SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST NUMBER 1935.05

"STANDARDIZED PERMIT FOR RCRA HAZARDOUS WASTE 

MANAGEMENT FACILITIES"

January 2016
Table of Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION

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

1(b) Short Characterization................................................................................... 1

2. NEED FOR AND USE OF THE COLLECTION

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

2(b) Practical Utility and Users of the Data.......................................................... 9

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication ............................................................................................ 12

3(b) Public Notice ............................................................................................... 12

3(c) Consultations............................................................................................... 12

3(d) Effects of Less Frequent Collection ............................................................ 13

3(e) General Guidelines...................................................................................... 13

3(f) Confidentiality............................................................................................. 13

3(g) Sensitive Questions ..................................................................................... 13

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes.................................................................. 13

4(b) Information Requested ................................................................................ 14

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities........................................................................................ 60

5(b) Collection Methodology and Management................................................. 62

5(c) Small Entity Flexibility ............................................................................... 62

5(d) Collection Schedule..................................................................................... 62

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden................................................................... 64

6(b) Estimating Respondent Costs...................................................................... 64

6(c) Estimating Agency Burden and Costs......................................................... 65

6(d) Estimating the Respondent Universe and Total Burden and Cost .............. 73

6(e) Bottom Line Burden Hours and Costs ........................................................ 73

6(f) Reasons for Change in Burden.................................................................... 73

6(g) Burden Statement ........................................................................................ 74

1. IDENTIFICATION OF THE INFORMATION COLLECTION
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1(a) Title and Number of the Information Collection

“Standardized Permit for RCRA Hazardous Waste Management Facilities”, ICR 

Number 1935.05, OMB Number 2050-0182.

1(b) Short Characterization

Under the authority of sections 3004, 3005, 3008 and 3010 of the Resource Conservation 

and Recovery Act (RCRA), as amended, the U.S. Environmental Protection Agency (EPA) is 

finalizing revisions to the RCRA hazardous waste permitting program to allow a “standardized 

permit”. The standardized permit would be available to facilities that generate hazardous waste 

and routinely manage the waste on-site in non-thermal units such as tanks, containers, and 

containment buildings. In addition, the standardized permit is available to facilities that receive 

hazardous waste generated off-site by a generator under the same ownership as the receiving 

facility, and then store or non-thermally treat the hazardous waste in containers, tanks, or 

containment buildings. The RCRA standardized permit would consist of two components: a 

uniform portion that is included in all cases, and a supplemental portion that the Director of a 

regulatory agency would include at his or her discretion. The uniform portion would consist of 

terms and conditions, relevant to the unit(s) at the permitted facility, and would be established on 

a national basis. The Director, at his or her discretion, may also issue a supplemental portion on 

a case-by-case basis. The supplemental portion would impose site-specific permit terms and 

conditions that the Director determines necessary to institute corrective action under section 

264.101 (or State equivalent), or otherwise necessary to protect human health and the 

environment. Owners and operators would have to comply with the terms and conditions in the 

supplemental portion, in addition to those in the uniform portion. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

This section describes the need and authority for each type of information collection 

analyzed in this ICR. Information collection requirements for the standardized permit are 

authorized by sections 2002 and 3007 of RCRA, as amended. In particular, section 2002 gives 

the Administrator the authority to promulgate such regulations as are necessary to carry out the 

functions of this subchapter. Section 3007 gives EPA the authority to compel anyone who 

generates, stores, treats, transports, disposes of or otherwise handles or has handled hazardous 

wastes to furnish information related to such wastes and make such information available to the 

government for the purposes of enforcing the provisions of this chapter. EPA believes the 

information collection requirements are necessary to balance the reduction in regulatory burden 

with the Agency’s responsibility to protect human health and the environment.

APPLYING FOR A STANDARDIZED PERMIT
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Section 270.275 requires that applicants for a standardized permit submit to the 

permitting agency information that will be used as the basis of the standardized permit 

application. This information includes: 

 Part A permit information required by section 270.13; 

 A summary of the pre-application public meeting and other materials required by section 

124.31; 

 Documentation of compliance with the location standards of sections 267.18 and 

270.14(b)(11);

 Information that allows the Director to carry out his obligations under other Federal laws 

required in section 270.3; 

 Solid waste management unit information required by section 270.14(d); and

 A signed certification of the facility’s compliance with part 267, as specified at section 

270.280.

 A report documenting the results of the compliance audit as required by section 270.280.

 A closure plan prepared in accordance with part 267 subpart G.

 The most recent closure cost estimate for your facility prepared under §267.142 and a 

copy of the documentation required to demonstrate financial assurance under §267.143. 

For a new facility, you may gather the required documentation 60 days before the initial 

receipt of hazardous wastes.

 A waste analysis plan, if you manage wastes generated off-site

 Documentation showing that the same person owns both the waste generator and 

receiving facility, if you manage waste generated off-site

EPA needs this information to comprehensively evaluate the potential risk posed by 

facilities seeking permits. This information aids EPA in meeting its goal of ascertaining and 

minimizing risks to human health and the environment from hazardous waste management 

facilities.

In addition, facilities that store or treat hazardous waste under a standardized permit must 

keep at their facilities general types of information (section 270.290), as well as unit-specific 

information for containers (section 270.300), tanks (section 270.305), equipment subject to part 

264, subpart BB (section 270.310), and tanks and containers subject to part 264, subpart CC 

(section 270.315). EPA anticipates that the owner or operator will use this information to ensure 
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that tanks, containers, and other equipment are in good condition and that operating requirements 

are being satisfied, and to prevent placing in proximity wastes that are incompatible with other 

wastes that are likely to ignite or explode. EPA needs this information to evaluate compliance of 

facilities with the permitting standards. These requirements contribute to EPA’s goal of insuring 

that hazardous waste management facilities are operated in a manner fully protective of human 

health and the environment.

MAINTAINING A STANDARDIZED PERMIT

Sections 124.211, 124.212, 124.213, and 124.214 specify procedures for making routine 

and significant changes to the standardized permit. Section 124.212 requires owners and 

operators seeking to make routine changes (Class 1 permit modification not requiring prior 

approval under 40 CFR 270.42, Appendix I) to their standardized permits to submit to the 

Director the revised information; and, in cases where the routine change amends information 

submitted under section 270.275, to provide notice of the changes to the facility mailing list and 

to state and local governments, in accordance with the procedures in sections 124.10(c)(1)(ix) 

and (x). Sections 124.213 requires owners and operators seeking to make routine changes with 

prior approval to submit their requests for changes to the Director for approval and follow the 

procedures in section 124.212(b)(1) - (2). Section 124.214 requires owners and operators 

seeking to make significant changes to their standardized permits to provide notice and conduct a 

public meeting. After holding the public meeting, the owner or operator of the facility must 

submit a modification request to the Director.

EPA needs this information to comprehensively evaluate whether requests for routine or 

significant changes should be granted. The permit modification procedures contribute to EPA’s 

goal of providing a role for the public in the permitting process. In general, these informational 

requirements aid in meeting EPA’s goal of ascertaining and minimizing risks to human health 

and the environment from hazardous waste management facilities.

GENERAL FACILITY STANDARDS

40 CFR part 267, subpart B (sections 267.10 through 267.18) specifies general facility

standards that apply to owners and operators of facilities who treat or store hazardous waste 

under a standardized permit. To comply with this subpart, owners and operators must follow 

record keeping and reporting requirements for waste analyses (section 267.13); security (section 

267.14); inspections (section 267.15); employee training (section 267.16); management of 

ignitable, reactive, or incompatible wastes (section 267.17); and facility location (section 

267.18). 

(1) Waste Analyses

EPA and owners and operators use information obtained in waste analysis results to 

determine: (1) whether the facility can adequately handle the waste, and (2) whether the waste is 

really what the generator claims it to be. The owner or operator also uses information obtained 
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from the waste analysis to determine whether there are any potential dangers from handling the 

waste. 

(2) Security

EPA uses information on security to ensure that the owner and operator of the facility has 

taken the necessary measures to ensure that there is no physical contact with the waste, 

structures, or equipment within the active portion of the facility that would injure people or 

livestock.

(3) Inspections

EPA and owners and operators use information in the inspection log to determine 

whether facility equipment is safe for handling hazardous waste. The inspection requirement 

contributes to EPA's goal of preventing hazardous waste constituents from being released into 

the environment due to faulty or deteriorated equipment. 

(4) Employee Training

Both EPA and owners and operators use information in employee training records to 

determine whether employees have acquired the necessary expertise to perform their jobs. EPA 

also reviews personnel records to determine whether employees are receiving a level of training 

that is commensurate with their duties and responsibilities as well as their ability to respond to 

any emergency situations at the facility. Requiring owners and operators to maintain personnel 

training documents decreases the likelihood that employees are unqualified to handle hazardous 

waste or respond to emergencies. The personnel record keeping requirement contributes to 

EPA's goal of minimizing the potential for employee-related mistakes that may threaten human 

health and the environment.

(5) Demonstration of Compliance for Ignitable, Reactive, 

or Incompatible Wastes

EPA uses information in the documentation of compliance for ignitable, reactive, or 

incompatible wastes to determine whether facilities are operating in a manner that is protective 

of human health and the environment. The documentation requirement contributes to EPA's goal 

of minimizing unanticipated damage from the treatment, storage, or disposal of hazardous waste. 

(6) Facility Location

EPA and owners and operators use site-specific information to determine whether a 

location is suitable for conducting hazardous waste management activities in a manner that does 

not pose a threat to human health or the environment

EPA needs all the information described above to evaluate the compliance of facilities 

with the permitting standards. These requirements contribute to EPA’s goal of insuring that 
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hazardous waste management facilities are operated in a manner fully protective of human health 

and the environment.

PREPAREDNESS AND PREVENTION

Sections 267.30 through 267.36 require owners and operators to design, construct, 

maintain, and operate their facilities in a manner that minimizes threats to human health and the 

environment caused by the release of waste from a fire, explosion, or any unplanned event. 

Section 267.36(b) specifically requires owners and operators to document any refusal on the part 

of any local authorities to enter into an arrangement to handle emergencies. EPA and the owner 

and operator of a facility use this information to ensure that adequate emergency response 

personnel are available, if needed, and to document that all necessary arrangements with State or

local authorities have been made.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Section 3004(a)(5) of RCRA, as amended, requires EPA to develop standards for 

contingency plans for effective action to minimize unanticipated damage from any treatment, 

storage, or disposal of any such hazardous waste. Sections 267.50 through 267.58 require all 

owners and operators of hazardous waste facilities to prepare and maintain contingency plans, 

and to notify State and local authorities and prepare and emergency reports whenever an 

imminent or actual emergency situation occurs. EPA reviews the contingency plan and 

emergency reports to determine whether a facility has developed adequate procedures to respond 

to unplanned sudden or non-sudden releases of hazardous waste or hazardous constituents to air, 

soil, or surface water. Notifications to State and local authorities facilitate remedial actions and 

evacuations, if necessary. Requiring facilities to develop and maintain contingency plans and 

prepare emergency response reports and notifications contributes to EPA's goal of minimizing 

unanticipated damage from the treatment, storage, or disposal of hazardous waste. 

RECORD KEEPING, REPORTING, AND NOTIFYING

Section 267.70 through 267.74 direct owners or operators of facilities that treat or store 

hazardous waste under a standardized permit to keep an operating record at the facility. The 

operating record must include, among other things, a description and the quantity of each 

hazardous waste received, and the method(s) and date(s) of its treatment, storage, or disposal at 

the facility; records and results of waste analyses performed; summary reports and details of all 

incidents that require implementing the contingency plan; and records and results of inspection 

reports. EPA uses information collected pursuant to these regulations to select appropriate 

corrective action and cleanup measures should an unanticipated release of hazardous waste 

occur. EPA compliance officials refer to the operating record to determine the following: (1) 

what cleanup measures are appropriate and (2) whether operating requirements can be better 

tailored to the needs of a particular site. EPA anticipates that the owner or operator will use 

information included in the operating record to prevent receiving, or placing in proximity, wastes 

that are incompatible with other wastes that are likely to ignite or explode. Requiring facilities to 

develop and maintain an operating record and conduct the record keeping activities contributes 
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to EPA's goal of minimizing damage to the environment due to the treatment, storage, or 

disposal of hazardous waste.

CLOSURE

40 CFR part 267, subpart G (sections 267.110 through 267.117) requires owners and 

operators to develop closure plans, amend these plans when appropriate, and submit to EPA 

closure certifications. EPA reviews information in the closure plans to determine whether 

closure activities will comply with the regulatory requirements. EPA uses information in the 

closure certifications to determine that closure took place in accordance with the approved 

closure plan. 

FINANCIAL REQUIREMENTS

Section 3004(a)(6) of the Resource Conservation and Recovery Act of 1976 (RCRA), as 

amended, requires EPA to promulgate regulations that include requirements respecting "the 

maintenance of operations of such facilities and requiring such additional qualifications as to ... 

financial responsibility (including financial responsibility for corrective action) as may be 

necessary or desirable."

The need for financial assurance of closure care is indicated by the numerous instances of 

environmental damage resulting from abandonment of hazardous waste management facilities 

and other failures by owners and operators to provide adequately for closure care. The 

likelihood of such failure is increased by the fact that the costs for closure care are expected to 

commence when the economic value of the facility is either at a minimum or nonexistent. 

EPA believes that significant numbers of owners and operators would lack the ability to 

provide for closure care without effective requirements for financial assurance. Consequently, 

the Agency developed 40 CFR part 267, subpart H financial responsibility requirements for 

closure care. 

The liability requirements are designed to assure that funds will be available during the 

operating life of a facility from which third parties can seek compensation for bodily injury and 

property damage arising from the operation of the facility. The liability requirements are 

necessary for several reasons. First, the requirements provide protection to human health and the 

environment by assuring that funds are available to owners and operators to compensate for 

damage caused by accidents at hazardous waste facilities, including payments for bodily injury

and property damage. In addition, the Agency believes that without liability coverage 

requirements, there would be less public confidence in and greater opposition to proposed and 

existing hazardous waste facilities. The liability requirements also result in other potential 

benefits for human health and the environment: the incentive, in the form of lower insurance 

premiums, to improve design and operation of the facility, and the oversight that insurers provide 

over facility operations.

USE AND MANAGEMENT OF CONTAINERS
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Sections 267.172 and 267.15(d) require owners and operators that store or treat hazardous 

waste in containers to inspect areas where they store containers, at least weekly, and record the 

inspection results. EPA needs this information to evaluate the compliance of facilities with the 

permitting standards and ensure that containers used for the storage and treatment of hazardous 

waste, under the standardized permit, do not pose a threat to human health and the environment. 

These requirements contribute to EPA’s goal of safe management of hazardous waste.

TANK SYSTEMS

40 CFR part 267, subpart J specifies record keeping and reporting requirements 

associated with demonstrations for secondary containment waivers (section 267.190), design and 

construction standards (section 267.191), installation requirements (section 267.194), inspection 

requirements (section 267.199), and leaks and spills (section 267.200). EPA needs this 

information to evaluate the compliance of facilities with the permitting standards and ensure that 

tank systems used for the storage and treatment of hazardous waste, under the standardized 

permit, do not pose a threat to human health and the environment. These requirements 

contribute to EPA’s goal of safe management of hazardous waste.

CONTAINMENT BUILDINGS

40 CFR part 267, subpart DD specifies record keeping and reporting requirements 

associated with inspections (section 267.1103); demonstrations for secondary containment 

requirement waivers (section 267.1104); containment buildings containing areas both with and 

without secondary containment (section 267.1105); and detection of releases (section 267.1106). 

EPA needs this information to evaluate the compliance of facilities with the permitting standards 

and ensure that containment buildings used for the storage and treatment of hazardous waste, 

under the standardized permit, do not pose a threat to human health and the environment. These 

requirements contribute to EPA’s goal of safe management of hazardous waste.

2(b) Practical Utility and Users of the Data

APPLYING FOR A STANDARDIZED PERMIT

EPA uses information submitted by facilities to evaluate exposure potential and minimize 

any risks to human health from hazardous waste management facilities. If EPA determines that a 

facility poses a substantial risk to human health, EPA may request that the Agency for Toxic 

Substances and Disease Registry conduct a health assessment.

EPA uses information regarding specific units at facilities to evaluate the adequacy of 

each unit to manage hazardous wastes. Additional information is required because each of the 

different types of hazardous waste management units present different risks to the environment 

and consequently requires different standards. EPA reviews the submittals of each type of 

hazardous waste management unit to evaluate whether it is designed, constructed, and operated 
10

in a manner protective of human health and the environment. EPA uses the information required 

by part 264, subparts BB and CC to ensure compliance with air emission standards.

MAINTAINING A STANDARDIZED PERMIT

EPA uses permit information to evaluate the initial permit application and any subsequent 

request for modification. The public may also use draft EPA permit and permit modification 

determinations, which incorporate data submitted by facilities, to assess hazardous waste 

management facilities being developed in their communities.

GENERAL FACILITY STANDARDS

EPA uses the information requirements in 40 CFR parts 267 and 270 for owners and 

operators submitting standardized permit applications to evaluate compliance with various 

elements of the regulations. The waste analysis and waste analysis plan, as well as the inspection 

schedule and documentation of compliance for ignitable or incompatible wastes, are primarily

internal record keeping requirements used by owners and operators of facilities to assure that 

they can adequately handle the waste, to assure that the incoming waste is really what the 

generator claims it to be, and to prevent undetected releases or reactions of hazardous waste onsite. Much of the information in the waste analysis plan will also be used to provide a quality 

assurance check on both the generator and the owners' and operators' facilities. Both EPA and 

owners and operators use information in the employee training records to ensure that employees 

acquire the necessary expertise to perform their jobs. During inspections, EPA reviews job 

descriptions and training documents to determine whether each person is receiving a level of 

training that is commensurate with the person's duties and responsibilities as well as the ability to 

respond to any emergency situations at the facility. 

PREPAREDNESS AND PREVENTION

The facility owner or operator uses the documented refusal on the part of the State or 

local authorities to enter in emergency response arrangements to demonstrate that he or she has 

undertaken all the necessary activities to minimize threats to human health and the environment 

caused by the release of waste from a fire, explosion, or any unplanned event.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Local emergency response teams, facility owners or operators, and EPA use information 

included in the contingency plan to assure an appropriate response to any unplanned release of 

hazardous waste or hazardous waste constituents. EPA reviews information in the contingency

plan and emergency report to determine whether additional site-specific emergency provisions 

are necessary. 

RECORD KEEPING, REPORTING, AND NOTIFYING
11

The facility owner or operator uses information included in the operating record and 

waste disposal location and quantity records to prevent the facility from placing in proximity

wastes that are incompatible or that are likely to ignite or explode. If an unanticipated release of 

hazardous waste occurs, the owner or operator may review information in the operating record to 

determine the composition of the waste. Reviewing information in the operating record 

facilitates the owner's or operator's selection of an appropriate corrective action and cleanup 

measure. By providing facility-specific data, the operating record also enables EPA compliance 

officials to determine whether operating requirements can be better tailored to the needs of a 

particular site.

CLOSURE

EPA uses information contained in closure plans to determine whether an owner or 

operator's planned closure activities will comply with environmental regulations. EPA officials 

use information contained in closure certifications to ensure that the owner or operator closed 

his/her facility according to the specifications outlined in the approved closure plan. EPA uses 

information contained in demonstrations to ensure that any activities taking place during the 

closure period are protective of human health and the environment. 

FINANCIAL REQUIREMENTS

EPA uses the financial insurance information requirements to evaluate the facility

owner’s financial ability to close the facility and to respond to any contingencies. The closure 

and liability coverage financial instruments submitted by the owner or operator are reviewed by

EPA to determine compliance with the applicable subpart H regulations. This review involves 

determinations of the validity of the instrument, acceptability of the financial assurance provider, 

adequacy of the instrument amount, and fulfillment of the other regulatory requirements. The 

information is also used to direct funds for closure and liability coverage in the event of default 

or bankruptcy of a facility owner or operator.

USE AND MANAGEMENT OF CONTAINERS

EPA uses information on containers obtained during facility inspections to evaluate the 

adequacy of each container to manage hazardous wastes, and ensure that containers are being 

used in a manner protective of human health and the environment. 

TANK SYSTEMS

EPA uses information on tank systems obtained during facility inspections to evaluate the 

adequacy of each tank to manage hazardous wastes, and ensure that tank systems are being used 

in a manner protective of human health and the environment. 

CONTAINMENT BUILDINGS
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EPA uses information on containment buildings obtained during facility inspections to 

evaluate the adequacy of each containment building to manage hazardous wastes, and ensure that 

containment buildings are being used in a manner protective of human health and the 

environment. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

In finalizing the standardized permit rule, EPA streamlined the permit process by

allowing certain types of facilities to obtain and modify permits more easily while maintaining 

the protectiveness currently existing in the individual RCRA permit process. Thus, facility

owners and operators are relieved of certain RCRA record keeping and reporting requirements 

that currently exist under the RCRA permitting process. 

3(b) Public Notice

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

the Federal Register on September 16, 2015 (80 FR 55618) and provided a 60 day comment 

period for this ICR. No comments were received.

3(c) Consultations

With only 5 states authorized for the standardized permit rule, we found only one facility 

that had been issued a standardized permit. A consultation was conducted with that one facility, 

BP Exploration in Alaska which received a standardized permit from EPA Region 10. They felt 

the burden estimates in this ICR were accurate.

3(d) Effects of Less Frequent Collection

The standardized permit application procedures are less cumbersome than the procedures 

for an individual permit. Owners and operators do not have to submit the amount of information 

needed to support an individual permit application, although they need to keep the information at 

their facility. In addition, the procedures for modifying standardized permits would allow 

owners and operators to make certain types of routine changes without prior approval, provided 

that they inform both the regulatory agency and the public of the changes. EPA believes the 

collection frequencies specified in this ICR are necessary to ensure protection of human health 

and the environment.

3(e) General Guidelines

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

OMB's implementing regulations, EPA's Information Collection Review Handbook, and other 

applicable OMB guidance.
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3(f) Confidentiality

Section 3007(b) of RCRA and 40 CFR part 2, subpart B, which define EPA's general 

policy on public disclosure of information, contain provisions for confidentiality. EPA does not 

anticipate requesting any confidential information.

3(g) Sensitive Questions

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

requirements.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The following is a list of North American Industrial Classification System (NAICS) 

codes associated with industries most likely affected by the information collection requirements 

covered under this ICR.

323110 Commercial Lithographic Printing

323114 Quick Printing

325131 Inorganic Dye and Pigment Manufacturing 

325188 All Other Basic Inorganic Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing 

331311 Alumina refining

325211 Plastics Material and Resins Manufacturing

32551 Paint and Coating Manufacturing

32511 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

325188 All Other Inorganic Chemical Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing

311942 Spice and Extract Manufacturing 

32411 Petroleum Refineries

332813 Electroplating, Plating, Polishing, Anodizing and Coloring

33271 Machine Shops

332991 All Other Miscellaneous Fabricated Metal Product Manufacturing

333319 Other Commercial or Service Industry Machinery Manufacturing

Accessories

333999 All Other General Purpose Machinery Manufacturing

336399 All Other Motor Vehicle Part Manufacturing

334 Computer and Electronic Product Manufacturing

336 Transportation Equipment Manufacturing
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48422 Specialized Freight (except Used Goods) Trucking, Local

56211 Waste Collection

22111 Electric Power Generation

22112 Fossil Fuel Electric Power Generation

22132 Sewage Treatment Facilities

56292 Materials Recovery Facilities

56221 Waste Treatment and Disposal

42271 Petroleum Bulk Stations and Terminals

45431 Fuel Dealers

4411 Automobile Dealers

4471 Gasoline Stations

811111 General Automotive Repair

4(b) Information Requested

This section describes information collection requirements applicable to facilities that are

affected by this ICR.

APPLYING FOR A STANDARDIZED PERMIT

(1) General Information Requirements

(i) Data items

Sections 124.202, 270.275, 270.280, and 270.285 require owners and operators wishing 

to obtain a standardized permit to provide the following data items:

 A written notice to the Director that the owner or operator intends to operate under a 

standardized permit;

 The Part A information required by section 270.13 (this information is described and 

burdened under the Part A Permit Application ICR);

 A meeting summary and other materials required by section 124.31;

 Documentation of compliance with the location standards of sections 267.18 and 

270.14(b)(11), including:

-- An identification of the political jurisdiction in which the facility is proposed to 

be located;

-- If the facility is proposed to be located in an area listed in Appendix VI of part 

264, a demonstration of compliance with the seismic standard as defined under 
15

section 264.18(a). This demonstration may be made using either published 

geologic data or data obtained from field investigations carried out by the 

applicant;

-- An identification of whether the facility is located within a 100-year floodplain

 Information that allows the Director to carry out his obligations under other Federal laws 

required in section 270.3;

 Solid waste management unit information required by section 270.14(d), including:

-- The location of each unit on the topographic map required under section 

270.14(b)(19);

-- Designation of the type of each unit;

-- General dimensions and structural description of each unit;

-- Dates when each unit was operated;

-- Specification of all wastes that have been managed at each unit, to the extent 

available;

-- All available information pertaining to any release of hazardous wastes or 

hazardous constituents from each unit (section 270.14(d)(2));

-- Results of sampling and analysis, where the Director ascertains that a RCRA 

Facility Assessment is necessary.

 A signed certification of the facility’s compliance with part 267, as specified at section 

270.280; and

 A closure plan prepared in accordance with part 267 subpart G.

 The most recent closure cost estimate for your facility prepared under §267.142 and a 

copy of the documentation required to demonstrate financial assurance under §267.143. 

For a new facility, you may gather the required documentation 60 days before the initial 

receipt of hazardous wastes.

 Results of a compliance audit, as required by section 270.280.

 A waste analysis plan, if you manage waste generated off-site.
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 Documentation showing that the same person owns both the waste generator and the 

receiving facility, if you manage waste generated off-site. 

(ii) Respondent activities

In order to obtain a standardized permit, owners and operators will have to perform the 

following activities:

 Read the regulations;

 Prepare a written notice of intent to operate under a standardized permit;

 Obtain the Part A information;

 Obtain the meeting summary and other materials required by section 124.31;

 Develop documentation of compliance with location standards;

 Prepare information that allows the Director to carry out his obligations under other 

Federal laws;

 Prepare the solid waste management unit information;

 Prepare and sign the certification of compliance with part 267;

 If necessary, prepare a schedule of compliance with part 267; 

 Prepare a closure plan;

 Prepare a closure cost estimate.

 Prepare documentation to demonstrate financial assurance under §267.143; and, 

 Conduct a compliance audit and prepare a report of the results of the audit.

 If you manage waste generated off-site, prepare a waste analysis plan.

 If you manage waste generated off-site, prepare documentation showing that the same 

person owns both the waste generator and the receiving facility. 

 Submit the above information to the Director.

(2) Record Keeping Requirements
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(i) Data items

Section 270.290 requires owners and operators applying for a standardized permit to keep 

the following information at their facilities:

 A general description of the facility;

 Chemical and physical analyses of the hazardous waste and hazardous debris handled at 

the facility. At a minimum, these analyses must contain all the information required to 

treat or store the wastes properly under the requirements of part 267;

 A copy of the waste analysis plan required by section 267.13(b);

 A description of the security procedures and equipment required by section 267.14, or a 

justification demonstrating the reasons for a waiver from these requirements;

 A copy of the general inspection schedule required by section 267.15(b), as well as the 

applicable inspection schedule requirements of sections 267.174, 267.193, 267.195, 

267.1033, 267.1052, 267.1053, 267.1058, and 267.1088;

 A justification for any modification of the preparedness and prevention requirements of 

part 267, subpart C;

 A copy of the contingency plan required by part 267, subpart D;

 A description of the procedures, structures, or equipment used at the facility to:

-- Prevent hazards in unloading operations;

-- Prevent runoff from hazardous waste handling areas to other areas of the facility

or environment, or to prevent flooding;

-- Prevent contamination of water supplies;

-- Mitigate effects of equipment failure and power outages;

-- Prevent undue exposure of personnel to hazardous waste; and

-- Prevent releases to the atmosphere;

 A description of precautions to prevent accidental ignition or reaction of ignitable, 

reactive, or incompatible wastes as required by section 267.17;

 A description of traffic patterns, estimated volumes, and controls near the facility;
18

 An outline of both the introductory and continuing programs you will use to prepare 

employees to operate or maintain the facility safely, as required by section 267.16;

 A brief description of how training will be designed to meet actual job tasks under 

section 267.16(a)(3) requirements;

 A copy of the closure plan required by section 267.112. Specific requirements in sections 

267.178, 267.197, and 267.1102 should be included, where applicable, as part of the 

plans;

 The most recent closure cost estimate for the facility prepared under section 267.142, and 

a copy of the documentation required to demonstrate financial assurance under section 

267.143. For new facilities, this documentation must be gathered at least 60 days prior to 

the initial receipt of hazardous wastes;

 Where applicable, a copy of the insurance policy or other documentation that complies 

with the liability requirements of section 267.147. For a new facility, documentation 

showing the amount of insurance meeting the specification of section 267.147(a) that the 

owner or operator plans to have in effect before initial receipt of hazardous waste for 

treatment or storage;

 Where appropriate, proof of coverage by a State financial mechanism, as required by

section 267.149 or section 267.150; and

 A topographic map that meets the requirements specified at section 270.290(s).

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will have to perform 

the following activities:

 Read the regulations;

 Prepare and maintain a general description of the facility;

 Maintain documentation of chemical and physical analyses of the hazardous waste and 

hazardous debris handled at the facility (this activity is covered under section 267.13(a));

 Maintain a copy of the waste analysis plan required by section 267.13(b);

 Prepare and maintain a description of the security procedures and equipment required by 

section 267.14, or a justification demonstrating the reasons for a waiver from these 

requirements;
19

 Maintain a copy of the applicable inspection schedules;

 Prepare and maintain a justification for any modification of the preparedness and 

prevention requirements of part 267, subpart C;

 Maintain a copy of the contingency plan;

 Prepare and maintain a description of the procedures, structures, or equipment used at the 

facility to:

-- Prevent hazards in unloading operations;

-- Prevent runoff from hazardous waste handling areas to other areas of the facility

or environment, or to prevent flooding;

-- Prevent contamination of water supplies;

-- Mitigate effects of equipment failure and power outages;

-- Prevent undue exposure of personnel to hazardous waste; and

-- Prevent releases to the atmosphere;

 Maintain a description of precautions to prevent accidental ignition or reaction of 

ignitable, reactive, or incompatible wastes;

 Prepare and maintain a description of traffic patterns, estimated volumes, and controls 

near the facility;

 Maintain an outline of both the introductory and continuing programs you will use to 

prepare employees to operate or maintain the facility safely, as required by section 

267.16;

 Maintain a brief description of how training will be designed to meet actual job tasks;

 Maintain a copy of the closure plan;

 Maintain records of most recent closure cost estimate and a copy of the documentation 

required to demonstrate financial assurance;

 Where applicable, maintain a copy of the insurance policy or other documentation that 

complies with the liability requirements of section 267.147;
20

 Where appropriate, maintain proof of coverage by a State financial mechanism; and

 Obtain and maintain a topographic map.

(3) Container Information Requirements

(i) Data items

In addition to the general information requirements listed at section 270.290, section 

270.300 requires owners and operators of facilities with containers to keep the following 

information at their facilities:

 A description of the containment system to demonstrate compliance with section 

267.173;

 For storage areas that store containers holding wastes that do not contain free liquids, a 

demonstration of compliance with section 267.173. This description must show the 

following:

-- Basic design parameters, dimensions, and materials of construction;

-- How the design promotes drainage or how containers are kept from contact with 

standing liquids in the containment system;

-- The capacity of the containment system relative to the number and volume of 

containers to be stored;

-- Provisions for preventing or managing run-on; and

-- How accumulated liquids can be analyzed and removed to prevent overflow;

 For storage areas that store containers holding wastes that do not contain free liquids, a 

demonstration of compliance with section 267.173(c), including:

-- Test procedures and results of other documentation or information to show that 

the wastes do not contain free liquids; and

-- A description of how the storage area is designed or operated to drain and remove 

liquids or how containers are kept from contact with standing liquids;

 Sketches, drawings, or data demonstrating compliance with section 267.174 (location of 

buffer zone and containers holding ignitable or reactive wastes) and section 267.175(c) 

(location of incompatible wastes), where applicable;
21

 Where incompatible wastes are stored or otherwise managed in containers, a description 

of the procedures used to ensure compliance with sections 267.175(a) and (b); and

 Information on air emission control equipment, as required by section 270.315.

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Prepare and maintain a description of the containment system;

 For storage areas that store containers holding wastes that do not contain free liquids, 

prepare and maintain a demonstration of compliance with section 267.173(c);

 Where applicable, obtain and maintain sketches, drawings, or data demonstrating 

compliance with sections 267.174 and 267.175(c);

 Where incompatible wastes are stored or otherwise managed in containers, prepare and 

maintain a description of the procedures used to ensure compliance with sections 

267.175(a) and(b); and

 Maintain information on air emission control equipment;

(4) Tank Information Requirements

(i) Data items

In addition to the general information requirements listed at section 270.290, section 

270.305 requires owners and operators of facilities with tanks to keep the following information 

at their facilities:

 A written assessment that is reviewed and certified by an independent, qualified, 

registered professional engineer on the structural integrity and suitability for handling 

hazardous waste of each tank system, as required under sections 267.191 and 267.192;

 The dimensions and capacity of each tank;

 A description of feed systems, safety cutoff, bypass systems, and pressure controls;

 A diagram of piping, instrumentation, and a process flow for each tank system;
22

 A description of materials and equipment used to provide external corrosion protection,

as required under section 267.192;

 For new tank systems, a detailed description of how the tank system(s) will be installed in 

compliance with section 267.194;

 Detailed plans and a description of how the secondary containment system for each tank 

system is or will be designed, constructed, and operated to meet the requirements of 

sections 267.195 and 267.196;

 A description of controls and practices to prevent spills and overflows, as required under 

section 267.198;

 For tank systems in which ignitable, reactive, or incompatible wastes are to be stored or 

treated, a description of how operating procedures and tank system and facility design 

will achieve compliance with the requirements of sections 267.202 and 267.203; and

 Information on air emission control equipment as required by section 270.315.

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Maintain an engineer’s written assessment on the structural integrity and suitability for 

handling hazardous waste of each tank system;

 Document and maintain the dimensions and capacity of each tank;

 Prepare and maintain a description of feed systems, safety cutoff, bypass systems, and 

pressure controls;

 Prepare and maintain a diagram of piping, instrumentation, and a process flow for each 

tank system;

 Maintain a description of materials and equipment used to provide external corrosion 

protection;

 For new tank systems, prepare and maintain a detailed description of how the tank 

system(s) will be installed in compliance with section 267.194;
23

 Prepare and maintain detailed plans and a description of how the secondary containment 

system for each tank system is or will be designed, constructed, and operated to meet the 

requirements of sections 267.195 and 267.196;

 Prepare and maintain a description of controls and practices to prevent spills and 

overflows;

 For tank systems in which ignitable, reactive, or incompatible wastes are to be stored or 

treated, prepare and maintain a description of how operating procedures and tank system 

and facility design will achieve compliance with the requirements of sections 267.202 

and 267.203; and

 Maintain information on air emission control equipment.

(5) Equipment Information Requirements

(i) Data items

In addition to the general information requirements listed at section 270.290, section 

270.310 requires owners and operators of facilities with equipment to which subpart BB of part 

264 applies to keep the following information at their facilities:

 For each piece of equipment to which subpart BB of part 264 applies:

-- Equipment identification number and hazardous waste management unit 

identification;

-- Approximate locations within the facility;

-- Type of equipment;

-- Percent by weight of total organics in the hazardous waste stream at the 

equipment;

-- Hazardous waste state at the equipment (e.g., gas/vapor or liquid); and

-- Method of compliance with the standard;

 For facilities that cannot install a closed-vent system and control device to comply with 40 

CFR part 264 subpart BB on the effective date that the facility becomes subject to the subpart 

BB provisions, an implementation schedule as specified in section 264.1033(a)(2);

 For owners and operators who apply for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, condenser, 
24

or carbon adsorption system and choose to use test data to determine the organic removal 

efficiency or the total organic compound concentration achieved by the control device, a 

performance test plan as specified in section 264.1035(b)(3);

 Documentation that demonstrates compliance with the equipment standards in sections 

264.1052 and 254.1059; and

 Documentation to demonstrate compliance with section 264.1060. This documentation must 

include the following information:

-- A list of all information references and sources used in preparing the 

documentation;

-- Records, including the dates, of each compliance test required by section 

264.1033(j);

-- A design analysis, specifications, drawings, schematics, and piping and 

instrumentation diagrams. The design analysis must address the vent stream 

characteristics and control device operation parameters as specified in section 

260.1035(b)(4)(iii);

-- A statement, signed and dated by the owner or operator, certifying that the 

operating parameters used in the design analysis reasonably represent the 

conditions that exist when the hazardous waste management unit is operating at 

the highest load or capacity level reasonably expected to occur; and

-- A statement, signed and dated by the owner or operator, certifying that the control 

device is designed to operate at an efficiency of 95 weight percent or higher.

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 For each piece of equipment to which subpart BB of section 264 applies:

-- Maintain the equipment identification number and hazardous waste management 

unit identification;

-- Prepare and maintain approximate locations within the facility;

-- Prepare and maintain a description of the type of equipment;
25

-- Prepare and maintain a description of the percent by weight of total organics in 

the hazardous waste stream at the equipment;

-- Prepare and maintain a description of the hazardous waste state at the equipment 

(e.g., gas/vapor or liquid); and

-- Prepare and maintain a description of the method of compliance with the 

standard;

 For facilities that cannot install a closed-vent system and control device to comply with 

40 CFR part 264 subpart BB on the effective date that the facility becomes subject to the 

subpart BB provisions, prepare and maintain an implementation schedule;

 For owners and operators who apply for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, 

condenser, or carbon adsorption system and choose to use test data to determine the 

organic removal efficiency or the total organic compound concentration achieved by the 

control device, develop and maintain a performance test plan as specified;

 Develop and maintain documentation that demonstrates compliance with the equipment 

standards in sections 264.1052 and 254.1059; and

 Develop and maintain documentation to demonstrate compliance with section 264.1060. 

(6) Air Emissions Control Requirements

(i) Data items

In addition to the general information requirements listed at section 270.290, section 

270.315 requires owners and operators of facilities with equipment subject to subpart CC of part 

264 to keep the following information at their facilities:

 Documentation for each floating roof cover installed on a tank subject to sections 

264.1084(d)(1) or (d)(2) that includes information prepared by the owner or operator or 

provided by the manufacturer describing the cover design;

 A certification that the cover meets applicable design specifications listed in sections 

264.1084(e)(1) or (f)(1);

 Identification of each container area subject to the requirements of part 264, subpart CC, 

and a certification that the requirements of this subpart are met;
26

 Documentation for each enclosure used to control air pollutant emissions from tanks or 

containers under requirements of sections 264.1084(d)(5) or 264.1086(e)(1)(ii). This 

documentation must include records for the most recent set of calculations and 

measurements performed to verify that the enclosure meets the criteria of a permanent 

enclosure as specified in section 52.741, appendix B;

 Documentation for each closed-vent system and control device installed under 

requirements of section 264.1087 that includes design and performance information as 

specified in section 270.24(c) and (d); and

 An emission monitoring plan for both Method 21 in 40 CFR part 60, appendix A, and 

control device monitoring methods. This plan must include monitoring points, 

monitoring methods for control devices, monitoring frequency, procedures for 

documenting exceedences, and procedures for mitigating noncompliances.

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Prepare and maintain documentation for each floating roof cover installed on a tank 

subject to sections 264.1084(d)(1) or (d)(2);

 Prepare and maintain a certification that the cover meets applicable design specifications 

listed in sections 264.1084(e)(1) or (f)(1);

 Prepare and maintain an identification of each container area subject to the requirements 

of part 264, subpart CC, and a certification that the requirements of this subpart are met;

 Prepare and maintain documentation for each enclosure used to control air pollutant 

emissions from tanks or containers under requirements of sections 264.1084(d)(5) or 

264.1086(e)(1)(ii);

 Prepare and maintain documentation for each closed-vent system and control device 

installed under requirements of section 264.1087; and

 Develop and maintain an emission monitoring plan for both Method 21 in 40 CFR part 

60, appendix A, and control device monitoring methods.

(7) Switching from an Individual RCRA Permit to a Standardized Permit

(i) Data items
27

Section 124.203 allows owners and operators to switch their individual RCRA permits to 

standardized permits by submitting a request to the Director requesting that their individual 

permits be revoked and reissued as a standardized permit, in accordance with section 124.5.

(ii) Respondent activities

In order to provide the data item listed above, owners and operators seeking to switch 

from a RCRA individual permit to a standardized permit will need to perform the following 

activities:

 Read the regulations; and

 Prepare and submit the request to the Director.

(8) Reapplying for a Standardized Permit

(i) Data items

Section 270.10(h) requires owners and operators wishing to reapply for a standardized 

permit to submit a notice of intent under 270.10(b)(1) at least 180 days before the expiration date 

of the effective permit.

(ii) Respondent activities

Owners and operators reapplying for a standardized permit will need to perform the 

following activities:

 Read the regulations;

 Prepare and submit the notice of intent.

MAINTAINING A STANDARDIZED PERMIT

(1) Making Routine Changes

(i) Data items

Sections 124.212 and 270.320 require owners and operators seeking to make routine 

changes (class 1 modifications under 40 CFR 270.42 Appendix I that do not require prior 

approval from the Director) to their standardized permits to provide the following data items:

 The revised information pursuant to section 270.267(b)(1); and
28

 A notice of changes to the facility mailing list and to state and local governments in 

accordance with the procedures in sections 124.10(c)(1)(ix) and (x).

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Prepare and submit the revised information to the Director; and

 Submit the revised information to the facility mailing list and local governments.

(2) Making Routine Changes Requiring Prior Approval from the Director 

(124.212, 270.320(b))

(i) Data items

Section 124.213 and 270.320 require owners and operators seeking to make routine 

changes to their standardized permits to provide the following data items:

 The revised information pursuant to section 270.267(b)(1) requesting approval; and

 A notice of changes to the facility mailing list and to state and local governments in 

accordance with the procedures in sections 124.10(c)(1)(ix) and (x).

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Prepare and submit the revised information to the Director requesting approval

 After approval, submit the revised information to the facility mailing list and local 

governments.

(3) Making Significant Changes (124.214, 270.320)

(i) Data items
29

Sections 124.214 and 270.320 require owners and operators seeking to make significant 

changes (based on the criteria specified in section 270.320(b)(1)-(3)) to their standardized 

permits to provide the following data items:

 A public meeting (with prior notice);

 A modification request to the Director that:

-- Describes the exact change(s) desired, and whether they are changes to 

information provided under section 270.275 or to terms and conditions in the 

supplemental portion of the standardized permit;

-- Explains why the modification is needed; and

-- Includes a summary of the public meeting described above, along with the list of 

attendees and their addresses and copies of any written comments or materials 

submitted at the meeting.

(ii) Respondent activities

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Read the regulations;

 Provide notice of and hold a public meeting; and

 Prepare and submit the modification request to the Director (after holding the public 

meeting).

GENERAL FACILITY STANDARDS

(1) Obtaining an Identification Number

(i) Data items

Section 267.12 requires owners and operators of facilities to obtain an EPA identification 

number.

(ii) Respondent activities

In order to obtain an EPA identification number, owners and operators will need to 

perform the following activities:
30

 Read the regulations; and

 Obtain, fill out, and submit an application for an EPA identification number.

(2) Waste Analysis

(i) Data items

Section 267.13(a) requires an owner or operator to obtain a detailed chemical and 

physical analysis of any hazardous waste he or she intends to treat or store. The analysis may

include data, either existing or published, developed under 40 CFR part 261, as well as existing 

data on the hazardous waste or hazardous waste generated from similar processes. 

(ii) Respondent activities

In order to comply with section 267.13, respondents must perform the following 

activities:

 Read the regulations;

 Collect data; and

 Perform waste analysis (sampling, testing).

(3) Waste Analysis Plan

(i) Data items

Section 267.13(b) states that an owner or operator of a hazardous waste facility must 

develop and follow a written waste analysis plan that describes the procedures to be used in 

obtaining a detailed chemical and physical analysis of the waste. The owner or operator is 

required to keep the waste analysis plan at the facility. If you receive wastes generated from 

off-site, and are eligible for a standardized permit, you also must have submitted the waste 

analysis plan with the Notice of Intent. At a minimum, the plan must include the following 

information:

 Parameters for which each hazardous waste will be analyzed and the rationale for the 

selection of these parameters;

 Test methods used to test for the parameters; 

 Sampling method used to obtain a representative sample of the waste to be analyzed;
31

 Frequency with which the initial analysis of the waste will be reviewed or repeated to 

ensure that the analysis is accurate and up to date; 

 Where applicable, the methods which will be used to meet additional waste analysis 

requirements for specific waste management methods as specified in sections 264.17, 

264.1034(d), 264.1063(d), and 264.1083

(ii) Respondent activities

To meet the requirements outlined in section 267.13(b), owners or operators must 

perform the following activities:

 Read the regulations;

 Collect the data required in the waste analysis plan; 

 Write the waste analysis plan; and

 Maintain the plan (e.g., photocopying and filing).

If you receive wastes generated from off-site, and are eligible for a standardized permit, 

you submit the waste analysis plan with the Notice of Intent.

(4) Inspections

(i) Data items

Section 267.15 requires owners and operators to develop and follow a written schedule 

for monitoring equipment that is important in preventing, detecting, or responding to 

environmental or human health hazards. This schedule must be kept at the facility; and must 

identify the equipment and devices to be inspected, as well as the problems to be looked for. The 

frequency of inspections must be based on the rate of deterioration of the equipment and the 

probability of an environmental or human health incident if the deterioration, malfunction, or any

operator error goes undetected between inspections. At a minimum, the inspection schedule 

must include the items and frequencies required in sections 267.174, 267.193, 267.195, 

264.1033, 264.1052, 264.1053, 264.1058, and 264.1083 through 264.1089, where applicable.

Section 267.15(d) states that an owner or operator must record inspections conducted 

according to the written schedule developed pursuant to section 267.15(b) in an inspection log or 

summary that is to be maintained at the facility. The inspection log or summary must contain, at 

a minimum, the date and time of the inspection, the name of the inspector, a notation of the 

observations made, and the date and nature of any repairs or other remedial actions.

(ii) Respondent activities
32

To meet the requirements outlined in sections 267.15(b) and 267.15(d), the owner or 

operator must conduct the following activities:

 Read the regulations;

 Prepare the inspection schedule; and

 Record the results of inspections in the inspection log.

(5) Employee Training

(i) Data items

Section 267.16(d) requires an owner or operator to maintain copies of personnel training 

documents and records at the facility. These documents should include the following data items:

 Job title for each position at the facility related to hazardous waste management, and the 

name of the employee filling each job;

 Written job description for each position, which includes the necessary skill, education, 

or other qualifications and duties of employees assigned to each position;

 Written description of the type and amount of both introductory and continuing training 

that will be given to each person filling a position; and

 Records that document that the training or job experience required have been given to, 

and completed by, facility personnel. 

(ii) Respondent activities

Respondent activities associated with section 267.16 (d) include reading the regulations, 

collecting the data items listed above, and maintaining (e.g., photocopying and filing) the 

information at the facility.

(6) Ignitable, Reactive, or Incompatible Wastes

(i) Data items

Section 267.17(c) states that the owner or operator of a hazardous waste facility must 

take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. The 

owner or operator of a permitted facility must document compliance with the requirements 

outlined in sections 267.17(a) and (b). The documentation may be based on references to 

published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale 
33

tests), waste analyses (as specified in section 267.13), or the results of the treatment of similar 

wastes by similar treatment processes and under similar operating conditions. 

(ii) Respondent activities

Respondent activities associated with section 267.17(c) include reading the regulations, 

collecting and documenting the data items mentioned above, and maintaining (e.g., 

photocopying and filing) documentation at the facility.

PREPAREDNESS AND PREVENTION

(1) Arrangements with Local Authorities

(i) Data items

Section 267.36(b) requires owners and operators to document any refusal on the part of 

local authorities to enter into an arrangement to handle emergencies.

(ii) Respondent activities

Respondent activities associated with section 267.36(b) include reading the regulations, 

documenting any refusals, and placing this documentation into the facility operating record.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

(1) Contingency Plan

(i) Data items

Section 267.51 requires owners or operators to have a contingency plan for their facilities 

and section 267.53 requires the owner or operator to maintain a copy of an updated contingency 

plan at the facility. Section 267.52 outlines the data elements that should be included in this 

plan: 

 A description of the actions facility personnel will take to comply with sections 267.51 

and 267.56 in response to fires, explosions, or any unplanned releases of hazardous waste 

from the facility;

 A description of the arrangements agreed to by local police departments, fire 

departments, hospitals, contractors, and State and local emergency response teams to 

coordinate emergency services;

 An updated list of the names, addresses, and phone numbers (office and home) of all 

persons qualified to act as emergency coordinators;
34

 An updated list of all emergency equipment at the facility and the location, physical 

description, and capabilities of the emergency equipment. The contingency plan should 

also indicate where the emergency equipment will be required; and 

 An evacuation plan for facility personnel where there is a possibility that evacuation may

be necessary.

Section 267.53(b) requires owner and operators to submit a copy of the contingency plan 

and all revisions to all local police departments, fire departments, hospitals, and State and local 

emergency response teams that may be called upon to provide emergency services.

Section 267.54 requires owners and operators to review and, if necessary, immediately

amend the contingency plan whenever:

 The facility permit is revised;

 The plan fails in an emergency;

 The facility is changed in a way that increases the potential for an emergency or changes 

the response necessary in an emergency;

 The list of emergency coordinators is changed; or

 The list of emergency equipment is changed.

(ii) Respondent activities

In order to comply with contingency plan requirements, owners or operators are required 

to perform the following activities:

 Read the regulations;

 Collect the data required in the contingency plan; 

 Write the contingency plan;

 Submit the contingency plan to State and local authorities;

 Maintain (e.g., photocopy and file) the contingency plan; and 

 Amend the contingency plan when appropriate.

(2) Emergency Reporting
35

(i) Data items

Section 267.56(c)(1) requires owners and operators to immediately notify State and local 

authorities with designated response roles of an imminent or actual emergency situation. 

Section 267.56(c)(2) the facility emergency coordinator to notify the on-scene 

coordinator or the National Response Center of any release, fire, or explosion that could threaten 

human health or the environment outside the facility. The emergency notification report must 

include the following information:

 Name and telephone number of reporter;

 Name and address of facility;

 Time and type of incident;

 Name and quantity of material(s) involved;

 The extent of injuries; and

 Possible hazards to human health or the environment outside the facility.

Section 267.58(a) states that the owner or operator should notify the Regional 

Administrator and appropriate State and local authorities that their facility is in compliance with 

section 267.57(b) before resuming operations in the affected area(s) of the facility. 

Within 15 days of the incident, owners and operators are required, under section 

267.58(b) to submit a written report on the incident to the Regional Administrator. The report 

must include the following data items:

 Name, address, and telephone number of the owner or operator;

 Name, address, and telephone number of the facility;

 Date, time, and type of incident;

 Name and quantity of material(s) involved;

 The extent of any injuries;

 An assessment of actual or potential hazards to human health or the environment; and

 Estimated quantity and disposition of recovered material that resulted from the incident.
36

Section 267.58(b) also requires owners and operators to note the time, date, and details of 

any incident that requires implementing the contingency plan in the operating record.

(ii) Respondent activities

In order to comply with the reporting requirements of section 267.58(c)(1), owners and 

operators must submit the required notification of an imminent or actual emergency situation to 

State and/or local authorities.

In order to comply with the reporting requirements of section 267.56(c)(2), owners and 

operators must perform the following activities:

 Notify the on-scene coordinator or the National Response Center of any release.

 Collect the information required in the emergency report; and

 Write the emergency notification report.

In order to prepare an owner/operator's emergency report under section 267.58(a), owners 

and operators must conduct the following activities:

 Read the regulations;

 Collect the information required in the emergency report; and

 Write the emergency report.

In addition to preparing an emergency report, the owner or operator must notify the 

Regional Administrator that the facility is in compliance with section 267.57(b) before resuming 

operations in affected areas of the facility. Respondent activities associated with this 

requirement include the following:

 Compiling information that demonstrates that all affected areas are in compliance; and

 Preparing a letter notifying the Regional Administrator of this compliance.

To comply with the requirements of section 267.58, owners and operators must record 

the details of any incident that requires implementing the contingency plan in the operating 

record.

RECORD KEEPING, REPORTING, AND NOTIFYING

(1) Record Keeping
37

(i) Data items

Section 267.71 requires owners and operators to record and maintain the following 

information, as it becomes available, in the facility operating record until the facility is closed:

 A description and the quantity of each hazardous waste received, and the method(s) and 

date(s) of its treatment, storage, or disposal at the facility as required by Appendix I of 

part 264;

 The location of each hazardous waste within the facility and the quantity at each location;

 Records and results of waste analyses performed;

 Summary reports and details of all incidents that require implementing the contingency

plan;

 Records and results of inspection reports (which must be kept for three years);

 Monitoring, testing, or analytical data and corrective action where required;

 All closure cost estimates;

 A certification by the permittee, no less often than annually, that the permittee has a 

program in place to reduce the volume and toxicity of hazardous waste that he generates 

to the degree determined by the permittee to be economically practicable; and the 

proposed method of treatment, storage, or disposal that is the practicable method 

currently available to the permittee which minimizes the present and future threat to 

human health and the environment;

 For an on-site treatment facility, the information contained in the notice (except the 

manifest number), and the certification and demonstration required under section 268.7 

or section 268.8;

 For an on-site storage facility, the information in the notice (except the manifest number), 

and the certification and demonstration if applicable, required under section 268.7 or 

section 268.8.

(ii) Respondent activities

In order to comply with section 267.71, owners or operators are required to maintain a 

written operating record at the facility. Respondent activities associated with maintaining an 

operating record include maintaining (e.g., photocopying and filing) the data items listed above.
38

(2) Reports

(i) Data items

Section 267.73(a) requires owners and operators to submit a single copy of a biennial 

report to the Regional Administrator by March 1 of each even numbered year. This requirement 

is covered in the The Hazardous Waste Report ICR.

Section 267.73(b) requires owners and operators to report to the Regional Administrator:

 Releases, fires, and explosions as specified in section 267.58(b);

 Facility closures specified in section 267.117; and

 As otherwise required by subparts I, J, and DD of part 267 and subparts BB and CC of 

part 264.

(ii) Respondent activities

As discussed above, the requirements at section 267.73(a) are covered under another 

ICR, and therefore are not burdened here. Additionally, the reports described in section 

267.73(b) are burdened under the applicable sections for each individual report.

(3) Notifications

(i) Data items

Section 267.74 requires that, before transferring ownership or operation of a facility 

during its operating life, an owner or operator must notify the new owner or operator in writing 

of the requirements of parts 267 and 270.

(ii) Respondent activities

In order to meet the requirement described above, owners and operators must prepare a 

written notification informing the new owner or operator of the requirements of parts 267 and 

270.

CLOSURE

(1) Closure Plan

(i) Data items
39

Owners and operators are required by section 267.112 to submit a written closure plan 

with the Notice of Intent. The plan must identify steps necessary to perform partial and/or final 

closure of the facility, and must include at least the following items:

 A description of how each hazardous waste management unit at the facility will be closed 

in accordance with section 267.111;

 A description of how final closure of the facility will be conducted in accordance with 

section 267.111 The description must identify the maximum extent of operations which 

will be unclosed during the active life of the facility; 

 An estimate of the maximum inventory of hazardous wastes ever on-site over the active 

life of the facility. This should include a detailed description of the methods to be used 

during partial closures and final closure such as methods for removing, transporting, 

treating, storing, or disposing of all hazardous wastes, and identification of the type(s) of 

off-site hazardous waste management units to be used, if applicable;

 A detailed description of the steps needed to remove or decontaminate all hazardous 

waste residues and contaminated containment system components, equipment, structures, 

and soils during partial and final closure;

 A detailed description of other activities necessary during the closure period to ensure 

that all partial closures and final closure satisfy the closure performance standards; and

 A schedule for closure of each hazardous waste management unit and for final closure of 

the facility. The schedule must include, at a minimum:

-- The total time required to close each hazardous waste 

management unit; and 

-- The time required for intervening closure activities which will allow tracking of 

the progress of partial and final closure.

(ii) Respondent activities

The respondent activities associated with the closure plan described above include:

 Reading the regulations;

 Conducting an inventory of the hazardous waste present; 

 Recording results of inventory; Writing descriptions for the necessary activities;

 Estimating final closure; and 
40

 Writing the closure schedule. 

(2) Notification Before Partial Closure and Final Closure

(i) Data items

Section 267.112(c) requires owners and operators to notify the Director in writing at least 

45 days before beginning final closure of a treatment or storage tank, container storage, or 

containment building.

(ii) Respondent activities

To meet the above requirement, respondents must read the regulations, and prepare a 

written notification.

(3) Certification of Closure

(i) Data items

Section 267.117 requires owners and operators to submit to the Director a certification of 

closure within 60 days of the completion of final closure of each unit under a part 270 subpart J 

standardized permit. This certification must sent by registered mail; must certify that each 

hazardous waste management unit or facility has been closed following the specifications in the 

closure plan; and must be signed by the owner or operator and an independent registered 

engineer.

(ii) Respondent activities

The respondent activities associated with the certification of closure include:

 Reading the regulations;

 Preparing the certification; and

 Submitting the certification.

FINANCIAL REQUIREMENTS

(1) Cost Estimate for Closure

(i) Data items
41

Section 267.142(a) requires owners and operators to develop a detailed written estimate, 

in current dollars, of the cost of closing the facility in accordance with the requirements in 

sections 267.111 through 267.115 and applicable closure requirements in sections 267.178, 

267.197, 267.1102. Section 267.142(b) specifies that this estimate must be updated annually for 

inflation. Section 267.142(c) specifies that owners and operators must keep the latest closure 

cost estimate (adjusted to the current year) at the facility.

(ii) Respondent activities

The requirements described above will entail the following activities:

 Reading the regulations;

 Preparing a detailed estimate of closure costs;

 Updating the estimate for inflation annually; and

 Maintaining the estimate at the facility.

(2) Closure Trust Fund

(i) Data items

Section 267.143(a) explains that owners and operators may use a closure trust fund to 

meet the financial assurance requirements of section 267.143. Data items for this mechanism 

include:

 A trust agreement in compliance with sections 264.143(a)(1) and (2), and 264.143(a)(6)-

(11). The wording of this agreement must follow the wording specified in section 

264.151(a)(1);

 For new facilities, a receipt from the trustee must be submitted to the Regional 

Administrator prior to the initial storage of waste;

(ii) Respondent activities

Owners and operators establishing a trust fund to meet the financial assurance 

requirements for closure will perform the following activities:

 Reading the regulations;

 Establishing a closure trust fund;
42

 Submitting an originally signed duplicate of the trust agreement to the EPA Regional 

Administrator;

 For owners and operators of new facilities, submitting a receipt for the first payment 

under the trust agreement before the initial receipt of hazardous wastes.

(3) Surety Bond Guaranteeing Payment into a Closure Trust Fund

(i) Data items

Section 267.143(b) allows owners and operators to meet the financial assurance 

requirements for closure by obtaining a surety bond guaranteeing payment into a closure trust 

fund. The data items associated with this mechanism are:

 A surety bond instrument, as specified at section 264.151(b); and

 A standby trust agreement, as specified at section 264.143(b)(3).

(ii) Respondent activities

In collecting these data items, owners and operators will need to engage in the following 

respondent activities:

 Reading the regulations;

 Establishing a surety bond and trust agreement that comply with the financial assurance 

requirements of section 267.143(b); and

 Submitting originally signed duplicates of the surety bond and trust agreement to the 

Regional Administrator.

(4) Surety Bond Guaranteeing Performance of Closure

(i) Data items

Section 267.143(c) allows owners and operators to meet the financial assurance 

requirements for closure by obtaining a surety bond guaranteeing the performance of closure. 

The data items for this instrument include:

 A surety bond instrument specified at section 264.151(c); and

 A standby trust agreement, as specified at section 264.143(c)(3).

(ii) Respondent activities
43

The respondent activities associated with this financial assurance instrument include:

 Reading the regulations;

 Obtaining a surety bond and trust agreement that comply with the financial assurance 

requirements of section 267.143(c); and

 Submitting originally signed duplicates of the surety bond and trust agreement to the 

Regional Administrator.

(5) Closure Letter of Credit

(i) Data items

Section 267.143(d) specifies that owners or operators may obtain an irrevocable standby

letter of credit in order to satisfy financial assurance requirements for closure. Data items for 

this information collection include:

 A letter of credit from an issuing institution authorized to issue letters of credit and whose 

letter-of-credit operations are regulated and examined by a Federal or State agency; and

 A trust agreement indicating the conditions of payment into the standby trust fund 

specified in section 264.143(d)(3).

(ii) Respondent activities

Owners or operators will need to engage in the following activities in order to satisfy the 

financial assurance requirements with a closure letter of credit:

 Reading the regulations;

 Obtaining a letter of credit from an issuing institution and establishing the stand-by trust 

fund; and

 The letter of credit and an originally signed duplicate of the trust agreement to the 

Regional Administrator.

(6) Closure Insurance

(i) Data items

Owners or operators may satisfy the financial assurance requirements for closure by

establishing closure insurance according to section 267.143(e). The data item for this 
44

information collection is a closure insurance policy (identified by a certificate of insurance) that 

meets the requirements specified in section 264.143(e).

(ii) Respondent activities

The following activities are necessary to meet the above requirement:

 Reading the regulations;

 Obtaining a closure or post-closure insurance policy that satisfies the requirements of 

section 264.143(e); and

 Submitting a certificate of this insurance policy to the Regional Administrator.

 Corporate Financial Test and Corporate Guarantee

(i) Data items

Section 267.143(f) allows owners and operators to satisfy closure financial assurance 

requirements by demonstrating financial strength using the financial test specified in this section. 

Data items for this demonstration include:

 A letter signed by the owner's or operator's chief financial officer as specified in section 

267.143(f)(2)(i)(A);

 A copy of an independent certified public accountant's report on examination of the 

owner's or operator's financial statements for the latest completed fiscal year;

 A special report from the owner's or operator's independent certified public accountant to 

the owner or operator covering the specifications outlined in sections 267.143(f)(2)(i)(c) 

and (d);

 Annual updates of the above data items;

 A notice of intent to establish alternative financial assurance, if the owner or operator 

fails the financial test and no longer meets the requirements of section 267.143(f)(1);

 Reports of financial conditions as required by the Regional Administrator under section 

267.143(f)(2)(v)(A); and

 If applicable, a written guarantee from the parent corporation of the owner or operator 

that satisfies the requirements at section 267.143(g)(1).

(ii) Respondent activities
45

Owners and operators will need to perform the following activities to provide the data 

items listed above:

 Reading the regulations;

 Writing the letter signed by the chief financial officer;

 Submitting the following documents to the Regional Administrator (for new facilities, 

these documents must be submitted at least sixty days prior to placing waste in the 

facility):

-- The letter signed by the chief financial officer;

-- A copy of the independent certified public accountant's report; and

-- The special report from the independent certified public accountant;

 Submitting updated information annually;

 If applicable, writing and submitting a notice, by certified mail, to the Regional 

Administrator of intent to establish other financial assurance; and

 Writing and submitting additional reports of financial condition at any time, as directed 

by the Regional Administrator; and

 If applicable, submitting the corporate guarantee from the parent corporation of the 

owner or operator.

(8) Use of a Financial Assurance Instrument for Multiple Facilities

(i) Data items

Section 267.143(i) allows owners and operators to use a single financial mechanism for 

multiple facilities, as specified in section 264.143(h). In such cases, the owner and operator must 

provide the following data items for each facility:

 EPA identification number, name, and address; and

 The amount of funds for closure or post-closure care assured by the mechanism.

(ii) Respondent activities
46

In order to provide the data items listed above, owners and operators will need to perform 

the following activities:

 Reading the regulations;

 Submitting the data items listed above to the Regional Administrator; and

 If the facilities covered by the mechanism are located in more than one Region, 

submitting identical evidence of financial assurance to all the applicable Regional 

Administrators.

(9) Trust Fund for Liability Coverage

(i) Data items

Section 267.147(a)(3) allows owners or operators to satisfy financial requirements for 

liability by establishing a trust agreement that conforms to the requirements specified in section 

264.147(j).

(ii) Respondent activities

Owners or operators using this option to satisfy financial assurance for liability will need 

to engage in the following activities:

 Reading the regulations;

 Establishing the trust fund described above; and

 Submitting an originally signed duplicate of the trust agreement to the Regional 

Administrator.

(10) Surety Bond for Liability Coverage

(i) Data items

Section 267.147(a)(2) allows owners or operators to satisfy financial requirements for 

liability. The owner/operator must obtain a surety bond (and other information, where 

applicable) that conforms to the requirements specified in section 264.147(i).

(ii) Respondent activities

Owners or operators using this option to satisfy financial assurance for liability will need 

to engage in the following activities:
47

 Reading the regulations;

 Obtaining the surety bond described above; and

 Submitting a copy of this surety bond to the Regional Administrator.

(11) Letter of Credit for Liability Coverage

(i) Data items

Section 267.147(a)(3) allows owners or operators to satisfy financial requirements for 

liability by obtaining an irrevocable standby letter of credit that conforms to the requirements of 

section 264.147(h).

(ii) Respondent activities

Owners or operators using this option to satisfy financial assurance for liability will need 

to engage in the following activities:

 Reading the regulations;

 Obtaining the standby letter of credit described above; and

 Submitting a copy of this letter of credit to the Regional Administrator.

(12) Liability Insurance

(i) Data items

Section 267.147 allows owners or operators to satisfy financial requirements for liability

by obtaining liability insurance that conforms to the requirements of section 264.147(h). The 

following data items are required:

 A duplicate of the endorsement or certificate of insurance; and

 A duplicate of the insurance policy, if requested by the Regional Administrator.

(ii) Respondent activities

Owners or operators will need to engage in the following activities to complete the 

requirements for this option:

 Reading the regulations;
48

 Obtaining an insurance policy amended by attachment of the Hazardous Waste Facility

Liability Endorsement or evidenced by a Certificate of Liability Insurance and meeting 

other specifications outlined in sections 264.147(a)(1) and 264.147(b)(1); 

 Submitting a signed duplicate original of the endorsement or the certificate of insurance 

to the Regional Administrator, or Regional Administrators if the facilities are located in 

more than one Region; and

 If requested by the Regional Administrator, submitting a signed duplicate original of the 

insurance policy (for new facilities this must be submitted at least sixty days before 

receiving hazardous waste for treatment or storage). 

(13) Financial Test for Liability Coverage

(i) Data items

Section 267.147(a)(5) allows owners or operators to satisfy liability requirements by

passing a financial test, as specified at section 267.147(f). Data items for this option include:

 A letter signed by the owner's or operator's chief financial officer and worded as specified 

in section 264.151(g); if the financial test is also being used to demonstrate closure 

financial assurance, the letter specified in section 264.151(g) must be submitted to cover 

both forms of financial responsibility;

 A copy of an independent certified public accountant's report on examination of the 

owner's or operator's financial statements for the latest completed fiscal year;

 A special report from the owner's or operator's independent certified public accountant to 

the owner or operator covering the specifications of section 267.147(f)(2)(i)(C);

 Annual updates of the above data items; and

 Should the owner or operator fail the test and no longer meet the requirements of section 

267.147(f)(1), evidence of alternate financial assurance obtained for the entire amount of 

required liability coverage specified in section 267.147.

(ii) Respondent activities

Owners or operators will need to engage in the following respondent activities in order to 

collect the data required by these sections:

 Reading the regulations;

 Writing the letter signed by the chief financial officer;
49

 Submitting the following documents to the Regional Administrator (for new facilities, 

these documents must be submitted at least sixty days prior to receiving hazardous waste 

for treatment or storage):

-- The letter signed by the chief financial officer;

-- A copy of an independent certified public accountant's report; and

-- The special report from an independent certified public accountant;

 Submitting updated information annually; and

 Should the owner or operator fail the test and no longer meet section 267.147 

requirements, submitting evidence to the Regional Administrator of alternate financial 

assurance for the entire amount of required liability coverage specified in this section.

(14) Corporate Guarantee for Liability Coverage

(i) Data items

Section 267.147(g) allows owners or operators to meet liability requirements by

obtaining a written guarantee, under the conditions specified in section 267.147(g)(2). Data 

items for this option include:

 A certified copy of a written guarantee from the direct or higher-tier parent corporation of 

the owner or operator, a firm whose parent corporation is the parent corporation of the 

owner or operator, or a firm with a "substantial business relationship" with the owner or 

operator;

 In the case of corporations incorporated in the United States, a written statement from 

applicable Attorney(s) General or Insurance Commissioners to EPA indicating that a 

guarantee executed as described in the regulations is a legally valid and enforceable 

obligation in that State;

 In the case of corporations incorporated outside the United States, identification by the 

non-U.S. corporation of a registered agent for service of process in each State in which 

the facility covered by the guarantee is located and in the State in which it has its 

principal place of business, and a written statement from applicable Attorney(s) General 

or Insurance Commissioner of each applicable State indicating that a guarantee executed 

as described in the regulations is a legally valid and enforceable obligation in that State; 

and
50

 A letter from the guarantor's chief financial officer as specified in section 

267.147(f)(2)(A) that demonstrates that the guarantor has passed the financial test.

(ii) Respondent activities

Owners or operators will need to engage in the following respondent activities in order to 

collect the data required by these sections:

 Reading the regulations;

 Obtaining a written guarantee from the direct or higher-tier parent corporation of the 

owner or operator, a firm whose parent corporation is the parent corporation of the owner 

or operator, or a firm with a "substantial business relationship" with the owner or 

operator;

 Submitting a certified copy of this written guarantee to the Regional Administrator along 

with the items specified in section 267.147(f)(2); and

 Submitting a letter from the guarantor's chief financial officer as specified in section 

264.147(f)(2)(i)(A) that demonstrates that the guarantor has passed the financial test.

(15) Incapacity of Owners or Operators, Guarantors, or Financial Institutions

(i) Data items

Section 267.148 requires owners or operators to submit a notification of the 

commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. 

Code, naming the owner or operator as debtor (if the guarantor is named as the debtor, the 

collection of this data is the guarantor's responsibility).

(ii) Respondent activities

Activities for this data collection will include:

 Reading the regulations; and

 Submitting, by certified mail, a notice to the Regional Administrator indicating the 

commencement of bankruptcy proceedings in which the owner or operator or guarantor is 

named as debtor.

(16) State Assumption of Responsibility

(i) Data items
51

Section 267.150 requires owners or operators to notify EPA when a State assumes legal 

responsibility or assures availability of funds for an owner's or operator's compliance with the 

closure, post-closure care, or liability requirements of this part. Data items to be collected in 

this case include:

 A letter from the owner or operator requesting that the State's assumption of 

responsibility be considered acceptable for meeting the requirements of this subpart;

 A letter from the State describing the nature of the State's assumption of responsibility, 

including the following information:

-- The facility's EPA identification number, name, and address; and

-- The amount of funds for closure or post-closure care or liability coverage that are 

guaranteed by the State; and

 Any additional information which the Regional Administrator deems necessary to make 

the determination whether the State's assumption of responsibility is acceptable.

(ii) Respondent activities

Activities for this data collection will include:

 Reading the regulations; and

 Submitting to the Regional Administrator:

-- The letter from the owner or operator; and

-- The letter from the State describing the State's assumption of responsibility and 

including the information specified above; and

 Submitting any additional information requested by the Regional Administrator.

USE AND MANAGEMENT OF CONTAINERS

(i) Data items

Section 267.172 requires owners and operators of facilities that store or treat hazardous 

waste in containers to inspect areas where they store containers, at least weekly. 

(ii) Respondent activities
52

In order to provide the above data item, owners and operators will need to perform the 

following activities:

 Read the regulations;

 Inspect the areas where they store containers, at least weekly (section 267.172); and

 Record the results of the inspection (section 267.15(d)).

In addition, section 267.177 requires owners and operators to manage all hazardous waste 

placed in containers according to the air emission requirements established in subparts BB and 

CC of part 264. These requirements, however, are not addressed in this ICR since they are 

already covered in the Hazardous Waste Specific Unit Requirements, and Special Waste 

Processes and Types ICR and in the Standards of Performance for Air Emission Standards for 

Tanks, Surface Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 

265, Subpart CC ICR.

TANK SYSTEMS

(1) Applicability

(i) Data items

Section 267.190 allows owners and operators to exempt their facilities from the 

secondary containment requirements in section 267.195 if they can demonstrate that their tank 

systems do not contain free liquids and are situated inside a building with an impermeable floor. 

To obtain this exemption, owners and operators must demonstrate the absence or presence of 

free liquids in the stored/treated waste, using Method 9095 (Paint Filter Liquids Test) as 

described in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA 

Publication SW-846.

(ii) Respondent activities

Respondent activities associated with the above data item include:

 Reading the regulations; and

 Preparing the no free liquids demonstration.

(2) Design and Construction Standards

(i) Data items
53

Section 267.191 requires owners and operators to obtain a written assessment, reviewed 

and certified by an independent, qualified registered professional engineer, following section 

270.11(d), attesting that the tank system has sufficient structural integrity and is acceptable for 

the storing and treating of hazardous waste. This assessment must include at least the following 

information:

 Design standard(s) for the construction of tank(s) and/or the ancillary equipment;

 Hazardous characteristics of the waste(s) to be handled;

 Factors affecting the potential for corrosion and the type and degree of external corrosion 

protection needed to ensure the integrity of the tank system; and

 Design considerations to ensure that the tank foundations will maintain the load of a full 

tank, will be anchored to prevent flotation or dislodgement, and will withstand the effects 

of frost heave.

(ii) Respondent activities

In order to provide the data items described above, owners and operators will need to 

perform the following activities:

 Read the regulations; and

 Obtain a written assessment from an independent, qualified registered professional 

engineer.

(3) Installation Requirements

(i) Data items

Section 267.194 requires owners and operators to obtain, and keep at the facility, written 

statements by those persons required to certify the design of the tank system and to supervise the 

installation of the tank system as required in sections 267.192, 267.193, and 267.194(a) and (b).

(ii) Respondent activities

In order to provide the data items described above, owners and operators will need to 

perform the following activities:

 Reading the regulations;

 Obtaining the written statements; and
54

 Maintaining the statements at the facility.

(4) Inspection Requirements

(i) Data items

Section 267.199 requires owners and operators to provide the following data items:

 A schedule and procedure for inspecting overfill controls; and

 The results of inspections carried out pursuant to 267.199(a)-(c).

(ii) Respondent activities

In order to comply with section 267.199 requirements, owners and operators must 

perform the following activities:

 Reading the regulations;

 Developing and follow a schedule and procedure for inspecting overfill controls;

 Inspecting the following at least once each operating day:

-- Aboveground portions of the tank system to detect corrosion or releases of waste;

-- Data gathered from monitoring and leak detection equipment to ensure that the 

tank system is being operated according to its design; and

-- The construction materials and the area immediately surrounding the externally

accessible portion of the tank system, including the secondary containment 

system to detect erosion or signs of releases of hazardous waste;

 Inspecting cathodic protection systems, if present, according to, at a minimum, the 

following schedule to ensure that they are functioning properly:

-- Confirm that the cathodic protection system is operating properly within six 

months after initial installation and annually thereafter;

-- Inspect and/or test all sources of impressed current, as appropriate, at least every

other month; and

 Documenting in the facility operating record the results of the above required inspections.

(5) Leaks and Spills
55

(i) Data items

Section 267.200 requires owners and operators to provide the following data items if 

there has been a leak or spill from a tank system or secondary containment system, or if either 

system is unfit for use:

 A report informing the Regional Administrator of the release within 24 hours of its 

detection; and

 A report to the Regional Administrator, within 30 days of detection, containing the 

following information:

-- The likely route of migration of the release;

-- The characteristics of the surrounding soil;

-- The results of any monitoring or sampling conducted in connection with the 

release;

-- The proximity to downgradient drinking water, surface water, and populated 

areas; and

-- A description of response actions taken or planned.

Section 267.200(f) requires owners and operators who have made extensive repairs to a 

tank system in accordance with section 267.200(e) to obtain and submit a certification from an 

independent, qualified, registered, professional engineer that the repaired system is capable of 

handling hazardous waste without release for the intended life of the system.

(ii) Respondent activities

The data items above will require the following respondent activities:

 Reading the regulations;

 Preparing and submitting a report to the Regional Administrator within 24 hours of leak 

detection;

 Preparing and submitting a report to the Regional Administrator within 30 days of leak 

detection; and

 Obtaining and submitting an engineer’s certification.
56

In addition, section 267.204 requires owners and operators to manage all hazardous waste 

placed in a tank according to the air emission requirements established in subparts BB and CC of 

part 264. These requirements, however, are not addressed in this ICR since they are already 

covered in the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and 

Types ICR and in the Standards of Performance for Air Emission Standards for Tanks, Surface 

Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart 

CC ICR.

CONTAINMENT BUILDINGS

(1) Additional Standards for Liquid Storage

(i) Data items

Section 267.1103(d) requires owners and operators to inspect and record in the facility’s 

operating record, at least once every seven days, data gathered from monitoring equipment and 

leak detection equipment as well as the containment building and the area immediately

surrounding the containment building to detect signs of releases of hazardous waste.

(ii) Respondent activities

In order to provide the above data items, owners and operators will have to perform the 

following activities:

 Read the regulations;

 Inspect data at least once every seven days; and

 Record the results in the facility’s operating record.

(2) Waiver from Secondary Containment Requirements

(i) Data items

Section 267.1104 allows owners and operators to obtain a waiver from secondary

containment requirements by demonstrating that the only free liquids in the unit are limited 

amounts of dust suppression liquids required to meet occupational health and safety 

requirements.

(ii) Respondent activities

Owners and operators wishing to waive the secondary containment requirements must 

perform the following activities:
57

 Reading the regulations; and

 Preparing the demonstration.

(3) Containment Buildings with Areas Both with and Without Secondary 

Containment

(i) Data items

Section 267.1105 requires owners and operators of containment buildings that have areas 

both with and without secondary containment to maintain in the facility’s operating log a written 

description of the operating procedures used to maintain the integrity of areas without secondary 

containment.

(ii) Respondent activities

Respondent activities associated with the above data items include:

 Reading the regulations; and

 Preparing and maintaining a written description of the operating procedures.

(4) Releases of Hazardous Waste

(i) Data items

Section 267.1106 requires owners and operators that detect a condition that could lead to 

or has caused a release of hazardous waste to provide the following:

 A record of the discovery in the facility operating record;

 A notification to the Director of the condition;

 A written notice to the Director with a description of the steps taken to repair the 

containment building, and the schedule for accomplishing the work; and

 Upon completion of all repairs and cleanup, a written notification to the Director 

providing verification, signed by a qualified, registered, professional engineer, that the 

repairs and cleanup have been completed according to the written plan described above.

(ii) Respondent activities

In order to provide the above data items, owners and operators will need to perform the 

following activities:
58

 Reading the regulations;

 Entering a record of the discovery in the operating record;

 Preparing and submitting a notification to the Director within 7 days of the discovery;

 Preparing and submitting the written notice to the Director within 14 working days of the 

discovery; and

 Preparing and submitting the written verification to the Director.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

The following section discusses how EPA and implementing agencies would collect and 

manage the information received from respondents. This section also includes a discussion of 

how EPA would take steps to ensure that the information collections are not overly burdensome 

on small entities.

5(a) Agency Activities

APPLYING FOR A STANDARDIZED PERMIT

Agency activities associated with a standardized permit application and renewal include 

reviewing the incoming notice of intent and supporting information, determining whether the 

facility is eligible for the standardized permit, and entering the information into a database. 

MAINTAINING A STANDARDIZED PERMIT

(1) Routine Changes

Agency activities associated with routine changes to a standardized permit include 

reviewing the information submitted by the permit holder.

(2) Routine Changes with Prior Approval of the Director

Agency activities associated with routine changes to a standardized permit include 

reviewing the information submitted by the permit holder, and approving/disapproving the 

request.

(3) Significant Changes
59

Agencies activities associated with significant changes to a standardized permit include 

reviewing the incoming modification request and supporting information, reviewing the proof of 

public notice, and entering the information into a database. 

GENERAL FACILITY STANDARDS

Agency activities associated with general facility standards requirements include: 

 Issuing an identification number to new facilities, and entering the facility in the 

hazardous waste facility data system. 

 During inspection of the facility, reviewing the security procedures and determining if the 

components of the security system are in place and in working order.

 Reviewing information submitted by permit holders seeking for a waiver from security

requirements, and deciding whether to grant the request. 

 Reviewing demonstration of compliance with location factors submitted by permit 

holders.

 Reviewing information submitted by permit holders seeking for a waiver from location 

standards.

PREPAREDNESS AND PREVENTION

Although the information is not formally submitted to the permitting agency, the 

permitting agency may review documentation on any refusal on the part of local authorities to 

enter into an arrangement to handle emergencies.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Agency activities associated with the development and amendment of the contingency

plan include: reviewing the contingency plan during on-site inspections and reviewing revisions 

to the contingency plan. 

Agency activities associated with emergency reporting requirements include reviewing 

documents in the owners' or operators' and emergency coordinators' emergency reports. 

RECORD KEEPING, REPORTING, AND NOTIFYING

Only one Agency activity is associated with the operating record requirements: on-site 

review of the record. 

CLOSURE
60

Agency activities associated with closure include reviewing closure plans, closure plan 

amendment notifications, partial/final closure notifications, and closure certifications. In 

addition, the permitting agency must issue a public notice for comments on the closure plan and 

make a determination whether to approve, modify, or disapprove the closure plan. 

FINANCIAL REQUIREMENTS

Agency activities pertaining to financial requirements include:

 Reviewing closure cost estimates, demonstrations of financial assurance for closure, and 

demonstrations of financial assurance for liability. 

 Entering the information into the RCRAInfo database. 

USE AND MANAGEMENT OF CONTAINERS

Although the information is not formally submitted to the permitting agency, the 

permitting agency may review inspection records during site inspections.

TANK SYSTEMS

Agency activities pertaining to tank systems requirements include reviewing notifications 

and detailed reports on any releases to the environment. In addition, the permitting agency may

review inspection records during site inspections.

CONTAINMENT BUILDINGS

Agency activities pertaining to tank systems requirements include reviewing notifications 

on any releases to the environment and documentation submitted to support requests for 

secondary containment requirements waivers. In addition, the permitting agency may review 

inspection records during site inspections.

5(b) Collection Methodology and Management

The permitting agency will receive and keep records of the notifications and supporting 

documentation submitted by facility owners and operators applying for, renewing, or modifying 

a standardized permit. The permitting agency will also collect and keep records of closure plans 

and closure certifications submitted by facilities operating under a standardized permit. In 

collecting and reviewing this information, the permitting agency would use state-of-the-art 

electronic equipment such as personal computers and applicable data software, when 

appropriate.
61

5(c) Small Entity Flexibility

The standardized permit provides regulatory relief from parts of RCRA hazardous waste 

permitting program for facilities with tanks, containers, and containment buildings that apply and 

obtain a standardized permit. Thus, small facilities, among others, would see relief. In addition, 

the final regulations would allow these facilities to maintain most information in facility records 

rather than in submittals to EPA, thus reducing time and costs for providing information. Since 

small facilities conduct operations that are equally as hazardous to the environment as those 

conducted by larger facilities, EPA determined that small businesses should be required to 

comply with the same regulations as large businesses. As a result of this interpretation, no 

specific requirements are outlined for smaller facilities.

5(d) Collection Schedule

Under section 124.204, the permitting agency is required to collect, review, and keep 

records of notices of intent and supporting information submitted by facility owners and

operators applying for standardized permits. This information is used to determine whether a 

facility is or is not eligible to operate under a standardized permit. Once the permitting agency

makes the preliminary decision to either grant or deny coverage under the standardized permit, 

section 124.207 requires the permitting agency to provide public notice of the draft permit 

decision, including any proposed site-specific conditions in a supplemental portion, and to 

provide an opportunity for the public to submit comments and request a hearing on that decision. 

The public notice issued by the permitting agency must allow at least 45 days for people to 

submit written comments on the draft permit decision (section 124.208(a)). Information 

collected during the public comment period is considered when making a final determination on 

whether to grant or deny coverage to a facility to operate under the standardized permit. If 

coverage is granted, the permitting agency considers the public comments when specifying terms 

and conditions in the supplemental portion of the standardized permit, if any.

Under section 267.112, facility owners and operators must submit a written closure plan 

with the Notice of Intent. Once the permitting agency receives this information, it must review 

and approve the closure plan. In addition, the permitting agency must provide the public an 

opportunity to comment on the plan. The comment period will be open for 30 days. The 

permitting agency will also, in response to a request or at its own discretion, hold a public 

hearing whenever such a hearing might clarify one or more issues concerning the closure plan. 

After review of the public comments, the permitting agency will approve, modify, or disapprove 

the plan. If the permitting agency does not approve the closure plan, it must provide the facility

owner or operator with a detailed written statement of reasons for the refusal. The permitting 

agency then will approve or modify the new closure plan. Once closure is completed, the 

permitting agency must collect and review a certification submitted by the facility owner or 

operator stating that each hazardous waste management unit or facility, as applicable, has been 

closed following the specifications in the closure plan.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
62

6(a) Estimating Respondent Burden

EPA estimated respondent burden associated with all of the requirements covered in this 

ICR in Exhibits 1 through 9. The exhibits estimate the number of hours required to conduct each 

individual information collection activity and the cost associated with that activity.

6(b) Estimating Respondent Costs

Labor Costs

EPA estimates an average hourly respondent labor cost (including overhead) of $107.72

for legal staff, $87.75 for managerial staff, $42.06 for technical staff, and $23.50 for clerical 

staff. These wage rates are based on the rates from last renewal, multiplied by an inflation rate 

of 3.4% to bring them up to 2015 rates.

Capital Costs 

EPA estimates that only new facilities will incur capital costs associated with purchasing 

file storage systems for maintaining records. EPA realizes that facilities will likely use different 

and various file storage systems (e.g., file cabinets, CD-ROM, off-site storage, etc) and store 

their files on different media (paper, microfiche, electronic files, etc). For purposes of estimating 

these capital costs across all facilities, EPA has made the conservative assumption that every

new facility will store their files in paper form in file cabinets.

EPA estimates that each new facility will need to purchase one 5-drawer lateral file 

cabinet to maintain their application materials over the ten-year life of their permit.1 The current 

market price for such a file cabinet is $549. EPA has annualized this cost at a discount rate of 7 

percent over ten years (based on the average life of the permit). Thus, EPA estimates the 

annualized net present value of this capital cost to be $78 per facility. In Exhibit 19, EPA has 

included the annualized capital cost for the two new facilities expected to apply for and obtain a 

standardized permit each year ($156 per year).

Operation and Maintenance Costs

EPA estimates that respondents may incur annual operations and maintenance costs 

associated with the information collection requirements. EPA estimates that sending a 

notification to EPA under sections 124.202, 270.275, 270.280, and 270.285 would cost about 

$5.25 for the mailing expense (e.g., for certified mail with return receipt). 

In this ICR, EPA also estimates costs to respondents for obtaining contractor-related 

services, such as preparing compliance demonstrations for containers and tank systems. 

 

1

 EPA assumes existing permitted and interim-status facilities have already compiled much of 

the materials required in the standardized permit application; and thus, they have already purchased the 

file cabinets needed.
63

6(c) Estimating Agency Burden and Costs

EPA estimates Agency burden hours and costs associated with all the requirements 

covered in this ICR in Exhibit 20. EPA estimates an average hourly Agency labor cost of $78.69

for Regional legal staff, $56.61 for Regional managerial staff, $39.73 for Regional technical 

staff, and $24.16 for Regional clerical staff. EPA used the 2016 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

EPA divided annual compensation estimates by 2,080, the number of hours in a Federal

work year, and multiplied the rates by the standard government overhead factor of 1.6 to derive 

hourly rates.

6(d) Estimating the Respondent Universe and Total Burden and Cost

Estimated Universe

The original ICR for the standardized permit rule included estimate for the number of 

eligible facilities, and for facilities expected to apply for the standardized permit. Since the rule 

was promulgated in 2005, 9 states have received authorization for the rule (AR, ID, IN, KS, MT, 

OK, SD, TX, and VA) and only one facility has been issued a standardized permit. 

The estimate of the number of facilities eligible for the standardized permit rule is 

derived from the RCRAInfo data system, and considers only facilities located in states currently

authorized for the standardized permit rule, and those states where EPA is the implementing 

agency. The criteria for the estimate include: permitted hazardous waste facilities currently 

operating container storage areas, tanks, or containment buildings, and that either manage the 

wastes they generate or manage wastes received from off-site from facilities under the same 

ownership. Based on these criteria, we estimate that 86 facilities are eligible for the standardized 

permit rule.

Respondent Burden and Costs

Based on this universe, EPA estimated respondent burden and costs associated with all of 

the requirements covered in this ICR in Exhibits 1 through 9. A discussion of the burden 

estimates presented in these exhibits follows.

APPLYING FOR A STANDARDIZED PERMIT
64

(1) General Information Requirements

EPA estimates that a total of 86 (permitted, interim status, and new) TSDFs per year will 

apply for a standardized permit. All of these facilities are expected to read the regulations and 

submit a written notice of intent to operate under a standardized permit, a public meeting 

summary, and a certification of compliance with part 267. 

EPA assumes that all of these facilities already have collected most of the required 

information as part of their previous permitting process (e.g., Part A information, documentation 

of compliance with location standards, waste management unit information). Permitted facilities 

will only need to collect those data items not already required at part 264 or 270, e.g., notice of 

intent to operate under a standardized permit. 

EPA assumes that interim status and new facilities (i.e., a total of 86 facilities per year) 

will have to prepare and maintain all general information, with two exceptions. One exception 

pertains to submitting the Part A application. EPA assumes that only new facilities will incur 

burden for this activity, since interim status facilities should already have submitted this 

information to EPA. 

The other exception pertains to compliance schedules. EPA assumes that 5 percent of the 

facilities will not be in compliance with general information requirements of part 264 or 265. 

The 5-percent estimate is based on EPA’s experience under the RCRA program. These 

facilities would have to prepare and submit a schedule of compliance with part 267 as part of 

their standardized permit application.

(2) Record Keeping Requirements

With few exceptions, EPA assumes that only interim-status and new facilities will have 

to incur burden for record keeping information. The exceptions pertain to the record keeping of 

particular data items. Specifically, EPA assumes that only new facilities will incur burden for 

preparing a general description of the facility and obtaining a topographic map. EPA also 

assumes that 5 percent will have to prepare a justification for modifications of the preparedness 

and prevention requirement. Again, these estimates are based on EPA’s experience under the 

RCRA program.

(3) Container Information Requirements

EPA assumes permitted facilities will not incur burden in compiling information on their 

containers, but that interim status and new facilities will need to collect information on 

containers, under section 270.300. 

(4) Tank Information Requirements

EPA assumes permitted facilities will not incur burden in compiling information on their 

tanks, but that interim status and new facilities will need to collect information on tanks, under 

section 270.305. 
65

(5) Equipment Information Requirements

EPA assumes permitted and interim status facilities will not incur burden in compiling 

information on their equipment. All permitted and interim status facilities are already required to 

have this information under 40 CFR part 270. However, EPA assumes that the one new facility

owning tank systems will be subject to the equipment standards. 

(6) Air Emissions Control Requirements

EPA assumes permitted and interim status facilities will not incur burden in compiling 

information on their air emission controls. All permitted and interim status facilities are already

required to have this information under 40 CFR part 270. However, EPA assumes that the two 

new facilities will be subject to the air emission control standards.

(7) Switching from an Individual RCRA Permit to a Standardized Permit

For permitted facilities switching to a standardized permit prior to permit renewal, EPA 

has added the burden of reading the regulations and preparing and submitting a request to the 

permitting agency.

(8) Reapplying for a Standardized Permit

For the purposes of this ICR, EPA assumes that no facilities will be reapplying for a 

standardized permit during the three-year period of this ICR.

MAINTAINING A STANDARDIZED PERMIT

EPA estimates that approximately 10 percent of the TSDFs operating under a 

standardized permit will have to make routine changes to their permits each year. 

GENERAL FACILITY STANDARDS

Information collection requirements pertaining to general facility standards are already

covered in the General Hazardous Waste Facility Standards ICR and the Part B Permit 

Application, Permit Modifications, and Special Permits ICR. Thus, EPA has chosen not to 

burden TSDFs applying for and obtaining a standardized permit with these requirements in this 

ICR, i.e., the number of respondents or activities is equal to zero. (Note that the two new 

facilities expected to apply for and obtain a standardized permit are covered in the above 

mentioned ICRs.)

PREPAREDNESS AND PREVENTION

Information collection requirements pertaining to preparedness and prevention are 

already covered in the General Hazardous Waste Facility Standards ICR. Thus, EPA has chosen 

not to burden TSDFs applying for and obtaining a standardized permit with these requirements in 
66

this ICR, i.e., the number of respondents or activities is equal to zero. (Note that the two new 

facilities expected to apply for and obtain a standardized permit are covered in the above 

mentioned ICR.)

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Information collection requirements pertaining to the contingency plan and emergency

procedures are already covered in the General Hazardous Waste Facility Standards ICR and the 

Part B Permit Application, Permit Modifications, and Special Permits ICR. Thus, EPA has 

chosen not to burden TSDFs applying for and obtaining a standardized permit with these 

requirements in this ICR, i.e., the number of respondents or activities is equal to zero. (Note that 

the two new facilities expected to apply for and obtain a standardized permit are covered in the 

above mentioned ICRs.)

RECORD KEEPING, REPORTING, AND NOTIFYING

Information collection requirements pertaining to record keeping and reporting are 

already covered in the General Hazardous Waste Facility Standards ICR. Thus, EPA has chosen 

not to burden TSDFs applying for and obtaining a standardized permit with these requirements in 

this ICR, i.e., the number of respondents or activities is equal to zero. (Note that the two new 

facilities expected to apply for and obtain a standardized permit are covered in the above 

mentioned ICR.)

CLOSURE

Information collection requirements pertaining to closure are already covered in the 

General Hazardous Waste Facility Standards ICR and the Part B Permit Application, Permit 

Modifications, and Special Permits ICR. Thus, EPA has chosen not to burden TSDFs applying 

for and obtaining a standardized permit with these requirements in this ICR, i.e., the number of 

respondents or activities is equal to zero. (Note that the two new facilities expected to apply for 

and obtain a standardized permit are covered in the above mentioned ICRs.)

FINANCIAL REQUIREMENTS

Information collection requirements pertaining to financial assurance are already covered 

in the General Hazardous Waste Facility Standards ICR and the Part B Permit Application, 

Permit Modifications, and Special Permits ICR. Thus, EPA has chosen not to burden TSDFs 

applying for and obtaining a standardized permit with these requirements in this ICR, i.e., the 

number of respondents or activities is equal to zero. (Note that the two new facilities expected to 

apply for and obtain a standardized permit are covered in the above mentioned ICRs.)

USE AND MANAGEMENT OF CONTAINERS

Information collection requirements pertaining to the use and management of containers 

are already covered in the Part B Permit Application, Permit Modifications, and Special Permits 

ICR, the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and Types
67

ICR, and the Standards of Performance for Air Emission Standards for Tanks, Surface 

Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart 

CC ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a standardized 

permit with these requirements in this ICR, i.e., the number of respondents or activities is equal 

to zero. (Note that the two new facilities expected to apply for and obtain a standardized permit 

are covered in the above mentioned ICRs.)

TANK SYSTEMS

Information collection requirements pertaining to tank systems are already covered in the 

Part B Permit Application, Permit Modifications, and Special Permits ICR, the Hazardous 

Waste Specific Unit Requirements, and Special Waste Processes and Types ICR, and the

Standards of Performance for Air Emission Standards for Tanks, Surface Impoundments and 

Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart CC ICR. Thus, EPA 

has chosen not to burden TSDFs applying for and obtaining a standardized permit with these 

requirements in this ICR, i.e., the number of respondents or activities is equal to zero. (Note that 

the two new facilities expected to apply for and obtain a standardized permit are covered in the 

above mentioned ICRs.)

CONTAINMENT BUILDINGS

Information collection requirements pertaining to containment buildings are already

covered in the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and 

Types ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a 

standardized permit with these requirements in this ICR, i.e., the number of respondents or 

activities is equal to zero. (Note that the two new facilities expected to apply for and obtain a 

standardized permit are covered in the above mentioned ICR.)

6(e) Bottom Line Burden Hours and Costs

Respondent Tally

Exhibit 19 summarizes the total annual respondent burden and cost associated with all the 

requirements covered in this ICR. As shown in the exhibit, EPA estimates that the annual 

respondent burden to be approximately 13,948 hours, at an annual cost of $1,242,205. Annual 

capital/operation & maintenance costs are estimated at $579,727. 

Agency Tally

Exhibit 20 summarizes the estimated Agency burden associated with all activities 

covered in this ICR. As shown in the exhibit, EPA estimates that the annual agency burden is 

approximately 5,489 hours, at an annual cost of $304,138. 

6(f) Reasons for Change in Burden

There is no change in burden for this renewal. The capital/operation & maintenance costs 
68

increased slightly and that is due to adjusting the numbers to current levels. 

6(g) Burden Statement

The annual reporting burden for the new information collection requirements in this ICR 

is estimated to range from 53 to 57 hours per respondent. This burden includes time for facility

owners and operators to submit to the permitting agency a notice of intent and supporting 

materials for a standardized permit application, if required, and permit modification requests for 

significant changes. 

The annual record keeping burden for the new information collection requirements in this 

ICR is estimated to range from 31 to 178 hours per respondent. This includes time for reading 

the regulations and keeping records under section 270.290 and, if required, under sections 

270.300 to 270.315 for containers, tanks, equipment, and air emission controls. 

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

is estimated to average 162 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 the Agency’s need for this information, the accuracy of the provided 

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

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

Docket ID Number EPA-HQ-RCRA-2015-0605, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

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-2015-0605 and OMB Control Number 

2050-0182 in any correspondence.
69

EXHIBIT 1

ST ANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

APPLYING FOR A ST ANDARDIZED PERMIT

Read the regulations 0.00 0.50 0.50 0.00 1.00 $64.91 $0.00 86 86 $5,582

Prepare a written notice of intent to operate under a standardized permit 0.10 0.10 0.25 0.17 0.62 $34.06 $0.00 86 53 $2,929

Obtain the Part A information 1.50 3.00 9.00 1.50 15.00 $838.62 $0.00 2 30 $1,677

Obtain the meeting summary and other materials required by section 124.31 0.00 8.00 24.00 4.00 36.00 $1,805.44 $0.00 86 3,096 $155,268

Develop documentation of compliance with location standards 0.00 0.00 2.00 0.50 2.50 $95.87 $0.00 86 215 $8,245

Prepare information allowing the Director to carry out other Federal obligations 0.00 1.00 4.00 2.00 7.00 $302.99 $0.00 86 602 $26,057

Prepare the solid waste management unit information 0.00 0.25 4.00 0.25 4.50 $196.05 $0.00 86 387 $16,860

Prepare and sign the certification of compliance with part 267 0.10 0.10 0.10 0.17 0.47 $27.75 $0.00 86 40 $2,387

If receiving waste from off-site, obtain infomration documenting same

ownership 0.17 0.10 0.00 0.10 0.37 $29.44 $0.00 25 9 $736

Prepare a schedule of compliance with part 267 0.17 0.25 2.00 0.50 2.92 $136.12 $0.00 9 26 $1,225

Submit the above information to the Director 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 86 43 $1,462

Read the regulations 0.00 0.50 0.50 0.00 1.00 $64.91 $0.00 86 86 $5,582

Prepare and maintain a general description of the facility 0.00 2.00 15.00 2.00 19.00 $853.40 $0.00 2 38 $1,707

Prepare and maintain a justification for any modification of the preparedness 

and prevention requirements 0.00 0.00 0.50 0.50 1.00 $32.78 $0.00 9 9 $295

Prepare and maintain a description of the procedures, structures, and 

equipment used at the facility 0.00 0.25 4.00 0.50 4.75 $201.93 $0.00 86 409 $17,366

Prepare and maintain a description of traffic patterns, estimated volumes, and 

controls near the facility 0.00 0.10 1.00 0.15 1.25 $54.36 $0.00 86 108 $4,675

Obtain and maintain a topographic map 0.00 0.00 11.00 0.50 11.50 $474.41 $20.00 2 23 $989

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 85 43 $2,758

Prepare and maintain a description of the containment system 0.00 1.00 4.80 0.40 6.20 $299.04 $1,233.33 85 527 $130,251

Prepare and maintain a demonstration of compliance with Section 267.175(c) 0.00 0.30 2.40 0.20 2.90 $131.97 $500.00 85 247 $53,717

Obtain and maintain sketches, drawings, or data demonstrating compliance 

with Sections 267.174 & 267.175(c) 0.00 1.00 5.00 0.50 6.50 $309.80 $500.00 85 553 $68,833

Prepare and maintain a description of the procedures used to ensure

compliance with Sections 267.175(a) & (b) 0.00 1.30 16.80 1.30 19.40 $851.23 $700.00 85 1,649 $131,855

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 71 36 $2,304

Document and maintain the dimensions and capacity of each tank 0.00 3.00 12.00 1.00 16.00 $791.47 $2,000.00 71 1,136 $198,194

Prepare and maintain a description of feed systems, safety cutoff, bypass 

systems, and pressure controls 0.00 0.00 3.00 1.00 4.00 $149.68 $500.00 71 284 $46,127

Prepare and maintain a diagram of piping, instrumentation, and a process 

flow of each tank system 0.00 3.00 12.00 1.00 16.00 $791.47 $500.00 71 1,136 $91,694

Prepare and maintain a detailed description of how new tank systems will be

installed in compliance with Section 267.194 0.00 0.00 4.00 0.50 4.50 $179.99 $500.00 14 63 $9,520

Prepare and maintain detailed plans for containment systems 0.00 1.00 5.00 0.40 6.40 $307.45 $1,200.00 71 454 $107,029

Prepare and maintain a description of controls and practices to prevent spills

and overflows 0.00 0.00 3.00 0.50 3.50 $137.93 $0.00 71 249 $9,793

Prepare and maintain a description of operating procedure compliance for 

ignitable, reactive, or incompatible wastes 0.00 2.00 15.00 2.00 19.00 $853.40 $0.00 71 1,349 $60,591

Total Hours and Costs

O&M

Cost/Year

Number of 

Respondents

Total Hours/

Year

Hours and Costs per Respondent

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

T ank Information Requirements (270.305)

Labor 

INFORMATION COLLECTION ACTIVITY Cost/Year

Container Information Requirements (270.300)

T otal Costs/

Year

General Information Requirements (124.202, 270.275, 270.280, & 270.285)

Record Keeping Requirements (270.290)
70

EXH IB IT 1 C o n't.

ST ANDARDIZ ED P ER M IT S

ESTIM A TED ANNUA L R ESP ONDENT B URDEN AND COST

APPLYIN G F OR A STANDARDIZ ED P ER M IT

Total H o urs and C o sts

O&M 

Cost/ Year

N umber o f 

Respo ndents

Total

Hours/ Year

Hours and C o sts per R espo ndent

Leg. 

$ 104.18/Hr

M gr. 

$ 84.86/ H r

T ech. 

$ 40.68/ H r

C ler. 

$ 22.73/ H r

R espo ndent

Hours/Year

Labo r 

IN F OR M ATION C OLLEC T ION ACTIVIT Y Cost/ Year

Total C o sts/

Year

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 1 1 $32

Maintain the equipment identification number and hazardous waste 

management unit identification 0.00 0.25 0.25 0.10 0.60 $34.80 $0.00 1 1 $35

Prepare and maintain approximate locations within the facility 0.00 0.25 0.25 0.10 0.60 $34.80 $0.00 1 1 $35

Prepare and maintain descriptions of the type of equipment 0.00 0.50 3.00 0.50 4.00 $181.81 $0.00 1 4 $182

Prepare and maintain descriptions of the percent by weight of total organics 

in the hazardous waste stream at the equipment 0.00 0.25 1.00 0.25 1.50 $69.87 $0.00 1 2 $70

Prepare and maintain descriptions of the hazardous waste state at the 

equipment 0.00 0.25 1.00 0.25 1.50 $69.87 $0.00 1 2 $70

Prepare and maintain descriptions of the methods of compliance 0.00 0.25 1.00 0.25 1.50 $69.87 $0.00 1 2 $70

Prepare and maintain an implementation schedule for compliance with Part

264 subpart BB requirements 0.00 0.25 1.00 0.25 1.50 $69.87 $0.00 1 2 $70

Develop and maintain a performance test plan 0.00 1.00 7.00 2.00 10.00 $429.17 $0.00 1 10 $429

Develop and maintain documentation that demonstrates compliance with

equipment standards 0.00 1.00 16.00 2.00 19.00 $807.71 $0.00 1 19 $808

Develop and maintain documentation to demonstrate compliance with Section 

264.1060 0.00 0.50 2.00 0.50 3.00 $139.75 $0.00 1 3 $140

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 2 1 $65

Prepare and maintain documentation for floating roof covers 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 2 1 $65

Prepare and maintain a certification that covers meet applicable design 

specifications 0.00 0.25 0.50 0.00 0.75 $42.97 $0.00 2 2 $86

Prepare and maintain identification and certifications for container areas 0.00 0.25 0.50 0.00 0.75 $42.97 $0.00 2 2 $86

Prepare and maintain documentation for enclosures used to control air 

pollutant emissions from tanks or containers 0.00 0.10 0.15 0.00 0.25 $15.08 $0.00 2 1 $30

Prepare and maintain documentation for closed-vent systems and control 

devices 0.00 0.10 0.15 0.00 0.25 $15.08 $0.00 2 1 $30

Develop and maintain emission monitoring plans and control device 

monitoring methods 0.00 3.00 6.00 2.00 11.00 $562.61 $0.00 2 22 $1,125

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 83 42 $2,693

Prepare and submit the request to the Director 0.50 1.00 2.00 0.50 4.00 $237.48 $5.25 83 332 $20,147

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Prepare and submit the notice of intent 0.50 1.00 2.00 0.50 4.00 $237.48 $5.25 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 2,122 13,437 $1,191,976

Equipment Information Requirements (270.310)

Air Emissions Control Requirements (270.315)

Switching from an Individual RCRA Permit to a Standardized Permit (124.203)

Reapplying for a Standardized Permit (270.10(h))
71

EXHIBIT 2

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

MAINTAINING A STANDARDIZED PERMIT

Read the regulations 2.00 1.00 1.00 0.00 4.00 $345.25 $0.00 9 36 $3,107

Prepare and submit revised information to the Director 1.00 1.00 8.00 2.00 12.00 $578.95 $5.25 9 108 $5,258

Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $69.87 $5.25 9 14 $676

Read the regulations 2.00 1.00 1.00 0.00 4.00 $345.25 $0.00 9 36 $3,107

Prepare and submit modification request to the Director 1.00 1.00 8.00 2.00 12.00 $578.95 $5.25 9 108 $5,258

Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $69.87 $5.25 9 14 $676

Read the regulations 2.00 1.00 1.00 0.00 4.00 $345.25 $0.00 3 12 $1,036

Prepare and submit proof of public notice 0.00 0.25 1.00 0.25 1.50 $69.87 $5.25 3 5 $225

Prepare and submit the modification request to the Director 5.00 15.00 80.00 12.00 112.00 $5,501.65 $8,000.00 3 336 $40,505

T otal Varies Varies Varies Varies Varies Varies Varies 36 511 $59,848

Hours and Costs per Respondent

T otal Costs/

Year

Total Hours/

Year

Total Hours and Costs

Cler. 

$22.73/Hr

O&M

Cost/Year

Number of 

Respondents

Respondent

Hours/Year

Labor 

INFORMATION COLLECTION ACTIVITY Cost/Year

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Making Routine Changes (124.212 & 270.320(a))

Making Significant Changes (124.213 & 270.320(b))

Making Routine Changes Requiring Prior Approval (124.213 & 270.320)
72

EXHIBIT 3

ST ANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

GENERAL FACILITY STANDARDS

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Obtain, fill out, and submit an application for an EPA identification number 0.00 0.25 0.50 0.25 1.00 $48.84 $5.25 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Collect data 0.00 0.00 3.00 0.50 3.50 $137.93 $0.00 0 0 $0

Perform waste analysis 0.00 0.00 10.00 0.00 10.00 $420.60 $1,500.00 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Collect the data required for the waste analysis plan 0.00 10.00 90.00 9.00 109.00 $4,874.40 $0.00 0 0 $0

Write the waste analysis plan 0.00 10.00 60.00 9.00 79.00 $3,612.60 $0.00 0 0 $0

Maintain the waste analysis plan 0.00 0.00 0.00 1.00 1.00 $23.50 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Collect the required documents 0.00 0.00 1.00 0.50 1.50 $53.81 $0.00 0 0 $0

Maintain the required documents 0.00 0.00 0.00 1.00 1.00 $23.50 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Prepare the inspection schedule 0.00 8.00 80.00 1.00 89.00 $4,090.30 $0.00 0 0 $0

Record the results of inspections in the inspection log 0.00 0.00 100.00 0.00 100.00 $4,206.00 $0.00 0 0 $0

Maintain the inspection schedule 0.00 0.00 0.00 1.00 1.00 $23.50 $100.00 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Prepare outline of employee training program 0.00 3.00 18.00 3.00 24.00 $1,090.83

Collect employee training documentation 0.00 0.50 2.00 0.50 3.00 $139.75 $0.00 0 0 $0

Maintain the employee training documentation 0.00 0.00 0.00 80.00 80.00 $1,880.00 $100.00 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Collect and document compliance 0.00 1.00 40.00 1.00 42.00 $1,793.65 $0.00 0 0 $0

Maintain the compliance documentation 0.00 0.00 0.00 1.00 1.00 $23.50 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

Number of 

Respondents

Total Hours/

Year

T otal Costs/

Year

Obtaining an Identification Number (267.12)

Employee Training (267.16(d))

Ignitable, Reactive, or Incompatible Wastes (267.17(c))

W aste Analysis (267.13(a))

W aste Analysis Plan (267.13(b))

Security (267.14(b))

Inspections (267.15)
73

EXHIBIT 4

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

PREPAREDNESS AND PREVENT ION

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Document any refusals of local authorities and place in operating record 0.00 0.25 1.00 0.50 1.75 $75.75 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

Total Hours/

Year

T otal Costs/

Year

Arrangements with Local Authorities (267.36(b))

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

EXHIBIT 5

STANDARDIZED PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Collect the data required in the contingency plan 0.00 0.00 12.00 3.00 15.00 $575.22 $0.00 0 0 $0

Write the contingency plan 0.00 1.00 60.00 4.00 65.00 $2,705.35 $0.00 0 0 $0

Submit the contingency plan to State and local authorities 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Maintain the contingency plan 0.00 0.00 0.00 1.00 1.00 $23.50 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.75 0.00 1.00 $53.48 $0.00 0 0 $0

Submit the notification of an imminent or actual emergency situation to State and/or local authorities 0.00 0.50 0.00 0.00 0.50 $43.88 $0.00 0 0 $0

Notify the on-scene coordinator or the National Response Center of any release 0.00 0.50 0.00 0.00 0.50 $43.88 $0.00 0 0 $0

Collect the information required in the emergency report 0.00 0.00 2.50 0.50 3.00 $116.90 $0.00 0 0 $0

Write the emergency notification report 0.00 1.00 0.00 0.00 1.00 $87.75 $0.00 0 0 $0

Collect the information required in the emergency report 0.00 0.00 8.00 0.50 8.50 $348.23 $0.00 0 0 $0

Write the emergency report 0.00 0.25 4.00 0.50 4.75 $201.93 $0.00 0 0 $0

Compile information that demonstrates that all affected areas are in compliance 0.00 0.00 2.50 0.50 3.00 $116.90 $0.00 0 0 $0

Prepare a letter notifying the Regional Administrator of compliance 0.00 0.25 1.50 0.25 2.00 $90.90 $0.00 0 0 $0

Record the details of any incident that requires implementing the contingency plan in the operating record 0.00 0.00 0.50 0.25 0.75 $26.91 $0.00 0 0 $0

Total Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

Tech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Emergency Reporting (267.56(c), 267.58(a) & (b))

Number of 

Respondents

Total Hours/

Year

Total Costs/ 

Year

Contingency Plan (267.51-54)
74

EXHIBIT 6

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

RECORD KEEPING, REPORT ING, AND NOTIFYING

Maintain documents in the facility operating record 0.00 0.00 50.00 100.00 150.00 $4,453.00 $0.00 0 0 $0

Read the regulations 0.00 0.10 0.25 0.00 0.35 $19.29 $0.00 0 0 $0

Prepare and submit written notification to new owner or operator 0.00 0.00 0.50 0.13 0.63 $24.09 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

Notifications (267.74)

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Record Keeping (267.71)

EXHIBIT 7

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST

CLOSURE

Read the regulations 0.00 1.00 6.00 0.00 7.00 $340.11 $0.00 0 0 $0

Conduct a hazardous waste inventory 0.00 0.00 16.00 0.00 16.00 $672.96 $0.00 0 0 $0

Record the results of the hazardous waste inventory 0.00 0.00 4.00 1.00 5.00 $191.74 $0.00 0 0 $0

Write a description for the necessary closure activities 0.00 2.00 40.00 6.00 48.00 $1,998.90 $0.00 0 0 $0

Estimate final closure 0.00 2.00 16.00 2.00 20.00 $895.46 $0.00 0 0 $0

Write the closure schedule 0.00 1.00 2.00 1.00 4.00 $195.37 $0.00 0 0 $0

Read the regulations 0.00 0.20 0.50 0.00 0.70 $38.58 $0.00 0 0 $0

Prepare the written notification of closure 0.00 0.50 1.00 0.50 2.00 $97.69 $5.25 0 0 $0

Submit the closure plan 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Read the regulations 0.00 0.20 0.50 0.00 0.70 $38.58 $0.00 0 0 $0

Prepare the certification 0.00 0.00 22.00 4.00 26.00 $1,019.32 $500.00 0 0 $0

Submit the certification 0.00 0.00 0.00 2.00 2.00 $47.00 $5.25 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Closure Plan (267.112)

Notification Before Partial Closure and Final Closure (267.112(c))

O&M

Cost/Year

Number of 

Respondents

Total Hours/

Year

T otal Costs/

Year

Certification of Closure

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year
75

EXHIBIT 8

STANDARDIZED PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

FINANCIAL REQUIREMENTS

Read the regulations covering financial requirements 8.00 2.00 8.00 0.00 18.00 $1,373.74 $0.00 0 0 $0

Prepare a detailed estimate of closure costs 0.00 0.00 10.00 3.00 13.00 $491.10 $0.00 0 0 $0

Update the estimate for inflation annually 0.00 0.00 0.50 0.00 0.50 $21.03 $0.00 0 0 $0

Maintain the estimate at the facility (under record keeping) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0

Establish a closure trust fund 4.00 1.50 2.00 0.50 8.00 $658.38 $0.00 0 0 $0

Submit a signed duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Submit a receipt for the first payment to the Regional Administrator 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Establish a surety bond and trust agreement 4.00 1.50 2.00 0.50 8.00 $658.38 $0.00 0 0 $0

Submit originally signed duplicates of the surety bond and trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Obtain a surety bond and trust agreement 4.00 1.50 2.00 0.50 8.00 $658.38 $0.00 0 0 $0

Submit signed duplicates of the surety bond and trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Obtain a letter of credit and establish a stand-by trust fund 4.00 1.50 2.00 0.50 8.00 $658.38 $0.00 0 0 $0

Submit the letter of credit and a duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Obtain a closure insurance policy 4.00 1.50 2.00 0.50 8.00 $658.38 $0.00 0 0 $0

Submit a certificate of the insurance policy to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Prepare and submit the letter signed by the chief financial officer 1.00 0.25 2.00 0.75 4.00 $231.40 $5.25 0 0 $0

Submit a copy of the independent certified public accountant's report and special report 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $94.00 $5.25 0 0 $0

Prepare and submit a notice of intent to establish alternate financial assurance to the Regional Administrator 3.25 0.25 0.00 0.50 4.00 $383.78 $5.25 0 0 $0

Write and submit additional reports of the facility's financial condition, as directed by the Regional Administrator 2.25 0.25 1.00 0.50 4.00 $318.12 $5.25 0 0 $0

Submit the corporate guarantee from the parent corporation 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Submit required information to the Regional Administrator 0.50 1.00 0.50 2.00 4.00 $209.64 $5.25 0 0 $0

Submit evidence of financial assurance to all other applicable Regional Administrators 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Establish a trust fund 4.50 1.50 1.00 1.00 8.00 $681.93 $0.00 0 0 $0

Submit a duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Obtain a surety bond and submit a copy to the Regional Administrator 4.00 1.00 2.00 1.00 8.00 $626.25 $5.25 0 0 $0

Obtain a standby letter of credit and submit a copy to the Regional Administrator 4.00 1.00 2.00 1.00 8.00 $626.25 $5.25 0 0 $0

Obtain an insurance policy and submit documentation to the Regional Administrator 4.00 1.00 2.00 1.00 8.00 $626.25 $5.25 0 0 $0

Prepare, write, and submit the letter signed by the chief financial officer 1.00 0.25 2.00 0.75 4.00 $231.40 $5.25 0 0 $0

Obtain and submit the report and special report from the independent certified public accountant 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $94.00 $5.25 0 0 $0

Prepare and submit a notice of intent to establish alternate financial assurance to the Regional Administrator 3.25 0.25 0.00 0.50 4.00 $383.78 $5.25 0 0 $0

Obtain and submit a written guarantee to the Regional Administrator 0.50 0.50 0.50 0.50 2.00 $130.52 $5.25 0 0 $0

Submit a letter from the guarantor's chief financial officer 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $94.00 $5.25 0 0 $0

Submit by certified mail a notice of bankruptcy to the Regional Administrator 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Prepare and submit a letter from the owner or operator to the Regional Administrator 1.00 5.00 2.00 0.50 8.50 $642.34 $5.25 0 0 $0

Obtain and submit the letter from the State 0.00 0.00 0.00 1.00 1.00 $23.50 $5.25 0 0 $0

Prepare and submit any additional information requested by the Regional Administrator 0.75 0.25 0.75 0.25 2.00 $140.15 $5.25 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler.

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

Number of 

Respondents

Total Hours/

Year

Total Costs/

Year

Reading the Regulations

Cost Estimate for Closure (267.142(a)-(c))

Closure Trust Fund (267.143(a))

Surety Bond Guaranteeing Payment into a Closure Trust Fund (267.143(b))

Surety Bond Guaranteeing Performance of Closure (267.143(c))

Closure Letter of Credit (267.143(d))

Corporate Financial Test and Corporate Guarantee (267.143(f) & (g))

Use of a Financial Assurance Instrument for Multiple Facilities (267.143(i))

Closure Insurance (267.143(e))

Incapacity of Owners or Operator, Guarantors, or Financial Institutions (267.148)

State Assumption of Responsibility (267.150)

T rust Fund for Liability Coverage (267.147(a)(3))

Surety Bond for Liability Coverage (267.147(a)(2))

Letter of Credit for Liability Coverage (267.147(a)(3))

Liability Insurance (267.147(a)(4))

Financial Test for Liability Coverage (267.147(a)(5) & 267.147(f))

Corporate Guarantee for Liability Coverage (267.147(g)
76

EXHIBIT 9

STANDARDIZED PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

SPECIFIC UNIT REQUIREMENTS

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Prepare the no free liquids demonstration 0.00 0.00 1.50 0.00 1.50 $63.09 $475.00 0 0 $0

Perform weekly inspections and record results 0.00 0.00 100.00 0.00 100.00 $4,206.00 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Obtain an engineer's written assessment 0.00 3.00 12.00 1.00 16.00 $791.47 $2,000.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Obtain the written statements 0.00 0.00 7.00 1.50 8.50 $329.67 $1,000.00 0 0 $0

Maintain the written statements at the facility 0.00 0.00 0.00 0.10 0.10 $2.35 $5.25 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Develop an inspection schedule 0.00 8.00 80.00 1.00 89.00 $4,090.30 $0.00 0 0 $0

Perform daily inspections and record the results 0.00 0.00 100.00 0.00 100.00 $4,206.00 $0.00 0 0 $0

Perform annual inspections of cathodic protection system and record the results 0.00 0.00 20.00 0.00 20.00 $841.20 $0.00 0 0 $0

Perform bimonthly inspections of sources of impressed current and record the results 0.00 0.00 40.00 0.00 40.00 $1,682.40 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Prepare and submit a report to the Regional Administrator (within 24 hours of leak detection) 0.00 0.00 0.25 0.00 0.25 $10.52 $5.25 0 0 $0

Prepare and submit a report to the Regional Administrator (within 30 days of leak detection) 0.00 1.00 7.50 1.00 9.50 $426.70 $5.25 0 0 $0

Obtain and submit an engineer's certification 0.00 0.00 0.00 0.50 0.50 $11.75 $5.25 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Inspect data weekly and record the results 0.00 0.00 26.00 0.00 26.00 $1,093.56 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.50 1.00 $44.20 $0.00 0 0 $0

Prepare the free liquids demonstration 1.00 1.00 2.00 0.50 4.50 $291.34 $1,500.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Prepare and maintain a written description of operating procedures 0.00 0.00 1.00 0.25 1.25 $47.94 $0.00 0 0 $0

Read the regulations 0.00 0.25 0.25 0.00 0.50 $32.45 $0.00 0 0 $0

Enter a record of the discovery in the operating record 0.00 0.00 0.50 0.00 0.50 $21.03 $0.00 0 0 $0

Prepare and submit a notification to the Director within 7 days 0.00 0.00 0.50 0.00 0.50 $21.03 $5.25 0 0 $0

Prepare and submit a written notification within 14 days 0.00 0.00 0.50 0.25 0.75 $26.91 $5.25 0 0 $0

Prepare and submit the written verification to the Director 0.00 0.50 0.00 0.25 0.75 $49.75 $5.25 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

Tech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Inspection Requirements (267.199)

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Inspection Requirements (267.172 & 267.15(d))

CONTAINERS

T ANK SYSTEMS

Applicability (267.190)

Design and Construction Standards (267.191)

Installation Requirements (267.194)

CONTAINMENT BUILDINGS

Releases of Hazardous Waste (267.1106)

Leaks and Spills (267.200)

Additional Standards for Liquid Storage (267.1103(d))

Waiver from Secondary Containment Requirements (267.1104)

Containment Buildings with Areas Both with and without Secondary Containment (267.1105)
77

EXHIBIT 10

ST ANDARDIZED PERMITS

ESTIMATED ANNUAL AGENCY BURDEN AND COST

APPLYING FOR A ST ANDARDIZED PERMIT

Review the notice of intent and supporting information, and make a determination 20.00 1.00 40.00 0.00 61.00 $3,219.49 $0.00 86 5,246 $276,876

Enter information into a database 0.00 0.00 0.00 0.50 0.50 $12.08 $0.00 86 43 $1,039

Total Varies Varies Varies Varies Varies Varies Varies 172 5,289 $277,915

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECT ION ACT IVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

Tech. 

$40.68/Hr

Cler.

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

Number of 

Respondents

Total Hours/

Year

Total Costs/

Year

Applying for a Standardized Permit (124.204, 270.275, 270.280, & 270.285)

EXHIBIT 11

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL AGENCY BURDEN AND COST

MAINTAINING A ST ANDARDIZED PERMIT

Review the information submitted by the permittee 0.00 0.25 1.00 0.00 1.25 $53.88 $0.00 9 11 $485

Review the modification request and supporting information 20.00 1.00 20.00 30.00 $2,424.93 7 427 $16,975

Review the modification request and supporting information 20.00 1.00 40.00 0.00 61.00 $3,219.49 $0.00 3 183 $9,658

Review proof of public notice 0.00 0.25 1.00 0.00 1.25 $53.88 $0.00 3 4 $162

Enter information into a database 0.00 0.00 0.00 0.50 0.50 $12.08 $0.00 3 2 $36

T otal Varies Varies Varies Varies Varies Varies Varies 18 200 $27,316

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

Significant Changes (124.213 & 270.320(b))

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Routine Changes (124.212 & 270.320(a))

Routine Changes with prior approval (124.213 & 270.320)
78

EXHIBIT 12

STANDARDIZED PERMITS

ESTIMATED ANNUAL AGENCY BURDEN AND COST

GENERAL FACILITY STANDARDS

Issue an identification number (to new facilities) and enter the facility into the hazardous

waste facility data system 0.00 0.25 2.00 0.50 2.75 $105.69 $0.00 0 0 $0

Review the security procedures and inspect the security system during an on-site inspection 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

Review the information submitted by permittees seeking a waiver from the security 

requirements and make a determination 0.00 0.25 0.50 0.00 0.75 $34.02 $0.00 0 0 $0

Review the demonstration of compliance with location factors 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

Review information submitted by permittees seeking a waiver from the location standards 

and make a determination 0.00 0.25 2.00 0.00 2.25 $93.61 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

Total Hours/

Year

T otal Costs/

Year

General Facility Standards (267.12, 267.14, & 267.18)

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/H

r

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year

EXHIBIT 13

STANDARDIZED PERMITS

ESTIMAT ED ANNUAL AGENCY BURDEN AND COST

PREPAREDNESS AND PREVENT ION

If necessary, review during inspections the documentation of any 

refusals of local authorities to enter into emergency arrangements 0.00 0.00 0.25 0.00 0.25 $9.93 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Agreements with Local Authorities (267.36)

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M

Cost/Year
79

EXHIBIT 14

STANDARDIZED PERMITS

EST IMATED ANNUAL AGENCY BURDEN AND COST

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Review the contingency plan during on-site inspections 0.00 0.00 0.50 0.00 0.50 $19.86 $0.00 0 0 $0

Review emergency reports 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

Total Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

Total Hours/

Year

Total Costs/

Year

Contingency Plan and Emergency Reporting (267.51-54, 267.55, & 267.58)

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECT ION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

Tech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

EXHIBIT 15

STANDARDIZED PERMITS

EST IMATED ANNUAL AGENCY BURDEN AND COST

RECORD KEEPING, REPORTING, AND NOTIFYING

Review the facility operating record during on-site inspections 0.00 0.00 2.00 0.00 2.00 $79.46 $0.00 0 0 $0

Total Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

Total Hours/

Year

Total Costs/

Year

Record keeping (267.71)

Hours and Costs per Respondent Total Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

Tech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year
80

EXHIBIT 16

STANDARDIZED PERMIT S

ESTIMATED ANNUAL AGENCY BURDEN AND COST

CLOSURE

Review all closure plans, closure plan amendment notifications, partial/final closure

notifications, and closure certifications 0.00 0.00 15.00 0.00 15.00 $595.92 $0.00 0 0 $0

Review the closure plan amendment notifications 0.00 0.00 2.00 0.00 2.00 $79.46 $0.00 0 0 $0

Review the partial/final closure notifications 0.00 0.00 2.00 0.00 2.00 $79.46 $0.00 0 0 $0

Review the closure certifications 0.00 0.00 4.00 0.00 4.00 $158.91 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Closure (267.112) 

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

EXHIBIT 17

STANDARDIZED PERMIT S

ESTIMATED ANNUAL AGENCY BURDEN AND COST

FINANCIAL REQUIREMENT S

Review closure cost estimates, demonstrations of financial assurance for closure, 

and demonstrations of financial assurance for liability 4.00 1.00 16.00 0.00 21.00 $1,007.01 $0.00 0 0 $0

Enter the information into the RCRIS database 0.00 0.00 0.00 0.25 0.25 $6.04 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Financial Requirements (267.142, 267.143, 267.147, 267.148, & 267.150)

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year
81

EXHIBIT 18

STANDARDIZED PERMIT S

ESTIMATED ANNUAL AGENCY BURDEN AND COST

SPECIFIC UNIT REQUIREMENT S

Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

Review notifications and detailed reports on releases to the environment 0.00 0.00 4.00 0.00 4.00 $158.91 $0.00 0 0 $0

Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

Review notifications on any releases to the environment 0.00 0.00 0.25 0.00 0.25 $9.93 $0.00 0 0 $0

Review documentation submitted to support requests for secondary containment

requirement waivers 0.00 0.25 1.00 0.25 1.50 $59.92 $0.00 0 0 $0

Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00 $39.73 $0.00 0 0 $0

T otal Varies Varies Varies Varies Varies Varies Varies 0 0 $0

Hours and Costs per Respondent T otal Hours and Costs

INFORMATION COLLECTION ACTIVITY

Leg. 

$104.18/Hr

Mgr. 

$84.86/Hr

T ech. 

$40.68/Hr

Cler. 

$22.73/Hr

Respondent

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

T ank Systems (267.200)

Containment Buildings (267.1104 & 267.1106)

Number of 

Respondents

T otal Hours/

Year

T otal Costs/

Year

Use and Management of Containers (267.15 & 267.172)
82

 

 

 

EXHIBIT 19

STANDARDIZED PERMITS

TOT AL ESTIMAT ED ANNUAL RESPONDENT BURDEN AND COST SUMMARY

Exhibit T itle

Annual 

Burden

Annual 

Labor Cost

Annual 

Capital/

Startup Cost

Annual 

O&M Cost

Total

Annual Cost

Exhibit 1 Applying for a Standardized Permit 13,437 $635,780 $156 $555,461 $1,191,397

Exhibit 2 Maintaining a Standardized Permit 511 $26,698 $0 $24,110 $50,808

Exhibit 3 General Facility Standards 0 $0 $0 $0 $0

Exhibit 4 Preparedness and Prevention 0 $0 $0 $0 $0

Exhibit 5 Contingency Plan and Emergency Procedures 0 $0 $0 $0 $0

Exhibit 6 Record Keeping, Reporting, and Notifying 0 $0 $0 $0 $0

Exhibit 7 Closure 0 $0 $0 $0 $0

Exhibit 8 Financial Requirements 0 $0 $0 $0 $0

Exhibit 9 Specific Unit Requirements 0 $0 $0 $0 $0

Annual Total 13,948 $662,478 $156 $579,571 $1,242,205

EXHIBIT 20

STANDARDIZED PERMITS

T OT AL ESTIMAT ED ANNUAL AGENCY BURDEN AND COST SUMMARY

Exhibit T itle

Annual 

Burden

Annual 

Labor Cost

Annual 

Capital/

Startup Cost

Annual 

O&M Cost

T otal

Annual Cost

Exhibit 10 Applying for a Standardized Permit 5,289 $277,915 $0 $0 $277,915

Exhibit 11 Maintaining a Standardized Permit 200 $26,223 $0 $0 $26,223

Exhibit 12 General Facility Standards 0 $0 $0 $0 $0

Exhibit 13 Preparedness and Prevention 0 $0 $0 $0 $0

Exhibit 14 Contingency Plan and Emergency Procedures 0 $0 $0 $0 $0

Exhibit 15 Record Keeping, Reporting, and Notifying 0 $0 $0 $0 $0

Exhibit 16 Closure 0 $0 $0 $0 $0

Exhibit 17 Financial Requirements 0 $0 $0 $0 $0

Exhibit 18 Specific Unit Requirements 0 $0 $0 $0 $0

Annual Total 5,489 $304,138 $0 $0 $304,138