SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0959.15

"FACILITY GROUND-WATER MONITORING REQUIREMENTS”

April 2015
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION................................ 3

1(b) SHORT CHARACTERIZATION...................................................................................... 3

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION .................................................... 3

2(b) USE AND USERS OF THE DATA................................................................................... 6

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION......................................................................................................... 8

3(b) PUBLIC NOTICE............................................................................................................... 8

3(c) CONSULTATIONS ........................................................................................................... 8

3(d) EFFECTS OF LESS FREQUENT COLLECTION............................................................ 9

3(e) GENERAL GUIDELINES ................................................................................................. 9

3(f) CONFIDENTIALITY ........................................................................................................ 9

3(g) SENSITIVE QUESTIONS ................................................................................................. 9

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS ................................................................................................................ 9

4(b) INFORMATION REQUESTED ...................................................................................... 10

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES................................................................................................... 19

5(b) COLLECTION METHODOLOGY AND MANAGEMENT.......................................... 20

5(c) SMALL ENTITY FLEXIBILITY .................................................................................... 20

5(d) COLLECTION SCHEDULE............................................................................................ 21

6. ESTIMATING THE BURDEN AND COST OF COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN...................................................................... 22

6(b) ESTIMATING RESPONDENT COSTS.......................................................................... 22

6(c) ESTIMATING AGENCY BURDEN AND COSTS........................................................ 23

6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND 

COSTS.............................................................................................................................. 24

6(e) BOTTOM LINE BURDEN HOURS AND COST........................................................... 28

6(f) REASONS FOR CHANGE IN BURDEN ....................................................................... 28

6(g) BURDEN STATEMENT ................................................................................................. 28

1. IDENTIFICATION OF THE INFORMATION COLLECTION
3

1(a) Title and Number of the Information Collection

This Information Collection Request (ICR) is entitled, "Facility Ground-Water Monitoring

Requirements (Renewal)," ICR number 0959.15, OMB number 2050-0033.

1(b) Short Characterization

Subtitle C of the Resource Conservation and Recovery Act of 1976 (RCRA) creates a 

comprehensive program for the safe management of hazardous waste. Section 3004 of RCRA requires 

owners and operators of facilities that treat, store, or dispose of hazardous waste to comply with standards 

established by EPA that are "necessary to protect human health and the environment." Section 3005 

provides for implementation of these standards under permits issued to owners and operators by EPA or 

authorized States. Section 3005 also allows owners and operators of facilities in existence when the 

regulations came into effect to comply with applicable notice requirements to operate until a permit is 

issued or denied. This statutory authorization to operate prior to permit determination is commonly 

known as "interim status." Owners and operators of interim status facilities also must comply with 

standards set under Section 3004.

This ICR examines the ground-water monitoring standards for permitted and interim status 

facilities at 40 CFR Parts 264 and 265, as specified. Sections 1 through 5 of this ICR describe the 

ground-water monitoring information collection requirements. In Section 6, EPA estimates the annual 

hour and cost burden to respondents and the Agency in carrying out these requirements.

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

PERMITTED FACILITIES

Detection Monitoring

40 CFR 264.98(c) requires owners and operators of facilities conducting a detection monitoring 

program to keep a record of all ground-water analytical data obtained under the program. Owners and 

operators must notify EPA of any statistically significant evidence of ground-water contamination ( 

§264.98(g)(1)), but may demonstrate that such contamination is caused by a source other than the 

regulated facility. Owners and operators detecting contamination are required to submit an engineering 

feasibility plan for a corrective action program and, if they wish to seek approval for an ACL, all data 

necessary to establish an ACL (§264.98(g)(5)). Owners, operators and EPA use the information required 

under this section to determine whether the facility is affecting ground-water quality, and whether a 

compliance monitoring program under section 264.99 is warranted. This information is also used for 

developing and evaluating an appropriate compliance monitoring program. The detection monitoring 

requirements contribute to EPA's goal of preventing undetected releases of hazardous waste from 

treatment, storage, and disposal facilities.

Compliance Monitoring
4

40 CFR 264.99(c)(2) requires owners and operators of facilities conducting a compliance 

monitoring program to keep a record of all ground-water analytical data obtained during monitoring. 

Owners and operators are required under sections 264.99(g) and (h) to notify EPA of the presence of new 

constituents or exceeded concentration limits at any monitoring well. Section 264.99(i) allows owners 

and operators to demonstrate that the exceeded concentration limits are caused by a source other than the 

regulated facility, or by an error in sampling and analysis. The information in this section is used by 

owners, operators and EPA to evaluate the extent of ground-water contamination at the facility and to 

determine whether a corrective action program under section 264.100 is warranted. The compliance

monitoring requirements contribute to EPA's goal of ensuring that ground-water contamination that 

exceeds acceptable levels is quickly identified and addressed.

Corrective Action

EPA promulgated regulations in 40 CFR 264.100 establishing requirements for owners and 

operators of hazardous waste LDFs conducting a corrective action program. Section 264.100(g) requires 

owners and operators conducting a corrective action program to submit a semi-annual report on the 

effectiveness of the program. This report allows EPA to monitor the progress of corrective action and 

identify any changes that should be made to the program. Exemption from the corrective action 

requirements may be obtained by submitting a demonstration under section 264.100(e)(2). Corrective 

action may be terminated by demonstrating that the ground-water protection standard has not been 

exceeded for a period of three consecutive years under section 264.100(f). This information is used by 

EPA to confirm that corrective action is undertaken where necessary to address ground-water 

contamination. The corrective action requirements contribute to EPA's goal of minimizing damage to the 

environment caused by the treatment, storage and disposal of hazardous waste by bringing regulated 

facilities back into compliance with their ground-water protection standards.

INTERIM STATUS FACILITIES

Applicability and Alternative Ground-Water Monitoring Systems

EPA promulgated standards in 40 CFR 265.90 establishing the applicability of ground-water 

monitoring and requirements for alternative ground-water monitoring systems. To waive the groundwater monitoring requirements, owners and operators must submit the demonstrations required under 40 

CFR 265.90(c) and/or 265.90(e). The demonstrations under this section are meant to ensure that LDFs 

are not unnecessarily required to conduct ground-water monitoring. Non-exempt facilities planning to 

implement an alternative ground-water monitoring system must submit a monitoring plan 

(§265.90(d)(1)), as well as initial and periodic reports on ground-water quality as required under sections 

265.90(d)(3) and (5), and must maintain a record of all ground-water quality assessments at the facility. 

Facilities planning to implement an alternate monitoring well location must meet certain criteria, make 

and submit a demonstration and obtain a certification from a qualified ground-water scientist. The 

requirements for alternative ground-water monitoring systems ensure that the alternative systems used are 

capable of early contamination detection, and the reports submitted to EPA are used to assess the impact 

of the facility on ground-water quality. This information contributes to EPA's goal of quickly detecting 

and characterizing contamination from LDFs in order to minimize damage to human health and the 

environment.

Sampling, Analysis and Assessment
5

EPA promulgated regulations in 40 CFR 265.92 requiring owners and operators to develop and 

implement sampling and analysis procedures for identifying ground-water contamination. The sampling 

and analysis plan must be kept on file at the facility and may be reviewed by EPA to determine whether 

the procedures effectively detect ground-water contamination (§265.92(a)). Section 265.93(d)(1) requires

owners and operators to notify EPA in writing of significant increases (or pH decreases) in indicator 

parameter concentrations at down gradient wells. Owners and operators of facilities where contamination 

is detected must develop and implement a ground-water quality assessment program, and submit an initial 

assessment report (§265.93(d)). These requirements provide EPA with the information necessary to 

evaluate the impact of the facility on ground-water quality. The sampling, analysis and assessment 

requirements contribute to EPA's goal of quickly detecting and characterizing contamination from LDFs 

in order to minimize damage to human health and the environment.

Recordkeeping and Reporting

EPA promulgated regulations in 40 CFR 265.94(a) establishing recordkeeping and reporting 

requirements for interim status facilities not conducting a ground-water quality assessment program. The 

regulations direct owners and operators of these facilities to keep records of initial background data, 

annual and semi-annual ground-water quality and indicator parameter analyses, and ground-water surface 

elevation data. A record of subsequent indicator parameter comparisons with background levels is also 

required. Reports included under this section include a quarterly report on drinking water suitability 

parameters during the first year, and annual reports on indicator parameters and variances from 

background concentrations, and an annual report on ground-water surface elevations.

40 CFR 265.94(b) establishes recordkeeping and reporting requirements for facilities conducting 

ground-water quality assessment programs. Owners and operators of these facilities are required to keep 

records of analyses and evaluations conducted under the program, and to submit annual assessment 

reports to the Regional Administrator. 

The records required under this section provide owners and operators with the information 

necessary to evaluate changes in ground-water quality at their facilities over time. The reporting 

requirements supply EPA with the information necessary to determine the impact of the facility on 

ground-water quality. These recordkeeping and reporting requirements contribute to EPA's goal of 

preventing undetected releases of hazardous waste from treatment, storage and disposal facilities.
6

2(b) USE AND USERS OF THE DATA

PERMITTED FACILITIES

Detection Monitoring

Records of ground-water analytical data are used primarily by owners and operators in 

determining whether their facilities are contaminating ground-water. Notifications of detected 

contamination are used by EPA to identify facilities that warrant closer attention, and as a basis for 

evaluating plans for compliance monitoring programs at these facilities. EPA uses data justifying ACLs 

to determine whether the new limits requested by owners and operators at a contaminated facility are 

appropriate, and uses engineering feasibility plans for corrective action to determine whether the proposed 

corrective action program will be effective at the contaminated facility. Demonstrations submitted under 

this section are used by owners and operators to obtain exemptions from the burden of conducting further 

monitoring or corrective action activities for contamination which is unrelated to activities at the facility.

Compliance Monitoring

Records of ground-water analytical data required under the compliance monitoring program are 

used primarily by owners and operators in determining the extent of ground-water contamination and in 

identifying exceeded concentration limits or new constituents. Notifications of new constituents are used 

by EPA in updating the facility monitoring requirements so that all constituents are carefully monitored. 

EPA uses notifications of exceeded concentration limits to learn as much as possible about the groundwater impact of each contaminated facility, and as a basis for evaluating plans for corrective action. 

Demonstrations submitted under this section are used by owners and operators to obtain exemptions from 

the burden of conducting corrective action for contamination which is unrelated to activities at the 

facility.

Corrective Action

Owners and operators of some contaminated facilities use the exemption demonstration submitted 

under this section to establish lack of need to implement a corrective action program. The demonstration 

required to terminate corrective action is used by EPA to evaluate the need for continued efforts where 

corrective action has already been instituted, and by owners and operators to justify such termination. 

Reports on the effectiveness of corrective action are used by both EPA and owners and operators to 

evaluate the success of corrective action and identify any improvements which can be made to the 

program.

INTERIM STATUS FACILITIES

Applicability and Alternative Ground-Water Monitoring Systems

The exemption demonstrations provided under this section are used by owners and operators of 

interim status facilities to minimize their monitoring burden, provided that their facilities pose little or no 

threat to ground-water quality. Plans for an alternative ground-water monitoring system are used by 

owners and operators of some facilities as a guideline for conducting ground-water quality analyses. The 

alternative ground-water monitoring plan is reviewed by EPA to determine whether it is appropriate for 
7

the specific facility, and the terms of the plan are enforceable against the owner or operator. Groundwater quality assessment reports and records of analyses conducted at facilities using alternative systems 

are used by owners, operators and EPA to determine the impact of these facilities on ground-water 

quality, and to identify any changes which should be made to the alternative ground-water monitoring 

program. Alternate down gradient well locations give some facilities flexibility in placing ground-water 

monitoring wells. The demonstrations allow EPA to assure that these alternate well locations will not 

adversely threaten ground-water quality.

Sampling, Analysis and Assessment

The ground-water sampling and analysis plan required under this section is used primarily by 

owners and operators as a guideline for determining whether their facilities are leaking. Although the 

sampling and analysis plan is not formally submitted to EPA, it may be reviewed by EPA at any time to 

determine whether it is appropriate for identifying and evaluating ground-water contamination at the 

facility. The terms of the plan are enforceable against the owner or operator. Notifications of increased 

indicator parameter concentrations are used by EPA to identify facilities requiring ground-water quality 

assessment plans. The plan is used primarily as a guideline for owners and operators in determining the 

extent of ground-water contamination. Reports on ground-water quality are used both by owners and 

operators and by EPA to evaluate the degree of ground-water contamination and the extent of 

contaminant migration.

Recordkeeping and Reporting

The recordkeeping requirements under section 265.90(a) require owners and operators of 

facilities not conducting ground-water quality assessment programs to keep records of initial background 

data; subsequent analyses of ground-water quality and indicator parameters; ground-water surface 

elevations; indicator parameter comparisons with background levels; and ground-water quality 

assessment data. These records are used primarily by owners and operators, but may also be reviewed by 

EPA upon request. Background data are used as a baseline for evaluations of ground-water quality. 

Subsequent analyses and comparisons with background levels are used by owners and operators to 

identify leaking contaminants. Records of ground-water surface elevations assist owners and operators in 

determining whether monitoring samples are being drawn from appropriately located wells. Records 

required in this section also provide an ongoing history of ground-water quality at the facility, which is 

important because changes in ground-water quality may occur slowly over time.

Reports on drinking water suitability parameters submitted during the first year are used by EPA 

to identify facilities which may already be contaminating ground water and to establish priorities for 

issuing permits. Reports on indicator parameters are used by EPA to evaluate the impact of the facility on 

ground-water quality and to identify facilities where further investigation or action is warranted. Reports 

on ground-water surface elevations are used by EPA to confirm that monitoring wells are appropriately 

placed.

The recordkeeping requirements of section 265.90(b) require owners and operators of facilities 

conducting ground-water quality assessments to record and report on information collected during the 

assessments. The records and reports are used by owners and operators and EPA, respectively, to 

evaluate the impact of facilities on ground-water quality.
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3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION

RCRA is currently the sole Federal statutory vehicle for protecting ground-water quality from the 

effects of the hazardous waste TSDFs for which this monitoring is being required. Pursuant to the Clean 

Water Act, standards have been established for maintaining surface water quality; however, that Act has 

limited jurisdiction over ground-water, and the implementation of the Act has only sought to protect 

against ground-water contamination by activities such as sewage treatment and related sludge disposal. 

The requirements of RCRA thus provide the only means for gathering information to use in determining 

the ground-water quality impacts of the regulated facilities. Most of the information required by RCRA is 

not available from any source but the respondents.

3(b) PUBLIC NOTICE

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

February 17, 2015, Federal Register (80 FR 8307), soliciting public comments for a 60-day period ending 

April 20, 2015. No comments were received.

3(c) CONSULTATIONS

Five members of the regulated community were consulted for the burden estimates in this ICR. 

Their names, company, and phone numbers are:

Ed Wallingford Virginia Department of Transportation 540-371-6824

Tim Johnson Phillips 66 Company 360-384-8368

James Denson Chemical Waste Management 541-454-2030

Brian Hennesey Westinghouse Savannah River Company 803-952-7824

Craig Nowell Continental Refining Company 606-679-6301

These consultants were picked from a list of facilities who filled out the 2013 Hazardous Waste 

Report form that have groundwater monitoring wells onsite, and because they represent a cross-section of

privately and publically-owned facilities complying with either detection monitoring, compliance 

monitoring, or corrective action monitoring.

From the feedback received as a result of these consultations, the burden estimates for sampling 

and analyzing groundwater have been increased from 48 hours to 80 hours per year. EPA feels this more 

accurately reflects the burden involved. All facilities have multiple wells, ranging from 10 up to 60. The 

agency estimate that sampling occurs semiannually was validated, with Spring and Fall being the 

preferred seasons to sample.
9

3(d) EFFECTS OF LESS FREQUENT COLLECTION

Collecting these data less frequently would hinder the Agency in promptly identifying facilities 

that may be discharging hazardous wastes or constituents to ground-water. Thus, Agency action to 

require remediation for the protection of potential ground-water users would be hampered or delayed. If 

contamination problems are allowed to proliferate and persist unremediated, the potential cost of future 

remediation may grow substantially. Additionally, for facilities which are known to be discharging 

hazardous wastes to ground-water, a reduction in the information collection requirements would seriously 

impair the Agency's ability to assess the rate of movement and extent of contamination from discharging 

facilities.

3(e) GENERAL GUIDELINES

Requirements and justification for reporting information to the Agency more often than quarterly 

are discussed under Section 4(d). Collection activities that must be prepared in less than 30 days are also 

discussed in Section 4(d). Sections 265.94(a)(1) and 265.94(b)(1) require the maintenance of records 

throughout the active life of the facility and, for disposal facilities, throughout the post-closure care period 

as well. These records provide a baseline for determining the presence and concentration of hazardous 

releases to ground-water, and provide a means to assess the effects of the facility on ground-water 

throughout its active life. Without these records, the impact of the facility on the ground-water beneath 

and adjacent to it cannot be ascertained. 

3(f) CONFIDENTIALITY

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which define EPA's general policy on 

the public disclosure of information, contain provisions for confidentiality.

3(g) SENSITIVE QUESTIONS

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

4. THE RESPONDENTS AND THE INFORMATION COLLECTED

4(a) Respondents and 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.

Description SIC Codes NAICS Codes

Industrial Inorganic Chemicals 281 32518, 32513

Plastic materials, Synthetic Resins, etc. 282 3252

Drugs 283 3254
10

Description SIC Codes NAICS Codes

Soaps, Detergents, etc. 284 3256

Paints, Varnishes, etc. 285 32551

Industrial Organic Chemicals 286 32511, 32512, 32519

Miscellaneous Chemical Products 289 3255

Petroleum 291 324199

Metal Working 330 331

Sanitary Services 495 5622, 5629

4(b) Information Collected

PERMITTED FACILITIES

Reading the Regulations

(i) Data items:

There are no data items associated with reading the regulations. However, respondents must first 

read the regulations in order to comply with ground-water monitoring requirements.

(ii) Respondent activities:

In order to comply with the ground-water monitoring requirements, respondents must perform the 

following activities:

• Read the regulations.

Ground-water Monitoring System

(i) Data items:

There are no data items associated with implementing a ground-water monitoring system. 

However, respondents must implement a ground-water monitoring system in order to comply with 

ground-water monitoring requirements.
11

(ii) Respondent activities:

In order to implement a ground-water monitoring system, respondents must perform the 

following activities:

• Conduct a hydrogeologic investigation; and

• Design and install a ground-water monitoring system.

Detection Monitoring

(i) Data items:

Owners and operators required to perform detection monitoring must provide the following data:

• A record of ground-water analytical data as measured and in a form necessary for the 

determination of statistical significance, as required by §264.98(c);

• Notification to the Regional Administrator within seven days of statistically significant 

evidence of contamination, including information on chemical parameters or hazardous 

constituents, as required by §264.98(g)(1);

• All data necessary to justify an alternate concentration limit if sought under §264.94(b), 

submitted within 180 days of confirmation of a release of hazardous constituents to 

ground-water, as required by §264.98(g)(5)(i);

• An engineering feasibility plan for a corrective action program, submitted within 180 

days of confirmation of a release of hazardous constituents to ground-water, as required 

by §264.98(g)(5)(ii); 

• To demonstrate that contamination, if detected, is caused by a source other than a 

regulated unit or by an error in sampling, analysis, statistical evaluation or natural 

variation in the ground-water, as required by §264.98(g)(6);

- A notification to the Regional Administrator, submitted within seven days of 

detection, of intent to make such a demonstration. 

- A report to EPA, submitted within 90 days of the notification, demonstrating that 

the exceeded standards were caused by a source other than a regulated unit or by 

an error in sampling, analysis, or evaluation. 

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following activities:

• Determine the ground-water flow rate and direction (annually);

• Sample and analyze ground-water (semi-annually);
12

• Record ground-water analytical data at the facility (semi-annually);

• Prepare and submit the notification of contamination;

• Re-sample and analyze ground-water for Appendix IX constituents;

• Compile and submit data necessary to establish an alternate concentration limit;

• Prepare and submit an engineering feasibility plan for corrective action;

• Prepare and submit notification of intent to make a demonstration of error or 

contamination from another source; and

• Prepare and submit the demonstration.

Compliance Monitoring

(i) Data items:

Owners and operators required to perform compliance monitoring must provide the following 

data:

• A record of all ground-water analytical data obtained under the compliance monitoring 

program as measured and in a form necessary for the determination of statistical 

significance by §264.99(c)(2);

• Notification, submitted to the Regional Administrator within seven days of initial or 

confirmed analysis, of the presence of new constituents in ground-water not already 

identified in the facility permit, and their concentrations, as required by §264.99(g);

• Notification, submitted to the Regional Administrator within seven days of detection, that 

concentration limits under §264.94 are being exceeded at any monitoring well, as 

required by §264.99(h)(1);

• To demonstrate that contamination, if detected, is caused by a source other than a 

regulated unit or by an error in sampling, analysis, statistical evaluation or natural 

variation in the ground-water, as required by §264.99(i):

- A notification to the Regional Administrator, submitted within seven days of 

detection, of intent to make such a demonstration. 

- A report, submitted within 90 days of the notification, demonstrating that the 

exceeded standards were caused by a source other than a regulated unit or by an 

error in sampling, analysis, or evaluation. 

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following activities:
13

• Determine the ground-water flow rate and direction (annually); 

• Sample and analyze ground-water (semi-annually); 

• Record ground-water analytical data at the facility (semi-annually).

• Compile information for notification of new constituents;

• Prepare and submit the notification of new constituents;

• Compile information on exceeded concentration limits;

• Prepare and submit the notification of exceeded concentration limits;

• Prepare and submit a notification of intent to make a demonstration of error or 

contamination from another source; and

• Prepare and submit the demonstration.

Corrective Action

(i) Data items:

Owners and operators required to perform corrective action must provide the following data:

• To obtain an exemption from the requirements to take corrective action beyond the 

facility's boundary, a demonstration that the owner or operator was unable to obtain the 

necessary permission to undertake such corrective action, despite his or her best efforts, 

as required by §264.100(e)(2);

• To terminate corrective action, a demonstration, as required by §264.100(f) that the 

ground-water protection standard has not been exceeded for a period of three consecutive 

years;

• A semi-annual report on the effectiveness of the corrective action program, as required by 

§264.100(g); and

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following activities:

• Design and install additional ground-water monitoring wells;

• Sample and analyze ground-water (semi-annually);

• Record ground-water analytical data at the facility (semi-annually);
14

• Compile and submit information for the demonstration for exemption from corrective 

action;

• Compile and submit information for the demonstration for termination of corrective 

action;

• Develop and submit to EPA a semi-annual report on the effectiveness of the program.

INTERIM STATUS FACILITIES

Reading the Regulations

(i) Data items:

There are no data items associated with regulations. However, respondents must first read the 

regulations in order to comply with ground-water monitoring requirements.

(ii) Respondent activities:

In order to comply with the ground-water monitoring requirements, respondents must perform the 

following activities:

• Read the regulations.

Applicability and Alternative Ground-Water Monitoring Systems

(i) Data items:

Section 265.90 establishes the applicability of the ground-water monitoring requirements at 

interim status facilities, and discusses requirements for alternative ground-water monitoring systems. 

Data items required under these regulations include:

• A demonstration, necessary in order to waive all or part of the ground-water monitoring 

requirements, of low potential for migration of hazardous waste or hazardous waste 

constituents from the facility through the uppermost aquifer to water supply wells or 

surface water (§265.90 (c)). This demonstration must be kept in writing at the facility 

and must be certified by a qualified geologist or geotechnical engineer. The 

demonstration must establish the following:

- The potential for migration of hazardous waste or hazardous waste constituents 

from the facility to the uppermost aquifer by an evaluation of water balance and 

unsaturated zone characteristics; and

- The potential for hazardous waste or hazardous waste constituents which enter 

the uppermost aquifer to migrate to a water supply well or surface water by an 

evaluation of saturated zone characteristics and the proximity of the facility to 

water supply wells or surface water; 
15

• A demonstration, necessary in order to waive the ground-water monitoring requirements 

for certain surface impoundments, that establishes, based upon consideration of the 

characteristics of the wastes and the impoundment, that the corrosive wastes will be 

neutralized to the extent that they no longer meet the corrosivity characteristic before 

they can migrate out of the impoundment. This demonstration must be in writing and 

must be certified by a qualified professional (§265.90(e));

• If necessary, a specific plan for an alternative ground-water monitoring system, certified 

by a qualified geologist or geotechnical engineer and submitted to the Regional 

Administrator within one year after the effective date of the regulations or within one 

year of obtaining interim status (§265.90(d)(1)); 

• If an alternative ground-water monitoring system is used, a written report containing an 

assessment of ground-water quality submitted to the Regional Administrator within 15 

days of the initial assessment, followed by annual reports submitted by March 1 

following each calendar year (§265.90(d)(3) and (5)); and

• For alternative systems, a record of the analyses conducted to determine ground-water 

quality under §265.90(d)(3) to be kept throughout the active life of the facility, and, for 

disposal facilities throughout the post-closure period as well (§265.90(d)(5)).

• For alternate hydraulically down gradient monitoring well locations, a demonstration 

showing that the location will meet the criteria outlined in §265.91(a)(3) and a 

certification by a qualified ground-water scientist that

(ii) Respondent Activities:

In order to provide the data items listed above, respondents must perform the following activities:

• Develop and submit the demonstrations;

• Maintain records of the demonstrations;

• Compile information for an alternative ground-water monitoring plan;

• Obtain certification; 

• Develop and submit the plan;

• Compile information for the ground-water quality assessment reports; 

• Develop and submit the reports;

• Maintain a record of the ground-water quality assessment data (quarterly);

• Develop and submit the demonstration for an alternate well location; and

• Maintain records of the demonstration.
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Sampling, Analysis and Assessment

(i) Data items:

Sections 265.92 and 265.93 require owners and operators of interim status facilities to conduct 

sampling, analysis and assessment to identify and evaluate changes in the concentrations of hazardous 

constituents in ground water. Data items required under these regulations include:

• Development of a ground-water sampling and analysis plan, which must be kept at the 

facility. The plan must include procedures and techniques for sample collection, sample 

preservation and shipment, analytical procedures, and chain of custody control 

(§265.92(a));

• If there is a confirmed significant increase (or pH decrease) in indicator parameter 

concentrations in down gradient wells, a written notification to the Regional 

Administrator within seven days that the facility may be affecting ground-water quality 

(§265.93(d)(1));

• If there is a confirmed significant increase (or pH decrease) of indicator parameter 

concentrations in down gradient wells, a specific plan to be submitted to the Regional 

Administrator within 15 days after the notification for a ground-water quality assessment 

program at the facility (§265.93(d)(2)). This plan must be certified by a qualified 

geologist or geotechnical engineer, and must specify:

- The number, location, and depth of the wells;

- Sampling and analytical methods for those hazardous waste constituents in the 

facility;

- Evaluation procedures, including any use of previously gathered ground-water 

quality information; and 

- A schedule of implementation;

• A written report containing an assessment of ground-water quality submitted to the 

Regional Administrator within 15 days after it is determined (§265.93(d)(5)). If the 

indicator evaluation program is reinstated, this information must also be included in this 

ground-water quality assessment report (§265.93(d)(6)); and

• A written report of any ground-water quality assessment conducted to satisfy the 

requirements of §264.93(d)(4) which is initiated prior to final closure of the facility. The 

report must be submitted to the Regional Administrator within 15 days after the 

assessment is completed and reported in accordance with §265.93(d)(5) (§265.93(e)).

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following activities:
17

• Conduct a hydrogeologic investigation;

• Design and install ground-water monitoring system;

• Compile information for a written sampling and analysis plan;

• File the plan at the facility;

• Prepare a ground-water quality assessment plan outline;

• Compile and submit notification;

• Develop and submit the ground-water quality assessment plan;

• Develop and submit the initial ground-water quality assessment report;

• Prepare and submit report of any ground-water quality assessment initiated prior to final 

closure;

• Conduct quarterly sampling and analysis of ground-water to determine ground-water 

quality under alternate ground-water monitoring system;

• Conduct semi-annual sampling and analysis of ground-water to obtain ground-water 

analytical data; and

• Conduct quarterly sampling and analysis as part of a ground-water quality assessment 

program.

Recordkeeping and Reporting 

(i) Data items:

Section 265.94 outlines specific recordkeeping and reporting requirements for owners and 

operators of interim status facilities. Owners and operators of interim status facilities that are not required 

to implement a ground-water quality assessment program under §265.93(d)(4) must perform reporting 

and recordkeeping activities throughout the active life of the facility, and for disposal facilities that do not 

clean close, throughout the post-closure care period as well (§265.94(a)). Required data items include:

• A record of information required under §265.94(a)(1), including:

- Initial background concentrations or values for ground-water quality parameters 

at all monitoring wells as calculated under §265.92(c)(1); 

- The initial arithmetic mean and variance for indicator parameters as calculated 

under §265.92(c)(2);
18

- Annual analyses of parameters used to establish ground-water quality and semiannual analyses of indicators of ground-water contamination as determined under 

§§265.92(d)(1) and (2);

- Ground-water elevation as determined under §265.92(e);

- Subsequent calculations of arithmetic means and variances for each indicator 

parameter at each well monitored, and comparisons with background means to 

determine statistically significant increases (or pH decreases) over initial 

background concentrations during the contamination indication program as 

calculated under §265.93(b);

• A report to the Regional Administrator, during the first year when initial background 

concentrations are being established for the facility, of concentrations or values of 

parameters characterizing the suitability of the ground water as a drinking water supply 

for each ground-water monitoring well (§265.92(b)(1)) within 15 days after completing 

each quarterly analysis, and an identification of any parameters whose concentration or 

value has been found to exceed the maximum contaminant levels listed in Appendix III 

(§265.94(a)(2)(i));

• An annual report to the Regional Administrator, submitted by March 1 following each 

calendar year, on concentrations or values of the indicator parameters listed in 

§265.92(b)(3) for each monitoring well, as well as the required evaluations for these 

parameters as calculated under §265.93(b). Also, a separate identification of any 

statistically significant differences from initial background concentrations found in the up 

gradient wells as calculated under §265.93(b) and required by §265.93(c)(1) 

(§265.94(a)(2)(ii)); and

• A report to the Regional Administrator, submitted by March 1 following each calendar 

year, of the results of the evaluations of ground-water surface elevations under §265.93(f) 

and a description of the response to that evaluation where applicable (§265.94(a)(2)(iii)).

Owners and operators of facilities conducting a ground-water quality assessment program under 

§265.93(d)(4) are required to provide the following data items:

• A record of analyses and evaluations specified in the assessment plan required under 

265.93(d)(3) throughout the active life of the facility, and, for disposal facilities, 

throughout the post-closure care period (§265.94(b)(1));

• An annual report, submitted to the Regional Administrator no later than March 1 

following each calendar year until final closure of the facility, containing the results of 

the ground-water quality assessment program, including the calculated or measured rate 

of migration of hazardous waste or hazardous waste constituents in the ground water 

during the reporting period (§265.94(b)(2)).

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following activities:
19

• Record ground-water analytical data at the facility (semi-annually);

• Prepare and submit a quarterly report of concentrations or values of the drinking water 

suitability parameters (quarterly);

• Prepare and submit a report on indicator parameter concentrations (annually); 

• Prepare and submit a report of any significant indicator parameter increases (or pH 

decreases) in up gradient wells; 

• Prepare and submit a report on ground-water surface elevations (annually);

• Record ground-water quality assessment data (quarterly); and

• Prepare and submit a report on the ground-water quality assessment program.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

The following subsections discuss how EPA will collect the information, what activities EPA will 

perform once the information has been received, and how EPA will manage the information it collects. 

The subsections also include a discussion of how the information collection requirements affect small 

entities.

5(a) AGENCY ACTIVITIES

PERMITTED FACILITIES

Detection and Compliance Monitoring

Agency activities associated with the detection and compliance monitoring requirements include 

reviewing notifications and demonstrations and entering information into a data base. The detection 

monitoring requirements also require EPA to evaluate ACL data and engineering feasibility plans for 

corrective action submitted under section 264.98(g)(5) to determine whether the proposed ACLs and 

corrective action programs are appropriate, and to enter information into a data base. Records of groundwater analytical data required under sections 264.98(c) and 264.99(c)(2) are not formally submitted to 

EPA, but must be kept on file at the facility and made available to EPA upon request. Accordingly, this 

analysis assumes that there are no Agency activities associated with these recordkeeping requirements.

Corrective Action

Agency activities associated with the corrective action requirements include reviewing 

demonstrations, evaluating reports on the effectiveness of corrective action, and entering the information 

into a data base.
20

INTERIM STATUS FACILITIES

Applicability and Alternative Ground-Water Monitoring Systems

Agency activities associated with applicability and alternative ground-water monitoring systems 

include reviewing demonstrations, alternative ground-water monitoring plans, ground-water quality 

assessment reports and alternate well location demonstrations, and entering information into a data base. 

The records required under this section are not formally submitted to EPA but must be filed at the facility 

and made available upon request for EPA review. Accordingly, this analysis assumes that there are no 

Agency activities associated with these recordkeeping requirements.

Sampling, Analysis and Assessment

Agency activities associated with the sampling, analysis and assessment requirements include 

reviewing the notification of increased indicator parameter concentrations, evaluating the ground-water 

quality assessment plan and initial reports, and entering information into a data base. Although EPA may 

review the sampling and analysis plan required under this section, the plan is not formally submitted to 

EPA. Therefore, there is no Agency activity associated with this requirement.

Recordkeeping and Reporting

Agency activities associated with the reporting requirements of this section include reviewing the 

information submitted and entering the information into a database. Records required under this section 

are not formally submitted to EPA. Therefore, there are no Agency activities associated with these 

recordkeeping requirements under this section.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

In collecting and analyzing the information required under the ground-water monitoring 

regulations, EPA uses state-of-the-art electronic equipment such as personal computers and applicable 

data base software, when appropriate.

5(c) SMALL ENTITY FLEXIBILITY

The burden imposed by the ground-water monitoring requirements is a function of the threat of 

contamination of ground-water, from which many people derive their drinking water, and is not sensitive 

to the size of the organization. Therefore, small entities must comply with the same requirements as large 

entities.
21

5(d) COLLECTION SCHEDULE

PERMITTED FACILITIES

Detection Monitoring

Since records of ground-water analytical data collected under detection monitoring are kept at the 

facility, discussion of a collection schedule is not applicable. Notification of statistically significant 

evidence of contamination must be submitted within seven days of the initial or confirmed detection. If 

an alternate concentration limit is sought under section 264.94(b), the data necessary to justify the 

alternate concentration limit, along with the required engineering feasibility plan for a corrective action 

program, must be submitted within 180 days of the initial or confirmed detection. If the owner or

operator plans to make a demonstration under section 264.98(g)(6), the notification of intent to make such 

a demonstration must be submitted within seven days of detection, and the demonstration submitted 

within 90 days of detection.

Compliance Monitoring

Since records of ground-water analytical data collected under compliance monitoring are kept at 

the facility, discussion of a collection schedule is not applicable. Notification of the presence of new 

constituents or exceeded concentration limits must be submitted within seven days of detection. If the 

owner or operator plans to make a demonstration under section 264.99(i), the notification of intent to 

make such demonstration must be submitted within seven days of detection, and the demonstration report 

submitted within 90 days of detection.

Corrective Action

The time frame for submission of demonstrations under sections 264.100(e)(2) and 264.100(f) is 

dependent upon the desire of owners and operators to submit such demonstrations. Reports on the 

effectiveness of the corrective action program must be submitted semi-annually.

INTERIM STATUS FACILITIES

Applicability Alternative Ground-Water Monitoring Systems

The time frame for submission of demonstrations under sections 265.90(c), 265.90(e), and 

265.91(a)(3) are dependent upon the desire of owners and operators to submit such demonstrations. If an 

owner or operators seeks to implement an alternative ground-water monitoring program, a plan for the 

alternative program must be submitted within one year of obtaining interim status. Ground-water quality 

assessment reports for alternative systems must be submitted within 15 days of the initial assessment, and 

then annually no later than March 1 following each calendar year. Since records of the analyses 

conducted under the alternative ground-water monitoring program are kept at the facility, a discussion of 

a collection schedule is not applicable.
22

Sampling, Analysis and Assessment

Since the sampling and analysis plan must be kept at the facility and made available to the 

Regional Administrator upon request, discussion of a collection schedule is not applicable. Notification 

of significant increases (or pH decreases) in indicator parameter concentrations in down gradient wells 

must be submitted within seven days of confirmation. Plans for a ground-water quality assessment 

program must be submitted within 15 days of the notification. The report of the results of the initial 

ground-water quality assessment must be submitted within 15 days of determination. Subsequent groundwater quality assessment reports will be submitted within 15 days of determination at intervals outlined in 

the ground-water quality assessment plan, which will differ for each facility.

Recordkeeping and Reporting

Since the records required under sections 265.94(a)(1) and 265.94(b)(1) are kept at the facility, 

discussion of a collection schedule is not applicable. Reports of drinking water suitability parameter 

concentrations and exceeded maximum contaminant levels (MCLs) must be submitted within 15 days of 

each quarterly analysis conducted during the first year of interim status standing, when initial background 

levels are being established. Reports of indicator parameter concentrations, variations from initial 

background concentrations, and ground-water surface elevations must be submitted annually, during the 

active life of the facility, no later than March 1 following each calendar year. Owners and operators 

conducting a ground-water quality assessment program must submit results of the ground-water quality 

assessment program annually no later than March 1 following each calendar year.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN

Exhibits 1 through 4 identify the reporting and recordkeeping activities and associated burden to 

respondents under the ground-water monitoring program. 

6(b) ESTIMATING RESPONDENT COSTS

Labor Costs

For purposes of this analysis, EPA estimates an average hourly respondent labor cost (including 

fringe and overhead) of $107.51 for legal staff, $87.58 for managerial staff, $41.98 for technical staff, and 

$23.46 for clerical staff.

For the non-federal respondent labor rates, EPA estimates an average hourly labor cost (including 

fringe and overhead) of $59.38 for legal staff, $55.75 for managerial staff, $33.35 for technical staff, and 

$21.28 for clerical staff. 

These respondent labor costs were obtained from the previously approved ICR (i.e., EPA ICR 

Number 0959.14), and updated to 2015 levels using Employment Cost Indexes developed by the U.S. 

Bureau of Labor Statistics
23

Operation and Maintenance (O&M) Costs

O&M costs include postage, materials, and lump-sum purchased service costs. Examples of 

O&M costs include:

• Laboratory fees for analyzing ground-water samples;

• Contractor travel/lodging costs;

• Transportation/disposal costs (if required for drill cuttings, purge water); 

• Professional certifications for certain work performed;

• Mailing and shipping costs;

• Software costs (e.g., applications of computer-based models for aquifer step drawdown or 

slug tests, statistical analysis computer program for demonstration); and

• Personal protective equipment. 

Capital Costs

The capital/startup costs associated with the ground-water monitoring requirements are the costs 

of designing and installing a ground-water monitoring system. For permitted and interim status facilities, 

the cost estimates are available in Exhibits 7 and 8.

6(c) ESTIMATING AGENCY BURDEN AND COSTS

Labor Costs

Exhibits 5 and 6 show the Agency burden hours and costs associated with the reporting 

requirements covered in this ICR. As shown in these exhibits, EPA estimates an average hourly labor 

cost of $77.92 for legal staff, $56.05 for managerial staff, $39.33 for technical staff, and $23.92 for 

clerical staff. 

EPA used the 2015 Federal Pay Schedule salary figures to estimate annual compensation of 

Regional legal, managerial, technical, and clerical staff. For purposes of this ICR, EPA assigned 

Regional staff the following government service levels:

Legal staff GS-15, Step 1

Managerial staff GS-13, Step 1

Technical staff GS-11, Step 1

Clerical staff GS-06, Step 1

Operation and Maintenance (O&M) Costs

EPA does not expect any O&M costs to the Agency as a result of these requirements.

Capital Costs

EPA does not expect any capital costs to the Agency as a result of these requirements.
24

6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND 

COSTS

Table 1 below shows the estimated universe for respondents for this ICR. Permitted land disposal 

facilities include those facilities that own and/or operate landfills, land treatment units, surface 

impoundments, and/or waste piles subject to 40 CFR Part 264. Permitted facilities were identified based 

on the legal status and operating status of their land disposal units. Interim status land disposal facilities 

include those facilities that own and/or operate landfills, land treatment units, and/or surface 

impoundments subject to 40 CFR Part 265. Interim status facilities were identified based on the legal 

status and operating status of their land disposal units. 

Table 1

Permitted and Interim Status Land Disposal Facilities Included in the ICR

Facility 

Type

Facilities with 

Permitted Land 

Disposal Units Only

Facilities with 

Interim Status Land 

Disposal Units Only

Total

Privatelyowned 299 533 832

NonFederal 

Gov’t 20 29 49

Total 319 562 881

Numbers based on the latest information available in RCRAInfo.
25

PERMITTED FACILITIES (EXHIBITS 1 and 3)

EPA estimates that each of the approximately 562 permitted facilities will read the regulations. 

Each of the permitted facilities is also required to conduct ground-water sampling and analysis. 

These activities require the implementation of a ground-water monitoring system, which involves 

conducting a hydrogeologic investigation and designing and installing a ground-water monitoring system. 

EPA assumes that permitted facilities will already have operational ground-water monitoring systems in 

place; and since the number of permitted facilities is assumed to be constant, no facilities are expected to 

perform the activities associated with implementing a ground-water monitoring system.

EPA estimates that about half of permitted facilities are conducting detection monitoring, 10 

percent compliance monitoring and about one third are undertaking corrective action. EPA applied these 

percentages to the universe of permitted facilities to provide a breakdown of the types of activities being 

conducted at facilities. 

Detection Monitoring

The facilities conducting detection monitoring will be required to submit a notification of 

contamination under section 264.98(g)(1), and will conduct additional sampling and analysis. EPA 

estimates that half of these facilities will identify Appendix IX constituents in the ground-water. EPA 

estimates that 40 percent of the facilities identifying Appendix IX constituents will submit all data 

necessary to establish an ACL, and that approximately 20 percent of those who submit such data will 

receive EPA approval to establish an ACL. Facilities not submitting an ACL and facilities that do not 

obtain approval for an ACL must submit an engineering feasibility plan for corrective action under 

section 264.98(g)(5)(ii). EPA estimates that none will receive an exemption from compliance monitoring 

regulations.

Compliance Monitoring

EPA assumes that the sampling and analysis and recordkeeping activities necessary to maintain 

ground-water analytical data at the facility are conducted semi-annually. These facilities must also 

determine the ground-water flow rate and direction annually. 

EPA estimates that approximately 25 percent of the facilities conducting compliance monitoring 

will confirm the presence of new constituents and submit a notification under section 264.99(g). 

Furthermore EPA estimates that approximately half of the facilities conducting compliance 

monitoring will identify exceeded concentration limits, and will therefore compile and submit a 

notification under section 264.99(h)(1). Of the facilities identifying exceeded concentration limits, EPA 

estimates that 10 percent will apply for an exemption from the corrective action requirements, but that no 

facility will submit sufficient information to justify an exemption. 

Corrective Action

This ICR assumes that facilities will sample and analyze ground-water and submit reports on the 

effectiveness of corrective action semi-annually.
26

Owners and operators of facilities already conducting corrective action who wish to submit a 

demonstration under section 264.100(e)(2) will have done so upon implementing corrective action. Of 

the facilities beginning corrective action during the period covered by this ICR, EPA does not expect any 

to submit a demonstration. In addition, because very few corrective action measures have been 

implemented to date, and since ground-water corrective action measures often take 5-10 years to 

complete, EPA estimates that the number of facilities requesting a termination of corrective action 

activities will be zero.

INTERIM STATUS FACILITIES (EXHIBITS 2 and 4)

EPA estimates that each of the approximately 319 interim status facilities will read the 

regulations. 

Applicability and Alternative Ground-Water Monitoring Systems

As no new LDFs will enter the interim status universe during the period covered by this ICR, 

EPA estimates that no facilities will submit a demonstration under sections 265.90(c) or (e), or under 

section 265.91(a)(3). This ICR assumes that demonstrations under this section are submitted in written 

form to the Regional Administrator.

This ICR also assumes that facilities wishing to submit an alternative ground-water monitoring 

plan do so upon obtaining interim status. As no new LDFs will enter interim status during the period 

covered by this ICR, no new interim status facilities will submit plans for an alternative ground-water 

monitoring system each year. EPA estimates that, prior to the period covered by this ICR, approximately 

5 percent of interim status facilities submitted alternative ground-water monitoring plans and 10 percent 

of those who applied received approval to operate an alternative ground-water monitoring system. These 

facilities are subject to the recordkeeping and reporting requirements of sections 265.90(d)(3) and (5). 

EPA assumes that ground-water sampling and analysis and recordkeeping activities will be conducted 

quarterly, and that ground-water quality assessment reports will be developed and submitted annually.

Sampling, Analysis and Assessment

Each of the interim facilities is required to conduct ground-water sampling and analysis of some 

sort. These activities require the implementation of a ground-water monitoring system. EPA assumes 

that all interim status facilities will already have operational ground-water monitoring systems in place; 

and since the no new LDFs are expected to enter the universe during the period covered by this ICR, the 

number of facilities expected to perform the activities associated with implementing a ground-water 

monitoring system is zero.

This ICR assumes that only new interim status facilities will submit sampling and analysis plans 

under section 265.92(a) and outlines of ground-water quality assessment plans under section 265.93(a). 

As no new LDFs will enter the interim status universe, no new interim status facilities will submit 

sampling and analysis plans or outlines of ground-water quality assessment plans.

However, this ICR assumes that all interim status facilities not conducting an alternative groundwater monitoring program and that have not already detected contamination are required to conduct 

ground-water sampling and analysis under section 265.93(b). 
27

In deriving these facility estimates, EPA estimates that 50 percent of all interim status facilities 

not conducting an alternative ground-water program have already detected contamination. These 

facilities must conduct sampling and analysis on a quarterly basis in accordance with section 

265.93(d)(4). In addition, EPA estimates that 2 percent of these facilities will confirm the presence of 

ground-water contamination each year. These facilities must submit a notification of contamination to the 

Regional Administrator, submit a ground-water quality assessment plan based on the outline developed 

under section 265.93(b), conduct an initial ground-water quality assessment, and submit a ground-water 

quality assessment report as required under section 265.93(d)(5). The remaining facilities must conduct 

sampling and analysis semi-annually, in accordance with sections 265.92(d) and (e).

This ICR assumes that there is no additional burden associated with the requirements of section 

265.93(e). Any facilities subject to the requirements of this section are considered in the burden estimates 

under section 265.93(d)(5). 

Recordkeeping and Reporting

The requirements of section 265.94(a) apply only to the facilities that are not conducting an 

alternative ground-water monitoring program and have not already detected contamination. EPA assumes 

that the records of ground-water analytical data required under this section will be updated semi-annually. 

Drinking water suitability parameter reports are developed and submitted only by newly interim facilities 

on a quarterly basis during the first year. Reports on indicator parameters and ground-water surface 

elevations are submitted annually by all respondents subject to the section 265.94(a) requirements.

Based on past experience, EPA estimates that two percent of the facilities conducting a groundwater monitoring program in accordance with section 265.93(b) will detect significant indicator 

parameter increases (or pH decreases) in up gradient wells, and will therefore be required to develop and 

submit a report in accordance with section 265.93(c)(1).

The requirements of section 265.94(b) apply to the facilities conducting ground-water quality 

assessments. Facilities conducting assessments as part of an alternative ground-water monitoring system 

are covered in the burden estimates for section 265.90. EPA assumes that the recordkeeping requirements 

of section 265.94 are conducted on a quarterly basis, and that reports on the results of the ground-water 

quality assessment program are submitted annually.

6(e) BOTTOM LINE BURDEN HOURS AND COST

Respondent Tally

Exhibits 7 and 8 show the aggregate annual hours, labor costs, total capital/startup costs, total 

O&M costs, and the overall annual costs to respondents. The bottom line annual hourly burden for

respondents is 117,027 at a cost of $4,553,948 in labor and $17,870,276 in capital/startup and operating 

and maintenance costs. 

Agency Tally

Exhibit 9 shows the annual hour and cost burden to the Agency. The bottom line annual hourly 

burden to the Agency is 34,850 at a cost of $1,327,862.
28

6(f) REASONS FOR CHANGE IN BURDEN

This current ICR estimates a total annual respondent burden of 117,027 hours. The previous ICR 

estimated a total annual respondent burden of 84,391 hours, which is an increase of 32,636 hours. The 

reason for the increase in hourly burden is due to an increase in the respondent universe (818 for the 

previous ICR vs 881 for this renewal), as well as an increase in burden estimates based on consultations, 

as described in Section 3.

6(g) BURDEN STATEMENT

Burden Statement: The annual public reporting and recordkeeping burden for this section of 

information is estimated to average 133 hours per response. Burden means the total time, effort, or 

financial resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and verifying information, 

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

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

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

information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR Part 9 and 

48 CFR Chapter 15. 

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

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

techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-RCRA2014-0926, 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), WJC West, Room 3334, 1301 Constitution Avenue, 

NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 

(202) 566-1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access those 

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

then key in the Docket ID Number identified above. Also, you can send comments to the Office of 

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

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA-HQ-RCRA-2014-0926 and OMB Control Number 2050-0033 in any correspondence.
29

EXHIBIT 1

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PRIVATELY-OW NED PERMITTED FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$107.51 $87.58 $41.98 $23.46 Hours Cost Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities Year Year

Reading the Regulations

 Read the regulations 0.50 0.50 0.50 0.00 1.50 $119 $0 $0 100 150.00 $11,900

SUBTOTAL varies varies varies varies varies varies varies varies varies 150.00 $11,900

Implement Ground-water Monitoring System

 Conduct hydrogeologic investigation 0.00 0.00 40.00 0.00 40.00 $1,679 $0 $48,663 0 0.00 $0

 Design and install ground-water monitoring system 0.00 0.00 4.00 0.00 4.00 $168 $12,236 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 0.00 $0

DETECTION MONITORING

Sampling and Analysis

 Determine ground-water flow rate and direction

 (annually)(264.98(e)) 0.00 4.00 25.00 4.00 33.00 $1,494 $0 $4,314 158 5,214.00 $917,664

 Sample and analyze ground-water (semi-annually)

 (264.98(d)-(f)) 0.00 8.00 32.00 8.00 80.00 $2,232 $0 $9,707 316 25,280.00 $3,772,566

 Record ground-water analytical data

 (semi-annually) (264.98(c)) 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 316 632.00 $31,284

Notification of Contamination

 Prepare and submit the notification of

 contamination (264.98(g)(1)) 0.25 0.50 1.00 0.50 2.25 $124 $0 $4 16 36.00 $2,041

Re-sampling and Analysis

 Re-sample and analyze ground-water for Appendix IX

 compounds (264.98(g)(2)) 0.00 14.00 60.00 14.00 88.00 $4,073 $0 $17,795 16 1,408.00 $349,892

 Record ground-water analytical data (264.98(c)) 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 16 32.00 $1,584

Alternate Concentration Limits

 Compile and submit data necessary to establish an

 alternate concentration limit (264.98(g)(5)(i)) 0.00 2.00 16.00 2.00 20.00 $894 $0 $26,963 3 60.00 $83,570

Engineering Feasibility plans

 Prepare and submit an engineering feasibility plan

 for corrective action if required under 264.98(g)(5)(ii) 0.00 2.00 80.00 2.00 84.00 $3,580 $0 $43,140 7 588.00 $327,040

Demonstration

 Prepare and submit notification of intent to make a 

 demonstration under 264.98(g)(6) 0.25 0.50 1.00 0.50 2.25 $124 $0 $4 1 2.25 $128

 Prepare and submit the demonstration (264.98(g)(6)) 0.00 2.00 16.00 2.00 20.00 $894 $0 $5,000 1 20.00 $5,894

SUBTOTAL varies varies varies varies varies varies varies varies varies 33,272.25 $5,491,662
30

EXHIBIT 1 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PRIVATELY-OWNED PERMITTED FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$107.51 $87.58 $41.98 $23.46 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

COMPLIANCE MONITORING

Sampling and Analysis

 Determine ground-water flow rate and direction

 (annually)(264.99(e)) 0.00 4.00 25.00 4.00 33.00 $1,494 $0 $4,314 30 990.00 $174,240

 Sample and analyze ground-water (semi-annually)

 (264.99(f)-(g)) 0.00 14.00 60.00 14.00 88.00 $4,073 $0 $17,795 60 5,280.00 $1,312,095

 Record ground-water analytical data

 (semi-annually)(264.99(c)(2)) 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 60 120.00 $5,940

Notification of New Constituents

 Compile information for notification of new

 constituents (264.99(g)) 0.00 2.00 4.00 2.00 8.00 $390 $0 $0 8 64.00 $3,120

 Prepare and submit the notification (264.99(g)) 0.25 1.00 2.00 1.00 4.25 $222 $0 $4 8 34.00 $1,804

Notification of Exceeded Concentration Limits

 Compile information on exceeded concentration 

 limits (264.99(h)(1)) 0.00 0.50 1.00 0.50 2.00 $98 $0 $0 15 30.00 $1,470

 Prepare and submit the notification (264.99(h)(1)) 0.25 0.50 1.00 0.50 2.25 $124 $0 $4 15 33.75 $1,913

Demonstration

 Prepare and submit a notification of intent (264.99(i)(1))

 to make a demonstration under 264.99(i) 0.25 0.50 1.00 0.50 2.25 $124 $0 $4 2 4.50 $255

 Prepare and submit the demonstration (264.99(i)(2)) 0.00 2.00 16.00 2.00 20.00 $894 $0 $5,393 2 40.00 $12,573

SUBTOTAL varies varies varies varies varies varies varies varies varies 6,596.25 $1,513,411

CORRECTIVE ACTION

Sampling and Analysis

 Sample and analyze ground-water (semi-annually)

 (264.100(d)) 0.00 8.00 32.00 8.00 80.00 $2,232 $0 $9,707 222 17,760.00 $2,650,347

 Record ground-water analytical data

 (semi-annually)(264.100(d)) 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 222 444.00 $21,978

Demonstrations

 Compile and submit information for the 

 demonstration from corrective action (264.100(e)(2)) 1.00 8.00 32.00 4.00 45.00 $2,245 $0 $4 0 0.00 $0

 Compile and submit information for the

 demonstration for termination of corrective 

 action (264.100(f)) 0.00 2.00 16.00 2.00 20.00 $894 $0 $5,393 0 0.00 $0

Report on the Effectiveness of Corrective Action

 Develop and submit the report (semi-annually)

 (264.100(g)) 0.00 2.00 8.00 2.00 12.00 $558 $0 $5,393 222 2,664.00 $1,321,011

SUBTOTAL varies varies varies varies varies varies varies varies varies 20,868.00 $3,993,336

TOTAL varies varies varies varies varies varies varies varies varies 60,886.50 $11,010,309
31

EXHIBIT 2

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PRIVATELY-OW NED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$107.51 $87.58 $41.98 $23.46 Hours/ Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

Reading the Regulations

 Read the regulations 1.00 1.50 1.50 0.00 4.00 $302 $0 $0 178 712.00 $53,756

SUBTOTAL varies varies varies varies varies varies varies varies varies 712.00 $53,756

APPLICABILITY AND ALTERNATE GROUND-W ATER

MONITORING SYSTEMS

Demonstrations (265.90(c) and 265.90(e))

 Develop and submit the demonstration (265.90(c)) 0.00 30.00 75.00 15.00 120.00 $6,128 $0 $93,830 0 0.00 $0

 Develop and submit the demonstration (265.90(e)) 0.00 30.00 75.00 15.00 120.00 $6,128 $0 $93,830 0 0.00 $0

 Maintain records 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 0 0.00 $0

Alternate Ground-water Monitoring Plan

(265.90(d)(1))

 Compile information for an alternate ground-water

 monitoring plan 0.00 200.00 400.00 150.00 750.00 $37,827 $0 $0 0 0.00 $0

 Obtain certification 0.00 10.00 25.00 5.00 40.00 $2,043 $0 $5,393 0 0.00 $0

 Develop and submit the plan 3.00 30.00 60.00 10.00 103.00 $5,703 $0 $4 0 0.00 $0

Ground-w ater Quality Assessment Reports

(265.90(d)(3) and (5))

 Develop and submit the reports 0.00 1.00 20.00 3.00 24.00 $998 $0 $5,393 3 72.00 $19,172

 Maintain a record of the ground-water quality

 assessment data at the facility 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 3 6.00 $297

Demonstration for alternate w ell location

(265.91(a)(3))

 Develop and submit the demonstration 0.00 2.00 16.00 2.00 20.00 $894 $0 $5,393 0 0.00 $0

 Maintain records 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 78.00 $19,469

Implementing Ground-water Monitoring System (265.90)

 Conduct hydrogeologic investigation 0.00 24.00 200.00 24.00 248.00 $11,061 $0 $32,355 0 0.00 $0

 Design and install ground-water monitoring system 0.00 40.00 120.00 8.00 168.00 $8,728 $4,314 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 0.00 $0
32

EXHIBIT 2 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PRIVATELY-OWNED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$107.51 $87.58 $41.98 $23.46 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

SAMPLING, ANALYSIS AND ASSESSMENT

Sampling and Analysis Plan (265.92(a))

 Compile information for a written sampling and

 analysis plan 0.00 0.00 40.00 0.00 40.00 $1,679 $0 $5,393 0 0.00 $0

 File the plan at the facilty 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 0 0.00 $0

Notification of Increased Indicator Parameter

Concentrations (265.93(d)(1))

 Prepare a ground-water quality assessment plan 

 outline (265.93(a)) 0.00 5.00 24.00 16.00 45.00 $1,821 $0 $0 0 0.00 $0

 Compile and submit notification 1.00 1.00 5.00 2.00 9.00 $452 $0 $4 5 45.00 $2,278

Ground-w ater Quality Assessment Program Plan

(265.93(d)(2)-(3))

 Develop and submit plan 0.00 8.00 24.00 16.00 48.00 $2,084 $0 $4 5 240.00 $10,438

Initial Ground-w ater Quality Assessment Report

(265.93(d)(5))

 Develop and submit the report 0.00 1.00 20.00 3.00 24.00 $998 $0 $5,393 5 120.00 $31,953

Sampling and Analysis

 Conduct sampling and analysis to determine

 ground-water quality under alternate ground-water

 monitoring system (quarterly) (265.90(d)(4)) 0.00 4.00 16.00 4.00 24.00 $1,116 $0 $4,853 12 288.00 $71,631

 Conduct sampling and analysis of ground-water to

 obtain analytical data (semi-annually) (265.92(d)-(e)) 0.00 4.00 16.00 4.00 24.00 $1,116 $0 $4,853 530 12,720.00 $3,163,703

 Conduct sampling and analysis as part of ground-water

 quality assessment program (quarterly) (265.93(d)(4)) 0.00 4.00 16.00 4.00 24.00 $1,116 $0 $4,853 1063 25,512.00 $6,345,313

SUBTOTAL varies varies varies varies varies varies varies varies varies 38,925.00 $9,625,314
33

EXHIBIT 2 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PRIVATELY-OW NED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$107.51 $87.58 $41.98 $23.46 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

RECORDKEEPING AND REPORTING

Recordkeeping (265.94(a)(1))

 Record ground-water analytical data at the

 facility (semi-annually) 0.00 0.50 1.00 0.50 2.00 $98 $1 $0 530 1,060.00 $52,470

Report on Drinking Water Suitability Parameters

(265.94(a)(2)(i))

 Prepare and submit a report of concentrations

 or values of the drinking water suitability

 parameters (quarterly) 0.00 0.50 1.00 0.50 2.00 $98 $1 $4 0 0.00 $0

Reports on Indicator Parameters and Groundwater Surface Elevations (265.94(a)(2)(ii) and (iii))

 Prepare and submit a report on indicator

 parameter concentrations and evaluations as

 determined under 265.93(b) 0.00 2.00 4.00 2.00 8.00 $390 $1 $4 265 2,120.00 $104,558

 Prepare and submit a report of any significant 

 indicator parameter increases (or pH decreases)

 in upgradient wells (265.93(c)(1)) 0.00 1.00 2.00 1.00 4.00 $195 $1 $4 5 20.00 $998

 Prepare and submit a report on ground-water

 surface elevations as determined under 265.92(e) 0.00 2.00 4.00 2.00 8.00 $390 $1 $4 265 2,120.00 $104,558

Record of Ground-w ater Quality Assessment

(265.94(b)(1))

 Record ground-water quality assessment data 

 obtained under 265.93(d)(4) (quarterly) 0.00 0.50 2.00 0.50 3.00 $139 $1 $0 1063 3,189.00 $148,820

Ground-w ater Quality Assessment Report

(265.94(b)(2))

 Prepare and submit a report on the results of the

 ground-water quality assessment program (annually) 0.00 1.00 2.00 1.00 4 $195 $1 $4 265.5 1,062.00 $52,983

SUBTOTAL varies varies varies varies varies varies varies varies varies 9,571.00 $464,387

TOTAL varies varies varies varies varies varies varies varies varies 49,286.00 $10,162,926
34

EXHIBIT 3

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PUBLICALLY-OW NED PERMITTED FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$59.38 $55.75 $33.35 $21.28 Hours Cost Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities Year Year

Reading the Regulations

 Read the regulations 0.50 0.50 0.50 0.00 1.50 $74 $0 $0 7 10.50 $518

SUBTOTAL varies varies varies varies varies varies varies varies varies 10.50 $518

Implement Ground-water Monitoring System

 Conduct hydrogeologic investigation 0.00 0.00 40.00 0.00 40.00 $1,334 $0 $48,663 0 0.00 $0

 Design and install ground-water monitoring system 0.00 0.00 4.00 0.00 4.00 $133 $12,236 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 0.00 $0

DETECTION MONITORING

Sampling and Analysis

 Determine ground-water flow rate and direction

 (annually)(264.98(e)) 0.00 4.00 25.00 4.00 33.00 $1,142 $0 $4,314 11 363.00 $60,016

 Sample and analyze ground-water (semi-annually)

 (264.98(d)-(f)) 0.00 8.00 32.00 8.00 80.00 $1,683 $0 $9,707 22 1,760.00 $250,569

 Record ground-water analytical data

 (semi-annually) (264.98(c)) 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 22 44.00 $1,606

Notification of Contamination

 Prepare and submit the notification of

 contamination (264.98(g)(1)) 0.25 0.50 1.00 0.50 2.25 $87 $0 $4 1 2.25 $91

Re-sampling and Analysis

 Re-sample and analyze ground-water for Appendix IX

 compounds (264.98(g)(2)) 0.00 14.00 60.00 14.00 88.00 $3,079 $0 $17,795 1 88.00 $20,874

 Record ground-water analytical data (264.98(c)) 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 1 2.00 $73

Alternate Concentration Limits

 Compile and submit data necessary to establish an

 alternate concentration limit (264.98(g)(5)(i)) 0.00 2.00 16.00 2.00 20.00 $688 $0 $26,963 0 0.00 $0

Engineering Feasibility plans

 Prepare and submit an engineering feasibility plan

 for corrective action if required under 264.98(g)(5)(ii) 0.00 2.00 80.00 2.00 84.00 $2,822 $0 $43,140 1 84.00 $45,962

Demonstration

 Prepare and submit notification of intent to make a 

 demonstration under 264.98(g)(6) 0.25 0.50 1.00 0.50 2.25 $87 $0 $4 0 0.00 $0

 Prepare and submit the demonstration (264.98(g)(6)) 0.00 2.00 16.00 2.00 20.00 $688 $0 $5,000 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 2,343.25 $379,191
35

EXHIBIT 3 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PUBLICALLY-OW NED PERMITTED FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$59.38 $55.75 $33.35 $21.28 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

COMPLIANCE MONITORING

Sampling and Analysis

 Determine ground-water flow rate and direction

 (annually)(264.99(e)) 0.00 4.00 25.00 4.00 33.00 $1,142 $0 $4,314 2 66.00 $10,912

 Sample and analyze ground-water (semi-annually)

 (264.99(f)-(g)) 0.00 14.00 60.00 14.00 88.00 $3,079 $0 $17,795 4 352.00 $83,497

 Record ground-water analytical data

 (semi-annually)(264.99(c)(2)) 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 4 8.00 $292

Notification of New Constituents

 Compile information for notification of new

 constituents (264.99(g)) 0.00 2.00 4.00 2.00 8.00 $287 $0 $0 1 8.00 $287

 Prepare and submit the notification (264.99(g)) 0.25 1.00 2.00 1.00 4.25 $159 $0 $4 1 4.25 $163

Notification of Exceeded Concentration Limits

 Compile information on exceeded concentration 

 limits (264.99(h)(1)) 0.00 0.50 1.00 0.50 2.00 $72 $0 $0 1 2.00 $72

 Prepare and submit the notification (264.99(h)(1)) 0.25 0.50 1.00 0.50 2.25 $87 $0 $4 1 2.25 $91

Demonstration

 Prepare and submit a notification of intent (264.99(i)(1))

 to make a demonstration under 264.99(i) 0.25 0.50 1.00 0.50 2.25 $87 $0 $4 0 0.00 $0

 Prepare and submit the demonstration (264.99(i)(2)) 0.00 2.00 16.00 2.00 20.00 $688 $0 $5,393 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 442.50 $95,313

CORRECTIVE ACTION

Sampling and Analysis

 Sample and analyze ground-water (semi-annually)

 (264.100(d)) 0.00 8.00 32.00 8.00 80.00 $1,683 $0 $9,707 14 1,120.00 $159,453

 Record ground-water analytical data

 (semi-annually)(264.100(d)) 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 14 28.00 $1,022

Demonstrations

 Compile and submit information for the 

 demonstration from corrective action (264.100(e)(2)) 1.00 8.00 32.00 4.00 45.00 $1,658 $0 $4 0 0.00 $0

 Compile and submit information for the

 demonstration for termination of corrective 

 action (264.100(f)) 0.00 2.00 16.00 2.00 20.00 $688 $0 $5,393 0 0.00 $0

Report on the Effectiveness of Corrective Action

 Develop and submit the report (semi-annually)

 (264.100(g)) 0.00 2.00 8.00 2.00 12.00 $421 $0 $5,393 14 168.00 $81,389

SUBTOTAL varies varies varies varies varies varies varies varies varies 1,316.00 $241,864

TOTAL varies varies varies varies varies varies varies varies varies 4,112.25 $716,886
36

EXHIBIT 4

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PUBLICALLY-OW NED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$59.38 $55.75 $33.35 $21.28 Hours/ Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

Reading the Regulations

 Read the regulations 1.00 1.50 1.50 0.00 4.00 $193 $0 $0 10 40.00 $1,930

SUBTOTAL varies varies varies varies varies varies varies varies varies 40.00 $1,930

APPLICABILITY AND ALTERNATE GROUND-W ATER

MONITORING SYSTEMS

Demonstrations (265.90(c) and 265.90(e))

 Develop and submit the demonstration (265.90(c)) 0.00 30.00 75.00 15.00 120.00 $4,493 $0 $93,830 0 0.00 $0

 Develop and submit the demonstration (265.90(e)) 0.00 30.00 75.00 15.00 120.00 $4,493 $0 $93,830 0 0.00 $0

 Maintain records 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 0 0.00 $0

Alternate Ground-water Monitoring Plan

(265.90(d)(1))

 Compile information for an alternate ground-water

 monitoring plan 0.00 200.00 400.00 150.00 750.00 $27,682 $0 $0 0 0.00 $0

 Obtain certification 0.00 10.00 25.00 5.00 40.00 $1,498 $0 $5,393 0 0.00 $0

 Develop and submit the plan 3.00 30.00 60.00 10.00 103.00 $4,064 $0 $4 0 0.00 $0

Ground-w ater Quality Assessment Reports

(265.90(d)(3) and (5))

 Develop and submit the reports 0.00 1.00 20.00 3.00 24.00 $787 $0 $5,393 0 0.00 $0

 Maintain a record of the ground-water quality

 assessment data at the facility 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 0 0.00 $0

Demonstration for alternate w ell location

(265.91(a)(3))

 Develop and submit the demonstration 0.00 2.00 16.00 2.00 20.00 $688 $0 $5,393 0 0.00 $0

 Maintain records 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 0.00 $0

Implementing Ground-water Monitoring System (265.90)

 Conduct hydrogeologic investigation 0.00 24.00 200.00 24.00 248.00 $8,519 $0 $32,355 0 0.00 $0

 Design and install ground-water monitoring system 0.00 40.00 120.00 8.00 168.00 $6,402 $4,314 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 0.00 $0
37

EXHIBIT 4 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PUBLICALLY-OW NED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$59.38 $55.75 $33.35 $21.28 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

SAMPLING, ANALYSIS AND ASSESSMENT

Sampling and Analysis Plan (265.92(a))

 Compile information for a written sampling and

 analysis plan 0.00 0.00 40.00 0.00 40.00 $1,334 $0 $5,393 0 0.00 $0

 File the plan at the facilty 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 0 0.00 $0

Notification of Increased Indicator Parameter

Concentrations (265.93(d)(1))

 Prepare a ground-water quality assessment plan 

 outline (265.93(a)) 0.00 5.00 24.00 16.00 45.00 $1,420 $0 $0 0 0.00 $0

 Compile and submit notification 1.00 1.00 5.00 2.00 9.00 $324 $0 $4 0 0.00 $0

Ground-w ater Quality Assessment Program Plan

(265.93(d)(2)-(3))

 Develop and submit plan 0.00 8.00 24.00 16.00 48.00 $1,587 $0 $4 0 0.00 $0

Initial Ground-w ater Quality Assessment Report

(265.93(d)(5))

 Develop and submit the report 0.00 1.00 20.00 3.00 24.00 $787 $0 $5,393 0 0.00 $0

Sampling and Analysis

 Conduct sampling and analysis to determine

 ground-water quality under alternate ground-water

 monitoring system (quarterly) (265.90(d)(4)) 0.00 4.00 16.00 4.00 24.00 $842 $0 $4,853 0 0.00 $0

 Conduct sampling and analysis of ground-water to

 obtain analytical data (semi-annually) (265.92(d)-(e)) 0.00 4.00 16.00 4.00 24.00 $842 $0 $4,853 30 720.00 $170,858

 Conduct sampling and analysis as part of ground-water

 quality assessment program (quarterly) (265.93(d)(4)) 0.00 4.00 16.00 4.00 24.00 $842 $0 $4,853 60 1,440.00 $341,715

SUBTOTAL varies varies varies varies varies varies varies varies varies 2,160.00 $512,573
38

EXHIBIT 4 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST

PUBLICALLY-OW NED INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$59.38 $55.75 $33.35 $21.28 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

RECORDKEEPING AND REPORTING

Recordkeeping (265.94(a)(1))

 Record ground-water analytical data at the

 facility (semi-annually) 0.00 0.50 1.00 0.50 2.00 $72 $1 $0 30 60.00 $2,190

Report on Drinking Water Suitability Parameters

(265.94(a)(2)(i))

 Prepare and submit a report of concentrations

 or values of the drinking water suitability

 parameters (quarterly) 0.00 0.50 1.00 0.50 2.00 $72 $1 $4 0 0.00 $0

Reports on Indicator Parameters and Groundwater Surface Elevations (265.94(a)(2)(ii) and (iii))

 Prepare and submit a report on indicator

 parameter concentrations and evaluations as

 determined under 265.93(b) 0.00 2.00 4.00 2.00 8.00 $287 $1 $4 15 120.00 $4,373

 Prepare and submit a report of any significant 

 indicator parameter increases (or pH decreases)

 in upgradient wells (265.93(c)(1)) 0.00 1.00 2.00 1.00 4.00 $144 $1 $4 0 0.00 $0

 Prepare and submit a report on ground-water

 surface elevations as determined under 265.92(e) 0.00 2.00 4.00 2.00 8.00 $287 $1 $4 15 120.00 $4,373

Record of Ground-w ater Quality Assessment

(265.94(b)(1))

 Record ground-water quality assessment data 

 obtained under 265.93(d)(4) (quarterly) 0.00 0.50 2.00 0.50 3.00 $105 $1 $0 60 180.00 $6,360

Ground-w ater Quality Assessment Report

(265.94(b)(2))

 Prepare and submit a report on the results of the

 ground-water quality assessment program (annually) 0.00 1.00 2.00 1.00 4 $144 $1 $4 15.5 62.00 $2,303

SUBTOTAL varies varies varies varies varies varies varies varies varies 542.00 $19,599

TOTAL varies varies varies varies varies varies varies varies varies 2,742.00 $534,102
39

EXHIBIT 5

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED AGENCY BURDEN AND COST

PERMITTED FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$77.92 $56.05 $39.33 $23.92 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

DETECTION MONITORING

Notification of Contamination (264.98(g)(1))

 Review the notification 0.00 0.00 8.00 0.00 8.00 $315 $0 $0 17 136.00 $5,355

 Enter the information into data base 0.00 0.00 0.00 2.00 2.00 $48 $0 $0 17 34.00 $816

Alternate Concentration Limits (264.98(g)(5)(i))

 Evaluate data submitted to justify an alternate

 concentration limit 0.00 0.00 160.00 0.00 160.00 $6,293 $0 $0 4 640.00 $25,172

 Enter information into data base 0.00 0.00 0.00 4.00 4.00 $96 $0 $0 4 16.00 $384

Engineering Feasibility plans (264.98(g)(5)(ii)

 Evaluate engineering feasibility plan for a

 corrective action program 0.00 0.00 160.00 0.00 160.00 $6,293 $0 $0 8 1,280.00 $50,344

 Enter information into data base 0.00 0.00 0.00 4.00 4.00 $96 $0 $0 8 32.00 $768

Demonstration (264.98(g)(6))

 Review notification of intent to submit a

 demonstration of contamination from an outside

 source 0.00 0.00 8.00 0.00 8.00 $315 $0 $0 1 8.00 $315

 Review the demonstration 0.00 0.00 40.00 0.00 40.00 $1,573 $0 $0 1 40.00 $1,573 $0 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 2,186.00 $84,727

COMPLIANCE MONITORING

Demonstration (264.99(i))

 Review the notification 0.00 0.00 8.00 0.00 8.00 $315 $0 $0 2 16.00 $630

 Review the demonstration 0.00 0.00 40.00 0.00 40.00 $1,573 $0 $0 2 80.00 $3,146

Notification of New Constituents (264.99(g))

 Review the notification 0.00 0.00 8.00 0.00 8.00 $315 $0 $0 8 64.00 $2,520

 Enter information into data base 0.00 0.00 0.00 2.00 2.00 $48 $0 $0 8 16.00 $384

Notification of Exceeded Concentration Limits

(264.99(h)(1))

 Review notification 0.00 0.00 8.00 0.00 8.00 $315 $0 $0 16 128.00 $5,040

 Enter information into data base 0.00 0.00 0.00 2.00 2.00 $48 $0 $0 16 32.00 $768

SUBTOTAL varies varies varies varies varies varies varies varies varies 336.00 $12,488

CORRECTIVE ACTION

Demonstrations (264.100(e)(2) and 264.100(f))

 Review the demonstrations 0.00 0.00 40.00 0.00 40.00 $1,573 $0 $0 0 0.00 $0

Report on the Effectiveness of Corrective Action

(264.100(g))

 Evaluate report 0.00 0.00 40.00 0.00 40.00 $1,573 $0 $0 236 9,440.00 $371,228

 Enter information into data base 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 236 1,888.00 $45,076

SUBTOTAL varies varies varies varies varies varies varies varies varies 11,328.00 $416,304

TOTAL varies varies varies varies varies varies varies varies varies 13,850.00 $513,519
40

EXHIBIT 6

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED AGENCY BURDEN AND COST

INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$77.92 $56.05 $39.33 $23.92 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

APPLICABILITY AND ALTERNATE GROUND-W ATER

MONITORING SYSTEMS

Demonstrations (265.90(c) and 265.90(e))

 Review the demonstrations 0.00 40.00 70.00 10.00 120.00 $5,234 $0 $0 0 0.00 $0

Alternate Ground-w ater Monitoring Plan

(265.90(d)(1))

 Review the alternate ground-water monitoring plan 0.00 25.00 50.00 5.00 80.00 $3,487 $0 $0 0 0.00 $0

Ground-w ater Quality Assessment Reports

(265.90(d)(3) and (5))

 Review the reports 0.00 15.00 25.00 0.00 40.00 $1,824 $0 $0 3 120.00 $5,472

 Enter information into a database 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 3 24.00 $573

Demostration for alternate w ell location

(265.91(a)(3))

Review the demonstrations 0.00 20.00 35.00 5.00 60.00 $2,617 $0 $0 0 0.00 $0

SUBTOTAL varies varies varies varies varies varies varies varies varies 144.00 $6,045

SAMPLING, ANALYSIS, AND ASSESSMENT

Notification of Increased Indicator Parameter

Concentrations (265.93(d)(1))

 Review the notification 0.00 2.00 6.00 0.00 8.00 $348 $0 $0 6 48.00 $2,088

 Enter information into a database 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 6 48.00 $1,146

Ground-water Quality Assessment Plan (265.93(d)(2))

 Evaluate the plan 0.00 10.00 30.00 0.00 40.00 $1,740 $0 $0 6 240.00 $10,440

Initial Ground-w ater Quality Assessment Report

(265.93(d)(5))

 Evaluate the reports 0.00 10.00 30.00 0.00 40.00 $1,740 $0 $0 6 240.00 $10,440

 Enter information into a database 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 6 48.00 $1,146

SUBTOTAL varies varies varies varies varies varies varies varies varies 624.00 $25,260
41

EXHIBIT 6 (continued)

REPORTING AND RECORDKEEPING REQUIREMENTS FOR GROUND-W ATER MONITORING REQUIREMENT

ANNUAL ESTIMATED AGENCY BURDEN AND COST

INTERIM STATUS FACILITIES

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Number of

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

$77.92 $56.05 $39.33 $23.92 Hours Cost Startup O & M or Hours Cost

INFORMATION COLLECTION ACTIVITY / Year / Year / Year / Year / Year / Year Cost Cost Activities / Year / Year

RECORDKEEPING AND REPORTING

Report on Drinking Water Suitability Parameters

(265.94(a)(2)(i))

 Review the report 0.00 23.00 69.00 0.00 92.00 $4,003 $0 $0 0 0.00 $0

 Enter information into a database 0.00 0.00 0.00 32.00 32.00 $765 $0 $0 0 0.00 $0

Reports on Indicator Parameters and Groundwater Surface Elevations (265.94(a)(2)(ii) and (iii))

 Review report on indicator concentrations and

 evaluations as determined under 265.93(b) 0.00 1.50 6.00 0.50 8.00 $332 $0 $0 280 2,240.00 $92,960

 Review report on significant indicator parameter

 increases in upgradient wells 0.00 1.50 6.00 0.50 8.00 $332 $0 $0 6 48.00 $1,992

 Review report on ground-water surface elevations

 as determined under 265.92(e) 0.00 1.50 6.00 0.50 8.00 $332 $0 $0 280 2,240.00 $92,960

 Enter information into a database 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 280 2,240.00 $53,480

Ground-w ater Quality Assessment Report

(265.94(b)(2))

 Review the ground-water quality assessment report 0.00 10.00 30.00 0.00 40.00 $1,740 $0 $0 280.5 11,220.00 $488,070

 Enter information into a database 0.00 0.00 0.00 8.00 8.00 $191 $0 $0 280.5 2,244.00 $53,576

SUBTOTAL varies varies varies varies varies varies varies varies varies 20,232.00 $783,038

TOTAL varies varies varies varies varies varies varies varies varies 21,000.00 $814,343
42

 

EXHIBIT 7

TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARY

PRIVATELY-OWNED PERMITTED AND INTERIM STATUS FACILITIES

Total Total Total Annual Total Total

Hours per Labor Cost Capital/ Startup Annual O&M Cost per

EXHIBIT Year Per Year Costs Per Year Costs Per Year Year

PERMITTED FACILITIES

Reading the Regulations 150 $11,900 $0 $0 $11,900

Implement Ground-water Monitoring

System 0 $0 $0 $0 $0

Detection Monitoring 33,272 $1,069,812 $332 $4,421,518 $5,491,662

Compliance Monitoring 6,596 $305,342 $60 $1,208,009 $1,513,411

Corrective Action 20,868 $641,136 $222 $3,351,978 $3,993,336

SUBTOTAL 60,887 $2,028,190 $614 $8,981,505 $11,010,309

INTERIM STATUS FACILITIES

Reading the Regulations 712 $53,756 $0 $0 $53,756

Applicability and Alternate Ground-water

Monitoring Systems 78 $3,288 $3 $16,178 $19,469

Implement Ground-water Monitoring

System 0 $0 $0 $0 $0

Sampling, Analysis, and Assessment 38,925 $1,808,850 $0 $7,816,464 $9,625,314

Recordkeeping and Reporting 9,571 $459,145 $2,394 $2,849 $464,387

SUBTOTAL 49,286 $2,325,039 $2,397 $7,835,491 $10,162,926

TOTAL 110,173 $4,353,229 $3,011 $16,816,996 $21,173,235
43

 

EXHIBIT 8

TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARY

PUBLICALLY-OWNED PERMITTED AND INTERIM STATUS FACILITIES

Total Total Total Annual Total Total

Hours per Labor Cost Capital/ Startup Annual O&M Cost per

EXHIBIT Year Per Year Costs Per Year Costs Per Year Year

PERMITTED FACILITIES

Reading the Regulations 11 $518 $0 $0 $518

Implement Ground-water Monitoring

System 0 $0 $0 $0 $0

Detection Monitoring 2,343 $57,232 $23 $321,936 $379,191

Compliance Monitoring 443 $15,493 $4 $79,816 $95,313

Corrective Action 1,316 $30,464 $14 $211,386 $241,864

SUBTOTAL 4,112 $103,707 $41 $613,138 $716,886

INTERIM STATUS FACILITIES

Reading the Regulations 40 $1,930 $0 $0 $1,930

Applicability and Alternate Ground-water

Monitoring Systems 0 $0 $0 $0 $0

Implement Ground-water Monitoring

System 0 $0 $0 $0 $0

Sampling, Analysis, and Assessment 2,160 $75,780 $0 $436,793 $512,573

Recordkeeping and Reporting 542 $19,302 $136 $162 $19,599

SUBTOTAL 2,742 $97,012 $136 $436,954 $534,102

TOTAL 6,854 $200,719 $177 $1,050,092 $1,250,988
44

 

EXHIBIT 9

TOTAL ESTIMATED AGENCY BURDEN AND COST SUMMARY

PERMITTED AND INTERIM STATUS FACILITIES

Total Total

Hours per Cost per

EXHIBIT Year Year

PERMITTED FACILITIES

Detection Monitoring 2,186 $84,727

Compliance Monitoring 336 $12,488

Corrective Action 11,328 $416,304

SUBTOTAL 13,850 $513,519

INTERIM STATUS FACILITIES

Applicability and Alternate Ground-water

Monitoring Systems 144 $6,045

Sampling, Analysis, and Assessment 624 $25,260

Recordkeeping and Reporting 20,232 $783,038

SUBTOTAL 21,000 $814,343

TOTAL 34,850 $1,327,862