SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.14

“NOTIFICATION OF REGULATED WASTE ACTIVITY

AND 2009 HAZARDOUS WASTE REPORT” 

September 10, 2009

Office of Resource Conservation and Recovery

United States Environmental Protection Agency

Washington, D.C. 20460
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION.......................................................1

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

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION.....................................1

2. NEED FOR AND USE OF THE COLLECTION ..............................................................................9

2(a) NEED AND AUTHORITY FOR THE COLLECTION...........................................................9

2(b) PRACTICAL UTILITY AND USERS OF THE DATA........................................................10

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA..............12

3(a) NONDUPLICATION .............................................................................................................12

3(b) PUBLIC NOTICE...................................................................................................................12

3(c) CONSULTATIONS................................................................................................................13

3(d) EFFECTS OF LESS FREQUENT COLLECTION................................................................14

3(e) GENERAL GUIDELINES......................................................................................................15

3(f) CONFIDENTIALITY.............................................................................................................15

3(g) SENSITIVE QUESTIONS......................................................................................................15

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ..............................................16

4(a) RESPONDENTS AND NAICS CODES ................................................................................16

4(b) INFORMATION REQUESTED.............................................................................................16

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT ......................................................25

5(a) AGENCY ACTIVITIES .........................................................................................................25

5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................27

5(c) SMALL ENTITY FLEXIBILITY...........................................................................................28

5(d) COLLECTION SCHEDULE..................................................................................................28

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ..............................32

6(a) ESTIMATING RESPONDENT BURDEN HOURS..............................................................32

6(b) ESTIMATING RESPONDENT COSTS ................................................................................38

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN ....................................................39

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR

AND COST BURDEN............................................................................................................39

6(e) BOTTOM LINE HOUR AND COST BURDEN ...................................................................46

6(f) REASONS FOR CHANGE IN BURDEN..............................................................................47

6(g) PUBLIC BURDEN STATEMENT.........................................................................................49
1

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “Notification of Regulated Waste

Activity and 2009 Hazardous Waste Report,” EPA ICR Number 0976.14.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

This is a request to renew two currently approved ICRs of the U.S. Environmental 

Protection Agency (EPA):

 “Notification of Regulated Waste Activity,” EPA ICR Number 0261.15 (OMB 

Control Number 2050-0028). The Notification ICR addresses the notification 

requirements under Section 3010 of Subtitle C of the Resource Conservation and 

Recovery Act (RCRA), as amended. RCRA Section 3010 requires any person 

who generates, transports, or recycles regulated wastes or who owns or operates a

facility for the treatment, storage, or disposal of regulated wastes to notify EPA of 

their activities, including the location and general description of the activities and 

the regulated wastes handled. As required by statute, EPA promulgated 

regulations to implement these notification requirements at 40 CFR Parts 262, 

263, 264, 265, 266, 270, 273, and 279. 

 “2007 Hazardous Waste Report,” EPA ICR Number 0976.13 (OMB Control 

Number 2060-0024). The Hazardous Waste Report ICR addresses the 

requirements of Sections 3002 and 3004 of RCRA, as amended, which require 

reporting to EPA or to authorized States at least every two years. The Hazardous 

Waste Report [EPA Form 8700-13 Form A/B], or comparable State report, is used 

by generators and treatment, storage, and disposal facilities (TSDFs) to satisfy

this requirement.

EPA integrated the above two ICRs into this current ICR, EPA ICR Number 0976.14, to 

ensure consistency and minimize duplication in its burden assumptions and estimates, since both 

ICRs address some of the same reporting elements under their respective requirements. In 

particular, both ICRs address the use of the RCRA Subtitle C Site Identification Form (i.e., the 

Site ID Form). Specifically, the Notification ICR addresses the requirements for all regulated 

entities to submit the Site ID Form (or alternative document, if specified) to notify EPA or the 

authorized State. The Hazardous Waste Report ICR addresses the requirements for large 

quantity generators (LQGs)1and TSDFs to prepare and submit the Site ID Form as part of their 

Hazardous Waste Report. Incorporating these two ICRs into this current ICR has allowed EPA 

to more comprehensively estimate the burden of the Site ID Form and other collections, ensure 

consistency and nonduplication in its analysis, and address recent changes to the Site ID Form.

 

1

 An LQG is a facility that generates 1,000 kilograms (2,200 pounds) or more of hazardous waste in any 

single calendar month, or more than 1 kilogram (2.2 pounds) of acute hazardous waste in any single calendar month, 

or more than 100 kilograms (220 pounds) of acute hazardous waste spill clean-up material in any single calendar 

month.
2

In addition, EPA integrated into this current ICR two additional reporting requirements 

related to the Site ID Form:

 The requirement at 40 CFR 260.42 that provides that hazardous secondary

material generators, tolling contractors, toll manufacturers, reclaimers, and 

intermediate facilities managing hazardous secondary materials that are excluded 

from regulation under section 261.2(a)(2)(ii) or section 261.4(a)(23), (24), or (25) 

must comply with specified notification requirements. This requirement is 

currently addressed in “Revisions to the RCRA Definition of Solid Waste,” EPA 

ICR Number 2310.01 (OMB Control Number 2050-0202).

 The requirements at 40 CFR 262.203 and 262.204 that provide the option to 

comply with an alternative set of generator requirements applicable to laboratories 

to eligible academic entities, teaching hospitals that are not owned by a college or 

university, and non-profit research institutes that are not owned or operated by a 

college or university. In order to comply with these alternative standards, 

facilities must comply with specified notification requirements. These 

requirements are currently addressed in “Generator Standards Applicable to 

Laboratories Owned by Eligible Academic Entities,” EPA ICR Number 2317.01

(2050-0204).

Sections 1 through 5 of this document describe the information collection requirements 

covered in this ICR (e.g., in regard to need and use of the information collected). Section 6 

estimates the annual hour and cost burden to respondents and the Agency under these 

requirements. 

The following paragraphs briefly summarize the information collection requirements 

covered in this ICR.

(1) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

40 CFR 260.42(a) provides that hazardous secondary material generators, tolling 

contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous 

secondary materials which are excluded from regulation under section 261.2(a)(2)(ii) or section 

261.4(a)(23), (24), or (25) must send a notification prior to operating under the exclusion(s) and 

by March 1 of each even numbered year thereafter to the Regional Administrator using EPA 

Form 8700-12 (i.e., the Site ID Form) that includes the specified information at section 

260.42(a)(1)-(10). 

Section 260.42(b) provides that, if a hazardous secondary material generator, tolling 

contractor, toll manufacturer, reclaimer or intermediate facility has submitted a notification, but 

then subsequently stops managing hazardous secondary materials in accordance with the 

exclusion(s), the facility must notify the Regional Administrator within thirty (30) days using 
3

EPA Form 8700-12. For purposes of this section, a facility has stopped managing hazardous 

secondary materials if the facility no longer generates, manages and/or reclaims hazardous 

secondary materials under the exclusion(s) and does not expect to manage any amount of 

hazardous secondary materials for at least one year.

(b) Notification of Hazardous Waste Activity under RCRA Section 3010

Facilities that generate, transport, recycle, treat, store, or dispose of hazardous waste as 

defined by 40 CFR Part 261 must notify EPA of their hazardous waste activities and obtain an 

EPA Identification Number. All of these facilities are required to use EPA Form 8700-12 (i.e., 

the Site ID Form) to notify EPA of their hazardous waste activities. These notification 

requirements are codified at 40 CFR Parts 262, 263, 264, 265, 266, 270, and 273. The specific 

notification requirements for each of these parts are described below and listed in Table 1.

40 CFR Parts 262, 263, 264, and 265 include the notification requirements for generators, 

transporters, and owners or operators of permitted and interim status TSDFs, respectively. 

Sections 262.12, 263.11, 264.11, and 265.11 list the specific notification requirements. Persons 

regulated under these sections must obtain an EPA Identification Number before treating, 

storing, transporting, offering for transport, or disposing of hazardous waste.

40 CFR Part 266, Subpart D includes notification requirements for generators and 

transporters; storers; and users of recyclable materials that are used in a manner that constitutes 

disposal. Specifically, sections 266.21, 266.22, and 266.23 subject generators and transporters of 

these materials; storers who are not the ultimate users; and users, respectively, to the notification 

requirement under RCRA Section 3010. In addition, these sections also subject these same 

generators and transporters; storers; and users to all of the applicable requirements of 40 CFR 

Parts 262 and 263; Parts 264 and 265, Subparts A through L; and Parts 264 and 265, 

respectively, that include the specific mechanics for implementing the notification requirements 

as described in sections 262.12, 263.11, 264.11, and 265.11. 

40 CFR Part 266, Subpart F includes notification requirements for generators, 

transporters, and storers of recyclable materials that are utilized for precious metal recovery. 

Specifically, section 266.70(b)(1) subjects these facilities to the RCRA Section 3010 notification 

requirements.

40 CFR Part 266, Subpart G includes notification requirements for owners or operators of 

interim status and permitted TSDFs that store spent lead-acid batteries (other than spent leadacid batteries that are regenerated) before reclaiming them. Specifically, section 266.80(b)(1)(i) 

requires interim status TSDFs that store these batteries before reclaiming them meet the 

notification requirements of RCRA Section 3010. In addition, section 266.80(b)(2)(i) requires 

permitted TSDFs that store these batteries before reclaiming them meet the notification 

requirements of RCRA Section 3010.

40 CFR Part 266, Subpart H includes notification requirements for facilities that burn or 

process hazardous waste in a boiler or industrial furnace (BIF). Subpart H also subjects 

generators, transporters, and storers (including processors, blenders, and distributors of 
4

hazardous waste fuel) of hazardous waste that is burned or processed in a BIF to the notification 

requirements of 40 CFR Parts 262, 263, and 264 and 265, respectively. Specifically, sections 

266.100(c)(1)(i) and 266.100(f)(1) require that owners or operators of smelting, melting, and 

refining furnaces that processes hazardous waste either solely for metals recovery or for recovery

of economically significant amounts of certain precious metals, respectively, to provide a 

written, one-time notification of their hazardous waste activities. In addition, sections 

266.101(a), 266.101(b), and 266.101(c) require that generators, transporters, and storers of 

hazardous waste that is burned or processed in a BIF follow specific notification requirements 

and procedures of sections 262.12, 263.11, and 264.11 and 265.11, respectively. Further, 

sections 266.102(a)(2)(ii) and 266.103(a)(4)(ii) subject owners or operators of permitted and 

interim status BIFs that burn or process hazardous waste, respectively, to 40 CFR Parts 264 and 

265, Subpart B, which includes the section 264.11 and 265.11 notification requirements. Finally, 

section 266.108(d) requires that facilities that qualify for the small quantity on-site burner 

exemption to provide a written, one-time notification of their hazardous waste activities.

40 CFR Part 270 prescribes the timing for notification of hazardous waste activities due 

to the listing of a hazardous waste in 40 CFR Part 261. Specifically, section 270.1(b) requires 

that “not later than 90 days after the promulgation or revision of regulations in Part 261 

(identifying and listing hazardous wastes), generators and transporters of hazardous waste, and 

owners or operators of hazardous waste treatment, storage, or disposal facilities may be required 

to file a notification of that activity under Section 3010.” 

40 CFR Part 273, Subpart D describes certain conditions under which a transporter of 

universal waste may be subject to the Section 3010 notification requirements of RCRA. 

Specifically, section 273.54 makes transporters who determine that any material resulting from a 

release of universal waste is a hazardous waste subject to 40 CFR Part 262. As a result, section 

273.54 may also make them, in certain circumstances, subject to the section 262.12 notification 

requirements and procedures. 

40 CFR Part 273, Subpart E includes notification requirements for destination facilities of 

universal waste. Specifically, section 273.60(a) subjects owners or operators of destination 

facilities to the notification requirement under RCRA Section 3010. Section 273.60(a) also 

subjects destination facilities to all applicable requirements of 40 CFR Parts 264, 265, 266, 268, 

and 270, which include the section 264.11 and 265.11 notification requirements and procedures.
5

Table 1

Hazardous Waste Notification Requirements

40 CFR 

Regulatory 

Citation

Regulated Entity

§262.12 Hazardous Waste Generators

§263.11 Hazardous Waste Transporters

§264.11 Permitted Hazardous Waste Treatment, Storage, and Disposal Facilities

(TSDFs)

§265.11 Interim Status Hazardous Waste Treatment, Storage, and Disposal Facilities

§266.21 Generators and Transporters of Recyclable Materials Used in a Manner 

Constituting Disposal

§266.22 Storers of Recyclable Materials Used in a Manner Constituting Disposal

§266.23 Users of Recyclable Materials in a Manner Constituting Disposal

§266.70(b)(1) Generators, Transporters, and Storers of Recyclable Materials Utilized for 

Precious Metal Recovery

§266.80(b)(1)(i) Interim Status TSDFs Storing Spent Lead-Acid Batteries (other than Spent 

Batteries that are to be Regenerated) before Reclamation

§266.80(b)(2)(i) Permitted TSDFs Storing Spent Lead-Acid Batteries (other than Spent Batteries 

that are to be Regenerated) before Reclamation

§266.100(c)(1)(i)

Smelting, Melting, and Refining Furnaces Processing Hazardous Waste Solely 

for Metal Recovery

§266.100(f)(1) Smelting, Melting, and Refining Furnaces Processing Hazardous Waste for 

Recovery of Significant Amounts of Certain Precious Metals

§266.101(a) Generators of Hazardous Waste Burned in Boilers or Industrial Furnaces

§266.101(b) Transporters of Hazardous Waste Burned in Boilers or Industrial Furnaces

§266.101(c) Storers of Hazardous Waste Burned in Boilers or Industrial Furnaces

§266.102(a)(2)(ii) Permitted Boilers and Industrial Furnaces

§266.103(a)(4)(ii) Interim Status Boilers and Industrial Furnaces

§266.108(d) Burners of Small Quantities of Hazardous Waste in On-Site Boilers or 

Industrial Furnaces 

§270.1(b) Generators and Transporters of, and TSDFs Managing Newly Listed Hazardous 

Wastes

§273.54 Transporters of Universal Waste That is Released and Determined to be 

Hazardous Waste

§273.60(a) Universal Waste Destination Facilities
6

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

(c1) Intent to Comply with Subpart K and Recordkeeping of Agreements

40 CFR 262.203(a) provides that an eligible academic entity must notify the appropriate 

EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form 

(EPA Form 8700-12), that it is electing to be subject to the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity under the same EPA Identification Number. 

An eligible academic entity that is a conditionally exempt small quantity generator (CESQG) and 

does not have an EPA Identification Number must notify that it is electing to be subject to the 

requirements of Subpart K for all the laboratories owned by the eligible academic entity that are 

on-site. An eligible academic entity must submit a separate notification (Site ID Form) for each 

EPA Identification Number (or site, for CESQGs) that is electing to be subject to the 

requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill 

out the fields on the form that are specified at section 262.203(b)(1)-(11).

Section 262.203(c) provides that an eligible academic entity must keep a copy of the 

notification on file at the eligible academic entity for as long as its laboratories are subject to 

Subpart K.

Section 262.203(d) provides that a teaching hospital that is not owned by a college or 

university must keep a copy of its formal written affiliation agreement with a college or 

university on file at the teaching hospital for as long as its laboratories are subject to Subpart K.

Section 262.203(e) provides that a non-profit research institute that is not owned by a 

college or university must keep a copy of its formal written affiliation agreement with a college 

or university on file at the non-profit research institute for as long as its laboratories are subject 

to Subpart K.

(c2) Withdrawal from 40 CFR Part 262, Subpart K

40 CFR 262.204(a) provides that an eligible academic entity must notify the appropriate 

EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form 

(EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K 

for all the laboratories owned by the eligible academic entity under the same EPA Identification 

Number. An eligible academic entity that is a CESQG and does not have an EPA Identification 

Number must notify that it is withdrawing from the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity that are on-site. An eligible academic entity

must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, 

for CESQGs) that is withdrawing from the requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill 

out the fields on the form that are specified at section 262.204(b)(1)-(11).
7

Section 262.204(c) provides that an eligible academic entity must keep a copy of the 

withdrawal notice on file at the eligible academic entity for three years from the date of the 

notification.

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Large quantity handlers of universal waste must notify EPA of their universal waste 

activities and obtain an EPA Identification Number. These notification requirements are 

codified at 40 CFR Part 273, Subpart C. Specifically, section 273.32(a) requires large quantity

handlers of universal waste to have notified EPA of their universal waste handling activities and 

received an EPA Identification Number prior to meeting or exceeding the 5,000 kilogram storage 

limit, unless they already have notified EPA, as provided by section 273.32(a)(2) or 

273.32(a)(3). Section 273.32(b) prescribes the contents of the notification. Large quantity

handlers of universal waste have the option of using a letter in lieu of submitting EPA Form 

8700-12 (i.e., the Site ID Form).

(e) Notification of Used Oil Activity under 40 CFR Part 279

Used oil handlers must notify EPA of their used oil management activities and obtain an 

EPA Identification Number. These notification requirements are codified at 40 CFR Part 279. 

(Refer to Table 2.) Specifically, sections 279.42, 279.51, 279.62, and 279.73 require used oil 

transporters and transfer facilities, used oil processors and re-refiners, burners of 

off-specification used oil, and used oil fuel marketers, respectively, who have not previously 

complied with RCRA Section 3010 requirements (under 40 CFR Part 266, Subpart E) to comply

with these requirements and obtain an EPA Identification Number. These used oil handlers have 

the option of using a letter in lieu of submitting EPA Form 8700-12 (i.e., the Site ID Form).

Table 2

Used Oil Notification Requirements

40 CFR 

Regulatory 

Citation

Regulated Entity

§279.42 Used Oil Transporters and Transfer Facilities

§279.51 Used Oil Processors and Re-Refiners

§279.62 Burners of Off-Specification Used Oil

§279.73 Used Oil Fuel Marketers
8

(2) Hazardous Waste Report

RCRA Sections 3002 and 3004, as amended by the Hazardous and Solid Waste 

Amendments of 1984 (HSWA), require reporting to EPA or to authorized States at least every

two years. The Hazardous Waste Report [EPA Form 8700-13 Form A/B], or comparable State 

report, is used by generators and TSDFs to satisfy this requirement.

Hazardous waste generators and TSDFs report information on the quantities, type, and 

management method of generated hazardous wastes and hazardous wastes received from off-site. 

The data collected are used by EPA’s Office of Resource Conservation and Recovery (ORCR) to 

prepare a national report that is made available to Congress and the public, summarizing 

hazardous waste generation and management activities. The data also are used by EPA and the 

States for programmatic and regulatory needs. 
9

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

(1) Notification of Regulated Waste Activity

Section 3010 of Subtitle C of RCRA, as amended, requires any person who generates, 

transports, or recycles regulated wastes or who owns or operates a facility for the treatment, 

storage, or disposal of regulated wastes to notify EPA of their activities, including the location 

and general description of the activities and the regulated wastes handled. As required by 

statute, EPA promulgated regulations to implement these notification requirements at 40 CFR 

Parts 262, 263, 264, 265, 266, 270, 273, and 279. (See Section 1(b) above for a detailed listing 

of notification requirements by type of regulated waste and regulated entity). EPA needs this 

information to determine the universe of persons who generate, handle, and manage these 

regulated wastes; assign EPA Identification Numbers; and ensure that these regulated wastes are 

managed in a way that protects human health and the environment, as required by RCRA, as 

amended.

(2) Hazardous Waste Report

RCRA Sections 3002 and 3004 authorize the Hazardous Waste Report. Both sections 

require EPA to establish standards for recordkeeping and reporting of hazardous waste. Section 

3002 applies to hazardous waste generators and Section 3004 applies to hazardous waste TSDFs. 

The implementing regulations are found at 40 CFR parts 262.40(b) and (d); 262.41(a)(1)-(5), 

(a)(8), and (b); 264.75(a)-(e) and (j); 265.75(a)-(e) and (j); and 270.30(l)(9). This is mandatory

reporting by the respondents.

Section 3002(a)(6) requires submission of reports to EPA or the States at least every two 

years on the: (1) quantities and nature of hazardous wastes that have been generated during the 

year and (2) disposition of these hazardous wastes.

Section 3004(a) requires EPA to issue regulations establishing performance standards 

applicable to owners and operators of facilities for the treatment, storage, or disposal of 

hazardous waste that include reporting and maintaining records of all hazardous wastes treated, 

stored, or disposed and the manner in which such wastes were treated, stored, or disposed.

There are a number of uses of the Hazardous Waste Report data. EPA uses these data for 

planning and developing regulations. In addition, Hazardous Waste Report data allows the 

Agency to determine whether its regulations are having the desired effect on the generation and 

management of hazardous waste. For example, Hazardous Waste Report data provides 

information on whether wastes have shifted from one method of disposal to another. Some State 

uses of Hazardous Waste Report data include: support of planning, fee assessment, compliance 

monitoring, and enforcement. 
10

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Notification of Regulated Waste Activity

EPA enters notification information submitted by respondents into an EPA national data 

system and assigns EPA Identification Numbers. EPA uses the information primarily for 

tracking purposes, and secondarily for a variety of enforcement and inspection purposes. In 

addition, EPA uses this information to identify the universe of regulated waste generators, 

handlers, and managers and their specific regulated waste activities. Finally, EPA uses this 

information to ensure that regulated waste is managed properly, that statutory provisions are 

upheld, and that regulations are adhered to by facility owners or operators.

(2) Hazardous Waste Report

Implementation of the RCRA program requires the collection of information on the 

characteristics of the regulated community generally (e.g., number of generators and TSDFs), as 

well as the specific characteristics of individual sites (e.g., waste handling activities undertaken). 

This information is used for waste activity monitoring, compliance monitoring, technical 

assistance, program planning, waste minimization, and other program activities taken by EPA 

and the States. The information is also used by public interest groups (such as the Right-toKnow Network) and industry. 

The Hazardous Waste Report also provides information to States for tracking shipments 

of waste. Many States do not collect or track manifests, which provide, information on off-site 

shipments of hazardous waste; therefore, the Hazardous Waste Report serves as the only source 

of this information. 

EPA compiles and publishes the National Biennial RCRA Hazardous Waste Report based 

on the data for each odd number reporting year. The reports for 1991 to 2007 are available on 

the Internet at http://www.epa.gov/waste/inforesources/data/biennialreport/index.htm.

EPA and the States have many uses for Hazardous Waste Report information, including: 

 Describing the various source activities that generate hazardous waste and the 

generated waste types and quantities.

 Describing the management methods by which the waste is treated, disposed, or 

recycled and the quantities managed by each method.

 Providing information for analysis of trends in waste generation, waste treatment 

and disposal, recycling, and source reduction.

 Understanding how much waste a State receives from out of State or sends out of 

State.
11

 Estimating available capacity for treating, recycling, and disposing hazardous 

wastes.

Additionally, EPA utilizes the Hazardous Waste Report information for planning and 

developing regulations; regulation development depends on descriptions and quantities of 

generated hazardous waste and management methods used for treatment, recycling, and disposal. 

The information allows the Agency to determine whether regulations are having the desired 

effect on the generation and management of hazardous waste; for example, the report provides 

information on whether the treatment of wastes has shifted from one method to another. EPA 

also uses the information for conducting technical assistance, planning facility inspections, and 

carrying out regulatory enforcement. States use the information for many of the same purposes 

as EPA; other State uses include planning, setting waste minimization goals, assessing fees, 

monitoring compliance, and carrying out enforcement.

EPA and States receive requests for the information from many public and private 

organizations including government agencies, businesses, public interest groups, and interested 

citizens. Many requests come from businesses that supply chemicals, equipment, and services to 

hazardous waste generators and TSDFs.
12

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) NONDUPLICATION

The information collected under this ICR is not available from any source other than 

respondents. EPA’s ORCR is the only office within the Agency requiring the recordkeeping or 

reporting of this information. No other Federal agency or department collects this information. 

The RCRA site identification information is collected on one common form―the RCRA 

Subtitle C Site Identification Form―for the Notification of Regulated Waste Activity, the RCRA 

Hazardous Waste Part A Permit Application, and the Hazardous Waste Report. A respondent 

may submit a copy of a previously reported Site ID Form and note any changes; this verifies and 

updates the site identification information.

3(b) PUBLIC NOTICE

As indicated in Section 1(b), this is a request to renew two currently approved ICRs. 

EPA integrated these two ICRs into this current ICR, “Notification of Regulated Waste Activity

and 2009 Hazardous Waste Report,” EPA ICR Number 0976.14, to ensure consistency and 

minimize duplication in its burden assumptions and estimates. Information on public notices 

associated with each of the currently approved ICRs is presented below.

 “Notification of Regulated Waste Activity,” EPA ICR Number 0261.15. In 

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

notice in the Federal Register on March 13, 2009 (74 FR 10909). The public 

comment period extended through May 12, 2009. EPA received no comments on 

this ICR in response to the Federal Register notice. A second Federal Register

notice was issued on June 29, 2009 (74 FR 31028) announcing that the ICR had 

been forwarded to the Office of Management and Budget (OMB) for review and 

approval.

 “2007 Hazardous Waste Report,” EPA ICR Number 0976.13. In compliance 

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

Federal Register on May 15, 2009 (74 FR 22922). The public comment period 

extended through July 14, 2009. EPA received no comments on this ICR in 

response to the Federal Register notice.
13

3(c) CONSULTATIONS

Most of the data and assumptions in this ICR are based on EPA consultations with 

industry or data from the Resource Conservation and Recovery Act Information (RCRAInfo) 

system2. In developing this current ICR, EPA carefully reviewed all of the ICR’s data and 

assumptions and determined that a few should be strengthened based on additional consultations. 

Specifically, EPA conducted consultations on the ICR’s assumptions regarding respondents’ 

hourly and cost burden for completing and submitting the Site ID Form. 

Table 3 identifies the seven organizations contacted. All seven organizations indicated 

that they used a blank Site ID Form to make their initial and subsequent notifications. They also 

indicated that, individually, they spent between 5 minutes and 3 hours reading the form 

instructions, completing the form, and submitting it to EPA or the authorized State. Based on the 

information provided by these organizations, the average hourly burden for completing a blank 

Site ID Form for initial and subsequent notifications was estimated to be 1 hour. Of the seven 

organizations, four submitted their notification via certified mail, two submitted the completed 

form electronically, and one hand delivered the notification.

The feedback provided by the organizations identified in Table 3 is reflected in the 

burden assumptions of this ICR, as appropriate. Detailed information on EPA’s assumptions 

regarding these and other activities are fully discussed in Section 6 of this document. 

Table 3

Organizations EPA Contacted during the Development of this ICR (August 2009)

Organization Contact Name Phone Number

Avista Utilities Kettle Falls Pamela Kish

Environmental Coordinator (509) 495-4948

Weill Cornell Medical College Evan Alberts

Environmental Specialist (646) 962-5098

Johnson Oil USA, LLC Jimmy Johnson

President (229) 378-5100

Recycle San Diego Inc. Jeff Harding

President (858) 569-1807

Rexnord Industries, LLC Thomas Frost

Environmental Engineer (414) 937-4332

Siemens Energy, Inc. Amy Gray

Senior HSE Engineer (407) 736-5183

Southwest Petroleum Waste 

Management LLC

Lore Parker

Office Manager (623) 772-5992

 

2

 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA 

(i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and 

management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.
14

3(d) EFFECTS OF LESS FREQUENT COLLECTION

EPA has carefully considered the information collection burden imposed by the 

information collection requirements covered in this ICR. EPA is confident that those activities 

required of respondents are necessary, and to the extent possible, the Agency has attempted to 

minimize the burden imposed. A number of the required activities, for example, will be 

performed once (e.g., one-time notifications). EPA believes strongly that, if the minimum 

information collection requirements are not met, EPA will not be able to ensure that hazardous 

waste and hazardous secondary material is being properly managed and do not pose a threat to 

human health and the environment.

(1) Notification of Regulated Waste Activity

New hazardous waste generators, transporters, or TSDFs must submit EPA Form 

8700-12 (i.e., the Site ID Form) and obtain an EPA Identification Number prior to treating 

(including recycling), storing, transporting, offering for transport, or disposing of hazardous 

waste. Existing hazardous waste generators, transporters, or TSDFs are required to notify the 

Agency of their hazardous waste activity(ies) not later than 90 days after the promulgation or 

revision of regulations in 40 CFR Part 261 (identification and listing of hazardous wastes). 

Owners or operators of smelting, melting, and refining furnaces that process hazardous waste 

either solely for metals recovery or for recovery of economically significant amounts of certain 

precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities 

that qualify for the small quantity on-site burner exemption under section 266.108(d) must 

provide a written, one-time notification of their hazardous waste activities. Under Section 

273.32(a), large quantity handlers of universal waste must submit a written, one-time notification 

of universal waste management to the Regional Administrator and obtain an EPA Identification 

Number before meeting or exceeding the 5,000 kilogram storage limit, unless they already have 

notified EPA, as provided by section 273.32(a)(2) or 273.32(a)(3). Under sections 279.42, 

279.51, 279.62 and 279.73, used oil handlers who have not previously complied with the 

notification requirement (under 40 CFR Part 266, Subpart E) must submit a written, one-time 

notification of used oil management activities and obtain an EPA Identification Number. Any

reduction in the frequency of this information collection would prevent the Agency from meeting 

the statutory requirements of RCRA Section 3010.

(2) Hazardous Waste Report

For the Hazardous Waste Report, the two-year cycle is statutorily required. Although 

some States collect information on an annual or quarterly basis, EPA does not require more 

frequent data collection.
15

3(e) GENERAL GUIDELINES

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

OMB’s implementing regulations, applicable OMB guidance, and EPA’s ICR Handbook. In 

addition, this information collection complies with EPA’s Data Standards and Information 

Quality Guidelines.

3(f) CONFIDENTIALITY

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which defines EPA’s general 

policy on public disclosure of information, contain provisions for confidentiality. The Agency

does not anticipate that businesses will assert a claim of confidentiality covering all or part of the 

information submitted as part of their notifications. However, the Hazardous Waste Report 

requires businesses to provide information on various aspects of hazardous waste generation and 

management. Some businesses consider some of their hazardous waste information to be 

Confidential Business Information (CBI). A business may, if it desires, protect its Hazardous 

Waste Report information from public disclosure by asserting a claim of confidentiality covering 

all or part of its information. If a confidentiality claim were asserted for any of the information 

collections covered in this ICR, EPA will treat the information in accordance with the 

regulations cited above. EPA also will ensure that the information collection procedures comply 

with the Privacy Act of 1974 and the OMB Circular 108.

3(g) SENSITIVE QUESTIONS

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

requirements covered in this ICR.
16

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

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

associated with industries most likely affected by the information collection requirements 

covered in this ICR.

NAICS Code Description NAICS Code

Agriculture, Forestry, Fishing, and Hunting 11

Mining 21

Utilities 22

Construction 23

Manufacturing 31-33

Wholesale Trade 42

Retail Trade 44-45

Transportation and Warehousing 48-49

Information 51

Finance and Insurance 52

Real Estate, Rental, Leasing 53

Professional, Scientific, and Technical Services 54

Management of Companies and Enterprises 55

Administrative Support, Waste Management, and Remediation 56

Educational Services 61

Health Care and Social Assistance 62

Arts, Entertainment, Recreation 71

Accommodation and Food Services 72

Other Services 81

Public Administration 92

4(b) INFORMATION REQUESTED

(1) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

40 CFR 260.42(a) provides that hazardous secondary material generators, tolling 

contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous 

secondary materials which are excluded from regulation under section 261.2(a)(2)(ii) or section 

261.4(a)(23), (24), or (25) must send a notification prior to operating under the exclusion(s) and 

by March 1 of each even numbered year thereafter to the Regional Administrator using EPA 

Form 8700-12 that includes the specified information at section 260.42(a)(1)-(10). 
17

Section 260.42(b) provides that, if a hazardous secondary material generator, tolling 

contractor, toll manufacturer, reclaimer or intermediate facility has submitted a notification, but 

then subsequently stops managing hazardous secondary materials in accordance with the 

exclusion(s), the facility must notify the Regional Administrator within thirty (30) days using 

EPA Form 8700-12. For purposes of this section, a facility has stopped managing hazardous 

secondary materials if the facility no longer generates, manages and/or reclaims hazardous 

secondary materials under the exclusion(s) and does not expect to manage any amount of 

hazardous secondary materials for at least one year

(i) Data Items:

 Notification using EPA Form 8700-12, which includes the following information:

- The name, address, and EPA ID number (if applicable) of the facility; 

- The name and telephone number of a contact person; 

- The NAICS code of the facility;

- The exclusion under which the hazardous secondary materials will be 

managed (e.g., section 261.2(a)(2)(ii), section 261.4(a)(23), (24), and/or (25));

- For reclaimers and intermediate facilities managing hazardous secondary

materials in accordance with section 261.4(a)(24) or (25), whether the 

reclaimer or intermediate facility has financial assurance (not applicable for 

persons managing hazardous secondary materials generated and reclaimed 

under the control of the generator); 

- When the facility expects to begin managing the hazardous secondary

materials in accordance with the exclusion;

- A list of hazardous secondary materials that will be managed according to the 

exclusion (reported as the EPA hazardous waste numbers that would apply if 

the hazardous secondary materials were managed as hazardous wastes); 

- For each hazardous secondary material, whether the hazardous secondary

material, or any portion thereof, will be managed in a land-based unit;

- The quantity of each hazardous secondary material to be managed annually; 

and

- The certification (included in EPA Form 8700-12) signed and dated by an 

authorized representative of the facility.

(ii) Respondent Activities:

 Complete and submit EPA Form 8700-12 prior to operating under exclusion(s).

 Complete and submit EPA Form 8700-12 by March 1 of each even numbered 

year thereafter.

 Complete and submit EPA Form 8700-12 indicating that the hazardous secondary

materials are no longer managed in accordance with the exclusion, if applicable. 
18

(b) Notification of Hazardous Waste Activity under RCRA Section 3010

Facilities that generate, transport, recycle, treat, store, or dispose of hazardous waste as 

defined by 40 CFR Part 261 must notify EPA of their hazardous waste activities and obtain an 

EPA Identification Number. These notification requirements are codified at 40 CFR Parts 262, 

263, 264, 265, 266, 270, and 273. In order to comply with these requirements, facilities must 

complete and submit EPA Form 8700-12.

(i) Data Item:

 Notification using EPA Form 8700-12, which includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be 

contacted regarding information on the form;

- Ownership information, including the legal status of the current owner of the 

facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the initial notification or a subsequent 

notification;

- A description of the hazardous wastes handled at the facility; and

- A certification signed by the facility owner, operator, or authorized 

representative.

(ii) Respondent Activities:

 Complete and submit EPA Form 8700-12.

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

(c1) Intent to Comply with Subpart K and Recordkeeping of Agreements

40 CFR 262.203(a) provides that an eligible academic entity must notify the appropriate 

EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form 

(EPA Form 8700-12), that it is electing to be subject to the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity under the same EPA Identification Number. 

An eligible academic entity that is a CESQG and does not have an EPA Identification Number 

must notify that it is electing to be subject to the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity that are on-site. An eligible academic entity

must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, 

for CESQGs) that is electing to be subject to the requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill 

out the fields on the form that are specified at section 262.203(b)(1)-(11).
19

Section 262.203(c) provides that an eligible academic entity must keep a copy of the 

notification on file at the eligible academic entity while its laboratories are subject to Subpart K.

Section 262.203(d) provides that a teaching hospital that is not owned by a college or 

university must keep a copy of its formal written affiliation agreement with a college or 

university on file at the teaching hospital while its laboratories are subject to Subpart K.

Section 262.203(e) provides that a non-profit research institute that is not owned by a 

college or university must keep a copy of its formal written affiliation agreement with a college 

or university on file at the non-profit research institute while its laboratories are subject to 

Subpart K.

(i) Data Items:

 Notification, using EPA Form 8700-12, with the following fields filled out, at a 

minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

- North American Industry Classification System (NAICS) code(s) for the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

 A copy of the formal written affiliation agreement with a college or university, as 

specified under section 262.203(d). 

 A copy of the formal written affiliation agreement with a college or university, as 

specified under section 262.203(e). 

(ii) Respondent Activities:

 Eligible academic entities electing to be subject to the requirements of Subpart K 

must perform the following:

- Complete and submit EPA Form 8700-12; and

- Keep a copy of the notification on file.

 Teaching hospitals that are not owned by a college or university must:

- Keep a copy of their formal written affiliation agreement with college or 

university on file while its laboratories are subject to Subpart K. 

 Non-profit research institutes that are not owned by a college or university must:
20

- Keep a copy of the formal written affiliation agreement with a college or 

university on file at the non-profit research institute while its laboratories are 

subject to Subpart K.

(c2) Withdrawal from 40 CFR Part 262, Subpart K

40 CFR 262.204(a) provides that an eligible academic entity must notify the appropriate 

EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form 

(EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K 

for all the laboratories owned by the eligible academic entity under the same EPA Identification 

Number. An eligible academic entity that is a CESQG and does not have an EPA Identification 

Number must notify that it is withdrawing from the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity that are on-site. An eligible academic entity

must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, 

for CESQGs) that is withdrawing from the requirements of Subpart K.

When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill 

out the fields on the form that are specified at section 262.204(b)(1)-(11).

Section 262.204(c) provides that an eligible academic entity must keep a copy of the 

withdrawal notice on file at the eligible academic entity for three years from the date of the 

notification.

(i) Data Items:

 A Site ID Form with the following fields filled out, at a minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

- North American Industry Classification System (NAICS) code(s) for the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

(ii) Respondent Activities:

 Complete and submit EPA Form 8700-12.

 Keep a copy of the withdrawal notice on file.
21

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Large quantity handlers of universal waste must notify EPA of their universal waste 

activities and obtain an EPA Identification Number. These notification requirements are 

codified at 40 CFR Part 273, Subpart C. In order to comply with these requirements, large 

quantity handlers of universal waste must complete and submit a notification (EPA Form 

8700-12), or complete and submit a letter to EPA requesting an EPA Identification Number. 

(i) Data Items:

 Notification (EPA Form 8700-12) that includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be 

contacted regarding information on the form;

- Ownership information, including the legal status of the current owner of the 

facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the initial notification or a subsequent 

notification;

- A description of the hazardous wastes handled at the facility; and

- A certification signed by the facility owner, operator, or authorized 

representative.

Or

 A letter that includes:

- The universal waste handler’s name and mailing address;

- Name and business telephone number of the person who should be contacted 

regarding the universal waste management activities;

- Address or physical location of the universal waste management activities;

- A list of all of the types of universal waste managed by the handler; and

- A statement indicating that the handler is accumulating more than 5,000 

kilograms of universal waste at one time and the types of universal waste 

(e.g., batteries, pesticides, thermostats) the handler is accumulating above this 

quantity.

(ii) Respondent Activities:

 Complete and submit EPA Form 8700-12 or a letter requesting an EPA 

Identification Number.
22

(e) Notification of Used Oil Activity under 40 CFR Part 279

Used oil handlers must notify EPA of their used oil activities and obtain an EPA 

Identification Number. These notification requirements are codified at 40 CFR Part 279. In 

order to comply with these requirements, used oil handlers must complete and submit EPA Form 

8700-12, or complete and submit a letter to EPA requesting an EPA Identification Number. 

(i) Data Items:

 Notification using EPA Form 8700-12, which includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be 

contacted regarding information on the form;

- Ownership information, including the legal status of the current owner of the 

facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the initial notification or a subsequent 

notification;

- A description of the hazardous wastes handled at the facility; and

- A certification signed by the facility owner, operator, or authorized 

representative.

Or

 A letter that includes:

- Company name;

- Owner of company;

- Mailing address of company;

- Name and telephone number of company contact;

- Type of used oil management activity(ies);

- Location of facility(ies) (except for used oil fuel marketers); and 

- Name and telephone number of each contact at each transfer facility, if 

applicable (for used oil transporters and transfer facilities only).

(ii) Respondent Activities:

 Complete and submit EPA Form 8700-12 or a letter requesting an EPA 

Identification Number.
23

(2) Hazardous Waste Report

The Hazardous Waste Report consists of four forms: RCRA Subtitle Site Identification 

Form, Waste Generation and Management (Form GM), Waste Received from Off-Site (Form 

WR), and Off-Site Identification (Form OI; used only by States). Only Large Quantity

Generators and Treatment, Storage, and Disposal Facilities are required to complete the 

Hazardous Waste Report.

(i) Data Items:

 RCRA Subtitle C Site Identification Form. The Site ID Form must be submitted 

by all sites required to file the Hazardous Waste Report. This form collects 

information such as site name, EPA Identification Number, address, contact, and 

type of hazardous waste generation and management activities taking place at the 

site; it verifies their information, especially the site’s generator status as the date 

of submission of the report. It requires a certification signature for the submission 

of the report.

 Form GM - Waste Generation and Management. Form GM must be submitted 

by all respondents that generated or shipped large quantity generator amounts of 

RCRA hazardous waste during the reporting year. This form collects information 

on each generated waste, including a narrative waste description, a waste 

characterization (waste codes, source, and form), quantity generated, and the 

method of waste management (whether managed on-site or shipped off-site).

 Form WR - Waste Received From Off-Site. Form WR must be submitted by all 

sites that received RCRA hazardous waste from off-site during the reporting year. 

This form collects information on each waste received from off-site, including a 

narrative description of the waste, a brief waste characterization (e.g., waste 

codes), the EPA Identification Number of the off-site generator, the quantity of 

waste received, and the method of waste management.

 Form OI - Off-Site Identification. Form OI is not required by EPA; rather, it is 

provided as an option for States to collect the names and addresses of transporters, 

generators that ship waste, and receivers of waste reported on GM and WR Forms

where only the EPA Identification Number is listed.

(ii) Respondent Activities:

 Read the Hazardous Waste Report instructions.

 Gather information and complete Site ID Form.

 Gather information and complete Form GM.

 Gather information and complete Form WR.
24

 Gather information and complete Form OI if required by the State (State-optional 

form, not a Federal form).

 Submit the report to the State (or EPA Regional Office for some States and 

Territories).

 Maintain a copy of each form for three years.
25

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Notification of Regulated Waste Activity

Agency activities are the same for all of the notification requirements covered in this 

ICR. These activities include:

 For initial notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA 

Identification Number, as specified.

- Entering information into the EPA national data system.

- Generating an EPA Identification Number and sending the EPA Identification 

Number to the facility.

 For subsequent notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA 

Identification Number, as specified.

- Entering information into the EPA national data system.

(2) Hazardous Waste Report

As with most of the RCRA program, the Hazardous Waste Report data collection process 

is delegated to the States. Briefly, the process is as follows.

States (or EPA Regions where the Region implements the RCRA hazardous waste 

program for a State) provide respondents with either the Federal form or a State equivalent, 

collect the responses, contact non-respondents, enter the data (or load files if the State employs 

electronic methods for preparation and submittal of reports by regulated entities) into a database 

using off-the-shelf software packages which have been developed to support the collection of 

Hazardous Waste Report data, assure data quality, and forward the data to EPA.

States have discretion on the methods used to identify entities to whom they distribute 

forms and the subsequent tracking of reports received. Most States generate mailing lists based 

on previous report submittals, augmented by recent notifications of regulated activity. Many 

States levy fees based on the nature and extent of regulated activity identified in the report. EPA 

makes all reported data (except any that may be claimed as CBI) available to the public on the 

Internet. This provides further incentive for sites (and also for States and EPA) to ensure the 

information is complete and accurate because the public regularly accesses this information.

The Regions support States in data gathering and data quality assessment. Regions may

also provide technical support to States for the transfer of their files to EPA for incorporation 

into the national database. All files are submitted to the Agency through EPA’s Central Data 

Exchange.
26

EPA Headquarters produces and distributes the Federal forms and related guidance, 

defines the data and file format for data, establishes the schedule for submitting data, manages 

the incorporation of State data into the national database, coordinates national data quality

review, maintains the national database, and prepares a national report listing major facts about 

the national picture of hazardous waste generation and management for the reporting year.

In practice, this distribution of activities does not always follow this path. In some cases, 

the Region performs all of the State roles. In others, the Region provides direct processing 

support for some, but not all, of the collection activities. In still other cases, the Regions provide 

additional resources to the States.

Agency activities for the Hazardous Waste Report include the following:

 Develop Hazardous Waste Report forms and instructions. Print paper and CD 

copies.

 Distribute Hazardous Waste Report forms and instructions. EPA Headquarters 

distributes the form and instruction booklets to the States and Regions. States (or 

Regions) prepare mailing lists, mail forms and instructions, record receipt of 

completed forms, and contact sites that fail to respond within the specified time 

period. Some States may pre-populate Site ID Forms prior to distribution to 

reduce the effort needed by respondents as well as to ensure accuracy.

 Develop computer capabilities required to compile national data. EPA 

Headquarters develops the computer capabilities required to load data into the 

national database, the reports which support data quality assessment and other 

programmatic use of the data, and preparation of the national report.

 Assist respondents. States, Regions, and Headquarters provide assistance to 

respondents. States are, however, the first point of contact for answering 

respondent questions and assistance.

 Key entry of report submissions. States or EPA Regions, and the regulated 

entities, key enter or electronically load the data into a database they select and 

maintain. The data entry function was privatized for the 1999 Hazardous Waste 

Report process. Many States, Regions, and the regulated community use one of 

the private vendor’s software packages for data entry and recordkeeping. Some 

reports are entered directly on State or vendor hosted Internet sites and some are 

submitted on diskettes.
27

 Perform quality assurance. States, Regions, and Headquarters all perform data 

quality assurance. This includes: follow-up to non-respondents, detection and 

correction of unacceptable responses (e.g., in cases where the respondent 

misunderstood the instructions); verification of exceptional responses (e.g., data 

reported by a respondent that differ significantly from data reported by the rest of 

the respondent universe) and identification of significant response changes 

between reporting years. The national software supports these activities with a 

variety of data editing functions.

Once reports are received, the QA/QC procedures include a hierarchy of 

assessments. First, system procedures ensure the data has fundamental internal 

consistency (e.g., required data fields are populated and the values are of the 

correct data type and within allowed ranges).

Second, the information content of the data for individual sites is evaluated to 

identify any potential over or under reporting (exception reports support 

identification of extremes and significant variance from one cycle to another).

Third, assessment reports support evaluation of intra-State and inter-State 

shipments of wastes to identify potential discrepancies between reports submitted 

by generators and the TSDF’s who were identified by the generator as receivers 

of the waste.

Based on the assessments, States identify cases where accuracy may be 

questionable. For those cases, they generally contact the site to review the 

information received; and site respondent confirms that the data are correct or that 

the site intends to submit an amended report to correct discrepancies. 

 Prepare the national report. EPA will prepare The National Biennial RCRA 

Hazardous Waste Report that will be made available to the Congress and the 

public.

 Store the data. The Hazardous Waste Reports will be stored by the States or 

Regions for three years and an electronic database may be maintained by each 

State or Region. The national database is maintained by EPA Headquarters in 

RCRAInfo.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

In collecting and analyzing the information associated with this ICR, EPA and authorized 

States may use a telephone system, personal computers, and applicable database software. They

will ensure the accuracy and completeness of collected information by reviewing the submittals. 

They will keep records of this information in file cabinets and/or computer systems.
28

5(c) SMALL ENTITY FLEXIBILITY

(1) Notification of Regulated Waste Activity

Some respondents will be individuals or small organizations. However, EPA believes 

that the information to be collected is the minimum amount necessary to fulfill the statutory

requirements of RCRA.

(2) Hazardous Waste Report

EPA uses the quantity of waste generated per month to determine the extent to which a 

firm should be regulated. EPA categorizes generators of less than 1,000 kilograms of non-acute 

hazardous waste per month as small quantity generators (SQGs) and relieves them of specific 

requirements.

SQGs are not required to file the Hazardous Waste Report. A SQG who is sent the 

Hazardous Waste Report booklet due to a change in generator status or error need not respond. 

They must return a completed RCRA Subtitle C Site Identification Form to update their 

generator status to ensure they are not subject to follow-up contact for biennial reporting.

5(d) COLLECTION SCHEDULE

(1) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

A claimant must prepare and submit a notification to EPA prior to operating under the 

exclusion(s). In addition, the claimant must update and submit notification to EPA by March 1 

of each even numbered year thereafter. A claimant that submitted a notification but then 

subsequently stops managing hazardous secondary materials in accordance with the exclusion(s) 

must submit notification to EPA within 30 days.

(b) Notification of Hazardous Waste Activity under RCRA Section 3010

Under sections 262.12, 263.11, 264.11 and 265.11, all new hazardous waste generators, 

transporters, and TSDFs must notify EPA of their hazardous waste activities and obtain an EPA 

Identification Number before treating, storing, transporting, offering for transport, or disposing 

of hazardous waste. Under section 270.1(b), these hazardous waste generators, transporters, and 

TSDFs, are also subject to newly promulgated or revised regulations at 40 CFR Part 261 

(identification and listing of hazardous wastes) and must notify EPA of new or revised hazardous 

waste activities no later than 90 days after promulgation or revision. In addition, other 

generators; transporters; recyclers; and treatment, storage and disposal facilities that are subject 

to notification requirements under sections 266.21, 266.22, 266.23, 266.70(b)(1), 266.80(b)(1)(i), 

266.80(b)(2)(i), 266.101(a), 266.101(b), 266.101(c), 266.102(a)(2)(ii), 266.103(a)(4)(ii), and 

273.60(a) must notify EPA of their hazardous waste activities within the same time frame. 

Under section 273.54, universal waste transporters who determine that any material resulting 
29

from a release of universal waste is a hazardous waste are subject to 40 CFR Part 262. As a 

result, these transporters may also be subject to, under these circumstances, the section 262.12 

notification requirements and procedures. As such, these transporters must, at that time, notify

EPA of their hazardous waste activities and obtain an EPA Identification Number before 

treating, storing, transporting, offering for transport, or disposing of hazardous waste. Finally, 

owners or operators of smelting, melting, and refining furnaces that process hazardous waste 

either solely for metals recovery or for recovery of economically significant amounts of certain 

precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities 

that qualify for the small quantity on-site burner exemption under section 266.108(d) must 

provide a written, one-time notification of their hazardous waste activities.

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

(c1) Intent to Comply with Subpart K and Recordkeeping of Agreements

Under 40 CFR 262.203(a), an eligible academic entity must notify the appropriate EPA 

Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA 

Form 8700-12), that it is electing to be subject to the requirements of Subpart K for all the 

laboratories owned by the eligible academic entity under the same EPA Identification Number. 

An eligible academic entity that is a CESQG and does not have an EPA Identification Number 

must notify for all the laboratories owned by the eligible academic entity that are on-site. An 

eligible academic entity must submit a separate notification (Site ID Form) for each EPA 

Identification Number (or site, for CESQGs) that is electing to be subject to the requirements of 

Subpart K. This is a one-time notification.

Section 262.203(c) provides that an eligible academic entity must keep a copy of the 

notification on file at the eligible academic entity while its laboratories are subject to Subpart K. 

Section 262.203(d) provides that a teaching hospital that is not owned by a college or 

university must keep a copy of its formal written affiliation agreement with a college or 

university on file at the teaching hospital while its laboratories are subject to Subpart K. 

Section 262.203(e) provides that a non-profit research institute that is not owned by a 

college or university must keep a copy of the formal written affiliation agreement with a college 

or university on file at the non-profit research institute while its laboratories are subject to 

Subpart K.

(c2) Withdrawal from 40 CFR Part 262, Subpart K

Under 40 CFR 262.204(a), an eligible academic entity must notify the appropriate EPA 

Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA 

Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all 

the laboratories owned by the eligible academic entity under the same EPA Identification 

Number. An eligible academic entity that is a CESQG and does not have an EPA Identification 

Number must notify for all the laboratories owned by the eligible academic entity that are onsite. An eligible academic entity must submit a separate notification (Site ID Form) for each 
30

EPA Identification Number (or site, for CESQGs) that is withdrawing from the requirements of 

Subpart K. This is a one-time notification.

Section 262.204(c) provides that an eligible academic entity must keep a copy of the 

withdrawal notice on file at the eligible academic entity for three years from the date of the 

notification.

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Under Section 273.32(a)(1), large quantity handlers of universal waste must submit a 

written, one-time notification of universal waste activity to the Regional Administrator and 

obtain an EPA Identification Number before meeting or exceeding the 5,000 kilogram storage 

limit, unless they already have notified EPA, as provided by section 273.32(a)(2) or 

273.32(a)(3).

(e) Notification of Used Oil Activity under 40 CFR Part 279

Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who were not 

previously required to comply with the notification requirements (under 40 CFR Part 266, 

Subpart E) must submit a written, one-time notification of their used oil management activities 

and obtain an EPA Identification Number.

(2) Hazardous Waste Report

EPA’s 2009 Hazardous Waste Report national implementation schedule is outlined in 

Table 4.
31

Table 4

2009 Hazardous Waste Report National Implementation Schedule

Activity Completion Date

Implementers begin loading 2009 Hazardous Waste Report data into RCRAInfo

Biennial Report National Data Quality Reports & National Exhibit Reports 

available for use in performing additional DQ checks

April 5, 2010

DEADLINE for Implementers to load Complete Data into RCRAInfo for HQ’s 

national DQ

Review work and publication of the Preliminary 2009 National Biennial Report

June 7, 2010

HQ Publishes Preliminary 2009 National Biennial Report (Post in RCRAInfo) July 6, 2010

HQ performs a national DQ review of 2009 Hazardous Waste Report data as 

each State’s data is loaded into RCRAInfo and provides results to States and 

Regions for use in completing FINAL DQ corrections

September, 6, 2010

DEADLINE for Implementers to load FINAL Data into RCRAInfo for 

development of Final 2009 National Biennial Report October 4, 2010

HQ Publishes Final 2009 National Biennial Report (Post on Internet ONLY) December 13, 2010

Source: EPA, 2009 Biennial Report National Implementation Schedule. Available online at: 

http://www.epa.gov/waste/inforesources/data/biennialreport/index.htm, last accessed on August 14, 2009.
32

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibits 1 and 2 provide estimates of the respondent hourly burden associated with the 

information collection requirements covered in this ICR. The exhibits include burden hours 

(total and by labor type) per respondent, as well as the overall burden hours for all respondents. 

The majority of the hour estimates in Exhibits 1 and 2 are based on industry consultations that 

EPA performed in renewing this ICR.

In the following paragraphs, EPA describes the methodologies used to estimate the 

hourly burden associated with the information collections covered in this ICR.

(1) Notification of Regulated Waste Activity

EPA contacted seven industry representatives to ascertain their burden for completing the 

Site ID Form for initial and subsequent notifications. All of them indicated that they complete a 

blank Site ID Form for each notification and their burdens ranged from 5 minutes to 3 hours per 

submittal. Refer to Section 3(c) of this document for additional information on the data 

collected.

None of the industry representatives used the Site ID Form’s optional procedures to use a 

previously submitted Site ID Form to make a subsequent notification. Specifically, the Site ID 

Form’s instructions indicate that, after a facility has submitted the form once, the State may

allow the facility to attach a copy of the facility’s most recently submitted form. If so, the 

facility must circle item numbers for which any information has changed. Then, circle the item 

numbers in the new form, enter the new information, and provide the required signatures in 

Item 14-Certification.

Although none of the industry representatives used a previously submitted form to notify, 

the Agency believes that a number of respondents do so. This is based on the Agency’s 

knowledge of common industry practices. For purposes of this ICR, EPA has estimated the 

percentage of respondents that use a previously submitted form to make a subsequent 

notification and their burden for doing so. These estimates, along with the consultation data 

collected, are discussed in the paragraphs below.

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

For purposes of this ICR, EPA anticipates that all of the facilities electing to operate 

under the hazardous secondary material exclusion under 40 CFR 260.42 during the two-year 

period covered by this ICR have already submitted the Site ID Form at least once. Of these 

facilities, EPA estimates that 50 percent will complete a blank Site ID Form to notify EPA or the 

State prior to operating under the exclusion and by March 1 of each even numbered year. EPA 

estimates that the other 50 percent will use their most recently submitted Site ID Form in 

complying with these notification requirements. 
33

EPA estimates the burden for completing a blank Site ID Form under section 260.42 to 

be 1.5 hours per respondent and the burden for using a previously submitted form to be 

50 minutes (0.83 hour) per respondent. EPA notes that section 260.42 imposes several new, 

substantive requirements specific to the exclusions that must be completed (e.g., quantity of 

secondary material to be managed annually) in addition to the rest of the Site ID Form.

For the notification submitted indicating that the hazardous secondary materials are no 

longer managed in accordance to the exclusion, EPA estimates the average hourly burden for 

completing the Site ID Form in its entirety (i.e., a blank form) to be 1 hour per respondent. EPA 

also estimates the average hourly burden for updating the most recently submitted Site ID Form 

to be 20 minutes (0.33 hour) per respondent. 

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA 

derived the weighted averages using the calculations in Table 5 below. EPA multiplied the 

percentage of facilities completing the Site ID Form on its entirety by the average burden for 

completing the blank form. EPA also multiplied the percentage of facilities that will use the 

most recently submitted Site ID Form by the average burden for updating the information 

contained in the form. Then, EPA added up these two products to derive an overall weightedaverage burden. 

Table 5

Assumptions and Weighted-Average Equation

Used in Estimating Burden to Complete the Notification of

Hazardous Secondary Material Activity under 40 CFR 260.42

Assumptions Weighted-Average Equation

Notification Prior to Operating under Exclusion AND

Notification Submitted by March 1 of Each Even Numbered Year Thereafter

1.5 hours to complete blank form;

50 percent of the facilities (1.5 hrs x 0.50) + (0.83 hr x 0.50)

= 1.17 hours 0.83 hour to update most recently submitted form;

50 percent of the facilities

Notification Indicating that Hazardous Secondary Materials are no Longer Managed in 

Accordance to the Exclusion

1 hour to complete blank form;

50 percent of the facilities (1 hr x 0.50) +(0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form;

50 percent of the facilities
34

(b) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

For purposes of this ICR, EPA anticipates that all of the facilities opting into Subpart K 

during the two-year period covered by this ICR have already submitted the Site ID Form at least 

once. Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form in 

opting into Subpart K and in withdrawing from Subpart K. EPA estimates that the other 50 

percent will use their most recently submitted Site ID Form in complying with these notification 

requirements. 

EPA estimates the burden for completing a blank Site ID Form under Subpart K to be 

1 hour per respondent and the burden for using a previously submitted form to be 20 minutes 

(0.33 hour) per respondent. 

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA 

derived the weighted averages using the calculations in Table 6 below. EPA multiplied the 

percentage of facilities completing the Site ID Form on its entirety by the average burden for 

completing the blank form. EPA also multiplied the percentage of facilities that will use the 

most recently submitted Site ID Form by the average burden for updating the information 

contained in the form. Then, EPA added up these two products to derive an overall weightedaverage burden. 

Table 6

Assumptions and Weighted-Average Equation

Used in Estimating Burden to Complete the Notification of

Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Assumptions Weighted-Average Equation

1 hour to complete blank form;

50 percent of the facilities (1 hr x 0.50) + (0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form;

50 percent of the facilities
35

(c) Other Notifications Covered in this ICR

For purposes of this ICR, EPA anticipates that 50 percent of the facilities submitting 

initial notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 

279 will complete a blank Site ID Form. EPA estimates that the other 50 percent will use their 

most recently submitted Site ID Form in complying with these notification requirements. 

EPA estimates the burden for completing a blank Site ID Form to be 1 hour per 

respondent and the burden for using a previously submitted form to be 20 minutes (0.33 hour) 

per respondent. 

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA 

derived the weighted averages using the calculations in Table 7 below. EPA multiplied the 

percentage of facilities completing the Site ID Form on its entirety by the average burden for 

completing the blank form. EPA also multiplied the percentage of facilities that will use the 

most recently submitted Site ID Form by the average burden for updating the information 

contained in the form. Then, EPA added up these two products to derive an overall weightedaverage burden. 

Table 7

Assumptions and Weighted-Average Equation Used in

Estimating Burden to Complete Other Notifications Covered in this ICR

Assumptions Weighted-Average Equation

1 hour to complete blank form;

50 percent of the facilities

(1 hr x 0.50) + (0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form;

50 percent of the facilities

(2) Hazardous Waste Report

(a) Methodology for Accounting for Site Identification Forms Pre-Populated by 

States

In estimating the hourly burden for preparing the Site ID Form of the Hazardous Waste 

Report, EPA assumes that 65 percent of all the Site ID Forms will be pre-populated by States 

prior to distribution to respondents or by vendor software used by the respondents. EPA also 

assumes that the remaining 35 percent of all the Site ID Forms will be completed manually. 

EPA estimates the burden for updating a pre-populated Site ID Form to be 20 minutes 

(0.33 hour) per respondent and the burden for completing a Site ID Form in its entirety (i.e., 

completing a blank form manually) to be 1 hour per respondent.
36

The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA 

derived the weighted averages using the calculations in Table 8 below. EPA multiplied the 

percentage of pre-populated Site ID Forms by the average burden for updating the information 

contained in the form. EPA also multiplied the percentage of blank Site ID Forms by the 

average burden for completing the blank form. Then, EPA added up these two products to 

derive an overall weighted-average burden. 

Table 8

Assumptions and Weighted-Average Equation Used in Estimating Burden to

Complete the Site Identification Form of the Hazardous Waste Report

Assumptions Weighted-Average Equation

0.33 hours to complete pre-populated form; 

65 percent of the forms are pre-populated (0.33 hrs x 0.65) + (1 hr x 0.35)

= 0.56 hours 1 hour to complete blank form;

35 percent of the forms are blank

(b) Methodology for Accounting for Form GM and Form WR Electronic 

Reporting

During consultations conducted during the development of previous versions of the

Hazardous Waste Report ICR, State and facility representatives indicated that GM and WR 

Forms often can be completed from databases that track manifests or other information for 

billing purposes. Based on these consultations, EPA estimated the hourly burden for the GM and 

WR Forms submitted electronically to be significantly less than for forms submitted on paper.

To estimate the percentage of facilities that submit GM and WR Forms electronically, 

EPA used information gained from consultations and 2007 Hazardous Waste Report data. For 

GM Form submissions, EPA estimated that, based on consultations and best professional 

judgment, facilities submitting five (5) or more GM Forms for the Hazardous Waste Report are 

likely to do so electronically. Using 2007 Hazardous Waste Report data3, EPA identified sites 

submitting GM Forms, counted their GM Forms submitted, and calculated the percentage that 

their GM Forms represented of the total number of GM Forms. Based on this methodology, 

EPA estimates that 48 percent of GM Forms are submitted electronically, while the remaining 52 

percent are sent manually.

 

3

2007 Hazardous Waste Report (i.e., 2007 Biennial Report) data used in this analysis are current as of 

September 6, 2009.
37

For WR Forms, EPA believes that TSDFs receiving large numbers of off-site shipments 

are more likely to have systems in place to track waste stream data, and as a consequence, to 

submit Hazardous Waste Report data electronically. Using 2007 Hazardous Waste Report data4, 

EPA reviewed the list of WR Forms reported to the Hazardous Waste Report by facility and, 

based on its own professional judgment and consultations, estimates that 100 percent of WR 

Forms are submitted electronically. 

To estimate the average burden per respondent in preparing a GM or WR Form, EPA 

used the weighted-average calculations in Table 9. EPA multiplied the percentage of both forms 

submitted electronically by their respective burden for electronic reporting and the percentage of 

both forms submitted manually by their respective burden for manual reporting. Then, EPA 

added the two products for each form, respectively, to calculate an overall weighted-average 

burden for both forms. These weighted-average burden estimates are used in Exhibit 2 to 

estimate total respondent burden for the GM and WR Forms.

Table 9

Assumptions and Weighted-Average Equations Used in Estimating Burden to

Complete Form GM and Form WR of the Hazardous Waste Report

Activity Assumptions Weighted-Average Equation

Complete

Form GM

0.16 hour to complete electronically; 

48% of the forms are completed 

electronically

1.04 hours to complete manually; 

52% of the forms are completed manually

(0.16 hr x 0.48) + (1.04 hrs x 0.52)

= 0.61 hour

Complete

Form WR

0.16 hour to complete electronically; 

100% of the forms are completed 

electronically

0.16 hr x 1= 0.16 hour

 

4

 2007 Hazardous Waste Report (i.e., 2007 Biennial Report) data used in this analysis are current as of 

September 6, 2009.
38

6(b) ESTIMATING RESPONDENT COSTS

Exhibits 1 and 2 provide estimates of the annual respondent costs associated with the 

information collection requirements covered in this ICR. These costs are based on the cost of 

labor, capital, and operation and maintenance (O&M). 

(1) Labor Costs

EPA estimates an average hourly respondent labor cost (including fringe and overhead) 

of $118.68 for legal staff, $70.15 for managerial staff, $52.26 for technical staff, and $31.44 for 

clerical staff. These respondent labor costs were obtained from a previously approved ICR 

(i.e., “Revisions to the RCRA Definition of Solid Waste,” EPA ICR Number 2310.01, dated 

October 28, 2008), and updated to 2009 levels using Employment Cost Indexes developed by the 

U.S. Bureau of Labor Statistics.5

Using the total burden hours discussed in Section 6(a) and the hourly labor costs outlined 

in this section, Exhibits 1 and 2 illustrate the labor costs associated with the information 

collection requirements covered in this ICR.

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. EPA does not anticipate that 

respondents will incur capital costs in carrying out the information collection requirements 

covered in this ICR.

(3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement 

incurred continually over the life of the ICR. For this ICR, O&M costs include mailing costs. In 

particular, EPA estimates that respondents will incur a cost of $3.25 to mail a one-ounce package 

by certified mail ($0.44 for postage, $2.80 for the certified-mail fee, and $0.01 for standard-size 

envelope). These O&M costs are shown in Exhibits 1 and 2 for all applicable respondent 

activities.

 

5

 Bureau of Labor Statistics, “Table 4. Employment Cost Index for total compensation, for civilian 

workers, by occupational group and industry,” Employment Cost Index-June 2009, June 31, 2009. Available online 

at: http://www.bls.gov/news.release/pdf/eci.pdf, last accessed on August 14, 2009. Civilian Workers, All Workers, 

June 2008=108.3 and June 2009=110.3.
39

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN

(1) Federal Agency

EPA estimates the Federal agency hour and cost burden associated with the notification 

and Hazardous Waste Report information collection requirements in Exhibits 3 and 4, 

respectively. As shown in the exhibits, EPA estimates an average hourly labor cost of $85.28 for 

legal staff (GS15, Step 5), $75.25 for managerial staff (GS-15, Step 1), $54.14 for technical staff 

(GS-13, Step 1), and $23.09 for clerical staff (GS-06, Step 1). To derive these hourly estimates, 

EPA referred to the General Schedule (GS) Salary Table 2009. This publication summarizes the 

unloaded (base) hourly rate for various labor categories in the Federal Government. EPA then 

applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded 

hourly rates.

(2) State Agency

EPA estimates the State agency hour and cost burden associated with the Hazardous 

Waste Report information collection requirements in Exhibit 5. As shown in the exhibit, EPA 

estimates an average hourly State agency labor cost (including fringe and overhead) of $57.43 

for legal staff, $53.91 for managerial staff, $32.26 for technical staff, and $20.58 for clerical 

staff. These State agency labor costs were obtained from a previously approved ICR (i.e., “2007 

Hazardous Waste Report,” EPA ICR Number 0976.13, dated September 18, 2007), and updated 

to 2009 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor 

Statistics.6

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND 

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then 

estimates the annual burden to respondents under the information collection requirements 

covered in this ICR. 

(1) Respondent Universe

(a) Notification of Regulated Waste Activity

(a1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

In estimating the number of respondents subject to the notification of hazardous 

secondary material activity under 40 CFR 260.42, EPA referred to the ICR developed for the 

recently promulgated rule: “Revisions to the RCRA Definition of Solid Waste,” EPA ICR 

 

6

 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation1, for State and 

local government workers, by occupational group and industry,” Employment Cost Index-June 2009, June 31, 2009. 

Available online at: http://www.bls.gov/news.release/pdf/eci.pdf, last accessed on August 14, 2009. State and 

Local Government Workers, All Workers, June 2008=109.4 and June 2009=112.9.
40

Number 2310.01. These estimates are presented in Table 10 and used to estimate the total 

respondent burden and costs per information collection activity shown in Exhibit 1 of this ICR.

Table 10

Annual Number of Respondents Subject to the

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42 a

Respondent Universe

Number of Respondents

State and Local 

Government Private Sector Total

Total number of facilities submitting notification prior to 

operating under exclusion 111 1,601 1,712

Number of small quantity generators (SQGs) submitting 

notification by March 1 of each even numbered year 

thereafter

15 216 231

a

 Based on information contained in currently approved EPA ICR Number 2310.01, “Revisions to the RCRA Definition of Solid 

Waste,” dated October 28, 2008.

(a2) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

In estimating the number of respondents subject to the notification of hazardous waste 

activity under 40 CFR Part 262, Subpart K, EPA referred to the ICR developed for the recently

promulgated rule: “Generator Standards Applicable to Laboratories Owned by Eligible 

Academic Entities,” EPA ICR Number 2317.01. These estimates are presented in Table 11 and 

used to estimate the total respondent burden and costs per information collection activity shown 

in Exhibit 1 of this ICR.

Table 11

Annual Number of Respondents Subject to the

Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K a

Respondent Universe

Number of Respondents

State and Local 

Government Private Sector Total

Number of eligible academic entities submitting notification 

of intent to comply with Subpart K and recordkeeping of 

agreements

11 26 37

Number of teaching hospitals not owned by a college or 

university opting into Subpart K 1 1 2

Number of non-profit research institutes not owned by a 

college or university opting into Subpart K 0 1 1

Number of eligible academic entities submitting notification 

of withdrawal from 40 CFR Part 262, Subpart K 0 0 0

a

 Based on information contained in currently approved EPA ICR Number 2317.01, “Generator Standards Applicable to 

Laboratories Owned by Eligible Academic Entities,” dated July 14, 2008.
41

(a3) Other Notifications Covered in this ICR

In estimating the number of respondents subject to the notification requirements covered 

under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279, EPA referred to 

the Resource Conservation and Recovery Act Information (RCRAInfo) system7. EPA estimated 

the annual number of initial and subsequent notifications tracked by RCRAInfo. EPA then 

averaged the number of notifications submitted in 2007 and 2008. These estimates are presented 

in Table 12 and used to estimate the total respondent burden and costs per information collection 

activity shown in Exhibit 1 of this ICR.

 

7

 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA 

(i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and 

management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.
42

Table 12

Annual Number of Respondents Subject to the Notification Requirements

under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 a

Respondent 

Universe

Year 2007 Year 2008 Average of Years 2007 and 2008

State and 

Local 

Government b

Private 

Sector c Total

State and 

Local 

Government b

Private 

Sector c Total

State and 

Local 

Government b

Private 

Sector c Total

Notification of Hazardous Waste Activity under RCRA Section 3010

Number of facilities 

submitting initial 

notification

1,619 8,806 10,425 2,156 7,930 10,086 1,888 8,368 10,256

Number of facilities 

submitting subsequent 

notification

1,535 32,585 34,120 1,739 35,426 37,165 1,637 34,006 35,643

Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Number of facilities 

submitting initial 

notification

2 21 23 9 37 46 6 29 35

Number of facilities 

submitting subsequent 

notification

1 10 11 0 6 6 1 8 9

Notification of Used Oil Activity under 40 CFR Part 279

Number of facilities 

submitting initial 

notification

5 102 107 12 115 127 8 109 117

Number of facilities 

submitting subsequent 

notification

4 109 113 4 134 138 4 122 126

a

 Based on data from two RCRAInfo tables: (1) “Hhandler” and (2) “Howner_operator2.” Both tables contain data current as of July 10, 2009.

b

 Includes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in order to qualify as “State and local government,” the facility 

cannot be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Municipal government would qualify as a 

“Federal government” facility, not a “State and local government” facility.

c

 Includes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facility cannot be owned or operated by a Federal, State, or local 

government. For example, a facility owned by a State government and operated by a private entity would qualify as a “State and local government” facility, not as a “private” 

facility.
43

(b) Hazardous Waste Report

Based on 2007 Hazardous Waste Report data8, EPA estimates that the total number of 

respondents to the 2009 Hazardous Waste Report will be 16,483, which annualized over the twoyear report cycle equals 8,242 per year (i.e., 16,483/2). Table 13 presents information on the 

total number of forms associated with the 2009 Hazardous Waste Report. In estimating annual 

respondent burden and cost, EPA annualized these numbers over the two-year report cycle.

Table 13

Total Number of 2009 Hazardous Waste Report Forms

Hazardous Waste Report Form

Number of Forms a

State and 

Local 

Government

Private 

Sector Total

Site Identification (Site ID) Form 1,347 15,136 16,483

Form GM - Generation and Management 16,873 189,121 205,994

Form WR - Waste Received from Offsite 13,668 847,972 861,640

Total 31,888 1,052,229 1,084,117

a

 Based on 2007 Hazardous Waste Report (i.e., 2007 Biennial Report) data current as of September 6, 

2009.

The number of respondents and forms for each respondent activity is presented in 

Exhibit 2. These estimates assume that all forms are submitted in accordance with the 

Hazardous Waste Report instructions. Exhibit 2 also estimates the annual respondent burden and 

cost for the activities examined.

(2) Annual Respondent Burden

(a) Notification of Regulated Waste Activity (Exhibit 1)

(a1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

EPA estimates that, each year, 1,712 entities will notify EPA under section 260.42 prior 

to operating under the exclusion and be required to complete the information laid out at section 

260.42(a). This includes 1,579 hazardous secondary materials generators, tolling contractors and 

toll manufacturers; 80 intermediate facilities; and 53 reclaimers. 

In addition, entities must re-notify EPA using the Site ID Form by March 1 of each even 

numbered year thereafter. Note that the Hazardous Waste Report regulations already require the 

submittal of the Site ID Form by March 1 of each even numbered year by large quantity 

generators (40 CFR Part 262) and treatment, storage and disposal facilities (40 CFR Part 264 and 

 

8

 2007 Hazardous Waste Report (i.e., 2007 Biennial Report) data used in this analysis are current as of 

September 6, 2009.
44

265). Hence, this section of the ICR estimates burden for SQG re-notifications only. For 

purposes of this ICR, EPA estimates that a total of 462 SQGs will re-notify over the two-year 

period covered by this ICR. Because each of these entities will perform this re-notification 

activity once during the two-period covered by this ICR, EPA has annualized the number of 

entities by dividing them by two (i.e., 462/2 = 231 SQGs annually).9

EPA estimates that, each year, five percent of entities (i.e., 1,712 x 0.05 = 86) will 

re-notify because they stopped operating under the exclusion.

(a2) Notification of Hazardous Waste Activity under RCRA Section 3010

EPA estimates that, each year, 10,256 facilities will submit an initial notification of 

hazardous waste activity under RCRA Section 3010. EPA also estimates that, each year, 35,643 

facilities will submit a subsequent notification associated with these requirements. 

(a3) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

An eligible academic entity must submit the Site ID Form to notify EPA or the 

authorized State that it is electing to be subject to Subpart K for all laboratories owned by the 

eligible academic entity under the same EPA Identification Number. An eligible academic entity

that is a CESQG and does not have an EPA Identification Number must notify for all 

laboratories that are owned or operated by the eligible academic entity that are on-site. EPA 

estimates that, each year, 37 forms will be completed, submitted, and retained.

Teaching hospitals opting into Subpart K must keep a copy of their formal written 

affiliation agreement with a college or university on file if they are not owned by a college or 

university. EPA estimates that, each year, two (2) sites will retain the agreements on file.

Non-profit research institutes not owned by a college or university opting into Subpart K 

must keep a copy of the formal written affiliation agreement with a college or university on file. 

EPA estimates that, each year, one (1) site will retain the agreement on file.

Withdrawal from 40 CFR Part 262, Subpart K

EPA does not expect any eligible academic entity to submit a withdrawal notification 

during the two-year period covered by this ICR.

 

9

 Even though these 462 SQGs are expected to re-notify once during the period covered by this ICR, EPA 

has annualized them over two years to estimate the average annual burden of the requirements. Note that this 

approach is taken with other one-time activities in this ICR, as applicable.
45

(a4) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

EPA estimates that, each year, 35 facilities will submit an initial notification of universal 

waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent (i.e., 35 x 0.75 = 

26) will use the Site ID Form and 25 percent (i.e., 35 x 0.25 = 9) will prepare and submit a letter 

requesting an EPA Identification Number. 

EPA also estimates that, each year, 9 facilities will submit a subsequent notification of 

universal waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent 

(i.e., 9 x 0.75 = 7) will use the Site ID Form and 25 percent (i.e., 9 x 0.25 = 2) will prepare and 

submit a letter requesting an EPA Identification Number. 

(a5) Notification of Used Oil Activity under 40 CFR Part 279

EPA estimates that, each year, 117 facilities will submit an initial notification of used oil 

activity under 40 CFR Part 279. Of these facilities, 75 percent (i.e., 117 x 0.75 = 88) will use the 

Site ID Form and 25 percent (i.e., 117 x 0.25 = 29) will prepare and submit a letter requesting an 

EPA Identification Number. 

EPA also estimates that, each year, 126 facilities will submit a subsequent notification of 

universal waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent 

(i.e., 126 x 0.75 = 95) will use the Site ID Form and 25 percent (i.e., 126 x 0.25 = 31) will 

prepare and submit a letter requesting an EPA Identification Number. 

(b) Hazardous Waste Report (Exhibit 2)

(b1) Gather Information and Complete Site Identification Form

EPA estimates that all 16,483 respondents will complete and submit a Site ID Form with 

the 2009 Hazardous Waste Report. Annualized over the two-year report cycle, this results in 

8,242 respondents preparing and submitting a Site ID Form each year. 

(b2) Gather Information and Complete Form GM

EPA estimates that respondents will submit a total of 205,994 GM Forms with the 2009 

Hazardous Waste Report. Annualized over the two-year report cycle, this results in 102,997 GM 

Forms each year.

(b3) Gather Information and Complete Form WR

EPA estimates that respondents will submit a total of 861,640 WR Forms with the 2009 

Hazardous Waste Report. Annualized over the two-year report cycle, this results in 430,820 WR 

Forms each year. 
46

Note that the number of WR Forms represents the number of blocks on Form WR that 

have been completed; the paper form actually contains three blocks of the same WR information 

(i.e., the same questions, repeated three times on the same page). 

(b4) Gather Information and Complete Form OI

Because this form is a State-optional form, EPA does not expect any facilities to submit 

Form OI and therefore does not calculate the burden for this form.

(b5) Submit the Biennial Report to State/Region

EPA expects each respondent, 8,242 facilities per year, to submit the report to the 

appropriate State or Region.

(b6) Maintain a Copy of Each Form 

EPA expects facilities to retain an estimated 542,059 (i.e., 8,242 Site ID Forms + 102,997 

GM Forms + 430,820 WR Forms) forms each year.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibit 6 summarizes the total annual respondent hour and cost burden associated with 

all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual 

respondent burden to be 206,305 hours and $10,598,875. The bottom line burden to respondents 

over two years is estimated to be 412,610 hours and $21,197,750.

(2) Agency Tally

(a) Federal Agency

Exhibit 7 summarizes the total annual Federal agency hour and cost burden associated 

with all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the 

annual Federal agency burden to be 126,245 hours and $6,477,984. The bottom line burden to 

the Federal agency over two years is estimated to be 252,490 hours and $12,955,968.

(a) State Agency

Exhibit 8 summarizes the total annual State agency hour and cost burden associated with 

all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual 

State agency burden to be 215,828 hours and $5,911,150. The bottom line burden to State 

agencies over two years is estimated to be 431,656 hours and $11,822,300.
47

6(f) REASONS FOR CHANGE IN BURDEN

(1) Notification of Regulated Waste Activity

The currently approved Notification ICR (EPA ICR Number 0261.15) covers the 

notification requirements under RCRA Section 3010 (i.e., for hazardous waste activities); 

40 CFR Part 273, Subpart C (i.e., for universal waste activities); and 40 CFR Part 279 (i.e., for 

used oil activities). The annual respondent burden estimate in the currently approved 

Notification ICR was 139,656 hours, with a total cost of $255,830 for capital/start-up and O&M. 

The annual respondent burden estimate for the same notification requirements covered in this 

current ICR is 36,525 hours, with a total cost of $156,819 capital/start-up and O&M. This 

represents a decrease of 103,131 hours and $99,011 in total cost for capital/start-up and O&M. 

This decrease in burden for respondents has occurred for two primary reasons. First, 

there was a decrease in the total number of notifications under RCRA Section 3010; 40 CFR Part 

273, Subpart C; and 40 CFR Part 279. The total number of initial notifications decreased from 

13,487 in the currently approved ICR to 10,408 in this current ICR. The total number of 

subsequent notifications decreased from 42,428 in the currently approved ICR to 35,778 in this 

current ICR. Note that, in estimating the number of initial and subsequent notifications in this 

current ICR, EPA used the average of the number of notifications submitted in 2007 and 2008 

(see Table 12). In each of these years, there was a decrease in the total annual number of 

notifications submitted to EPA, when compared to the annual number of notifications in the 

currently approved ICR. Thus, EPA believes that the number of notifications included in this 

current ICR is consistent with the respondent universe subject to these notification requirements.

Second, the burden associated with the notification activities decreased because of 

adjustments made to the hourly burden estimates for the Site ID Form. These adjustments were 

based, in part, on consultations with industry representatives. Refer to Section 3(c) for additional 

information on consultations. In addition, adjustments were made to the hourly burden estimates 

for the Site ID Form based on EPA’s best judgment to take into account the option given to 

respondents in the Site ID Form’s instructions to use their most recently submitted form in 

making a subsequent notification. These optional procedures relieve them of the need to 

complete the form from in its entirety (i.e., complete a blank form), saving time. These 

adjustments do not reflect any change in requirements; they represent instead a more accurate 

representation of the burden that respondents will incur as a result of this information collection.

(2) Hazardous Waste Report

(a) Respondent Burden

The annual respondent burden estimate for the 2007 Hazardous Waste Report (EPA ICR 

Number 0976.13) was 267,974 hours, with a total cost of $47,713 for capital/start-up and O&M. 

The annual respondent burden estimate for the 2009 Hazardous Waste Report is 169,780 hours,

with a total cost of $26,787 for capital/start-up and O&M. This represents a decrease of 98,194 

hours and $20,926 in total cost for capital/start-up and O&M. 
48

This decrease in burden for respondents has occurred for two primary reasons. First, 

there was a decrease in the annualized number of respondents, from 12,619 projected for 2007 to 

8,242 projected for 2009. Second, there was a decrease in the number of Hazardous Waste 

Report forms projected for 2007 versus the number of forms projected for 2009. Table 14

compares the projected number of forms for the 2007 and the 2009 Hazardous Waste Reports.

Table 14

Comparison of Projected Number of Forms

for the 2007 and 2009 Hazardous Waste Report

Hazardous Waste Report Form

Projected Number of Forms

Difference 2007 a

Hazardous

Waste Report

2009

Hazardous

Waste Report

Site Identification (Site ID) Form 25,238 16,483 -8,755

Form GM - Generation and Management 254,660 205,994 -48,666

Form WR - Waste Received from Offsite 851,540 861,640 10,100

Total 1,131,438 1,084,117 -47,321

a

 Negative value indicates a decrease in the number of forms.

(b) State Agency Burden

The annual State agency burden estimate for the 2007 Hazardous Waste Report (EPA 

ICR Number 0976.13) was 417,222 hours, with a total cost of $18,929 for capital/start-up and 

O&M. The annual State agency burden estimate for the 2009 Hazardous Waste Report is 

215,828 hours, with a total cost of $17,061 for capital/start-up and O&M. This represents a 

decrease of 201,394 hours and $1,868 in total cost for capital/start-up and O&M. 

This decrease in burden for State agencies has occurred because there was a decrease in 

the number of respondents and Hazardous Waste Report forms projected for 2007 versus the 

number of forms projected for 2009. Refer to Table 14 for a comparison of the projected number 

of forms for the 2007 and the 2009 Hazardous Waste Reports.
49

6(g) PUBLIC BURDEN STATEMENT

(1) Notification of Regulated Waste Activity

(a) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

The average annual public reporting burden associated with hazardous secondary

material notification requirements is estimated to be approximately 1.36 hours. This includes 

time to notify EPA under section 260.42. There are no recordkeeping requirements associated 

with hazardous secondary material notification requirements, and as such, there is no 

recordkeeping burden.

(b) Notification of Hazardous Waste Activity under RCRA Section 3010

The average annual public reporting burden associated with RCRA Section 3010 

notification requirements (initial and subsequent) is estimated to be approximately 0.74 hour. 

This includes time for reading the Site ID Form instructions, completing the form, and 

submitting the form. There are no recordkeeping requirements associated with the RCRA 

Section 3010 notification requirements, and as such, there is no recordkeeping burden.

(c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

The average annual public reporting burden associated with notification requirements 

under 40 CFR Part 262, Subpart K is estimated to be 0.67 hour per respondent. This includes 

time for preparing and submitting a Site ID Form to opt into or withdraw from Subpart K. 

The average annual public recordkeeping burden associated with notification 

requirements under 40 CFR Part 262, Subpart K is estimated to be 0.08 hour per respondent. 

This includes time for keeping copies of notification and affiliation agreements on-site.

(d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

The average annual public reporting burden associated with 40 CFR Part 273, Subpart C 

notification requirements (initial and subsequent) is estimated to be approximately 0.82 hour. 

This includes time for reading the Site ID Form instructions or applicable regulations, 

completing the Site ID Form or preparing a letter requesting an EPA Identification Number, and 

submitting the completed Site ID Form or letter. There are no recordkeeping requirements 

associated with the 40 CFR Part 273, Subpart C notification requirements, and as such, there is 

no recordkeeping burden.
50

(e) Notification of Used Oil Activity under 40 CFR Part 279

The average annual public reporting burden associated with 40 CFR Part 279 notification 

requirements (initial and subsequent) is estimated to be approximately 0.75 hour. This includes 

time for reading the Site ID Form instructions or applicable regulations, completing the Site ID 

Form or preparing a letter requesting an EPA Identification Number, and submitting the 

completed Site ID Form or letter. There are no recordkeeping requirements associated with the 

40 CFR Part 279 notification requirements, and as such, there is no recordkeeping burden.

(2) Hazardous Waste Report

The reporting burden is estimated to average 16.63 hours per respondent, and includes 

time for reviewing instructions, gathering data, completing and reviewing the forms, and 

submitting the report. The record keeping requirement is estimated to average 3.97 hours per 

response and includes the time for filing and storing the Hazardous Waste Report submission for 

three years.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

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

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

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

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-RCRA-2008-0912, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

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

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

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

those documents in the public docket that are available electronically. When in the system, 

select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-RCRA-2008-0912 and OMB Control Number 

2050-0024 in any correspondence.
51

EXH IB IT 1- a

N O TIFIC ATIO N O F R E G U L AT E D W A S T E A C T I VITY

EST IM A T E D A NNUAL P R IV A T E -S E C T O R RE S P O N D E N T H O U R AND C O ST B URD E N

Hours a n d C o s ts P er Respon dent P e r A c tiv it y T o t al H o u rs a n d C o sts

L e g . M g r . T e ch . C le r. R es p on. L a bor Capita l / N u m b e r Tot a l T o tal

 $ 1 18 . 68 / $ 70.15/ $ 5 2. 2 6/ $31.44 / Hou rs / C o s t/ S t a rt u p O & M Resp o n./ H o u rs / C o s t /

I N F O RMAT ION C O L L E CTIO N ACT I VITY Y e a r Y ea r Y e a r Y ea r Y e ar Y e ar C o s t C o s t Activ . Y e a r Y e ar

Com ple te and s ub m it E PA F o r m 8700-12 p rio r to

opera t in g under ex c lu s io n( s ) 0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $0.0 0 $ 3. 2 5 1, 6 01 1 ,865.1 7 $102, 303.9 0

Com ple te and s ub m it E PA F o r m 8700-12 b y M a rc h 1 o f 

eac h e v en numbered y ea r t h er e a ft er

0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $0.0 0 $ 3. 2 5 2 16 251.6 4 $13, 802.4 0

Com ple te and s ub m it E PA F o r m 8700-12 in d ic a ting t ha t

t he ha z a r d ou s s e c ondary m a t er ia ls are n o lo n ge r

m anaged in ac c o r da n c e w it h t he e x c lus ion

0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 80 53.2 0 $ 3, 021.6 0

S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 2 ,170.0 1 $119, 127.9 0

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 8, 3 68 8 ,368.0 0 $462, 583.0 4

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 3 4, 0 06 22 ,6 13.9 9 $1,284, 406.6 2

S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 30 ,9 81.9 9 $1,746, 989.6 6

P r e pa r e and s ubmit E PA Form 8700 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 26 17.2 9 $ 982.0 2

Keep a c opy of t he no tif ic a tion on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 26 2 .0 8 $6 5 .5 2

Keep a c opy of t he ir f or m al w rit te n a ff iliat io n a gr e e m e nt 

w it h c o lle ge or un iv e r s it y o n f ile while it s lab o r at o rie s a re

s ub je c t t o Su bpar t K

0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 1 0 .0 8 $2.5 2

Keep a c opy of t he fo r m a l w r itt en af filia tion agreement wit h

a c o llege o r u n iv e rs ity o n fi le a t th e non- p r o fit res e arch

in s t itu te w hile it s labor at orie s a re s u bje c t t o S ubpart K

0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 1 0 .0 8 $2.5 2

P r e pa r e and s ubmit E PA Form 8700 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 0 0 .0 0 $0.0 0

Keep a c opy of t he w ithdr a wal n o tic e on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 0 0 .0 0 $0.0 0

S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 19.5 3 $ 1, 052.5 8

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 22 22.0 0 $ 1, 216.1 6

P r e pa r e and s ubmit le tte r r e q uestin g a n E P A Ident ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 7 3 .5 0 $ 204.0 5

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 6 3 .9 9 $ 226.6 2

P r e pa r e and s ubmit le tte r r e q uestin g a n E P A Ident ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0

S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 30.4 9 $ 1, 705.1 3

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 82 82.0 0 $ 4, 532.9 6

P r e pa r e and s ubmit le tte r r e q uestin g a n E P A Ident ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 27 13.5 0 $ 787.0 5

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 92 61.1 8 $ 3, 474.8 4

P r e pa r e and s ubmit le tte r r e q uestin g a n E P A Ident ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 30 15.0 0 $ 874.5 0

S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 171.6 8 $ 9, 669.3 5

T O T A L varie s va ri e s vari es v ar ie s varie s varie s v ar ie s va r ie s varie s 33,374 $1,8 78 , 54 5

Lett er

N o t if icatio n o f H az a rdou s S ec o n d a ry M a t er ia l Act i vi ty u n der 4 0 C F R 26 0 .4 2

N o t if icatio n o f H az a rdou s W a s t e Ac t i vi t y u nder R CRA S e c tion 301 0

Init i al N o tif ic a tio n

S u b se q u en t Notifi c ati o n

Lett er

EPA F o r m 8 700- 1 2

Lett er

S u b se q u en t Notifi c ati o n

N o t if icatio n o f U se d O il A ct i vi t y u nder 4 0 CFR P ar t 2 79

Init i al N o tif ic a tio n

EPA F o r m 8 700- 1 2

E l ig ible A c adem ic E n t itie s

T ea c h ing Hos p ita ls

Non-P ro f it R es ea rch In s t it u te s

EPA F o r m 8 700- 1 2

Init i al N o tif ic a tio n

S u b se q u en t Notifi c ati o n

EPA F o r m 8 700- 1 2

Lett er

W it h d r a w al f ro m 40 C F R P a rt 262, S ubpa rt K

N o t if icatio n o f U n iversal W a st e A c tiv it y u n der 4 0 C F R P a rt 2 73, Su b p a rt C

N o t if icatio n o f H az a rdou s W a s t e Ac t i vi t y u nder 40 CFR Pa rt 26 2 , S ubpa r t K

Int e n t t o Com p ly w i th S ubp ar t K an d R eco rdkeeping of A gree m e n t s
52

EXH IB IT 1- b

N O TIFIC ATIO N O F RE G U L AT E D W A S T E A C T I VITY

EST IM ATE D ANNUAL S T AT E AND L O CAL G O V E R N M E N T R E S PO N D E N T H O U R AN D C O S T B U RDE N

H o u r s a n d C o s t s P er R espon d e n t P e r A c tiv it y T o t al H o u rs a n d C o st s

L e g . M g r . T e ch . C le r. R es p on. L a bor Cap i ta l / N u m b e r Tot a l T o t al

 $ 1 18 . 68 / $ 70.15/ $ 5 2. 2 6/ $ 31 . 44 / Hou rs / C o s t/ S t a rt u p O & M Resp o n./ H o u rs / C o s t/

INFO R M A T ION C O L L E C T I O N ACT I VITY Y e a r Y ea r Y e a r Y ea r Y e ar Y e ar C o s t C o s t Activ . Y e a r Y e ar

Com ple te and s ub m it E PA F o r m 8700-12 p rio r to

opera t in g under ex c lu s io n( s ) 0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $0.0 0 $ 3. 2 5 1 11 129.3 2 $ 7, 092.9 0

Com ple te and s ub m it E PA F o r m 8700-12 b y M a rch 1 o f

eac h e v en num bered y ea r t h er e a ft er

0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $0.0 0 $ 3. 2 5 15 17.4 8 $ 958.5 0

Com ple te and s ub m it E PA F o r m 8700-12 in d ic a ting t ha t

t he ha z a r d ou s s e c ondary m a t er ia ls ar e no lo n ge r

m anaged in ac c o r danc e w it h t he e x c lus ion

0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 6 3 .9 9 $ 226.6 2

S u b to ta l v a r ie s v a rie s v arie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 150.7 9 $ 8, 278.0 2

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 1, 8 88 1 ,888.0 0 $104, 368.6 4

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 1, 6 37 1 ,088.6 1 $61, 829.4 9

S u b to ta l v a r ie s v a rie s v arie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 2 ,976.6 1 $166, 198.1 3

P r e pa r e and s ubm it E P A Fo rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 11 7 .3 2 $ 415.4 7

K e e p a c opy of t he no tif ic a tion on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 11 0 .8 8 $2 7 .7 2

K e e p a c opy of t he ir f or m al w r it te n a ff iliat io n a gr e e m e nt 

w it h c o lle ge or un iv e r s it y o n f ile while it s lab o r at o rie s a re 

s ub je c t t o Subpar t K

0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 1 0 .0 8 $2.5 2

K e e p a c opy of t he fo r m a l w r itt en af filia tion agreem ent wit h

a c o llege o r u n iv e rs ity o n file a t th e non- p r o fit r es e arch

in s t itu te w hile it s labor at orie s a re s u bje c t t o S ubpar t K

0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 0 0 .0 0 $0.0 0

P r e pa r e and s ubm it E P A Fo rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 0 0 .0 0 $0.0 0

K e e p a c opy of t he w it h dr awal n o tic e on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $2.5 2 $0.0 0 $ 0. 0 0 0 0 .0 0 $0.0 0

S u b to ta l v a r ie s v a rie s v arie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 8 .2 8 $ 445.7 1

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 4 4 .0 0 $ 221.1 2

P r e pa r e and s ubm it le tte r r e q ue s tin g a n E PA Id e nt ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 1 0 .6 7 $3 7 .7 7

P r e pa r e and s ubm it le tte r r e q ue s tin g a n E PA Id e nt ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 0 0 .0 0 $0.0 0

S u b to ta l v a r ie s v a rie s v arie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 5 .6 7 $ 317.1 9

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $0.0 0 $ 3. 2 5 6 6 .0 0 $ 331.6 8

P r e pa r e and s ubm it le tte r r e q ue s tin g a n E PA Id e nt ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0

Com ple te and s ub m it E PA F o r m 8700-1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $0.0 0 $ 3. 2 5 3 2 .0 0 $ 113.3 1

P r e pa r e and s ubm it le tte r r e q ue s tin g a n E PA Id e nt ific a t ion

Num be r

0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $0.0 0 $ 3. 2 5 1 0 .5 0 $2 9 .1 5

S u b to ta l v a r ie s v a rie s v arie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 9 .5 0 $ 532.4 4

T O T A L varie s va ri e s vari es v ar ie s varie s varie s v ar ie s va r ie s varie s 3 ,151 $175 , 77 1

N o t if icatio n o f Haz a rd o u s W a s t e Ac t i vi t y u nde r 40 CFR Pa rt 26 2 , S ubpa r t K

Int e n t t o Com p ly w i th S ubp ar t K an d R eco r d k ee p ing of A g r ee m e nts

Lett er

W it h d r awal f ro m 40 C F R P a rt 26 2 , S ubpa rt K

N o t if icatio n o f Universal W a st e A c tiv it y u n d e r 40 C F R P a rt 2 73, Su b p a rt C

Non-P ro f it R es ea rch In s t it u te s

EPA F o r m 8 700- 1 2

Init i al N o tific a tio n

S u b se q u en t Noti fi c ation

EPA F o r m 8 700- 1 2

E lig ible A c adem ic En t itie s

T ea c h ing Hos p ita ls

Lett er

S u b se q u en t Noti fi c ation

N o t if icatio n o f Use d O il A ct i vi t y u nde r 4 0 CFR P ar t 2 79

Init i al N o tific a tio n

EPA F o r m 8 700- 1 2

Lett er

EPA F o r m 8 700- 1 2

Lett er

N o t if icatio n o f Haz a rd o u s S ec o n d a ry M a t er ia l A cti vi t y u n d e r 4 0 CFR 260.4 2

N o t if icatio n o f Haz a rd o u s W a s t e Ac t i vi t y u nde r RCRA S e c tion 3 01 0

Init i al N o tific a tio n

S u b se q u en t Noti fi c ation
53

EXHIBIT 2-A

2009 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL PRIVATE-SECTOR RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

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

 $118.68/ $70.15/ $52.26/ $31.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Hazardous Waste Report instructions 0.00 1.00 1.00 0.00 2.00 $122.41 $0.00 $0.00 7,568 15,136.00 $926,399

Gather information and prepare Site Identification Form 0.00 0.08 0.40 0.08 0.56 $29.03 $0.00 $0.00 7,568 4,238.08 $219,699

Gather information and prepare Form GM 0.00 0.10 0.47 0.04 0.61 $32.83 $0.00 $0.00 94,561 57,681.91 $3,104,421

Gather information and prepare Form WR 0.00 0.00 0.12 0.04 0.16 $7.53 $0.00 $0.00 423,986 67,837.76 $3,192,615

Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0

Submit report to the State or Regional EPA Office 0.00 0.00 0.00 0.08 0.08 $2.52 $0.00 $3.25 7,568 605.44 $43,667

Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $1.15 $0.00 $0.00 526,115 15,783.44 $605,032

TOTAL varies varies varies varies varies varies varies varies varies 161,282.63 $8,091,833

Hazardous Waste Report

EXHIBIT 2-b

2009 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL STATE AND LOCAL GOVERNMENT RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

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

 $118.68/ $70.15/ $52.26/ $31.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Hazardous Waste Report instructions 0.00 1.00 1.00 0.00 2.00 $122.41 $0.00 $0.00 674 1,347.00 $82,443

Gather information and prepare Site Identification Form 0.00 0.08 0.40 0.08 0.56 $29.03 $0.00 $0.00 674 377.16 $19,552

Gather information and prepare Form GM 0.00 0.10 0.47 0.04 0.61 $32.83 $0.00 $0.00 8,437 5,146.27 $276,970

Gather information and prepare Form WR 0.00 0.00 0.12 0.04 0.16 $7.53 $0.00 $0.00 6,834 1,093.44 $51,460

Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0

Submit report to the State or Regional EPA Office 0.00 0.00 0.00 0.08 0.08 $2.52 $0.00 $3.25 674 53.88 $3,886

Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $1.15 $0.00 $0.00 15,944 478.32 $18,336

TOTAL varies varies varies varies varies varies varies varies varies 8,496.07 $452,647

Hazardous Waste Report
54

EXHIBIT 3

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $85.28/ $75.25/ $54.14/ $23.09/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 1,712 428.00 $23,180.48

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 1,712 3,852.00 $195,253.60

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 231 57.75 $3,127.74

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 231 519.75 $26,345.55

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 86 21.50 $1,164.44

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 86 193.50 $9,808.30

Subtotal varies varies varies varies varies varies varies varies varies 5,072.50 $258,880.11

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 10,256 2,564.00 $138,866.24

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 10,256 23,076.00 $1,169,696.80

Generate EPA Identification Number and send EPA 

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.55 $0.00 $0.45 10,256 5,128.00 $123,072.00

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 35,643 8,910.75 $482,606.22

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 35,643 80,196.75 $4,065,084.15

Subtotal varies varies varies varies varies varies varies varies varies 119,875.50 $5,979,325.41

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 37 9.25 $500.98

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 37 83.25 $4,219.85

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 0 0.00 $0.00

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 92.50 $4,720.83

a

 Exhibit includes rounding.

Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

Withdrawal from 40 CFR Part 262, Subpart K

Eligible Academic Entities

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Notification of Hazardous Waste Activity under RCRA Section 3010

Initial Notification

Subsequent Notification

Notification prior to operating under exclusion(s)

Notification by March 1 of each even numbered year thereafter

Notification indicating that the hazardous secondary materials are no longer managed in accordance with the exclusion
55

EXHIBIT 3 (continued)

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $0.00/ $0.00/ $0.00/ $0.00/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 26 6.50 $352.04

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 26 58.50 $2,965.30

Generate EPA Identification Number and send EPA 

Identification Number to facility 0.00 0.00 0.00 0.50 0.50 $11.55 $0.00 $0.45 26 13.00 $312.00

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 9 2.25 $121.86

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 9 20.25 $1,026.45

Generate EPA Identification Number and send EPA 

Identification Number to facility 0.00 0.00 0.00 0.50 0.50 $11.55 $0.00 $0.45 9 4.50 $108.00

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 7 1.75 $94.78

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 7 15.75 $798.35

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 2 0.50 $27.08

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 2 4.50 $228.10

Subtotal varies varies varies varies varies varies varies varies varies 127.50 $6,033.96

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 88 22.00 $1,191.52

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 88 198.00 $10,036.40

Generate EPA Identification Number and send EPA 

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.55 $0.00 $0.45 88 44.00 $1,056.00

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 29 7.25 $392.66

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 29 65.25 $3,307.45

Generate EPA Identification Number and send EPA 

Identification Number to facility 0.00 0.00 0.00 0.50 0.50 $11.55 $0.00 $0.45 29 14.50 $348.00

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 95 23.75 $1,286.30

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 95 213.75 $10,834.75

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.54 $0.00 $0.00 31 7.75 $419.74

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $114.05 $0.00 $0.00 31 69.75 $3,535.55

Subtotal varies varies varies varies varies varies varies varies varies 666.00 $32,408.37

TOTAL varies varies varies varies varies varies varies varies varies 125,834 $6,281,369

a

 Exhibit includes rounding.

Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Initial Notification

Subsequent Notification

EPA Form 8700-12

Letter

Subsequent Notification

EPA Form 8700-12

Notification of Used Oil Activity under 40 CFR Part 279

Initial Notification

Letter

EPA Form 8700-12

Letter

EPA Form 8700-12

Letter
56

EXHIBIT 4

2009 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $85.28/ $75.25/ $54.14/ $23.09/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Develop Hazardous Waste Report forms and instructions 0.00 8.00 80.00 20.00 108.00 $5,395.00 $0.00 $20,000.00 0.50 54.00 $12,697.50

Distribute Hazardous Waste Report forms and instructions 0.00 0.01 0.25 0.50 0.76 $25.83 $0.00 $0.00 50 38.00 $1,291.50

Develop computer capabilities required to compile national data 0.00 8.00 80.00 0.00 88.00 $4,933.20 $0.00 $250,000.00 0.50 44.00 $127,466.60

Assist respondents 0.00 0.01 0.50 0.50 1.01 $39.37 $0.00 $0.00 50 50.50 $1,968.50

Key entry of report submissions 0.00 0.01 0.08 0.25 0.34 $10.86 $0.00 $0.00 29 9.86 $314.94

Perform quality assurance 0.00 0.02 0.16 0.16 0.34 $13.56 $0.00 $0.00 150 50.40 $2,034.00

Prepare the National Report 0.00 8.00 200.00 40.00 248.00 $12,353.60 $0.00 $50,000.00 0.50 124.00 $31,176.80

Store the data 0.00 0.00 80.00 0.00 80.00 $4,331.20 $0.00 $35,000.00 0.50 40.00 $19,665.60

TOTAL varies varies varies varies varies varies varies varies varies 411 $196,615

a

 Exhibit includes rounding.

Hazardous Waste Report

EXHIBIT 5

2009 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL STATE AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $57.43/ $53.91/ $32.26/ $20.58/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Distribute and collect Report forms and instructions 0.00 0.01 0.25 0.50 0.76 $18.89 $0.00 $2.07 8,242 6,263.92 $172,752.32

Assist respondents 0.00 0.01 0.50 0.50 1.01 $26.96 $0.00 $0.00 8,242 8,324.42 $222,204.32

Key entry of report submissions 0.00 0.01 0.08 0.25 0.34 $8.26 $0.00 $0.00 56,199 19,107.66 $464,203.74

Perform quality assurance 0.00 0.02 0.16 0.16 0.34 $9.32 $0.00 $0.00 542,059 182,131.82 $5,051,989.88

TOTAL varies varies varies varies varies varies varies varies varies 215,828 $5,911,150

a

 Exhibit includes rounding.

Hazardous Waste Report
57

EXHIBIT 6

NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORT

TOTAL ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN SUMMARY a

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Information Collection Requirement Year Year Costs Costs Year

Notification of Regulated Waste Activity (Exhibits 1-a and 1-b) 36,525 $1,897,497 $0 $156,819 $2,054,316

Hazardous Waste Report - Respondents (Exhibits 2-a and 2-b) 169,780 $8,517,772 $0 $26,787 $8,544,559

TOTAL 206,305 $10,415,269 $0 $183,606 $10,598,875

a

 Exhibit includes rounding.

EXHIBIT 7

NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORT

TOTAL ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN SUMMARY a

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Information Collection Requirement Year Year Costs Costs Year

Notification of Regulated Waste Activity (Exhibit 3) 125,834 $6,276,685 $0 $4,684 $6,281,369

Hazardous Waste Report (Exhibit 4) 411 $19,115 $0 $177,500 $196,615

TOTAL 126,245 $6,295,801 $0 $182,184 $6,477,984

EXHIBIT 8

NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORT

TOTAL ESTIMATED ANNUAL STATE AGENCY HOUR AND COST BURDEN SUMMARY a

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Information Collection Requirement Year Year Costs Costs Year

Hazardous Waste Report (Exhibit 5) 215,828 $5,894,089 $0 $17,061 $5,911,150

TOTAL 215,828 $5,894,089 $0 $17,061 $5,911,150

a

 Exhibit includes rounding.