# Supporting Statement

For

Information Collection Request (ICR)

0 801.1 8

Requirements for Generators, Transporters,

& Waste Management Facilities

Under the

RCRA Hazardous Waste Manifest System

January 2012

### 2 

## TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1A Title and Number of the Information Collection

................................ ................................ .............. 1

1B Short Characterization

................................ ................................ ................................ ...................... 1

2. NEED, AUTHO RITY & USE FOR THE INFORMATION

2A Need & Au thority to Collect Information

................................ ................................ ........................ 1

2B Practical Util ity & Users of the Information

................................ ................................ .................... 2

3. NONDUPLICATION, CONSULTATIO NS & OTHER COLLECTION CRITERIA

3A Nonduplication

................................ ................................ ................................ ................................ . 3

3B Public Notice

................................ ................................ ................................ ................................ .... 3

3C Consultations

................................ ................................ ................................ ................................ .... 3

3D Effec ts of Les s Frequent Collection

................................ ................................ ................................ . 4

3E Confidentiality

................................ ................................ ................................ ................................ .. 5

3F Sensitive Questions

................................ ................................ ................................ .......................... 5

4. U NIVERSE OF AFFECTED RESPONDENTS

4A Economic Sectors & Industries Affected

................................ ................................ ......................... 5

4B Types & Counts of Entities Affected

................................ ................................ ............................... 6

4C Nu mber of Annual RCRA Manifests

................................ ................................ ............................... 8

5. ELEM ENTS OF INFORMATION REQUESTED

5A Manifest Pr inter Registrant Requirements

................................ ................................ ....................... 9

5B Gene rator Requirements

................................ ................................ ................................ ................. 15

5C Transporter Requirements

................................ ................................ ................................ .............. 17

5D Designated TSDF Requirements

................................ ................................ ................................ .... 22

6. AGENCY ACTIVITIES, COLLECTION METHODO LOGY & INFORMATION MANAGEMENT

6A Agency Activities

................................ ................................ ................................ ........................... 25

6B Collec tion Methodology & Management

................................ ................................ ....................... 26

6C Small Entity Flexibility

................................ ................................ ................................ .................. 26

6D Collection Schedule

................................ ................................ ................................ ........................ 26

7. ES TIMATE OF BURDEN HOURS & COST

7A Labor Wage Rates

................................ ................................ ................................ .......................... 28

7B Respondent Capital Costs

................................ ................................ ................................ ............... 29

7C Respondent O&M Costs

................................ ................................ ................................ ................. 29

7D Itemized Estimates of National Burden Hours & Costs

................................ ................................ . 30

7E Bottom Line Burden Hours and Cost

................................ ................................ ............................. 35

7F Reasons for Change in Burden

................................ ................................ ................................ ....... 35

7G Burden Stat e ment

................................ ................................ ................................ ........................... 35

BURDEN ESTIMATION SPREADSHEETS (Exhibits 1 to 1 )

................................ ................................ .............. 37

### 1



## 1. IDENTIFICATION OF THE INFORMATION COLLECTION

1 A. Title and Number o f The Information Collection

"Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA

Hazardous Waste Manif

est System (Renewal) ," OMB Control No. 2050

- 0039, EPA ICR number 0 801. 1 8

1 B. Short Characterization

EPA adopted the hazardous waste manifest system pursuant to its directive under the Resource

Conservation and Recovery Act (RCRA), as amended, to protect human health and the environment. RCRA

establishes a national program to improve hazardous waste management by regulating hazardous wastes from

"cradle to grave." An essential part of this management program is the manifest system. According to section

3002(a)(5) of RCRA, EPA must "...establish requirements respecting...use of a manifest system and any other

reasonable means necessary to assure that all such hazardous waste generated is designated for treatment , storage,

or disposal, and arrives at treatment, storage, or disposal facilities...for which a permit has been issued..."

The manifest is a control and transport document that accompanies the waste from its generation site to its

treatment, storage, or d isposal site. Among other things, the manifest lists the wastes that are being shipped and

the treatment, storage, or disposal facility (TSDF) to which the wastes are bound. The term "manifest system"

refers to the overall set of requirements for the use of the manifest.

These requirements are intended to ensure that hazardous waste designated for delivery to an off

- site

TSDF actually reaches its destination. Thus, the manifest system serves as a self

- enforcing mechanism that

requires generators, tran sporters, and owner/operators of TSDFs to participate in an active hazardous waste

tracking system. This system does not ordinarily involve intervention on the part of EPA unless hazardous wastes

do not reach their designated point of disposal within a sp ecified timeframe. In most cases, RCRA

- authorized

States operate the manifest system, and requirements may vary among authorized States, including submission of

manifests to States for routine shipments.

The critical components of the manifest system inc lude the information required on the manifest itself, the

transmittal of manifest copies to specified parties, the submission of exception, discrepancy, and unmanifested

waste reports to EPA, and recordkeeping requirements. Each of these components assist s in tracking the waste

and helps the Agency in reviewing whether hazardous waste shipments have been handled properly. The

manifest, by incorporating Department of Transportation requirements applicable to shipping papers, also serves

as an important saf

ety tool. In the event of an accident during transport or delivery, information on the manifest,

such as the identification of the waste's hazard class, can be used to help response teams determine appropriate

response actions.

2. NEED, AUTHORITY & USE FOR THE INFORMATION

2A. Need & Authority to Collect Information

This ICR 801.1 8 renews the existing information collection (ICR nr. 801. 1 6 ) for a three

- year extension, thereby

superseding and replacing the existing ICR.

EPA’s authority to require use of a hazardous waste manifest system stems primarily from Section

3002(a)(5) of the 1976 Resource Conservation and Recovery Act (RCRA) (See also RCRA Sections 3003(a)(3)

and 3004.) Regulations are found in 40 CFR 262 (registrant organizations and generators ), 40 CFR 263

(transporters), and 40 CFR 264 & 265 (TSDFs). Section 3002(a)(5) of RCRA, as amended, directs the US

Environmental Protection Agency (EPA) to:

“ ...establish requirements respecting...use of a manifest system and any other reasonable means

n ecessary to assure that all such hazardous waste generated is designated for treatment, storage,

or disposal, and arrives at treatment, storage, or disposal facilities...for which a permit has been

issued... ”

### 2



## Under this authority, USEPA published regulati ons for a manifest system on February 26, 1980 (45 Federal

Register 12724). 1 

## USEPA established requirements for manifest completion, transmittal, and recordkeeping for

hazardous waste generators at 40 CFR 262 subpart B, for transporters at 40 CFR 263 subp art B, and for treatment,

storage, and disposal facilities (TSDFs) at 40 CFR 264 & 265 subpart E. In 1984, USEPA published the Uniform

Hazardous Waste Manifest, which consisted of a Federally

- required portion (i.e., Federally required data elements

in Blo cks 1

- 20) and a State

- optional portion (i.e., Blocks A

- K on the manifest reserved for optional State use). 2



## In 2005, USEPA finalized modifications to the RCRA manifest system to minimize unnecessary

paperwork burden on hazardous waste handlers resulting f rom variable State manifest data requirements, and to

address other stakeholder

- requested improvements to the manifest system. USEPA proposed these modifications

on 22 May 2001 (http://www.epa.gov/epaoswer/hazwaste/gener/manifest/mods.htm). Specifically, USEPA has

eliminated the State

- optional blocks from EPA’s RCRA manifest form (EPA Form 8700

- 22 & 8700

- 22A

continuation sheet), and made the manifest form completely uniform. USEPA has also established special

tracking procedures for international hazardo us waste shipments (i.e. exports/ imports), rejected waste loads, and

waste container residues.

In addition, USEPA has established a RCRA manifest printing registry process at 40 CFR 262.21. Under

these regulations, any organization (e.g., waste handler, commercial printer, State agency) can register with

USEPA to print RCRA manifests. Members of the public can only obtain blank manifest forms from these

registered sources

2B. Practical Utility & Users of the Information

(a) USEPA Registry of Approved Manifest Printers

In regard to the USEPA registry, USEPA will review the initial application from each registrant to:

(1) ascertain basic organizational information (e.g., name and address of organization);

(2) determine if the registrant's proposed suffi x is unique;

(3) evaluate the qualifications of the printing company;

(4) understand how the registrant intends to print, use, and distribute the forms; and

(5) review the registrant's proposed controls, and establish additional controls as needed, to ensu re that the

registrant tightly controls its tracking numbers and prints a quality manifest.

EPA will review the registrant's form samples to:

(1) evaluate the competence of the registrant to print the manifest;

(2) evaluate if the registrant's form satisfies the print requirements of 40 CFR 262.21(f) (e.g., by visually

examining the samples and writing on them to see if they convey handwritten imprints legibly from copy

to copy, as required under 40 CFR 262.21(f)(5)); and

(3) ascertain the paper type , paper weight, ink color of the instructions, and binding method of the

registrant's form.

If the registrant is approved to print the form, the registrant must print the form according to the paper type, paper

weight, ink color, and binding method of its approved samples.

Manifest Procedures

In regard to the manifest procedures, generators, transporters, and designated TSDFs handling hazardous waste

are required to complete the data requirements for manifests and other reports primarily to:

(1) track ea ch shipment of hazardous waste from the generator to a designated facility;

1 USEPA intended the manifest to serve three primary purposes: (1) to serve as a tracking device which creates clear lines of a ccountability among

the participants in the hazardous waste systems; (2) to serve, together with other USEPA and USDOT requirements, to protect human health and the

environment during the transportation of hazardous waste by providing information on the waste to persons handling the waste and to emergency response

personnel; and (3) to provide the principal basis for USEPA’s recordkeeping and reporting requirements.

2 Pursuant to the 1995 Paperwork Reduction Act, this ICR examines only Federal information collection requirements. It does no t address State

requirements (e.g., State

- opt ional elements of the manifest, or manifest burden associated with state

- only regulated hazardous wastes).

### 3



## (2) provide information requirements sufficient to allow the use of a manifest in lieu of a United States

Department of Transportation ( USDOT ) shipping paper or bill of lading, thereby reducing the duplication

of paperwork to the regulated community;

(3) provide information to transporters and waste management facility workers on the hazardous nature of

the waste;

(4) inform emergency response t eams of the waste's hazard in the event of an accident, spill, or leak; and

(5) ensure that shipments of hazardous waste are managed properly and delivered to their designated

facilities.

Although the generators, transporters, TSDFs, and emergency respons e teams (in the case of accidents) are the

primary users of these records, USEPA may review these documents during a facility inspection to make sure

proper records are being kept and regulations are complied with. USEPA also reviews and responds to excep tion

reports, discrepancy reports, and unmanifested waste reports.

3. NONDUPLICATION, CONSULTATIONS & OTHER COLLECTION CRITERIA

3A. Nonduplication

No document identical or similar in purpose to the manifest is required by the Federal government for the

shipment of RCRA hazardous waste. Although a USDOT hazardous materials shipping paper 3 

## contains most of

the information contained on the manifest, it does not appear to be legally sufficient to track hazardous waste

shipments from the generator to the des ignated facility (i.e. from “cradle

- to

- grave”). For example, USDOT’s

shipping paper does not require USEPA ID numbers and signatures of the transporters and all other chain

- of

custody entities involved in shipping or handling the hazardous waste. USEPA r equires such signatures and

identification numbers on the manifest to ensure accountability of each waste handler during shipment of the

hazardous waste. Also, since USEPA coordinated the development of the manifest with USDOT, the manifest

form can be us ed as a USDOT shipping paper, thus eliminating the need for the transporter to carry both

documents. Furthermore, the manifest form was developed as a means of standardizing the information

requirements, both Federal and State, thereby eliminating the nee d for a generator to complete and a transporter to

carry multiple manifests for interstate shipments.

3B. Public Notice

In compliance with the Paperwork Reduction Act of 1995, USEPA issued a public notice in the Federal Register

on September 21, 2011 (76 FR 58493) , soliciting public comments for a 60

- day period ending November 21,

2011 . No comments were received.

3C. Consultations

Dan Appelt Director , Compliance Administration



## Safety

- Kleen

dappelt@safety

- kleen.com

Melinda Keillor

Environmental Manager

Michigan Department of Environmental Quality

melinda.keillor@eqonline.com

Michael Williams

3 Any person who offers a hazardous material for transportation in commerce must describe the hazardous material on a USDOT shi pping paper in the

man ner required in 49 CFR 172 subpart C. A shipping paper includes ``a shipping order, bill of lading, manifest or other shippin g document serving a

similar purpose and containing the information required by 49 CFR 172.202, 172.203 & 172.204.'' 49 CFR 171.8 provides a definition of ``shipping paper''.

49 CFR 172.205(h) states that an USEPA RCRA hazardous waste manifest (EPA Form 8700

- 22) ``may be used as the shipping paper'' if it contains all the

information required by 49 CFR 172 subpart C.

### 4



## PSC, LLC l

Vice President , Support Services

202

- 783

- 0870

3D. Effects of Less Frequent Collection

USEPA requires registrants to submit an initial application to USEPA under 40 CFR 262.21(b) and form samples

and descriptions under 40 CFR 262.21(d). These are one

- time submittals. Registrants need not submit any other

application information under 40 CFR 262.21(b) or (d), except if USEPA requests changes or has questions. If

USEPA did not receive these submittals, USEPA would not be able to determine if the registrant:

· will tightly control its manifest tracking numbers to ensure that each number pre

- printed on the manifest

is uni que;

· will use appropriate quality control measures to print a quality manifest consistently; and

· is competent to print the manifest.

USEPA also would not have any way to determine if the registrant’s manifest satisfies the print requirements at

40 CFR 262. 21(f). USEPA needs to visually examine the samples (e.g., to determine if it has acceptable copy

- to

copy registration; if the instructions on the back of the copies do not bleed through; if the binding method is

adequate; if the paper weight and paper typ e are adequate to convey handwritten imprints copy to copy).

An approved registrant need not re

- submit information to the Agency, unless it:

· updates its initial application approved under 40 CFR 262.21(c)

· wants a new suffix

· seeks to change the paper type, paper weight, ink color of the instructions, or binding method of its

approved forms

· seeks to change the printing company.

In regard to updates to the application, USEPA needs to learn about any updates. For example, if the name or

address of the registra nt changes, USEPA must be informed of this. If the registrant updates its quality control

methods, USEPA must be apprised so it can evaluate the updated methods and require modifications if needed.

Less frequent information submittal would not allow USEP A to learn about these important updates and ensure

they are appropriate.

In regard to requests for a new suffix, USEPA needs to evaluate the registrant’s proposed new suffix to

ensure it is unique. Each registrant must generate its unique manifest tracki ng numbers using its unique suffix. If

registrants do not submit a request to USEPA for a new suffix, USEPA will not have a way to ensure that a

registrant’s new suffix is unique.

In regard to changes to the paper type, paper weight, ink color, or binding method or changes to the

approved printer, USEPA must evaluate the form to determine if it satisfies the print requirements of 40 CFR

262.21(f). After they are approved to print the form, for example, some registrants might seek to change their

paper typ e to a lesser grade, which may not effectively convey impressions copy to copy. Less frequent

information submittal would not allow USEPA to evaluate changes to these key aspects of the registrant’s form.

In regard to the manifest requirements, USEPA does not collect manifests under normal situations, but

requires instead preparation of the manifest, use of the manifest during transportation, and recordkeeping of the

manifests for a 3

- year period. Manifests are only collected by USEPA either to accompany an exception or

discrepancy report or in the case of an export. In addition, since the manifest is required to accompany all

shipments of hazardous waste when shipped off site by the generator, less frequent preparation is not possible.

The frequency of off

- site shipment is determined by the generator and depends on:

· the quantities of waste to be shipped as they impact the economies of shipment

· transporter scheduling

· the applicable regulatory requirements.

The present system gives the generator the opport unity to maximize the economies of off

- site shipments by

selecting a shipping frequency that is appropriate for the rate of waste generation. Further, by requiring a

manifest to accompany each shipment, USEPA ensures the manifest is available in the case of a discharge of

hazardous waste during transportation. Information on the manifest could be useful to emergency response

personnel responding to the scene. In this regard, less frequent manifesting could result in a less expedient or

protective respons e to the release.

Note, however, that USEPA provides a manifest exemption at 40 CFR 262.20(e) and (f) for specified

types of shipments, as appropriate. Under 40 CFR 262.20(e), small quantity generators (SQGs), or those

### 5



## generators who generate between 10 0 and 1,000 kilograms/month of hazardous waste, can be exempt from

manifest requirements if the waste is reclaimed under a contractual agreement that specifies the type of waste and

frequency of shipments; the transporting vehicle is owned and operated by the reclaimer; and the generator retains

a copy of the reclamation agreement for three years after termination or expiration of the agreement. Under 40

CFR 262.20(f), generators who transport hazardous wastes on a public or private right

- of

- way within or along the

border of contiguous property under the control of the same person, even if such contiguous property is divided

by a public or private right

- of

- way, are exempt from manifesting requirements.

3E. Confidentiality

Section 3007(b) of RCRA and 40 CF R 2 subpart B, which define USEPA’s general policy on the public

disclosure of information, contain provisions for confidentiality. However, the Agency does not anticipate that

businesses will assert a claim of confidentiality covering all or part of the information collection requirements

covered in this ICR. If such a claim was asserted, USEPA must and will manage that information in accordance

with the regulations cited above.

3F. Sensitive Questions

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

4. UNIVERSE OF AFFECTED RESPONDENTS

4A. Respondents/SIC Codes

Following are the Standard Industrial Classification (SIC) codes and the North American Industry

Classification System (NAICS) codes of facilities most likely subject to the requirements in this ICR.

Industrial Sector SIC Code(s) NAICS Code(s)

Agriculture, Forestry, Fishing, and Hunting 01

- 09 11

Mining 10

- 14 21

Utilities 49 22

Construction 15

- 17 23

Manufacturing 20

- 39 31

- 33

Wholesale Trade 50

- 51 42

Retail Trade 52

- 59 44

- 45

Transportation and Warehousing 40

- 47 48

- 49

Information 27, 48, 73 (partial), 78 51

Waste Management & Remediation Services 1799, 4953, 4959 562

Public Administration 91

- 97 92

4B. Types & Count of Entities Affected

There are basically five categories of entities affected by the respondent activities required for each information

collection element discussed in this ICR:

· Registrant organizations (manifest printer registry)

### 6



## · Hazardous waste generators which ship hazardous waste offsite

· Hazardous waste transporters

· Hazardous waste TSDFs (treatment, storage, disposal facilities) which receive offsite shipments

· Agency (i.e. Federal RCRA

- authorized state government progr ams, and USEPA regional offices, and

USEPA headquarters)

(4B.1) Registrant Organizations

In the previously approved information collection, USEPA estimated 40 entities would apply to USEPA’s

manifest printing registry during the first two years of operat ion

. That estimated included roughly 20 States that

previously printed manifests and 20 TSDFs or large generators . In addition, USEPA used its best judgment to

estimate that the Agency will receive two new applications in the third year covered by this I CR. As displayed in

Table 1 , USEPA estimates that 7 entities will apply to USEPA’s manifest printing registry during the first two

years covered by this ICR. 4 

## In addition, USEPA used its best judgment to estimate th a t the Agency will receive

three new application s in the third year covered by this ICR. Thus, USEPA estimates that, on average, 3

registrant organizations will be subject to the requirements in 40 CFR 262.21 over the 3

- year period covered by

this ICR.

Table 1

Estimated Number of Registran t Organizations Subject to 40 CFR 262.2

EPA Manifest Printing Registry

Year 1 Year 2 Year 3 Average

Number of registry applicants 4 3 3 3

(4B.2) Waste Handlers

For purposes of estimating respondent burden

, th is ICR use s USEPA

- OSW’s 200 9 RCRA Hazardous Waste

Biennial Report ( BR ) data to determine the universe of SQGs, LQGs, and TSDFs. The respondent burden

estimates detailed in the previous ICR were based on 2005 BR data. Although the respondent burden estimates

were updated using 200 9 BR data, certain assumptions used to determine the respondent burden estimates in the

previous ICR were also used in this ICR . For instance, it remains appropriate to distinguish between LQGs that

generate but do not manage hazardous waste onsite, versus LQGs that both generate and manage (i.e., treat, store,

or dispose of) hazardous waste on site. USEPA has found differences between these two groups in their

manifesting practices and number of outbound shipments.

Based on 200 9 BR data, USEPA estimates t hat 14,381 LQGs in the US generate but do not manage

hazardous waste ( t hese sites are referred to simply as “LQGs” in this ICR.) In addition, 200 9 BR data indicate

that 1,468 sites in the US both generate and manage hazardous waste onsite and hence qualif y as TSDFs. 5 

## (This

ICR refers to these 1,468 sites as “TSDFs acting as generators.”)

EPA estimates that, of the 1,468 TSDFs acting as generators, approximately 25% are commercial TSDFs

( 367 ) and 75% are captive TSDFs ( 1,101 )

. 6 

## USEPA defines a commercial TSDF as a facility whose waste

management capacity is available to any generators or facilities for commercial hazardous waste management, or

to a limited group of generators or facilities for commercial hazardous waste managem ent. A captive TSDF is a

facility that receives hazardous waste from on

- site sources only, or from on

- site sources and off

- site sources that

are part of its same company only. USEPA estimates there are significant differences between commercial and

4 Estimates of new registrants are estimates by Wanda Lebleu, the Office of Solid Waste’s (OSW) primary contact for the OSW’s paper manif est

printing registry.

5 To determine the number of LQGs and TSDFs shipping hazardous waste off site, USEPA used information from the Waste Generation and

Management (GM) Form and the RCRA Subtitle C Site Identification (Site ID) Form of the 2009 BRS. USEPA then eliminated facil ities operated by the

Federal government (i.e., government

- owned, government

- operated facilities (GOGOs) and privately

- owned, government

- operated facilities (POGOs)).

6 These percentages are based on an analysis of prior year data on TSDFs contained in USEPA’s Office of Solid Waste RCRA Hazard ous Waste

Biennial Report database.

### 7



## capti ve TSDFs regarding waste volumes managed and number of manifests completed, and thus, the Agency has

chosen to examine their manifest preparation burdens separately in this ICR.

To determine the number of SQGs that ship hazardous waste off site each year , USEPA performed an in

depth analysis of data from the 200 9 BR data and from other USEPA information collection instruments (e.g.,

3010 Notification)

. 7 

## Based on that analysis, U SEPA estimates that 161,720 SQGs ship hazardous waste off site

each year and are subject to the manifest system

. 8



## In addition, there are 304 hazardous waste transporter companies subject to the manifest system. 9 

## Finally,

USEPA referred to 200 9 BR data to estimate that, each year, 577 TSDFs receive hazardous waste from off site. 10



## Table 2 summarizes the number of waste handlers subject to manifesting requirements each year.

Table 2

Annual Number of Waste Handlers Subject to Manifesting System

Type of Waste Handler Number of Waste Handlers

1 Generators

LQGs 14,381 a



## Commercial TSDFs 367 b



## Captive TSDFs 1,101 b



## SQGs 145,871 a



## Subtotal 161,720

2 Transporters 304

3 Designated TSDFs (“ receiving

facilities ”) 577 b



## a Includes sites that generate hazardous waste but do not manage it onsite under a

permit.

b Many TSDFs acting as generators may also qualify as designated TSDFs.

Hence, the number of designated TSDFs and TSDFs acting as generators are not

additive.

Number of Annual RCRA Manifests

Number of Manifests that Accompany Shipments Initiated by the Generator

This ICR addresses the RCRA manifesting requirements for three types of hazardous waste shipments estimated

in Table 3 :

· Domestic shipments of hazardous waste (i.e. shipments originating and terminating within the US)

· Import shipments (i.e. shipments received from a foreign country and shipped within the US)

· Export shipments subject to 40 CFR 262 subpart E (i.e. exports from the US to non

- designated members

of the Organization for Economic Cooperation and Development (OECD), as identified at 40 CFR

262.58(a)(1)). [Note: this ICR does not include manifest burden for waste exports to designated OECD

countries.]

Table 3

7 ICF Consulting Inc collected data used in this analysis from USEPA’s Office of Solid Waste RCRAInfo database during 07

- 14 Nov 2003

(http://www.epa.gov/epaoswer/hazwaste/data/index.htm#rcra

- info).

8 The estimate does not include facilities operated by t he Federal government (i.e., GOGOs or POGOs).

9 Calculated by adjusting figure in 2008 ICR, which was based on data in USEPA

- OSW’s “Economics Background Document” developed for the

March 2004 Manifest Form Revisions Final Rule.

10 The estimate does not include facilities operated by the Federal government (i.e., GOGOs or POGOs).

### 8 

## Estimated Annual Number of Manifests Completed by Hazardous Waste Generators:

Domestic Shipments + Export Shipments to Non

- Designated OECD Countries

Type of Generator Number of

Generators that

Manifest Average Annual Number of

Manifests Completed p er

Generator* Annual Number of Manifests

Completed

LQGs 14,381 46 654,888

Commercial TSDFs 367 347 127,513

Captive TSDFs 1,101 36 32,240

SQGs** 145,871 ** 9 1,065,763

Total 161,720 14 1,887,404

* These numbers are rounded.

** Of the 174,867 SQGs shipping hazardous waste off site each year, USEPA estimates that 145,871 must

prepare and transmit a manifest with their off

- site shipments and the remaining 26,257 operate under a

reclamation agreement. As provided under 40 CFR 262.20(e), these 26 ,257 SQGs need not undertake any

manifesting activities for their hazardous waste shipments to the recycling facility.

Table 4 breaks down the annual number of manifests that accompany domestic shipments, import shipments, and

export shipments to non

- des ignated OECD countries. Based on USEPA consultations, as well as data compiled

by USEPA’s Office of Enforcement and Compliance Assurance (OECA), USEPA estimates that 1,849,020

manifests accompany domestic shipments of hazardous waste and 19,509 manifests accompany export shipments

to non

- designated OECD countries each year, including Mexico and Canada. In addition, USEPA has used its

best judgment to estimate that 18,875 manifests are prepared each year by transporters for imported hazardous

wastes at poi nt

- of

- entry into the US and all are received by commercial TSDFs (i.e. “ receiving facilities ”), which

represents 1% of total annual manifests.

Table 4

Estimated Total Annual Number of Manifests Completed for Domestic Shipments,

Import Shipments, and Exp ort Shipments to Non

- Designated OECD Countries

Type of Generator Total Number of Manifests Completed/Year

Domestic

Shipments Import

Shipments Export Shipments to Non

Designated OECD Counties

a 

## All

Shipments

LQGs 639,170 6,549 9,169 654,888

Commercial TSDFs 124,677 1,275 1,561 127,513

Captive TSDFs 38,263 392 585 32,240

SQGs 1,046,911 10,658 8,194 1,065,763

Total 1,849,020 18,875 19,509 1,887,404

a Includes Mexico and Canada.

(4C.2) Number of Manifests that Accompany Shipments Rejected by the Designated TSDF

EPA estimates that each manifest completed and sent off site by a generator ( 1,887,404 ) will be delivered to the

designated TSDF, minus those manifests accompanying export shipments (19,509 manifests) or lost during

transpo rt ( 185 manifests), plus import manifests ( 18,874 ). Hence, USEPA estimates that 1,886,584 manifests will

be delivered to the designated TSDF. USEPA estimates that 3% ( 62,258 ) will be rejected.

Table 5 presents the number of manifests accompanying shipments that are rejected or for which a

container residue is identified by the TSDF. USEPA estimates that 50% of these problem shipments ( 31,129 )

involve partially rejected loads or container residues iden tified after the transporter has left the TSDF’s premises.

USEPA estimates that 99% of these shipments will be sent to the alternate TSDF and 1% will be sent back to the

generator. A new manifest must be prepared to send these shipments to the alternate TSDF or generator. EPA

estimates that the remaining 50% of these problem shipments ( 31,129 ) involve fully rejected loads or container

### 9



## residues identified while the transporter is still on the TSDFs’ premises. USEPA estimates that 99% of these

shipments w ill be sent to the alternate TSDF and 1% will be sent back to the generator. The original manifest

may be used to send these shipments to the alternate TSDF or generator.

Table 5

Total Annual Number of Manifests that

Accompany Rejected Loads and Contai ner Residues a



## Type of Shipment Estimated Annual Number of Manifests

New Manifests that Accompany Rejected Shipments or Container Residues

Shipments sent back to generator (1%) 311

Shipments sent to alternate TSDF (99%) 30,819

Subtotal 31,129

Original Manifests that Accompany Rejected Shipments or Container Residues

Shipments sent back to generator (1%) 311

Shipments sent to alternate TSDF (99%) 30,818

Subtotal 31,129

Total 62,258

a Table contains rounding error.

4B

. Information Requested

Manifest Printer Registrant Requirements

(a) Applying to the Registry

40 CFR 262.21(a) provides that a person may not print the manifest for use or distribution unless his/her

organization (e.g., company, State agency) has received approval from USEPA to do so under 40 CFR 262.21(c)

and (e). In order to receive USEPA approval, a registrant must submit to USEPA an application that contains the

information specified in 40 CFR 262.21(b). Upon USEPA approval of the application, the registrant m ust submit

three fully assembled manifests and, if needed, continuation sheets that meet the specifications of 40 CFR

262.21(f) and a description of the form samples, as specified in 40 CFR 262.21(d). In reviewing these submittals,

USEPA may request modif ication to them before approval.

In developing the registry process, USEPA performed thorough consultation with waste handlers,

commercial printers, and States and concluded that it is imperative for USEPA to evaluate the printing capabilities

and form sam

ples of registrants. Although many commercial printers have developed an expertise in multi

- forms

printing (the final rule requires RCRA manifests to be printed on a six

- copy form), USEPA expects that certain

prospective registrants will not have such exp ertise. Printing the manifest requires some degree of sophistication

and expertise in order to consistently satisfy the performance requirements at 40 CFR 262.21(f). For example,

registrants must design their manifest so that handwritten and typed imprin ts are legible on all six copies, the

manifest instructions do not bleed through the front of the copies, and the binding of copies is reasonably secure.

The USEPA has posted print guidance on its Manifest Registry Web site

( http://www.epa.gov/osw/hazard/transportation/manifest/registry/index.htm ) t o assist organizations

– including

states, waste management companies, industrial facilities and printing companies

– in a pplying to USEPA to print

the manifest. The web site also provides a list of registered printers approved by USEPA to print the form.

Although USEPA has posted print guidance on the web, significant discretion will be left to the registrant to

determine th e appropriate paper type, paper weight, ink color of the instructions, and binding methods that will

satisfy the print specifications. Because of this, it is essential that the registry review samples of their forms to

determine if they comply with the pr int specifications, e.g., to evaluate the samples to see if they comply with the

performance requirements.

In addition, USEPA and the States are keenly interested in making sure that manifest tracking numbers

pre

- printed on forms are tightly controlled and remain unique. One of the highest priorities of the registry is

ensuring that each manifest used or distributed to the pub l ic has a unique tracking number. Because USEPA will

### 10



## allow registrants to pre

- print numbers onto their manifests without any ongoin g Agency oversight, it is essential

that the registry evaluate and approve the registrant's procedures and systems for controlling their tracking

numbers, as described in their applications.

Data Items

· An application that contains the following informatio n:

-- Name and mailing address of registrant.

-- Name, telephone number, and email address of contact person.

-- Brief description of registrant’s government or business activity.

-- EPA ID number of the registrant, if applicable.

-- Description of the sco pe of the operations that the registrant plans to undertake in

printing, distributing, and using its manifests, including:

- A description of the printing operation. The description should include an

explanation of whether the registrant intends to print its manifests in

- house or

through a separate printing company. If the registrant intends to use a separate

printing company to print the manifest on its behalf, the application must identify

this printing company and discuss how the registrant will overse e the company.

If this includes the use of intermediaries, the role of each must be discussed. The

application must provide the name and mailing address of each company. It also

must provide the name and telephone number of the contact person at each

co mpany.

- A description of how the registrant will ensure that its organization and

unaffiliated companies, if any, comply with the requirements of 40 CFR 262.21.

The application must discuss how the registrant will ensure that a unique

manifest tracking number will be pre

- printed on each manifest. The application

must describe the internal control procedures to be followed by the registrant and

unaffiliated companies to ensure that numbers are tightly controlled and remain

unique. If computer systems or other infrastructure will be used to maintain,

track, or assign numbers, these should be indicated. The application must

indicate how the printer will pre

- print a unique number on each form. The

application must explain the quality procedures to be follo wed by each

establishment and printing company to ensure that all required print

specifications are consistently achieved and that printing violations are identified

and corrected at the earliest practicable time.

- An indication of whether the registrant intends to use the manifests for its own

business operations or to distribute the manifests to a separate company or to the

general public (e.g., for purchase).

-- A brief description of the qualifications of the company that will print the manifest. The

registrant may use readily available information to do so (e.g., corporate brochures,

product samples, customer references, documentation of ISO certification), so long as

such information pertains to the establishments or company being proposed to print the

manifest.

-- Proposed unique three

- letter manifest tracking number suffix. If the registrant is

approved to print the manifest, the registrant must use this suffix to pre

- print a unique

manifest tracking number on each manife st.

-- A signed certification by a duly authorized employee of the registrant that the

organizations and companies in its application will comply with the procedures of its

approved application and the requirements of 40 CFR 262.21 and that it will notify

USEPA of any duplicated manifest tracking numbers on manifests that have been used or

distributed to other parties as soon as this becomes known.

· Three fully assembled manifests and, if needed, continuation sheets that meet all of the specifications in

40 CFR 262.21(f). The form samples must be printed by the company that will print the manifest as

identified in the application approved under 40 CFR 262.21(c). The registrant need not submit samples

of the continuation sheet if the continuation sheet will be printed using the same paper type, paper weight,

ink color of the instructions, and binding method as the manifest.

### 11



## · A description of the manifest samples as follows:

-- Paper type (i.e., manufacturer and grade of the manifest paper).

-- Paper weight of each copy.

-- Ink color of the manifest’s instructions. If screening of the ink was used, the registrant

must indicate the extent of the screening.

-- Method of binding the copies.

Respondent Activities

· Prepare and submit initial application.

· Submit revi sed initial application to USEPA, if requested.

· Submit three fully assembled manifests and, if needed, continuation sheets and a description of the form

samples.

· Submit revised form samples based on USEPA comment on the initial samples, if requested.

(b) Updating General Information in the Approved Application

40 CFR 262.21(h)(1) provides that, if an approved registrant would like to update any of the information provided

in its application (e.g., to update a company phone number or name of contact perso n), the registrant must revise

the application and submit it to USEPA, along with an indication or explanation of the update, as soon as

practicable after the change occurs. USEPA will review and either approve or deny the revision. If the revision is

de nied, the registrant must respond to the Agency’s concerns.

Data Item

· Revised application, along with an indication or explanation of the update.

Respondent Activities

· Revise and submit the application to USEPA, along with an indication or explanation of the update.

· Respond to the Agency’s concerns, if applicable.

(c) Requesting Approval for a New Tracking Number Suffix

40 CFR 262.21(h)(2) provides that, if an approved registrant would like a new tracking number suffix, the

registrant must submit a prop osed suffix to USEPA, along with the reason for requesting it.

Data Item

· Proposed tracking number suffix, along with the reason for requesting it.

Respondent Activity

· Submit a proposed tracking number suffix, along with the reason for requesting it.

(d) Requesting Approval for Changes to Printing Specifications or Use of a New Printer

40 CFR 262.21(h)(3) provides that, if a registrant would like to change the paper type, paper weight, ink color of

the manifest instructions, or binding method of its manifest or continuation sheet subsequent to approval under 40

CFR 262.21(e), then the registrant must submit three samples of the revised form for USEPA review and

approval. If the approved registrant would like to use a new printer , the registrant must submit three manifest

samples printed by the new printer, along with a brief description of the printer’s qualifications to print the

manifest. In reviewing these submittals, USEPA may request modification to them before approval.

D ata Items

· Three samples of the manifest form and/or continuation sheet.

· A brief description of the qualifications of the new printer, if applicable.

Respondent Activity

### 12



## · Submit three samples of the manifest form and/or continuation sheet and, if applicable , a brief description

of the qualifications of the new printer.

· Submit revised manifest form and/or continuation sheet samples to USEPA, if requested.

(e) Typesetting the Manifest Form Subsequent to its Approval

40 CFR 262.21(i) provides that, if subseq uent to its approval under 40 CFR 262.21(e), a registrant typesets its

manifest or continuation sheet instead of using the electronic file of the forms provided by USEPA, it must submit

three samples of the manifest or continuation sheet to the registry fo r approval. The registrant cannot use or

distribute its typeset forms until USEPA approves them.

Data Items

· Three samples of the manifest or continuation sheet.

Respondent Activity

· Submit three samples of the manifest or continuation sheet to the registry for approval.

(f) Requesting an Exemption

40 CFR 262.21(j) provides that USEPA may exempt a registrant from the requirement to submit form samples

under 40 CFR 262.21(d) or 262.21(h)(3) if the Agency is persuaded that a separate review of the r egistrant’s

forms would serve little purpose in informing an approval decision (e.g., a registrant certifies that it will print the

manifest using the same paper type, paper weight, ink color of the instructions, and binding method of the form

samples appr oved for some other registrant). A registrant may request an exemption from USEPA by indicating

why an exemption is warranted.

Data Item

· Documentation indicating why an exemption is warranted.

Respondent Activity

· Submit documentation to USEPA indicatin g why an exemption is warranted.

(g) Notifying USEPA of a Printing Specification Violation

40 CFR 262.21(k) requires an approved registrant to notify USEPA by phone or email as soon as it becomes

aware that it has used or distributed manifests that contain duplicated manifest tracking numbers.

Data Item

· Notification of duplicated manifest tracking numbers.

Respondent Activity

· Notify USEPA of duplicated manifest tracking numbers.

(h) Revising the Approved Manifest if Requested by USEPA

40 CFR 262.21(l) provides that, if, subsequent to approval of a registrant under 40 CFR 262.21(e), USEPA

becomes aware that the registrant’s approved form does not satisfactorily meet the print specifications in 40 CFR

262.21(f), USEPA wi ll contact the registrant and require modifications to the form.

Data Item

· Revised manifest form samples.

Respondent Activity

· Submit revised manifest form samples to USEPA, if requested.

### 13



## (i) Responding to Suspension and Revocation Procedures

40 CFR 262.21(m) provides that USEPA may suspend and, if necessary, revoke printing privileges if it finds that

the registrant: (i) has deviated from its application approved under 40 CFR 262.21(c) in printing the form; (ii) has

knowingly used or distributed form s that deviate from its approved form samples in regard to paper weight, paper

type, ink color of the instructions, or binding method; or (iii) exhibits a continuing pattern of behavior in using or

distributing manifests that contain duplicate manifest tra cking numbers. USEPA will send a warning letter to the

registrant that specifies the date by which it must come into compliance with the requirements. If the registrant

does not come in compliance by the specified date, USEPA will send a second letter no tifying the registrant that

USEPA has suspended or revoked its printing privileges. An approved registrant must provide information on its

printing activities to USEPA if requested.

Data Item

· Information requested by USEPA.

Respondent Activity

· Submit information if requested by USEPA.

Generator Requirements

The 1976 RCRA statute, as well as regulations promulgated by USEPA, established the following requirements

for hazardous waste generators, and related waste handlers:

· Large Quantity Generators (L QGs): RCRA, as amended, requires USEPA to establish the "use of a

manifest system and any other reasonable means necessary to assure that all such hazardous

waste...arrives at" the designated facility (Section 3002(5)). On May 19, 1980, USEPA promulgated

regulations calling for the use of manifests by generators of greater than 1,000 kilograms/month of

hazardous waste, thereby establishing the manifest system.

· Small Quantity Generators (SQGs: generators of between 100 and 1,000 kilograms/month): The

Hazar dous and Solid Waste Amendments of 1984 (HSWA) directed USEPA to promulgate standards for

the generation, treatment, and disposal of hazardous waste produced by SQGs. In compliance with

HSWA, USEPA promulgated regulations on March 24, 1986, that require S QGs to comply with the

manifest requirements of 40 CFR 262 subpart B. A SQG can be exempt from the requirements listed in

this section when its waste is reclaimed under a contractual agreement and certain other conditions are

met. However, the SQG must m aintain records of the agreement for at least three years after termination

or expiration of the agreement, as required by 40 CFR 262.20(e)(2).

· Hazardous Waste Exporters: On August 8, 1986, USEPA promulgated regulations relating to the export

of hazardous waste out of the US to supplement the 1980 regulations. 40 CFR 262 subpart E sets forth

special manifesting requirements that primary exporter s must meet in exporting their waste.

(a) Manifest Completion

40 CFR 262.20 requires generators transporting, or offering for transportation, hazardous waste for off

- site

treatment, storage, or disposal to prepare a manifest (EPA Form 8700

- 22) and, if ne cessary, continuation sheets

(EPA Form 8700

- 22A). Generators must prepare these forms in accordance with 40 CFR 262.20, 262.23, 262.54,

and 262.60, as appropriate, as well as the instructions in the appendix to 40 CFR 262.

Data Items

 The generator’s US EPA ID or State ID number.

· The total number of pages used to complete the manifest.

· The emergency response phone number.

· The manifest tracking number.

 The generator’s name and mailing address.

 The generator’s phone number.

· The generat or’s site address (if different than mailing address).

 The name and USEPA ID number for transporters.

### 14



##  The designated facility’s name and site address.

· The designated facility’s phone number.

 The USEPA ID number of the designated facility.

· The USDOT description of the waste.

 The container description (number and type).

 The total quantity of each waste described.

 The unit of measure.

· The waste codes representing the waste.

 Special handling instructions and additional information.

 The generator’s/offeror’s certification. 11



## · For primary exporters only: The primary exporter must prepare the manifest in accordance with 40 CFR

262.20 and 262.23, except as provided under 40 CFR 262.54(a) through (d):

 In lieu of the site name, site address and USEPA ID number of the designated permitted

facility, enter the name and site address of the consignee.

 In lieu of the name, site address, and USEPA ID number of a permitted alternate facility,

enter the name a nd site address of any alternate consignee.

 In the International Shipments Block, check the export box and enter the point of exit

(city and State) from the US.

· For primary importers only: The primary importer must prepare the manifest in accordance wit h 40 CFR

262.20 & 262.23, except as provided in 40 CFR 262.60(b) and (d):

 In place of the generator’s name, address, and USEPA ID number, use the name and

address of the foreign generator and the importer’s name, address, and USEPA ID

number.

 In place of the generator’s signature on the certification statement, the US importer or his

agent must sign and date the certification and obtain the signature of the initial

transporter.

 In the International Shipment Block, check the import box and enter the po int of entry

(city and State) into the US.

Respondent Activities

 Complete the manifest for domestic, export, and import shipments.

 Complete continuation sheet, if required.

(b) Compliance with State Program Requirements

Under 40 CFR 262.21(g)(2), ge nerators must determine whether the consignment State regulates any additional

wastes (beyond those regulated Federally) as hazardous wastes under its State hazardous waste program.

Generators must also determine whether the consignment State or generator State requires the generator to submit

any copies of the manifest to these States.

Data Item

· Information provided by the State on its manifest program.

Respondent Activities

· Contact the consignment/generator State if needed and submit any copies of the manifest to these States,

as applicable.

(c) Manifest Transmittal and Recordkeeping

Generators must transmit and keep records of the manifest in accordance with 40 CFR 262.23, 262.40, 262.44,

262.54 and 262.60, as appropriate.

11 The generator’s/offeror’s certification in Item 15 of the manifest form references the waste minimization certification codif ied at 40 CFR 262.27.

### 15



## Data Items

 A generator must sign and give copies of the manifest to the transporter along with the hazardous

waste in accordance with 40 CFR 262.23(a) & (b), and retain copies of the manifest in

accordance with 40 CFR 262.23(a) & 262.40 (a).

 For shipments of hazardous waste within the US solely by water (bulk shipments only), the

generator, as required by 40 CFR 262.23(c), must send three copies of the manifest to the

owner/operator of the designated facility or the last water transport er to handle the waste in the

US if exported by water.

 For rail shipments of hazardous waste within the US which originate at the site of generation, the

generator, as required under 40 CFR 262.23(d), must send at least three copies of the manifest to

th e next non

- rail transporter, the designated facility, or the last rail transporter to handle the waste

in the US if exported by rail.

· Exports: Acknowledgment of Consent: For exports, the primary exporter must provide the transporter

with a USEPA Acknowle dgment of Consent, and an additional copy of the manifest or shipping papers

for delivery to the US Customs official at the point the hazardous waste exits the US, as required by 40

CFR 262.54(h) and (i).

· Reclamation Agreements: In the event an SQG’s wast e is reclaimed under a contractual agreement

pursuant to 40 CFR 262.20(e)(1), the SQG must retain the reclamation agreement for at least three years

from the date of termination or expiration of the agreement, as required by 40 CFR 262.20(e)(2).

Responde nt Activities

 Sign the manifest certification and obtain the signature of the initial transporter and date of

acceptance on the manifest in accordance with 40 CFR 262.23(a).

 Keep a copy of the manifest and give the remaining copies to the initial trans porter, in accordance

with 40 CFR 262.23(a) & (b).

 Keep a copy of the manifest returned from the designated facility for at least three years from the

date the waste was accepted by the initial waste transporter, in accordance with 40 CFR 262.40(a)

or 26 2.44(a).

 For shipments solely by water, send three copies of the manifest, dated and signed in accordance

with 40 CFR 262.23(a), to the designated facility or the last water transporter to handle the waste

in the US, as required by 40 CFR 262.23(c). [Note: Copies of the manifest are not required for

each transporter.]

 For shipments by rail originating at the site of generation, send at least three copies of the

manifest to the next non

- rail transporter, the designated facility, or the last rail tra nsporter to

handle the waste in the US, as required by 40 CFR 262.23(d).

· Exports: Acknowledgment of Consent: Primary exporters must provide the transporter with an USEPA

Acknowledgment of Consent and an additional copy of the manifest or shipping papers f or delivery to the

US Customs official at the point the hazardous waste exits the US, as required by 40 CFR 262.54(h) and

(i).

· Reclamation Agreements: An SQG operating under a tolling agreement must retain a copy of each

reclamation agreement, if applicabl e, for at least three years after the termination or expiration of the

agreement, as required by 40 CFR 262.20(e)(2).

(d) Undeliverable Shipments

Generators must provide instructions to the transporter on how to deal with shipments that cannot be deliver ed to

the designated or the alternate TSDF. For shipments that a transporter is unable to deliver to the designated

facility or the alternate facility, generators must designate another facility or instruct the transporter to return the

waste, as required by 40 CFR 262.20(d) and 262.54(g)(3).

Data Item

· Instructions to the transporter on how to deal with shipments that cannot be delivered to the designated or

the alternate TSDF.

### 16



## Respondent Activity

· For shipments that a transporter is unable to deliver to the designated facility or the alternate facility,

designate another facility or instruct the transporter to return the waste.

Rejected Waste and Container Residues

USEPA has promulgated regulations at 40 CFR 262.34(j) to improve the tra cking of rejected waste and container

residues. USEPA has also expanded the definition of " designated facility " to include generators that receive

rejected loads or container residues from the TSDF designated on their manifest to receive the waste. It is

important to clarify the procedures that generators will need to follow for receiving and managing rejected load or

container residue shipments sent back by the designated TSDF. These regulations will improve hazardous waste

tracking, while placing minim al paperwork burden on generators (i.e. generators need only sign the form

accompanying the problem shipment delivered to them).

Under 40 CFR 262.34(j), a generator who sends a shipment of hazardous waste to a designated facility

with the understanding th at the designated facility can accept and manage the waste and later receives that

shipment back as a rejected load or residue in accordance with the manifest discrepancy provisions of 40 CFR

264.72 or 265.72 may accumulate the returned waste on

- site, as s pecified. Upon receipt of the returned shipment,

the generator must sign the manifest that accompanies the rejected load or residue.

Data Item

 Complete a manifest.

Respondent Activities

· Sign Item 18c of the manifest, if the transporter returned the shipment using the original manifest.

· Sign Item 20 of the manifest, if the transporter returned the shipment using a new manifest.

(f) Exception Reports: Completion, Submission, and Recordkeeping

(f1) Large Quantity Generators

USEPA's May 19, 1988 RCRA manifest regulations included requirements for generators to prepare, submit, and

keep records of exception reports (40 CFR 262.42). In the event an LQG does not receive a copy of the signed

manifest from the designated facility owner/operator within 35 d ays of the date the waste was accepted by the

initial transporter, the LQG must contact the transporter and/or the owner/operator of the designated facility to

determine the status of the hazardous waste. The LQG must submit an exception report to USEPA i f he/she has

not received a copy of the signed manifest from the designated facility owner/operator within 45 days of the date

the waste was accepted by the initial transporter and must retain a copy of the exception report for at least three

years from th e due date of the report, in accordance with 40 CFR 262.42(a) and 262.40(b).

Data Item

· An exception report containing the following data:

-- A legible copy of the manifest for which the generator does not have confirmation of

delivery, as required by 4 0 CFR 262.42(a)(2)(i).

-- A cover letter signed by the generator or his authorized representative explaining the

efforts taken to locate the hazardous waste and the results of those efforts, as required by

40 CFR 262.42(a)(2)(ii).

Respondent Activities

 Prepare and submit a signed cover letter to USEPA explaining the generator’s efforts to locate the

hazardous waste and the results of those efforts, along with a legible copy of the manifest, in

accordance with 40 CFR 262.42(a)(2)(i) and (ii).

 Keep a cop y of each exception report, as required by 40 CFR 262.40(b).

(f2) Small Quantity Generators

### 17



## EPA's March 24, 1986 final regulations mandated use of the manifest system by SQGs, but exempted them from

the exception report requirements applicable to LQGs. On June 6, 1986, the Environmental Defense Fund (EDF)

sued in the US Court of Appeals for the reinstatement of the exception report requirement. Under the terms of the

settlement agreement negotiated with EDF, the Agency agreed to propose a modified excep tion report

requirement for SQGs and to take comment on other options for accomplishing the exception reporting purpose.

On September 23, 1987, USEPA promulgated regulations calling for exception reporting by SQGs.

These regulations are similar to the exi sting requirements for LQGs, except that the SQG is not required to

contact the transporter or facility owner/operator to determine the waste's disposition, the length of time before an

exception report is required is 60 days, and the generator need only n ote on the manifest that he has not received

confirmation of delivery (§262.42).

In the event an SQG does not receive a copy of the signed manifest from the owner/operator of the

designated facility within 60 days of the date the waste was accepted by the initial transporter, he/she must submit

to the USEPA Regional Administrator a legible copy of the manifest with some indication that he has not

received confirmation of delivery, in accordance with 40 CFR 262.42(b).

Data Item

· A legible copy of the manifest with some indication that the SQG has not received confirmation of

delivery.

Respondent Activity

· Submit a legible copy of the manifest with some indication that the waste has not been delivered.

Transporter Requirements

(a) Manifest Completion, Transmittal, and Recordkeeping

A critical part of the manifest system is the use of multiple copies of the manifest to track the shipment of

hazardous waste as it moves from the generator to the designated TSDF by way of the transport er. Regulations

found in 40 CFR 263 subpart B require transporters to ensure that the manifest accompanies the hazardous waste

during transportation, to deliver the hazardous waste and the manifest as indicated on the manifest, and to keep

records of the manifests.

Under 40 CFR 263.20 & 263.22, a SQG's waste, transported following a reclamation agreement, can be

exempt from the manifest requirements of the section. However, the transporter is required to record waste

generator data information on a log o r shipping paper and retain a copy of these records, as required by 40 CFR

263.20(h).

40 CFR 263.20, 263.21 & 263.22 detail the completion, transmittal, and recordkeeping requirements of

manifests or shipping papers for hazardous waste transporters, includ ing those exporting hazardous waste outside

the US. In accordance with these requirements, transporters must complete specified parts of the manifest (or

shipping paper, as provided in 40 CFR 263.20(e)(2)), retain a copy of the manifest (or shipping paper ), transmit

copies to specified parties, and ensure that the original manifest or shipping papers accompany the waste to its

destination.

(a1) Hazardous Waste Transporters (except as exempted by 40 CFR 263.20(e) and (f))

Except for certain water and rail transporters exempted under 40 CFR 263.20(e)&(f), transporters transporting

hazardous waste outside the US (40 CFR 263.20(g)) and transporters transporting hazardous waste pursuant to a

reclamation agreement (40 CFR 263.20(h)) & 263.20(b), (c),(d) require transporters to sign and date the manifest

acknowledging acceptance of the waste from the generator before transporting the hazardous waste. Before

leaving the property, the transporter must return or transmit a signed copy of the manifest to the generat or. In

addition, the transporter must ensure that a copy of the manifest or other shipping paper accompanies the

shipment and is readily available and recognizable.

A transporter who delivers a hazardous waste to another transporter or to the designated facility must

obtain the date of delivery and the signature of the transporter or designated facility; retain a copy in accordance

with 40 CFR 263.22; and give the remaining copies of the manifest to the accepting transporter or designated

facility, as re quired at 40 CFR 263.20(d).

### 18



## Data Item

 Complete a manifest and/or shipping paper.

Respondent Activities

 Sign and date the manifest, as required by 40 CFR 263.20(b).

 Return a signed copy of the manifest to the generator, as required under 40 CFR 263. 20(b).

 Ensure that the manifest (or other shipping paper) accompanies the waste to its destination, as

required by 40 CFR 263.20(c).

 In delivering the hazardous waste and manifest to another transporter or to the designated facility,

perform the following activities, as required by 40 CFR 263.20(d):

-- Obtain the date of delivery and signature of that transporter or the owner/operator of the

facility or alternate facility designated on the manifest, pursuant to 40 CFR 263.20(d)(1).

-- Retain a copy of the manifest pursuant to 40 CFR 263.22(a).

-- Give remaining copies of the manifest to the accepting transporter or facility, in

accordance with 40 CFR 263.20(d)(3).

(a2) Water (Bulk Shipment) Transporters Regulated under 40 CFR 263.20(e)

Water (bulk shipment) transporters who are regulated under 40 CFR 263.20(e) must sign and date the manifest

upon receipt of the hazardous waste; must ensure that a shipping paper containing the generator, waste, and

facility information, and a USEPA Acknowledgme nt of Consent for exports, accompany the waste during

transportation; must obtain the signature of the facility owner/operator on the manifest or shipping paper; and

must retain a copy of the manifest or shipping paper for three years.

Dat a Items

 Copies of the manifest.

 Copies of the shipping paper containing all the information on the manifest except the USEPA ID

numbers, the generator certification, and required signatures, as required under 40 CFR

263.20(e).

 A USEPA Acknowledgment of Consent (for exporters only), as required by 40 CFR 263.20(e)(2).

Respondent Activities

 Obtain the date of delivery and signature of the initial water transporter on the manifest, in

accordance with 40 CFR 263.20(e)(4).

 Forward the manifest to the designated facility, in accordance with 40 CFR 263.20(e)(4).

· Bulk water transporters identified under 40 CFR 263.20(e) must perform the following activities:

 Ensure that the shipping paper (and Acknowledgment of Consent, for exports)

accompanies the waste to its destination, as required by 40 CFR 263.20(e)(2).

 If the delivering (water) transporter, obtain the date of delivery and signature of the

owner/operator of the designated facility on either the manifest or shipping paper, as

required by 40 C FR 263.20(e)(3).

 If the initial water transporter, sign and date the manifest and return it to the delivering

transporter so that the manifest can be forwarded to the designated facility

owner/operator, as required by 40 CFR 263.20(e)(4).

 Retain a cop y of the manifest or shipping paper, as required by 40 CFR 263.22(b).

(a3) Rail Transporters Regulated under 40 CFR 263.20(f)

Under 40 CFR 263.20(f)(1), initial rail transporters must sign and date the manifest acknowledging acceptance of

the hazardous w aste; return or transmit a signed copy of the manifest to the non

- rail transporter; and forward at

least three copies of the manifest to the next non

- rail transporter, the designated facility, if the shipment is

delivered to that facility by rail, or the l ast rail transporter designated to handle the waste in the US; and retain a

copy of the manifest and rail shipping paper in accordance with 40 CFR 263.22.

### 19



## Rail transporters must ensure that a shipping paper containing all the information required on the ma nifest

(excluding the USEPA ID numbers, generator certification, and signatures) and, for exports, a USEPA

Acknowledgment of Consent accompanies the hazardous waste at all times, as required by 40 CFR 263.20(f)(2).

When delivering hazardous waste to the d esignated facility, a rail transporter must obtain the date of delivery and

signature of the owner or operator of the designated facility on the manifest, or a signature on the shipping paper

(if the manifest has not been received by the facility) and reta in a copy of the manifest or signed shipping paper,

as required under 40 CFR 263.20(f)(3). When delivering hazardous waste to a non

- rail transporter, a rail

transporter must obtain the date of delivery and the signature of the next non

- rail transporter on the manifest and

retain a copy of the manifest, as required under 40 CFR 263.20(f)(4). Before accepting hazardous waste from a

rail transporter, a non

- rail transporter must sign and date the manifest and provide a copy to the rail transporter, as

require d by 40 CFR 263.20(f)(5).

Data Items

 Complete a manifest.

 A shipping paper containing all the information on the manifest, except the USEPA ID numbers,

the generator certification, and required signatures.

 A USEPA Acknowledgment of Consent (for exp orts only).

Respondent Activities

 When accepting waste from a non

- rail transporter, sign and date the manifest, as required by 40

CFR 263.20(f)(1)(i) and return or transmit a signed copy of the manifest to the non

- rail

transporter, as required by 40 CFR 263.20(f)(1)(ii).

 Forward at least three copies of the manifest to either the next non

- rail transporter, the designated

facility, or the last rail transporter designated to handle the waste in the US, as required by 40

CFR 263.20(f)(1)(iii).

 Ensure a shipping paper containing all the information required on the manifest excluding the

USEPA ID number, generator certification, and signatures (and for exports an Acknowledgment

of Consent) accompanies the waste, as required under 40 CFR 263.20(f)(2).

 Whe n delivering hazardous waste to the designated facility or to the next non

- rail transporter,

obtain the signature and date of delivery of the facility or non

- rail transporter on the manifest, as

required under 40 CFR 263.20(f)(3)(i) or (f)(4)(i).

 Retain a copy of the manifest and/or rail shipping paper, as required under 40 CFR

263.20(f)(1)(iv), 263.20(f)(3)(ii), 263.20(f)(4)(ii) and 263.22, as applicable.

 Before accepting hazardous waste from a rail transporter, sign and date the manifest and provide

a copy to the rail transporter, as required under 40 CFR 263.20(f)(5).

(a4) Transporters Who Import or Export Hazardous Wastes (40 CFR 263.20(g) & (i))

Under 40 CFR 263.20(g), transporters who either transport hazardous waste into (import) or out of (exp ort) the

US, must sign and date the manifest to indicate the date that the shipment arrived (import) or left (export) the US,

respectively; retain one copy in accordance with 40 CFR 263.22; for exports return a signed copy to the generator

and provide a co py of the exported waste manifest to a US Customs official at the point of departure from the US.

In addition for exports, the transporter also must ensure that a copy of the USEPA Acknowledgment of Consent

accompanies the waste, as required by 40 CFR 263 .20(a).

Data Items

 Complete a manifest or shipping paper.

 EPA Acknowledgment of Consent.

Respondent Activities

 For imports and exports, sign and date the manifest in the International Shipments block to

indicate the date that the shipment entered o r left the US, respectively, as required by 40 CFR

263.20(g)(1).

### 20



##  For imports and exports, retain a copy of the manifest, as required by 40 CFR 263.20(g)(2).

 For exports, return a signed copy of the manifest to the generator, as required by 40 CFR

263.20(g)(3).

· For exports, give a copy of the manifest to a US Customs official at the point of departure from the US, as

required by 40 CFR 263.20(g)(4).

 For exports, ensure that copies of the manifest and USEPA Acknowledgment of Consent

accompanies the waste, as required by 40 CFR 263.20(a).

(a5) Transporters Who Transport Hazardous Waste Pursuant to a Reclamation Agreement

(263.20(h))

40 CFR 263.20(h) provides that transporters can be exempt from the requirements of 40 CFR 263.20 & 263.22

when transp orting a SQG’s waste pursuant to a reclamation agreement in accordance with 40 CFR 262.20(e).

These transporters are required to record data items on a log or shipping papers, carry the record to the

reclamation facility, and retain these records, as requ ired by 40 CFR 263.20(h).

Data Items

 The name, address, and USEPA ID number of the hazardous waste generator.

 The quantity of waste accepted.

 All USDOT

- required shipping information.

 The date the waste is accepted.

Respondent Activities

 Record the waste information on a log or shipping paper, as required by 40 CFR 263.20(h)(2).

 Carry the record when transporting waste to the reclamation facility, as required by 40 CFR

263.20(h)(3).

 Retain the records for at least three years after termination or expiration of the agreement, as

required by 40 CFR 263.20(h)(4).

(b) Undeliverable Shipments

Under 40 CFR 263.21(a), the transporter must deliver the entire quantity of hazardous waste which he has

accepted from a generator or a transporter to the designated facility listed on the manifest; the alternate designated

facility, the next designated tr ansporter; or the place outside the US designated by the transporter. 40 CFR

263.21(b)(1) requires that, if the hazardous waste cannot be delivered in accordance with 40 CFR 263.21(a)

because of an emergency condition other than rejection of the waste by the designated facility, then the transporter

must contact the generator for further directions and must revise the manifest according to the generator’s

instructions.

Data Items

 A manifest that has been revised according to the generator’s instruction s.

Respondent Activities

· Contact the generator for further directions and revise the manifest according to the generator’s

instructions.

(c) Rejected Waste and Container Residues

USEPA has promulgated regulations at 40 CFR 263.21 to improve the tracking of rejected waste and container

residues. These regulations further clarify procedures that transporters will need to follow when dealing with

rejected waste or container residue shipments sent back to the original generator or to an alternate TSDF. Und er

40 CFR 263.21(b)(2), if a hazardous waste is rejected or a container residue is identified by the designated facility

listed on the manifest while the transporter is on the facility’s premises, then the transporter must comply with the

appropriate proce dures:

· Partial load rejections: The transporter must obtain the facility’s signature and date, the manifest tracking

number of the new form, and a description/indication of the rejected waste in the discrepancy block on the

### 21



## original manifest. The transpo rter must retain this copy of the manifest in accordance with 40 CFR

263.22 and give the remaining copies to the designated facility. If the transporter is forwarding the

shipment to the alternate facility or returning it the generator, the transporter mu st obtain the new

manifest for the shipment.

· Full load rejections or container residues: The transporter must obtain the original manifest that includes

the facility’s signature and date, name and address of the alternate facility or generator, and a descr iption

of the rejected load or container residue in the discrepancy block as appropriate. The transporter must

retain this copy of the manifest in accordance with 40 CFR 263.22 and give a copy to the facility. If the

original manifest is not used, then t he transporter must obtain a new manifest for the shipment.

Data Item

 Complete a manifest.

Respondent Activities

· For partially rejected loads made while the transporter is on site, obtain the amended manifest from the

facility, keep a copy, and, if rec eiving the rejected waste, obtain the new manifest.

· For fully rejected loads made or container residues identified while the transporter is on site, obtain the

original manifest, as amended, from the facility.

(d) Notification of Discharge of Hazardous Waste

The 49 CFR 263 subpart C regulations reference USDOT notification requirements for hazardous waste

transporters responding to a discharge of hazardous waste and establish requirements for water (bulk shipment)

transporters who discharge hazardous wa ste, similar to notification requirements for oil and hazardous substances

releases.

In the event of a discharge of hazardous waste during transportation, 40 CFR 263.30(a) requires the

transporter to take appropriate immediate action to protect human healt h and the environment, for example,

notifying local authorities. 40 CFR 263.30(c) requires an air, rail, highway, or water transporter who has

discharged hazardous waste to give notice, if required by 49 CFR 171.15, to NRC and to report in writing to

USDO T as required by 49 CFR 171.16. 40 CFR 263.30(d) requires a water (bulk shipment) transporter who has

discharged hazardous waste to give the same notice as required by 33 CFR 153.203 for oil and hazardous

substances, if not already required under 33 CFR 1 53.203. Water (bulk shipment) transporters, as soon as they

have knowledge of any discharge of hazardous waste, must immediately notify NRC, US Coast Guard, as

required by 33 CFR 153.203. If the direct reporting to the NRC is not practicable, reports may be made to the US

Coast Guard or USEPA predesignated OSC for the geographic area where the discharge occurs. If it is not

possible to notify the NRC or the predesignated OSC immediately, reports may be made immediately to the

nearest US Coast Guard unit, provided the transporter notifies the NRC as soon as possible.

Data Item

· Notification of a discharge of hazardous waste

Respondent Activities

 In the event of a discharge of hazardous waste during transportation, the transporter must take

appropriate a ction to protect human health and the environment, including notification of the

discharge to local authorities, as required by 40 CFR 263.30(a).

 Water (bulk shipment) transporters must immediately notify NRC of the discharge or, if it is not

practicable to notify the NRC, a predesignated OSC can be notified. If the OSC is notified, the

transporter must notify the NRC of the discharge as soon as possible, as required by 40 CFR

263.30(d) and 33 CFR 153.203.

[Note: This ICR does not include hour and cost burden estimates for activities associated with

the 49 CFR 171 notification requirements referenced in 40 CFR 263 since Part 263 does not add

any notification requirements to those already in 49 CFR 171.]

Designated Treatment, Storage, and Disposal Facility Requirements

### 22



## (a) Manifest Completion, Transmittal, and Recordkeeping

40 CFR 264.71(a),(b) and 40 CFR 265.71(a),(b) set forth completion, transmittal, and recordkeeping requirements

for TSDFs that receive hazardous waste accompanied by a manifest or shipping paper. 40 CFR 264.71(a),(b) and

40 CFR 265.71(a),(b) provide that, if a facility receives hazardous waste accompanied by a manifest (or shipping

paper, for certain rail or water shipments), the TSDF or his/her agent must sign and date each co py of the manifest

to certify that the hazardous waste covered by the manifest was received; note any significant discrepancies in the

manifest on each copy; immediately return to the transporter a signed copy; within 30 days of delivery send a

copy of the manifest to the generator; and retain a copy for at least three years from the date of delivery.

Data Items

 Copies of the manifest or shipping paper.

Respondent Activities

 Complete, transmit, and retain copies of the manifest, as required by 40 CF R 264.71(a),(b) or 40

CFR 265.71(a),(b) and the manifest instructions:

-- Enter the name of the person accepting the waste and sign and date each copy of the

manifest (or shipping paper, if applicable).

-- Complete the management method codes.

-- Note any discrepancies (as defined in 40 CFR 264.72(a)) on each copy of the manifest (or

shipping paper, if applicable).

-- Immediately give the transporter at least one copy of the manifest (or shipping paper).

-- Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the

generator.

– Imported wastes: Within 30 days of delivery, the receiving TSDF must mail a final

signed copy of the imported waste manifest to EPA’s International Compliance

Assurance Division.

-- Retain a copy of the manife st (or shipping paper) for at least three years from the date of

delivery. [Note: Although the noting of manifest or shipping paper discrepancies is

mentioned above, it is burdened in the subsection entitled “Discrepancy Reports.”]

(b) Compliance with S tate Program Requirements

Under 40 CFR 264.71(e) and 40 CFR 265.71(e), TSDFs must determine whether the consignment State for a

shipment regulates any additional hazardous wastes (beyond those regulated Federally). TSDFs must also

determine whether the c onsignment State or generator State requires the facility to submit any copies of the

manifest to these States.

Data Item

· Information provided by the State on its manifest program.

Respondent Activities

· Contact the consignment/generator State if needed and submit any copies of the manifest to these States,

as applicable.

(c) Discrepancy Reports

The 40 CFR 264 & 265 subpart E regulations also require TSDFs to note and potentially report discrepancies (40

CFR 264.71& 264.72; 265.71 & 265.72), and make re cords and reports available to USEPA (40 CFR 264.74 &

264.77; 265.74 & 265.77). 40 CFR 264.72 and 265.72 provide that, upon discovering a significant discrepancy,

TSDFs must attempt to reconcile the discrepancy with the waste generator or transporter. If the discrepancy is not

resolved within 15 days after receiving the waste, the owner/operator must immediately submit to USEPA a copy

of the manifest or shipping paper in question, as well as a letter describing the discrepancy and attempts to

reconcile it

.

### 23



## Data Items

 A copy of the manifest or shipping paper in question.

· A letter describing the manifest discrepancy and the facility’s efforts to reconcile it.

Respondent Activities

· Attempt to reconcile any discrepancies, as required by 40 CFR 264.72(c) or 265.72(c).

· Prepare and submit a letter to USEPA describing the discrepancy and attempts to reconcile it, along with

a copy of the manifest or shipping paper at issue, as required by 40 CFR 264.72(c) or 265.72(c).

(d) Rejected Waste and Container Residu es

40 CFR 264.72 and 40 CFR 265.72 provide that the TSDF must forward rejected waste or container residues to an

alternate facility that can accept the waste. If the TSDF is unable to locate an alternate facility to take the waste,

then the TSDF may retu rn the shipment to the original generator. 40 CFR 264.72(d) through (g) and 40 CFR

265.72(d) through (g) describe manifest procedures for TSDFs that originate a rejected waste or container residue.

(d1) Rejection of Waste after the Transporter Leaves the Facility

For full or partial load rejections and residues that are to be sent off site to an alternate facility or back to the

generator after the transporter has left the facility, the facility is required to prepare a new manifest, as required by

40 CF R 264.72(d), (e)(1)

- (6), or (f)(1)

- (6) or 40 CFR 265.72(d), (e)(1)

- (6), or (f)(1)

- (6).

In addition, if a facility rejects a waste or identifies a container residue that exceeds the quantity limits for

“empty” containers set forth in 40 CFR 261.7(b) after i t has signed, dated, and returned a copy of the manifest to

the transporter, the facility must comply with 40 CFR 264.72(g) or 265.72(g). The facility must amend its copy

of the manifest to indicate the rejected wastes or residues in the discrepancy spac e of the amended manifest. The

facility must also copy the manifest tracking number from Item 4 of the new manifest to the Discrepancy space of

the amended manifest, and must re

- sign and date the manifest to certify to the information as amended. The

faci lity must retain the amended manifest for at least three years from the date of amendment, and must within 30

days, send a copy of the amended manifest to the delivering transporter and to the generator.

Data Items

· Instructions provided by the generator.

 Copy of the original manifest and/or shipping paper.

 Copy of a new manifest and/or shipping paper.

Respondent Activities

 Contact the generator to obtain the generator’s instructions for forwarding the waste to another

facility that can manage the waste, as required by 40 CFR 264.72(d) or 265.72(d).

· Prepare a new manifest for rejected loads or container residues sent to the alternate designated facility or

back to the generator:

-- Write the facility’s USEPA ID, name, and address in the appropriate blocks of the new

manifest (i.e. Items 1 and 5), as required by 40 CFR 264.72(e)(1) or (f)(1) or 265.72(e)(1)

or (f)(1).

-- Write the name of the alternate designated facility/initial generator and the

facility’s/generator’s USEPA ID number in the designat ed facility block (Item 8) of the

new manifest, as required by 40 CFR 264.72(e)(2) or (f)(2) or 265.72(e)(2) or (f)(2).

-- Copy the manifest tracking number found in Item 4 of the old manifest to the Special

Handling and Additional Information Block of the new manifest, and indicate that the

shipment is a residue or rejected waste from the previous shipment, as required by 40

CFR 264.72(e)(3) or (f)(3) or 265.72(e)(3) or (f)(3).

-- Copy the manifest tracking number found in Item 4 of the new manifest to the manifest

reference number line in the Discrepancy Block of the old manifest (Item 18a), as

required by 40 CFR 264.72(e)(4) or (f)(4) or 265.72(e)(4) or (f)(4).

### 24 

## -- Write the USDOT description for the rejected load or the residue in the Item 9 (USDOT

Descri ption) of the new manifest and write the container types, quantity, and volume(s)

of waste, as required by 40 CFR 264.72(e)(5) or (f)(5) or 265.72(e)(5) or (f)(5).

-- Sign the Generator’s/Offeror’s Certification to certify, as the offeror of the shipment, that

the waste has been properly packaged, marked and labeled and is in proper condition, as

required by 40 CFR 264.72(e)(6) or (f)(6) or 265.72(e)(6) or (f)(6).

 Amend the facility’s copy of the manifest to indicate the rejected wastes or residues in the

discrepancy space of the amended manifest, as required by 40 CFR 264.72(g) or 265.72(g).

· Copy the manifest tracking number from Item 4 of the new manifest to the Discrepancy space of the

amended manifest, as required by 40 CFR 264.72(g) or 265.72(g).

· Re

- s ign and date the manifest, as required by 40 CFR 264.72(g) or 265.72(g).

· Retain the amended manifest for at least three years from the date of the amendment, as required by 40

CFR 264.72(g) or 265.72(g).

· Within 30 days, send a copy of the amended manifest to the delivering transporter and to the generator, as

required by 40 CFR 264.72(g) or 265.72(g).

(d2) Rejection of Waste while the Transporter Remains Present at the Facility

For container residues and full load rejections that are made while the transporter remains present at the facility,

the facility may forward the shipment to the alternate facility or return the shipment to the generator using the

original manifest, as specified in 40 CFR 264.72(e)(7) or (f)(7) or 40 CFR 265.72(e)(7) or (f)(7)

.

Data Item

 Copy of the original manifest and/or shipping paper.

Respondent Activities

· Contact the generator to obtain the generator’s instructions for forwarding the waste to another facility

that can manage the waste, as required by 40 CFR 264.72(d) or 265.72(d).

· Complete Item 18a and 18b of the original manifest, as applicable, by supplying the information on the

next destination facility or the generator in the Alternate Facility space.

· Retain a copy of the manifest.

· Give the remaining copies back t o the transporter.

(e) Unmanifested Waste Report: Completion and Submission

Pursuant to 40 CFR 264.76 and 265.76, if the TSDF accepts a hazardous waste for treatment, storage, or disposal

from any off

- site source without an accompanying manifest or a sh ipping paper as described in 40 CFR

263.20(e)(2), and the waste is not excluded from the manifest requirement, the facility owner/operator must

prepare and submit a letter to USEPA.

Data Items

 The USEPA ID number, name, and address of facility.

 The date the facility received the waste.

 The USEPA ID number, name, and address of generator and transporter, if available.

 A description and quantity of each unmanifested hazardous waste the facility received.

 The method of treatment, storage, or disposal for each hazardous waste.

 The certification signed by the owner/operator of the facility or his authorized representative.

 A brief explanation of why the waste was unmanifested, if known.

Respondent Activities:

 Prepare and submit to USEPA a letter of the unmanifested waste within 15 days after receiving

the waste.

### 25



## 5

. AGENCY ACTIVITIES, COLLECTION METHODOLOGY & INFORMATION

MANAGEMENT

The following subsections discuss how USEPA will collect the information, what activities USEPA will perfor m

once the information has been received, and how USEPA will manage the information it collects under the

manifest system. The subsections also include a discussion of how the information collection requirements will

affect small entities.

5 A. Agency Act ivities

The Agency activities associated with the manifest requirements include the review of exception reports,

discrepancy reports, and unmanifested waste reports. The Agency reviews these reports to identify potentially

non

- compliant or otherwise unre solved activities that warrant Agency attention. For example, upon receipt of an

exception report, the Agency may conduct a follow

- up investigation to assist the generator in locating the

shipment. The Agency keeps these reports on file. In addition, US EPA requires manifest form printers to register

with USEPA, as provided under 40 CFR 262.21. The Agency will need to review, process, and keep records of

the data submitted. Note that, as provided under the regulations, manifests, shipping papers, contra ctual

agreements, and reclamation agreements are not formally submitted to USEPA, but must be kept on file at the

generator’s, transporter’s or TSDF’s location and made available to USEPA upon request. Accordingly, this

analysis does not include Agency ac tivities associated with review of these documents.

5 B. Collection Methodology & Management

Under the registry, USEPA will collect registrants’ initial applications under 40 CFR 262.21(b) through the

regular mail, although some registrants may voluntarily choose to send them by certified mail. USEPA will

examine each application to ensure that the registrant takes appropriate steps to control its tracking numbers and

print a quality manifest. USEPA will then request form samples from the regis trant through the mail. USEPA

will evaluate each registrant’s form samples to ensure they satisfy the print specifications at 40 CFR 262.21(f).

USEPA will then keep the forms on file for future reference. USEPA will post the name, manifest tracking

numb er suffix, and contact information of each approved registrant on its web site, so that the general public is

aware of who the approved registrants are, what suffixes have been approved, and how to contact registrants for

forms.

USEPA collects reports subm itted by waste handlers under the manifest system (e.g., exception reports

and discrepancy reports) through the regular mail, although some waste handlers may voluntarily choose to send

them by certified mail. USEPA reviews the reports to understand the s ituation at issue and take follow up action

as needed. USEPA keeps the files on record for future reference.

5 C. Small Entity Flexibility

The current regulations require both large and small quantity generators of hazardous waste to use the manifest to

track shipments of hazardous waste. However, the Agency has found that most small businesses do not generate

hazardous waste either at all or in large enough quantities to make them subject to regulation and, therefore, are

not affected by the manifest re quirements. Generators of less than 100 kg/month (conditionally exempt small

quantity generators) are exempted from manifest requirements. Also, USEPA has exempted from the manifest

requirements universal wastes (i.e., batteries, mercury thermostats, lam ps, and pesticides, as specified), spent

lead

- acid batteries going for recycling, and used oil being recycled or burned for energy recovery.

(1) Contractual Reclamation Agreements

A small quantity generator (SQG) is exempt from the manifest requirements w hen his hazardous

waste is reclaimed under a contractual agreement, and he complies with limited requirements,

including recordkeeping of the contractual agreement, as required by 40 CFR 262.20(e)(2).

(2) Exception Reports

### 26 

## The exception report requireme nts, under 40 CFR 262.42, for SQGs are less stringent than those

for large quantity generators (LQGs). A SQG is only required to submit to USEPA a legible copy

of the manifest with some indication he/she has not received confirmation of delivery and has 6 0

days to fulfill this requirement. LQGs, on the other hand, are required to contact the transporter

or facility owner/operator if he/she has not received a copy of the manifest within 35 days. In

addition, if 45 days have passed and the LQG still has no t received a signed copy of the manifest,

he/she must submit a copy of the manifest as well as a cover letter explaining the generator’s

efforts to locate the hazardous waste. Hence, the exception report requirements for SQGs are not

as burdensome.

5 D. Collection Schedule

(1) Registry Document Collection: Registrant Organizations

Before printing the manifest for use or distribution, registrants must submit an initial application,

three fully assembled manifests, and a description of the form samples to USEPA. USEPA will

either approve the registrant to print the forms, or request modification to the application and/or

samples before approval. In addition, registrants that would like to use a new tracking number

suffix, change the printing specificatio ns of their manifest, use a new printer, or typeset their

manifest subsequent to USEPA approval to print the manifest must submit additional

documentation (e.g., proposed suffix, manifest samples, brief description of the new printer’s

qualifications to pr int the manifest), as specified.

Before an approved registrant can change its form in regard to paper type, paper weight,

ink color of the instructions, or binding method, or before using a new printer, it must seek

USEPA approval by submitting new form s amples and, if applicable, a description of the new

printer. Note, however, that a registrant may request an exemption from the requirement to

submit form samples if the Agency is persuaded that a separate review of the registrant’s forms

would serve litt le purpose in informing an approval decision. Any approved registrant wanting to

update any information provided in its application must revise the application and submit it to

USEPA, along with an indication or explanation of the update, as soon as pract icable after the

change occurs.

Finally, an approved registrant must notify USEPA by phone or email as soon as it

becomes aware that it has duplicated manifest tracking numbers on forms that have been used or

distributed. The registrant must also provide information on its printing activities, if requested by

USEPA.

(2) Manifest and Other Document Collection: Generators, Transporters, and TSDFs

Since copies of manifests, shipping papers, contractual agreements, and reclamation agreements

are kept at the generator’s, transporter’s or TSDF’s location and not normally submitted to

USEPA, discussion of a collection schedule is not applicable.

(3) Exception Reports Collection: Generators

LQGs must submit exception reports to USEPA within 45 days of the dat e the waste was

accepted by the initial transporter, if he or she has not received a copy of the manifest signed by

the TSDF. SQGs must submit an abbreviated version of an exception report to USEPA within 60

days.

(4) Manifests Returned to Generators: De signated TSDFs

Designated TSDFs must return a signed and dated copy of the manifest to the generator within 30

days after delivery of the waste.

(5) Discrepancy and Unmanifested Waste Report Collection: Designated TSDFs

Designated TSDFs must submit discr epancy reports and unmanifested waste reports to USEPA

within 15 days of delivery of the waste to the TSDF.

6

. ESTIMATE OF BURDEN HOURS & COST

### 27



## The attached spreadsheet Exhibits 1 to 19 present USEPA’s estimates of burden hours and associated costs for al l

the information collection requirements covered in this ICR. The burden estimates for each activity presented in

spreadsheet Exhibits 1 through 18 include the burden hours (total and by labor type) per respondent, as well as the

overall burden hours for all respondents. Associated annual costs for all paperwork burden activities covered in

this ICR include annual labor, capital, and operation and maintenance (O&M) costs. According to the 1995

Paperwork Reduction Act, “burden” is defined as follows:

" T he term ‘burden’ means time, effort, or financial resources expended by persons to generate,

maintain, or provide information to or for a Federal agency, including the resources expended

for: (a) reviewing instructions; (b) acquiring, installing, and utili zing technology and systems (c)

adjusting the existing ways to comply with any previously applicable instructions and

requirements; (d) searching data sources; (e) completing and reviewing the collection of

information; and (f) transmitting or otherwise di sclosing the information. ” (PRA Section

3502(2)).

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.

(i)

. Estimating Labor Costs

( 6 A.1) Respondent Labor:

Table 6 estimates an average hourly respondent labor cost (overhead and fringe benefits loaded wage rates:

Table 6

Labor Category Labor Category Labor Category Labor Category Labor Category

Legal Lawyers $ 62.23 1

. 4845 $ 92.38

Managerial SOC 11

- 0000

Management

Occupations $ 50.69 1.4845 $ 75.25

Technical Industrial Engineering

Technicians $ 24.30 1.4845 $ 36.07

Clerical SOC 43

- 9061 Office

Clerks, General $ 13.58 1.4845 $ 20.16

* Data Source: US Bureau of Labor Statistics (BLS) Occupational Employment Statistics (OES) for May 2010

National Occupational Employment and Wage Estimates (averages across all NAICS codes):

http://www.bls.gov/oes/current/oes_nat.htm

** Loaded wage rates estimated by multiplying the unloaded wage rates by 1.4845, which represents addition of

two cost factors (i.e., Federal government civilian wage full fringe benefit cost factor of 36.45%, plus 12%

overhead cost factors) from Figure C1 of the 29 May 2003 OMB Circular A

- 76: Performance of Commercial

Activities: http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html

( 6 A.2) Agency Labor:

Table 7 estimates th e Agency hour and cost burden associated with the new information collection requirements

covered in this ICR in Exhibit 19. Based on the General Schedule (GS) Salary Table 2004 , USEPA estimates the

following average hourly labor costs (overhead and fring e benefit loaded wage rates):

### 28 

## Table 7

Labor Category BLS Standard

Occupational

Category (SOC) code May 20 10

Unloaded

Wage Rate

($/hour)* Fringe/Overhead

Multiplier May 20 10 Loaded

Wage Ra te

Legal SOC 23

- 1011

Lawyers $ 39.51 1

. 6 $ 63.22

Managerial SOC 11

- 0000

Management

Occupations $ 38.36 1. 6 $ 61.38

Technical Environmental

Science & Protection $ 22.85 1. 6 $ 36.56

Clerical SOC 43

- 9061 Office

Clerks, General $ 15.03 1. 6 $ 24.05

· US Bureau of Labor Statistics (BLS) Occupational Employment Statistics (OES) for May 2010 National

Industry

- Specific Occupational Employment & Wage Estimates for NAICS 999200 State Government:

http://www.bls.gov/oes/current/naics4_999200.htm US Bureau of Labor Statistics (BLS)

Occupational Employment Sta tistics (OES) for May 2010 National Industry

- Specific Occupational

Employment & Wage Estimates for NAICS 999200 State Government:

http://www.bls.gov/oes/current/naics4_999200.htm US Bureau of Labor Statistics (BLS)

Occupational Employment Statistics (OES) for May 2010 National Industry

- Specific Occupational

Employment & Wage Estimates for NAICS 999200 State Government:

http://www.bls.gov/oes/current/naics4_999200.htm

** Loaded wage rates estimated by multiplying the unloaded wage rates by 1.6, which incorporates Federal

benefits into hourly wages. The 1.6 benefits multiplier is taken from the ICR Handbook section 6(c), page A

- 31.

It can be found at: http://intranet.epa.gov/icrintra/ivb.html

(iii) Respondent O&M Costs

O&M costs are those costs associated with a paperwork requirement incurred continually over the life of the ICR.

They are defined by the Paperwork Reduction Act of 1995 as “the recurring dollar amount of costs associated

with O&M or purchasing services.” For this ICR, O&M c osts include:

· Mailing costs: USEPA estimates that respondents will incur a cost of $ 0. 44 to mail a n one

- ounce package ($ 0.041 for postage and $0.0 3 for standard

- size envelope). USEPA also estimates that

respondents will incur a cost of $ 4. 53 for mailing a larger package (i.e., a five

- ounce package) by certified

mail ($ 1. 6 8 for postage, $ 2. 8 5 for the certified

- mail fee, and $0.0 8 for a manila envelope).

· Photocopying costs: USEPA estimates that respondents will incur a cost of $0.10 for each photocopy

the y make.

· Long distance telephone call costs: USEPA estimates that respondents will incur a cost of $2.00 for each

long distance telephone call they make.

· Printing cost for sample manifests: USEPA estimates that respondents will incur a cost of $500 for ea ch

set of manifest form samples. These respondents are expected to contract with a printing company.

Hence, the fee of $500 is considered a lump

- sum cost.

These O&M costs are shown in Exhibits 1 through 19 for all applicable respondent activities.

(iv) Respondent Capital Costs

### 29



## Capital costs usually include any produced physical good needed to provide the needed information, such as

machinery, computers, and other equipment. For this ICR, USEPA estimates that respondents will incur capital

costs associ ated with the purchase of banker boxes for manifest storage, estimated by the following steps:

· Annual manifest copies for file storage: Under the manifest system, generators, transporters, and

designated TSDFs must keep copies of manifests and other mani fest

- related documents for a period of

three years (the RCRA manifest is printed as a six

- copy form). In addition, as of 2001, 34 state

governments collect at least one completed manifest copy representing 76% of annual manifests, and

some states collect two copies, both initial and final (source: USEPA

- OSW “Economics Background

Document” for the final rule). Thus, at any given time during the effective period of this ICR, the

hazardous waste industry and state governments are keeping about four copies of three years’ worth of

RCRA manifests:

[( 1,887,404 manifests/year) x (3 years retention) x (4 copies/manifest)] = 22,648,852 copies/year

· Number of banker boxes needed: USEPA estimates that a 15 inch long storage banker box holds 2,700

pages and costs $ 6.67 each. 12 

## Thus, for storing copies of RCRA manifests, waste handlers would need to

purchase the following number of banker boxes each year:

[( 22,648,852 manifest copies/year) / (2,700 copies/banker box)] = 8,388 banker boxes/year

[ ( 8,388 banker boxes/year) x ($ 6.67 /banker box)] = $ 55,948 /year

· Warehouse needed: USEPA estimates that the 8,388 banker boxes will be stored in a warehouse, and the

warehouse lease space per box is 7.5 square feet. 13 

## The square foot lease cost for storage box

warehousing is $ 6.17

.

· Annual leasing Cost of warehouse: [( 8,388 banker boxes/year) x ($ 6.17 leasing cost/sq.ft.) x 7.5 sq.ft.

lease space/ box)] = $ 388,155 /year 14



## · Annualized cost of storage boxes and warehousing = $ 55,948 /year + $ 388,155 /year = 444,103 /year

Itemized Estimates of Burden Hours and Costs

Based on the labor wage rates and capital and O&M cost assumptions presented above, the attached spreadsheet

Exhibits 1 to 18 present USEPA’s estimates of respondents’ burden hour and costs associated wi th all the

requirements covered in this ICR. Exhibit 19 presents USEPA’s estimate of Agency burden.

(a) Registrant Organization Requirements

(a1) Reading the Regulations

Exhibit 1 presents the total annual hour and cost burden to registrant organizations in reading the manifest

regulations at 40 CFR 262.21. USEPA expects that on average, 14 registrant organizations will read 40 CFR

262.21 regulations each year.

(a2) Applying to the Registry

USEPA estimates that each year, 3 entities will r egister with USEPA to print their own forms. As shown in

Exhibit 1, USEPA estimates that all 3 entities registering with USEPA will submit an application, three fully

assembled manifests, and a description of the manifest form samples, as required by 40 C FR 262.21(b) and (d).

USEPA further estimates that, each year, all registrants (i.e., three registrants) will need to prepare and submit a

revised application under 40 CFR 262.21(c). USEPA expects that 67% of the registrant s (i.e., 2 registrants) will

need to submit revised manifest form samples under 40 CFR 262.21(e).

12 Banker storage box cost b ased on price for (180 paper sheets per inch) x (15 inched deep box) advertised price from

http://www.specialmoving.com/Boxes.html

13 Lease space per square foot is base on Source: (1.5ft box width x 2ft depth)+(1.5ftx3ft frontage walkspace)

14 Calculated by adjusting the 2007 ICR update figure, $5.68, to July 2011 dollars. Inflation between May 2007 and July 2011 was calculated to be

8.64% using CPI data from the BLS. The original figure from the 2007 ICR renewal was from: May 2007 US average from:

http:/ /www.bizlex.com/story.php?id=443

### 30



## (a3) Updating General Information in the Approved Application

USEPA estimates that, each year, one registrant organization will revise and submit its application to USEPA,

along w ith an indication or explanation of the update, under 40 CFR 262.21(h)(1). USEPA further estimates that

no registrant organization will need to respond to USEPA’s concerns regarding its revised application during the

3

- year period covered by this ICR. US EPA will provide print guidance to each prospective registrant on the

USEPA website to assist them in designing an approvable form, minimizing the likelihood that they will be asked

to resubmit samples to the registry.

(a4) Requesting App roval for a New Tracking Number Suffix

EPA estimates that no approved registrant organization will request a new tracking number suffix during the 3

- year period covered by this ICR. Because each manifest tracking number consists of the three

- letter suffi x and

nine digits, each registrant will be able to generate more than 999 million forms using its original suffix. USEPA

does not expect a registrant to request a new suffix for many years.

(a5) Requesting Approval for Changes to Printing Specifications or Use of a New Printer

USEPA estimates that no registrant organization will request approval for changes to its form or for the use of a

new printer during the 3

- year period covered by this ICR, assuming that each registrant will be forward looking

when originally applying to the registry. Applicants will determine the appropriate paper type, paper weight, and

other form aspects, so that they will not need to seek changes to their forms subsequent to their approval under 40

CFR 262.21(e).

(a6) Typesett ing the Manifest Form Subsequent to its Approval

USEPA estimates that no registrant organization will typeset its manifest form, instead of using the electronic file

of the forms provided by USEPA, during the 3

- year period covered by this ICR. Upon appro val of a registrant’s

application under 40 CFR 262.21(c), USEPA will provide it with an electronic file of the manifest, continuation

sheet, and instructions and ask it to use these files to develop the forms. In its consultations, USEPA found that

printe rs intend to share these files among their printing establishments so that none will need to typeset the form.

Typesetting the form would be unappealing to registrants because of the level of effort required in comparison

with using the electronic files.

(a7) Requesting an Exemption

USEPA estimates that, each year, one registrant organization will submit a request for an exemption under 40

CFR 262.21(j). As mentioned, USEPA expects each registrant to be forward looking when originally registering

under 40 CFR 262.21(b) through (e), and carefully select the appropriate paper type, paper weight, and other

aspects of the form. Therefore, few, if any, are expected to request changes to the approved form subsequent to

approval.

(a8) Notifying USEPA of a Pr inting Specification Violation

EPA estimates that no registrant organization will notify USEPA that it has duplicated tracking numbers on forms

used or distributed to other parties. Registrants must print their forms according to their approved applicati ons,

which will lay out procedures for tightly controlling their tracking numbers and ensuring that each manifest has a

unique number. Because of these assurances, USEPA expects that no registrant will duplicate its numbers and

notify USEPA.

(a9) Revisin g the Approved Manifest if Requested by USEPA

USEPA estimates that no registrant organization will need to submit revised manifest form samples, per USEPA’s

request, during the 3

- year period covered by this ICR. USEPA will carefully review each registran t’s forms under

### 31



## 40 CFR 262.21(e) to determine if they satisfy the requirements of 40 CFR 262.21(f). USEPA does not expect to

identify problems in forms that have been approved.

(a10) Responding to Suspension and Revocation Procedures

USEPA does not expect to conduct suspension or revocation procedures during the 3

- year period covered by this

ICR. The registration process under 40 CFR 262.21(b) through (e) will ensure that each approved registrant is

capable of tightly controlling its tracking number s and printing forms consistent with the approved samples and

the print specifications. Therefore, USEPA anticipates it will rarely invoke its suspension and revocation

procedures.

(b) Generator Requirements

(b1) Reading the Regulations

Exhibit 2 prese nts the total annual hour and cost burden to hazardous waste generators in reading the manifest

regulations at 40 CFR 262. In total, USEPA expects that 131,803 generators will read the 40 CFR 262

regulations each year.

### 32



## (b2) Manifest Com

pletion

Exhibits 3 and 4 present the total annual hour and cost burden for generators to complete their manifests. Note that the

exhibits reflect the fact that destination sites (referred to as designated TSDFs) often provide assistance to their generato r

customers in preparing manifests for shipments to their facility. For purposes of analysis, this ICR assumes that a

percentage of LQGs and SQGs rely on the designated TSDFs’ assistance in manifest preparation, while the remaining

LQGs and SQGs, as well as all TSDFs acting as generators, prepare their manifests themselves, as follows:

· Completing the Manifest w ithout the Assistance of Designated TSDF: Based on consultations with hazardous

waste generators and the States, USEPA estimates that about 58% of LQG manifests and 20% of SQG manifests

accompanying hazardous waste shipments are prepared without the assistance of the designated TSDF. This is

reflected in Exhibit 3. In addition, USEPA estimates that about 5% of manifests include continuation sheets

.

· Completing the Manifest With the Assistance of Designated TSDF: As discussed, USEPA recognizes that many

LQGs and SQGs rely on the assistance of the designated TSDF to complete the manifest form. Because the

designated TSDF normally fills out most of t he manifest form for the generator, the collaborative effort

significantly reduces the burden on generators. Based on its consultations, USEPA estimates that about 42% of

manifests from LQGs and 80% of manifests from SQGs are jointly completed with the de signated TSDF. This is

reflected in Exhibit 4. [Note: Refer to Exhibit 14 for the hour and cost burden for designated TSDFs to assist

LQGs and SQGs in completing their manifests.]

(b3) Compliance with State Program Requirements

40 CFR 262.21(g)(2) provides that generators must determine whether they are required to comply with requirements

specific to State hazardous waste manifest programs. As shown in Exhibit 5, USEPA assumes that each generator must

contact, on average, three State manifest prog rams each year. Because these activities are already required under State

hazardous waste programs, they are not burdened in this ICR.

(b4) Manifest Transmittal and Recordkeeping

As shown in Exhibit 6, USEPA estimates that LQGs, TSDFs acting as generato rs, and SQGs will send 3% of their

manifests with water shipments and 6% with rail shipments. Generators must comply with the requirements of 40 CFR

262.23, 262.24, and 262.40 when transmitting and keeping records of the manifest, as appropriate. In addi tion, USEPA

estimates that, each year, LQGs, TSDFs acting as generators, and SQGs will send 19,509 manifests with exports of

hazardous waste and 18,874 manifests with imports of hazardous waste. Finally, USEPA estimates that approximately

26,257 SQGs ship their hazardous waste off site under a reclamation agreement, pursuant to 40 CFR 262.20. These SQGs

are required to keep a copy of the contractual agreement under which their hazardous waste is shipped to the recycling

facility.

(b5) Undeliverable Ship ments

Based on consultations as shown in Exhibit 7, USEPA estimates that roughly 0.10% of shipments cannot be delivered to

the designated TSDF each year. Generators must provide instructions to the transporter on how to deal with these

shipments, as requ ired by 40 CFR 262.20(d) and 262.54(g)(3).

(b6) Rejected Waste and Container Residues

As shown in Exhibit 8, USEPA estimates that, each year, a total of 586 shipments initiated by generators will be rejected

by designated TSDFs and sent back to the gener ator (see Table 8). Upon receipt of the rejected shipments, generators must

sign the manifest that accompanies the rejected load or residue.

(b7) Exception Reports: Completion, Submission, and Recordkeeping

EPA estimates that, on average, LQGs, TSDFs acting as generators, and SQGs will need to develop an exception report

under 40 CFR 262.42 for approximately 0.5% of the manifests sent off site. This assumption is reflected in Exhibit 9.

### 33



## (c) Transporter Requirements

(c1) Reading the Regulations

As shown in Exhibit 10, there are reportedly 304 hazardous waste transporter companies subject to the RCRA

manifest system. USEPA expects that each company will read the manifest regulations once a year.

(c2) Manifest Completion, Transmittal, and Recordk eeping

Exhibit 11 examines the manifesting hour and cost burden for transporters transporting domestic and international

shipments of hazardous waste. USEPA estimates that, of the manifests completed and transmitted each year for

domestic and import ship ments, approximately 91% will accompany highway shipments, 3% will accompany

water shipments, and 6% will accompany rail shipments. USEPA further estimates that 18,875 manifest forms

will accompany imports and 19,509 manifest forms will accompany exports to non

- designated OECD countries.

Finally, USEPA estimates that transporters transporting hazardous waste shipments under a reclamation agreement

will need to comply with 40 CFR 263.20(h).

(c3) Undeliverable Shipments

In Exhibit 11 EPA estimates that ea ch year transporters will be unable to deliver approximately 1,888 shipments of

hazardous waste they have accepted from a generator or a transporter to the designated facility listed on the

manifest, the alternate designated facility, the next designated t ransporter, or the place outside the US designated

by the generator. These transporters will have to contact the generator for further directions and revise the

manifest according to the generator’s instructions, as required by 40 CFR 263.21.

(d3) Reject ed Waste and Container Residues

Exhibit 11 also provides an estimate that each year 3,113 shipments are partially rejected while the transporter is

still on the premises. The transporter must follow applicable procedures for obtaining the manifest from t he

facility and, if it accepts the forwarded shipment, it must obtain the new manifest. USEPA estimates that 31,129

shipments initiated by generators will be fully rejected by the designated TSDF while the transporter is on the

facility’s premises. For t hese shipments, the transporter must follow applicable procedures for obtaining the

original manifest from the facility in order to forward the waste to the alternate facility or generator.

(d4) Notification of Discharge of Hazardous Waste

The Statistical Abstract of the United States , released in 200 9 by the US Census Bureau indicates that there were

14,822 accidents involving transporters of hazardous substances in 2009 . Of these, USEPA estimates that

approximately 5% ( 741 ) involved hazardous waste transporters who had a discharge of hazardous waste. In

Exhibit 12, USEPA used its best professional judgment to estimate that approximately 741 hazardous waste

transporters will be required to notify local authorities of a hazardous waste discharg e annually, as required under

40 CFR 263.30.

In addition, the NRC indicates that it received approximately 4,527 notifications of marine source

incidents in 200 9 for discharges of oil or hazardous substances. NRC estimates that about 66% of these incide nts

involved oil discharges ( 3,033 ) and that 33% involved hazardous substances discharges ( 1,494 ). Of the 1,494

discharges of hazardous substances, NRC estimates that 5% ( 7 5 ) involved a hazardous waste. As shown in Exhibit

12, USEPA expects that, on aver age, 75 water transporters transporting hazardous waste will notify NRC or

USEPA under 33 CFR 153. The purpose of 33 CFR 153 is to prescribe regulations concerning notification to the

US Coast Guard of the discharge of oil or hazardous substances as requi red by the Federal Water Pollution Control

Act, as amended; the procedures for the removal of a discharge of oil; and the costs that may be imposed or

reimbursed for the removal of a discharge of oil or hazardous substances.

(d) Designated Treatment, Stor age, and Disposal Facility Requirements

(d1) Reading the Regulations

### 34



## Based on USEPA’s 200 9 RCRA Hazardous Waste Biennial Report (BR) data, USEPA estimates that 577 TSDFs

receive off

- site shipments of hazardous waste each year. As shown in Exhibit 13, USEPA expects that each

facility will read the manifest regulations once a year.

(d2) Manifest Completion, Transmittal, and Recordkeeping

Exhibit 14 presents USEPA’s estimates that approximately 42% and 80% of manifests from LQGs and SQGs,

respectively, are completed jointly with the designated TSDF. In addition, USEPA estimates that 5% of these

manifests include continuation sheets.

Exhibit 15 presents the burden to designated TSDFs for receiving and completing manifests that are not

rejected and that do not result in a container residue.

(d3) Compliance with State Program Requirements

40 CFR 264.71(e) and 265.71(e) provides that TSDFs must determine whether they are required to comply with

requirements specific to State hazardous waste manifest pro grams. USEPA assumes that each TSDFs must

contact, on average, three State manifest programs each year. Because these activities are already required under

State hazardous waste programs, they are not burdened in this ICR. This is reflected in Exhibit 1 5.

(d4) Discrepancy Reports

As shown in Exhibit 15, USEPA estimates that approximately 25% of manifests accepted by the designated TSDF

require reconciling discrepancies between the manifest data and the shipment (e.g. by phoning the generator).

USEPA f urther estimates that about 0.4% of manifests accepted by the designated TSDF will require a discrepancy

report under 40 CFR 264.72 or 265.72.

(d5) Rejected Waste and Container Residues

· Rejection of Waste after the Transporter Leaves the Facility: As shown in Exhibit 16, USEPA estimates that each

year designated TSDFs will reject a shipment or identify a container residue after the transporter has left the

TSDFs' premises for 31,129 hazardous waste shipments received.

· Rejection of Waste while the Trans porter Remains Present at the Facility: As shown in Exhibit 16, USEPA

estimates that each year designated TSDFs will fully reject or identify a container residue while the transporter is

on the TSDFs' premises for 31,129 hazardous waste shipments received

.

· Manifest Completion by the Alternate TSDF: Also shown in Exhibit 16, USEPA estimates that each year

designated TSDFs will reject a total of 62,298 shipments and forward 61,635 shipments to an alternate TSDF (see

Table 8).

(d6) Unmanifested Waste Reports: Completion and Submission

As shown in Exhibit 17, USEPA estimates that designated TSDFs will need to complete approximately 185 letters

notifying the Agency of unmanifested waste shipments each year, as required under 40 CFR 264.76 or 265.76.

6 E. Bottom Line Burden Hours & Cost

National aggregate respondent and Agency burden hour and associated costs are summarized below, as estimated

in spreadsheet Exhibits 1 to 20 provid ed as an appendix to this document. Cumulative burden hours and costs are

based on a 3

- year time

- span over which the ICR is effective, and over which USEPA averaged burden and cost

estimates. Therefore, cumulative burden is equal to annual burden estimat es multiplied by three.

### 35



## Respondent Burden (Exhibits 1 to 18): 3,472,218 hours at an average annual cost of $ 105,221,281 , including

$ 974,463 per year capital cost and $ 2,092,291 per year O&M cost. Cumulative burden to respondents over three

years is 10,4 16,654 hours at a cost of $ 315,663,844

.

Agency Burden (Exhibit 19): About 10,413 hours at an average annual cost of $ 496,693 . Cumulative burden to

the Agency over three years is 31,239 hours at a cost of about $ 1, 490,079

.

Total Burden (Respondents + Age ncy): 3,482,631 million hours at an average annual cost of $ 105, 717,974

. Cumulative total burden over three years is 10,447,893 hours at a cost of $ 317,153,923

.

6 F. Reasons for Change in Burden

This current ICR (#801.1 8 ) renews and updates the previously approved ICR (#801.1 6 ). ICR #801.1 6 estimated a

total annual respondent burden of 3,743,122 hours. This ICR estimates a total annual respondent burden of

3, 472,218 hours, which is a decrease of 2 70,904 hours

. The reason for the change in burd en is primarily due to the

decrease in the number of entities affected by the respondent activities detailed in this ICR supporting document

. As mentioned previously, US E PA used 2009 BR data to update its estimates of waste handlers (e.g., SQGs, LQGs,

and TSDFs ) subject to the Federal manifest requirements . The previously approved ICR estimated 190,628 annual

respondents were subject to the recordkeeping and reporting activities . The annual respondents for this ICR

renewal cycle decreased to 161,720. Th e effect of th is reduction reduced the projected number of manifests

completed annually (1,887,404) by 9.03% (projected number for previously approved ICR was 2,074,900).

6 G. Burden Statement

Table 8 summarizes the estimated average burden hours for rep orting and recordkeeping per affected entities (i.e.

registrants, generators, transporters, and TSDFs) under USEPA’s final rule revising the RCRA hazardous waste

manifest system.

Reporting burden : For generators includes time for reviewing and signing th e manifest (i.e. for generators whose

manifests are prepared by TSDFs). May also include time for preparing the entire manifest and submitting an

exception report to USEPA. For transporters includes time to carry copies during shipment. For TSDFs includ es

time for reviewing the manifest at shipment delivery and transmitting a copy to the generator. May also include

time for preparing a generator’s manifest and submitting a discrepancy report to USEPA.

Recordkeeping burden : For generators includes time reading the regulations once per year and keeping copies of

the initial manifest and final manifest received from the TSDF. For LQGs and TSDFs, it may also include time for

keeping a copy of an exception report. For transporters and TSDFs, the recordkeep ing burden includes time for

reading the regulations once per year and keeping a copy of the manifest accompanying the shipment.

Table 8 : Summary of Disaggregate Paperwork Burden Hours (Per Affected Entity Per Waste

Shipment)

Respondent Type Reporting

Burden

(Hours) Recordkeep

ing Burden

(Hours) Total

Burden

(Hours)

1 Manifest printer registrants 1.72

- 2.42 1.25 2.97

- 3.67

2 Hazardous Waste Generators

Large Quantity

Generators (LQGs) 0.04

- 1.84 1.45

- 1.55 1.49

- 3.39

TSDFs acting as

generators 0.54

- 1.87 1.45

- 1.55 1.99

- 3.42

Small Quantity 0.04

- 1.20 1.45 1.49

- 2.65

### 36



## Table 8 : Summary of Disaggregate Paperwork Burden Hours (Per Affected Entity Per Waste

Shipment)

Respondent Type Reporting

Burden

(Hours) Recordkeep

ing Burden

(Hours) Total

Burden

(Hours)

Generators (SQGs)

3 Transporters 0.17

- 2.80 1.42 1.59

- 4.22

4 Designated TSDFs 0. 4 3

- 1. 4 1 1.42

- 1.59 1. 8 5

- 3. 0 0

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

average about 2 hours per response. Burden means the total time, effort, and financial resources expended by

persons to generate, maintain, retain, dis close, 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 source s; 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 minimiz ing respondent burden, including the use of automated collection techniques,

EPA has established a public docket for this ICR under Docket ID No. EPA

- HQ

- RCRA

- 20 11

- 0750 , 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 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 f

or the Reading Room is (202)566

- 1744, and the telephone number for RCRA Docket is

(202)566

- 0270. An electronic version of the public docket is available at www.regulations.gov. This site can be

used to submit or view public comments, access the index lis ting 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 Of fice 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

- 2011

- 0750 and OMB Control

Number 2050

- 0039 in an y correspondence.

### 37

### 38

EXHIBIT 2

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

READING THE REGULATIONS

Hours per Generator

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Generators Total

Hours Total Cost

Read the regulations

LQGs 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 14,381 17,976 $789,202

TSDFs 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 1,468 1,835 $80,564

SQGs 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 145,871 182,339 $8,005,400

TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 161,720 202,150 $8,875,166

a Exhibit contains rounding error.

EXHIBIT 3

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

COMPLETING THE MANIFEST (WITHOUT ASSISTANCE

OF DESIGNATED TSDFs)

Hours per Generator

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion: LQGs (262.20)

Complete the manifest 0.00 0.00 0.40 0.10 0.50 $16.44 $0.00 379,835 189,918 $6,244,487

Complete the continuation sheet 0.00 0.00 0.19 0.04 0.23 $7.66 $0.00 18,992 4,368 $145,479

Subtotal (for LQGs) 0.00 0.00 varies varies varies varies $0.00 379,835 194,286 $6,389,966

Manifest completion: TSDFs who are also generators (262.20)

Commercial TSDFs

Complete the manifest 0.00 0.00 0.43 0.10 0.53 $17.53 $0.00 127,513 67,582 $2,235,301

Complete the continuation sheet 0.00 0.00 0.18 0.04 0.22 $7.30 $0.00 6,376 1,403 $46,545

Captive TSDFs

Complete the manifest 0.00 0.00 0.43 0.10 0.53 $17.53 $0.00 39,240 20,797 $687,879

Complete the continuation sheet 0.00 0.00 0.18 0.05 0.23 $7.50 $0.00 1,962 451 $14,715

Subtotal (for TSDFs) 0.00 0.00 varies varies varies varies $0.00 166,753 90,233 $2,984,440

Manifest completion: SQGs (262.20)

Complete the manifest 0.00 0.00 0.40 0.08 0.48 $16.04 $0.00 213,153 102,313 $3,418,974

Complete the continuation sheet 0.00 0.00 0.18 0.03 0.21 $7.10 $0.00 10,658 2,238 $75,672

Subtotal (for SQGs) 0.00 0.00 varies varies varies varies $0.00 213,153 104,551 $3,494,646

TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 varies varies varies varies $0.00 759,741 389,070 $12,869,052

a Exhibit contains rounding error.

### 39

EXHIBIT 4

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

COMPLETING THE MANIFEST (WITH ASSISTANCE OF

DESIGNATED TSDFs)

Hours per Generator

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion: LQGs (262.20)

Complete the manifest 0.00 0.00 0.02 0.01 0.03 $0.92 $0.00 275,053 8,252 $253,049

Manifest completion: SQGs (262.20)

Complete the manifest 0.00 0.00 0.02 0.01 0.03 $0.92 $0.00 852,610 25,578 $784,401

TOTAL (LQGs and SQGs) 0.00 0.00 0.02 0.01 0.03 $0.92 $0.00 1,127,663 33,830 $1,037,450

a Exhibit contains rounding error.

EXHIBIT 5

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

COMPLIANCE WITH STATE PROGRAM

REQUIREMENTS

Hours per Generator

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Phone

Calls Total

Hours Total Cost

Compliance with State program requirements: LQGs (262.21(g))

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 43,142 0 $0

Compliance with State program requirements: TSDFs who are also generators (262.21(g))

Commercial TSDFs

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 1,101 0 $0

Captive TSDFs

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 3,303 0 $0

Subtotal (for TSDFs) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 4,404 0 $0

Compl iance with State program requirements: SQGs (262.21(g))

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 358,843 0 $0

TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 406,388 0 $0

a Exhibit contains rounding error.

### 40

EXHIBIT 6

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

TRANSMITTING THE MANIFEST

Hours per Generator Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest transmittal and recordkeeping: LQGs

Manifest (262.23(a), 262.23(b), and 262.40(a))

Sign the manifest certification and obtain the

signature of the initial transporter and date of

acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 654,888 6,549 $235,760

Keep a copy of the manifest and give the

remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 654,888 65,489 $1,322,875

Keep a copy of the manifest returned from the

designated facility 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 654,888 65,489 $1,322,875

For shipments solely by water, send three copies

of the manifest, dated and signed, to the

designated facility or th e last water transporter to

handle the waste in the U.S. 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 19,647 3,144 $72,694

For shipments by rail originating at the site of

generation, send at least three copies of the

manifest to the next non

- rail transporter, the

designated facility, or the last rail transporter to

handle the waste in the U.S. 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 39,293 6,287 $145,384

Exports (262.54(h) and (i))

Provide the transporter with an EPA

Acknowledgment of Consent and an additional

copy of the manifest or shipping papers for

delivery to the U.S. Customs official at the point

the hazardous waste exits the U.S. 0.00 0.00 0.00 0.25 0.25 $5.04 $0.10 9,169 2,292 $47,129

Subtotal (for LQGs) 0.00 0.00 varies varies varies varies varies varies 149,250 $3,146,717

EXHIBIT 6 (CONTINUED)

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

TRANSMITTING THE MANIFEST

Hours per Generator Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest transmittal and recordkeeping: Commercial TSDFs

Manifest (262.23(a), 262.23(b), and 262.40(a))

Sign the manifest certification and obtain the

signature of the initial transporter and date of

acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 127,513 1,275 $45,905

### 41

Keep a copy of the manifest and give the

remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 127,513 12,751 $257,576

Keep a copy of the manifest returned from the

designated facility 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 127,513 12,751 $257,576

For shipments solely by water, send three copies

of the manifest, dated and signed, to the

designated facility or the last water transporter to

handle the waste in the U.S.(Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 3,825 612 $14,153

For shipments by rail originating at the site of

generation, send at least three copies of the

manifest to the next non

- rail transporter, the

designated facility, or the last rail transporter to

handle the waste in the U.S. (Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 7,651 1,224 $28,309

Exports (262.54(h) and (i))

Provide the transporter with an EPA

Acknowledgment of Consent and an additional

copy of the manifest or shipping papers for

delivery to the U.S. Customs official at the point

the hazardous waste exits the U.S. 0.00 0.00 0.00 0.25 0.25 $5.04 $0.10 1,561 390 $8 ,023

Subtotal (for Commercial TSDFs) 0.00 0.00 varies varies varies varies varies varies 29,003 $611,542

EXHIBIT 6 (CONTINUED)

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

TRANSMITTING THE MANIFEST

Hours per Generator Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest transmittal and recordkeeping: Captive TSDFs

Manifest (262.23(a), 262.23(b), and 262.40(a))

Sign the manifest certification and obtain the

signature of the initial transporter and date of

acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 39,240 392 $14,126

Keep a copy of the manifest and give the

remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 39,240 3,924 $79,265

Keep a copy of the manifest returned from the

designated facility 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 39,240 3,924 $79,265

For shipments solely by water, send three copies

of the manifest, dated and signed, to the

designated facility or the last water transporter to

handle the waste in the U.S.(Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 1 ,177 188 $4,355

For shipments by rail originating at the site of

generation, send at least three copies of the

manifest to the next non

- rail transporter, the

designated facility, or the last rail transporter to

handle the waste in the U.S. (Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 2,354 377 $8,709

### 42

Exports (262.54(h) and (i))

Provide the transporter with an EPA

Acknowledgment of Consent and an additional

copy of the manifest or shipping papers for

delivery to the U.S. Customs official at the point

the hazardous waste exits the U.S. 0.00 0.00 0.00 0.25 0.25 $5.04 $0.10 585 146 $3,007

Subtotal (for Captive TSDFs) 0.00 0.00 varies varies varies varies varies varies 8,951 $188,727

EXHIBIT 6 (CONTINUED)

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

TRANSMITTING THE MANIFEST

Hours per Generator Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest transmittal and recordkeeping: SQGs

Manifest (262.23(a), 262.23(b), and 262.40(a))

Sign the manifest certification and obtain the

signature of the initial transporter and date of

acceptance on the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,065,763 10,658 $383,675

Keep a copy of the manifest and give the

remaining copies to the initial transporter 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 1,065,763 106,576 $2,152,841

Keep a copy of the manifest returned from the

designated facility 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 1,065,763 106,576 $2,152,841

For shipments solely by water, send three copies

of the manifest, dated and signed, to the

designated facility or the last water transporter to

handle the waste in the U.S.(Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 31,973 5,116 $118,300

For shipments by rail originating at the site of

generation, send at least three copies of the

manifest to the next non

- rail transporter, the

designated facility, or the last rail transporter to

handle the waste in the U.S. (Domestic and

Exports) 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 63,946 10,231 $236,601

Exports (262.54(h) and (i))

Provide the transporter with an EPA

Acknowledgment of Consent and an additional

copy of the manifest or shipping papers for

delivery to the U.S. Customs official at the point

the hazardous waste exits the U.S. 0.00 0.00 0.00 0.25 0.25 $5.04 $0.10 8,194 2,049 $42,117

Reclamation agreements (262.20(e)(2))

Retain a copy of each reclamation agreement 0.00 0.00 0.00 0.10 0.10 $2.02 $0.00 26,257 2,626 $53,039

Subtotal (for SQGs) 0.00 0.00 varies varies varies varies varies varies 243,832 $5,139,414

TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 varies varies varies varies varies varies 431,036 $9,086,400

a Exhibit contains rounding error.

### 43

EXHIBIT 7

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

UNDELIVERABLE SHIPMENTS

Hours per TSDF

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Undeliverable shipmentst: LQGs (262.20(d) and 262.54(g)(3))

Designate another facility or instruct the

transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 655 52 $1,893

Undeliverable shipments: Commercial TSDFs (262.20(d) and 262.54(g)(3))

Designate another facility or instruct the

transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 128 10 $370

Undeliverable shipments: Captive TSDFs (262.20(d) and 262.54(g)(3))

Designate another facility or instruct the

transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 39 3 $113

Undeliverable shipments: SQGs (262.20(d) and 262.54(g)(3))

Designate another facility or instruct the

transporter to return the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 1,066 85 $3,081

TOTAL (LQGs, TSDFs, and SQGs) 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 1,888 150 $5,457

a Ex hibit contains rounding error.

EXHIBIT 8

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

REJECTED WASTE AND CONTAINER

RESIDUES

Hours per TSDF

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Rejected waste and container residues (262.34(j))

Sign Item 18c of the manifest, if the transporter

returned the shipment using the original

manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 311 3 $112

Sign Item 20 of the manifest, if the transporter

returned the shipment using a new manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 311 3 $112

Comply with new manifest rules presented in 75

FR 12989 0.00 0.00 0.01 0.00 0.01 $0.36 $0.44 623 6 $498

TOTAL 0.00 0.00 0.01 0.00 0.01 $0.36 $0.44 1245.160074 12 $722

### 44

EXHIBIT 9

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

GENERATORS a

DEVELOPING EXCEPTION REPORTS

Hours per Generator

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Reports Total

Hours Total Cost

Exception report completion, submission, and recordkeeping: LQGs (262.42(a)(i)

- (ii) and 262.40(b))

Prepare and submit a signed cover letter to EPA

explaining the generator’s efforts to locate the

hazardous waste and the results of those efforts,

along with a legible copy of the manifest 0.00 0.50 0.50 0.10 1.10 $57.68 $0.57 6,985 7,684 $406,876

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.02 $0.10 6,985 699 $14,809

Subtotal (for LQGs) 0.00 varies varies 0.10 varies varies $0.67 6,985 8,383 $421,685

Exception report completion, submission, and recordkeeping: Commercial TSDFs (262.42(a)(i)

- (ii) and 262.40(b))

Prepare and submit a signed cover letter to EPA

explaining the generator’s efforts to locate the

hazardous waste and the results of those efforts,

along with a legible copy of the manifest 0.00 0.50 0.50 0.10 1.10 $57.68 $0.57 645 710 $37,572

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.02 $0.10 645 65 $1,368

Subtotal (for Commercial TSDFs) 0.00 varies varies 0.10 varies varies $0.67 645 775 $38,940

Excep tion report completion, submission, and recordkeeping: Captive TSDFs (262.42(a)(i)

- (ii) and 262.40(b))

Prepare and submit a signed cover letter to EPA

explaining the generator’s efforts to locate the

hazardous waste and the results of those efforts,

alon g with a legible copy of the manifest 0.00 0.50 0.50 0.10 1.10 $57.68 $0.57 198 218 $11,534

Keep a copy of each exception report 0.00 0.00 0.00 0.10 0.10 $2.02 $0.10 198 20 $420

Subtotal (for Captive TSDFs) 0.00 varies varies 0.10 varies varies $0.67 198 238 $11,954

Excep tion report completion, submission, and recordkeeping: SQGs (262.42(b))

Submit a legible copy of the manifest with some

indication that the waste has not been delivered 0.00 0.25 0.25 0.00 0.50 $27.83 $0.57 5,329 2,665 $151,344

Subtotal (for SQGs) 0.00 0.25 0.25 0.00 0.50 $27.83 $0.57 5,329 2,665 $151,344

TOTAL (LQGs, TSDFs, and SQGs) 0.00 varies varies varies varies varies varies varies 12,061 $623,923

a Exhibit contains rounding error.

EXHIBIT 10

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

TRANSPORTERS a

READING THE REGULATIONS

Hours per Transporter

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Transporters Total

Hours Total Cost

Read the regulations

Transporters 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 304 380 $16,673

TOTAL 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 304 380 $16,673

### 45

EXHIBIT 11

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

TRANSPORTERS a

COMPLETING AND TRANSMITTING THE

MANIFEST

Hours per Transporter

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion, transmittal and recordkeeping: Transporters

Manifest requirements for highway transporters (263.20(b), 263.20(c), 263.20(d), and 263.22(a))

Sign and date the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,728,112 17,281 $622,120

Return a signed copy of the manifest to the

generator 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,728,112 17,281 $622,120

Ensure that the manifest (or other shipping

paper) accompanies the waste to its destination 0.00 0.00 0.13 0.00 0.13 $4.69 $0.00 1,728,112 224,655 $8,104,845

Obtain the date of delivery and signature of that

transporter or the owner/operator of the facility or

alternate facility designated on the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,728,112 17,281 $622,120

Retain a copy of the manifest 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 1,728,112 293,779 $5,927,424

Give remaining copies of the manifest to the

accepting transporter or facility 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,728,112 17,281 $622,120

Manifest requirements for person delivering to initial water transporters (263.20(e))

Obtain the date of delivery and signature of the

initial water transporter on the manifest 0.00 0.00 0.00 0.01 0.01 $0.20 $0.00 56,971 570 $11,394

Forward the manifest to the designated facility 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 56,971 9,115 $210,792

Manifest requirements for water (bulk shipment) transporters (263.20(e))

Ensure that the shipping paper (and

Acknowledgment of Consent, for exports)

accompanies the waste to its destination 0.00 0.00 0.13 0.00 0.13 $4.69 $0.00 56,971 7,406 $267,194

If the delivering (water) transporter, obtain the

date of delivery and signature of the

owner/operator of the designated facility on

either the manifest or shipping paper 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 56,971 570 $20,510

If the initial water transporter, sign and date the

manifest and return it to the delivering

transporter so that the manifest can be

forwarded to the designated facility

owner/operator 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 56,971 570 $20,510

Retain a copy of the manifest or shipping paper 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 56,971 9,685 $195,411

Manifest requirements for rail transporters (263.20(f) and 263.22(c))

When accepting waste from a non

- rail

transporter, sign and date the manifest and

return or transmit a signed copy of the manifest

to the non

- rail transporter 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 113,942 1,139 $41,019

Forward at least three copies of the manifest to

either the next non

- rail transporter, the

designated facility, or the last rail transporter

designated to handle the waste in the U.S. 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 113,942 18,231 $421,586

Ensure a shipping paper containing all the

information required on the manifest excluding

the U.S. EPA ID number, generator certification, 0.00 0.00 0.13 0.00 0.13 $4.69 $0.00 113,942 14,812 $534,388

### 46

and signatures (and for exports an

Acknowledgment of Consent) accompanies the

waste

When delivering hazardous waste to the

designated facility or to the next non

- rail

transporter, obtain the signature and date of

delivery of the facility or non

- rail transporter on

the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 113,942 1,139 $41,019

Retain a copy of the manifest and/or rail shipping

paper 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 113,942 19,370 $390,821

Before accepting hazardous waste from a rail

transporter, sign and date the manifest and

provide a copy to the rail transporter 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 113,942 1,139 $41,019

### 47

EXHIBIT 11 (CONTINUED)

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

TRANSPORTERS a

COMPLETING AND TRANSMITTING THE

MANIFEST

Hours per Transporter Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion, transmittal and recordkeeping: Transporters

Manifest requirements for transporters who transport waste into and/or out of the U.S. (263.20(g) and (i))

For imports and exports, sign and date the

manifest in the International Shipments block

to indicate the date that the shipment left the

U.S., as required by section 263.20(g)(1) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 38,384 384 $13,818

For imports and exports, retain a copy of the

manifest, as required by section 263.20(g)(2) 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 38,384 6,525 $131,657

For imports give copy of import manifest to

TSDF receiving facility 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 17,624 176 $6,345

For exports, return a signed copy of the

manifest to the generator, as required by

section 263.20(g)(3) 0.00 0.00 0.00 0.01 0.01 $0.20 $0.00 19,509 195 $3,902

For exports, give a copy of the manifest to a

U.S. Customs official at the point of departure

from the U.S., as required by section

263.20(g)(4) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.10 19,509 195 $8,974

For exports, ensure that copies of the

manifest and EPA Acknowledgment of

Consent accompanies the waste, as required

by section 263.20(a) 0.00 0.00 0.13 0.00 0.13 $4.69 $0.00 19,509 2,536 $91,497

Manifest requirements for transporters who transport waste pursuant to a reclamation agreement (263.20(h))

Record the waste information on a log or

shipping paper 0.00 0.25 0.75 0.00 1.00 $45.87 $0.00 26,257 26,257 $1,204,399

Carry the record when transporting waste to

the reclamation facility 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 26,257 263 $9,452

Retain the records 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 26,257 4,464 $90,061

Undeliverable shipments (263.21(b)(1))

Contact the generator for further directions

and revise the manifest according to the

generator’s instructions 0.00 0.00 0.08 0.00 0.08 $2.89 $2.00 1,888 151 $9,232

Rejected waste and container residues (263.21(b)(2))

For partially rejected loads made while the

transporter is on site, obtain the amended

manifest from the facility, keep a copy, and, if

receiving the rejected waste, obtain the new

manifest 0.00 0.00 0.10 0.00 0.10 $3.61 $0.00 3,113 311 $11,238

For fully rejected loads made or container

residues identified while the transporter is on

site, obtain the original manifest, as amended,

from the facility 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

TOTAL varies varies varies varies varies varies varies varies 713,072 $20,308,193

a Exhibit contains rounding error.

### 48

EXHIBIT 12

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR

TRANSPORTERS a

NOTIFYING OF DISCHARGE OF HAZARDOUS

WASTE

Hours per Transporter

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Notifications Total

Hours Total Cost

Notification of discharge of hazardous waste: Transporters (263.30(a))

Notify local authorities 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 741 926 $40,666

Notification of discharge of hazardous waste: Water (bulk shipment) Transporters (33 CFR 153.203)

Notify NRC, or a predesignated OSC, of the

discharge 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 75 94 $4,116

TOTAL 0.00 varies 1.00 0.00 1.25 $54.88 $0.00 varies 1,020 $44,782

a Exhibit contains rounding error.

EXHIBIT 13

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND

DISPOSAL FACILITIES (TSDFs) a

READING THE REGULATIONS

Hours per TSDF

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent TSDFs Total

Hours Total Cost

Read the regulations

TSDFs 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 577 722 $31,678

TOTAL 0.00 0.25 1.00 0.00 1.25 $54.88 $0.00 577 722 $31,678

a Exhibit contains rounding error.

EXHIBIT 14

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND

DISPOSAL FACILITIES (TSDFs) a

COMPLETING THE MANIFEST (ASSISTING

THE GENERATORS)

Hours per TSDF Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion: Designated TSDFs (264.71(a) and (b), or 265.71(a) and (b))

Complete the manifest 0.00 0.00 0.43 0.10 0.53 $17.53 $0.00 1,127,663 597,661 $19,767,932

Complete continuation sheets 0.00 0.00 0.18 0.05 0.23 $7.50 $0.00 56,383 12,968 $422,873

TOTAL 0.00 0.00 varies varies varies varies $0.00 1,127,663 610,629 $20,190,805

a Exhibit contains rounding error.

### 49

EXHIBIT 15

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE,

AND DISPOSAL FACILITIES (TSDFs) a

TRANSMITTING THE MANIFEST AND

REPORTING TO EPA

Hours per TSDF Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Manifest completion, transmittal and recordkeeping: Designated TSDFs (264.71(a) and (b), or 265.71(a) and (b))

Enter the name of the person accepting the

waste and sign and date each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 1,742,594 17,426 $627,334

Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.72 $0.00 1,742,594 34,852 $1,254,668

Note any discrepancies on each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 456,287 36,503 $1,318,669

Immediately give the transporter at least one

copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.13 $0.00 1,742,594 296,241 $10,682,101

Within 30 days of delivery, send a copy of the

manifest (or shipping paper) to the generator

(or to EPA

- OECA for import manifests) 0.00 0.00 0.00 0.15 0.15 $3.02 $0.47 1,760,218 264,033 $6,143,160

Retain a copy of the manifest (or shipping

paper) for at least three years from the

delivery date (includes import manifests) 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 1,760,218 299,237 $6,037,548

Subtotal (manifest completion, transmittal,

and recordkeeping) 0.00 0.00 varies varies varies varies varies varies 948,292 $26,063,480

Compliance with State program requirements: TSDFs who are also generators (264.71(e) and 265.71(e))

Commercial TSDFs

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 1,101 0 $0

Captive TSDFs

Contact the consignment/generator State if

needed and submit any copies of the manifest

to these States, as applicable 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 3,303 0 $0

Subtotal (for TSDFs) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 4,404 0 $0

Disc repancy report completion and submission: Designated TSDFs (264.72(c) or 265.72(c))

Attempt to reconcile any discrepancies 0.00 0.00 0.08 0.00 0.08 $2.89 $2.00 456,287 36,503 $2,231,243

Prepare and submit a letter to EPA describing

the discrepancy and attempts to reconcile it,

along with a copy of the manifest or shipping

paper at issue 0.00 0.10 0.17 0.10 0.37 $15.67 $0.57 7,301 2,701 $118,569

Subtotal (discrepancy report) 0.00 varies varies varies varies varies varies varies 39,204 $2,349,812

TOTAL 0.00 varies varies varies varies varies varies varies 987,496 $28,413,292

a Exhibit contains rounding error.

### 50

EXHIBIT 16

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE, AND

DISPOSAL FACILITIES (TSDFs) a

REJECTED WASTE AND CONTAINER RESIDUES

Hours per TSDF

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Manifests Total

Hours Total Cost

Rejected waste and container residues (264.72(d) through (g) and 265.72(d) through (g))

Rejection of Waste after the Transporter Leaves the Facility

Enter the name of the person accepting the

waste and sign and date each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.72 $0.00 31,129 623 $22,413

Immediately give the transporter at least one

copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.13 $0.00 31,129 5,292 $190,821

Within 30 days of delivery, send a copy of the

manifest (or shipping paper) to the generator 0.00 0.00 0.00 0.16 0.16 $3.23 $0.00 31,129 4,981 $100,547

Contact the generator to obtain the generator’s

instructions for forwarding the waste to another

facility that can manage the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $2.00 31,129 2,490 $152,221

Prepare a new manifest for rejected loads or

container residues sent to the alternate

designated facility or back to the generator 0.00 0.00 0.43 0.10 0.53 $17.53 $0.00 31,129 16,498 $545,691

Amend the facility’s copy of the manifest to

indicate the rejected wastes or residues in the

discrepancy space of the amended manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

Copy the manifest tracking number from Item 4

of the new manifest to the Discrepancy space of

the amended manifest 0.00 0.00 0.02 0.00 0.02 $0.72 $0.00 31,129 623 $22,413

Re

- sign and date the manifest 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

Retain the amended manifest for at least three

years from the date of the amendment 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 31,129 5,292 $106,772

Within 30 days, send a copy of the amended

manifest to the delivering transporter and to the

generator 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 31,129 4,981 $115,178

Subtotal 0.00 0.00 varies varies varies varies varies varies 41,713 $1,289,674

Rejection of Waste while the Transporter Remains Present at the Facility

Enter the name of the person accepting the

waste and sign and date each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

Contact the generator to obtain the generator’s

instructions for forwarding the waste to another

facility that can manage the waste 0.00 0.00 0.08 0.00 0.08 $2.89 $2.00 31,129 2,490 $152,221

Complete Item 18a and 18b of the original

manifest, as applicable 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 31,129 2,490 $89,963

Retain a copy of the manifest (or shipping paper)

for at least three years from the date of delivery 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 31,129 5,292 $106,772

### 51

Give the remaining copies back to the

transporter 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 31,129 311 $11,206

Subtotal 0.00 0.00 varies varies varies varies varies varies 10,894 $371,368

Manifest completion, transmittal and recordkeeping by Alternate TSDFs (264.71(a) and (b), or 265.71(a) and (b))

Enter the name of the person accepting the

waste and sign and date each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.01 0.00 0.01 $0.36 $0.00 61,635 616 $22,189

Complete the management method code 0.00 0.00 0.02 0.00 0.02 $0.72 $0.00 61,635 1,233 $44,378

Note any discrepancies on each copy of the

manifest (or shipping paper, if applicable) 0.00 0.00 0.08 0.00 0.08 $2.89 $0.00 61,635 4,931 $178,126

Immediately give the transporter at least one

copy of the manifest (or shipping paper) 0.00 0.00 0.17 0.00 0.17 $6.13 $0.00 61,635 10,478 $377,825

Within 30 days of delivery, send a copy of the

manifest (or shipping paper) to the generator 0.00 0.00 0.00 0.16 0.16 $3.23 $0.47 61,635 9,862 $228,051

Retain a copy of the manifest (or shipping paper)

for at least three years from the date of delivery 0.00 0.00 0.00 0.17 0.17 $3.43 $0.00 61,635 10,478 $211,410

Subtotal 0.00 0.00 varies varies varies varies varies varies 37,598 $1,061,979

TOTAL 0.00 0.00 varies varies varies varies varies varies 90,205 $2,723,021

a Ex hibit contains rounding error.

### 52

EXHIBIT 17

ESTIMATED ANNUAL HOUR AND COST BURDEN FOR DESIGNATED TREATMENT, STORAGE,

AND DISPOSAL FACILITIES (TSDFs) a

UNMANIFESTED WASTE REPORTS

Hours per TSDF Annual

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Number of

@

$92.38/hr @

$75.25/hr @

$36.07/hr @ $20.16/hr Respondent Respondent Respondent Shipments Total

Hours Total Cost

Unmanifested waste report: completion and submission (264.76(a) and 265.76(a))

Prepare and submit to EPA a letter of the

unmanifested waste within 15 days after

receiving waste 0.00 0.50 1.00 0.50 2.00 $83.78 $0.57 185 370 $15,604

T OTAL 0.00 0.50 1.00 0.50 2.00 $83.78 $0.57 185 370 $15,604

a Exhibit contains rounding error.

### 53

### 54

EXHIBIT 19

TOTAL ANNUAL AGENCY HOUR AND COST

BURDEN a

Hours per Agency Respondent Number of

Legal Managerial Technical Clerical Hours/ Labor Cost/ O&M Costs/ Reports

@

$63.22/hr @

$61.38/hr @

$36.56/hr @ $24.05/hr Respondent Respondent Respondent Received Total

Hours Total Cost

Registrant Organizations

Applying to the registry (262.21(c) and 262.21(e))

Review initial application 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 3 2 $69

Notify registrant of EPA's decision regarding its

application 0.00 0.00 0.00 0.10 0.10 $2.41 $0.47 3 0 $10

Review revised application 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 3 2 $69

If application is approved, provide electronic file of

the manifest, continuation sheet, and manifest

instructions to approved registrant and request

manifest form samples 0.00 0.00 0.00 0.10 0.10 $2.41 $4.61 3 0 $23

Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 3 2 $69

Notify registrant of EPA's decision regarding its

manifest form samples 0.00 0.00 0.00 0.10 0.10 $2.41 $0.47 3 0 $10

Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 2 1 $48

Updating General Information in the Approved Application (262.21(h)(1))

Review revised application 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 3 2 $62

Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 1 1 $21

Requesting Approval for a New Tracking Number Suffix (262.21(h)(2))

Provide new tracking number suffix to registrant 0.00 0.10 0.25 0.10 0.45 $17.68 $0.47 0 0 $0

Requesting Approval for Changes to Printing Specifications or Use of a New Printer (262.21(h)(3))

Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 1 1 $21

Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 1 1 $21

Typesetting the Manifest Form Subsequent to its Approval (262.21(i))

Evaluate manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 0 0 $0

Requesting an Exemption (262.21(j))

Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 2 1 $48

Notifying EPA of a Printing Specification Violation (262.21(k))

Receive notification that a serious violation of a

printing specification 0.00 0.20 0.80 0.00 1.00 $41.52 $0.00 1 1 $55

Revising the Approved Manifest if Requested by EPA (262.21(l))

Evaluate revised manifest form samples 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 0 0 $0

Responding to Suspension and Revocation Procedures (262.21(m))

Review documentation submitted by registrant 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 0 0 $0

Subtotal (Registrant Organizations) 0.00 varies varies varies varies varies varies varies 14 $526

### 55

EXHIBIT 19 (CONTINUED)

TOTAL ANNUAL AGENCY HOUR AND

COST BURDEN a

Hours per Agency Respondent Number of

Legal Manageria

l Technica

l Clerical Hours/ Labor Cost/ O&M

Costs/ Reports

@

$63.22/hr @

$61.38/hr @

$36.56/hr @

$24.05/hr Responden

t Responden

t Responden

t Received Total

Hours Total Cost

Generators

Exception report (262.42)

Review exception reports: LQGs 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 6,985 3,493 $145,009

Review exception reports: Commercial

TSDFs 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 645 323 $13,390

Review exception reports: Captive TSDFs 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 198 99 $4,110

Review exception reports: SQGs 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 5,329 2,665 $110,630

Subtotal (Generators) 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 varies 6,580 $273,139

Transporters

Notification of discharge (263.30(a) and (d))

Receive notifications of discharge 0.00 0.20 0.80 0.00 1.00 $41.52 $0.00 75 75 $3,114

Subtotal (Transporters) 0.00 0.20 0.80 0.00 1.00 $41.52 $0.00 75 75 $3,114

Designated TSDFs

Receive import manifests (264.71(a)(3) &

265.71(a)(3)) 0.00 0.00 0.10 0.00 0.10 $3.66 $0.00 17,624 1,762 $64,504

Discrepancy report (264.72(a) and (b) and 265.72(a) and (b))

Review designated TSDF discrepancy

reports 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 7,301 3,651 $151,569

Unmanifested waste report (264.76 and 265.76)

Review designated TSDF unmanifested

waste reports 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 185 93 $3,841

Subtotal (TSDFs) 0.00 0.10 0.40 0.00 0.50 $20.76 $0.00 varies 3,744 $155,410

TOTAL: AGENCY 0.00 varies varies varies varies varies varies varies 10,413 $ 496,693

a Exhibit contains rounding error.

Three Year Burden 31,239 $1, 490,079

Annual respondent +

agency burden = 3,482,631 $105, 717,974