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. ID ENTIFICATION OF THE INFORMATION COLLECTION 1(a) Title and Number of the Information Collection
................................ ..................... 2 1(b) Short Characterization of the I nformation 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 R EQUESTED 3(a) Respondents/SI C codes
................................ ................................ ............................ 3 3(b) Public Notice
................................ ................................ ................................ ............ 3 3( c ) In formation Requested
................................ ................................ ............................. 3 4. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIES, COLLECTI ON 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, CONSUL TATIONS, AND OTHER COLLECTION CRI TERIA 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. ESTI MATING THE BURDEN HOURS AND COST OF THE COLLECTION 6(a) Estimating the Respondent Burden Hours
- Original I CR
........................... 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 L ine Burden Hours and Costs/Master Tables
................................ ........... 1 9 6(g) Reasons for Change in Burden
................................ ................................ .............. 19 6(h) Burden Statement
................................ ................................ ................................ ... 202

**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 P ractices" (Renewal), ICR 1745.0 8 , OMB Number 2050
- 0154
. **1(b) SHORT**  **C HARACTERIZATION 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 conditionall y 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 f ound 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 th at there might be a basis for concern and further stud y 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 delay ed as the Agency had little information concerning the potential or actual impacts that these ty pes 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 M ay 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 L isting 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 recordkeeping3

requirements for owners and operators of new, existing, and lateral expansions of existing non
municipal 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 requiremen ts. These regulations were finalized under the authority of Sections 1008, 2002 (general rulemaking authorit y), 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 an d ensure that non
- municipal non - hazardous waste disposal units that receive CESQG hazardous wastes, and CESQGs, are comply ing 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)**  **NONDUPLICA TION**  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 deliberatel y 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 Soli d 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 f or 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
- IC R #1381). The part 258 ICR developed estimates in consultation with owners and operators of M SWLFs, State personnel (see below), EPA personnel (Headquarters4

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 estimate s 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 I CR, EPA contacted state solid waste offic ials to review and comment on this document. EPA is grateful the following people reviewed this document: 1) Ed Dexter, of the Mary land 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 Wy oming 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, especiall y 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 viol ate an y 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 an y 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 b y 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 un its that receive CESQG wastes. This continuing information request expires on September 30, 2015.5

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 requi rement on CESQGs; therefore, the rest of the anal ys is 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 c ollecting information. Rather, the owners or operators of non
municipal 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 documen tation is placed in the operating record. The operating record is intended to be equivalent to a permit file that is routinely kept b y the State permitting agency. The Agency did not intend for the final rule to create additional recordkeeping except whe n 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 deliberatel y 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 demon stration 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 Directo r 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 Petition6

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 presente d 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 n on - 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 t he approved State should consider the factors in §257.21(i)(3) when authorizing and considering these alternatives. Owners and operators of these qualify ing small and arid or remote non
municipal non
- hazardous waste disposal units must place in their oper ating 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 facilit y." 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 a lternative." 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 non
hazardous waste disposal units that detect cont amination through the use of any alternative ground
water 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 an ywhere 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 S ys tems Owners and operators must notify the State Director that documentation pertaining to measurement, sampling, and anal yt ical devices has been placed in the operating record. The numbering, spacing, and depth of monitoring s ys tems shall be certified by a qualified ground
- water scientist or approved b y t he Director of an approve d State. Within 14 day s of the certification, the owner or operator must notify the State Director that certification has been placed in the operating record.7

Owners or operators must notify the State Director that the description of the sampling and ana ly sis 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 257.2 4
- 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 day s 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) th at 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 b y a qualified ground
- wat er 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 detecte d, the owner or operator must, within 14 day s after obtaining the results, place a notice in the operating record identify ing 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 day s, 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 concentration s 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 (Append ix I I of part 258) constituents are detected at statistically

significant levels above the ground
- water protection standard established under §257.25 (h) or (i) in an y s ampling event, the owner or operator must, within 14 day s of this finding, place a noti ce in the operating record identify ing 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 plac ed in the operating record. The owner or operator must also notify all persons who own the land or reside on the land that directl y overlies an y part of the plume of contamination if contaminants have migrated off site, if indicated by sampling wells in a ccordance with §257.25(g)(1). Section 257.25(g)(2)
- "False Positives"8

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 con tamination 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 Remed y 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 day s of selecting a remedy , that a report describing the selected remedy and specify in g 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
- Im plementation of Corrective Action Program The owner or operator may determine that corrective action cannot be achieved with any currentl y available remedy. If so, the owner or operator must document in the operating record that a report justify ing 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 c ompletion of the requirements of §257.28(e), the owner or operator must document in the operating record that the remed y has been completed in compliance with the requirements of §257.28(e) and notify

the State Director. **RECORDKEEPING REQUIREMENT** Sectio n 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 an y location restriction demonstration required under §§257.7 through 257.12 or an y demonstrat ion, certification, finding, monitoring, testing, or anal yt ical 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 appro ved b y 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 ACTI VITIES, METHODS, AND INFORMATION MANAGEMENT**  **5 (a)**  **AGENCY ACTIVITIES**9

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 ind ividual 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 t he 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
- implementi ng format. **5 (d)**  **COLLECTION SCHEDULE** All collection requirements discussed in this I CR 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 ac cording 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 sp ecify 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 ex isting units were in compliance b y J uly

1, 1998 and all existing units were in compliance by July 1, 1999.10

Once established at a unit, ground
- water monitoring is to be conducted throughout the active life of the unit plus 30 y ears. The Director of an ap proved State may decrease the 30
- ye ar 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 maintaine d 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 ty pes 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 originall y assumed, and continues to assume , that units that co
- disposed industrial non
hazardous 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 currentl y operating are subj ect 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 t yp e of unit t hat continues to be affected b y the part 257, subpart B rule is construction and demolition waste disposal units. Consequently , the onl y units that will incur burdens under the part 257, subpart B rule continue to be construction and demolition landfill s that receive CESQG waste from off site generators. EPA currently estimates t hat there are approximately 1,57 1 construction and demolition landfills in the United States as of 2004 as reported in the April 2006 issue of BioC ycle (down from the estimate o f 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 way s: (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 b y the recordkeeping or reporting requirements of part 257, subpart B; or (2) upgraded and accepted CESQG waste (become subject to the recordk eeping and reporting requirements of the revisions to part 257, subpart B). The Agency's Regulatory I mpact Anal ys is (RIA) (June 1996) for the final part 257, subpart B rule, indicated that 162 construction and demolition waste landfills in 18 affected St ates 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
- municipal11

units that would have opted to use alternative groun d
- 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 a lternative 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, th e total number of upgrades of existing units was estimated to be 227. In the original ICR, 227 existing facilities were used to ca lculate 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 r eduction 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 wou ld 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 landf

ills that would have continued to be subject to the reporting and recordkeeping burdens associated with corrective action (23 facilities in the original I CR vs. 21 in the first update). Small/arid/remote construction and demolition facilities incur red reporting and recordkeeping burdens in the original ICR, but, in the first update to the I CR, they did not incur any

burdens because small/arid/remote construction and demolition wastes facilities incurred onl y one - time burdens during the time period b etween September 30, 1996 and September 30, 1999. The Agency ’s original assumption that none of the existing small/arid/remote facilities would need to u ndergo expanded ground
- water monitoring and corrective action continued to be assumed in the first upd ate to the original I CR for the reasons that were presented in the original ICR. In the first update to the original I CR, one
- time reporting and recordkeeping burden hours for existing construction and demolition waste facilities were also reduced bec ause 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 w ill 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) w ould be activated in a year. This concurs with the percentage used in the part 258 ICR, #1381 where information from a Waste Age articl e and GAO also estimated 5% or 1/20.12

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 groun d
- water monitoring s ys tem. For the first update to the original I CR, like the original ICR, the Agency assumed 11 new and lateral expansions of existing units will be activated per y ear as construction and demolition waste units accepting CESQG waste become subject to the part 2 57, 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 tha t 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 land fills 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 a nd demolition waste landfills back towards the original estimated number in 1994 because EPA is evaluating the change onl y in the original 18 affected States. This same 13% reduction was used to reduce the number of existing construction and de molition waste landfills that continue to be subje c t 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 i ncurred reporting and recordkeeping burdens in the first update between September 30, 1999 and September 30, 2002 did not incur an y additional burdens under the second update due to the one
- time nature of those reporting and recordkeeping burdens. In addi tion, any new construction and demolition waste landfill (new between September 30, 1999 and September 30, 2002) did not incur an y additional burdens under this second update due to the one
- time reporting and recordkeeping burdens associated with the floo dplain provision, the small/arid/remote demonstration, and the establishment of the ground
- water monitoring s ys tem. **Third Update** For the third update, EPA is again developing new recordkeeping and reporting burden estimates. EPA has revised thi s I CR by increasing the number of C&D landfills subject to this I CR 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 BioC yc le 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.13

For this IC R, 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 I CR 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 Biocy cle 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 repre sents 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 Biocy cle 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 expa nsion of existing units will be activated per year accepting CESQG w aste 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 Biocy cle 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 re spondents. 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 expansion s. **LOCATION RESTRICTIONS** Section 257.8
- Floodplains No existing facilities incur an y 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 and14

lateral expansions of existing units that are affected by this requirement, approximately 20% are expected to be within a 100
- ye ar floodplain. EPA has estimated a one
- time recordkeeping requirement for this location restriction of 10 hours per unit. There is a one
- time re porting 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 a ttributable 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 esti mate. 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 an y 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 const ituents 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 d ocumentation 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 includ ed 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 d isposal 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 one
time reporting burden of two hours per unit. Section 257.21(i)(2)
- Small and Arid or Remote Non
- municipal Non
- hazardous waste disposal Units15

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 up grade 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 mo nitoring. Section 257.21
- §257.23
- Establish Ground
- Water Monitoring S ys tems 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 m onitoring 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 257.2 3 (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 ye ar for the 134 existing units and th e 14 new or lateral expansions of existing units per ye ar. The annual recordkeeping requirement burden is two hours for each unit. This burden does not appl y to existing, new or lateral expansions of existing units meeting the criteria for small units lo cated 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 b y this I CR. None of the new units are expected to require assessment monitoring prior to January 31, 2009
. For assessment monito ring, EPA estimates that this rule would impose a n annual reporting burden of 32 hours per occurrenc e per ye ar. 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 25 7.25(g)(2)
- "False Positives" See the discussion for §257.25
- Assessment Monitoring Program. Section 257.27
- Selection of Remed y For corrective action, EPA estimated an annual reporting burden of 200 hours per ye ar to document progress in clean
- up a c tivities. 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 compl eting remedial measures. The estimated burden also includes consideration of §257.27(e), the conditions that would allow no ground
- water clean
up. If the owner or operator determines that compliance with §257.27(b) cannot be practically achieved, then th e owner or operator must compl y 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
- Im plementation of Corrective Action Program EPA assumes that no owner or operator will have completed corrective action and, therefore, be required to comply with §257.2 8(f) prior to August 01, 2015 . Section 257 .28(e) requires, at a minimum, 3 consecutive ye ars of data to demonstrate compliance with the ground
water protection standard. Assuming existing facilities entered into assessment monitoring no earlier than 2001, it is highl y unlikel y that an y existing facility would have b urdens 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 y ear. **6(c) ESTIMATING RESPONDENT BURD**  **EN 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 use d the estimates prep ared in similar programs that have been approved b y OMB. The primary I CR used as a guideline was the ICR for part 258, which contains similar reporting and recordkeeping requirements. Additional I CRs 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. Offi ce of Personne l Management, 2015 GS Salary table. The wage rates were determined as follows: L egal
- 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 i n exhibit 1.17 **EXHIBIT 1 Estimated Respondent Wage Rates for Commercial**  **Construction and Demolition Landfills Only** Legal $ 7 5.07 Managerial $ 8 8.30 Technical $ 5 3.42 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, revie w 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. Offi ce of Personnel Management, 2015 GS Salary table. The wage rates were determined as follows: L egal
- 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 2.18 **EXHIBIT 2 Estimated Agency/State Wage Rates**  Legal $ 7 5.07 Managerial $ 88.30 Technical $ 5 3.42 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 I CR for part 258 (I CR #1381), the total estimated recordkeeping and reporting burden for clerical staff is 2.5 hours per notificatio n 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 an y additional burden or cost. **EXHIBIT 3** Estimated State Recordkeeping/Reporting Burden and Cost

Number of Notifi
cations Legal

$7 5.07 Manager

$8 8.30 Technical

$5 3.42 Clerical

$30.11 Total

Hours Per/y r Total Cost ($) Per/ yr
LOCAT ION RESTRI CTIONS Annual 0 0 0 0 0 0.0 0.00 One
Time 3 0 0 1 2.5 10.5 $ 3 86 GROUND
- WATER MONITORING AND CORRECTI VE ACTION Annual 202 0 0 1 2.5 707 $ 2 5,996 One
- Time 12 0 0 1 2.5 42.0 $ 1, 54 4 **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 an d the estimated cost is $ 4 93,489
. Exhibits 5 and 7 present the estimate d one
- time respondent burden hours and cost for reporting and recordkeeping requirements. The total one
- time burden for respondents is 548 hours an d the estimated cost is $ 30,750
. Exhibit 8 presents a summary of the burden hours and cost incu rred 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 an d the estimated cost is $ 518,485 . The total one
- time burden for reporting and r ecordkeeping 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 ye ar period and added to the annual burden hours, therefore, the total annual burden hours for rep or ting and recordkeeping is 11,219 . In a similar manner, the total an nual estimated cost is $ 530,378
. **6(g) REASONS FOR CHANGE IN BURDEN**  This is a continuing ICR. Primary reasons for no chang es 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 peri od 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 i s due to an evaluation of the number of state respondents anticipated in the next three y ears.

**CHANGES TO CAPITAL/STARTUP AND O&M COSTS** In addition, the first update to this I CR was approved subject to the following te rms of clearance. It was requested that EPA verify that no non
- labor costs would be incurred by respondents in comply ing with this collection. If non
- labor costs were to be incurred by respondents, EPA was to revise the second ICR to account for them. E PA has revised this as well as the previous ICR to address these additional costs associated with performing a h ydrogeologic study , installation of ground
- water monitoring wells, and sampling costs associated with sampling of ground water wells. EPA has a ssumed 14 new or lateral expan sions for the period of July 31, 2012 unt il August 01, 2015 . These 14 expansions will each need to perform a hy drogeologic 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 e stablish 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 y ear. Lastl y, the costs assoc iated with sampling and analy tical work would be a total of $ 803,860 per ye ar. This assumes that the sampling and anal yt ical work is not performed by facility personal and that the anal yt ical work is for anal ys is of VOCs only
.20

The total annual O&M costs will be $1,577,659. Hy drogeologic Study $640,967 56 Wells $132,832 Analy tical Work $803,860 **Total $1,577,659**  **6(h) BURDEN STATEMENT**  The annual public reporting and recordkeeping burden for this collection of informat ion 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 sy stems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the exist ing way s to comply with an y 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 disclos e the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR p art 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the accuracy of the provided burden estimates, and an y suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has est ablished a public docket for this I CR under Doc ket 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 Dock et Center Public Reading Room is open from 8: 3 0 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holiday s. 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 t he 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 s ys tem, select “search,” then key in the docket ID number identified above. Also, you can send commen ts 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 Dock et ID N umber EPA
- HQ
- RCRA
2015
- 0278 a nd OMB C ontrol N umber 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 TO TA L HOURS PER YEAR TO TA L 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 Sm all and Remote Facilities
- 257.21(h) 0 0 0 0 0 0 0 0 Sm all and Remote Facilities
- 257.21(i) 0 0 0 0 0 0 0 0 Establish GWM Sy stem - 257.23 0 0 0 0 0 0 0 0 Detection Monitoring Program
- 257.24 134 14 0 0 1 1 296 1 2, 362 Assessment Monitoring Program
- 257.25 22 0 0 0 1 1 4 4 1, 838 Selection of Remedy 257.27 22 0 0 0 3 3 13 2 5, 513 Recordkeeping Requirements
- 257.30 0 0 0 0 0 0 0 0 TO TA L ANNUAL RECORDKEEPING BURDEN AND COST 178 14 472 1 9,513**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 TO TA L HOURS PER YEAR TO TA L COST

PER YEAR Floodplains
- 257.8 0 3 0 2 4 4 30 1, 53 2 Wetlands
- 257.9 0 0 0 0 0 0 0 0 No Migration Petition 257.21(b) 0 1 0 0 1 1 2 8 4 Sm all and Remote Facilities
- 257.21(h) 0 3 0 2 3 5 30 1, 462 Sm all and Remote Facilities
- 257.21(i) 0 0 0 0 0 0 0 0 Establish GWM Sy stem - 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 51 1 TO TA L 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 TO TA L HOURS PER YEAR TO TA L 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 Sm all and Remote Facilities
- 257.21(h) 0 0 0 0 0 0 0 0 Sm all and Remote Facilities
- 257.21(i) 0 0 0 0 0 0 0 0 Establish GWM Sy stem - 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 3 7,011 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 TO TA L 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 TO TA L HOURS PER YEAR TO TA L COST

PER YEAR Floodplains
- 257.8 0 3 0 0 1 1 6 2 51 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 Sm all and Remote Facilities
- 257.21(h) 0 3 0 0 1 1 6 2 51 Sm all and Remote Facilities
- 257.21(i) 0 0 0 0 0 0 0 0 Establish GWM Sy stem - 257.23 0 14 2 5 11 2 280 1 7,353 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 TO TA L ONE
- TIME REPORTING BURDEN AND COST 0 21 392 2 3,653

**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 70 7 $ 25,996 53 $ 1,930 Respondent Reporting and Recordkeeping Burden 10,312 $4 93,489 548 $30,750 TO TA L ESTIMATED BURDEN 11,01 9 $ 519,485 601 $32,680 Total Annual Burden Hours and Costs = Annual Burden + 1/3 of One
- time burden To tal Annual Burden Hours = 11,019 + 1/3 (601) = 11,219 Total Annua l Burden Costs = 519,485 + 1/3 (32,680) = $530,378