1 

### SUPPORTING STATEMENT FOR **INFORMATION C OLLECTION REQUEST NUMBER 1688.0**  **8**

**“ RCRA EXPANDED PUBLIC PARTICIPATION**  **”** May 20152 TABLE OF CONTENTS

1. ID ENTIFICATION OF THE INFORMATION COLLECTION
................................ ........ 4 1(a) Title of the Information Collection
................................ ................................ .......... 4 1(b) Short Characterization
................................ ................................ ............................. 4 2. NEED FOR AND USE OF THE COLLECTION
................................ ............................... 5 2(a) Need/Authority for the Collection
................................ ................................ ........... 5 2(b) Practical Utility

/Users of the Data
................................ ................................ ........... 5 3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
................................ ................................ ................................ . 6 3(a) Nonduplication
................................ ................................ ................................ ......... 6 3(b) Public Notice
................................ ................................ ................................ ............ 6 3(c) Consultations
................................ ................................ ................................ ............ 6 3(d) Effects of Less Frequent Collection
................................ ................................ ......... 6 3(e) General Guidelines
................................ ................................ ................................ ... 6 3(f) Confidentiality
................................ ................................ ................................ ......... 7 3(g) Sensitive Questions
................................ ................................ ................................ .. 7 4. THE RESPONDENTS AND THE INFORMATION REQUESTED
................................ . 7 4(a) Respondents/NAICS Codes
................................ ................................ ..................... 7 4(b) In formation Requested
................................ ................................ ............................. 8
5. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
................................ ................................ ................................ ............... 11 5(a) Agency

Activities
................................ ................................ ................................ ... 11 5(b) Collection Methodology and Management
................................ ............................ 12 5(c) Small Entity

Flexibility
................................ ................................ .......................... 12 5(d) Collection Schedule
................................ ................................ ............................... 123

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION
................................ ................................ ................................ .................. 13 6(a) Estimating Respondent Hours
................................ ................................ ................ 13 6(b) Estimating Respondent Costs
................................ ................................ ................ 13 Labor Costs
................................ ................................ ................................ ............ 13 Capital/Start
- Up Costs
................................ ................................ ........................... 13 6(c) Estimating Agency Hour and Cost Burden
................................ ............................ 15 6(d) Estimating the Respondent Universe and Total H our and Cost Burden
................................ ................................ ................................ .................... 17 6(e) Bottom Line Hour and Cost Burden
................................ ................................ ...... 18 6(f) Reasons for Change in Burden
................................ ................................ .............. 22 6(g) Burden Statement
................................ ................................ ................................ ... 184 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title of the Information Collection**  RCRA Expanded Public Participation (Renewal) , EPA IC R number 1688.0 8 , OMB control number 2050
- 0149
. **1(b) Short**  **Characterization** The Resource Conservation and Recovery Act (RCRA) of 1976, as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1984, requires EPA to establish a national regulatory

program to ensure that hazardous wastes are managed in a manner protective of hum an health and the environment. EPA has a statutory obligation, under Section 7004(b) of RCRA, to provide for, encourage, and assist public participation in the development, revision, implementation, and enforcement of any regulation, guideline, information, or program under the Act. The regulations implementing these requirements are codified at 40 CFR 124 and 40 CFR 270. EPA promulgated requirements for providing additional opportunities for the public to be involved in the RCRA permitting process at 40 CFR 124.31 through 124.33 and at 40 CFR 270.62 and 270.66. The 40 CFR 124 requirements apply to all types of hazardous waste treatment, storage, and disposal facilities, unless exempted under a specific section; the 40 CFR270 requirements apply onl y to hazardous waste combustors planning trial burns. Under 40 CFR 124.31(a) and (b), facilities appl yi ng for an initial Part B permit or a Part B permit renewal, where the renewal application is proposing a change that would qualify as a Class 3 permit modification under 40 CFR 270.42, are required to hold at least one meeting with the public prior to submitting the Part B permit application to the permitting agency . The applicant must submit a summary of the meeting, along with the list of attendees and their addresses, and copies of any written comments or materials submitted at the meeting, to the permitting agency

as part of the Part B application (§124.31(c)). Under 40 CFR 124.31(d), applicants must provide public notice (i.e., newspaper advertisement, visible and accessible sign, and broadcast media announcement) of the pre
application meeting at least 30 days prior to the meeting. The applicant also must provide a copy of the notice to the permitting agency and to the appropriate units of State and local government. The required activities and information are needed to help assure timely and effective public participation in the permitting process. The requirements are intended to provide equal access to information to all stakeholders in the permitting process: the permitting agency , the permit applicant, and the community where a facility

is located. EPA believes that these regulations encourage people to become involved in the permitting process and increase understanding of hazardous waste facilities.5

**2. NEED FOR AND USE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  Section 7004(b) of RCRA gives EPA broad authority to provide for, encourage, and assist public participation in the development, revision, impl ementation, and enforcement of any regulation, guideline, infor mation, or program under RCRA. Inaddition, the statute specifies certain public notices (i.e., radio, newspaper, and a letter to relevant agencies) that EPA must provide b efore issuing any RCRA permit. The statute also establishes a process b y which the public can dispute a permit and request a public hearing to discuss it. EPA carries out much of its RCRA public involvement at 40 CFR Parts 124 and 270. In 1995, EPA expanded the public participation requirements under the RCRA program by promulgating the RCRA Expanded Public Participation Rule (60 FR 63417; December 11, 1995). The rule responded to calls by the Administration and stakeholders (e.g., States and private citizens) to provide earlier and better public participation in EPA ’ s permitting programs, including procedures for more timely information sharing. In particular, the rule require d earlier public involvement in the permitting process (e.g. , pre - application meetings), expanded public notice for significant events (e.g., notices of upcoming trial burns), and more opportunities for the exchange of permitting information (e.g., information repository). In May of 2003, EPA finalized the Public Involvement Policy
. The policy updates an earlier po licy

issued in 1981. Among other things, the policy calls for a strengthened commitment to meaningful public involvement, greater attention to the specific concerns and interests of affected people and entities, and use of a wider variety of public involv ement techniques. In this regard, the RCRA Expanded Public Participation Rule can serve as an example to the EPA programs of how to achieve many of the goals of the policy
. **2(b) Practical Utility/Users of**  **the Data** The required activities and information are needed to help assure timely and effective public participation in the permitting process. The requirements are intended to provide equal access to information to all stakeholders in the permitting pro cess: the permitting agency, the permit applicant, and the community where a facility is located. Some facilities may be required to develop information repositories to allow for expanded public participation and access to detailed facility

information as part of the permitting process.6

**3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Nonduplication** The information collections covered in this ICR are not available from sources other than the respondents. EPA ’ s Office of Solid Waste is the only office within the Agency collecting this information, and no other Federal agency or department collects this information. **3(b) Public Notice**  In compliance with the Paperwork Reduction Act of 1995, EPA issued a publ ic notice in the Federal Register on March 13, 2015 . EPA announced in the Federal Register ( 80 FR 13375 ) that it intended to this IC R
. The comment period ended on May 12, 2015
. No comments were received. **3(c) Consultations**  EPA consulted with two facilities that have recently submitted Part B permit applications and thus were subject to these inform ation submission requirements. EPA specificall y inquired about the requirements regarding the pre - application public meeting. Ed Krise of Safety- Kleen Systems, Inc., in Nashville Tennessee (615
- 230
- 6882) said the estimate of 89.1 hour s w as a little high. Ri chie Haddock of Precious Metals Recovery L LC, Crescent Valley, Nevada (801
- 990
- 3373) , however, felt the estimate was too low, an d suggested 150 hours. Based on these consultations, plus the consultations conducted for the previous ICR, which indicated the 89.1 hour estimate was accurate, the Agency has raised the estimate from 89.1 hours to 90 hours. **3(d) Effects of Less Frequent**  **Collection** EPA sought to reduce the reporting frequency to the minimum that is necessary to en sure compliance with the rule. Itwould not be possible to collect this information less frequentl y and still assure that the requirements of permit and public involvement regulations are met b y owners or operators. The reporting frequency is essential to assure that any changes in the trial burn plans or in the anticipated permit application contents are made known to EPA and to the public. **3(e) General Guidelin**  **es** 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.7

**3(f) Confidentiality**  Section 3007(b) of RCRA and 40 CF R Part 2, Subpart B, which define EPA ’ s general policy on the public disclosure of information, contain provisions for confidentiality
. If the Agency receives any

confidential information, it will manage that information according to the protocols established b y the Agency, as appropriate. **3(g) Sensitive Questions**  No questions of a sensitive nature are included in any of the information collection requirements. **4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents/NAICS Codes**  The following is a list of North American Industrial Classification System (NAICS) codes associated with the facilities most likely to be affected b y the expanded public participation requirements analyzed under this ICR: 22132 Sewage Treatment Facilities 32411 Petroleum Refineries 32511 Petrochemical Manufacturing 32512 Industrial Gas Manufacturing 32551 Paint and Coating Manufacturing 33271 Machine Shops 33422 Radio and Television Broadcasting and Wireless Communications Equipment

Manufacturing 33633 Motor Vehicl e Steering and Suspension Components (except Spring)

Manufacturing 33634 Motor Vehicle Brake System Manufacturing 33635 Motor Vehicle Transmission and Power Train Parts Manufacturing 42271 Petroleum Bulk Stations and Terminals 44111 New Car Dealers 447 11 Gasoline Stations with Convenience Store 44719 Other Gasoline Stations 48411 General Freight Trucking, Local 48421 Used Household and Office Goods Moving 48422 Specialized Freight (except Used Goods) Trucking, Local 56292 Materials Recovery Facilities 221111 Hydroelectric Power Generation 221112 Fossil Fuel Electric Power Generation 221113 Nuclear Electric Power Generation 221119 Other Electric Power Generation8

221121 Electric Bulk Power Transmission and Control 221122 Electric Power Distribution 311942 Spice and Extract Manufacturing 323110 Commercial Lithographic Printing 323114 Quick Printing 325131 Inorganic Dye and Pigment Manufacturing 325188 All Other Basic Inorganic Chemical Manufacturing 325193 Ethyl Alcohol Manufacturing 325199 All O ther Basic Organic Chemical Manufacturing 325211 Plastics Material and Resin Manufacturing 325998 All Other Miscellaneous Chemical Product Manufacturing 331311 Alumina Refining 332813 Electroplating, Plating, Polishing, Anodizing, and Coloring 332999 Other Miscellaneous Fabricated Metal Product Manufacturing 333319 Other Commercial and Service Industry Machinery

Manufacturing 333999 All Other General Purpose Machinery Manufacturing 334418 Printed Circuit/Electronics Assembly Manufacturing 334419 Other Electronic Component Manufacturing 336211 Motor Vehicle Body Manufacturing 336312 Gasoline Engine and Engine Parts Manufacturing 336322 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing 336399 All Other Motor Vehicle Part Manufacturing 454311 Heating Oil Dealers 454312 Liquefied Petroleum Gas (Bottled Gas) Dealers 562111 Solid Waste Collection 562112 Hazardous Waste Collection 562119 Other Waste Collection 562211 Hazardous Waste Treatment and Disposal 562212 Solid Waste Landfills 562213 Solid Waste Combustors and Incinerators 562219 Other Nonhazardous Waste Treatment and Disposal 811111 General Automotive Repair **4(b) Information Requested**  **Pre -**  **application Public Meeting and Notice** Under 40 CFR 124.31(a) and (b), facilities appl yi ng fo r an initial Part B permit or a Part B permit renewal, where the renewal application is proposing a change that would qualify as a Class 3 permit modification under 40 CFR 270.42, are required to hold at least one meeting with the public prior to submitting the Part B permit application to the permitting agency
. The applicant must submit a summary of the meeting, along with the list of attendees and their addresses, and copies of any written comments or materials submitted at the meeting, to the permitting agency

as part of the Part B application ( § 124.31(c)). Under 40 CFR 124.31(d),9

applicants must provide public notice (i.e., newspaper advertisement, visible and accessible sign, and broadcast media announcement) of the pre
- application meeting at least 30 days prior to the meeting. The applicant also must provide a cop y of the notice to the permitting agency and to the appropriate units of State and local government. (Note: In regard to 40 CFR 124.31(c), this ICR addresses the respondent activities associate d with collecting the required information. Submittal of this information to the permitting agency is addressed in Supporting Statement for EPA Information Collection Request Number 1573, “ Part B Permit Appl ication, Permit Modifications, and Special Permits. ” (i) Data Items :

· A public notice that includes:

-- The date, time, and location of the meeting;

-- A brief description of the purpose of the meeting;

-- A brief description of the facility and proposed operations, including the address or a map (e.g., a sketched or copied street map) of the facility location;

-- A statement encouraging people to contact the facility at least 72 hours before the meeting if they

need special access to participate in the meeting; and

-- The name, address, and telephone number of a contact person for the

applicant.

· In formation to be submitted to the permitting agency as part of the Part B permit application:

-- Copy

of newspaper notice announcing the pre
- application meeting;

-- A summary of a pre
- application meeting with the public;

-- A list of attendees and their addresses; and

-- Copies of any written comments or materials distributed at the meeting. (ii) Respondent Activities : To comply

with the requirements in Section 124.31, applicants must perform the following activities:

· Read the regulations;10

· Prepare notice of pre
- application meeting;

· Prepare a multilingual notice of pre
- application meeting, if appropriate;

· Provide for publication/posting/broadcasting of notice;

· Provide cop y of pre
- application meeting notice to the permitting agency and appropriate units of State and local government;

· Retain documentation of the notice;

· Prepare for and conduct the meeting;

· Prepare a meeting summary ; and

· Copy

the list of attendees with their addresses. **Information Repository** Under 40 CFR 124.33, the Agency Director has the authority to require certain applicants/facilities to establish and maintain an information repository
. Applicants/facilities instructed by

the Agency Director to establish an information repository must, at a minimum, provide a written notice about the information repository to all individuals on the facility mailing list. The Agency

Director will determine the information to be placed in the information repository . (i) Data Items:

· Written notice about the information repository ; and

· In formation in the repository, e.g.:

-- A summary of the pre
- application public meeting;

-- A cop y of the Part B permit application; and

-- Any

other information the Agency Director determines to be relevant to public understanding of permitting activities at the facility. (ii) Respondent Activities : To comply

with the requirements in section 124.33, applicants must conduct the following activities:11

· Read the regulations;

· Arrange with a local building for space to establish the information repository ;

· Provide notice of the repository to individuals on the facility mailing list;

· Provide a multilingual notice of the repository to individuals on the facility mailing list, i f appropriate;

· Establish the information repository ; and

· Maintain the information repository
. **5. THE INFORMATION COLLECTED**  **-- AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities Notice at Application Submittal**  40 CFR 124.32 requires the Agency to provide public notice, as set forth in sections 124.10(c)(1)(ix) and (x), at the application submittal stage. **Information Repository** 40 CFR 124.33 provides discretionary authority for the Agency

to require, on a case
-by
case basis, the owner or operator of a facility to set up an information repository, and to provide a notice to the facility

mail ing list about the repository
. Section 124.33(d) requires the Agency Director to specify

the contents of the repository and establish requirements for informing the public about the establishment of the repository (at a minimum, the Agency Director will require the facility

to provide written notice to the facility mailing list). **Trial Burn Notice** 40 CFR 270.62(b)(6), 40 CFR 270.62(d), 40 CFR 270.66(d)(3), and 40 CFR 270.66(g) require the Agency

to provide public notice, as set forth in sections 124.10(c)(1)(ix) and (x), of an impending trial burn at a permitted hazardous waste combustion facility, or at a hazardous was te combustion facility operating under interim status.12

**5(b) Collection Methodology and Management**  In collecting and anal yz ing the information required by the expanded public participation activities, EPA uses equipment such as personal computers and appl icable data base software, when appropriate. The public will receive information through newspaper announcements and other media, and, in some cases, will have access to additional data through an information repository

as specified by

the Agency

under 40 CFR 124.33. **5(c) Small Entity Flexibility**  In developing the regulations for expanding public involvement in the RCRA permitting process, EPA was sensitive to the needs and concerns of small businesses. Therefore, the regulations describe the minimum efforts necessary to fulfill the public involvement requirements. EPA avoided including narrow, prescriptive requirements in the final RCRA Expanded Public Participation Rule, in order to provide as much flexibility as possible

—for the facility, the community, and the Agency

—in implementing the requirements. Furthermore, EPA conducted a small entity impact screening anal ys is for the proposed rule and determined that there were no small entities significantly impacted (see 59 FR 28680; June 2, 1994). Because there were no substantive changes to the public participation requirements since the proposal, EPA determined that the requirements do not significantly impact small entities. EPA ’ s intent in developing the requirements was to provide flexibility for a facil ity, in cooperation with local agencies or community groups, to determine the most effective communication mechanis ms for a particular situation. EPA recognizes that, in some situations, an information repository could become resource
- intensive for a facil ity or for the local community
. EPA addressed this concern b y providing discretion to the Director to determine whether to require a repository, rather than requiring it for all facilities. **5(d) Collection Schedule**  Many of the requirements do not have sp ecific schedules governing the submittal of the information. Requirements that have specific time frames associated with them are described below. Pre
- application Public Meeting and Notice 40 CFR 124.31(d) requires the applicant to provide public notice of the pre
- application meeting at least 30 days before the meeting is scheduled. Notice at Application Submittal 40 CFR 124.32(b)(2) requires the Agency Director to publish the notice “within a reasonable period of time after the application is received. ”13

Trial Burn Notice 40 CFR 270.62(b)(6)(i), 270.62(d), 270.66(d)(3)(i), and 270.66(g) require the Agency Director to provide notice to the mailing list and to appropriate units of State and local government “within a reasonable time period before the sch eduled trial burn. ” **6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION**  **6(a) Estimating Respondent Hours**  EPA estimates respondent burden hours for the information collection requirements associated with the pre
- application meeting and the information repository requirements in Exhibit 1. The burden estimates for each activity presented in Exhibit 1 include the burden hours (total and by

labor type) per facility, as well as the overall burden hours associated with the given activities. **6(b) Estimating**  **Respondent Costs Labor Costs**  EPA estimates an average hourly respondent labor cost of $ 12 8.72 for legal staff, $ 9 3.22 for managerial staff, $ 71.02 for technical staff, and $ 39.95 for clerical staff. These respondent labor costs were obtained from the previousl y approved ICR (i.e., EPA ICR Number 1688.07), and updated to 2015 levels using Employ ment Cost Indexes developed by the U.S. Bureau of Labor Statistics
. **Capital/Start -**  **Up Costs** Capital costs usually

include any

produced phys ical good needed to provide the needed information, such as machinery , c omputers, and other equipment. For this ICR, capital costs include the purchase of file cabinets for an information repository
. In complying with the requirements covered in this ICR, facilities may be required to maintain an information repository
. The information repository will require file cabinet space to retain the information required. EPA took the following steps to estimate the cost of the file cabinets:

• Estimate the number of file cabinets per facility required for the information repository . Given that the standard
- size, five
- drawer, lateral file cabinet is expected to hold approximately

16,000 pages of material, EPA estimates that each facility would need to purchase only one file cabinet to retain copies of the applications and other required documentation within the time period of this ICR. The approximate cost of purchasing a file cabinet is estimated at $ 830
.14

• Calculate the annualized cost . EPA used the following formula to calculate the annual cost to facilities for acquiring the file cabinets: Annualized Net Present Value = $ 830 x [1/(∑ 1/(1+k) t)] where k = discount rate of 7 percent; and

t = life of permit (10 ye ars). 1 EPA estimates that each facility will pay an annual cost o f $ 11 8 for its file cabinet
. This capital cost is shown in Exhibit 3. **Operation and Maintenance Costs** Operation and maintenance (O&M) costs are those costs associated with a paperwork requirement incurred continually over the life of the ICR. They are defined by

the Paperwork Reduction Act of 1995 as “the recurring dollar amount of costs associated with O&M or purchasing services. ” For this ICR, O&M costs include: (ii) Newspaper advertisement: EPA estimates that a permit applicant will incur a cost of $ 28 fo r one inch of column space in a newspaper of general circulation in the county or equivalent jurisdiction that hosts the proposed location of the facility
. (iii) Broadcast media announcement: EPA assumes that the radio broadcast will be a public service. Therefore, the applicant will incur no costs for the radio announcement. (iv) Meeting materials: EPA estimates that a permit applicant will incur a cost of $30 for 100 copies of a three
- piece handout (i.e., 300 pages @ $0.10/page )
. (v) Space rental : EPA assumes that a permit applicant will conduct the pre
application public meeting in a community center. Thus, the applicant will incur no space rental costs.

1 Based on an OMB
- approved discount rate of seven percent (OMB Circular A
- 94) and an estimated life of 10 years for a permit.15

(vi) Mailing costs: EPA estimates that a permit appl icant will incur a cost of $3. 48 to mail the pre
- a

pplication notice to the permitting agency and the appropriate units of State and local government (i.e., 6 government agencies @ $0.5 8 /agency ($0. 4 9 for stamp and $0.0 9 for envelope)). EPA also estimates a cost of $1 4 5 for mailing a written notice about the information repository to all individuals on the facility mailing list (i.e., 250 individuals on the facility mailing list @ $0.5 8 /individual). These O&M costs are shown in Exhibit 1. The total estimated O&M costs are $5,681.00. **6(c) Estimating Agency**  **Hour and Cost Burden** EPA estimates the Agency hour and cost burden associated with all of the requirements covered in this ICR in Exhibit 2. **Describing Agency Activities** Notice at Application Submittal
. To estimate the number of facilities for which the Agency will have to provide public notice at application submittal in each year covered by the ICR, EPA referred to RCRAInfo. 2 , 3 Based on RCRAInfo data, EPA estimated the average annual number of Part B permit applications to be received over a three year period for initial permits and permit renewals. 4 By adding these two estimates, EPA ascertained the number of application submittals for which the Agency will have to provide public notice during the three
year period covered in the ICR. Based on RC RAInfo data, EPA estimates that 4 initial Part B permit applications, on average, will be received annually over a three year period and 55 permits , on average, will be renewed annually over a three year period
. Based on the above assumptions, EPA estimates that the Agency will have to provide public notice at application submittal for 59 facilities per ye ar (i.e., 4 + 55 = 59 ). In formation Repository . The Agency Director may

require facilities to establish in formation repositories at any point during the permit application process, or during the life of the permit. EPA anticipates that information repositories will be required in a limited number of situations. Unlike the pre
- application meeting requirements, facilities submitting post
- closure
2 RCRAInfo is EPA’s comprehensive information system on hazardous waste generation and management facilities. RCRAInfo characterizes facility status, regulated activities, and compliance histories and captures detailed data on the generation and management of hazardous waste.
3 EPA referred to the PEVENT table of the Permit, Closure and Post
- Closure Module in RCRAInfo to ascertain the permit data.
4 In ascertaining the number of new permit applications, EPA identified records with a permit event code of “OP020” (i.e., Part B Received). In ascertaining the number of permit renewals, EPA identified records with a permit event code of “OP270” (i.e., Permit Expires).16

permit applications or modification requests (e.g., a Class 3 modification to add a combustion unit or to begin burning dioxin) could also potentially be required to establish a repository
. EPA is assuming that 15 percent of the estimated 59 annual respondents subject to the pre - application meeting requirements (i.e., 0.15 x 59 = 9 facilities) will be required to set up a repository

(see Section 6(d) for a description of the respondent universe estimate for the pre
appli cation requirements). Trial Burn Notice . In estimating the number of facilities for which the Agency will have to provide public notice of an upcoming trial burn, EPA again referred to RCRAInfo. 5 RCRAInfo indicates that only one trial burn plan was a pproved over a three year period
. 6 For purposes of this ICR, EPA assumes that the same number will be approve d annually over a three ye ar period
. **Estimating Agency Hour and Cost Burden** EPA estimates Agency

burden hours for the information collection requirements associated with the application submittal notice, the information repository, and the trial burn notice requirements in Exhibit 2. The burden estimates for each activity presented in Exhibit 2 include the burden hours (total and by labor type) per respondent, as well as the overall burden hours associated with the given activities. EPA estimates an average hourly labor cost (labor plus overhead) of $ 7 7.92 for legal staff, $ 7 2.86 for managerial staff, $ 5 3.42 for technical staff, and $ 2 1.46 for clerical staff. To derive these estimates, EPA used the General Schedule (GS) Salary Table 201 5
. For purposes of this ICR, EPA assigned staff the following government service levels: Le gal Staff GS
- 15, Step 1 Managerial Staff GS
- 14, Step 4 Technic al Staff GS
- 12, Step 5 Clerical Staff GS
- 5, Step 1 To derive hourl y estimates, EPA divided annual compensation estimates by 2,080, which is the number of hours in the Federal work
- ye ar. EPA then multiplied hourly rates by the standard government overhead factor of 1.6.

5 EPA referred to the PEVENT table of the Permit, Closure and Post
- Closure Module in RCRAInfo to ascertain the permit data.
6 In ascertaining the number of trial burns, EPA identified records with the following permit event codes: “MO070” (i.e., Operating Permit Modification, Trial Burn Plan Approved); “OP070” (i.e., Operating Permit, Trial Burn Plan Approved); and “RD070” (i.e., Research and Development, Trial Burn Plan Approved).17

Capital/Start
- Up Costs . The Agency is not expected to incur capital costs in conducting the activities covered in this ICR. Operation and Maintenance Costs
. For this ICR, O&M costs to the Agency include the costs associated with a public notice announcing that a Part B permit application has been received or that a trial burn will take place. For the announcement of receipt of a RCRA permit application, EPA estimates the total cost of each public notice to be $1 50.50
. This cost includes the cost of a newspaper announcement and mailing costs for providing a written notice to all individuals on the facility mailing list. EPA assumes that the radio announcement will be a public service. Thus, the Agency will incur no cost for a radio announcement. For the announcement of a trial burn, EPA estimates the total O &M cost of each notice to be $12 2 .50. These O&M costs are shown in Exhibit 2. The total O&M cost is $5,681.00. **6(d) Estimating the Respondent Universe and Total Hour and Cost B**  **urden Pre**  **- application Public Meeting and Notice**  The pre
- application meeting requirements appl y t o all facilities applying for an initial RCRA permit, and to already permitted facilities proposing a significant change in facility operations (i.e., changes equivalent to a Cla ss 3 modification) at renewal. These requirements do not apply to other renewal applications (i.e., those that do not include significant changes), post
closure applications, or routine permit modification requests. To estimate the number of initial RCRA permits, EPA referred to RCRAInfo. Based on RCRAInfo data, EPA estimates that 4 initial Part B permit applications, on average, will be receive d annuall y over a three ye ar period
. To estimate the number of permit renewals involving a s ignificant change in facility operations, EPA again relied on RCRAInfo. RCRAInfo indicates that 55 RCRA permits, on average, will be renewe d annually over a three year period
. EPA assumes that only ten percent (i.e., 55 x 0.10 = 5 permits) will involve significant changes to facility operations and thus be subject to the pre
- application meeting requirements. Based on the above assumptions, EPA estimates that 9 facilities (i.e., 4 + 5 = 9 ), on average, will be subject to the pre
- application requirements each year. **Information Repository** EPA estimates that, each year, seven facilities will incur the costs associated with the information repository
. (See Section 6(c) for a description of the universe estimate for the information repository

requirements.)18

**6(e) Bottom Line Hour and Cost Burden**  **Respondent Tally** Exhibit 3 shows the aggregate annual hour and cost burden to respondents. As shown in the exhibit, EPA estimates the annual resp ondent burden to be 5 ,614 hours. **Agency Tally** Exhibit 4 shows the aggregate annual hour and cost burden to the Agency
. As shown in the exhibit, EPA estimates the annual Agency burden to be 472 hours, at a cost of $ 29,379. **6( f)**  **Reasons for Change in Burden**  There is increase of 2,609 hours in the total estimated respondent burden compared with the ICR currentl y approved by OMB. This increase is due to the adjustment in the respondent universe from 33 to 59. **6(g) Burden Statement**  The annual public reporting burden for this collection of information is estimated to average 9 0 hours per response. The estimated recordkeeping burden for this collection of information is estimated to average 5 hours per response. The overall annual public reporting and recordkeeping burden for this collection of information is estimated to average 95 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide informati on 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 other wise 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 co ntrol numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. To comment on EPA 's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA
- HQ
- RCRA
- 2015
- 0108 , which is available for online viewing at www.regulations.gov, or in person vi ewing at the RCRA Docket in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Avenue, NW , Washington, D.C. The19

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Fri day, excluding legal holidays. The telephone number for the Reading Room is (202) 566
- 1744, and the telephone number for the RCRA Docket i s (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 electronicall y. 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
- 0108 and O MB Control Number 2050
- 0149 in any correspondence.20

**Ex hibit**  **1 R e**  **quirem en**  **ts R e**  **ga rding E**  **xp an**  **de d P**  **ublic P**  **ar ti**  **ci pat**  **io n**  **Esti mated**  **A nnual R**  **esp o n**  **de nt**  **H o u**  **r a nd C**  **o s t**  **B u rde**  **n**

Legal M a nagerial Te ch nic al Cl eric al IN FORM AT IO N CO LLEC TI ON A CTI VIT Y $126. 20/ hr $9 1. 39/ hr $6 9. 63/ hr $3 9. 17/h r
Re ad th e regulat io ns 0. 00 0. 10 0. 50 0. 00 0. 50 $4 5. 00 $0 .0 0 $0 .0 0 59 30 $2 ,6 55 Prepare no ti ce o f pre-applic at io n me et ing 0. 00 0. 25 1. 00 0. 25 1. 50 $1 04. 00 $0 .0 0 $0 .0 0 59 89 $6 ,1 36 Prepare mu lt ilingual no ti ce o f pre-applic at io n me et ing 0. 00 0. 00 3. 50 1. 00 4. 50 $2 89. 00 $0 .0 0 $0 .0 0 59 266 $17, 051 Prov ide fo r public at io n/ po sti ng/ bro adc as ti ng oft he no ti ce 0. 00 0. 00 1. 00 0. 50 1. 50 $9 1. 00 $0 .0 0 $2 8. 00 59 89 $7 ,0 21 Prov ide co py

o f pre-applic at io n me et ing no ti ce t o th e perm it ti ng agenc y a nd appro priat e unit s of St at e and lo ca l go ve rnm ent 0. 00 0. 25 1. 00 0. 25 2. 00 $1 04. 00 $0 .0 0 $2 .2 2 59 118 $6 ,2 67 Re ta in do cu me nt at io n oft he no ti ce 0. 00 0. 00 0. 00 0. 50 1. 00 $2 0. 00 $0 .0 0 $0 .0 0 59 59 $1,1 80 Prepare fo r and co nduc t th e me et ing 0. 00 0. 00 64. 50 5. 50 70. 00 $4 ,8 01 .0 0 $0 .0 0 $3 0. 00 59 4,1 30 $2 85, 029 Prepare me et ing su mma ry 0. 00 0. 00 1. 00 7. 00 8. 00 $3 51 .0 0 $0 .0 0 $0 .0 0 59 472 $2 0, 709 Co py l is t ofa tte ndees wi th t heir address es 0. 00 0. 00 0. 00 1. 00 1. 00 $4 0. 00 $0 .0 0 $0 .0 0 59 59 $2 ,3 60 Subt ot al 0. 00 0. 60 72. 50 16 .0 0 90. 00 $5 ,8 45. 00 $0 .0 0 $6 0. 22 59 5,31 2 $3 48,408
Re ad th e regulat io ns 0. 00 0. 10 0. 50 0. 00 0. 60 $4 5. 00 $0 .0 0 $0 .0 0 9 5 $3 98 Ar range wi th a lo ca l building fo r spac e to e sta blis h th e inf or ma ti on repo si to ry 0. 00 0. 00 10 .0 0 0. 00 10 .0 0 $7 10 .0 0 $0 .0 0 $0 .0 0 9 89 $6 ,2 84 Prov ide no ti ce o f repo si to ry t o indiv iduals o n fa ci lit y m ailing lis t 0. 00 0. 00 1. 00 1. 50 2. 50 $131 .0 0 $0 .0 0 $6 1. 25 9 22 $1,7 01 Prov ide mu lt ilingual no ti ce o f repo si to ry t o indiv iduals o n fa ci lit y ma iling lis t 0. 00 0. 00 3. 50 1. 00 4. 50 $2 89. 00 $0 .0 0 $6 1. 25 9 40 $3 ,1 00 Es ta blis h t he inf or ma ti on repo si to ry 0. 00 0. 00 0. 10 4.40 4. 50 $1 83. 00 $1 18 .0 0 $0 .0 0 9 40 $2 ,6 64 M a int ain th e inf or ma ti on repo si to ry 0. 00 0. 00 10 .0 0 2. 00 12 .0 0 $7 90. 00 $0 .0 0 $0 .0 0 9 10 6 $6 ,9 92 Subt ot al 0. 00 0. 10 25. 10 8. 90 34. 10 $2 ,1 48. 00 $1 18 .0 0 $122.50 9 302 $2 1, 13 9 **T O TAL**  **0.00 vari**  **es vari**  **es var**  **ie s**  **var ie**  **s var**  **ie s**  **var ie**  **s var**  **ies vari**  **es 5,**  **61 4**  **$ 3 69,**  **547** To ta l Cost/Y ear Re sp on dent Hou rs Labo r Co st Ca pit al/ St art up Co sts O&M

Co sts

**Inf o r**  **mati o n**  **R ep**  **o s it**  **o r y**  **(1 24.**  **33)** Ho urs a nd Co sts per Re sp on dent To ta l H ou rs a nd Co sts

**P r e-A**  **pplic ati**  **o n P**  **ublic M eeti**  **ng a nd N**  **o t ice (1**  **24.31 )**  Nu mb er of Re sp on dent s/ Ac ti vi ty Tota l H ou rs/

Year21

**Ex hibit**  **2 R e**  **quire men**  **ts R e**  **ga rding E**  **xp an**  **de d P**  **ublic P**  **ar ti**  **ci pa**  **ti o n**  **Esti mated**  **A nnua**  **l A ge**  **nc y**  **Hou r a**  **nd C o s**  **t B u**  **rde n** 

Legal M a nagerial Te ch nic al Cl eric al IN FO RM AT IO N CO LLEC TI ON A CTIVI TY $7 6. 38/ hr $7 1. 42/ hr $5 2. 37/ hr $2 1. 02/ hr
Prov ide public n oti ce a t applic at io n su bm it ta l 0.00 0. 00 1. 50 1. 50 3. 00 $1 12 .0 0 $0 .0 0 $8 9. 25 59 17 7 $1 1, 874 Prov ide mu lt ilingual no ti ce 0.00 0. 00 3.50 1. 00 4. 50 $2 08. 00 $0 .0 0 $6 1. 25 59 266 $15, 886 **Su bt**  **o t al**  0.00 0. 00 5.00 2. 50 7. 50 $3 20. 00 $0 .0 0 $150. 50 59 443 $2 7, 760 Spec ify c on te nt s ofrepo si to ry 0.00 0. 50 1. 00 0. 15 1. 65 $9 3. 00 $0 .0 0 $0 .0 0 9 15 $8 23 Es ta blis h requirem ent s fo r inf or mi ng th e public 0.00 0. 50 0.00 0. 15 0. 65 $4 0. 00 $0 .0 0 $0 .0 0 9 6 $3 54 **Su bt**  **o t al**  0.00 1. 00 1. 00 0. 30 2. 30 $133. 00 $0 .0 0 $0 .0 0 9 21 $1 ,177 **Inf o r**  **mati o n**  **R ep**  **o s it**  **o r y**  **(1 24.**  **33(b )**  **an d (**  **d) )** 

**T r ia**  **l B urn N**  **o t ic**  **e (270.**  **62(b )(6)**  **an d (**  **d); 2**  **70. 66(d**  **)(3) an**  **d ( g)**  **)** Re sp on dent Ho urs Labo r Co st Ca pit al St art up Costs O&M

Co sts Nu mb er of

Re sp on dent s/ Acti vi ty To ta l Ho urs /

Year To ta l

Co st/Y ear To ta l Ho urs a nd Co sts Ho urs a nd Co sts Pe r Re sp on dent

**Not ic**  **e at**  **A p plic**  **ati o n**  **S ubm**  **it tal**  **( 12**  **4. 32)** 22 **Ex hibit**  **3 Tot**  **al A**  **nnua l R**  **esp o n**  **de nt**  **H o u**  **r a nd C**  **o s t**  **B u rde**  **n**

IN FO RM AT IO N CO LLEC TI ON A CTIVI TY To ta l Ho urs To tal L abo r

Co sts To tal C apit al

Co st To ta l O&M

Co sts To ta l Co sts Pre-A pplic at io n Pu blic M eet ing and No ti ce 5, 31 2 $3 44, 855 $0 $3 ,5 53 $3 48, 408 In fo rm at io n Re po si to ry 302 $19, 01 1 $1 ,0 44 $1 ,0 84 $2 1, 13 9 **T O TAL**  **5, 61**  **4 $ 3**  **63, 866**  **$ 1 ,0**  **44 $ 4**  **,6 37**  **$ 3 69,**  **547**

**Ex hibit**  **4 Tot**  **al A**  **nnua l A**  **ge nc**  **y Hou**  **r a nd C**  **ost B u**  **rde n** 

IN FO RM AT IO N CO LLEC TI ON A CTIVI TY To ta l Ho urs To ta l Labo r

Co sts To ta l Ca pit al

Co st To ta l O&M

Co sts To ta l Co sts No ti ce a t Ap plic at io n Subm it ta l 443 $18, 880 $0 $8 ,8 80 $2 7, 760 In fo rm atio n Re po si to ry 21 $1,177 $0 $0 $1 ,177 Tr ial Bu rn No ti ce 8 $3 20 $0 $1 22 $4 42 **T O TAL**  **472 $ 2**  **0, 377**  **$ 0 $ 9**  **,0 02**  **$ 2 9,**  **379**