## SUPPORTING STATEMENT FOR

EPA INFORMATION COLLEC TION REQUEST #1571.10

"GENERAL HAZARDOUS WA STE FACILITY STANDARDS"

August 13, 2012

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TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) Title and Number of the Information Collection ................................................................ 3 1(b) Characterization of the Information Collection .................................................................. 3

2. NEED FOR AND USE OF THE COLLECTION
2(a) Need and Authority for the Collection ................................................................................ 6 2(b) Use and Users of the Data ................................................................................................ . 10

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a) Nonduplication ........................................................................................................... ....... 12
3(b) Consultations ............................................................................................................ ........ 12 3(c) Public Notice ............................................................................................................ ......... 13 3(d) Effects of Less Fr equent Collection .................................................................................. 13 3(e) General Guidelines ....................................................................................................... .... 13 3(f) Confidentiality .......................................................................................................... ........ 14 3(g) Sensitive Questions ...................................................................................................... ..... 14

4. THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents/NAICS Codes .............................................................................................. 14 4(b) Information Requested .................................................................................................... .. 15

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
5(a) Agency Activities ........................................................................................................ ..... 58 5(b) Collection Methodology and Management ....................................................................... 60 5(c) Small Entity Flexibility ................................................................................................. .... 60 5(d) Collection Schedule ...................................................................................................... .... 60

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a) Estimating Respondent Burden ......................................................................................... 64 6(b) Estimating Respondent Cost ............................................................................................. 6 5 6(c) Estimating Agency Burden and Cost ................................................................................ 66 6(d) Respondent Universe and Total Respondent Burden and Costs ....................................... 66 6(e) Bottom Line Burden Hours and Costs .............................................................................. 75 6(f) Reasons for Change in Burden ......................................................................................... 76 6(g) Burden Statement ......................................................................................................... ..... 76

Exhibits 1-10 ................................................................................................................. ............ 78-90

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1. IDENTIFICATION OF TH E INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF TH E INFORMATION COLLECTION

This ICR is entitled “General Hazardous Waste Facility Standards (Renewal)” EPA ICR #1571.10, OMB # 2050-0120.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

Section 3004 of the Resource Conservation and R ecovery Act (RCRA), as amended, requires that the U.S. Environmental Protection Agency (EPA) develop standards for hazardous waste treatment, storage and disposal facilities (TSDFs) as may be n ecessary to protect human health and the environment. Subsections 3004(a) (1), (3), (4), (5) and (6) specify that these standards include, but not be limited to, the following requirements:

 Maintaining records of all hazardous wastes id entified or listed under Subtitle C that are treated, stored, or disposed of, and the manne r in which such wastes were treated, stored, or disposed of;

 Operating methods, techniques, and practices for treatment, storage, or disposal of hazardous waste;

 Location, design, and construction of such h azardous waste treatment, disposal, or storage facilities;

 Contingency plans for effective action to minimize unanticipated damage from any treatment, storage, or disposal of any such hazardous waste; and

 Maintaining or operating such facilities and re quiring such additional qualifications as to ownership, continuity of operation, traini ng for personnel, and financial responsibility as may be necessary or desirable.

The regulations implementing these requirements are codified in the Code of Federal Regulations (CFR) Title 40, Parts 264 and 265. A brief summa ry of the information collection requirements associated with each TSDF regulation for the above areas is provided below. A more specific discussion of the data elements and respondent activities asso ciated with each of the information collection requirements is presented in Section 4.

GENERAL FACILITY OPERATING REQUIREMENTS

EPA promulgated the general facility standards in 40 CFR Parts 264 and 265, Subpart B. In order to comply with these regulations, owners or operators of TSDFs must collect, record, and in some cases report, data to EPA. Information collection requirements associated with the general facility standards regulations include:

 

### Foreign Shipment Import Report (§264.12(a) and §265.12(a));

 Notice of Appropriate Permits (§264.12(b));

 Notice of Part 264 and Part 270 Requirements (§264.12(c) and §265.12(b));

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 Waste Analysis (§264.13(a)(1) and §265.13(a)(1));

 Waste Analysis Plan (§264.13(b) and §265.13(b));

 Inspection Schedule (§264.15(d) and §265.15(d));

 Personnel Training (§264.16(d) and §265.16(d));

 Documentation of Compliance for Ignitable, Reactive, or Incompatible Wastes (§264.17(c)); and

 Construction Quality Assurance Plan (§265.19).

EPA uses the general facility information to determine whether facilities are operating in a manner that is protective of human health and the environment.

RECORDKEEPING REQUIREMENTS

In 40 CFR 264.73 and 265.73, EPA promulgated re gulations directing owne rs or operators of hazardous waste TSDFs to keep written operating records at their facilities. Since the operating record is not submitted to EPA but must be available for inspection, maintaining an operating record is a recordkeeping activity. The operating record contai ns information regarding general operating practices conducted at the facility. Other recordkeeping requi rements under 40 CFR Parts 264 and 265, Subpart E, include maintaining copies of records of waste disposal locations and quantities (§§264.74(c) and 265.74(c)). In addition, 40 CFR 264.37(b) requires facilities to document in the operating record any

refusal of State or local authorities to enter into arrangements for emergency situations. Information collected pursuant to these regulations is used by EPA and the owner or operator to assure safe operation of the facility.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Contingency plan and emergency procedure regul ations promulgated in 40 CFR 264.51 through 264.54 and 264.56, and 265.51 throu gh 265.54 and 265.56, require permitte d and interim status facilities to prepare and maintain contingency plans and co mply with emergency reporting and recordkeeping requirements. The contingency plan describes the actions facility personnel will take should a fire, explosion, or any unplanned sudden or non-sudden release of hazardous wast e constituents to air, soil, or surface water occur. Local emergency response team s use the information required in the contingency plan to minimize unanticipated damage from the treatme nt, storage, or disposal of hazardous waste. The contingency plan also enables EPA to assess the effe ctiveness of facility responses to incidents that may

threaten human health or the environment.

Other emergency reporting and recordkeepi ng requirements under 40 CFR Parts 264 and 265, Subpart D, include notifying State and local author ities of an imminent or actual emergency situation (264.56(a)(2) and 265.56(a)(2)), and notifying local authorities of the need to evacuate local areas (264.56(d)(1) and 265.56(d)(1)). If a release, fire, or explosion occurs, the owner or operator must notify the on-scene coordinator or the National Response Cent er (264.56(d) (2) and 265.56(d) (2)). Owners and operators also must notify the Regional Administrato r that a facility is in compliance with specific regulations before operations resume in any area a ffected by an emergency situation (§§264.56(i) and 265.56(i)), and submit a report to the Regional Admi nistrator containing deta ils of any emergency

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situation that requires implementation of the contingency plan (§264.56(j) and 265.56(j)).

RELEASES FROM SOLID WASTE MANAGEMENT UNITS

In 40 CFR Part 264, Subpart F, EPA promulgated regulations pertaining to releases from solid waste management units. Section 264.96(c) requir es owners and operators to prepare and submit a demonstration for termination of the compliance period during which the ground-water protection standard of §264.92 applies. Under 40 CFR 264.97(g), owners and operators must propose to EPA an appropriate sampling procedure and interval for each hazardous constituent listed in the facility permit.

CLOSURE AND POST-CLOSURE REQUIREMENTS

In 40 CFR Parts 264 and 265, Subpart G, EPA promulgated regulations requiring owners or operators to provide for the proper closure of h azardous waste management (HWM) facilities, and for proper post-closure care of hazardous waste dispo sal facilities. Under 40 CFR 264.112, 265.112, 264.118, and 265.118 owners or operators are required to maintain closure and post-closure plans at the facilities, notify EPA and amend the closure and pos t-closure plans when a ppropriate, and submit these plans to EPA when necessary. Other closure and post-closure requirements under Subpart G of Part 264 and 265 include requiring owners or operators to:

 Demonstrate that they can comply with specifi c regulations if requesting an extension for treatment, storage, or removal of hazar dous waste (§§264.113(a) and 265.113(a)); Demonstrate that they can comply with specifi c regulations if requesting an extension for completing closure activities under an approved closure plan (§§264.113(b) and 265.113(b)); Demonstrate that they can comply with specific regulations if requesting an allowance to receive non-hazardous waste after the final receipt of hazardous waste (§§264.113(d) and 265.113(d)); Certify that a facility has been clo sed in accordance with the approved closure and post-closure pl ans (§§264.115, 265.115, 264.120, and 265.120); Submit a certified survey plat (§§264.116 a nd 265.116); Submit an amended post-closure plan, if necessary (§265.118(d)(4)); Submit a m odified post-closure plan, if the original plan is not approved by EPA (§265.118(f)); Submit a petition to extend or reduce the post-closure period (§265.118(g)(1)); and

 Submit a record of the type, location, and qua ntity of hazardous wastes disposed of at the facility, record a notation on the property deed according to the requirements in §§264.119(b)(1) and 265.119(b)(1), submit certif ication of this notation, and request a modification to the post-closure permit, if necessary. (§§264.119 and 265.119).

EPA uses closure and post-closure plans to ensu re that hazardous waste management facilities close in accordance with the Congressional mandate of protecting human health and the environment.

EPA reviews closure certifications to determine whether closure took place in accordance with the approved closure plan and EPA, local authorities, and potential purchasers of a closed facility review

closure notices to ensure that future uses of the site will not lead to a release of hazardous waste.

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FINANCIAL REQUIREMENTS

In 40 CFR Parts 264 and 265, Subpart H, EPA promulgated regulations requiring owners or operators to establish financial assurance mechanisms for closure, post-closure care, and liability for third-party bodily injury or property damage, and to provide EPA with evidence of such established financial mechanisms. Owners or operators are al so required by Subpart H to provide initial cost estimates and subsequent updates of those estimates for closure and post-closure care. EPA uses these financial assurance requirements to ensure, in the case of closure and post-closure care, that hazardous waste management facilities have the financial means to conduct closure or post-closure care, and in the case of liability requirements, that human health a nd the environment are protected in the event of accidental release of hazardous constituents from the facility.

CONDITIONS APPLICABLE TO ALL PERMITS

40 CFR Part 270, Subpart C specifies conditions applicable to all RCRA permits. 40 CFR 270.30(h) requires owners and opera tors of permitted facilities to fu rnish any relevant information requested by EPA to determine whether cause exists for modifying, revoking and reissuing, or terminating a permit, or to determine compliance with the permit. In addition, section 270.30(l) specifies the following reporting requirements, which are applicable to all permitted facilities:

 Notice of planned physical alterations or additions (270.30(l)(1)); Notice of planned changes or activities which may result in noncompliance (270.30(l)(2)); Letter certifying that the facility has been constructed or modified in compliance with the permit (270.30(l)(2)(i)); Monitoring reports (270.30(l)(4));Reports of compliance or noncompliance with compliance schedule (270. 30(l)(5)); Information concerning a release that may threaten drinking water (270.30(l)(6)(i)(A)); Information concerning a release, fire, or explosion that could threaten human health or the environment outside of the facility (270.30(l)(6)(i)(B)); Notice of noncompliance due to a release, fire, or explosion (270.30(l)(6)(iii)); Report of other noncompliance (270.30(l)(10)); and

 Submittal of originally omitted or corrected information (270.30(l) (11)).

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

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

this ICR.

GENERAL FACILITY OPERATING REQUIREMENTS

(1) Foreign Shipment Import Report

EPA promulgated regulations in §§264.12(a) and 265.12(a) requiri ng owners and operators of hazardous waste facilities that have arranged to recei ve hazardous wastes from foreign sources to notify the Regional Administrator in writing at least four we eks prior to the expected date of arrival of the shipments at the facility. EPA uses information in th e foreign shipment import report to determine: (1) whether hazardous wastes will be transported safely to the United States, and (2) whether the waste will

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be managed in a manner that is protective of human health and the environment. The foreign shipment import report requirement contributes to EPA's goa l of minimizing detrimental impacts to the environment resulting from the unsafe transporta tion and management of hazardous waste.

(2) Notice of Appropriate Permits

Section 264.12(b) requires the owner or operator of a facility receiving off-site waste to send a one-time notice to the generator stating that he or she has the appropriate permits, and will accept the waste the generator is shipping. The owner or operato r must retain a copy of the notice at the facility.

The notice is needed to ensure that waste is be ing managed properly. EPA may examine the notices during inspections to ensure that the notifications are being transmitted.

(3) Notice of Part 264 or 265 and Part 270 Requirements

Sections 264.12(c) and 265.12(b) require owners and operators transferring ownership of a facility during its operating life, or of a disposal f acility during the post-closure care period, to notify the new owner or operator in writing of the requirements of 40 CFR Parts 264 and 270. This information is needed to help new owners and ope rators understand applicable regula tions and facilitate compliance.

(4) Waste Analysis

EPA promulgated regulations in §§264.13(a) (1) and 265.13(a) (1) requiring owners or operators to obtain a detailed chemical and physical analysis of a representative sample of the waste that will be received. EPA and the owner or operator use inform ation obtained in the waste analysis sample to determine: 1) whether a facility can adequately handle incoming waste, and 2) whether the waste is really what the generator claims it to be. The owner or operator also uses information obtained from the waste analysis to determine whether there are any poten tial dangers from handling the waste. The waste analysis requirement contributes to EPA's goal of pr eventing releases or reactions of hazardous waste onsite.

(5) Waste Analysis Plan

Sections 264.13(b) and 265.13(b) state that the owner or operator of a hazardous waste facility must develop and follow a written waste analysis pl an that describes the pro cedures to be used in obtaining a detailed chemical and physical analysis of the waste. EPA uses the waste analysis plan as a planning tool to ensure the quality of information obtained from the waste analysis samples required in 264.13(a)(1) and 265.13(a)(1).

(6) Inspection Schedule

EPA promulgated regulations in §§264.15(d) and 265.15(d) requiring the owner or operator of a facility to record inspections in an inspection lo g or summary. EPA and owners and operators use information in the inspection log to determine whet her facility equipment is safe for handling hazardous waste. The inspection requirement contributes to EPA's goal of preventing hazardous waste constituents from being released into the environment due to faulty or deteriorated equipment.

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(7) Personnel Training

Sections 264.16(d) and 265.16(d) require owners and operators to mainta in copies of personnel training documents and records at their facilities. Bo th EPA and owners and opera tors use information in personnel training records to determine whether em ployees have acquired the necessary expertise to perform their jobs. EPA also reviews personnel r ecords to determine whether employees are receiving a level of training that is commensurate with thei r duties and responsibilities as well as their ability to respond to any emergency situations at the facility . Requiring owners and operators to maintain personnel training documents decreases the likeliho od that employees are unqualified to handle hazardous waste or respond to emergencies. The personnel reco rdkeeping requirement contributes to EPA's goal of minimizing the potential for employee-related mist akes that may threaten human health and the

environment.

(8) Documentation of Compliance for Ignitable, Reactive or Incompatible Wastes

Section 264.17(c) states that any owner or operator who treats, stores, or disposes of ignitable or reactive wastes, or mixes incompatible wastes, mu st document compliance with §264.17(a) and (b), which require certain precautions to prevent reacti ons. EPA uses information in the documentation of compliance to determine whether facilities are operati ng in a manner that is protective of human health and the environment. The documentation requirement contributes to EPA's goal of minimizing damage from the treatment, storage, or disposal of hazardous waste.

(9) Construction Quality Assurance Plan

Section 265.19(b) requires each owner or operator of a surface impoundment, waste pile, or landfill to develop a written construc tion quality assurance (CQA) plan that identifies steps that will be used to monitor and document the quality of materials and the condition and manner of their installation. The CQA plan helps to ensure proper structural stab ility and integrity of all unit components, and proper

construction of all units.

RECORDKEEPING REQUIREMENTS

EPA promulgated regulations in 40 CFR 264.73 a nd 265.73 directing owners or operators of hazardous waste treatment, storage, or disposal faciliti es to keep a written operating record at the facility. Other recordkeeping requirements under 40 CFR Parts 264 and 265, Subpart E, include submitting copies of records of waste disposal locations and qua ntities under §§264.73(b)(2) and 265.73(b)(2) to the Regional Administrator and local land authority upon closure of the facility (§§264.74(c) and 265.74(c)). In addition, 40 CFR 264.37(b) requires facilities to doc ument in the operating record any refusal of State or local authorities to enter into arrangements for em ergency situations. EPA uses information collected pursuant to these regulations to select appropriate corrective action and cleanup measures should an unanticipated release of hazardous waste occur. EPA co mpliance officials refer to the operating record to determine the following: 1) what cleanup measu res are appropriate and 2) whether operating requirements can be better tailored to the needs of a particular site. EPA anticipates that the owner or operator will use information included in the opera ting record to prevent receiving, or placing in proximity, wastes that are incompatible with other wast es that are likely to ignite or explode. Requiring facilities to develop and maintain an operating reco rd and conduct the recordkeeping activities contributes to EPA's goal of minimizing damage to the environm ent due to the treatment, storage, or disposal of

hazardous waste.

CONTINGENCY PLAN AND EMERGENCY REPORTING AND RECORDKEEPING

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REQUIREMENTS

Section 3004(a) (5) of RCRA, as amended, requires EPA to deve lop standards for contingency plans for effective action to minimize damage from an y treatment, storage, or disposal of any such hazardous waste. EPA codified regulations that a ddress this statutory requirement in 40 CFR Parts 264 and 265. 40 CFR §§264.51 through 264.54 and 264.56 and 265.51 through 265.54 and 265.56 require all owners and operators of hazardous waste facilities to prepare and maintain contingency plans, and to notify State and local authorities and prepare and em ergency reports whenever an imminent or actual emergency situation occurs. EPA reviews the con tingency plan and emergency reports to determine whether a facility has developed adequate pro cedures to respond to unpla nned sudden or non-sudden

releases of hazardous waste or hazardous constituents to ai r, soil, or surface water. Notifications to State

and local authorities facilitate remedial actions and evacuations, if necessary. Requiring facilities to develop and maintain contingenc y plans and prepare emergency r esponse reports and notifications contributes to EPA's goal of minimizing damage from the treatment, storage, or disposal of hazardous

waste.

RELEASES FROM SOLID WASTE MANAGEMENT UNITS

Under 40 CFR 264.96(c), EPA requires owners a nd operators to demonstrate that the groundwater protection standard has not been exceeded for a period of three years to ensure that the compliance period can be safely terminated. 40 CFR 264.97(g) re quires owners and operators to prepare and submit an appropriate sampling procedure and interval to ensure that ground-water monitoring is being performed accurately and adequately.

CLOSURE AND POST-CLOSURE REQUIREMENTS

EPA promulgated regulations in 40 CFR Part s 264 and 265, Subpart G (§§264.112, 264.115, 264.116, 264.118-120 and 265.112, 265.113, 265.115, 265.116, and 265.118-120), that require owners and operators to develop closure a nd post-closure plans, amend these pl ans when appropriate, and submit to EPA closure certifications and post-closure notices. EPA reviews information in the closure and postclosure plans to determine whether closure and post- closure activities will comply with the regulatory requirements. EPA uses information in the closure cer tifications to determine that closure took place in accordance with the approved closure plan. EPA, local authorities, and potential purchasers of a closed facility review information included in the post-closur e notices to determine what future uses of the site

will not lead to a release of hazardous waste.

In addition, 40 CFR 264.113 and 265.113 allow owners and operators to apply for allowances and extensions during the closure period by preparing and submitting demonstrations . These demonstrations are needed to ensure that any activities taking place dur ing closure are protective of human health and the

environment.

Requiring facilities to comply with these regulations contributes to EPA's goal of ensuring that all hazardous waste management facilities are closed in a manner that minimizes the need for post-closure maintenance, and controls, minimizes, or eliminates po st-closure escape of waste, leachate, contaminated rainfall, or waste decomposition products to ground or surface waters and the atmosphere to the extent necessary to protect human health and the environment.

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FINANCIAL REQUIREMENTS

Section 3004(a) (6) of the Resource Conservation and Recovery Act of 1976 (RCRA), as amended, requires EPA to promulgate regulations that include requirements respecting "the maintenance of operations of such facilities and requiring such addi tional qualifications as to ... financial responsibility (including financial responsibility for correctiv e action) as may be necessary or desirable."

(1) Closure and Post-Closure Financial Assurance Requirements

The need for financial assurance of closure and post-closure care is indicated by the numerous instances of environmental damage resulting from abandonment of hazardous waste management (HWM) facilities and other failures by owners and operators to provide adequately for closure and post-closure care. The likelihood of such failure is increased by th e fact that the costs for closure and post-closure care are expected to commence when the economic value of th e facility is either at a minimum or nonexistent. For most disposal facilities, post-closure care will extend for at least 30 years beyond the operating life of the facility.

EPA believes that significant numbers of owners a nd operators would lack the ability to provide for closure and post-closure care without effective re quirements for financial assurance. Consequently, the Agency developed 40 CFR Parts 264 and 265, Su bpart H financial responsibility requirements for closure and post-closure care. (The requirements in Part 264, Subpart H, are identical to the requirements in Part 265, Subpart H. The remainder of this s upporting statement will use the reference to Subpart H as referring to both the Part 264 and Part 265 financial responsibility requirements.)

(2) Liability Requirements

The liability requirements are designed to assure th at funds will be availa ble during the operating life of a facility from which third parties can seek compensation for bodily inju ry and property damage arising from the operation of the facility. The liabilit y requirements are necessary for several reasons. First, the requirements provide protection to human health and the environment by assuring that funds are available to owners and operators to compensate for damage caused by accidents at hazardous waste facilities, including payments for bodily injury and property damage. In addition, the Agency believes that without liability coverage requirements, ther e would be less public confidence in and greater opposition to proposed and existing hazardous waste faciliti es. The liability requirements also result in other potential benefits for human health and the e nvironment: the incentive, in the form of lower insurance premiums, to improve design and operation of the facility, and the oversight that insurers provide over facility operations.

CONDITIONS APPLICABLE TO ALL PERMITS

EPA promulgated conditions applicable to a ll permits at 40 CFR Part 270, Subpart C. Information collected under this authority is needed to ensure that permittees are complying with permit conditions, and to determine whether cause exists for modifying, revoking and reissuing, or modifying a permit.

2(b) USE AND USERS OF THE DATA

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GENERAL FACILITY OPERATING REQUIREMENTS

(1) Foreign Shipment Import Report, Notice of Appropriate Permit(s), and Notice of Part 264 and Part 270 Requirements

EPA uses foreign shipment import reports to determine the quantities and types of hazardous wastes being imported from abroad. Information in the foreign shipment import report also allows EPA

to determine whether hazardous wastes w ill be safely transported and managed.

Generators use notices of appropriate permits to ensure that their waste is being managed by a permitted facility. Owners and operators of TSDFs mu st keep the notices in the operating record, and these notices may be reviewed by EPA during facility inspections.

New owners and operators use the notice of Part 264 and Part 270 requirements to improve their understanding of applicable regulations.

(2) Waste Analysis, Waste Analysis Plan, Inspection Schedule, and Documentation of Compliance

The waste analysis and waste analysis plan, as well as the inspection schedule and documentation of compliance for ignitable or incompatible wastes, are primarily internal recordkeeping requirements used by owners and operators of facilities to assure th at they can adequately handle incoming waste, to assure that the incoming waste is re ally what the generator claims it to be, and to prevent undetected

releases or reactions of hazardous waste on-site. Much of the information in the waste analysis plan will also be used to provide a qua lity assurance check on both the generator and the owners' and operators'

facilities.

(3) Personnel Training

Both EPA and owners and operators use information in the personn el training records to ensure that personnel acquire the necessary expertise to perfo rm their jobs. During inspections, EPA reviews job descriptions and training documents to determine whet her each person is receiving a level of training that is commensurate with the person's duties and res ponsibilities as well as the ability to respond to any emergency situations at the facility.

RECORDKEEPING REQUIREMENTS

The facility owner or operator uses information included in the operating record and waste disposal location and quantity records to prevent the facility from receiving or placing in proximity wastes that are incompatible or that are likely to i gnite or explode. If an unanticipated release of hazardous waste occurs, the owner or operator may review information in the operating record to determine the composition of the waste. Reviewing information in the operating record facilitates the owner's or operator's selection of an appropriate corrective action and cleanup measure. By providing facility-specific data, the operating record also enab les EPA compliance officials to determine whether operating requirements can be better tailore d to the needs of a particular site.

CONTINGENCY PLAN AND EMERGENCY REPORTING AND RECORDKEEPING REQUIREMENTS

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Local emergency response teams, certain hazardous waste generators, treatment, storage, and disposal facility owners or operators, and EPA use in formation included in the contingency plan to assure an appropriate response to any unplanned release of hazardous waste or hazardous waste constituents. EPA reviews information in the contingency plan an d emergency report to dete rmine whether additional site-specific emergency provisions are necessary.

RELEASES FROM SOLID WASTE MANAGEMENT UNITS

EPA uses data demonstrating compliance with th e ground-water protection standard to ensure that the compliance period can be safely terminat ed. EPA collects and reviews proposed sampling procedures and intervals to ensure that facilities are taking appropriate steps to ensure that any groundwater contamination is detect ed rapidly and effectively.

CLOSURE AND POST-CLOSURE REQUIREMENTS

EPA uses information contained in closure and post-closure plans to determine whether an owner or operator's planned closure and post-closure activ ities will comply with environmental regulations.

EPA officials use information contained in closure cer tifications to ensure that the owner or operator closed his/her facility according to the specifications outlined in the approved closure plan. EPA uses

information contained in demonstrations to ensu re that any activities taking place during the closure period are protective of human health and the envi ronment. Local authorities, EPA, and potential purchasers of a closed facility review information included in post-closure notices to ensure that new owners or operators will not use land in a manner that will lead to a release of hazardous waste into the

environment.

FINANCIAL REQUIREMENT S

The closure, post-closure care, and liability c overage financial instruments submitted by the owner or operator are reviewed by EPA to dete rmine compliance with the applicable Subpart H regulations. This review involves determinations of the validity of the instrument, acceptability of the financial assurance provider, adequacy of the instru ment amount, and fulfillment of the other regulatory requirements. The information is also used to dir ect funds for closure, post-closure care, and liability coverage in the event of default or bank ruptcy of a facility owner or operator.

CONDITIONS APPLICABLE TO ALL PERMITS

EPA uses data collected from permitted facilities to evaluate compliance with the terms of the permit and to decide whether cause exists for modify ing, revoking and reissuing, or terminating the permit. By collecting this information, EPA ensu res that permitted facilities are operating in a manner protective to human health and the environment.

3. NONDUPLICATION, CONSULTATION, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION

Most of the information required by the regulation is not available from any source but the respondents. To avoid duplicating previous work, EPA is allowing respondents to draw upon similar analyses in compiling data for waste analysis and t esting requirements, provided the information meets the requirements specified in the regulations.

3(b) PUBLIC NOTICE

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In compliance with the Paperwork Reduction Ac t of 1995, EPA issued a public notice in the Federal Register on April 5, 2012 (77 FR 20623), and provided a 60 day comment period. One comment

was received from the American Petroleum Institute. API is concerned with the regulations at 40 CFR 264.52(d), 265.52(d), and 267.52(a)(3), which require contact information for all persons qualified to act as emergency coordinator be provide d in the contingency plan. API is concerned with the regulatory language stating that home addresses and home phone numbers are private and it is unnecessary to provide such information since the contingency plan is potentially available to the public. The regulations in question require a home phone number for the em ergency contact, not home address. The issue of home phone numbers being a security concern has been ra ised to the Agency before and we are currently investigating a remedy.

3(c) CONSULTATIONS

The burden hours and cost estimates for this ICR have been well established. However, additional consultations with members of the regulated commun ity were conducted by tele phone with James Allen, US Amines, (251) 829-3820; Brian Stith (Regulator y Contact), Americas Styrenics, (310) 224-5459; Jill Banaszak (Technical Manager), CWM Chemical Se rvices, (716) 286-0295 and others. Based on a comment received for the 1999 ICR, we solicited co mments on the burden of doing waste analyses in the Federal Register (see section 6(d) (4)). No commen ts were received on that item, so the burden has not been changed.



### 3(d) EFFECTS OF LESS FREQUENT COLLECTION

EPA has carefully considered the burden imposed upon the regulated community by the general facility standards. EPA is confident that those ac tivities required of respondents are necessary, and to the extent possible, have attempted to minimize the burden imposed. EPA believes strongly that if the minimum requirements specified under the regulations are not met, neither the facilities nor EPA can ensure that hazardous wastes are being properly mana ged, and do not pose a serious threat to human

health and the environment.

3(e) GENERAL GUIDELINES

In general, the information collection requirement s covered by this ICR adhere to the guidelines stated in the 1995 Paperwork Reduction Act as am ended, OMB's implementing regulations, EPA's Information Collection Review Handbook, and other applicable OMB guidance. However, certain general facility regulations listed below require TSDFs to retain records for more than three years. As explained below, EPA believes that maintenance of these records for longer than three year s meets substantial needs to protect human health and the environment.

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GENERAL FACILITY OPERATING STANDARDS

(1) General Inspection Requirements

The general inspection requirements require the ow ner or operator to keep inspection records at the facility for at least three years from the date of inspection. Keeping inspection records for longer than three years may be advisable to keep track of any l ong standing violations or continued areas of concern regarding potential spills, leaks or mi smanagement of the hazardous wastes.

(2) Personnel Training

Training records on current employees must be kept at the facility until closure of the facility. Records of former employees must be held for at l east three years after the date the employee left the facility. Keeping these records will provide documenta tion of preparations made for handling hazardous waste, and allow the facility to keep up to date on its employee training.

OPERATING RECORD

Owners or operators are required to maintain an operating record at the facility until closure. This record will help ensure compliance with the h azardous waste regulations, and make it easier to locate the cause of any potential hazardous waste leak or spill.

CLOSURE/POST-CLOSURE PLANS

Owners or operators are required to keep a copy of the closure plan at the facility until closure. The owner or operator is also required to keep the certifica tion of closure at the facility until the facility is released from financial assurance requirements for clos ure. These requirements assure that the facility is closing in accordance with the regulations at the least possible risk to human health and the environment.

3(f) CONFIDENTIALITY

Section 3007(b) of RCRA and 40 CFR Part 2, Su bpart B, which define EPA’s general policy on the public disclosure of information, contain provi sions for confidentiality. EPA does not anticipate requesting any confidential information.

3(g) SENSITIVE QUESTIONS

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

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS/NAICS CODES

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

associated with industries most likel y affected by the information co llection requirements covered under

this ICR.

323110 Commercial Lithographic Printing 323114 Quick Printing 325131 Inorganic Dye and Pigment Manufacturing

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325188 All Other Basic Inorganic Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing 331311 Alumina refining 325211 Plastics Material and Resins Manufacturing 32551 Paint and Coating Manufacturing 32511 Petrochemical Manufacturing 32512 Industrial Gas Manufacturing 325188 All Other Inorganic Chemical Manufacturing 325193 Ethyl Alcohol Manufacturing 325199 All Other Basic Organic Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing 311942 Spice and Extract Manufacturing

32411 Petroleum Refineries 332813 Electroplating, Plating, Polishing, Anodizing and Coloring 33271 Machine Shops

332991 All Other Miscellaneous Fabr icated Metal Product Manufacturing 333319 Other Commercial or Service Industry Machinery Manufacturing

Accessories 333999 All Other General Purpose Machinery Manufacturing 336399 All Other Motor Vehicle Part Manufacturing 334 Computer and Electronic Product Manufacturing 336 Transportation Equipment Manufacturing 48422 Specialized Freight (except Used Goods) Trucking, Local

56211 Waste Collection

22111 Electric Power Generation

22112 Fossil Fuel Electric Power Generation 22132 Sewage Treatment Facilities 56292 Materials Recovery Facilities 56221 Waste Treatment and Disposal

42271 Petroleum Bulk Stations and Terminals

45431 Fuel Dealers

4411 Automobile Dealers

4471 Gasoline Stations 811111 General Automotive Repair

4(b) INFORMATION REQUESTED

The following subsections summarize the data ite ms and respondent activities required for each of the information collection requirements discussed in th is ICR. The information collection requirements are divided into seven categories:

 General facility operating requirements;

 Recordkeeping requirements;

 Contingency plan and emergency report ing and recordkeeping requirements;

 Releases from solid waste management units;

 Closure and post-closure requirements;

### 16

 Financial requirements;

 Corrective action management unit requirements; and

 Conditions applicable to all permits.

GENERAL FACILITY OPERATING REQUIREMENTS

(1) Foreign Shipment Import Report

(i) Data items:

Sections 264.12(a) and 265.12(a) require owners or operators th at have arranged to receive hazardous wastes from foreign sources to notify the Regi onal Administrator in writing at least four weeks prior to the expected date of arrival of the shipments at the facility. Data items that should be included in

this notification include:

 Description of the type and quantity of waste to be received;

 Date shipment is expected to arrive; and

 Description of how imported waste will be managed at the facility.

(ii) Respondent activities:

In order to comply with the foreign shipment report requirements, respondents must perform the following activities:

 Read the regulations;

 Collect data; and

 Prepare and submit the notification.

(2) Notice of Appropriate Permits

(i) Data item:

Section 264.12(b) requires the owner or operator of a facility that receives off-site waste to inform the generator in writing that he or she has the appr opriate permits, and will accept, the waste the generator is shipping. This notice must be sent to the generato r before receiving the first shipment of waste. The owner or operator must retain a copy of the notice at the facility.

(ii) Respondent activities:

In order to comply with Section 264.12(b), respondents must perform the following activities:

### 17

 Read the regulations;

 Prepare and submit the one-time notice; and

 Retain a copy of the notice.

(3) Notice of Part 264 and Part 270 Requirements

(i) Data item:

Sections 264.12(c) and 265.12(b) require owners or operators transferring ownership of a facility during its operating life, or of a disposal facility during the post-closure care period, to notify the new owner or operator in writing of the requirements of 40 CFR Part 264 or 265 and Part 270. This notice must be submitted before the transfer in ownership.

(ii) Respondent activities:

In order to comply with sections 264.12(c) and 265.12(b), respondents must perform the following activities:

 Read the regulations; and

 Prepare and submit the notice.

(4) Waste Analysis

(i) Data items:

Sections 264.13(a) (1) and 265.13(a) (1) require an owner or operator to obtain a detailed chemical and physical analysis of any hazardous waste he or she intends to treat, store, or dispose. Sections 264.13(a) (2) and 265.13(a) (2) state that th e analysis may include data, either existing or published, developed under 40 CF R Part 261, as well as existing data on the hazardous waste or hazardous waste generated from similar processes.

(ii) Respondent activities:

In order to comply with sections 264.13(a) (1) and 265.13(a) (1), respondents must perform the following activities:

 Read the regulations;

 Collect data; and

 Perform waste analysis (sampling, testing).

(5) Waste Analysis Plan

(i) Data items:

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Sections 264.13(b)-(c) and 265.13(b)-(c) state that an owner or operator of a hazardous waste facility must develop and follow a written waste analysis plan that describes the procedures to be used in obtaining a detailed chemical and physical analysis of the waste. The owner or operator is required to keep the waste analysis plan at the facility. At a minimum, the plan must include the following

information:

 Parameters for which each hazardous waste w ill be analyzed and the rationale for the selection of these parameters;

 Test methods used to test for the parameters;

 Sampling method used to obtain a representativ e sample of the waste to be analyzed;

 Frequency with which the initial analysis of the waste will be reviewed or repeated to ensure that the analysis is accurate and up to date;

 For off-site facilities, the waste analyses that hazardous waste generators have agreed to supply;

 Where applicable, the methods which will be used to meet additi onal waste analysis requirements for specific waste management methods as specified in §§264.17, 264.314, 264.341, 264.1034(d), 264.1063(d), 265.200, 265.225, 265.252, 265.273, 265.314, 265.341, 265.375, 265.402, 265.1034(d), 265.1063(d), a nd 268.7; For surface impoundments exempted from land disposal restrictions under Section 268.4(a) procedures and schedules for:

-- The sampling of impoundment contents;

-- The analysis of test data;

-- The annual removal of residues which are not delisted under
§260.22 or which exhibit a characteristic of hazardous waste and meet the requirements specified in §§264.13(b)(7)(iii)(A),(B),(B)(1) or (B)(2) and 265.13(b)(7)(iii)(A), (B), (B)(1), or (B)(2); and

 For off-site facilities, the procedures used to inspect and analyze each movement of hazardous waste received at the facility, as required unde r §§264.13(c) and 265.13(c), including:

-- Procedures that will be used to determine the identity of each
movement of waste managed at the facility; and

-- The sampling method which will be used to obtain a representative
sample of the waste to be identified, if the identification method includes sampling.

(ii) Respondent activities:

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Since permitted facilities submit the waste analysis pl an with the Part B permit application, activities associated with developing and modifying the waste anal ysis plan are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifi cations ICR (#1573). However, prior to submitting a permit application, an interim status facility must prep are a waste analysis plan. Therefore, preparation and modification of waste analysis plans for interim status facilities will be discussed in this ICR (#1571). In addition to the development of the plan, this I CR will also focus on activiti es associated with the recordkeeping aspects of the regulations for both permitted and interim status facilities.

To meet the recordkeeping requirement outlined in §§264.13(b) and 265.13(b) , owners or operators must file the waste analysis plan at the facility. Ac tivities associated with developing a waste analysis plan

include:

 Reading the regulations;

 Collecting the data required in the waste analysis plan;

 Writing the waste analysis plan;

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

 Modifying the waste analysis plan (for ne w and existing interim status facilities).

(6) Inspection Schedule

(i) Data items:

Sections 264.15(b)(1) and 265.15(b)(1) require ow ners and operators to develop and follow a written schedule for monitoring equipment that is impor tant in preventing, detecting, or responding to

environmental or human health hazards. At a mini mum, the inspection schedule must include the terms and frequencies called for in §§264.174, 264.194, 264.195, 264.226, 264.253, 264.254, 264.303, 264.347, 264.602, 264.1033, 264.1052, 264.1053, 264.1058, 265.174, 265.193, 265.195, 265.226, 265.347, 265.377, 265.403, 265.1033, 265.1052, 265.1053, and 265.1058 and must identify the types of problems that are to be investigated during the inspection.

Section 264.15(d) and 265.15(d) state that an owner or operator must record inspections conducted according to the written schedule developed pur suant to §§264.15(b)(1) and 265.15(b)(1) in an inspection log or summary that is to be maintained at the facility. The inspection log or summary must contain the following data items:

 Date and time of inspection;

 Name of inspector;

 Notation of the observations made; and

 Date and nature of any repairs or other remedial action.

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(ii) Respondent activities:

Since permitted facilities submit the inspection sch edule with the Part B permit application, activities associated with developing and modifying the schedule are discussed in the Hazardous Waste Part B Permit Applications, Speci al Permits, and Permit Modifications ICR (#1573). Prior to submitting a permit application, interim status facilities must prepare an inspection schedule; preparation of and modification to the inspection schedule for these facil ities will be discussed in this ICR (#1571). This

ICR will also focus on activities associated with the recordkeeping aspects of the regulations for both permitted and interim status facilities.

To meet the requirements outlined in §§264.15(d) and 265.15(d), the owner or operator must conduct the following activities:

 Read the regulations;

 Develop an inspection schedule (new interim status facilities only);

 

### Maintain and modify the inspection sche dule at the facility (new and existing interim facilities only); and

 

### Record problems identified during inspections in the inspection log

(7) Personnel Training

(i) Data items:

Sections 264.16(d) and 265.16(d) require an owne r or operator to maintain copies of personnel training documents and records at the facility. Th ese documents should include the following data items:

 Job title for each position at the facility rela ted to hazardous waste management, and the name of the employee filling each job;

 Written job description for each position, whic h includes the necessary skill, education, or other qualifications and duties of employees assigned to each position;

 Written description of the type and amount of both introductory and continuing training that will be given to each person filling a pos ition; and records that document that the training or job experience required have b een given to, and completed by, facility personnel.

(ii) Respondent activities:

Respondent activities associated with Sec tions 264.16(d) and 265.16(d) include:

 Reading the regulations;

 Collecting the data items listed above; and

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 Maintaining (e.g., photocopying and filing) the information at the facility.

(8) Documentation of Compliance for Ignitable, Reactive, or Incompatible Wastes

(i) Data items:

Section 264.17(c) states that the owner or opera tor of a hazardous waste facility must take precautions to prevent accidental ignition or reacti on of ignitable or reactive waste. The owner or operator of a permitted facility must document complia nce with the requirements outlined in §§264.17(a) and (b). The documentation may be based on referen ces to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (as specified in §264.13), or the results of the treatment of similar wastes by si milar treatment processes and under similar operating

conditions.

(ii) Respondent activities:

Respondent activities associated with Section 264.17(c) include:

 Reading the regulations;

 Collecting and documenting the data items mentioned above; and

 Maintaining (e.g., photocopying and filing) documentation at the facility.

(9) Construction Quality Assurance Plan

(i) Data items:

Section 265.19(b) requires any owner or operato r of an interim status surface impoundment, waste pile, or landfill to develop a written constructio n quality assurance (CQA) plan that identifies steps that will be used to monitor and document the qualit y of materials and the condition and manner of their installation. [Permitted facilities must also devel op a CQA plan for surface impoundments, waste piles, and landfills. Activities associated with CQA plans at permitted facilities are burdened in the Part B Permit Application, Permit Modifications, and Special Permits ICR, #1573.] The CQA plan must include the following information:

 Identification of applicable units, and a descr iption of how they w ill be constructed;

 Identification of key personnel in the deve lopment and implementation of the CQA plan, and CQA officer qualifications;

 A description of inspection and sampling ac tivities for all unit components, including

observations and tests that will be used befo re, during, and after c onstruction to ensure

that the construction materials and th e installed unit components meet design specifications. This description must cover:

- Sampling size and locations;

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- Frequency of testing;

- Data evaluation procedures;

- Acceptance and rejection criteria for construction materials;

- Plans for implementing corrective measures; and

- Data or other information to be recorded and retained in the operating record under §265.73.

The owner or operator also must prepare and submit a certification signed by the CQA officer at least 30 days prior to receiving waste that the CQA plan has been successfully carried out and that the unit meets the requirements of §§265.221(a), 265.254, or 265.301(a).

(ii) Respondent activities:

In order to comply with Section 265.19, owners and operators must:

 Read the regulations;

 Prepare the CQA plan;

 Prepare the certification;

 Submit materials to EPA; and

 Maintain records of the materials.

RECORDKEEPING REQUIREMENTS

(1) Operating Record Requirements

(i) Data items:

Sections 264.73 and 265.73 outline specific ope rating recordkeeping requirements that are imposed on TSDFs. This ICR covers the requireme nts found at §264.73(b) (1)-(16) and §265.73(b) (1)- (16), which state that the operating record must contain the following data items:

 A description and the quantity of each hazardous waste received, and the method(s) and date(s) of its treatment, storage, or disposal at the facility as required by Appendix I;

 The location of each hazardous waste within the facility and the quantity at each location. For disposal facilities, the location and quantity of each hazardous waste must be recorded on a map or diagram of each cell or disposal area;

 Records and results of waste analyses performed;

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 Summary reports and details of all incident s that require implementing the contingency plan;

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

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

 Copies of written notices (for off-site facilities) certifying that the facility is permitted and will accept the waste the generator is shipping;

 Closure cost estimates and, for disposal facilities, post-closure cost estimates;

 A certification by the permittee, no less often than annually, that the permittee has a program in place to reduce the volume and toxicity of hazardous waste that he generates to the degree determined by the permittee to be economically practicable; and the proposed method of treatment, storage, or di sposal that is the practicable method currently available to the permittee which minimizes the present and future threat to human health and the environment;

 Records of the quantities (and date of place ment) for each shipment of hazardous waste placed in land disposal units under an extension to the effective date of any land disposal restriction, or a certification, and the applicable notice required by a generator;

 Documents stating refusal of State or local authorities to enter into arrangements to address emergency situations;

 Records of hazardous waste application dates and rates; and

 Maps detailing (1) the exact location, dimensions , and depths of each cell with respect to permanently surveyed benchmarks, and (2) th e contents of each cell and the approximate location of each hazardous waste type within each cell.

(ii) Respondent activities:

In order to comply with sections 264.73 a nd 265.73, 264.37, 264.279 and 265.279, and 264.309 and 265.309, owners or operators are required to maintain a written operating record at the facility. Respondent activities associated with maintaining an operating record include maintaining (e.g., photocopying and filing) the data items listed above.

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(2) Other Recordkeeping and Reporting Requirements

Sections 264.74(c) and 265.74(c) require owne rs or operators to submit to the Regional Administrator and local land authority a copy of th e records of waste disposal locations and quantities under §§264.73(b)(2) and 265.73(b)(2) upon closure of the facility. Since this information is submitted upon closure of the facility, data items and respondent activities are included in the closure/post-closure

section.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS

(1) Contingency Plan Requirements

(i) Data items:

Sections 264.51 and 265.51 require owners or operators to have a contingency plan for their facilities and sections 264.53(a) and 26 5.53(a) require the owner or operator to maintain a copy of an updated contingency plan at the facility. Sections 264. 52 and 265.52 outline the data elements that should be included in this plan:

 A description of the arrangements agreed to by local police departments, fire departments, hospitals, contractors, and St ate and local emergency response teams to coordinate emergency services;

 An updated list of the names, addresses, a nd phone numbers (office and home) of all persons qualified to act as emergency coordinators;

 An updated list of all emergency equipment at the facility and the location, physical description, and capabilities of the emergency equipment. The contingency plan should also indicate where the emergency equipment will be required; and

 An evacuation plan for facility personnel wh ere there is a possibility that evacuation may be necessary.

In addition, sections 264.53(b) and 265.53(b) re quire owner/operators to submit a copy of the contingency plan and all revisions to all local police departments, fire departme nts, hospitals, and State and local emergency response teams that may be called upon to provide emergency services.

(ii) Respondent activities:

Since permitted facilities submit the contingency plan with the Part B permit application, activities associated with developing and modifying th e contingency plan are discussed in the Hazardous Waste Part B Permit Applications, Special Permits , and Permit Modifications ICR (#1573). Interim status facilities must prepare contingency plans pr ior to submitting a permit application; therefore, preparation of the contingency plan for these facilities is covered under this ICR (#1571). This ICR also includes submittal of the plan to State and local authorities and recordkeeping activities for both permitted and interim status facilities.

In order to comply with contingency plan requi rements, owners or operators are required to perform the following activities:

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 Read the regulations;

 Collect the data required in the contingency plan;

 Write the contingency plan (new interim status facilities only);

 Submit the contingency plan to State and local authorities;

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

 Amend the contingency plan when appropriate.

[Although permitted and interim-status facilities must comply with appropriate requirements for amending a contingency plan, this ICR addresses only in terim status facilities amending their plans. As mentioned, permitted facilities amending their plan s must comply with sections 264.54 and submit a permit modification under section 270.42. These perm itted facilities are addressed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications, ICR #1573].

(2) Emergency Reporting and Recordkeeping Requirements

(i) Data items:

Sections 264.56(a) (2) and 265.56(a) (2) require owners and operators to immediately notify State and local authorities with designated response rol es of an imminent or actual emergency situation. Sections 264.56(d)(1) and 265.56(d)(1) require owners and opera tors to notify local authorities if his or her assessment of a release, fire, or explosion indi cates that evacuation of local areas may be advisable.

Sections 264.56(d) (2) and 265.56(d) (2) require th e facility emergency coordinator to notify the on-scene coordinator or the National Response Center of any release, fire, or explosion that could threaten human health or the environment outside the facility. The emergency notification report must include the following information:

 Name and telephone number of reporter;

 Name and address of facility;

 Time and type of incident;

 Name and quantity of material(s) involved;

 The extent of injuries; and

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

Sections 264.56(i) and 265.56(i) state that th e owner or operator should notify the Regional Administrator and appropriate State and local author ities that their facility is in compliance with §§264.56(h) and 265.56(h) before resuming operations in the affected area(s) of the facility.

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Within 15 days of the incident, owners and ope rators are required, under Sections 264.56(j) and 265.56(j) to submit a written report ("owner/operator emergency report") on the incident to the Regional Administrator. The report must include the following data items:

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

 Name, address, and telepho ne number of the facility;

 Date, time, and type of incident;

 Name and quantity of material(s) involved;

 The extent of injuries;

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

 Estimated quantity and dispositi on of recovered material that resulted from the incident.

(ii) Respondent activities:

In order to comply with the reporting requiremen ts of §264.56(a) (2) and §265.56(a) (2), owners and operators must perform the following activities:

 Submit the required notification of an immine nt or actual emergency situation to State

and/or local authorities.

In order to comply with the reporting require ments of §264.56(d) (1) and §265.56(d) (1), owners and operators must perform the following activities:

 Notify local authorities of the owner or op erator's recommendation to evacuate local

areas.

In order to comply with the reporting require ments of §264.56(d) (2) and §265.56(d) (2), owners and operators must perform the following activities:

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

In order to prepare an emergency repor t under §264.56(d) (2) and §265.56(d) (2), emergency coordinators must conduct the following activities:

 Collect the information required in the emergency report; and

 Write the emergency notification report.

In order to prepare an owner/operator's em ergency report under §264.56(j) and §265.56(j), owners and operators must conduct the following activities:

 Read the regulations;

### 27

 Collect the information required in the emergency report; and

 Prepare and submit the emergency report.

In addition to preparing an emergency report, the owner or operator must notify the Regional Administrator that the facility is in complian ce with §§264.56(h) and 265.56(h) before resuming operations in affected areas of the facility. In orde r to comply with this requirement, respondents must conduct the following activities:

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

### 28

 Prepare and submit a letter notifying the Re gional Administrator of this compliance.

Sections 264.56 and 265.56 require the owner/operator to note in the operating record the time, date, and details of any incident that requires implementing the contingenc y plan (§§264.56(j) and 265.56(j)). Respondent activities associated with this requirement are burdened in the respondent activity section for the operating record requirements.

RELEASES FROM SOLID WASTE MANAGEMENT UNITS

(1) Termination of Compliance Period

(i) Data item:

Section 264.96(c) extends the compliance period for facilities that are engaged in corrective action. Owners and operators of these facilities must demonstrate, with monitoring data, that the groundwater protection standard of §264.92 has not been ex ceeded for a period of three consecutive years to complete the compliance period.

(ii) Respondent activities:

In order to comply with section 264.96(c), ow ners and operators must perform the following

activities:

 Read the regulations; and

 Prepare the monitoring data and submit it to EPA.

(2) Sampling Procedures and Intervals

(i) Data items:

Section 264.97(g) requires owners and operators conducting detection monitoring and compliance monitoring to determine an appropriate sampling pr ocedure and interval for each hazardous constituent listed in the facility permit. The sampling procedure must include:

 A sequence of at least four samples, taken at an interval that assures, to the greatest extent technically possible, that an independent sample is obtained, by reference to the uppermost aquifer's effective porosity, hydrau lic conductivity, and hydraulic gradient, and the fate and transport characteristi cs of the potential contaminants; or

### 29

 An alternative sampling procedure proposed by the owner or operators and approved by

EPA.

(ii) Respondent activities:

In order to comply with section 264.97(g), ow ners and operators must perform the following

activities:

 Read the regulations; and

 

### Develop an appropriate sampling pro cedure and interval, and submit this information to EPA for approval.

CLOSURE AND POST-CLOSURE REQUIREMENTS

(1) Closure Plan

(i) Data items:

Sections 264.112(a) and 265.112(a) state that an owner or operator must have a written closure plan. The closure plan must include the following data items:

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

in accordance with §§264.111 a nd 265.111;

 A description of how final closure of the f acility will be conducted in accordance with §§264.111 and 265.111. The description must identify the maximum extent of operations which will be unclosed during the active life of the facility;

 An estimate of the maximum inventory of hazardous wastes ever on-site over the active life of the facility. This should include a de tailed description of the methods to be used during partial closures and final closure such as methods for removing, transporting, treating, storing, or disposing of all hazardous wastes, and identification of the type(s) of off-site hazardous waste management un its to be used, if applicable;

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

waste residues and contaminated containment system components, equipment, structures, and soils during partial and final closure;

 A detailed description of other activities necess ary during the closure period to ensure that all partial closures and final closure satisfy the closure performance standards, including ground-water monitoring, leachate co llection, and run-on and run-off control;

 A schedule for closure of each hazardous waste management unit and for final closure of the facility. The schedule must include, at a minimum:

-- The total time required to close each hazardous waste
management unit; and

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-- The time required for intervening closure activities which will allow tracking of the progress of partial and final closure; and

 For facilities that use trust funds to est ablish financial assura nce under §§264.143 and 265.143, or 264.145 and 265.145, and that are expected to close prior to the expiration of the permit, an estimate of the expected year of final closure.

Certain permitted surface impoundments and waste piles from which the owner or operator

intends to remove or decontaminate the hazardous w aste at partial or final closure are required by Sections 264.228(c)(1)(ii) and 264.258(c)(1)(ii) to have c ontingent closure plans. In addition, owners or operators of tank systems or drip pads that intend to remove or decontaminate hazardous waste at partial or final closure are required to submit contingent cl osure plans as specified in sections 264.197(c)(1) and 265.197(c)(1), and 264.575(c)(1)(i)and 265.445(c)(1)(i), respectively.

(ii) Respondent activities:

Since permitted facilities submit the closure plan and contingency closure plans with the Part B permit application, activities associated with devel oping and modifying the closure plan are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (#1573). Prior to submitting a permit application, inte rim status facilities must prepare a closure plan. Therefore, preparation of and modification to the clos ure plan for interim status facilities will be covered in this ICR (#1571). This ICR will also include activ ities associated with the r ecordkeeping aspects of the regulations for both permitted and interim status facilities.

Maintaining the closure plan at the facility is the only respondent activity associated with the recordkeeping aspects of this regulation. Respondent activities associated with developing a closure plan

include:

 Reading the regulations;

 Conducting an inventory of the hazardous waste present;

 Recording results of inventory;

 Writing descriptions for the necessary activities;

 Estimating final closure; and

 Writing the closure schedule.

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(2) Notification and Amendment of Closure Plan

(i) Data items:

Permit modifications for permitted facilities under section 264.112(c) are included in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modi fications ICR (#1573). Under section 265.112(c), owners or op erators of interim status facilities may amend the closure plan at any time prior to notification of partial or final clos ure of the facility. An owner or operator with an approved closure plan must submit a written request to EPA to authorize a change in the approved closure plan. The owner or operator must amend the closure plan at least 60 days prior to the proposed change in the facility design or operation, or no later than 60 days after an unexpected ev ent has occurred which has affected the closure plan. An owner or operator w ith an approved closure plan must submit the amended plan to EPA.

(ii) Respondent activities:

Interim status facilities with approved closure plans must prepare and submit a notification of amendment, amend the plan, and submit the plan to EPA, pursuant to section 265.112(c).

(3) Partial Closure and Final Closure Notification

(i) Data items:

Under Section 264.112(d)(1), owne rs or operators of permitted facilities must notify the Regional

Administrator of imminent closure intentions. Sec tion 265.112(d)(1) requires owners or operators of interim status facilities with approved closure plans to notify EPA of closure in writing within a specified period of time before closure of the unit. Section 265.112(d)(1) also requires owners or operators of interim status facilities to submit a closure plan to the Regional Administrator prior to closure. In addition, section 265.112(d )(3) requires owners or operators of interim status facilities to submit the closure plan to the Regional Administrator no later th an 15 days after termination of interim status.

(ii) Respondent activities:

Under section 264.112(d)(1) or 265. 112(d)(1) permitted and interim status facilities must prepare

and submit a notification to EPA of imminent closure. Interim status facilities also must submit a closure plan under section 265.112(d)(1) or 265.112(d)(3).

(4) Extensions and Allowances During the Closure Period

(i) Data items:

Under 40 CFR 264.113 and 265.113, owners and operators may prepare demonstrations in support of certain extensions and allowances duri ng the closure period. Sections 264.113(a) and 265.113(a) allow owners and operators to request an ex tension for the treatment, storage, or removal of hazardous waste. To receive such an extension, th e owner or operator must request a permit modification and demonstrate the following:

 Treatment, storage, and removal activities will, of necessity, take longer than 90 days to complete; or

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 The hazardous waste management unit or fac ility has the capacity to receive additional hazardous or non-hazardous wastes; there is a likelihood that operations will be recommenced within one year; and closure of the unit would be incompatible with continued operation of the site; and

 The owner or operator has taken and will conti nue to take all steps necessary to prevent threats to human health and the environment, including compliance with all applicable permit requirements.

Sections 264.113(b) and 265.113(b) allow owners and operators to request an extension of the closure period. To receive such an extension, th e owner or operator must request a permit modification and demonstrate the following:

 Partial of final closure activities will, of necessity, take longer than 180 days to complete;

or

 The hazardous waste management unit or fac ility has the capacity to receive additional hazardous or non-hazardous wastes; there is a reasonable likelihood that operations will be recommenced within one year; and closur e of the unit would be incompatible with continued operation of the site; and

 The owner or operator has taken and will conti nue to take all steps necessary to prevent threats to human health and the environment, including compliance with all applicable permit requirements.

Sections 264.113(d) and 265.113(d) allow owners and operators to request an allowance to receive only non-hazardous wastes in a landfill, land treatment, or surface impoundment unit after the final receipt of hazardous waste. To receive such an allowance, the owner or operator must request a permit modification, and include the foll owing demonstrations and information:

 The unit has the existing design capacity as indi cated on the part A application to receive non-hazardous wastes;

 There it a reasonable likelihood that operati ons will be recommenced within one year after the final receipt of hazardous wastes;

 The non-hazardous wastes will not be incompatib le with any remaining wastes in the unit or facility;

 Closure of the unit would be incompatible with continued operation of the site;

 The owner or operator is operating and will c ontinue to operate in compliance with all applicable permit requirements;

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 The request to modify the permit includes an amended waste analysis plan, ground-water monitoring and response program, human expos ure assessment, closure and post-closure plans, updated cost estimates and demonstrations of financial assurance for closure and post-closure care, and changes in closure activities.

(ii) Respondent activities:

The burden associated with developing a permit mo dification for such an extension or allowance is addressed in the Hazardous Waste Part B Permit Application, Permit Modifications, and Special Permits ICR (#1573). Other respondent activities asso ciated with obtaining an extension or allowance include the following:

 Reading the regulations;

 Preparing and submitting the demonstration for an extension for treatment, storage, or removal of hazardous waste;

 Preparing and submitting the demonstration for an extension of the closure period; and

 Preparing and submitting the demonstration for receiving non-hazardous wastes.

(5) Closure Certification

(i) Data items:

Sections 264.115 and 265.115 require owners or operators to submit to the Regional Administrator a certification that the unit or facility has been closed in accordan ce with the specifications in the approved closure plan. Documentation s upporting the independent registered professional engineer's certification must be furnished to the Re gional Administrator upon request before he or she releases the owner or operator from the financial assurance requirements for closure under §§264.143(i) and 265.143(h).

(ii) Respondent activities:

In order to certify that the unit or facility has b een closed in accordance w ith the specifications in the approved closure plan, respondents must perform the following activities:

 Read the regulations;

 Have a registered professional engineer inspect the facility; and

 Collect documentation to support the certif ication and submit the certification.

(6) Survey Plat

(i) Data item:

Sections 264.116 and 265.116 require an owne r or operator to submit to the Regional Administrator a survey plat indicating the location and dimensions of landfill cells or other hazardous waste disposal units with respect to permanently surveyed benchmarks.

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(ii) Respondent activities:

In order to comply with §2 64.116 and §265. 116, respondents must have a professional land surveyor prepare and certify a survey plat, and submit the plat to the Regional Administrator.

(7) Post-Closure Plan

(i) Data items:

Sections 264.118(a) and 265. 118(a) state that the owner or operator of a hazardous waste disposal facility must have a written post-closure plan. Surface impoundments and waste piles from which the owner or operator intends to remove or decontaminate the hazardous waste at partial or final closure are required by §§264.228(c)(1)(ii) and 264.258(c)(1)(ii) to have contingent post-closure plans submitted with the Part B permit application. In addition, owners or operators of tank systems or drip pads that

intend to remove or decontaminate the hazardous waste at partial or final closure are required to submit a contingent post-closure plan, as specified in sections 264.197(c)(2) and 265.197(c)(2), and 264.575(c)(1)(ii) and 265.445(c)(1)(ii), respectively. Section 265.118 requires owners or operators to maintain a copy of the post-closure plan at the facility.

Data items included in the post-closure plan are listed below:

 A description of the facility's monitoring activities and frequencies at which they will be performed to comply with Subparts F, K, L, M, N, and X during the post-closure care period;

 A description of the planned maintenance activ ities, and frequencies at which they will be performed;

 The name, address, and phone number of th e person or office to contact about the hazardous waste disposal unit or facility during the post-closure care period; and

 A copy of the approved post-closure plan, to be provided to the Regional Administrator upon request, until final closure of the facility.

(ii) Respondent activities:

Since permitted facilities submit post-closure and co ntingent post-closure plans with the Part B permit application, activities associated with deve loping these post-closure plans are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modi fications ICR (#1573). Prior to submitting a permit, interim status facilities must develop a post-closure plan. Therefore, preparation of these plans for interim status facilities will be covered in this IC R (#1571). This ICR will

also focus on activities associated with the recordkeeping aspects of the regulations for both permitted

and interim status facilities.

Section 265.118(e) requires an interim status f acility owner or operator to submit a post-closure plan to the Regional Administrator no later than 15 days after termination of interim status, except when a permit is issued simultaneously with termination of in terim status, or the facility is issued a judicial decree or final order under §3008 of RCRA to cease r eceiving hazardous wastes or close. If the Regional

### 35

Administrator does not approve the plan, the owner or operator must modify the plan or submit a new plan for approval.

In order to comply with the post-closure plan requirements, respondents must perform the following activities:

 Read the regulations;

 Collect the necessary information;

 Prepare and submit the post-closure plan or c ontingent post-closure plan, if applicable (new interim status facilities only); and

 Maintain the plan.

(8) Notification and Amendment of Post-Closure Plan Under 265.118(d)(1)-(3)

(i) Data items:

Section 265.118(d)(1)-(3) requires owners or opera tors of interim status facilities to submit written requests to authorize changes to approved post closure plans, and requires submittal of modified plans to the Regional Administrator. Under secti on 264.118(d)(1)-(3), permitted facilities must request permit modifications to authorize and make chang es to approved post-closure plans. Such permit

modifications are included in ICR #1573.

(ii) Respondent activities:

Interim status facilities must:

 Prepare a notification of amendment;

 Amend the plan; and

 Submit these data items to EPA, as re quired by section 265.118(d)(1)-(3).

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(9) Amendment of Post-Closure Plan Under 265.118(d)(4), (f), and (g)(1)

(i) Data items:

Under 40 CFR 265.118(d)(4), if the Regional Admini strator determines that an owner or operator of a surface impoundment or waste pile who intended to remove all hazardous wastes at closure must close the facility as a landfill, the owner or operator must submit to the Regional Administrator within 90 days of the determination a post-closure plan fo r approval. If the Regional Administrator requests modifications to the plan, the owner or operator must submit the modified plan no later than 60 days after the Regional Administrator's request or no later than 90 days if the unit is a surface impoundment or waste pile not previously required to prepare a contingent closure plan.

Under section 265.118(f), if the Regional Administrato r does not approve the plan, he or she must provide the owner or operator with a detailed written st atement of reasons for the refusal. The owner or operator must modify the plan or submit a new plan w ithin 30 days after receiving such written statement.

Under section 265.118(g)(1), the owner or operato r may prepare and submit a petition to the Regional Administrator to extend or reduce the pos t-closure period applicable to a hazardous waste management unit or facility, or to alter the requirements of the post-closure care period.

(ii) Respondent activities:

In order to comply with sections 265.118(d)(4 ) and 265.118(f), respondents must perform the following activities:



###  Prepare an amended post-closure plan;

 Submit the amended plan to EPA; and

 Modify and resubmit plan, if not approved by EPA

In order to obtain an extension or reduction of the post-closure period, per section 265.118(g)(1), respondents must prepare a petition and submit it to EPA. (Permitted facilities are covered in the Hazardous Waste Part B Permit Applications, Speci fic Permits and Permit Modifications ICR, #1573.)

(10) Hazardous Waste Disposal Records

(i) Data items:

Sections 264.119(a) and 265.119(a) require owners or operators to submit to the local zoning authority, or to the authority with jurisdiction ove r local land use, and to the Regional Administrator a record of the type, location, and quantity of hazar dous wastes disposed of within each cell or other disposal unit of the facility.

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(ii) Respondent activities:

In order to comply with sections 264.119(a) and 265.119(a), respondents must perform the following activities:

 Determine the specifications of the hazardous waste activity; and

 Establish, submit, and maintain (i.e., photocopying and filing) a record of the activity.

(11) Hazardous Waste Notation Certification

(i) Data items:

Sections 264.119(b)(2) and 265.119(b)(2) require owne rs or operators to submit to the Regional Administrator a signed certification that they have recorded the notation required in §§264.119(b)(1) and 265.119(b)(1), including a copy of the docume nt in which the notation has been placed.

(ii) Respondent activities:

In order to comply with sections 264.119(b)(2) and 265.119(b)(2), respondents must record the notation on the deed, and develop and submit the certification to the Regional Administrator.

(12) Post-Closure Permit Modification

(i) Data items:

Sections 264.119(c) and 26 5.119(c) state that if an owner wishes to remove hazardous wastes and residues, liners, or contaminated soils, he or she must request a modification to the post-closure permit

and demonstrate that removal of hazardous waste will satisfy the criteria of §§264.117(c) and 265.118(g). For permitted facilities, the modification will be done through the permit modification process and will be covered by the Hazardous Waste Part B Permit App lications, Special Permits, and Permit Modifications ICR (#1573).

(ii) Respondent activities:

Respondent activities associated with modification of the post-closure permit include:

 Reading the regulations;

 Preparing a request for modification; and

 Demonstrating compliance through a writte n document or some other form of

notification.

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(13) Post-Closure Care Certification

(i) Data items:

Sections 264.120 and 265.120 state that owners or operators must submit to the Regional Administrator a certification that the post-closure care period for the facility was performed in accordance with the specifications in the approved closure plan. Documentation supporting the independent registered professional engineer's certification must be furnished to the Regional Administrator upon request before he or she releases the owner from the financial assurance requirements for closure under §§264.145(i) and 265.145(h).

(ii) Respondent activities:

Respondent activities associated with certifying completion of post-closure care include:

 Reading the regulations;

 Obtaining certification of compliance from an independent registered professional engineer;

 Maintaining a copy of the certification; and

 Submitting the necessary documentation to th e Regional Administrator as required.

FINANCIAL REQUIREMENTS

(1) Financial Responsibility for Corrective Action

(i) Data item:

Sections 264.101(b) and 264.101(c) require owners and operators of facilities containing solid waste management units (SWMUs) to institute corr ective action as necessary, and to provide assurances of financial responsibility for completing such corr ective action. This assurance must contain the

documented assurances of financial responsibility in the permit for the means of corrective action chosen.

(ii) Respondent activity:

In order to comply with sections 26 4.101(b) and 264.101(c), respondents must prepare and submit to the Regional Administrator, with the permit, documented assurances of financial responsibility for the corrective action chosen to be implemented.

(2) Cost Estimates for Cl osure and Post-Closure Care

(i) Data items

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Sections 264.142, 265.142, 264.144, and 265.144 requ ire owners and operators to maintain a detailed written estimate of the cost of facility clos ure or post-closure care, in accordance with the requirements specified in §§264.142(a), 265.142(a), 264.144(a), and 265.144(a), respectively. Section 264.144 only applies to owners or ope rators of disposal surface imp oundments, disposal miscellaneous units, land treatment units, or landfill units, or owne rs or operators of surface impoundments or waste piles required to prepare contingency closure and pos t-closure plans, while Section 265.144 applies to owners or operators of interim status hazardous w aste disposal units. These estimates must include the following data items:

 A written estimate containing:

-- The costs of final closure at the point in the facility's active life

when the extent and manner of its operation would make closure the most expensive, as indicated by its closure plan (§§264.142(a)(1) and 265.142(a)(1)); or

-- The annual cost of post-closure monitoring and maintenance of the
facility in accordance with the a pplicable post-closure regulations specified in §§264.144(a) and 265.144(a);

 Estimates of the following cost, as required under §264.258(c)(2) for waste piles only:

-- The cost of complying with the contingent closure plan or the
contingent post-closure plan, but not the cost of expected closure under §264.258(c)(2);

 Estimates of the following cost, as required under §§264.197(c)(3) and 265.197(c)(3) for tank systems only:

-- The cost of complying with the contingent closure plan and the
contingent post-closure plan, if tho se costs are greater than the costs of complying with the closure plan prepared for the expected closure under §§264.197(a) and 265.197(a).

 Estimates of the following cost, as re quired under §264.228(c)(2) for surface impoundments, §§264.575(c)(2) and 265.445(c)(2) for drip pads, and §264.258(c)(2) for waste piles:

-- The cost of complying with the contingent closure plan and the
contingent post-closure plan, but not the cost of expected closure under §§264.228(a) for surface impoundment s, 264.575(a) or 265.445(a) for drip pads, and 264.258(a) for waste piles.

 Costs to owners or operators of hiring a thir d party to conduct closure or post-closure care at the facility;

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 An adjustment of the closure or post-closure cost estimate for inflation within sixty days of the anniversary date of the establishment of the financial instrument(s) used to assure financial responsibility for closure (thirty days in the case of owners or operators using the financial test or corporate guarant ee)(§§264.142(b), 265.142(b), 264.144(b), and 265.144(b)); and

 A revision of the closure or post-closure cost estimate no later than thirty days after a

modification has been made to the closur e or post-closure plan which increases the closure or post-closure cost (§§264.142( c), 265.142(c), 264.144(c), and 265.144(c)).

(ii) Respondent activities:

Owners and operators will need to engage in several activities in order to collect and maintain the data required by §§264.142, 265.142, 264.144, and 265.144:

 Reading the regulations;

 Collecting data;

 Preparing the written cost estimate;

 Periodically adjusting the cost estimate to incl ude inflation and/or revisions to the closure or post-closure plan; and

 Maintaining at the facility the latest closure or post-closure cost estimate and any subsequent adjustments.

(3) Financial Assurance for Cl osure and Post-Closure Care

Owners or operators are required to establish a nd provide evidence of financial assurance for facility closure (§§264.143 and 265.143) and post- closure care (§§264.145 a nd 265.145). Several financial instruments are described throughout th ese sections for the purpose of establishing financial

assurance:

(a) Closure or Post-Closure Trust Fund

(i) Data items:

Sections 264.143(a), 265.143(a), 264.145(a), and 265.145(a) explain that owners or operators may establish a closure or post-closure trust fund in order to comply with §§264.143, 265.143, 264.145, and 265.145 requirements. Data items for estab lishing and providing evidence of a closure or postclosure trust fund include:

 A trust agreement in compliance with §§264 .143(a)(2)-(8) and (10), 265.143(a)(2)-(8) and (10), 264.145(a)(2)-(8) and (11) , and 265.145(a)(2)-(8) and (11); and

 For post-closure trust funds, a formal ce rtification of acknowledgment (§§264.145(a)(2) and 265.145(a)(2)).

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(ii) Respondent activities:

Owners and operators establishing a trust fund in order to comply with the closure and postclosure financial assurance requirements of sections 2 64.143, 265.143, 2 64.145, and 265.145 will need to engage in the following respondent activities:

 Reading the regulations;

 Establishing a closure or post-closure trus t fund, in compliance with §§264.143(a)(2)-(8) and (10), 265.143(a)(2)-(8) and (10), 264.145(a)(2)-(8) and (11), and 265.145(a)(2)-(8) and (11);

 Submitting an originally signed duplicate of the trust agreement to the EPA Regional Administrator (owners or operators of new f acilities must submit this at least sixty days prior to receiving hazardous waste for treatment, storage, or disposal);

 Submitting the formal certification of acknow ledgment required for post-closure trust funds; and

 For owners and operators of new facilities, submitting a receipt for the first payment under the trust agreement before the initial receipt of hazardous wastes.

(b) Surety Bond Guaranteeing Payment into a Closure or Post-Closure Trust

Fund

(i) Data items:

Sections 264.143(b), 265.143(b), 264.145(b), and 265.145(b) allow owners and operators to establish surety bonds in order to comply with the financial assurance requirements of Sections 264.143, 265.143, 264.145, and 265.145. Establishing surety bonds that guarantee payment into a closure or postclosure trust fund will entail the co llection of the following data items:

 A surety bond and trust agreement indicating the conditions of payment into the closure or post-closure standby trust fund speci fied in §§264.143(b)(2)-(6) and (8), 265.143(b)(2)-(6) and (8), 264.145(b)(2)-(6) and (8), and 265.145(b)(2)-(6) and (8); and

 Evidence of an increase or decrease in the clos ure or post-closure cost estimate that may require the penal sum of the surety bond to be increased or decreased accordingly (§§264.143(b)(7), 265.143(b)(7), 264.145(b)(7), and 265.145(b)(7)).

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(ii) Respondent activities:

In collecting these data items, owners and oper ators will need to engage in the following respondent activities:

 Reading the regulations;

 Establishing a surety bond and trust agreemen t that comply with the financial assurance requirements of §§264.143, 265.143, 264.145, and 265.145;

 Submitting originally signed duplicates of the surety bond and trust agreement to the Regional Administrator (for new facilities, these must be submitted at least sixty days before receiving hazardous waste for disposal);

 Submitting evidence of and obtaining approval from the Regional Administrator for alternate financial assurance mechanisms, in the case of cancellation of the bond by the

surety;

 Increasing the penal sum amount, in the case of an corresponding increase in the closure or post-closure cost estimate; and

 Submitting evidence of such an increase in th e closure or post-closure cost estimate to the Regional Administrator.

(c) Surety Bond Guaranteeing Performance of Closure or Post-Closure Care

(i) Data items:

Sections 264.143(c) and 264.145(c) allow owners or operators of permitted facilities to comply with §§264.143 and 264. 145 requirements by obtaining a surety bond that guarantees performance of closure or post-closure care. Da ta items for this option include:

 A surety bond and trust agreement indicating the conditions of payment into the standby trust fund specified in §§264.143(c)(2)-(6) a nd (8) and 264.145(c)(2)-(6) and (9); and

 Evidence of an increase in the closure or post- closure cost estimate that may require the penal sum of the surety bond to be increased or decreased accordingly (§§264.143(c)(7) and 264.145(c)(7)).

(ii) Respondent activities:

In collecting these data items, owners and oper ators will need to engage in the following respondent activities:

 Reading the regulations;

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 Obtaining a surety bond and trust agreement that comply with the financial assurance requirements of §§264.143 and 264.145;

 Submitting originally signed duplicates of the surety bond and trust agreement to the Regional Administrator (for new facilities, these must be submitted at least sixty days prior to receiving hazardous wastes for disposal);

 Submitting evidence of and obtaining approval from the Regional Administrator for alternate financial assurance mechanisms, in the case of cancellation of the bond by the

surety;

 Increasing the penal sum amount, in the case of a corresponding increase in the closure or post-closure cost estimate; and

 Submitting evidence of such an increase in the closure or post-closure cost estimate to the Regional Administrator.

(d) Closure or Post-Closure Letter of Credit

(i) Data items:

Sections 264.143(d), 265.143(c), 264.145(d), and 265.145(c) specify that owners or operators may obtain an irrevocable standby letter of credit in order to satisfy financial assurance requirements.

Data items for this information collection include:

 A letter of credit from an issuing institution authorized to issue letters of credit and whose letter-of-credit operations are regulat ed and examined by a Federal or State

agency;

 A trust agreement indicating the conditions of payment into the standby trust fund specified in §§264.143(d)(2)-(4) and (6), 265 .143(c)(2)-(4) and (6), 264.145(d)(2)-(6), and 265.145(c)(2)-(6);

 Notification from the issuing institution to th e owner/operator and EPA of a decision not to extend the expiration date mailed at least 120 days before the current expiration date of the letter of credit (§§264.143(d)(5) and 265.143(c)(5));

 A letter (to accompany the letter of credit) from the owner or operator providing the following information:

-- The number, issuing institution, and date of the letter of credit;

-- The EPA identification number, name, and address of the facility;

and

-- The amount of funds assured for closure of or post-closure care for the facility by the letter of credit; and

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 Evidence of an increase in the closure or post- closure cost estimate that may require the

amount of credit to be increased accord ingly (§§264.143(d)(7 ), 265.143(c)(7), 264.145(d)(7), and 265.145(c)(7)).

(ii) Respondent activities:

Owners or operators will need to engage in the fo llowing activities in order to satisfy the financial assurance requirements with a closure or post-closure letter of credit:

 Reading the regulations;

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

 Writing a letter from the owner or operator to accompany the letter of credit;

 Submitting the following documents to the Regional Administrator:

-- The letter of credit (in the case of new permitted facilities, this must be submitted at least sixty days prior to receiving hazardous waste for treatment, storage, or disposal, pursuant to §§264.143(d)(1) and 264.145(d)(1));

-- The accompanying letter from the owner or operator; and

-- An originally signed duplicate of the trust agreement;

 Increasing the amount of the letter of credit, in the case of corresponding increase in the closure or post-closure cost estimate; and

 

### Submitting evidence of such an increase in the closure or post-closure cost estimate to the Regional Administrator.

(e) Closure or Post-Closure Insurance

(i) Data items:

Owners or operators may satisfy the financial assu rance requirements for closure or post-closure care by establishing closure or post-closure insuran ce according to §§264.143(e), 265.143(d), 264.145(e), and 265.145(d). Data items for th is information collection include:

 A closure or post-closure insurance policy (ide ntified by a certificate of insurance) that meets the requirements specified in §§264.1 43(e)(1)-(4) and (8), 265.143(d)(1)-(4) and (8), 264.145(e)(1)-(5) and (8), or 265.145(d)(1 )-(5) and (8);

 In the case of some interim status facilities, a letter from an insurer stating that an owner or operator is being considered for a cl osure insurance policy (§§265.143(d)(1) and 265.145(d)(1)); and

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 Evidence of an increase in the closure or post- closure cost estimate that may require the face amount of the insurance policy to be increased accordingly (§§264.143(e)(7), 265.143(d)(7), 264.145(e)(7), and 265.145(d)(7)).

(ii) Respondent activities:

Collecting this data will entail the following respondent activities:

 Reading the regulations;

 Obtaining a closure or post-closure insurance policy that satisfies the requirements of §§264.143, 265.143, 264.145, or 265.145;

 Submitting a certificate of this insurance policy to the Regional Administrator (for new facilities, this must be submitted at least sixty days prior to receiving hazardous wastes for treatment, storage, or disposal);

 In the case of some interim status facilities, submitting a letter from an insurer stating that the insurer is considering issuance of an in surance certificate (in this case, owners or operators must submit the certificate of insuran ce within ninety days of the effective date of these regulations); and

 Submitting evidence of an increase in the curre nt closure or post-closure cost estimate that may require the face amount of the insu rance policy to be modified accordingly.

(f) Financial Test and Corporate Guarantee for Closure or

Post-Closure Care

(i) Data items:

Sections 264.143(f), 265.143(e), 264. 145(f), and 265.145(e) allow owne rs and operators to satisfy closure or post-closure financial assurance require ments by demonstrating financial strength using the financial test specified in these sections. Data items for this demonstration include:

 A letter signed by the owner's or operator's ch ief financial officer and worded as specified in §264.151(f);

 A copy of an independent certified public accountant's report on examination of the owner's or operator's financial statements for the latest completed fiscal year;

 A special report from the owner's or operato r's independent certified public accountant to the owner or operator covering the speci fications outlined in §§264.143(f)(3)(iii), 265.143(e)(3)(iii), 264.145(f)(3)( iii), or 265.145(e)(3)(iii);

 If an extension of submission of the above documents is sought, a letter from the owner's or operator's chief financial officer to th e Regional Administrator of each Region in

which facilities to be covered under the financia l test are located. This letter, allowed only under §§265.143(e)(4) and 265.145(e)(4), mu st contain the following data items:

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-- A request for the extension;

-- A certification that the chief financ ial officer believes that the owner or operator meets the criteria of the financial test;

-- For each facility to be covered by the test, the EPA identification number, name, address, and current closure and post-closure cost estimates to be covered by the test;

-- A specification of the date (no later than ninety days after the end of such fiscal year) when the owner or operator will submit the documents specified in §§265.143(e)(3) and 265.145(e)(3); and

-- A certification that the year-end financial statements of the owner or operator for such fiscal year w ill be audited by an independent certified public accountant;

 Annual updates of the above data items;

 A notice of intent to establish alternative fi nancial assurance, if the owner or operator fails the financial test and no longer meets the requirements of §§264.143(f)(1), 265.143(e)(1), 264.145(f)(1), or 265.145(e)(1);

 Reports of financial conditions as re quired by the Regional Administrator (§§264.143(f)(7), 265.143(e)(7), 264.145(f)(7), and 265.145(e)(7));

 If applicable, a written guarantee from the pare nt corporation of the owner or operator that satisfies financial assurance require ments (§§264.143(f)(10) , 265.143(e)(10), 264.145(f)(10), or 265.145(e)(10)); and

 Notification from the insurer to the owner/ operator and EPA of a decision to cancel, terminate, or fail to renew the policy ( §§264.145(f)(11)(ii) and 265.143(e)(11)(ii)).

(ii) Respondent activities:

Owners or operators will need to engage in the following respondent activities in order to collect the data required by these sections:

 Reading the regulations;

 Writing the letter signed by the chief financial officer;

 Submitting the following documents to the Re gional Administrator (for new facilities, these documents must be submitted at least sixty days prior to receiving hazardous waste for treatment, storage, or disposal):

-- The letter signed by the chief financial officer;

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

-- The special report from the independent certified public

accountant;

 Submitting updated information annually;

 If applicable, writing and submitting a notice, by certified mail, to the Regional Administrator of intent to establish other financial assurance;

 Writing and submitting additional reports of financial condition at any time, as directed by the Regional Administrator; and

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

owner or operator.

(g) Use of a Financial Mechanism for Multiple Facilities

(i) Data items:

Sections 264.143(h), 265.143(g), 264.145(h), and 265 .145(g) specify that owners or operators may use one of the above financial assurance mech anisms to meet the requirements of §§264.143, 265.143, 264.145, or 26 5.145 for more than one facility. In such cases, the owner and operator must provide the following data items for each facility:

 EPA identification number, name, and address; and

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

(ii) Respondent activities:

To comply with the requirements of these sections , owners and operators w ill need to engage in the following activities:

 Reading the regulations;

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

 If the facilities covered by the mechanism are located in more than one Region, submitting identical evidence of financial assurance to all the applicable Regional

Administrators.

(4) Liability Requirements

(a) Coverage for Sudden or Nonsudden Accidental Occurrences

(i) Data items:

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Sections 264.147(a) and 265.147(a) specify that owners and operators of hazardous waste treatment, storage, and disposal facilities must demons trate financial responsibilit y for bodily injury and property damage to third parties caused by sudden accidental occurrences arising from operations of the facility or group of facilities. Si milarly, §§264.147(b) a nd 265.147(b) require ow ners or operators of surface impoundments, landfills, land treatment facilities managing hazardous wastes, or combinations of

such facilities to demonstrate fina ncial responsibility for bodily injury and property damage to third parties caused by nonsudden accidental occurrences arisi ng from facilities' operations. In order to comply with these sections, owners or operators will need to gather the following data items:

 Liability coverage demonstrated by one of the following documents (data items for these documents are described in full in the following sections):

-- A liability insurance policy (§§264. 147(a)(1), 265.147(a)(1), 264.147(b)(1), or 265.147(b)(1)), accompanied by a signed duplicate original of a Hazardous Waste Facility Liability Endorsement or a Certificate of Liability Insurance (§§264.147(a)(1) and 264.147(b)(1) only);

-- Written evidence of passing a financial test or a written
guarantee for liability coverage from th e owner's or operator's parent corporation, a firm whose parent cor poration is the parent corporation of the owner or operator, or a firm with a "substantial business relationship" with the owner or operator (§§264.147(a)(2), 265.147(a)(2), 264.147(b)(2), and 265.147(b)(2));

-- A letter of credit for liabilit y coverage (§§264.147(a)(3),
265.147(a)(3), 264.147(b)(3), and 265.147(b)(3));

-- A surety bond for liability coverage (§§264.147(a)(4),
265.147(a)(4), 264.147(b)(4), and 265.147(b)(4));

-- A trust fund for liability coverage ( §§264.147(a)(5), 265.147(a)(5),
264.147(b)(5), and 265.147(b)(5)); or

-- A combination of insurance, financial test, guarantee, letter of
credit, surety bond, and trust fund (§§264.147(a)(6), 265.147(a)(6), 264.147(b)(6), and 265.147(b)(6));

 A written notification to the Regional Administrator whenever a claim or verification of a valid claim for bodily injury or property damages caused by the operation of a hazardous waste treatment, storage, or disposal fac ility is made against the owner or operator (§§264.147(a)(7), 265.147(a)(7), 264.147(b)(7), and 265.147(b)(7)); and

 A written notification to the Regional Admini strator whenever the amount of financial assurance for liability coverage under one of th e above-mentioned instruments is reduced, contingent on a claim or verification of a valid claim (§§264.147(a)(7), 265.147(a)(7), 264.147(b)(7), and 265.147(b)(7)).

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(ii) Respondent activities:

Owners or operator will need to engage in the following activities in order to comply with the information collection requirements of §§264.1 47(a) and (b), and 265.147(a) and (b):

 Read the regulations;

 Establish liability coverage using one of the financial instruments listed above;

 Submit appropriate evidence of such financia l instruments to the Regional Administrator (in the case of new facilities establishing liability insurance, this must be submitted at least sixty days before receiving hazardous wastes for treatment, storage, or disposal, according to §§264.147(a)(1)(i) and 265.147(b)(1)(i));

 Prepare, write, and submit a notification to the Regional Administrator whenever a claim for bodily injury is made against the owner or operator; and

 

### Prepare, write, and submit a notification to the Regional Administrator whenever

the amount of financial assurance fo r liability coverage is reduced.

Submission of the two notifications listed immediatel y above will only occur in the event of a claim; therefore, if no accidental releases occur, owners or operators may never need to submit these notifications.

(b) Liability Insurance

(i) Data item:

Sections 264.147(a)(1), 264.147(b)(1), 265.147(a)(1), and 265.147(b)(1) require owners or operators to submit a duplicate of the endorsement or certificate of insura nce, and, if requested by the Regional Administrator, a duplicate of the insurance policy.

(ii) Respondent activities:

Owners or operators will need to engage in the foll owing activities to complete the requirements for this option:

 Reading the regulations;

 Obtaining an insurance policy amended by attachment of the Hazardous Waste Facility Liability Endorsement or evidenced by a Cer tificate of Liability Insurance and meeting other specifications outlined in §§264.147 (a)(1), 264.147(b)(1), 265.147(a)(1), or 265.147(b)(1);

 Submitting a signed duplicate original of the endorsement or the certificate of insurance to the Regional Administrator, or Regional Ad ministrators if the facilities are located in more than one Region; and

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 If requested by the Regional Administrator, submitting a signed duplicate original of the insurance policy (for new facilities this must be submitted at least sixty days before receiving hazardous waste for treatment, storage, or disposal).

(c) Variance of Financial Responsibility Regulations

(i) Data item:

Section 265.147(c) provides for a variance from th e financial responsibility requirements if the owner or operator can demonstrate that the required le vels of financial respons ibility are not consistent with the degree and duration of risk associated with tr eatment, storage, or disposal at the facility. The request for a variance must be submitted in writing to EPA, and may include technical and engineering information that is deemed necessary by the Regional Administrator.

(ii) Respondent Activity:

Owners and operators that wish to apply for a variance must prepare and submit information in support of the variance.

(d) Financial Test for Liability Coverage

(i) Data items:

Sections 264.147(f) and 265.147(f) a llow owners or operators to sa tisfy liability requirements by passing a financial test. Data items for these sections include:

 A letter signed by the owner's or operator's ch ief financial officer and worded as specified in §264.151(g); if the financial test is also being used to demonstrate closure or postclosure financial assurance, the letter specified in §264.151(g) must be submitted to cover both forms of financial responsibility;

 A copy of an independent certified public accountant's report on examination of the owner's or operator's financial statements for the latest completed fiscal year;

 A special report from the owner's or operato r's independent certified public accountant to the owner or operator covering the specifi cations outlined in §§264.147(f)(3)(iii) and 265.147(f)(3)(iii);

 If an extension of submission of the above documents is sought, a letter from the owner's or operator's chief financial officer to th e Regional Administrator of each Region in

which facilities to be covered under the financia l test are located. This letter, allowed only under §265.147(f)(4), must cont ain the following data items:

-- A request for the extension;

-- A certification that the chief financ ial officer believes that the owner
or operator meets the criteria of the financial test;

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-- For each facility to be covered by the test, the EPA identification

number, name, address, and current closure and post-closure cost estimates to be covered by the test;

-- A specification of the date (no later than ninety days after the end
of such fiscal year) when the owner or operator will submit the documents specified in §§265.147(f)(3); and

-- A certification that the year-end financial statements of the owner
or operator for such fiscal year w ill be audited by an independent certified public accountant;

 Annual updates of the above data items; and

 Should the owner or operator fail the test and no longer meet the requirements of §§264.147(f)(1) or 265.147(f)(1), evidence of insurance obtained for the entire amount of required liability coverage specified in §§264.147 and 265.147.

(ii) Respondent activities:

Owners or operators will need to engage in the following respondent activities in order to collect the data required by these sections:

 Reading the regulations;

 Writing the letter signed by the chief financial officer;

 Submitting the following documents to the Re gional Administrator (for new facilities, these documents must be submitted at least sixty days prior to receiving hazardous waste for treatment, storage, or disposal):

-- The letter signed by the chief financial officer;

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

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

 Submitting updated information annually; and

 Should the owner or operator fail the test and no longer meet §§264.147 or 265.147 requirements, submitting evidence to the Regional Administrator of insurance obtained for the entire amount of required liability coverage specified in these sections.

(e) Guarantee for Liability Coverage

(i) Data items:

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Sections 264.147(g) and 2 65.147(g) allow owners or operators to meet liability requirements by obtaining a written guarantee, under the conditions speci fied in §§264.147(g)(2) and 265.147(g)(2). Data items for this option include:

 A certified copy of a written guarantee from the direct or higher-tier parent corporation of the owner or operator, a firm whose parent co rporation is the parent corporation of the owner or operator, or a firm with a "substa ntial business relationship" with the owner or

operator;

 In the case of corporations incorporated in the United States, a written statement from applicable Attorney(s) General or Insuran ce Commissioners to EPA indicating that a guarantee executed as described in the regula tions is a legally valid and enforceable obligation in that State (§§264.147(g)(2) and 265.147(g)(2));

 In the case of corporations incorporated outsi de the United States, identification by the non-U.S. corporation of a registered agent for service of process in each State in which the facility covered by the guarantee is locat ed and in the State in which it has its principal place of business, and a written stat ement from applicable Attorney(s) General or Insurance Commissioner of each applicable State indicating that a guarantee executed as described in the regulations is a legally va lid and enforceable obligation in that State (§§264.147(g)(2) and 265.147(g)(2)); and

 A letter from the guarantor's chief financia l officer as specified in §§264.147(f)(3) and 265.147(f)(3) that demonstrates that the gua rantor has passed the financial test.

(ii) Respondent activities:

Owners or operators will need to engage in the following respondent activities in order to collect the data required by these sections:

 Reading the regulations;

 Obtaining a written guarantee from the direct or higher-tier parent corporation of the owner or operator, a firm whose parent corpor ation is the parent corporation of the owner or operator, or a firm with a "substantia l business relationship" with the owner or

operator;

 Submitting a certified copy of this written gua rantee to the Regional Administrator along with the items specified in §§26 4.147(f)(3) and 265.147(f)(3); and

 Submitting a letter from the guarantor's chief financial officer as specified in §§264.147(f)(3) and 265.147(f)(3) that demonstr ates that the guarantor has passed the

financial test.

(f) Letter of Credit for Liability Coverage

(i) Data items:

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Sections 264.147(h) and 265.147(h) allow owners or operators to satisfy financial requirements for liability by obtaining the following data item:

 An irrevocable standby letter of credit that conforms to applicable requirements and is

submitted from a financial institution with the au thority to issue letters of credit, whose letter of credit operations are regulated and ex amined by a Federal or State agency, and

whose letters of credit meet the requirements of §264.147(h).

(ii) Respondent activities:

Owners or operators using this option to satisfy financial assurance for liability will need to engage in the following activities:

 Reading the regulations;

 Obtaining the standby letter of credit described above; and

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

(g) Surety Bond for Liability Coverage

(i) Data item:

Sections 264.147(i) and 265.147(i) allow owners or operators to satisfy financial requirements for liability. Under sections 264.147(i )(4) and 265.147(i)(4), a surety bond may be used to satisfy the requirements of this section only if the applicable Attorneys General or Insurance Commissioners have submitted a written statement to EPA that a surety bond executed as described in the regulations is a legally valid and enforceable obligation in that State. The owner/operator must obtain a surety bond (and other information, where applicable) that conforms to the requirements specified in §§264.147(i) and 265.147(i).

(ii) Respondent activities:

Owners or operators using this option to satisfy financial assurance for liability will need to engage in the following activities:

 Reading the regulations;

 Obtaining the surety bond described above; and

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

(h) Trust Fund for Liability Coverage

(i) Data item:

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Sections 264.147(j) and 265.147(j) allow owners or operators to satisfy financial requirements for liability by establishing a trust fund that conforms to the requirements specified in §§264.147(j) and 265.147(j).

(ii) Respondent activities:

Owners or operators using this option to satisfy financial assurance for liability will need to engage in the following activities:

 Reading the regulations;

 Establishing the trust fund described above; and

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

Administrator.

(i) Adjustments by the Regional Administrator

(i) Data items:

Sections 264.147(d) and 265.147(d) allow Regional Ad ministrators to adjust the level of financial responsibility required under §§264.1 47 and 265.147 in order to protect human health and the environment. Respondents will need to furnish the following data items should Regional Administrators

make such a determination:

 Any information which the Regional Administ rator requests to determine whether cause exists for such adjustments of level or type of coverage; and

 If the Regional Administrator decides to adjust the level or type of coverage, the data elements necessary for a permit modification (detailed in ICR #1573).

(ii) Respondent activities:

Owners or operators will need to engage in th e following activities in order to satisfy the information collection requir ements of this section:

 Reading the regulations;

 Submitting to the Regional Administrator any requested information; and

 

### Preparing, writing, and submitting a pe rmit modification if the Regional

Administrator decides to ad just level or type of co verage (specific respondent activities for permit modificati ons are detailed in ICR #1573).

(5) Incapacity of Owners or Operators, Guarantors, or Financial Institutions

(i) Data item:

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Sections 264.148 and 265.148 require owners or opera tors to submit, if applicable, a notification of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the owner or operator as debtor (if the guarantor is named as the debtor, the collection of this data is the guarantor's responsibility).

(ii) Respondent activities:

Activities for this data collection will include:

 Reading the regulations; and

 Submitting, by certified mail, a notice to the Regional Administrator indicating the commencement of bankruptcy proceedings in wh ich the owner or operator or guarantor is

named as debtor.

(6) Use of State-Required Mechanisms

(i) Data items:

Sections 264.149 and 265.149 allow ow ners or operators to use St ate-required financial assurance mechanisms to meet §§264.143, 264.145, 264.147, 265 .143, 265.145, or 265.147 requirements. Data items for this option include:

 A letter from the owner or operator requesti ng that the State-required mechanism be considered acceptable for meeting the requirements of this subpart;

 Evidence of the establishment of a State -required mechanism, including the following

information:

-- The facility's EPA identification number, name, and address; and

-- The amount of funds for closure or post-closure care or liability
coverage assured by the mechanism; and

 Any additional information required by the Re gional Administrator in order to make the

determination.

(ii) Respondent activities:

Activities for this data collection will include:

 Reading the regulations; and

 Submitting to the Regional Administrator:

-- The letter from the owner or operator;

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-- Written evidence of the establishment of a State-required financial

assurance mechanism; and

-- Any additional information requested by the Regional

Administrator.

(7) State Assumption of Responsibility

(i) Data items:

Sections 264.150 and 265.150 require owners or ope rators to notify EPA when a State assumes legal responsibility or assures availability of funds for an owner's or operator's compliance with the closure, post-closure care, or liability requirements of th is part. Data items to be collected in this case

include:

 A letter from the owner or operator requesting that the State's assumption of responsibility be considered acceptable for m eeting the requirements of this subpart;

 A letter from the State describing the nature of the State's assumption of responsibility, including the following information:

-- The facility's EPA identification number, name, and address; and

-- The amount of funds for closure or post-closure care or liability
coverage that are guaranteed by the State; and

 Any additional information which the Regiona l Administrator deems necessary to make the determination whether the State's assumption of responsibility is acceptable.

(ii) Respondent activities:

Activities for this data collection will include:

 Reading the regulations; and

 Submitting to the Regional Administrator:

-- The letter from the owner or operator; and

-- The letter from the State describing the State's assumption of
responsibility and including the information specified above; and

 

### Submitting any additional information requested by the Regional Administrator.

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(8) Subpart F and G Requirements (§§266.70 and 266.80)

Sections 266.70(d) and 266.80(b)(2) explain that two specific groups of respondents are also subject to Parts 264 and 265 financial assurance requirements:



 Persons who generate, transport, or store r ecyclable materials that are reclaimed to recover economically significant amounts of gol d, silver, platinum, palladium, iridium, osmium, rhodium, ruthenium, or any combination of these; and

 Owners or operators of facilities that store spent lead acid batteries before reclaiming

them.

CONDITIONS APPLICABLE TO ALL PERMITS

(i) Data items:

40 CFR Part 270, Subpart C specifies conditions ap plicable to all permitted facilities. 40 CFR 270.30(h) requires owners and opera tors of permitted facilities to fu rnish any relevant information requested by EPA to determine whether cause exists for modifying, revoking and reissuing, or terminating a permit, or to determine compliance wi th the permit. Section 270.30(j)(2) and (3) requires permittees to retain records of all monitoring informat ion, copies of all reports required by the permit, the certification required by §264.73(b)(9), and records of all data used to complete the application for a period of at least three years from the date of the sample, measurement, report, certification, or application. [These requirements are burdened in the section entitled "Operating Record" of this ICR.] In addition, section 270.30(l) specifies the following repor ting requirements, which are applicable to all permitted facilities:

 Prompt notice of planned physical alte rnations or additions (§270.30(l)(1));

 Notice of planned changes or activities which may result in noncompliance with permit requirements (§270.30(l)(2));

 Letter certifying that the facility has been cons tructed or modified in compliance with the permit (§270.30(l)(2)(i);

 Monitoring reports, submitted at the interval s specified in the permit (§270.30(l)(4));

 Reports of compliance or noncompliance with , or any progress reports on, interim and final requirements contained in any complian ce schedule of the permit, submitted no later than 14 days following each schedule date (§270.30(l)(5));

 A report containing information concerning a release that may threaten drinking water supplies (§270.30(l)(6)(i)(A), or informati on concerning a release, fire, or explosion which could threaten human health or the environment outside the facility (§270.30(l)(6)(i)(B)), within 24 hours from the time the permittee becomes aware of the circumstances. Such a report must include the following information:

-- Name, address, and telephone num ber of the owner or operator;

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-- Name, address, and telepho ne number of the facility;

-- Date, time, and type of incident;

-- Name and quantity of material(s) involved;

-- The extent of injuries, if any;

-- An assessment of actual or potential hazards to the environment
and human health outside the facility; and

-- Estimated quantity and dispositi on of recovered material that

resulted from the incident.

 A written notice within five days of noncompliance, or a written report within 15 days, that includes a description of the noncompliance and its cause, the period of noncompliance, the anticipated time the nonc ompliance is expected to continue, and steps taken to reduce, eliminate, and prevent reoccurrence of the noncompliance (§270.30(l)(6)(iii);

 Report of any manifest discrepancy, as required by §264.72 (§270.30(l)(7). [This requirement is burdened in "Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System", ICR #801.];

 Report of any receipt of unmanifested waste, as required by §264.76 (§270.30(l)(8)). [This requirement is burdened in "Requireme nts for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System", ICR #801.];

 A biennial report covering facility activities, as required by §264.75 (§270.30(l)(9)). [This requirement is burdened in the "Hazardous Waste Report ICR", ICR #976.]

 Report of other noncompliance not submitte d with monitoring reports, compliance schedule reports, and reports of releases, fi res, or explosions (§270.30(l)(10)); and

 For cases where the permittee becomes aware that he or she failed to submit any relevant facts in a permit application, or submitted in correct information in any permit application or report, corrected or new information (§270.30(l)(11)).

(ii) Respondent activities:

In order to comply with 40 CFR Part 270, Subpar t C, owners and operators of permitted facilities must perform the following activities:

 Read the regulations; and

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 Prepare and submit the required information as described above.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

The following subsections discuss how EPA will co llect the information, what activities EPA will perform once the information has been received, and how EPA will manage the information it collects.

The subsections also include a discussion of how th e information collection requirements affect small

entities.

5(a) AGENCY ACTIVITIES

GENERAL FACILITY OPERATING STANDARDS

Although the information is not formally s ubmitted to EPA, EPA may review information collected from the requirements outlined in Subpart E dur ing facility inspections. Therefore, this analysis assumes that the Agency will spend a minimal amount of review time annually at each facility.

The requirements for the foreign shipment import re port, however, state that owners or operators must notify the Regional Administrator of the anticip ated collection of hazardous waste. In turn, the Agency must review the informa tion included in the notification.

RECORDKEEPING REQUIREMENTS

Only one Agency activity is associated with the ope rating record requirements: on-site review of

the record.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS

(1) Contingency Plan

Two Agency activities are associated with the de velopment and amendment of the contingency plan: reviewing the contingency plan during on-s ite inspections and reviewing revisions to the contingency plan.

(2) Emergency Reporting Requirements

Agency activities associated with emergenc y reporting requirements include reviewing documents in the owners' or operators' and emergency coordinators ' emergency reports.

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RELEASES FROM SOLID WASTE MANAGEMENT UNITS

There are two Agency activities associated with ground-water monitoring demonstrations and procedures: reviewing demonstrations to terminat e the compliance period and review and approval of proposed sampling methods and intervals.

CLOSURE AND POST-CLOSURE REQUIREMENTS

Agency activities associated with the regulations promulgated in 40 CFR, Parts 264 and 265, Subpart G, include reviewing the following data items:

 Closure plans;

 Closure plan amendment notifications;

 Partial/final closure notifications;

 Closure extensions and allowances;

 Survey plats;

 Post-closure plans;

 Post-closure plan amendment notifications;

 Post-closure plan modifications;

 Hazardous waste disposal records; and

 Post-closure permit modifications.

FINANCIAL REQUIREMENTS

EPA uses the cost estimates and financial assura nce mechanisms to en sure compliance with Subpart H. In the event that an owner or operato r is unable or unwilling to perform closure or postclosure activities or to pay third-party damages, EPA will draw upon the mechanisms. The cost estimates are normally retained by the owner or operator during interim status; they are submitted to the Region or authorized State as part of the permit process.

The financial assurance instruments for closure, post-closure care, and lia bility coverage, with standard wording, are submitted by the owner or ope rator (or the third-party financial entity) to the Region or authorized State that serves the area and wh ere the facility is located. These submissions must be made by the effective date of the regulations fo r existing facilities -- July 6, 1982 (Assurance) and July 15, 1982 (Liability) -- and sixty days before the initial receipt of hazardous wastes at new facilities. There was a phase-in period for nonsudden coverage for existing facilities. January 16, 1985 was the final phase-in date.

When financial assurance information is submitte d, EPA conducts a review for completeness,

then enters the information into the RCRIS data base. The EPA Regional or State offices establish a file

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for each applicant that contains the submissions. Th e financial instruments are maintained in a secure

area. Submissions are tabulated in the EPA Regional Offices and Headquarters and are used by Agency management to oversee implementation of the RCRA financial responsibility requirements. The

information is also shared with States to assist th em in implementing their hazardous waste management programs. There are no plans to publish information obtained under the Subpart H financial requirements.

CONDITIONS APPLICABLE TO ALL PERMITS

EPA reviews all information submitted at interval s specified in the permit. This information includes monitoring reports and reports on complianc e or noncompliance with compliance schedules. EPA also reviews information that may be submitt ed on occasion by facilities, if necessary. Such information includes notices of planned physical alte rations or additions; noti ces of planned changes or activities; letters certifying compliance; information con cerning releases, fires, or explosions; reports of other noncompliance; and corrected or new information.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

To collect and analyze the information discussed in this ICR, EPA keeps records of and reviews

all of the information submitted. Authorized St ates and EPA Regions enter the information into electronic data base systems. States coordinate w ith the EPA Regions and OS W Headquarters to supply EPA with the data reported for inclus ion in the RCRAInfo national database.

5(c) SMALL ENTITY FLEXIBILITY

When promulgating the regulations covered under th is ICR, EPA considered developing separate and simplified requirements for small businesses. Since small facilities conduct operations that are equally as hazardous to the environment as those conduc ted by larger facilities, EPA determined that small businesses should be required to comply with th e same regulations as large businesses. As a result of this interpretation, no specific require ments are outlined for smaller facilities.

5(d) COLLECTION SCHEDULE

GENERAL FACILITY STANDARDS

The reporting requirements outlined in the regulatio ns will vary according to individual facility circumstances (e.g., when receiving hazardous waste from a foreign source).

RECORDKEEPING REQUIREMENTS

Since the operating record is maintained at the facility, discussion of a collection schedule is not applicable. Copies of records of waste disposal are submitted to EPA upon closure of the facility.

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CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS

The contingency plan is collected when the perm ittee submits the Part B permit application. A discussion of the contingency plan collection sch edule for permitted facilities is included in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modi fications ICR (#1573). Since interim status facilities are not required to s ubmit their contingency plans to EPA, discussion of a collection schedule for these facilities is not applicable.

The owner or operator must submit a written repor t of any incident that requires implementation of the contingency plan within 15 days after the incident occurs. The emergency coordinator must immediately notify the appropriate authorities of an imminent or actual emergency situation.

CLOSURE AND POST-CLOSURE REQUIREMENTS

Permitted facilities submit their closure and post-cl osure plans to EPA when submitting a Part B permit application. A discussion addressing collection schedules for permitted facilities is included in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifi cations ICR (#1573).

Interim status closure and post-closure plan s must be submitted according to the following

schedules:

 The owner or operator must submit the closure plan to the Regional Administrator at least 180 days prior to the date on which he or sh e expects to begin closure of the first surface impoundment, waste pile, land treatment, or la ndfill unit, or final closure if it involves such a unit, whichever is earlier;

 The owner or operator must submit the closure plan to the Regional Administrator at least 45 days prior to the date on which he or sh e expects to begin final closure of a facility with only tanks, container storage, or incinerator units;

 Owners or operators with approved closure plans must notify the Regional Administrator in writing at least 60 days prior to the date on which they expect to begin closure of a surface impoundment, waste pile, landfill, or land treatment unit, or final closure of a facility involving such a unit;

 Owners and operators with approved cl osure plans must notify the Regional Administrator in writing at least 45 days prior to the date on which they expect to begin final closure of a facility with only tanks, container storage, or incinerator units;

 The owner or operator must submit the closure plan to the Regional Administrator no later than 15 days after:

-- Termination of interim status except when a permit is issued
simultaneously with termination of interim status; or

-- Issuance of a judicial decree or final order under §3008 of RCRA
to cease receiving hazardous wastes or close

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 If the Regional Administrator does not approve the closure plan, he or she shall provide the owner or operator with a detailed written st atement of reasons for the refusal and the owner or operator must modify the plan or submit a new plan for approval within 30 days after receiving such written statement;

 An owner or operator of a surface impoundment or waste pile that intends to remove all hazardous waste at closure must prepare a post-closure plan and submit it to the Regional Administrator within 90 days of the date that the owner or operator or Regional Administrator determines that the hazardous waste management unit or facility must be closed as a landfill, subject to the requi rements of §§265.117 through 265.120;

 If an owner or operator of a surface impoundment or a waste pile who intended to remove

all hazardous wastes at closure in accordance with §265.228(b) or §265.258(a) is required to close as a landfill in accordance with §265.3 10, the owner or operator must submit a post-closure plan within 90 days of the determination by the owner or operator or Regional Administrator that the unit must be closed;

 If the Regional Administrator determines that an owner or operator of a surface impoundment or waste pile who intended to rem ove all hazardous wastes at closure must close the facility as a landfill, the owner or operator must submit a post-closure plan for approval to the Regional Administrator w ithin 90 days of the determination;

 The owner or operator must submit the post-clos ure plan to the Regional Administrator at least 180 days before the date he or she expects to begin partial or final closure of the first hazardous waste disposal unit. The date he "expects to begin closure" of the first hazardous waste disposal unit must be either within 30 days after the date on which the hazardous waste management unit receives the known final volume of hazardous waste or, if there is a reasonable possibility th at the hazardous waste management unit will receive additional hazardous wastes, no later th an one year after the date on which the unit received the most recent volume of hazardous wastes; and

 The owner or operator must submit his post-cl osure plan to the Regional Administrator no later than 15 days after:

-- Termination of interim status except when a permit is issued
simultaneously with termination of interim status; or

-- Issuance of a judicial decree or final order under §3008 of RCRA
to cease receiving hazardous wastes or close.

Both interim status and permitted facilities are requi red to request approval for post-closure plan modifications. Since permitted facilities must submit permit modifications to authorize changes to their post-closure plans, a discussion addressing scheduling requirements for permitted facilities' modifications to the post-closure plan is included in ICR #1573. Th e following is a schedule for interim status facilities:

 An owner or operator with an approved post-cl osure plan must submit the modified plan to the Regional Administrator at least 60 days prior to the proposed change in facility

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design or operation, or no more than 60 days after an unexpected event has occurred which has affected the post-closure plan; and

 If the Regional Administrator requests modifica tions to the post-closure plan, the owner or operator with an approved post-closure plan must submit the modified plan to the Regional Administrator no later than 60 days of the request from the Regional

Administrator.

Both interim status and permitted facilities are re quired to submit closure certifications, survey plats, and post-closure notices according to the following schedules:

 The owner or operator must submit a cer tification of closure to the Regional Administrator within 60 days of completion of closure for each hazardous waste surface impoundment, waste pile, land treatment, and landfill unit and within 60 days of final closure;

 No later than the submission of the certification of closure, the owner or operator must submit to the Regional Administrator a survey plat;

 If the Regional Administrator does not approve the post-closure plan, he shall provide the owner or operator with a detailed written stat ement of reasons for the refusal and the owner or operator must modify the plan or submit a new plan for approval within 30 days after receiving such written statement;

 The owner or operator must submit a post-cl osure notice to the Regional Administrator within 60 days of certification of closure for each hazardous waste disposal unit;

 No later than 60 days after certification of closure of each hazardous waste disposal unit, the owner or operator must submit to the Re gional Administrator a record of the type, location, and quantity of hazardous wastes dispo sed of within each cell or other disposal unit of the facility; and

 No later than 60 days after the completion of the established post-closure care period for each hazardous waste disposal unit, the owner or operator must submit to the Regional Administrator a certification that the post-c losure care period for the unit was performed in accordance with the specifications in the approved post-closure plan.

FINANCIAL REQUIREMENTS

For closure and post-closure cost estimates, ow ners or operators must prepare initial cost estimates for activities identified in the closure and post- closure plans. Thereafter, owners or operators must provide annual adjustments of these cost estim ates to account for inflation. Also, owners or operators may be required to prepare new cost estimat es, if changes in the closure or post-closure plan increase closure or post-closure costs. This burden will vary from facility to facility.

For closure and post-closure care financial inst ruments, owners or operators must initially establish a financial instrument(s) assuring the cost of closure and post-closure care. Thereafter, owners or operators must annually check the amount covered by the instrument(s) to make sure it equals the adjusted cost estimate, and change the amount assured accordingly.

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For liability coverage requirements, owners or operators of facilities id entified in §§264.147 and 265.147 must initially demonstrate liability coverage for sudden an d nonsudden accidents during the

facilities' active life. Some of the financial instru ments for liability coverage require additional reporting on an annual basis; for example, owners or ope rators must annually s ubmit documentation to EPA supporting the use of the financial test or guarantee. Furthermore, owners or operators may also have to provide information due to varying circumstances; fo r example, whenever a cl aim for bodily injury or property damages caused by a hazardous waste treatmen t, storage, or disposal facility is made.

CONDITIONS APPLICABLE TO ALL PERMIT S

EPA collects information from permitted facilities at intervals specified in the permit. EPA may also collect other information if the Agency determ ines that it needs informatio n to determine whether a permit should be terminated, revoked and reissued, or modified. EPA may collect additional information from permitted facilities if noncomplian ce with permit c onditions occurs.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN

EPA estimated respondent burden hours associated wi th all of the requirements covered in this ICR in Exhibits 1 through 8. The e xhibits address the following requirements:

 Exhibit 1 - General facility standards;

 Exhibit 2 - Operating record requirements;

 Exhibit 3 - Contingency plan and emergency procedure requirements;

 Exhibit 4 - Requirements for releases from solid waste management units;

 Exhibit 5 - Closure and post-closure requirements;

 Exhibit 6 - Financial requirements;

 Exhibit 7 - Conditions applicable to all permits; and

 Exhibit 8 - Total respondent burden and costs.

Exhibits 1 through 7 present the number of hours required to conduct each individual information collection activity and the cost associ ated with that activity. Exhibi t 8 presents annual respondent bottomline burden hours and costs for all informa tion collection requirements in this ICR.

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6(b) ESTIMATING RESPONDENT COSTS

LABOR COSTS

For the private sector, EPA estimates an averag e hourly respondent labor cost (including fringe and overhead) of $122.72 for legal staff, $72.54 for managerial staff, $54.04 for technical staff, and $32.51 for clerical staff. These respondent labor costs were obtained from EPA ICR Number 0976.15.

For State agencies, EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $57.54 for legal staff, $54.02 for managerial staff, $32.32 for technical staff, and $20.62 for

clerical staff. These labor costs were obtained from EPA ICR Number 0976.15.

CAPITAL COSTS

EPA estimates that all new facilities and facilities with new Part B permits will incur capital costs associated with purchasing file storage systems for ma intaining records. EPA realizes that facilities will likely use different and various file storage systems (e.g., file cabinets, CD-ROM, off-site storage, etc) and store their files on different media (paper, microfiche, electronic files, etc). For purposes of estimating these capital costs across all facilities, EP A has made the conservative assumption that every facility will store their files in paper form in file cabinets.

In addition, EPA estimates that during the f acilities’ operating and post-closure periods each facility will store an average of 48,000 pieces of pape r. Therefore, the average facility will need to purchase three 5-drawer lateral file cabinets that each hold 16,000 pieces of paper. As the current market price for such a file cabinet is $549, each facility w ould therefore purchase $1,647 worth of file cabinets.

To annualize this capital cost of $1,647, EPA assume d a discount rate of 7 percent and a discount period of 15 years (based on the average life of file cabin ets). As such, the present value factor for this discount rate and period would be 9.1079. Thus, EPA estimates the annualized net present value of this capital cost as $180.83 per facility.

As most of the recordkeeping in this ICR is asso ciated with paperwork activities listed in Exhibit 2, EPA added an activity for purchasing file storage syst ems at the end of this exhibit. Even though there are additional recordkeeping activities in Exhibit 1, EPA accounts for all file maintenance capital costs in this one exhibit and line item. As such, EPA multip lied this annualized capital cost over all new facilities for a total annualized capital cost of $12,658.

OPERATION AND MAINTENANCE COSTS

EPA also estimates that facilities will incur ope rations and maintenance (O&M) costs such as postage costs for submitting information to EPA, pur chased material costs, and various lump-sum purchased service costs. These O&M costs are expected to be incurred on an ongoing, annual, or periodic basis per the associated regulatory requirement and assumptions in this ICR.

As shown in all exhibits, postage costs are est imated at $0.44 per one ounce letter, $4.95 per submittal for all other submittals weighing up to tw o pounds and sent by priority mail, and $9.75 per submittal that must be sent by registered, priority mail. In Exhibit 1, EPA estimates purchased material costs/and or lump-sum purchased service costs for wa ste analysis, specifically $1,000 per analysis for non-commercial facilities and $400 per analysis for co mmercial facilities. In Exhibit 5, EPA estimates

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lump-sum purchased service costs for certain inspections and/or certifications that must be completed by independent professionals, specifically $1,000 per insp ection/certification by an independent registered professional engineer and $750 per survey/certification by a professional land surveyor.

6(c) ESTIMATING AGENCY BURDEN AND COST

EPA estimates annual Agency burden hours and costs associated with all the requirements

covered in this ICR in Exhibit 9. EPA estimates the Agency hour and cost burden associated with the information collection requirements covered in this IC R. EPA estimates an average hourly labor cost of $86.56 for legal staff (GS15, Step 5), $76.38 for mana gerial staff (GS-15, Step 1), $54.94 for technical staff (GS-13, Step 1), and $23.44 for clerical staff (GS-06, Step 1). To derive these hourly estimates, EPA referred to the General Schedule (GS) Sala ry Table 2012. This publication summarizes the unloaded (base) hourly rate for various labor categori es in the Federal Government. EPA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly rates.

6(d) RESPONDENT UNIVERSE AND TOTAL RESPONDENT BURDEN AND COST

RESPONDENT UNIVERSE

Table 1 presents the estimated universe of facilities th at are affected by the General Facility Standard requirements.

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TABLE 1 Estimated Universe of Facilities Affected by General Facility Standard Requirements

Permitted Interim Status Total

All Facilities (Operating & Closed/Post Closed) 1,427 395 1,822

Operating Facilities 707 28 838

Commercial 310 5 315

Non-Commercial 397 23 420

Closed Facilities (New Annual Closures) 134 13 147

Post-Closed Facilities 586 88 674

Land Disposal Facilities (Op. & Cl/P-Cl) 609 229 838

Operating LDFs 72 3 75

Closed LDFs (New Annual Closures) 7 4 11

Post-Closed LDFs 560 80 640

Closed or Post-Closed LDFs 583 226 809

Facilities with Incinerators 58 0 58

Treatment and Storage Only Facilities 665 25 690

New Interim Status NA 0 0

New Part B Permits (Incl. New Construction) 7 NA 7

Facilities Who Intend to Close Annually 58 4 62

LDFs Who Intend to Close Annually 9 0 9

Facilities Who Intend to Post-Close Annually 8 0 8

LDFs Who Intend to Post-Close Annually 2 0 2

Facilities Completing Post-Closure Annually 5 0 5

GENERAL FACILITY OPERATING REQUIREMENTS

(1) Foreign Shipment Import Report

Based on previous experience, EPA estimates th at approximately six percent of the operating respondent universe will submit foreign sh ipment import reports annually.

(2) Notice of Appropriate Permits

EPA estimates that approximate ly 12 percent of operating TSDFs accept off-site waste. These

commercial facilities must submit a one-time notice to these generators before accepting their waste.

(3) Notice of Part 264 or Part 265, and Part 270 Requirements

EPA estimates that approximately one percent of all facilities will experience a transfer in ownership each year. The owners and operators of these facilities will be required to submit a notice of

Part 264 or 265 and Part 270 requirements to the new owner or operator of the facility.

(4) Waste Analysis

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Only operating facilities are required to conduct wast e analysis testing. EPA believes that the commercial incinerator and land disposal sites have the greatest responsibility for waste analysis. Based on previous experience, EPA estimates that commerc ial incinerator and land disposal facilities will conduct testing 50 times a year, while the remaining op erating facilities will conduct this analysis twice a

year.

(5) Waste Analysis Plan

This ICR assumes that existing interim status and permitted facilities have already developed a waste analysis plan. Therefore, only new interim and permitted facilities will develop waste analysis plans. EPA estimates that no new interim facilities will be entering the universe whereas the 13 newly permitted facilities will have to prepare a waste analysis plan. In addition to preparing a waste analysis plan, these 13 facilities must also maintain (i.e., p hotocopy and file) the plan at the facility.

EPA also assumes that 20 percent of all operating facilities will modify the plan and maintain the modified plan each year.

(6) Inspection Schedule

This ICR assumes that existing interim status a nd permitted facilities have already developed an inspection schedule. Therefore, only new permitted and interim status facilities will develop inspection

schedules. EPA estimates that no new interim and 13 new permitted facilities will enter the universe during the period covered by this ICR.

In addition to preparing an inspection schedule, new permitted facilities must also maintain (i.e., photocopy, file, and update) the schedule at the facility . EPA estimates that five percent of all operating facilities and facilities undergoing closure or post-clos ure will modify their inspection schedules annually and maintain the modified inspection schedule. All operating facilities are required to record problems in an inspection log.

(7) Personnel Training

This ICR assumes that existing interim status a nd permitted facilities have already collected the information necessary to prepare a personnel training r ecord. Therefore, only new interim status facilities and newly constructed pe rmitted facilities will be required to collect information regarding their employees' training experiences. EPA estimates that no new interim status facilities will join the universe during the period covered by this ICR. Newly construc ted facilities with Part B permits will have to read the regulations and collect information.

All operating and newly constructed facilities must also maintain (i.e., photocopy, file, and update) their training records.

(8) Documentation of Compliance for Ignita ble, Reactive, or Incompatible Wastes

Based on previous experience, EPA estimates th at 40 percent of the permitted operating universe

will have to maintain documentation of compliance for ignitable, reactiv e, or incompatible wastes.

(9) Construction Quality Assurance Plan

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This ICR assumes that existing permitted and in terim status facilities have submitted their construction quality assurance plan to EPA. Therefor e, only new interim status facilities will be required to submit the CQA plan. EPA estimates that no new facilities will obtain interim status during the period covered by this ICR.

RECORDKEEPING REQUIREMENTS

Operating Record

Excluding the inspection information requireme nts, only operating facilities are required to comply with the operating record recordkeeping requi rements. There are sixteen information components of the operating record requirements contained in 40 CFR §§264.73(b)(1)-(16) and 265.73(b)(1)-(16). Some of the requirements apply only to certain types of facilities:

 Facilities must document any refusal of State and local agencies to enter into arrangements to address emergency situations (§264 .37(b)). EPA estimates that only one percent of all operating facilities will be required to co mply with this regulation.

 Facilities that have emergency incidents requiring implementation of the contingency plan must maintain (i.e., photocopy and f ile) written documentation of the incident (§§264.73(b)(4) and 265.73(b)(4)). EPA estimates that only one percen t of all operating facilities will be required to comply with this regulation.

 Both operating and post-closure facilities are requi red to maintain updated inspection information in the operating record (§§264.73(b)(5) and ( 265.73(b)(5)).Only land disposal facilities and incinerator facilities are required to collect a nd record monitoring data (§264.73(b)(6)) in the operating record.

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 Only land disposal facilities and incinerator faciliti es are required to collect and record monitoring data (§264.73(b)(6)) in the operating record.



 Only facilities that receive hazardous waste from an off-site source (except where the owner or operator is also the generator) are required to maintain (i.e., photocopy and file) notices for generators verifying that they have a permit to handle the hazardous waste they are receiving (§§264.73(b)(7) and (265.73(b)(7)). Thus, EPA h as determined that 12 percent of the operating universe, including non-commercial facilities, will need to maintain, in the operating record, the notice to generators.

 All facilities must maintain updated information in the operating record closure cost estimates. However, only land disposal facilities must main tain post-closure cost estimates (§§264.73(b)(8) and (265.73(b)(8)). EPA expects that all perm itted and interim status facilities will have to

maintain closure cost estimates. Permitted and interim status operating land disposal facilities will also need to maintain post-closure cost estimates.

 All operating land disposal facilities must also ma intain records of the quantities (and date of placement) for each shipment of hazardous waste pl aced in land disposal units under an extension to the effective date of any land disposal restric tion, or a certification, and the applicable notice required by the generator (§§264.73(b)(10) and (265.73(b)(10)).

 Only off-site TSDFs are required to maintain (i.e ., photocopy and file) a copy of the notice, and the certification and demonstration, if applicable, required by the generator or owner or operator in the operating record (§§264.73(b)(11), (13) and (15) and (265.73(b)(11), (13) and 15)). Thus EPA has determined that five percent of the operati ng universe will need to maintain (i.e., photocopy and file) this information in the operating record.

 Only on-site TSDFS are required to maintain (i.e ., photocopy and file) the information contained in the notice (except the manifest number), and th e certification and demonstration if applicable, required by the generator or owner or operator ( §§264.73(b)(12), (14) and (16) and (265.73(b)(12), (14) and (16)). EPA had determined that 95 percent of the operating universe will need to maintain (i.e. photocopy and file) this information in the operating record.

The remaining requirements (§§264.73(b)(1)-(3) a nd (9) and (265.73(b)(1)-(3), and (9)) apply to
the entire universe of operating facilities.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS

(1) Contingency Plan

For this ICR, the Agency assumes that existing interim status and permitted facilities have already prepared contingency plans. Therefore, only new in terim status facilities will be required to prepare a contingency plan. (Modifications to contingency plans of permitted facilities are covered under the hazardous Waste Part B Permit Application, Special Permits, and Permit Modifications ICR (#1573)).

EPA estimates that no new facilities will obtain interi m status during the period covered by this ICR (#1571), or submit the contingency plan to all local police and fire departments, hospitals, and State and local response teams.

(2) Emergency Reporting And Recordkeeping

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Based on program experience, the Agency estim ates that one percent of all facilities with experience an emergency situation each year that will re quire the help of State or local authorities with designated response roles. Therefore, emergency c oordinators at permitted and interim status facilities will be required to notify these authorities of an actua l or imminent emergency situation (§§264.56(a)(2) and (265.56(a)(2)).

EPA estimates that one percent of those faciliti es experiencing an emergency situation will have a release, fire, or explosion for which the emergency c oordination determines that is may be advisable to

evacuate local areas.

EPA estimates that one percent of facilities will notify either a government official designated as the on-scene coordinator or the National Response Center of a release, fire, or explosion (§§264.56(d)(2) and 265.56(d)(2)). EPA estimates that only one per cent of all facilities will have emergency incidents requiring implementation of the contingency plan and w ill be required to prepare an emergency report.

All owners and operators experiencing an emerge ncy situation are required to notify the Regional Administrator that the facility is in compliance with §265.56(h) before resuming operation in the affected areas. The owner operator must also submit a writte n report to the Regional Administrator 15 days after the incident (§§264.56(j) and 265.56(j)). The respondent burden for recording emergency details in the operating record is covered in the operating record section.

RELEASES FROM SOLIE WASTE MANAGEMENT UNITS

EPA expects that no facilities will be required to demonstrate that the ground-water protection standard of §264.92 has not been ex ceeded for three consecutive years ( §264.96(c)). EPA also expects all facilities submitting a Part B permit application to develop and submit sampling procedures to EPA (§264.97(g)).

CLOSURE AND POST-CLOSURE REQUIREMENTS

(1) Reading the Regulations

The only facilities that are expected to read th e closure requirements will be the newly permitted facilities. Land disposal facilities are expect ed to read the post-closure regulations.

(2) Closure Plans

Since existing interim status and permitted facilities have already developed closure and postclosure plans, activities associated with developing closure/pose-closure plans apply to newly interim status facilities only. EPA expects no new f acilities to develop and submit closure plans.

(3) Closure Plan Amendment

Based on previous experience, EPA estimates that five percent of operating or closing interim status facilities, such as facilities converting waste pil es to containment building, will amend their closure plans annually and will submit a request to the Re gional Administrator to authorize a change in the closure plan. Since closure plan amendmen ts for permitted facilities ar e associated with permit modifications, amendments and discussed in the Hazar dous Waste Part B Permit Application, Special

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Permits, and Permit Modifications ICR, #1573.

(4) Partial Closure and Final Closure Notification

Owners and operators of all perm itted and interim status facilities who intend to close their facility annually must notify EPA of closure. In a ddition, owners and operators of the interim status facilities must also submit their closure plans to EPA.

(5) Extensions and Allowances During the Closure Period

Of the total number of facilities that will be clos ing, EPA estimates that 20 percent will request an extension for the treatment, storage, or removal of hazardous waste (§§264.113(a) and 265.113(a)). EPA estimates that an additional 20 percent will request an extension for completing closure activities. EPA also estimates that an additional five percent of a ll closing facilities will request an allowance to receive

non-hazardous wastes in a land-based unit after the fi nal receipt of hazardous waste (§§264.113(d) and 265.113(d)).

(6) Closure Certification

EPA estimates that all of the permitted and interi m status facilities that will be closing annually will complete a certification of closure.

(7) Survey Plat

EPA estimates that 50 percent of the land dis posal facilities that will be closing annually will submit a survey plat to the Regional Administrator.

(8) Post-Closure Plan

Existing permitted land disposal facilities already ha ve approved post-closure plans. Therefore, only new interim status land disposal facilities will de velop post-closure plans. EPA estimates that no new interim status land disposal facilities will prepar e a post-closure plan annually. In addition to preparing a post-closure plan, all permitted and interi m status land disposal facilities must also maintain (i.e., photocopy, file, and update) the post-closure plan at the facility.

(9) Notification and Amendment of Post-Closure Plan Under 265.118(d)

Since respondent activities associated with permit modifications are discussed in the Hazardous Waste Part B Permit Applications, Special Permits , and Permit Modifications ICR (#1573), this ICR

focuses on interim status facilities' activities associated with notification of a post-closure amendment. EPA estimates that 20 percent of interim status f acilities that will be undergoing post-closure, or two facilities, will amend their post-closure plans and su bmit written notification of a change in the approved post-closure plans.
(10) Amendment of Post-Closure Plan Under 265.118(d)(4), (f), and (g)(1)

In some cases, the Regional Administrator w ill require owners or operators of surface impoundments or waste piles who intend to remove al l hazardous wastes at closure to modify their postclosure plans. EPA expects that ten percent of in terim status facilities that are undergoing post-closure

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will be required to modify their post-closure plan. EPA estimates that the Agency will reject ten percent of these plans, which will require approximately no facilities to modify its plan or submit a new plan.

In some cases, facilities will re quest that the Agency extend or reduce the post-closure period applicable to a hazardous waste management unit or facility, or to alter the requirements of the postclosure care period. EPA estimates that 20 percent of interim status facilities that are undergoing postclosure (two facilities), will prepare and submit such a request.

(11) Hazardous Waste Disposal Records

All owners and operators who close their land di sposal facilities annually must submit hazardous waste disposal records.

(12) Hazardous Waste Notation Certification

All owners and operators who close their la nd disposal facilities annually must submit a certification that they have recorded the notation required in §§264.119(b)(2) and 265.119(b)(2).

(13) Post-Closure Plan Modifications

EPA does not expect that any interim status f acilities will subject to section 265.119(c) during the effective period of this ICR.

(14) Post-Closure Care Certification

Since the post-closure care period lasts for 30 years, except for those facilities that qualify for "early outs," EPA does not expect many owners/ope rators to submit certifications of post-closure care during the period covered by this ICR. Based on pr evious experience, EPA estimates that no facilities will complete post-closure care and be required to submit certifications.

FINANCIAL REQUIREMENTS

(1) Reading the Regulations

All operating and newly constructed facilities are expected to read the financial requirements regulations.

(2) Financial Responsibility for Corrective Action

Because financial responsibility for corrective ac tion is required under Part 264, only permitted

facilities are included in the burden estimate. EPA estimates that 80 percent of permitted facilities completed a RCRA Facility Assessment (RFA) that i ndicated that further investigation, or a RCRA Facility Investigation (RFI), was n ecessary. Because such further inv estigation will entail the submission of corrective action financial assurance documentation, EPA concludes that 80 percent of the permitted

facilities will need to meet corrective action financ ial responsibility requirements. These facilities will

need to include this financial assurance documen tation in their permit renewals; because most TSDF permits are valid for five years, EPA estimates th at each year approximately 20 percent will submit

financial assurance documentation for corrective action. EPA estimates that ten percent of these facilities per year will need to provide the additional demonstr ation of denied permission to implement corrective action beyond facility boundaries.

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(3) Cost Estimates for Cl osure and Post-Closure Care

The burden for respondents to collect data, to prepare closure and post-closure care cost estimates, and to maintain these estimates at the facility is already calculated in Exhibit 5, Closure and Post-Closure Care Requirements. Therefore, E xhibit 6 only determines the burden for owners or operators to update cost estimates on a yearly basis to reflect inflation, and the burden for amending cost estimates due to changes in the closure or post-cl osure care plan. Except for those facilities already closed or post-closed, all operating facilities will need to adjust estimates annually to reflect inflation. Since closure and post-closure plan amendments fo r permitted facilities are associated with permit modifications, such amendments are instead discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Pe rmit Modifications ICR (#1573).

(4) Financial Assurance for Closure or Post-Closure Care

Because evidence of establishing a financial in strument for closure or post-closure care is submitted with the Part B permit application, such activities for permitted facilities are discussed in the Hazardous Waste Part B Permit Applications, Speci al Permits, and Permit M odifications ICR (#1573). However, prior to submitting a permit application, in terim status facilities must present evidence of an

established financial instrument for closure or post-closure care under §§265.143 and 265.145. Therefore, preparation of the required evidence for inte rim status facilities is discussed in Exhibit 6. In addition, the burden associated with annual updates or m odifications to financial instruments is calculated in this exhibit for both permitted and interim status facilities.

Only new interim facilities will have to choose be tween the financial test for liability coverage and the other coverage options. EPA estimates that no new interim facilities will join the universe in the period this ICR covers.

EPA projects that two percent of existing fac ilities amend closure and post-closure financial instruments due to changes in the cost estimates or plans. Finally, all facilities covered under the financial test will need to submit annual updates; acco rdingly, 50 percent of existing facilities will submit this update.

(5) Liability Requirements

EPA calculates the number of respondents for de monstrating liability coverage in a manner similar to determining the number of closure and post-closure care respondents. Because evidence of establishing a financial instrument for liability coverage is submitted with the Part B permit application, such activities for permitted facilities are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (#1573). However, prior to submitting a permit application, interim status facilities must present ev idence of an established financial instrument for liability coverage under §265.147. Therefore, prepar ation of the required evidence for interim status

facilities is shown in Exhibit 6 of this ICR. In a ddition, the burden associated with annual updates or modifications to financial instruments for liability cove rage is calculated in this exhibit for both permitted

and interim status facilities.

Only new interim facilities will have to choose between the liability c overage options. EPA estimates that no new interim facilities will join the universe in the period this ICR covers.

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EPA expects that all existing TSDFs using the fina ncial test or guarantee will submit the financial

test documentation on an annual basis for review. EPA estimates that one percent of all facilities will become bankrupt and will need to submit evidence of insurance.

(6) Other Requirements

For activities relating to State-required mechanis ms and State assumption of responsibility, EPA estimates that one percent of interim status faciliti es (permitted facilities are in cluded in ICR #1573), will be included in the respondent burden estimate. EPA estimates that of these facilities, only one percent (approximately zero interim status facilities) will be required by EPA to furnish additional information under the State assumption of responsibility requirements.

CONDITIONS APPLICABLE TO ALL PERMITS

EPA estimates that each year 20 percent of permitted facilities will submit a permit modification at the request of the Agency. These permittees will be required to furnish an y relevant information requested by EPA to determine whether cause exists to modify, revoke and reissue, or terminate a permit, or to determine compliance with a permit.

EPA estimates that 15 percent of permitted f acilities will annually submit a notice of physical

alterations or additions. Of these facilities, 50 percent will submit a notice of planned changes that may result in noncompliance with permit requirements. Of these facilities, 50 percent will submit a letter certifying that the facility has been constructed or mo dified in compliance with the terms of the permit.

EPA estimates that all permitted facilities with la nd-based units and incinerators must submit monitoring reports. EPA further estimates that one pe rcent will be required to prepare and submit reports of compliance and noncompliance with the compliance sch edule at intervals specified in the permit.

EPA estimates that one percent of all permitte d facilities will experience a release, fire, or explosion that may threaten drinking water suppli es, human health, or the environment outside the facility. These facilities will be required to submit a re port within 24 hours of the incident and a more detailed written notice or report within 5 or 15 days, respectively, of the incident.

EPA estimates that two percent of all permitted facilities will be required to submit reports of other noncompliance that are not submitted with monitoring reports, compliance schedule reports, and reports of releases, fires, and explosions. An add itional one percent will submit amended information that was incorrect or omitted during an initial submittal.

6(e) BOTTOM LINE BURDEN HOURS AND COSTS

Exhibit 8 illustrates the total respondent burden and costs associated with private entities and

Exhibit 11 illustrates burden for states covered in th is ICR. EPA estimates that the total annual respondent burden for all activities covered in the ICR is approximately 672,417 h ours, at an annual cost of $40,676,696 which includes $40,143,171 annualized labor costs and $533,525 annualized capital or

O&M costs.

6(f) REASONS FOR CHANGE IN BURDEN

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There is an increase of 94,036 hours in this renewal. The reason for this increase is the inclusion of State Agency hours in this renewal.

6(g) BURDEN STATEMENT

The annual public reporting and recordkeeping bur den for this collection of information is estimated to average 359 hours per response. The annual public re porting burden is estimated to average 293 hours per respondent, and the annual public recordkeeping burden is estimated to average 66 hours per respondent. Burden means the total time, effort , or financial resources expended by persons to generate, maintain, retain, or disclose or provide inform ation 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 in formation, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train pe rsonnel to be able to respond to a collection of information; search data sources; complete and revi ew the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, a nd 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 lis ted 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 fo r this ICR under Docket ID Number EPA-HQ-RCRA2012-0187, 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.regulati ons.gov. This site can be used to submit or view public comments, access the index listing of the cont ents of the public docket, and to access those documents in the public docket that are available el ectronically. When in th e system, select “search,” then key in the Docket ID Number identified a bove. 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 fo r EPA. Please include the EPA Docket ID Number EPA-HQ-RCRA-2012-0187 and OMB Control Number 2050-0120 in any correspondence.78EXHIBIT 1ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTGENERAL FACILITY OPERATING STANDARDSNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearForeign Shipment Import Report (264.12(a) and 265.12(a))Read the regulations 42 2 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 44.10 $2,587.13Collect Data 42 2 0.00 0.00 0.75 0.25 $48.66 $0.00 $0.00 44.10 $2,145.80Prepare and submit notification 42 2 0.00 0.25 0.50 0.25 $53.28 $0.00 $0.33 44.10 $2,364.31Subtotal 42 2 0.00 0.50 2.00 0.50 $160.61 $0.00 $0.33 132.30 $7,097.23Notice of appropriate permit(s) (264.12(b)Read the regulations 85 N/A 0.00 0.10 0.25 0.00 $20.76 $0.00 $0.00 29.69 $1,761.62Prepare, keep records of, and submit notice(55 annually) 85 N/A 0.00 0.13 0.25 0.13 $26.64 $0.00 $0.33 2,333.10 $125,853.25Subtotal 85 N/A 0.00 0.23 0.50 0.13 $47.41 $0.00 $0.33 2,362.79 $127,614.86Notice of Part 264 or 265 and Part 270 requirements (264.12(c) and 265.12(b))Read the regulations 14 4 0.00 0.10 0.25 0.00 $20.76 $0.00 $0.00 6.38 $378.32Prepare and submit notice 14 4 0.00 0.00 0.50 0.13 $31.25 $0.00 $0.33 11.48 $575.32Subtotal 14 4 0.00 0.10 0.75 0.13 $52.01 $0.00 $0.33 17.86 $953.64Waste Analysis (264.13(a)(1) and 265.13(a)(1))Non-commercial facilitiesRead the regulations 397 23 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 420.00 $24,639.30Collect data (tw ice annually) 397 23 0.00 0.00 3.00 0.50 $178.38 $0.00 $0.00 2,940.00 $149,835.00Perform w aste analysis (tw ice annually) 397 23 0.00 0.00 10.00 0.00 $540.40 $0.00 $750.00 8,400.00 $1,083,936.00Commercial facilitiesRead the regulations 310 5 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 315.00 $18,479.48Collect data (50 times annually) 310 5 0.00 0.00 1.50 0.25 $89.19 $0.00 $0.00 27,562.50 $1,404,703.13Perform w aste analysis (50 times annually) 310 5 0.00 0.00 20.00 0.00 $1,080.80 $0.00 $400.00 315,000.00 $23,322,600.00Subtotal varies varies varies varies varies varies varies varies varies 354,637.50 $26,004,192.90Waste Analysis Plan (264.13(b) and 265.13(b))Read the regulations N/A 0 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 0.00 $0.00Collect data N/A 0 0.00 0.00 10.00 0.00 $540.40 $0.00 $0.00 0.00 $0.00Write the w aste analysis plan N/A 0 0.00 10.00 60.00 0.50 $3,984.06 $0.00 $0.00 0.00 $0.00Maintain the w aste analysis plan 6 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 6.00 $195.06Modify the w aste analysis plan 141 6 0.00 10.00 80.00 0.50$5,064.86$0.00$0.00 13,303.50$744,533.69Maintain the modified w aste analysis plan 141 6 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 147.00 $4,778.97Subtotal varies varies varies varies varies varies varies varies varies 13,456.50 $749,507.72Inspection Schedule (264.15(b)(1) and 265.15(b)(1))Read the regulations N/A 0 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 0.00 $0.00Develop an inspection schedule N/A 0 0.00 8.00 80.00 1.00 $4,936.03 $0.00 $0.00 0.00 $0.00Maintain the inspection schedule 6 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 6.00 $195.06Modify the inspection schedule 647 58 0.00 0.00 8.00 0.00 $432.32 $0.00 $0.00 5,636.00 $304,569.44Maintain the modified inspection schedule 647 58 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 704.50 $22,903.30Record problems in the inspection log 707 28 0.00 0.00 100.00 0.00 $5,404.00 $0.00 $0.00 73,500.00 $3,971,940.00Subtotal varies varies varies varies varies varies varies varies varies 79,846.50 $4,299,607.8079EXHIBIT 1 (con't)ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTGENERAL FACILITY OPERATING STANDARDSNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearPersonnel Training (264.16(d) and 265.16(d))Read the regulations 8 0 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 8.00 $469.32Collect data 8 0 0.00 0.50 2.00 0.50 $160.61 $0.00 $0.00 24.00 $1,284.84Maintain training records (new facilities) 8 0 0.00 0.00 0.00 80.00 $2,600.80 $0.00 $0.00 640.00 $20,806.40Maintain training records (existing facilities) 707 28 0.00 0.00 0.00 4.00 $130.04 $0.00 $0.00 2,940.00 $95,579.40Subtotal varies varies varies varies varies varies varies varies varies 3,612.00 $118,139.96Documentation of Compliance for Ignitable, Reactive, or Incompatible Wastes (264.17)Read the regulations 283 N/A 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 282.80 $16,590.46Collect and document data 283 N/A 0.00 1.00 40.00 1.00 $2,266.65 $0.00 $0.00 11,877.60 $641,008.62Maintain documentation at the facility 283 N/A 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 282.80 $9,193.83Subtotal 283 N/A 0.00 1.25 40.75 2.00 $2,357.83 $0.00 $0.00 12,443.20 $666,792.91Construction Quality Assurance Plan (265.19)Read the regulations N/A 0 0.00 0.00 1.00 0.00 $54.04 $0.00 $0.00 0.00 $0.00Complete the data items of 265.19(b), and,if applicable, an alternative demonstration N/A 0 0.00 0.00 15.00 5.00 973.15 $0.00 $0.00 0.00 $0.00Obtain a certification from CQA officer N/A 0 0.00 0.00 1.00 0.00 $54.04 $0.00 $0.00 0.00 $0.00Submit materials to EPA N/A 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $3.20 0.00 $0.00Maintain records of materials N/A 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 0.00 $0.00Subtotal N/A 0 0.00 0.00 17.00 6.50 $1,130.00 $0.00 $3.20 0.00 $0.00TOTAL varies varies varies varies varies varies varies varies varies 466,508.65 $31,973,907.0280EXHIBIT 2ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTOPERATING RECORDNumber ofRespondents Hours and Costs per Respondent or ActivityTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearArrangements w ith Local Authorities (264.37(b) and 265.37(b))Document refusal of State or local authoritiesto enter into arrangements 7 0 0.00 0.25 1.00 0.50 $88.43 $0.00 $0.00 12.86 $649.96Determine Quantity of Waste (264.73 and 265.73(b)(1) & (b)(2))Maintain updated information in operating record 707 28 0.00 0.00 40.00 40.00 $3,462.00 $0.00 $0.00 58,800 $2,544,570.00Records and Results of Waste Analysis (264.73 and 265.73(b)(3))Maintain updated information in operating record 707 28 0.00 0.00 0.00 20.00 $650.20 $0.00 $0.00 14,700 $477,897.00Emergency Reports (264.73 and 265.73(b)(4))Maintain updated information in operating record 7 0 0.00 0.00 0.00 4.00 $130.04 $0.00 $0.00 29.4 $955.79Inspections (264.73 and 265.73(b)(5))Maintain updated information in operating record 1,293 116 0.00 0.00 4.00 20.00 $866.36 $0.00 $0.00 33,816 $1,220,701.24Monitoring, Testing, or Analytical Data and Corrective Action (264.73 and 265.73(b)(6))Maintain updated information in operating record 609 229 0.00 0.00 2.00 10.00 $433.18 $0.00 $0.00 10,056 $363,004.84Notices to Generators (264.73 and 265.73(b)(7))Maintain updated information in operating record 85 3 0.00 0.00 0.00 2.00 $65.02 $0.00 $0.00 176.4 $5,734.76Closure Cost Estimates (264.73 and 265.73(b)(8))Maintain updated information in operating record 1,427 395 0.00 0.00 0.00 0.25 $8.13 $0.00 $0.00 455.5 $14,808.31Post-Closure Cost Estimates (264.73 and 265.73(b)(8))Maintain updated information in operating record 72 3 0.00 0.00 0.00 0.25 $8.13 $0.00 $0.00 18.75 $609.56Certification (264.73 and 265.73(b)(9))Maintain updated information in operating record 707 28 0.00 0.00 0.00 2.00 $65.02 $0.00 $0.00 1,470 $47,789.70Records of w aste disposed under an extension to effective date of the LDRs and notice required by generator under 268.7(a) (264.73 and 265.73(b)(10))Maintain updated information in operating record 72 3 0.00 0.00 1.00 2.00 $119.06 $0.00 $0.00 225 $8,929.50Copy of notice, certification, and demonstration required by generator: Off-site treatment, storage, and disposal facilities (264.73 and 265.73(b)(11), (b)(13), and (b)(15))Maintain updated information in operating record 35 1 0.00 0.00 0.00 2.00 $65.02 $0.00 $0.00 73.5 $2,389.49Information in the notice, certification and demonstraton required by generator or ow ner or operator: On-site treatment, storage, and disposal facilities (264.73 and 265.73(b)(12), (b)(14), and (b)(16))Maintain updated information in operating record 672 27 0.00 0.00 0.00 2.00 $65.02 $0.00 $0.00 1,396.5 $45,400.22File Storage Systems for RecordkeepingPurchase file cabinets 1,427 395 0.00 0.00 0.00 0.00 $0.00 $180.83 $0.00 0.00 $329,475.95TOTAL varies varies varies varies varies varies varies varies varies 121,229.91 $5,062,916.3281EXHIBIT 3ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTCONTINGENCY PLAN AND EMERGENCY PROCEDURESNumber ofRespondents Hours and Costs per Respondent or AcitivityTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearPrepare and Submit Contingency Plan (265.50 - .54)Read the regulations N/A 0 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 0.00 $0.00Collect information required to develop ormodify the contingency plan N/A 0 0.00 0.00 12.00 3.00 $746.01 $0.00 $0.00 0.00 $0.00Develop the contingency plan N/A 0 0.00 1.00 60.00 4.00 $3,444.98 $0.00 $0.00 0.00 $0.00Submit contingency plan to local authorities 0 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $3.20 0.00 $0.00Maintain the contingency plan 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 0.00 $0.00Subtotal 0 0 0.00 1.25 72.75 8.50 $4,298.42 $0.00 $3.20 0.00 $0.00Emergency Coordinator Reports (264.56(a)(2), (d)(1), and (d)(2)), and 265.56(a)(2), (d)(1), and (d)(2))Notify State and local authorities of animminent or actual emergency situation 14 4 0.00 0.50 0.00 0.00 $36.27 $0.00 $0.00 9.11 $660.84Collect information required for an emergencyreport 14 4 0.00 0.00 2.50 0.50 $151.36 $0.00 $0.00 54.66 $2,757.69Notify local authorities of the need to evacuatelocal areas 0 0 0.00 1.00 0.00 0.00 $72.54 $0.00 $0.00 0.18 $13.22Submit an emergency report to the on-scenecoordinator or the National Response Center 14 4 0.00 1.00 0.00 0.00 $72.54 $0.00 $3.20 18.22 $1,379.98Subtotal varies varies varies varies varies varies varies varies varies 82.17 $4,811.73Notify Regional Administrator that facility is in compliance w ith 264.56(h) or 265.56(h) before resuming operations in the affected area (264.56(i) and 265.56(i))Compile information that demonstrates thatall affected areas are in compliance w ith264.56(h) or 265.56(h) 14 4 0.00 0.00 2.50 0.50 $151.36 $0.00 $0.00 54.66 $2,757.69Prepare and submit notification letter 14 4 0.00 0.25 1.50 0.25 $107.32 $0.00 $0.33 36.44 $1,961.43Subtotal 14 4 0.00 0.25 4.00 0.75 $258.68 $0.00 $0.33 91.10 $4,719.12Prepare an Ow ner/Operator's Emergency Report (264.56(j) and 265.56(j))Read the regulations 14 4 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 18.22 $1,068.88Collect information required in theemergency report 14 4 0.00 0.00 8.00 0.50 $448.58 $0.00 $0.00 154.87 $8,173.04Prepare and submit the emergency report 14 4 0.00 0.25 4.00 0.50 $250.55 $0.00 $3.20 86.55 $4,623.33Subtotal 14 4 0.00 0.50 12.75 1.00 $757.79 $0.00 $3.20 259.64 $13,865.24TOTAL varies varies varies varies varies varies varies varies varies 432.91 $23,396.0882EXHIBIT 4ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTRELEASES FROM SOLID WASTE MANAGEMENT UNITSNumber ofRespondents Hours and Costs per Respondent or ActivityTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearTermination of compliance period (264.96(c))Read the regulations 0 N/A 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 0.00 $0.00Prepare and submit demonstration 0 N/A 0.00 1.00 4.00 1.00 $321.21 $0.00 $3.20 0.00 $0.00Subtotal 0 N/A 0.00 1.25 4.75 1.00 $379.88 $0.00 $3.20 0.00 $0.00Proposal of sampling procedure and interval (264.97(g))Read the regulations 6 N/A 0.00 0.25 0.75 0.00 $58.67 $0.00 $0.00 6.00 $351.99Develop and submit sampling procedure 6 N/A 0.00 20.00 100.00 2.00 $6,919.82 $0.00 $3.20 732.00 $41,538.12Subtotal 62 N/A 0.00 20.25 100.75 2.00 $6,978.49 $0.00 $3.20 738.00 $41,890.11Total varies varies varies varies varies varies varies varies varies 738.00 $41,890.1183EXHIBIT 5ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTCLOSURE AND POST-CLOSURE REQUIREMENTSNumber ofRespondents Hours and Costs per Respondent or ActivityTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearClosure Plan (265.112(a))Read the regulations N/A 0 0.00 0.50 3.00 0.00 $198.39 $0.00 $0.00 0.00 $0.00Conduct an inventory of hazardous w aste N/A 0 0.00 0.00 8.00 0.00 $432.32 $0.00 $0.00 0.00 $0.00Record results of inventory N/A 0 0.00 0.00 2.00 0.50 $124.34 $0.00 $0.00 0.00 $0.00Write descriptions for activities N/A 0 0.00 1.00 20.00 3.00 $1,250.87 $0.00 $0.00 0.00 $0.00Estimate final closure N/A 0 0.00 0.25 0.25 0.00 $31.65 $0.00 $0.00 0.00 $0.00Write the closure schedule N/A 0 0.00 0.50 1.00 0.50 $106.57 $0.00 $0.00 0.00 $0.00Subtotal N/A 0 0.00 2.25 34.25 4.00 $2,144.13 $0.00 $0.00 0.00 $0.00Notification and Amendment of Closure Plan (265.112(c))Prepare and submit notification of amendment N/A 2 0.00 0.25 1.00 0.25 $80.30 $0.00 $0.33 3.08 $165.30Amend and submit closure plan N/A 2 0.00 0.00 8.00 1.00 $464.83 $0.00 $3.20 18.45 $959.46Subtotal N/A 2 0.00 0.25 9.00 1.25 $545.13 $0.00 $3.53 21.53 $1,124.76Notification of Partial or Final Closure (264.112(d) and 265.112(d))Prepare and submit notification of closure 58 4 0.00 0.25 0.50 0.25 $53.28 $0.00 $0.33 62.00 $3,323.98Submit closure plan 58 4 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 62.00 $2,214.02Subtotal 58 4 0.00 0.25 0.50 1.25 $85.79 $0.00 $3.53 124.00 $5,538.00Extension and Allow ances During the Closure Period (264.113(a), 265.113(a), 264.113(b), 265.113(b), 264.113(d), and 265.113(d))Prepare and submit demonstration for extensionfor treatment, storage, or removal of hazardousw aste (264/265.113(a)) 12 1 0.00 4.00 80.00 1.00 $4,645.87 $0.00 $3.20 1054.00 $57,648.47Prepare and submit demonstration for extensionof the closure period (264/265.113(b)) 12 1 0.00 4.00 80.00 1.00 $4,645.87 $0.00 $3.20 1054.00 $57,648.47Prepare and submit demonstration for receivingnon-hazardous w aste (264/265.113(d)) 3 0 0.00 4.00 100.00 1.00 $5,726.67 $0.00 $3.20 325.50 $17,762.60Subtotal varies varies varies varies varies varies varies varies varies 2,433.50 $133,059.53Certification of Closure (264.115 and 265.115)Have an independent registered professionalengineer inspect the facility58 4 0.00 0.00 1.00 0.00 $54.04 $0.00 $1,000.00 62.00 $65,350.48Collect documentation to supportcertification and submit certification 58 4 0.00 0.00 3.00 2.00 $227.14 $0.00 $9.20 310.00 $14,653.08Subtotal 58 4 0.00 0.00 4.00 2.00 $281.18 $0.00 $1,009.20 372.00 $80,003.56Survey Plat (264.116 and 265.116)Have a professional land surveyor prepare andcertifyplat, and submit plat5 0 0.00 0.00 1.00 2.00 $119.06 $0.00 $750.00 13.50 $3,910.77Subtotal 5 0 0.00 0.00 1.00 2.00 $119.06 $0.00 $750.00 13.50 $3,910.77Post-Closure Plan (265.118)Read the regulations N/A 0 0.00 0.50 3.00 0.00 $198.39 $0.00 $0.00 0.00 $0.00Collect data N/A 0 0.00 1.00 12.00 7.00 $948.59 $0.00 $0.00 0.00 $0.00Write and submit post-closure plan N/A 0 0.00 1.00 20.00 2.00 $1,218.36 $0.00 $3.20 0.00 $0.00Maintain post-closure plan 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 0.00 $0.0084EXHIBIT 5 (con't)ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTCLOSURE AND POST-CLOSURE REQUIREMENTSNumber ofRespondents Hours and Costs per Respondent or ActivityTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearNotification and Amendment of Post-Closure Plan Under 265.118(a)(1)-(3)Prepare and submit notification of amendment N/A 0 0.00 0.25 1.00 0.25 $80.30 $0.00 $0.33 0.00 $0.00Prepare and submit amended post-closure plan N/A 0 0.00 0.00 8.00 1.00 $464.83 $0.00 $3.20 0.00 $0.00Subtotal N/A 0 0.00 0.25 9.00 1.25 $545.13 $0.00 $3.53 0.00 $0.00Amendment of Post-Closure Plan Under 265.118(d)(4), (f), and (g)(1)Amend and submit post-closure plan asrequested by EPA (265.118(d)(4)) N/A 0 0.00 0.50 6.00 1.50 $409.28 $0.00 $3.20 0.00 $0.00Modify and resubmit plan, if not approvedby EPA (265.118(f)) N/A 0 0.00 0.50 6.00 2.00 $425.53 $0.00 $3.20 0.00 $0.00Petition to extend or reduce the post-closurecare period (265.118(g)(1)) N/A 0 0.00 0.50 1.00 0.50 $106.57 $0.00 $3.20 0.00 $0.00Subtotal N/A varies varies varies varies varies varies varies varies 0.00 $0.00Hazardous Waste Disposal Records (264.119 and 265.119(a))Determine specifications of hazardous w asteactivity 9 0 0.00 0.00 2.00 0.00 $108.08 $0.00 $0.00 18.00 $972.72Establish and submit a record of activity 9 0 0.00 0.00 1.00 0.00 $54.04 $0.00 $3.20 9.00 $515.16Maintain the record of activity 9 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 9.00 $292.59Subtotal 9 0 0.00 0.00 3.00 1.00 $194.63 $0.00 $3.20 36.00 $1,780.47Hazardous Waste Notation CertificationRecord notation on deed, and develop andsubmit certification9 0 1.00 0.00 1.00 2.00 $241.78 $0.00 $0.33 36.00 $2,178.99Subtotal 9 0 0.00 0.00 1.00 2.00 $241.78 $0.00 $0.33 36.00 $2,178.99Post-Closure Plan Modifications (265.119(c))Prepare request for modification N/A 0 0.00 0.50 1.25 0.25 $111.95 $0.00 $0.00 0.00 $0.00Demonstrate compliance N/A 0 0.00 0.25 1.75 1.00 $145.22 $0.00 $0.00 0.00 $0.00Subtotal N/A 0 0.00 0.75 3.00 1.25 $257.16 $0.00 $0.00 0.00 $0.00Certification of Completion of Post-Closure Care (264.120 and 265.120)Obtain certification of compliance from anindependent registered professional engineer 5 0 0.00 1.00 4.00 0.00 $288.70 $0.00 $1,000.00 25.00 $6,443.50Maintain a copy of the certification 5 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.00 5.00 $162.55Submit documentation to EPA 5 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 5.00 $178.55Subtotal 0 0 0.00 1.00 4.00 2.00 $353.72 $0.00 $1,003.20 35.00 $6,784.60TOTAL varies varies varies varies varies varies varies varies varies 3,071.53 $234,380.6885EXHIBIT 6ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTFINANCIAL REQUIREMENTSNumber ofRespondents Hours and Costs per RespondentTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearReading the RegulationsRead the regulations covering financialresponsibility requirements (new facilities) 8 0 8.00 2.00 8.00 0.00 $1,559.16 $0.00 $0.00 144 $12,473.28Read the regulations covering financialresponsibility requirements (existing facilities) 707 28 4.00 1.00 4.00 0.00 $779.58 $0.00 $0.00 6,615 $572,991.30Subtotal varies varies varies varies varies varies varies varies varies 6,615 $585,464.58Financial Responsibility for Corrective Action (264.101)Prepare and submit documented assurancesof financial responsibility for corrective action 231 N/A 2.00 0.50 5.50 1.00 $611.44 $0.00 $3.20 2,081 $142,088.79Demonstrate, if applicable, that permission denied toimplement correction action beyond facility boundary 23 N/A 1.00 0.50 1.25 0.25 $234.67 $0.00 $3.20 69 $5,498.88Subtotal varies N/A varies varies varies varies varies varies varies 2,150 $147,587.67Cost Estimates for Closure and Post-Closure Care (264.142, 264.144, 265.142, and 265.144)Adjust estimate annually to reflect inflation 707 28 0.00 0.00 0.50 0.00 $27.02 $0.00 $0.00 368 $19,859.70Amend cost estimate due to closure/post-closure plan changes 0 2 0.00 0.50 6.50 0.50 $403.79 $0.00 $0.00 15 $807.57Subtotal varies varies varies varies varies varies varies varies varies 383 $20,667.27Closure or Post-Closure Trust Fund (264.143, 265.143, 264.145, and 265.145)Establish a closure or post-closure trust fund 0 0 4.00 1.50 2.00 0.50 $724.03 $0.00 $0.00 0 $0.00Submit orginally signed duplicate of trustagreement 0 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $3.20 0 $0.00Submit formal certification ofacknow ledgement (post-closure trust funds only) 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 0 $0.00Submit receipt for first payment under trustagreement (new facilities) 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 0 $0.00Amend trust fund due to changes inclosure/post-closure plan 4 1 2.00 1.00 0.75 0.25 $366.64 $0.00 $0.00 18 $1,670.03Subtotal varies varies varies varies varies varies varies varies varies 18 $1,670.03Surety bond guaranteeing payment into a closure or post-closure trust fund (264.143(b), 265.143(b), 264.145(b) and 265.145(b)),or guaranteeing performance of closure or post-closure care (264.143(c) and 264.145(c))Establish surety bond and trust agreement 0 0 4.00 1.50 2.00 0.50 $724.03 $0.00 $0.00 0 $0.00Submit orginally signed duplicates ofbond/trust agreement 0 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $3.20 0 $0.00Submit evidence of alternate financialmechanisms, if bond cancelled 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 0 $0.00Increase penal sum amount, if cost estimate modified 4 1 2.25 0.75 1.00 0.00 $384.57 $0.00 $0.00 18 $1,751.69Submit evidence of increase in cost estimate 4 1 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 5 $162.66Subtotal varies varies varies varies varies varies varies varies varies 23 $1,914.3586EXHIBIT 6 (con't)ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTFINANCIAL REQUIREMENTSNumber ofRespondents Hours and Costs per RespondentTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearClosure or Post-Closure Letter of Credit (264.143(d), 265.143(c), 264.145(d), and 265.145c))Obtain and submit letter of credit fromissuing institution 0 0 4.00 1.50 2.00 0.50 $724.03 $0.00 $0.33 0 $0.00Write and submit letter to accompany letterof credit 0 0 1.25 0.25 0.00 0.50 $187.79 $0.00 $0.33 0 $0.00Submit originally signed duplicate of thetrust agreement 0 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $3.20 0 $0.00Increase credit amount, if cost estimate modified 4 1 0.75 0.50 0.75 0.00 $168.84 $0.00 $0.00 9 $769.07Submit evidence of increase in cost estimate 4 1 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 5 $162.66Subtotal varies varies varies varies varies varies varies varies varies 14 $931.73Closure or Post-Closure Insurance (264.143(e), 265.143(d), 264.145(e), and 265.145(d))Establish closure or post-closure insurance policy 0 0 4.00 1.50 2.00 0.50 $724.03 $0.00 $0.00 0 $0.00Submit insurance policy certificate to EPA 0 0 0.00 0.00 0.00 0.50 $16.26 $0.00 $0.33 0 $0.00Submit letter from insurer (for some interim statusfacilities only) 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 0 $0.00Increase insured amount, if cost estimate modified 4 1 2.50 0.50 0.00 0.00 $343.07 $0.00 $0.00 14 $1,562.68Submit evidence of increase in cost estimate 4 1 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 5 $162.66Subtotal varies varies varies varies varies varies varies varies varies 18 $1,725.34Financial Test and Corporate Guarantee (264.143(f), 265.143(e), 264.145(f), and 265.145(e))Write and submit letter signed by chieffinancial officer 0 0 1.00 0.25 2.00 0.75 $273.32 $0.00 $0.33 0 $0.00Submit copy of public accountant's reportand special report 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 0 $0.00Submit updated information annually 714 198 0.00 0.00 0.00 4.00 $130.04 $0.00 $3.20 3,644 $121,381.64Write and submit notice of intent to establishother financial assurance, if applicable 14 4 3.25 0.25 0.00 0.50 $433.23 $0.00 $0.33 73 $7,899.46Write and submit any additional reports offinancial condition 14 4 2.25 0.25 1.00 0.50 $364.55 $0.00 $3.20 73 $6,700.41Submit corporate guarantee from parentcorporation 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 0 $0.00Subtotal varies varies varies varies varies varies varies varies varies 3,790 $135,981.51Coverage for Sudden or Nonsudden Accidental Occurrences (264.147(a), 265.147(a), 264.147(b), and 265.147(b))Prepare, w rite, and submit a claimnotification, if applicable 7 2 2.50 1.00 0.00 0.50 $395.60 $0.00 $0.33 36 $3,606.88Prepare, w rite, and submit notification of reductionof liability coverage amount if applicable 29 8 2.00 1.00 0.50 0.50 $361.26 $0.00 $0.33 146 $13,176.16Subtotal varies varies varies varies varies varies varies varies varies 182 $16,783.03Variance of financial responsibility regulations (265.147(c))Prepare and submit petition for variance 0 0 0.50 0.50 0.50 0.00 $124.65 $0.00 $3.20 0 $0.00Subtotal 0 0 0.50 0.50 0.50 0.00 $249.30 $0.00 $3.20 0 $0.0087EXHIBIT 6 (con't)ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTFINANCIAL REQUIREMENTSNumber ofRespondents Hours and Costs per RespondentTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearFinancial Test for Liability Coverage (264.147(f) and 265.147(f))Prepare, w rite, and submit letter signed bychief financial officer 0 0 1.00 0.25 2.00 0.75 $273.32 $0.00 $0.33 0 $0.00Submit copy of public accountant's reportand special report 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 0 $0.00Submit updated information annually 357 99 0.00 0.00 0.00 4.00 $130.04 $0.00 $3.20 1,822 $60,690.82Submit evidence of insurance obtained forentire liability coverage, if applicable 14 4 0.00 0.00 0.00 2.00 $65.02 $0.00 $3.20 36 $1,242.97Subtotal varies varies varies varies varies varies varies varies varies 1,858 $61,933.79Guarantee for Liability Coverage (264.147(g) and 265.147(g))Obtain and submit w ritten guarantee fromparent corporation 0 0 0.50 0.50 0.50 0.50 $140.91 $0.00 $0.33 0 $0.00Submit letter from guarantor's chieffinancial officer 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 0 $0.00Submit updated information annually 357 99 0.00 0.00 0.00 4.00 $130.04 $0.00 $3.20 1,822 $60,690.82Subtotal varies varies varies varies varies varies varies varies varies 1,822 $60,690.82Letter of Credit for Liability Coverage (264.147(h) and 265.147(h))Obtain and submit stand-by letter of credit 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $0.33 0 $0.00Subtotal 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $0.33 0 $0.00Liability Insurance (264.147(a) and (b), and 265.147(a) and (b))Obtain and submit insurance policy documentation 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $3.20 3 $282.88Subtotal 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $3.20 3 $282.88Surety Bond for Liability Coverage (264.147(i) and 265.147(i))Obtain surety bond and submit copy to EPA 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $0.33 3 $281.74Subtotal 0 0 4.00 1.00 2.00 1.00 $704.01 $0.00 $0.33 3 $281.74Trust Fund for Liability Coverage (264.147(j) and 265.147(j))Establish trust fund 0 0 4.50 1.50 1.00 1.00 $747.60 $0.00 $0.00 3 $299.04Submit originally signed duplicate of trustagreement to EPA 0 0 0.00 0.00 0.00 1.00 $32.51 $0.00 $3.20 0 $14.28Subtotal 0 0 4.50 1.50 1.00 2.00 $780.11 $0.00 $3.20 4 $313.3288EXHIBIT 6 (con't)ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTFINANCIAL REQUIREMENTSNumber ofRespondents Hours and Costs per RespondentTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearIncapacity of Ow ners or Operators, Guarantors, or Financial Institutions (264.148 and 265.148)Submit notice indicating commencement ofbankruptcy proceedings 14 4 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 18 $598.34Subtotal 14 4 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 18 $598.34Use of State-Required Mechanisms (264.149) and 265.149)Submit letter from ow ner or operator 0 4 0.00 0.00 0.00 4.00 $130.04 $0.00 $0.33 16 $514.96Submit w ritten evidence of establishment ofState-required financial assurance mechanism 0 4 0.00 0.00 0.00 2.00 $65.02 $0.00 $3.20 8 $269.47Subtotal 0 4 0.00 0.00 0.00 6.00 $195.06 $0.00 $3.53 24 $784.43State Assumption of Responsibility (264.150 and 265.150)Prepare and submit letter fromow ner or operator 0 4 1.00 5.00 2.00 0.50 $609.76 $0.00 $0.33 34 $2,409.84Obtain and submit letter from Statedescribing assumption of responsiblity 0 4 0.00 0.00 0.00 1.00 $32.51 $0.00 $0.33 4 $129.72Prepare and submit any additional informationrequested by EPA 0 0.0 0.75 0.25 0.75 0.25 $158.83 $0.00 $3.20 0 $6.40Subtotal varies varies varies varies varies varies varies varies varies 38 $2,545.95Estimated decrease in Federally-requiredcost due to facilities using State-requiredmechanisms 0 4 5.00 3.00 11.00 3.00 $1,523.19 $0.00 $0.00 87 $6,016.60Subtotal 0 4 5.00 3.00 11.00 3.00 $1,523.19 $0.00 $0.00 87 $6,016.60TOTAL varies varies 0.00 varies varies varies varies varies varies 17,049 $1,046,173.3989EXHIBIT 7ANNUAL ESTIMATED RESPONDENT BURDEN AND COSTPERMIT CONDITIONSNumber ofRespondents Hours and Costs per RespondentTotal Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total TotalInterim $122.72/ $72.54/ $54.04/ $32.51/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/Year Cost Cost Year YearConditions applicable to all permits (270.30(h) and (l))Prepare and submit information requestedby EPA 173 N/A 0.00 0.25 1.00 0.25 $80.30 $0.00 $3.20 259.50 $14,445.93Prepare and submit notice of plannedphysical alterations or additions 155 N/A 0.00 0.25 1.00 0.25 $80.30 $0.00 $0.33 232.50 $12,498.04Prepare and submit notice of planned changesor activities w hich may result in noncompliance 78 N/A 0.00 0.25 1.00 0.25 $80.30 $0.00 $0.33 117.00 $6,289.34Prepare and submit letter certifying compliance 39 N/A 0.00 0.25 1.00 0.25 $80.30 $0.00 $0.33 58.50 $3,144.67Prepare and submit monitoring reports 1171 N/A 0.00 0.25 8.00 0.25 $458.58 $0.00 $3.20 9953.50 $540,747.31Prepare and submit reports of compliance ornoncompliance w ith compliance schedule 14 N/A 0.00 0.25 2.00 1.00 $158.73 $0.00 $3.20 46.38 $2,310.67Compile and submit information for 24-hourreporting of a release of hazardous w aste, a fire,or an explosion 14 N/A 0.00 0.50 8.00 0.50 $484.85 $0.00 $3.20 128.43 $6,964.40Prepare and submit notice of noncompliancedue to a release, fire, or explosion 14 N/A 0.00 0.50 4.00 0.50 $268.69 $0.00 $0.33 71.35 $3,838.84Prepare and submit a report of othernoncompliance 29 N/A 0.00 0.50 2.00 0.50 $160.61 $0.00 $3.20 85.62 $4,674.99Prepare and submit omitted or correctedinformation 14 N/A 0.00 0.25 0.50 0.25 $53.28 $0.00 $3.20 14.27 $806.01TOTAL varies N/A varies varies varies varies varies varies varies 10,967.05 $595,720.2090EXHIBIT 8TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARYTotal Total Total Total TotalHours per Capital per O&M per Labor Cost Cost perEXHIBIT Year Year Year per Year YearExhibit 1General Facility Standards 466,509 $0 $441,049 $31,532,858 $31,973,907Exhibit 2Recordkeeping Requirements 121,230 $12,658 $0 $5,050,258 $5,062,916Exhibit 3Contingency Plan and Emergency Procedures 433 $0 $123 $23,273 $23,396Exhibit 4Ground-Water Monitoring Requirements 738 $0 $19 $41,871 $41,890Exhibit 5Closure and Post-Closure Requirements 3,072 $0 $71,309 $163,072 $234,381Exhibit 6Financial Requirements 17,049 $0 $3,744 $1,042,429 $1,046,173Exhibit 7Permit Conditions 10,967 $0 $4,624 $591,097 $595,720TOTAL 619,997 12,658 520,867 38,444,859 $38,978,38491EXHIBIT 9ESTIMATED ANNUAL AGENCY BURDEN AND COSTNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total Total$86.56/ $76.38/ $54.94/ $23.44/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/Year Cost Cost Year YearGENERAL FACILITY OPERATING REQUIREMENTSForeign Shipment Import ReportReview foreign shipment import report 52 3 0.00 0.00 1.00 0.00 54.94 0.00 0.00 55.32 $3,039.28Review of records during inspections 13 0 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 13.00 $714.22Subtotal varies varies 0.00 0.00 varies varies varies $0.00 $0.00 68.32 $3,753.50RECORDKEEPING REQUIREMENTSOperating RecordOn-site review of the operating record 864 58 0.00 0.00 2.00 0.00 109.88 0.00 0.00 1,844.00 $101,309.36Subtotal 864 58 0.00 0.00 2.00 0.00 109.88 0.00 0.00 1,844.00 $101,309.36CONTINGENCY PLAN AND EMERGENCY PROCEDURESContingency PlanOn-site review of the contingency plan 1,333 198 0.00 0.00 0.50 0.00 27.47 0.00 0.00 765.50 $42,056.57Emergency Reporting RequirementsReview ow ner/operator's emergency report 13 2 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 15.31 $841.13Subtotal varies varies 0.00 0.00 varies varies varies $0.00 $0.00 780.81 $42,897.70RELEASES FROM SOLID WASTE MANAGEMENT UNITSReview demonstration to terminate compliance period 0 N/A 0.00 0.00 4.00 0.10 $222.10 $0.00 $0.00 0.00 $0.00Review and approve proposed samplingprocedures 13 N/A 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 26.00 $1,428.44Subtotal varies 0 0.00 0.00 varies varies varies 0.00 0.00 26.00 $1,428.44CLOSURE AND POST-CLOSUREReview closure plans N/A 0 0.00 0.00 15.00 0.00 $824.10 $0.00 $0.00 0.00 $0.00Review closure plan amendment notifications N/A 4 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 7.80 $428.53Review partial or final closure notificationsand closure plans (interim status facilities) 19 9 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 56.00 $3,076.64Review demonstration for extension for treatment, storage, or removal of hazardous w aste 4 2 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 11.20 $615.33Review demonstration for extension ofclosure period 4 2 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 5.60 $307.66Review demonstration for receivingnon-hazardous w aste 1 0 0.00 0.00 0.50 0.00 $27.47 $0.00 $0.00 0.70 $38.46Review closure certifications 19 9 0.00 0.00 4.00 0.00 $219.76 $0.00 $0.00 112.00 $6,153.28Review survey plat 1 4 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 4.50 $247.23Review post-closure plan N/A 0 0.00 0.00 15.00 0.00 $824.10 $0.00 $0.00 0.00 $0.00Review post-closure plan amendmentnotifications and amended plans N/A 1 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 2.80 $153.83Review post-closure plan modifications N/A 1 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 1.40 $76.92Review resubmitted plans N/A 0 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 0.14 $7.69Review petition to extend or reduce thepost-closure care period N/A 1 0.00 0.50 1.00 0.00 $93.13 $0.00 $0.00 2.10 $130.38Review hazardous w aste disposal records 2 7 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 9.00 $494.46Review hazardous w aste notation certification 2 7 0.00 0.00 1.00 0.00 $54.94 $0.00 $0.00 9.00 $494.46Review post-closure care certification 0 0 0.00 0.00 4.00 0.00 $219.76 $0.00 $0.00 0.00 $0.00Subtotal varies varies 0.00 varies varies varies varies $0.00 $0.00 222.24 $12,224.8792EXHIBIT 9 (con't)ESTIMATED ANNUAL AGENCY BURDEN AND COSTNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total Total$86.56/ $76.38/ $54.94/ $23.44/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/Year Cost Cost Year YearFINANCIAL REQUIREMENTSReview increases in sum amounts, if costestimate modified, and additional reportsof financial conditions 0 0 0.00 0.00 8.00 0.00 $439.52 $0.00 $0.00 0.00 $0.00Review new estimates and instruments 0 0 0.00 0.00 7.50 0.00 $412.05 $0.00 $0.00 0.00 $0.00Review annual closure cost updatesto reflect inflation 0 0 0.00 0.00 0.50 0.00 $27.47 $0.00 $0.00 0.00 $0.00Review liability claim notifications 0 0 1.00 0.00 2.00 0.00 $196.44 $0.00 $0.00 0.00 $0.00Review and approve or deny petition for variance 0 59 0.00 0.50 1.00 0.00 $93.13 $0.00 $0.00 88.50 $5,494.67Review revisions due to plan changes 56 274 0.00 0.00 8.00 0.00 $439.52 $0.00 $0.00 2,640.00 $145,041.60Review updated financial test and corporateguarantee information 1,390 3,624 0.00 0.00 8.00 0.00 $439.52 $0.00 $0.00 40,112.00 $2,203,753.28Review bankruptcy notifications 28 72 1.00 0.00 2.00 0.00 $196.44 $0.00 $0.00 300.00 $19,644.00Review State assumptions of responsibility/required mechanism documentation 0 0 0.00 0.00 2.00 0.00 $109.88 $0.00 $0.00 0.00 $0.00Review corrective action financial assurance 0 0 1.00 0.00 8.00 0.00 $526.08 $0.00 $0.00 0.00 $0.00Subtotal varies varies varies varies varies 0.00 varies $0.00 $0.00 43,140.50 $2,373,933.55PERMIT CONDITIONSReview submitted information 173 0 0.00 0.25 1.00 0.10 $76.38 $0.00 $0.00 233.55 $13,213.57Review notice of planned physical alterationsor additions 155 0 0.00 0.00 0.50 0.10 $29.81 $0.00 $0.00 93.00 $4,621.17Review notice of planned changes or activities 78 0 0.00 0.25 0.50 0.10 $48.91 $0.00 $0.00 66.30 $3,814.90Review letter certifying compliance 39 0 0.00 0.25 0.50 0.10 $48.91 $0.00 $0.00 33.15 $1,907.45Review monitoring reports 1171 0 0.00 0.00 5.00 0.00 $274.70 $0.00 $0.00 5,855.00 $321,673.70Review reports of compliance or noncompliance 13.33 0 0.00 0.00 1.00 0.10 $57.28 $0.00 $0.00 14.66 $763.60Review information concerning a release,fire, or explosion 13 0 0.00 0.00 0.50 0.10 $29.81 $0.00 $0.00 8.00 $397.42Review notices and reports of noncompliance 13 0 0.00 0.00 0.50 0.10 $29.81 $0.00 $0.00 8.00 $397.42Review reports of other noncompliance 27 0 0.00 0.00 0.50 0.10 $29.81 $0.00 $0.00 16.00 $794.84Review corrected information 13 0 0.00 0.00 0.50 0.25 $33.33 $0.00 $0.00 10.00 $444.29Subtotal varies 0 0.00 varies varies varies varies $0.00 $0.00 6,337.65 $348,028.36TOTAL varies varies varies varies varies varies varies varies varies 52,419.52 $2,883,575.7893EXHIBIT 10ESTIMATED ANNUAL STATE AGENCY BURDEN AND COSTNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total Total$57.54/ $54.02/ $32.32/ $20.62/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/Year Cost Cost Year YearGENERAL FACILITY OPERATING REQUIREMENTSForeign Shipment Import ReportReview foreign shipment import report 52 3 0.00 0.00 1.00 0.00 32.32 0.00 0.00 55.32 $1,787.94Review of records during inspections 13 0 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 13.00 $420.16Subtotal varies varies 0.00 0.00 varies varies varies $0.00 $0.00 68.32 $2,208.10RECORDKEEPING REQUIREMENTSOperating RecordOn-site review of the operating record 864 58 0.00 0.00 2.00 0.00 64.64 0.00 0.00 1,844.00 $59,598.08Subtotal 864 58 0.00 0.00 2.00 0.00 64.64 0.00 0.00 1,844.00 $59,598.08CONTINGENCY PLAN AND EMERGENCY PROCEDURESContingency PlanOn-site review of the contingency plan 1,333 198 0.00 0.00 0.50 0.00 16.16 0.00 0.00 765.50 $24,740.96Emergency Reporting RequirementsReview ow ner/operator's emergency report 13 2 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 15.31 $494.82Subtotal varies varies 0.00 0.00 varies varies varies $0.00 $0.00 780.81 $25,235.78RELEASES FROM SOLID WASTE MANAGEMENT UNITSReview demonstration to terminate compliance period 0 N/A 0.00 0.00 4.00 0.10 $131.34 $0.00 $0.00 0.00 $0.00Review and approve proposed samplingprocedures 13 N/A 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 26.00 $840.32Subtotal varies 0 0.00 0.00 varies varies varies 0.00 0.00 26.00 $840.32CLOSURE AND POST-CLOSUREReview closure plans N/A 0 0.00 0.00 15.00 0.00 $484.80 $0.00 $0.00 0.00 $0.00Review closure plan amendment notifications N/A 4 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 7.80 $252.10Review partial or final closure notificationsand closure plans (interim status facilities) 19 9 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 56.00 $1,809.92Review demonstration for extension for treatment, storage, or removal of hazardous w aste 4 2 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 11.20 $361.98Review demonstration for extension ofclosure period 4 2 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 5.60 $180.99Review demonstration for receivingnon-hazardous w aste 1 0 0.00 0.00 0.50 0.00 $16.16 $0.00 $0.00 0.70 $22.62Review closure certifications 19 9 0.00 0.00 4.00 0.00 $129.28 $0.00 $0.00 112.00 $3,619.84Review survey plat 1 4 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 4.50 $145.4494EXHIBIT 10 (con't)ESTIMATED ANNUAL STATE AGENCY BURDEN AND COSTNumber ofRespondents Hours and Costs per Respondent or Activity Total Hours and CostsLegal Manager Technical Clerical Labor Capital/ Total Total$57.54/ $54.02/ $32.32/ $20.62/ Cost Startup O&M Hours per Cost perINFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/Year Cost Cost Year YearReview post-closure plan N/A 0 0.00 0.00 15.00 0.00 $484.80 $0.00 $0.00 0.00 $0.00Review post-closure plan amendmentnotifications and amended plans N/A 1 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 2.80 $90.50Review post-closure plan modifications N/A 1 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 1.40 $45.25Review resubmitted plans N/A 0 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 0.14 $4.52Review petition to extend or reduce thepost-closure care period N/A 1 0.00 0.50 1.00 0.00 $59.33 $0.00 $0.00 2.10 $83.06Review hazardous w aste disposal records 2 7 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 9.00 $290.88Review hazardous w aste notation certification 2 7 0.00 0.00 1.00 0.00 $32.32 $0.00 $0.00 9.00 $290.88Review post-closure care certification 0 0 0.00 0.00 4.00 0.00 $129.28 $0.00 $0.00 0.00 $0.00Subtotal varies varies 0.00 varies varies varies varies $0.00 $0.00 222.24 $7,197.99FINANCIAL REQUIREMENTSReview increases in sum amounts, if costestimate modified, and additional reportsof financial conditions 0 0 0.00 0.00 8.00 0.00 $258.56 $0.00 $0.00 0.00 $0.00Review new estimates and instruments 0 0 0.00 0.00 7.50 0.00 $242.40 $0.00 $0.00 0.00 $0.00Review annual closure cost updatesto reflect inflation 0 0 0.00 0.00 0.50 0.00 $16.16 $0.00 $0.00 0.00 $0.00Review liability claim notifications 0 0 1.00 0.00 2.00 0.00 $122.18 $0.00 $0.00 0.00 $0.00Review and approve or deny petition for variance 0 59 0.00 0.50 1.00 0.00 $59.33 $0.00 $0.00 88.50 $3,500.47Review revisions due to plan changes 56 274 0.00 0.00 8.00 0.00 $258.56 $0.00 $0.00 2,640.00 $85,324.80Review updated financial test and corporateguarantee information 1,390 3,624 0.00 0.00 8.00 0.00 $258.56 $0.00 $0.00 40,112.00 $1,296,419.84Review bankruptcy notifications 28 72 1.00 0.00 2.00 0.00 $122.18 $0.00 $0.00 300.00 $12,218.00Review State assumptions of responsibility/required mechanism documentation 0 0 0.00 0.00 2.00 0.00 $64.64 $0.00 $0.00 0.00 $0.00Review corrective action financial assurance 0 0 1.00 0.00 8.00 0.00 $316.10 $0.00 $0.00 0.00 $0.00Subtotal varies varies varies varies varies 0.00 varies $0.00 $0.00 43,140.50 $1,397,463.11PERMIT CONDITIONSReview submitted information 173 0 0.00 0.25 1.00 0.10 $47.89 $0.00 $0.00 233.55 $8,284.45Review notice of planned physical alterationsor additions 155 0 0.00 0.00 0.50 0.10 $18.22 $0.00 $0.00 93.00 $2,824.41Review notice of planned changes or activities 78 0 0.00 0.25 0.50 0.10 $31.73 $0.00 $0.00 66.30 $2,474.71Review letter certifying compliance 39 0 0.00 0.25 0.50 0.10 $31.73 $0.00 $0.00 33.15 $1,237.35Review monitoring reports 1171 0 0.00 0.00 5.00 0.00 $161.60 $0.00 $0.00 5,855.00 $189,233.60Review reports of compliance or noncompliance 13.33 0 0.00 0.00 1.00 0.10 $34.38 $0.00 $0.00 14.66 $458.31Review information concerning a release,fire, or explosion 13 0 0.00 0.00 0.50 0.10 $18.22 $0.00 $0.00 8.00 $242.90Review notices and reports of noncompliance 13 0 0.00 0.00 0.50 0.10 $18.22 $0.00 $0.00 8.00 $242.90Review reports of other noncompliance 27 0 0.00 0.00 0.50 0.10 $18.22 $0.00 $0.00 16.00 $485.80Review corrected information 13 0 0.00 0.00 0.50 0.25 $21.32 $0.00 $0.00 10.00 $284.13Subtotal varies 0 0.00 varies varies varies varies $0.00 $0.00 6,337.65 $205,768.56TOTAL varies varies varies varies varies varies varies varies varies 52,419.52 $1,698,311.9495EXHIBIT 11TOTAL ESTIMATED STATE AGENCY BURDEN AND COST SUMMARYTotal TotalHours per Cost perEXHIBITYear YearGeneral Facility Standards 68 2,208Recordkeeping Requirements 1,844 59,598Contingency Plan and Emergency Procedures 781 25,236Releases from Solid Waste Management Units 26 840Closure and Post-Closure Requirements 222 7,198Financial Requirements 43,141 1,397,463Permit Conditions 6,338 205,769TOTAL52,420 $1,698,312