i

CRITERIA FOR CLASSIFICATION OF SOLID WASTE 

DISPOSAL FACILITIES AND PRACTICES

EPA ICR Number 1745.08, OMB Control Number 2050-0154
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection .....................................................2

1(b) Short Characterization of the Information Collection .............................................2

2. NEED FOR AND USE OF THE COLLECTION

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

2(b) Use and Users of the Data........................................................................................3

3. THE RESPONDENTS AND THE INFORMATION REQUESTED

3(a) Respondents/SIC codes............................................................................................3

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

3(c) Information Requested.............................................................................................3

4. THE INFORMATION COLLECTED-- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

4(a) Agency Activities.....................................................................................................7

4(b) Collection Methodology and Management..............................................................8

4(c) Small Entity Flexibility............................................................................................8

4(d) Collection Schedule .................................................................................................8

5. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

5(a) Non-duplication .......................................................................................................9

5(b) Consultations............................................................................................................9

5(c) Effect of Less Frequent Collection ..........................................................................9

5(d) General Guidelines.................................................................................................10

5(e) Confidentiality .......................................................................................................10

5(f) Sensitive Questions................................................................................................10

6. ESTIMATING THE BURDEN HOURS AND COST OF THE COLLECTION

6(a) Estimating the Respondent Burden Hours - Original ICR...........................10

 6(b) Estimating the respondent Burden Hours - Continuing ICR.......................... 13

 6(c) Estimating Respondent Burden Hours and Costs..................................................16

6(d) Estimating Agency Burden Hours and Cost ..........................................................17

6(e) Estimating State Burden Hours and Cost...............................................................18

6(f) Bottom Line Burden Hours and Costs/Master Tables...........................................19

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

6(h) Burden Statement...................................................................................................20
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION

This continuing ICR is entitled "Criteria for Classification of Solid Waste Disposal 

Facilities and Practices" (Renewal), ICR 1745.08, OMB Number 2050-0154.

1(b) SHORT CHARACTERIZATION OF THE INFORMATION COLLECTION

The 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation 

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

(EPA) revise the Criteria for Solid Waste Disposal Facilities that may receive household hazardous 

wastes and conditionally exempt small quantity generator (CESQG) wastes. EPA submitted a 

Report to Congress in October 1988 that assessed the impacts on human health and the environment 

associated with Subtitle D (non-hazardous waste) units. While this study found that the revised 

Criteria for municipal solid waste disposal units were necessary to protect human health and the 

environment, the report failed to draw a conclusion relating to industrial Subtitle D units. The 

limited data on such units indicated that there might be a basis for concern and further study was 

needed.

The proposed solid waste disposal facility criteria were published on August 30, 1988. On 

October 9, 1991 EPA promulgated revised Criteria for Solid Waste Disposal Facilities (56 FR

50978) accepting household hazardous wastes. These revisions fulfilled the part of the statutory

mandate in RCRA Section 4010 for all units that receive household and CESQG hazardous wastes 

(i.e., municipal solid waste landfills (MSWLFs)). Revisions to the part 257 criteria for other 

Subtitle D disposal units that may receive CESQG hazardous wastes were delayed as the Agency

had little information concerning the potential or actual impacts that these types of units had on 

human health and the environment.

On October 21, 1993, the Sierra Club filed suit against EPA in the United States District 

Court for the District of Columbia to compel EPA to promulgate revised Criteria for non-municipal 

units that may receive small quantity generator hazardous waste. As a result of the October 21, 

1993 lawsuit, EPA and the Sierra Club reached agreement on a schedule concerning revised Criteria 

for non-municipal units that may receive CESQG wastes. This schedule required that the EPA 

Administrator sign a proposal by May 15, 1995 and a final rule by July 1, 1996. The proposal was 

signed on May 15, 1995 and the Agency promulgated the final rule on July 1, 1996.

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

The final revisions to the Criteria for Classification of Solid Waste Disposal Facilities and 

Practices and Identification and Listing of Hazardous Waste set forth in 40 CFR part 257, subpart B 

and revisions to 40 CFR 261 were developed in response to Sections 4010(c) and 3001(d) (4) of 

RCRA, which were added to the statute in the 1984 Hazardous and Solid Waste Amendments. The 

final revisions to part 257, subpart B established specific standards and reporting and recordkeeping 
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requirements for owners and operators of new, existing, and lateral expansions of existing nonmunicipal non-hazardous waste disposal units that receive conditionally exempt small quantity

generator (CESQG) hazardous wastes. The final revisions to part 261 involved no new reporting or 

recordkeeping requirements. These regulations were finalized under the authority of Sections 1008, 

2002 (general rulemaking authority), 3001(d)(4), 4004 and 4010 of RCRA, as amended.

2(b) USE AND USERS OF THE DATA

The information collected is used by the States to regulate and ensure that non-municipal 

non-hazardous waste disposal units that receive CESQG hazardous wastes, and CESQGs, are 

complying with the final revisions to the part 257, subpart B criteria and the revisions to part 261. 

The information collected is used by the State Director to confirm owner and operator compliance, 

and CESQG compliance, with the final regulations under the revised part 257 subpart B and the 

revised part 261.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) NONDUPLICATION

EPA took steps to minimize duplication of information collection. The part 257, subpart B 

final rule included minimum recordkeeping and reporting necessary to document compliance with 

the rule's provisions. 

EPA deliberately did not prescribe specific recordkeeping procedures or formats. This 

would allow States and owners or operators maximum flexibility in developing site-specific 

procedures that satisfy existing State requirements and the provisions of the Criteria for 

Classification of Solid Waste Disposal Facilities and Practices. Furthermore, part 257, subpart B 

provides additional flexibility to approved States: approved States have flexibility in establishing 

the location of the operating record and establishing alternative schedules for recordkeeping and 

notification requirements.

3(b) PUBLIC NOTICE

 EPA issued a public notice in the Federal Register on June 15, 2015 (80 FR 34154). The 

public comment period ended on August 14, 2015. No comments were received in response to the 

notice.

3(c) CONSULTATIONS

This continuing ICR is based on the data collected for the original and the revised ICR for 

part 258 (municipal landfills - ICR #1381). The part 258 ICR developed estimates in consultation 

with owners and operators of MSWLFs, State personnel (see below), EPA personnel (Headquarters 
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and Regional), and consultants working for EPA on the hazardous and solid waste programs. 

Individuals from these organizations were interviewed to characterize the time an owner or operator 

(as well as the State) would need to spend on each separate requirement. Since the minimum 

statutory requirements finalized in part 257, subpart B are almost identical to the corresponding 

sections of part 258, the Agency has prepared similar time estimates for the activities required 

under part 257, subpart B, making reasonable alterations and allowances to correspond with those 

sections where the requirements differ.

In an effort to verify EPA’s development this ICR, EPA contacted state solid waste officials to 

review and comment on this document. EPA is grateful the following people reviewed this 

document: 1) Ed Dexter, of the Maryland Department of the Environment; telephone (410) 537-

3315, 2) Geoff Christe, of the Virginia Department of Environmental Quality; telephone (804) 698-

4283, 3) Robert Grefe, of the Wisconsin Department of Natural Resources; telephone (608) 266-

2178, and 4) Bob Doctor, of the Wyoming Solid Waste Permitting and Corrective Action Division, 

telephone (307) 473-3468.

3(d) EFFECT OF LESS FREQUENT COLLECTION

The Agency believes that less frequent recordkeeping and reporting could hamper State 

enforcement and compliance efforts, especially in States that have not been approved, since these 

States may not establish requirements more stringent than the Federal minimum. However, the part 

257, subpart B criteria allow approved States the discretion to establish alternative schedules for 

recordkeeping and notification requirements.

3(e) GENERAL GUIDELINES

This collection does not violate any of the Paperwork Reduction Act (50 CFR 1320.6) 

general guidelines.

3(f)-(g) CONFIDENTIALITY AND SENSITIVE QUESTIONS

No data requested are believed to be confidential. The Agency is not requesting any trade 

secret information and believes that the information collection complies with the Privacy Act of 

1974 and OMB Circular A-108. The recordkeeping and reporting requirements do not request 

information that is of a sensitive nature.

4. THE RESPONDENTS AND INFORMATION COLLECTED

4(a) RESPONDENTS/SIC CODES

The groups affected by the final revisions to part 257, subpart B and part 261 include both 

the generators of CESQG wastes and owners or operators of new, existing, or lateral expansions of 

existing non-municipal non-hazardous waste disposal units that receive CESQG wastes. This 

continuing information request expires on September 30, 2015. 
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As the rule affects generators of CESQG waste as well as the units where the waste is 

disposed, a relevant list of NAICS codes would potentially include most business areas contained in 

the NAICS document. Therefore, it is not practical to include such a comprehensive list in this 

continuing supporting statement. However, the final revision to 261.5 did not impose any new 

reporting or recordkeeping requirement on CESQGs; therefore, the rest of the analysis will address 

only new reporting and recordkeeping requirements for disposal units.

The following subsections discuss how the information will be collected. State agencies 

will not be responsible for collecting information. Rather, the owners or operators of nonmunicipal non-hazardous waste disposal units that receive CESQG wastes are required to collect 

the information, compile it in an operating record, and notify the State Director when the 

documentation is placed in the operating record. The operating record is intended to be equivalent 

to a permit file that is routinely kept by the State permitting agency. The Agency did not intend for 

the final rule to create additional recordkeeping except when the rule imposed more stringent 

Federal standards in addition to State requirements.

4(b) INFORMATION REQUESTED

The following subsections describe the recordkeeping requirements and reporting 

(notification) required in the final rule. EPA deliberately did not use design standards to prescribe 

specific activities, conditions, or components. This allowed owners and operators maximum 

flexibility in developing site-specific procedures that satisfy State requirements and provisions of 

the revised Criteria. 

LOCATION RESTRICTIONS

Section 257.8 - Floodplains

Owners and operators of new non-municipal non-hazardous waste disposal units that receive 

CESQG wastes, existing non-municipal non-hazardous waste disposal units that receive CESQG 

wastes, and lateral expansions of existing units must document (record) in their operating record 

demonstrations that the unit meets the location restrictions regarding floodplains (§257.8). The 

owner or operator must notify the State Director when an exemption demonstration is recorded in 

the operating record.

Section 257.9 - Wetlands

Owners and operators of new non-municipal non-hazardous waste disposal units that receive 

CESQG waste and lateral expansions of existing units must demonstrate (report) to the Director of 

an approved State that the unit meets the requirements addressing wetlands (§257.9). 

GROUND-WATER MONITORING AND CORRECTIVE ACTION

Section 257.21(b) - No Migration Petition
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In an approved State, owners and operators of non-municipal non-hazardous waste disposal 

units that receive CESQG wastes may demonstrate (document) that there is no potential for 

migration of hazardous constituents from the unit. The demonstration is to be based on site-specific 

data and fate and transport modeling as presented in §257.21(b)(1)-(2).

Section 257.21(h) and (i) - Small and Arid or Remote Non-Municipal Non-Hazardous Waste 

Disposal Units 

Directors of approved States may allow owners and operators of new, existing, or lateral 

expansions of existing non-municipal non-hazardous waste disposal units that receive CESQG 

wastes to use alternative ground-water monitoring techniques and alternative indicator lists as 

presented in §257.21(i)(1) and (2) for units meeting the criteria defined in §257.21(h). The Director 

of the approved State should consider the factors in §257.21(i)(3) when authorizing and considering 

these alternatives. Owners and operators of these qualifying small and arid or remote nonmunicipal non-hazardous waste disposal units must place in their operating record documentation 

demonstrating that they meet the criteria in §257.21(h). Section 257.21(h) allows units to use the 

flexibility provided in §257.21(i) if the non-municipal non-hazardous waste disposal units receive 

less than 20 tons of waste per day, have no evidence of ground-water contamination, and are either 

in a remote area or an arid area of the country. A remote area is defined at §257.21(h)(3) as "a 

community that experiences an annual interruption of at least three consecutive months of surface 

transportation that prevents access to a regional waste management facility." An arid area is 

defined at §257.21(h)(4) as "an area that annually receives less than or equal to 25 inches of 

precipitation" and "has no practicable waste management alternative." 

Section 257.21(i)(2) - Small and Arid or Remote Non-Municipal Non-Hazardous Waste Disposal 

Units

Owners and operators of new, existing, or lateral expansions of existing non-municipal nonhazardous waste disposal units that detect contamination through the use of any alternative groundwater monitoring technique must perform expanded monitoring to show the nature and extent of the 

contamination and submit those results to (notify) the Director of the approved State of the 

contamination as required by §257.21(i)(2). If the contamination has reached the saturated zone, 

then the owner or operator must comply with the requirements of §257.21 (i)(2)(i). If the 

contamination is present in the vadose zone, on the surface, or anywhere else but the saturated zone, 

then the owner or operator must comply with the requirements of §257.21(i)(2)(ii). 

Section 257.21 - §257.23 - Establish Ground-Water Monitoring Systems 

Owners and operators must notify the State Director that documentation pertaining to 

measurement, sampling, and analytical devices has been placed in the operating record. The 

numbering, spacing, and depth of monitoring systems shall be certified by a qualified ground-water 

scientist or approved by the Director of an approved State. Within 14 days of the certification, the 

owner or operator must notify the State Director that certification has been placed in the operating 

record.
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Owners or operators must notify the State Director that the description of the sampling and 

analysis program documentation has been placed in the operating record.

The owner or operator must specify in the operating record a statistical method from 

§257.23(g) to be used in evaluating ground-water monitoring data for each hazardous constituent. 

If another statistical method that meets the performance standards of §257.23(h) is used, the owner 

or operator must place justification for this alternative in the operating record and notify the State 

Director of use of this alternative test.

Section 257.24 - Detection Monitoring Program

If the owner or operator determines that there is a statistically significant increase over 

background for one or more of the constituents in Appendix I (Appendix I of part 258), the owner 

or operator must, within 14 days of this finding, place a notice in the operating record and notify the 

State Director indicating which constituents have shown statistically significant changes from the 

background levels.

The owner or operator may demonstrate pursuant to §257.24(c)(3) that a source other than 

the non-municipal non-hazardous waste disposal unit or an error has caused the statistically

significant changes in background levels of one or more of the constituents. This demonstration 

must be certified by a qualified ground-water scientist or approved by the Director of an approved 

State and be placed in the operating record.

Section 257.25 - Assessment Monitoring Program

If the sampling results indicate that Appendix II (Appendix II of part 258) constituents have 

been detected, the owner or operator must, within 14 days after obtaining the results, place a notice 

in the operating record identifying the Appendix II (Appendix II of part 258) constituents that have 

been detected and notify the State Director that this notice has been placed in the operating record. 

Within 90 days, and at least on a semiannual basis thereafter, the owner or operator must resample 

and record the concentrations of the detected Appendix II (Appendix II of part 258) constituents. If 

the concentrations of all Appendix II (Appendix II of part 258) constituents are shown to be at or 

below background values for two consecutive sampling events, the owner or operator must notify

the State Director of this finding. 

If one or more of the Appendix II (Appendix II of part 258) constituents are detected at 

statistically significant levels above the ground-water protection standard established under §257.25 

(h) or (i) in any sampling event, the owner or operator must, within 14 days of this finding, place a 

notice in the operating record identifying the Appendix II (Appendix II of part 258) constituents 

that have exceeded the ground-water protection standard and notify the State Director and all 

appropriate local government officials that the notice has been placed in the operating record. The 

owner or operator must also notify all persons who own the land or reside on the land that directly 

overlies any part of the plume of contamination if contaminants have migrated off site, if indicated 

by sampling wells in accordance with §257.25(g)(1). 

Section 257.25(g)(2) - "False Positives"
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The owner or operator may voluntarily attempt to demonstrate that a source other than the 

non-municipal non-hazardous waste disposal unit that may receive CESQG wastes caused the 

contamination or that a sampling error occurred and that it is not required to move into remedy

selection under the corrective action requirements.

Section 257.27 - Selection of Remedy

The owner or operator must discuss the results of the corrective measure assessment, prior 

to the selection of remedy, in a public meeting with interested and affected parties. The owner or 

operator must notify the State Director, within 14 days of selecting a remedy, that a report 

describing the selected remedy and specifying a schedule for initiating and completing remedial 

activities has been placed in the operating record, and how it meets the standards in §257.27(b). 

The owner or operator may document in the operating record that no clean-up is required if 

the conditions of §257.27(e) are met and the State Director is notified.

Section 257.28 - Implementation of Corrective Action Program 

The owner or operator may determine that corrective action cannot be achieved with any

currently available remedy. If so, the owner or operator must document in the operating record that 

a report justifying alternative corrective action measures has been placed in the operating record in 

compliance with the requirements of §257.28 (c)(4) and notify the State Director.

Upon completion of the requirements of §257.28(e), the owner or operator must document 

in the operating record that the remedy has been completed in compliance with the requirements of 

§257.28(e) and notify the State Director.

RECORDKEEPING REQUIREMENT

Section 257.30 - Recordkeeping Requirements

The owner and operator must record and retain near the unit in an operating record, 

information as it becomes available on any location restriction demonstration required under 

§§257.7 through 257.12 or any demonstration, certification, finding, monitoring, testing, or 

analytical data required in §§257.21 through 257.28. 

The owner and operator must notify the State Director when the information has been 

placed in the operating record or alternative location as approved by the Director of an approved 

State. The Director of approved State can set alternative schedules the recordkeeping and

notification requirements specified under §257.30, except for the notification requirement in 

§257.25(g)(1)(iii). 

5. AGENCY ACTIVITIES, METHODS, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES
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This program is implemented by approved States and all information will be reported to the 

States or kept in an operating record; in unapproved States, the "Criteria for Classification of Solid 

Waste Disposal Facilities and Practices" (40 CFR part 257) are self implementing, meaning that the 

owner/operator documents compliance with the Criteria and places the documentation in the 

operating record. EPA will not collect information from individual non-municipal non-hazardous 

waste disposal units. EPA does have enforcement authority in States where EPA has made a formal 

determination that the State permit program is not adequate. In enforcement situations, EPA may

request information from the owner or operator.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

EPA has not specified how these records are to be developed and maintained. This ensures 

the maximum flexibility and minimum burden in meeting the final requirements.

5(c) SMALL ENTITY FLEXIBILITY

Respondents may include small businesses; all data requested are essential for both large 

and small businesses. The information burden was minimized to the extent possible for all potential 

respondents through the final rule's self-implementing format.

5(d) COLLECTION SCHEDULE

All collection requirements discussed in this ICR are for the period of time starting October 

01, 2015 until September 30, 2018. 

The final part 257, subpart B language established a schedule for the establishment of a 

ground-water monitoring program. Owners and operators of existing non-municipal non-hazardous 

waste disposal units that receive CESQG waste and lateral expansions of existing units were to 

comply with the ground-water requirements of §§257.22 - 257.25 according to the schedule 

established in the regulations unless an alternative schedule was specified by the Director of an 

approved State under §257.21(d):

1. Existing non-municipal non-hazardous waste disposal units that received CESQG 

wastes and lateral expansions of existing units were to be in compliance by July 1, 

1998. 

2. New non-municipal non-hazardous waste disposal units were to be in compliance 

before waste was placed in the unit.

3. Under §257.21(d), the Director of an approved State could specify an alternative 

schedule for owners and operators of existing units and lateral expansions of existing 

units to comply with the ground-water requirements specified in §§257.22 - 257.25. 

The alternative schedule was to ensure that 50 percent of all existing units were in 

compliance by July 1, 1998 and all existing units were in compliance by July 1, 

1999. 
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Once established at a unit, ground-water monitoring is to be conducted throughout the active 

life of the unit plus 30 years. The Director of an approved State may decrease the 30-year period if 

the owner/operator demonstrates that a shorter period of time is adequate to protect human health 

and the environment and the Director approves that demonstration.

The records and reports are to be maintained on an ongoing basis in the unit operating 

record; however, the part 257, subpart B Criteria allow approved States the discretion to establish 

alternative schedules for recordkeeping and notification requirements.

6. ESTIMATING THE BURDEN HOURS AND COST OF THE COLLECTION

6(a) ESTIMATING THE RESPONDENT BURDEN HOURS - Original ICR

The total universe of non-municipal non-hazardous waste disposal units that may receive 

CESQG waste includes two types of units: (1) units where CESQG waste is co-disposed with 

industrial waste on site; and (2) Subtitle D units receiving CESQG waste from off site (including 

construction and demolition waste disposal units and commercial industrial solid waste disposal 

units).

EPA originally assumed, and continues to assume, that units that co-disposed industrial nonhazardous waste and CESQG waste on site have ceased that practice to avoid the cost of 

compliance with part 257, subpart B. The commercial (off-site) industrial waste disposal units 

currently operating are subject to stringent environmental controls, imposed by States and corporate 

policy, therefore, EPA continues to believe, that these off-site units will incur a negligible burden 

from the revisions to part 257, subpart B. Therefore, the primary type of unit that continues to be 

affected by the part 257, subpart B rule is construction and demolition waste disposal units. 

Consequently, the only units that will incur burdens under the part 257, subpart B rule 

continue to be construction and demolition landfills that receive CESQG waste from off site 

generators. EPA currently estimates that there are approximately 1,571 construction and demolition 

landfills in the United States as of 2004 as reported in the April 2006 issue of BioCycle (down from 

the estimate of 1,931 in 2003).

 Construction and demolition waste landfills that were not in compliance with the part 257, 

subpart B revisions in 1996 would have responded to the regulation in one of two ways: (1) elected 

not to upgrade and decided to accept only construction and demolition waste that does not contain 

CESQG hazardous waste (these units would not be affected by the recordkeeping or reporting 

requirements of part 257, subpart B; or (2) upgraded and accepted CESQG waste (become subject 

to the recordkeeping and reporting requirements of the revisions to part 257, subpart B).

The Agency's Regulatory Impact Analysis (RIA) (June 1996) for the final part 257, subpart 

B rule, indicated that 162 construction and demolition waste landfills in 18 affected States would 

have elected to upgrade and thus become subject to the reporting and recordkeeping requirements 

of part 257, subpart B. The RIA also accounted for the number of small/dry/remote non-municipal 
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units that would have opted to use alternative ground-water monitoring techniques. As a result of 

this added flexibility, EPA believed that more units would have opted to upgrade. For the purpose 

of the original ICR, EPA assumed that 50% of the construction and demolition units that were 

eligible to use alternative ground-water monitoring techniques would have chosen to upgrade. This 

included half of the 21 landfills in Alaska (remote) and half of the 109 small landfills that were 

located in affected States with low precipitation. Overall, EPA estimated that 65 additional landfills 

would upgrade and use alternative ground-water monitoring techniques. Additional, EPA assumed 

that none of these 65 additional landfills would require expanded ground-water monitoring as 

discussed in the original ICR. Thus, the total number of upgrades of existing units was estimated to

be 227. In the original ICR, 227 existing facilities were used to calculate burdens. In addition, EPA 

projected, in the original ICR that 11 new and lateral expansions of existing units will be activated 

per year as construction and demolition waste units accepting CESQG waste became subject to this 

final rule.1 

First Update

 In the first update (September 22, 1999) for this continuing ICR, EPA developed new 

recordkeeping and reporting burden estimates. EPA revised its original estimate (162) of the 

number of construction and demolition waste landfills in the 18 affected States that would have 

elected to upgrade. EPA revised the original estimate down from 162 landfills to 146. This 

reduction was based on a decrease in the overall number of construction and demolition waste 

landfills that existed in the original 18 affected States. This reduction equated to a 10% reduction in 

the number of construction and demolition landfills that would have continued to have annual 

reporting and recordkeeping burdens during the period of time from September 30, 1999 until 

September 30, 2002.

 This same 10% reduction was used to reduce the number of existing construction and demolition 

waste landfills that would have continued to be subject to the reporting and recordkeeping burdens 

associated with corrective action (23 facilities in the original ICR vs. 21 in the first update). 

 Small/arid/remote construction and demolition facilities incurred reporting and recordkeeping 

burdens in the original ICR, but, in the first update to the ICR, they did not incur any burdens 

because small/arid/remote construction and demolition wastes facilities incurred only one-time 

burdens during the time period between September 30, 1996 and September 30, 1999. The 

Agency’s original assumption that none of the existing small/arid/remote facilities would need to 

undergo expanded ground-water monitoring and corrective action continued to be assumed in the 

first update to the original ICR for the reasons that were presented in the original ICR. 

 In the first update to the original ICR, one-time reporting and recordkeeping burden hours for 

existing construction and demolition waste facilities were also reduced because these one-time 

 

 

1 This estimate was based on a steady state environment where over 20 years (the remaining life of 

C&D landfills) all facilities that choose to upgrade will be replaced. In this steady state environment, 5% of 227 or 11 

facilities (8 of the original 162 facilities and 3 of the 65 small facilities in arid or remote areas) would be activated in a 

year. This concurs with the percentage used in the part 258 ICR, #1381 where information from a Waste Age article

and GAO also estimated 5% or 1/20.
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burdens occurred during the period of time between September 30, 1996 and September 30, 1999. 

These one-time burdens were associated with the floodplain provision, the small/arid/remote 

demonstration, and the establishment of the ground-water monitoring system. 

 

 For the first update to the original ICR, like the original ICR, the Agency assumed 11 new and 

lateral expansions of existing units will be activated per year as construction and demolition waste 

units accepting CESQG waste become subject to the part 257, subpart B rule

Second Update

 For the second update, EPA developed new recordkeeping and reporting burden estimates. 

EPA revised its first update estimate (146) of the number of construction and demolition waste 

landfills in the 18 affected that would have elected to upgrade. EPA revised the first update down 

from 146 construction and demolition waste landfills to 127. This reduction was based on a 

decrease in the overall number of construction and demolition waste landfills that exist in the 

original 18 affected States. The total number of respondents was therefore 127 construction and 

demolition waste landfills plus 18 States (145 respondents). This reduction equated to a 13% 

reduction in the number of construction and demolition waste landfills that would continue to have 

annual reporting and recordkeeping burdens during the period of time from October 1, 2002 until 

September 30, 2005. There is a reduction even though there has been an increase in the total 

overall number of construction and demolition waste landfills back towards the original estimated 

number in 1994 because EPA is evaluating the change only in the original 18 affected States. 

 This same 13% reduction was used to reduce the number of existing construction and demolition 

waste landfills that continue to be subject to the reporting and recordkeeping burdens associated 

with corrective action (21 in the first update vs. 18 in this second update).

 Any small/arid/remote construction and demolition facility that incurred reporting and 

recordkeeping burdens in the first update between September 30, 1999 and September 30, 2002 did 

not incur any additional burdens under the second update due to the one-time nature of those 

reporting and recordkeeping burdens. In addition, any new construction and demolition waste 

landfill (new between September 30, 1999 and September 30, 2002) did not incur any additional 

burdens under this second update due to the one-time reporting and recordkeeping burdens 

associated with the floodplain provision, the small/arid/remote demonstration, and the 

establishment of the ground-water monitoring system. 

Third Update

 For the third update, EPA is again developing new recordkeeping and reporting burden 

estimates. EPA has revised this ICR by increasing the number of C&D landfills subject to this ICR 

by revising the second update up from 127 construction and demolition landfills to 165. This 

increase is based upon the original 18 affected States as reported in BioCycle trade magazine in 

January 2004. The total number of respondents is therefore 165 construction and demolition waste 

landfills plus 18 States (183 respondents). This increase represents a 30% increase in the number of 

construction and demolition waste landfills that were reported in the last update.
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For this ICR, the Agency assumes 14 new and lateral expansions of existing units will be activated 

per year as construction and demolition waste units accepting CESQG waste become subject to the 

part 257, subpart B rule.

Fourth Update

For the fourth update, EPA is again developing new recordkeeping and reporting burden estimates. 

EPA has revised this ICR by decreasing the number of C&D landfills subject to this ICR by

revising the third update down from 165 C&D landfills to 134. This decrease is based upon the 

original 18 affected states as reported in Biocycle trade magazine in April 2006. The number of 

respondents is therefore 134 C&D waste landfills plus 18 States, for a total of 152 respondents. 

This decrease represents a 19% reduction in the number of C&D waste landfills that were reported 

in the last update.

 For this current ICR, the Agency assumes 14 new and lateral expansion of existing units will be 

activated per year accepting CESQG waste subject to Part 257, Subpart B rule. The Agency

believes that fewer, larger landfills will sustain the need for lateral expansions.

Fifth Update

For this fifth update, EPA is once again developing new recordkeeping and reporting burden 

estimates. EPA has reviewed Biocycle trade magazine and has concluded that the number of C&D 

landfills has stopped the decline and has remained at the current level of 134. The number of 

respondents is therefore 134 C&D waste landfills plus 18 States, for a total of 152 respondents. 

This decrease represents a 19% reduction in the number of C&D waste landfills that were reported 

in the last update.

 For this current ICR, the Agency assumes 14 new and lateral expansion of existing units will be 

activated per year accepting CESQG waste subject to Part 257, Subpart B rule. 

(b) ESTIMATING THE RESPONDENT BURDEN HOURS - Sixth update Continuing 

ICR

 For this sixth update, EPA is once again developing new recordkeeping and reporting burden 

estimates. EPA has reviewed Biocycle trade magazine and has concluded that the number of C&D 

landfills has remained at the current level of 134. The number of respondents is therefore 134 C&D 

waste landfills plus 18 States, for a total of 152 respondents.

 For this current ICR, the Agency assumes 14 new and lateral expansion of existing units will be 

activated per year accepting CESQG waste subject to Part 257, Subpart B rule. The Agency

believes that the current trend of fewer, larger landfills will sustain the need for lateral expansions.

LOCATION RESTRICTIONS

Section 257.8 - Floodplains

No existing facilities incur any one-time or annual burdens in this continuing ICR. For the 

14 new non-municipal non-hazardous waste disposal units that may receive CESQG waste and 
14

lateral expansions of existing units that are affected by this requirement, approximately 20% are 

expected to be within a 100-year floodplain. EPA has estimated a one-time recordkeeping 

requirement for this location restriction of 10 hours per unit. There is a one-time reporting burden 

of two hours per unit. 

Section 257.9 - Wetlands

The requirement for the wetlands location restriction comes from the Clean Water Act 

(CWA) and incorporates EPA guidelines developed pursuant to the CWA. Any recordkeeping 

requirement is attributable to implementing the CWA and not the Criteria for Classification of Solid 

Waste Disposal Facilities and Practices. Therefore, in order to avoid double counting, no 

recordkeeping requirements for this location provision are included in this estimate. The reporting 

and recordkeeping requirements are reported under OMB Control Number 2040-0086.

Section 257.13 - Deadline for Making Demonstrations

This section does not include any recordkeeping or reporting requirements.

GROUND-WATER MONITORING AND CORRECTIVE ACTION

Section 257.21(b) - No Migration Petition

Owners and operators of non-municipal non-hazardous waste disposal units that may

receive CESQG wastes may demonstrate (document) that there is no potential for migration of 

hazardous constituents from the unit. The demonstration is to be based on site-specific data and 

fate and transport modeling. EPA estimates that no more than 1 owner/operator out of the 14 new 

facilities will attempt this demonstration. EPA assumes that the required documentation would 

result in a one-time reporting requirement of 100 hours per unit. Section 257.21(b) does not contain 

recordkeeping requirements; however, the one-time recordkeeping requirements of two hours per 

unit from Section 257.30 have been included here. 

Section 257.21(h) and (i) - Small and Arid or Remote Non-municipal Non-hazardous Waste 

Disposal Units 

One-time burden hours are incurred under this provision for 3 of the 14 new 

small/arid/remote facilities that are eligible to use alternative ground-water monitoring and choose 

to upgrade. The Agency assumes that 3 of the total 14 new units will be located in 

small/arid/remote locations. The requirement is for owners and operators of these small/arid/remote 

non-municipal non-hazardous waste disposal units to make the determination that they meet the 

criteria in §257.21(h). There is a one-time recordkeeping burden of 10 hours per unit and a onetime reporting burden of two hours per unit. 

Section 257.21(i)(2) - Small and Arid or Remote Non-municipal Non-hazardous waste disposal 

Units
15

EPA has assumed that none of the 3 new or lateral expansions of existing non-municipal 

non-hazardous waste disposal units that are eligible to use alternative ground-water monitoring 

techniques and choose to upgrade will detect contamination requiring expanded ground-water 

monitoring. First, because these disposal units are small and located in dry or generally frozen 

climates, they are less likely to have contamination. Moreover, the economics are such that 

upgrading will be cost-effective for the small units only if expanded monitoring will not be 

necessary. Therefore, EPA assumes that none of these units will have to incur the reporting or 

recordkeeping requirements associated with expanded ground-water monitoring.

Section 257.21 - §257.23 - Establish Ground-Water Monitoring Systems 

EPA estimates 14 new or lateral expansions of existing construction and demolition landfills 

will choose to upgrade and will not be eligible to use alternative ground-water monitoring 

techniques. The Agency assumes the one-time reporting requirement of 20 hours per unit would 

result for these 14 new or lateral expansions of existing units. There are one-time recordkeeping 

requirements at §§257.22(d)(2), 257.23(a), and 257.23(g). All three sections has a six-hour per unit 

recordkeeping requirement. 

Section 257.24 - Detection Monitoring Program

EPA estimates the total annual reporting burden for detection monitoring to be 32 hours per 

year for the 134 existing units and the 14 new or lateral expansions of existing units per year. The 

annual recordkeeping requirement burden is two hours for each unit. This burden does not apply to 

existing, new or lateral expansions of existing units meeting the criteria for small units located in 

remote or arid regions as defined in §257.21(h).

Section 257.25 - Assessment Monitoring Program

EPA assumes that only existing units may need to establish an assessment monitoring 

program within the time frame covered by this ICR. None of the new units are expected to require 

assessment monitoring prior to January 31, 2009. 

For assessment monitoring, EPA estimates that this rule would impose an annual reporting 

burden of 32 hours per occurrence per year. EPA assumes that 22 units are included in the 

recordkeeping estimate. This estimate includes the units that voluntarily chose to make the "false 

positives" demonstration at §257.25(g)(2). There is an annual recordkeeping requirement of two 

hours for each unit. 

Section 257.25(g)(2) - "False Positives"

See the discussion for §257.25 - Assessment Monitoring Program.

Section 257.27 - Selection of Remedy

For corrective action, EPA estimated an annual reporting burden of 200 hours per year to 

document progress in clean-up activities. The Agency assumes 22 units are included in the 

recordkeeping estimate and would have increased burdens. 
16

The estimated reporting burden includes consideration of §257.27(d), the requirement to 

establish a schedule for implementing and completing remedial measures. The estimated burden 

also includes consideration of §257.27(e), the conditions that would allow no ground-water cleanup.

If the owner or operator determines that compliance with §257.27(b) cannot be practically

achieved, then the owner or operator must comply with the requirements of §257.28(c)(4).

There are annual recordkeeping burdens at §§257.27(b), 257.28(c)(4) and 257.28(e)(2). 

Each of these annual recordkeeping burdens requires two hours per unit, for a total of six hours. 

Section 257.28 - Implementation of Corrective Action Program 

EPA assumes that no owner or operator will have completed corrective action and, 

therefore, be required to comply with §257.28(f) prior to August 01, 2015. Section 257.28(e) 

requires, at a minimum, 3 consecutive years of data to demonstrate compliance with the groundwater protection standard. Assuming existing facilities entered into assessment monitoring no 

earlier than 2001, it is highly unlikely that any existing facility would have burdens associated with 

Section 257.28. This section, therefore, contains no reporting requirements.

RECORDKEEPING REQUIREMENT

Section 257.30 - Recordkeeping Requirements

EPA estimates that the recordkeeping requirement at §257.30 to place notifications in the 

operating record will impose a one-time recordkeeping burden of 10 hours on 1 new or lateral 

expansion of an existing unit per year. 

6(c) ESTIMATING RESPONDENT BURDEN HOURS AND COSTS

For a summary of the estimated respondent annual and one-time recordkeeping and 

reporting requirements burdens and costs, see Exhibits 4 through 7. For the purpose of preparing 

cost and burden estimates for this continuing ICR, EPA used the estimates prepared in similar 

programs that have been approved by OMB. The primary ICR used as a guideline was the ICR for 

part 258, which contains similar reporting and recordkeeping requirements. Additional ICRs 

reviewed included the Underground Storage Tanks (UST) program (Subtitle I) and the Subtitle C 

program. Costs for construction and demolition waste facility respondents were estimated based on 

the wage rates presented in Exhibit 1. These wage rates are based on the U.S. Office of Personnel 

Management, 2015 GS Salary table. The wage rates were determined as follows: Legal- GS-14, 

step 5; Managerial- GS-15, step 5; Technical- GS-12, step 5; and Clerical- GS-7, step 5. An 

overhead factor of 1.6 was applied to the rates and are shown below in exhibit 1.
17

EXHIBIT 1

Estimated Respondent Wage Rates for Commercial 

Construction and Demolition Landfills Only

Legal $ 75.07

Managerial $ 88.30

Technical $ 53.42

Clerical $ 30.11

6(d) ESTIMATING AGENCY BURDEN HOURS AND COST

All information is submitted to the States; therefore, Agency burden and cost are negligible. 

The State burden for recordkeeping will be for processing notifications sent by the owners or 

operators of units that elect to continue receiving CESQG wastes, review of the unit 

demonstrations, and certification of requirements. States will be notified as specified previously

under 3(b). Exhibit 2 presents the wage rates used to estimate the cost to the Agency and States.

These Agency/State wage rates are based on the U.S. Office of Personnel Management, 2015 GS 

Salary table. The wage rates were determined as follows: Legal- GS-14, step 5; Managerial- GS15, step 5; Technical- GS-12, step 5; and Clerical- GS-7, step 5. An overhead factor of 1.6 was 

applied to the rates and are shown below in exhibit 2.
18

EXHIBIT 2

Estimated Agency/State Wage Rates

Legal $ 75.07

Managerial $ 88.30

Technical $ 53.42

Clerical $ 30.11

6(e) ESTIMATING STATE BURDEN HOURS AND COST

The annual and one-time recordkeeping and reporting burden for State agencies is 

summarized in Exhibit 3 below. Based on the information in the recently revised ICR for part 258 

(ICR #1381), the total estimated recordkeeping and reporting burden for clerical staff is 2.5 hours 

per notification and the total estimated burden for technical staff is one hour per notification. For 

both recordkeeping and reporting estimates, the Agency assumes that neither the legal nor the 

managerial staff will be responsible for any additional burden or cost.

EXHIBIT 3

Estimated State Recordkeeping/Reporting Burden and Cost

Number 

 of 

Notifications

Legal

$75.07

Manager

$88.30

Technical

$53.42

Clerical

$30.11

Total 

Hours

Per/yr

Total Cost 

($) Per/yr 

LOCATION RESTRICTIONS

Annual 0 0 0 0 0 0.0 0.00

OneTime3 0 0 1 2.5 10.5 $386

GROUND-WATER MONITORING AND CORRECTIVE ACTION

Annual 202 0 0 1 2.5 707 $25,996

One -

Time

12 0 0 1 2.5 42.0 $1,544

6(f) BOTTOM LINE BURDEN HOURS AND COST/MASTER TABLES
19

Exhibits 4 and 6 present the estimated annual respondent burden hours and cost for 

reporting and recordkeeping requirements. The annual burden for respondents is 10,312 hours and 

the estimated cost is $493,489.

Exhibits 5 and 7 present the estimated one-time respondent burden hours and cost for 

reporting and recordkeeping requirements. The total one-time burden for respondents is 548 hours 

and the estimated cost is $30,750.

 Exhibit 8 presents a summary of the burden hours and cost incurred by both the States and 

owners and operators as a result of this final rule. The annual burden for reporting and 

recordkeeping requirements is 11,019 hours and the estimated cost is $518,485. The total one-time 

burden for reporting and recordkeeping requirements is 601 hours and the estimated cost is 

$32,680. The total one-time burden hours for reporting and recordkeeping has been annualized over 

a three year period and added to the annual burden hours, therefore, the total annual burden hours 

for reporting and recordkeeping is 11,219. In a similar manner, the total annual estimated cost is 

$530,378. 

6(g) REASONS FOR CHANGE IN BURDEN

This is a continuing ICR. Primary reasons for no changes in the burden is due to the number 

of C&D facilities have remained the same since the last renewal that were previously incurred 

during the period of time from October 01, 2015 until September 30, 2018. There is a decrease of 1 

hour and this is due to rounding. There is also a decrease of 10 responses and this is due to an 

evaluation of the number of state respondents anticipated in the next three years. 

 CHANGES TO CAPITAL/STARTUP AND O&M COSTS 

 In addition, the first update to this ICR was approved subject to the following terms of 

clearance. It was requested that EPA verify that no non-labor costs would be incurred by

respondents in complying with this collection. If non-labor costs were to be incurred by

respondents, EPA was to revise the second ICR to account for them. EPA has revised this as well 

as the previous ICR to address these additional costs associated with performing a hydrogeologic 

study, installation of ground-water monitoring wells, and sampling costs associated with sampling 

of ground water wells. EPA has assumed 14 new or lateral expansions for the period of July 31, 

2012 until August 01, 2015. These 14 expansions will each need to perform a hydrogeologic study

in order to assess where to establish ground water monitoring wells. The study, for a small site like 

most construction and demolition waste landfills are, would cost $137,350 per site for a total of 

$1,922,900. This total cost averaged over the 3-year period would be $640,967 per year. 

For these new or lateral expansions, they will need to establish 4 wells per site for the 

purpose of ground water monitoring. The capital cost for a total of 56 wells, at a depth of 50 feet, 

would total $398,496. This total averaged over the 3-year period would cost $132,832 per year. 

Lastly, the costs associated with sampling and analytical work would be a total of $803,860 per 

year. This assumes that the sampling and analytical work is not performed by facility personal and 

that the analytical work is for analysis of VOCs only. 
20

The total annual O&M costs will be $1,577,659. 

Hydrogeologic Study $640,967

56 Wells $132,832

Analytical Work $803,860

Total $1,577,659

 

6(h) BURDEN STATEMENT

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

estimated to average about 79 hours per respondent. 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-2015-0278, which is available for public viewing at the RCRA Docket in 

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

Washington, DC. The EPA/DC 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 for online viewing at http://www.regulations.gov

. Use http://www.regulations.gov 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. Once 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, DC 20503, 

Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-RCRA2015-0278 and OMB Control Number 2050-0154 in any correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information. 
 EXHIBIT 4

ESTIMATED ANNUAL RESPONDENT RECORDKEEPING BURDEN AND COST

REQUIREMENT NUMBER OF 

RESPONDENTS - 

ACTIVITY

EXISTING NEW

HOURS PER RESPONDENT - ACTIVITY

LEGAL MANAGER TECHNICAL CLERICAL

$75.07/HR $88.30/HR $55.42/HR $30.11/HR

TOTAL

HOURS 

PER YEAR

TOTAL COST

PER YEAR

Floodplains - 257.8 0 0 0 0 0 0 0 0

Wetlands - 257.9 0 0 0 0 0 0 0 0

No Migration Petition 

257.21(b)

0 0 0 0 0 0 0 0

Small and Remote

Facilities - 257.21(h)

0 0 0 0 0 0 0 0

Small and Remote

Facilities - 257.21(i)

0 0 0 0 0 0 0 0 

Establish GWM 

System - 257.23

0 0 0 0 0 0 0 0

Detection Monitoring 

Program - 257.24

134 14 0 0 1 1 296 12,362

Assessment Monitoring

Program - 257.25

22 0 0 0 1 1 44 1,838

Selection of Remedy

257.27

22 0 0 0 3 3 132 5,513

Recordkeeping

Requirements - 257.30

0 0 0 0 0 0 0 0

TOTAL ANNUAL

RECORDKEEPING

BURDEN AND COST

178 14 472 19,513
EXHIBIT 5

ESTIMATED ONE-TIME RESPONDENT RECORDKEEPING BURDEN AND COST

REQUIREMENT NUMBER OF 

RESPONDENTS - 

ACTIVITY

EXISTING NEW

HOURS PER RESPONDENT - ACTIVITY

LEGAL MANAGER TECHNICAL CLERICAL

$75.07/HR $88.30/HR $53.42/HR $30.11/HR

TOTAL

HOURS 

PER YEAR

TOTAL COST

PER YEAR

Floodplains - 257.8 0 3 0 2 4 4 30 1,532

Wetlands - 257.9 0 0 0 0 0 0 0 0

No Migration Petition 

257.21(b)

0 1 0 0 1 1 2 84

Small and Remote

Facilities - 257.21(h)

0 3 0 2 3 5 30 1,462

Small and Remote

Facilities - 257.21(i)

0 0 0 0 0 0 0 0 

Establish GWM 

System - 257.23

0 14 0 0 3 3 84 3,508

Detection Monitoring 

Program - 257.24

0 0 0 0 0 0 0 0

Assessment Monitoring

Program - 257.25

0 0 0 0 0 0 0 0

Selection of Remedy

257.27

0 0 0 0 0 0 0 0

Recordkeeping

Requirements - 257.30

0 1 0 2 4 4 10 511

TOTAL ONE-TIME

RECORDKEEPING

BURDEN AND COST

0 22 156 7,097
 EXHIBIT 6

ESTIMATED ANNUAL RESPONDENT REPORTING BURDEN AND COST

REQUIREMENT NUMBER OF 

RESPONDENTS - 

ACTIVITY

EXISTING NEW

HOURS PER RESPONDENT - ACTIVITY

LEGAL MANAGER TECHNICAL CLERICAL

$75.07/HR $88.30/HR $53.42/HR $30.11/HR

TOTAL

HOURS 

PER YEAR

TOTAL COST

PER YEAR

Floodplains - 257.8 0 0 0 0 0 0 0 0

Wetlands - 257.9 0 0 0 0 0 0 0 0

No Migration Petition 

257.21(b)

0 0 0 0 0 0 0 0

Small and Remote

Facilities - 257.21(h)

0 0 0 0 0 0 0 0

Small and Remote

Facilities - 257.21(i)

0 0 0 0 0 0 0 0 

Establish GWM 

System - 257.23

0 0 0 0 0 0 0 0

Detection Monitoring 

Program - 257.24

134 14 0 6 12 14 4,736 235,672

Assessment Monitoring

Program - 257.25

22 0 2 6 12 12 704 37,011

Selection of Remedy

257.27

22 0 10 30 40 120 4,400 201,293

Recordkeeping

Requirements - 257.30

0 0 0 0 0 0 0 0

TOTAL ANNUAL

REPORTING

BURDEN AND COST

178 14 9,840 473,967

EXHIBIT 7

ESTIMATED ONE-TIME RESPONDENT REPORTING BURDEN AND COST
REQUIREMENT NUMBER OF 

RESPONDENTS - 

ACTIVITY

EXISTING NEW

HOURS PER RESPONDENT – ACTIVITY

LEGAL MANAGER TECHNICAL CLERICAL

$75.07/HR $88.30/HR $53.42/HR $30.11/HR

TOTAL

HOURS 

PER YEAR

TOTAL COST

PER YEAR

Floodplains - 257.8 0 3 0 0 1 1 6 251

Wetlands - 257.9 0 0 0 0 0 0 0 0

No Migration Petition 

257.21(b)

0 1 5 20 60 15 100 5,798

Small and Remote

Facilities - 257.21(h)

0 3 0 0 1 1 6 251

Small and Remote

Facilities - 257.21(i)

0 0 0 0 0 0 0 0 

Establish GWM 

System - 257.23

0 14 2 5 11 2 280 17,353

Detection Monitoring 

Program - 257.24

0 0 0 0 0 0 0 0

Assessment Monitoring

Program - 257.25

0 0 0 0 0 0 0 0

Selection of Remedy

257.27

0 0 0 0 0 0 0 0

Recordkeeping

Requirements - 257.30

0 0 0 0 0 0 0 0

TOTAL ONE-TIME

REPORTING

BURDEN AND COST

0 21 392 23,653

EXHIBIT 8

TOTAL ESTIMATED ANNUAL AND ONE-TIME BURDEN HOURS AND COSTS
ANNUAL BURDEN ONE-TIME BURDEN

Hours Costs Hours Costs

State Reporting and Recordkeeping Burden 707 $ 25,996 53 $ 1,930

Respondent Reporting and Recordkeeping Burden 10,312 $493,489 548 $30,750

TOTAL ESTIMATED BURDEN 11,019 $519,485 601 $32,680

Total Annual Burden Hours and Costs = Annual Burden + 1/3 of One-time burden

Total Annual Burden Hours = 11,019 + 1/3 (601) = 11,219

Total Annual Burden Costs = 519,485 + 1/3 (32,680) = $530,378