Small Entity Flexibility

The respondent type identified as “Other Stakeholders” are not classified as small entities 

due to the non-profit nature of these respondents. Many of the project owner/operators are 

municipalities or cities. Both municipalities and cities as well as state liaisons are considered 
12

government entities. According to the United States Small Business Administration (SBA), 

government entities are not permitted to be classified as small businesses for the purposes of this 

analysis. 

Based on the applicable thresholds for the remaining NAICS codes as established by the 

SBA (see: https://www.sba.gov/content/small-business-size-standards) some industry 

representatives may be considered small entities. In particular, manufacturers or distributors of 

AD systems and consultants and system developers could be classified as small entities. 

However, the average annual burden and cost per respondent requested under this ICR is 

estimated to be 30 minutes and $74, respectively. The response burden does not require any 

capital investments, only a small amount of labor and EPA ensures that the process for 

responding to the AD inventory electronic survey and updates is as efficient as possible through 

automatic data submission at the completion of the survey. This annual burden and cost is not 

expected to pose a significant burden on small entities. In addition, a response is requested by 

EPA, but not required and respondents may choose not to respond. 

5(d) Collection Schedule

EPA will collect information annually for the SFM AD Facility Inventory through the use 

of electronic surveys and pre-populated spreadsheets which respondents can review, complete 

and update.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

In order to obtain accurate hourly burden and cost estimates, EPA consulted with three

stakeholders regarding burden and cost assumptions for this ICR. The total hourly burden 
13

estimates for the program (for the entire 3-year ICR time period) are summarized in Table 7 

below. 

Table 7: Total Burden Hours for SFM AD Inventory Updates (3 Year Period)

Respondent Type NAICS Code Total Burden (hours) 

October 2016 – September 2019

State Liaisons 999200 100

Industry Representatives

221100 17

333100 34

541300 42

Project Owners or Operators

541300 125

221300 331

611300 26

Other Stakeholders 813900 17

TOTAL 692

Average Annual Burden Hours 231

The burden hours listed in the table above are based on the following assumption: each 

annual inventory update for the SFM AD Facility Inventory requires 30 minutes. The burden 

hour estimates displayed in Table 7 are rounded to the nearest hour. The respondent costs, 

including wage rate assumptions, are described below. Table 9 presents the estimated total 

respondent costs during the 3-year ICR period for each type of respondent, using the wage rates 

outlined in Table 8.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

For each respondent type and NAICS code, EPA used the mean hourly wage for the 

applicable SOC codes, which are listed in Table 8 below. Labor rates were not divided into 

clerical, legal, or other labor sub-categories for a specific NAICS code since respondents subject 

to the information collection effort will be primarily engineers/scientists. Rates were obtained 
14

from the Bureau of Labor Statistics’ May 2014 National Industry-Specific Occupational 

Employment and Wage Estimates (see: http://www.bls.gov/oes/current/oessrci.htm#11). The 

total labor rate used to calculate cost was obtained by applying an overhead rate of 110 percent. 

Table 8: Mean Hourly Wages by Respondent Type and SOC Code

Respondent Type NAICS 

Code SOC code

May 2014

Mean Hourly 

Wage ($)

May 2014

Mean Hourly 

Wage ($)

(+110% 

overhead)

May 2016

Mean Hourly 

Wage ($) 

(+ 2% annual 

growth)

State Liaisons 999200 SOC code 11-9041: Architectural 

and Engineering Managers 45.20 94.92 98.75

Industry 

Representatives

221100 SOC code 17-2081: 

Environmental Engineers 40.43 84.90 88.33

333100 SOC code 11-9041: Architectural 

and Engineering Managers 64.51 135.47 140.94

541300

SOC code 17-2081: 

Environmental Engineers 42.35 88.94 92.53

Project Owners or 

Operators

541300 SOC code 17-2081: 

Environmental Engineers 42.35 88.94 92.53

221300

SOC Code 51-8031: Water and 

Wastewater Treatment Plant and 

System Operators

21.25 44.63 46.43

611300 SOC code 17-2081: 

Environmental Engineers 37.76 79.30 82.50

Other Stakeholders 813900

SOC code 19-4091: 

Environmental Science and 

Protection Technicians (For 

Conservation Non-profit staff, 

university researchers 

25.26 53.05 55.19

To ensure that the rates accurately reflect the expected rates at the start of this ICR, May 

2016 labor rates were estimated by applying an annualized 2% growth factor from the 

Employment Cost Index to account for increases in wages from May 2014 to May 2016. This is 

based on the fact that for both private industry and civilian workers, the Employment Cost Index 

increased by 2.0 percent in 2015 (see: http://www.bls.gov/news.release/eci.t04.htm). Labor costs 
15

across the 3-year time period for this ICR are calculated using labor rates that assume an average 

2% increase each year using the May 2016 rates as a starting point. 

(ii) Estimating Capital and Operations and Maintenance Costs

Because this information collection requires respondents only to report information that is

already available to them, there are no capital costs. EPA does not expect that the operations and 

maintenance (O&M) costs of this program will be significant. The total costs for this information 

collection are summarized in Table 9 below and are rounded to the nearest dollar. The total cost 

values are based on the fully loaded rates that include overhead and growth as shown in Table 8 

(and then increased by 2% each year during the 3-year time period for this ICR) and the total 

burden hours in Table 7.
16

Table 9: Summary of Respondent Burden – Total Cost for SFM AD Inventory (3 Year 

Period)

Respondent Type NAICS Code Total Burden Cost ($): 

May 2016 – April 2019

State Liaison 999200 10,024

Industry Representatives

221100 1,532 

333100 4,817 

541300 3,964 

Project Owners or Operators

541300 11,799 

221300 15,676 

611300 2,146 

Other Stakeholders 813900

 957 

TOTAL $50,915

Average Annual Burden Cost $16,972

The total cost for the entire 3-year ICR time period is $50,915. This represents the 

total overall cost for the respondent portion of this ICR since there are no capital expenditures 

or O&M costs.

6(c) Estimating Agency Burden and Costs 

Following is a summary of the Agency burden associated with each activity, as described in 

Section 5(a). 

 Maintain all submitted data received automatically through electronic surveys

Clerical: 1 hour per update (updates are annual; 1 hour per year)

 Review the information provided and follow up with respondent if necessary

Technical: 40 hours per update (updates are annual; 40 hours per year)

 Develop an updated inventory (Year 1) 
17

Technical: 80 hours (Year 1 only)

 Enter data into the SFM AD Facility Inventory file (Years 2 and 3 only)

Clerical: 8 hours per update (8 hour per year; Years 2 and 3 only)

 Post SFM AD Facility Inventory data on the EPA website

Technical: 0.25 hours per update (updates are annual; 0.25 hour per year) 

Tables 9a and 9b present the estimated total agency burden hours and costs, respectively, 

for the information collection activities associated with this ICR. The burden hours in Table 9a 

reflect the entire 3-year time period covered by this ICR. The totals are rounded to the nearest 

hour. To obtain an hourly burden estimate for the entire ICR time period, annual time estimates 

for each relevant labor category as described above were multiplied by the appropriate factor 

depending on whether the activity will be conducted for one, two or all three years. The totals in 

Table 9b reflect the associated cost by labor category based on the total burden hours presented in 

Table 9a. 

EPA estimates an average hourly cost using set EPA salary rates for labor plus an 

additional 60% for overhead. To derive these estimates, EPA used the “Salary Table 2016 - GS” 

from the Department of Personnel Management (see: http://www.opm.gov/policy-dataoversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf). For purposes of this ICR, 

EPA assigned staff the following government service levels: 1) Technical Staff - GS-12, Step 5; 

and 2) Clerical Staff - GS-5, Step 1. The corresponding salary rates are $33.72 for technical staff 

and $13.54 for clerical staff. When the 60% overhead is included the corresponding rates are 

$53.95 for technical staff and $21.66 for clerical staff. No managerial hours will be spent on 

implementation of this ICR. 
18

Table 9a: Total Agency Burden Hours 

Labor Category Total Agency Burden (hours): 

May 2016 – April 2019

Technical (GS-12, step 5) 216

Clerical (GS-5, step 1) 4

TOTAL 220

Average Annual Burden Hours 73

Table 9b: Total Agency Cost 

Labor Category Total Agency Cost ($): 

May 2016 – April 2019

Total Agency Cost + 60% Overhead ($): 

May 2016 – April 2019

Technical (GS-12, step 5) 7,284 11,654

Clerical (GS-5, step 1) 54 87

TOTAL ($) 7,338 11,741

Average Annual Costs 2,446 3,914

Table 9b presents the total cost to the Agency as described in Section 5(a). The total agency 

burden for the relevant ICR time period is 220 hours and the total cost is $11,741.

6(d) Estimating the Respondent Universe

The number of respondents for each year of this ICR is expected to gradually increase 

over time. It is anticipated that the entire number of facilities will increase by approximately 

10% per year over the three years of the ICR. Tables 10a and 10b present a summary of the 
19

respondent universe by category for the next 3-year ICR period for total hours and total costs, 

respectively. The burden estimates are based on the total respondent universe.

Table 10a: Total Hours (3 Year Period)

Total Hours: 

May 2016 – April 2019

AGENCY BURDEN 220

RESPONDENT BURDEN 691

TOTAL BURDEN 911

ANNUAL BURDEN 304

Table 10b: Total Costs (3 Year Period)

Total Cost ($): 

May 2016 – April 2019

AGENCY COST 11,740

RESPONDENT COST 52,038

O&M/Capital Costs 0

TOTAL COST ($) 63,778

ANNUAL COST ($) 21,259

6(e) Bottom Line Burden Hours and Costs

Over the 3-year period covered by this ICR, EPA estimates the total respondent burden 

to be 691 hours and $50,915. There are no O&M or capital costs. EPA estimates the total 

Agency burden to be 220 hours and $11,741. The annual respondent burden and cost, averaged 

over the three-year period, is 231 hours and $16,972, respectively. There are no O&M or 

capital costs. The annual Agency burden and cost, averaged over the three-year period, is 73 

hours and $3,914. The total estimated burden and cost is 304 hours and $20,886 per year.

6(f) Reasons for Change in Burden
20

The change in burden is not applicable in this case since this is a new ICR.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is

estimated to average approximately 30 minutes per response. 

Burden means the total time, effort or financial resources expended by persons to 

generate, maintain, retain and disclose or provide information to or for a federal agency. This 

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

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

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

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

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

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

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

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

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the agency’s need for this information, the accuracy of the provided 

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

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

Docket ID EPA-HQ RCRA-2015-0836, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Resource Conservation and Recovery Act 

Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave. 

NW, Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., 

Monday through Friday, excluding legal holidays. The telephone number for the Reading Room 
21

is 202-566-1744, and the telephone number for the Resource Conservation and Recovery Act 

Docket is 202-566-0270.

An electronic version of the public docket is available at www.regulations.gov. This 

site can be used to submit or view public comments, access the index listing of the contents of 

the public docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the Docket ID Number 

identified above. Also, you can send comments to the Office of Information and Regulatory 

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, 

Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-RCRA2015-0836 and OMB Control Number 2050-NEW in any correspondence.