### SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.14

“NOTIFICATION OF REGU LATED WASTE ACTIVITY

AND 2009 HAZARDOUS WASTE REPORT”

September 10, 2009

Office of Resource Conservation and Recovery United States Environmental Protection Agency Washington, D.C. 20460

### TABLE OF CONTENTS

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

2. NEED FOR AND USE OF THE COLLECTION .............................................................................. 9 2(a) NEED AND AUTHORITY FOR THE COLLECTION ........................................................... 9 2(b) PRACTICAL UTILITY AND USERS OF THE DATA ........................................................ 10

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA .............. 12 3(a) NONDUPLICATION ........................................................................................................... .. 12 3(b) PUBLIC NOTICE ............................................................................................................ ....... 12 3(c) CONSUL TATIONS ............................................................................................................ .... 13 3(d) EFFECTS OF LESS FREQUENT COLLECTION ................................................................ 14 3(e) GENERAL GUIDELINES ...................................................................................................... 15 3(f) CONFIDENTIALITY .......................................................................................................... ... 15 3(g) SENSITIVE QUESTIONS ...................................................................................................... 15

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .............................................. 16 4(a) RESPONDENTS AND NAICS CODES ................................................................................ 16 4(b) INFORMATION REQUESTED ............................................................................................. 16

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT ...................................................... 25 5(a) AGENCY ACTIVITIES ........................................................................................................ . 25 5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................ 27 5(c) SMALL ENTITY FLEXIBILITY ........................................................................................... 28 5(d) COLLECTION SCHEDULE .................................................................................................. 28

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION .............................. 32 6(a) ESTIMATING RESPONDENT BURDEN HOURS .............................................................. 32 6(b) ESTIMATING RESPONDENT COSTS ................................................................................ 38 6(c) ESTIMATING AGENCY HOUR AND COST BURDEN .................................................... 39 6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR

AND COST BURDEN ............................................................................................................ 39 6(e) BOTTOM LINE HOUR AND COST BURDEN ................................................................... 46 6(f) REASONS FOR CHANG E IN BURDEN .............................................................................. 47 6(g) PUBLIC BURDEN STATEMENT ......................................................................................... 491 1. IDENTIFICATION OF THE INFORMATION COLLECTION

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

This Information Collection Request (ICR) is entitled “Notificati on of Regulated Waste Activity and 2009 Hazardous Waste Report,” EPA ICR Number 0976.14.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

This is a request to renew two currently approved ICRs of the U.S. Environmental Protection Agency (EPA):

• “Notification of Regulated Waste Activity,” EPA ICR Number 0261.15. The

Notification ICR addresses the notification requireme nts under Section 3010 of Subtitle C of the Resource Conservation and Recovery Act (RCRA), as amended. RCRA Section 3010 requires any person who generates, transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal of regulated wastes to notify EPA of their activities, including the location and general description of the activ ities and the regulated wastes handled. As required by statute, EPA promulga ted regulations to implement these notification requirements at 40 CFR Parts 262, 263, 264, 265, 266, 270, 273, and

279.

• “2007 Hazardous Waste Report ,” EPA ICR Number 0976.13. The Hazardous Waste Report ICR addresses the requir ements of Sections 3002 and 3004 of RCRA, as amended, which requ ire reporting to EPA or to authorized States at least every two years. The Hazardou s Waste Report [EPA Form 8700-13 Form A/B], or comparable State report, is us ed by generators and treatment, storage, and disposal facilities (TSDFs) to satisfy this requirement.

EPA integrated the above two ICRs into th is current ICR, EPA ICR Number 0976.14, to ensure consistency and minimize duplication in it s burden assumptions and estimates, since both ICRs address some of the same reporting elem ents under their respective requirements. In particular, both ICRs address the use of the RCRA Subtitle C Site Identification Form (i.e., the Site ID Form). Specifically, the Notification ICR addresses the requirements for all regulated

entities to submit the Site ID Fo rm (or alternative document, if specified) to notify EPA or the authorized State. The Hazardous Waste Repor t ICR addresses the requirements for large quantity generators (LQGs) 1 and TSDFs to prepare and submit the Site ID Form as part of their Hazardous Waste Report. Incorporating these two ICRs into this current ICR has allowed EPA to more comprehensively estimate the burden of th e Site ID Form and other collections, ensure consistency and nonduplication in its analysis, and address recent ch anges to the Site ID Form.

1 An LQG is a facility that generates 1,000 kilogram s (2,200 pounds) or more of hazardous waste in any single calendar month, or more than 1 kilogram (2.2 pounds) of acute hazardous waste in any single calendar month, or more than 100 kilograms (220 pounds) of acute hazardous waste spill cl ean-up material in any single calendar

month.2 In addition, EPA integrated into this current ICR two additional reporting requirements

related to the Site ID Form:

• The requirement at 40 CFR 260.42 that provides that hazardous secondary material generators, tolling contractor s, toll manufacturers, reclaimers, and intermediate facilities managing hazardous secondary materials that are excluded from regulation under section 261.2(a)(2)(ii) or section 261.4(a)(23), (24), or (25) must comply with specified notificati on requirements. This requirement is currently addressed in “Revisions to the RCRA Definition of Solid Waste,” EPA

ICR Number 2310.01.

• The requirements at 40 CFR 262.203 and 262.204 that provide the option to comply with an alternative set of generator requirements applicable to laboratories to eligible academic entities, teaching hos pitals that are not owned by a college or university, and non-profit research institu tes that are not owned or operated by a college or university. In order to co mply with these alternative standards, facilities must comply with specified notification requirements. These requirements are currently addressed in “Generator Standards Applicable to Laboratories Owned by Eligible Academ ic Entities,” EPA ICR Number 2317.01.

Sections 1 through 5 of this document descri be the information collection requirements covered in this ICR (e.g., in regard to need a nd use of the information collected). Section 6

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

The following paragraphs briefly summarize the information collection requirements

covered in this ICR.

(1) Notification of Regulated Waste Activity

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

40 CFR 260.42(a) provides that hazardous secondary material generators, tolling contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous secondary materials which are excluded from re gulation under section 261.2( a)(2)(ii) or section 261.4(a)(23), (24), or (25) must send a notificatio n prior to operating unde r the exclusion(s) and by March 1 of each even numbered year thereaf ter to the Regional Administrator using EPA Form 8700-12 (i.e., the Site ID Form) that incl udes the specified information at section 260.42(a)(1)-(10).

Section 260.42(b) provides that, if a hazardous secondary material generator, tolling contractor, toll manufacturer, recl aimer or intermediate facility has submitted a notification, but then subsequently stops managing hazardous se condary materials in accordance with the exclusion(s), the facility must notify the Regional Administrator w ithin thirty (30) days using EPA Form 8700-12. For purposes of this secti on, a facility has stopped managing hazardous secondary materials if the facility no longer ge nerates, manages and/or reclaims hazardous3 secondary materials under the ex clusion(s) and does not exp ect to manage any amount of hazardous secondary materials for at least one year.

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

Facilities that generate , transport, recycle, treat, store, or dispose of hazardous waste as defined by 40 CFR Part 261 must notify EPA of th eir hazardous waste ac tivities and obtain an

EPA Identification Number. All of these facili ties are required to use EPA Form 8700-12 (i.e., the Site ID Form) to notify EPA of their ha zardous waste activities . These notification requirements are codified at 40 CFR Pa rts 262, 263, 264, 265, 266, 270, and 273. The specific notification requirements for each of these parts are described below and listed in Table 1.

40 CFR Parts 262, 263, 264, and 265 include the no tification requirements for generators, transporters, and owners or operators of perm itted and interim status TSDFs, respectively. Sections 262.12, 263.11, 264.11, and 265.11 list the specific notification requirements. Persons regulated under these sections must obtain an EPA Identification Number before treating, storing, transporting, offering for transpor t, or disposing of hazardous waste.

40 CFR Part 266, Subpart D includes notific ation requirements for generators and transporters; storers; and users of recyclable materials that are used in a manner that constitutes disposal. Specifically, sections 266.21, 266.22, and 266.23 subject generators and transporters of these materials; storers who are not the ultimate users; and users, respectively, to the notification requirement under RCRA Section 3010. In additi on, these sections also subject these same generators and transporters; stor ers; and users to all of the ap plicable requirements of 40 CFR Parts 262 and 263; Parts 264 and 265, Subpart s A through L; and Parts 264 and 265, respectively, that include the sp ecific mechanics for implementing the notification requirements as described in sections 262.12, 263.11, 264.11, and 265.11.

40 CFR Part 266, Subpart F includes notif ication requirements for generators, transporters, and storers of recyclable materials that are utilized for precious metal recovery. Specifically, section 266.70(b)(1) subjects these facilities to the RCRA Section 3010 notification requirements.

40 CFR Part 266, Subpart G includes notification requirements for owners or operators ofinterim status and permitted TSDFs that store spent lead-acid batteries (other than spent leadacid batteries that are regenera ted) before reclaiming them. Specifically, section 266.80(b)(1)(i) requires interim status TSDFs that store thes e batteries before reclaiming them meet the notification requirements of RC RA Section 3010. In addition, section 26 6.80(b)(2)(i) requires permitted TSDFs that store these batteries be fore reclaiming them meet the notification requirements of RCRA Section 3010.

40 CFR Part 266, Subpart H includes notification requirements for facilities that burn or process hazardous waste in a boiler or industr ial furnace (BIF). Subpart H also subjects generators, transporters, and storers (including processors, blenders, and distributors of hazardous waste fuel) of hazardous waste that is bu rned or processed in a BIF to the notification requirements of 40 CFR Parts 262, 263, and 264 a nd 265, respectively. Specifically, sections4 266.100(c)(1)(i) and 266.100(f)(1) require that owne rs or operators of smelting, melting, and refining furnaces that processes hazardous waste either solely for metals recovery or for recovery of economically significant amounts of certain precious metals, resp ectively, to provide a written, one-time notification of their hazardous waste activitie s. In addition, sections 266.101(a), 266.101(b), and 266.101(c) requi re that generators, tran sporters, and storers of hazardous waste that is burned or processed in a BIF follow specific notification requirements and procedures of sections 262.12, 263.11, and 264.11 and 265.11, respectively. Further, sections 266.102(a)(2)(ii) and 266.103(a)(4)(ii) s ubject owners or operators of permitted and interim status BIFs that burn or process h azardous waste, respectively, to 40 CFR Parts 264 and 265, Subpart B, which includes the section 264.11 and 265.11 notification requirements. Finally, section 266.108(d) requires that facilities that qualify for th e small quantity on-site burner exemption to provide a written, one-time notif ication of their hazar dous waste activities.

40 CFR Part 270 prescribes the timing for notif ication of hazardous waste activities due to the listing of a hazardous waste in 40 CFR Part 261. Specifically, section 270.1(b) requires that “not later than 90 days after the promulga tion or revision of regulations in Part 261 (identifying and listing hazardous wa stes), generators and transpor ters of hazardous waste, and owners or operators of hazardous waste treatment, storage, or disposal fa cilities may be required

to file a notification of th at activity under Section 3010.”

40 CFR Part 273, Subpart D describes certain conditions under which a transporter of universal waste may be subject to the Sec tion 3010 notification requirements of RCRA. Specifically, section 273.54 makes tr ansporters who determine that any material resulting from a

release of universal waste is a hazardous waste subject to 40 CFR Part 262. As a result, section 273.54 may also make them, in certain circumst ances, subject to the section 262.12 notification requirements and procedures.

40 CFR Part 273, Subpart E includes notificati on requirements for des tination facilities of universal waste. Specificall y, section 273.60(a) subjects owners or operators of destination facilities to the notification requirement under RCRA Section 3010. Section 273.60(a) also subjects destination facilitie s to all applicable requirem ents of 40 CFR Parts 264, 265, 266, 268, and 270, which include the section 264.11 and 265.11 notification requireme nts and procedures.5 Table 1 Hazardous Waste Notification Requirements

40 CFR Regulatory

Citation Regulated Entity

§262.12 Hazardous Waste Generators

§263.11 Hazardous Waste Transporters

§264.11 Permitted Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs)

§265.11 Interim Status Hazardous Waste Trea tment, Storage, and Disposal Facilities

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

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

§266.23 Users of Recyclable Material s in a Manner Constituting Disposal

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

§266.80(b)(1)(i) Interim Status TSDFs Storing Spent Lead-Acid Batteries (other than Spent Batteries that are to be Regenerated) before Reclamation

§266.80(b)(2)(i) Permitted TSDFs Storing Spent Lead-Acid Batteries (other than Spent Batteries that are to be Regenera ted) before Reclamation

§266.100(c)(1)(i) Smelting, Melting, and Refining Furnaces Processing Hazardous Waste Solely for Metal Recovery

§266.100(f)(1) Smelting, Melting, and Refining Furnaces Processing Hazardous Waste for Recovery of Significant Amounts of Certain Precious Metals

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

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

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

§266.102(a)(2)(ii) Permitted Boile rs and Industrial Furnaces

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

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

Industrial Furnaces

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

Wastes

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

Hazardous Waste

§273.60(a) Universal Waste Destination Facilities6 (c) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

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

40 CFR 262.203(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subj ect to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number. An eligible academic entity that is a conditiona lly exempt small quantity generator (CESQG) and

does not have an EPA Identification Number must notify that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible ac ademic entity that are on-site. An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs ) that is electing to be subject to the requirements of Subpart K.

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

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

Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity for as long as its laboratories are subject to Subpart K.

Section 262.203(d) provides that a teaching hos pital that is not ow ned by a college or university must keep a copy of its formal wr itten affiliation agreement with a college or university on file at the teaching hospital for as long as its laboratories are s ubject to Subpart K.

Section 262.203(e) provides th at a non-profit research inst itute that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the non-pr ofit research institute for as l ong as its laborator ies are subject to Subpart K.

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

40 CFR 262.204(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all the laboratories owned by the eligible ac ademic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify that it is withdrawing from the requireme nts of Subpart K for all the laboratories owned by the eligible academic entity th at are on-site. An eligible academic entity must submit a separate notification (Site ID Fo rm) for each EPA Identification Number (or site, for CESQGs) that is withdrawing fr om the requirements of Subpart K.

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

out the fields on the form that are specified at section 262.204(b)(1)-(11).7 Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the

notification.

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

Large quantity handlers of uni versal waste must notify EP A of their universal waste

activities and obtain an EPA Identification Nu mber. These notification requirements are codified at 40 CFR Part 273, Subpart C. Sp ecifically, section 273.32(a) requires large quantity

handlers of universal waste to ha ve notified EPA of their universal waste handling activities and

received an EPA Identification Number prior to meeting or exceeding the 5,000 kilogram storage limit, unless they already have notified EP A, as provided by section 273.32(a)(2) or 273.32(a)(3). Section 273.32(b) prescribes the co ntents of the notification. Large quantity handlers of universal waste have the option of using a letter in lieu of submitting EPA Form 8700-12 (i.e., the Site ID Form).

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

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

EPA Identification Number. These notification requirements are codified at 40 CFR Part 279. (Refer to Table 2.) Specifically, se ctions 279.42, 279.51, 279.62, and 279.73 require used oil transporters and transfer facilities, used oil processors and re-refiners, burners of off-specification used oil, and used oil fuel ma rketers, respectively, w ho have not previously complied with RCRA Section 3010 requirements ( under 40 CFR Part 266, Subpart E) to comply with these requirements and obtain an EPA Identif ication Number. These used oil handlers have the option of using a letter in lieu of subm itting EPA Form 8700-12 (i.e., the Site ID Form).

Table 2 Used Oil Notification Requirements

40 CFR Regulatory

Citation Regulated Entity

§279.42 Used Oil Transporters and Transfer Facilities

§279.51 Used Oil Processors and Re-Refiners

§279.62 Burners of Off-Specification Used Oil

§279.73 Used Oil Fuel Marketers8 (2) Hazardous Waste Report

RCRA Sections 3002 and 3004, as amende d by the Hazardous and Solid Waste Amendments of 1984 (HSWA), require reporting to EPA or to aut horized States at least every two years. The Hazardous Waste Report [EPA Form 8700-13 Form A/B], or comparable State report, is used by generators and TSDFs to satisfy this requirement.

Hazardous waste generators and TSDFs repor t information on the quantities, type, and management method of generated hazardous wastes and hazardous wastes rece ived from off-site. The data collected are used by EPA’s Office of Resource Conservation and Recovery (ORCR) to prepare a national report that is made available to C ongress and the public, summarizing hazardous waste generation and management activiti es. The data also are used by EPA and the States for programmatic and regulatory needs.9 2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORIT Y FOR THE COLLECTION

(1) Notification of Regulated Waste Activity

Section 3010 of Subtitle C of RCRA, as amended, requires any person who generates, transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal of regulated wastes to not ify EPA of their activities, including the location and general description of the activities and the regulated wast es handled. As required by statute, EPA promulgated regulations to implem ent these notification requirements at 40 CFR Parts 262, 263, 264, 265, 266, 270, 273, and 279. (See Section 1(b) above for a detailed listing of notification requirements by type of regulated waste and regulat ed entity). EPA needs this information to determine the universe of pers ons who generate, handle, and manage these regulated wastes; assign EPA Identification Number s; and ensure that these regulated wastes are managed in a way that protects human health and the environment, as required by RCRA, as

amended.

(2) Hazardous Waste Report

RCRA Sections 3002 and 3004 authorize the Ha zardous Waste Report. Both sections require EPA to establish standards for recordkeep ing and reporting of hazardous waste. Section 3002 applies to hazardous waste generators and Section 3004 applies to hazardous waste TSDFs. The implementing regulations are found at 40 CFR parts 262.40(b) and (d); 262.41(a)(1)-(5), (a)(8), and (b); 264.75(a)-(e) and (j); 265.75(a)-(e) a nd (j); and 270.30(l)(9). This is mandatory reporting by the respondents.

Section 3002(a)(6) requires subm ission of reports to EPA or th e States at least every two years on the: (1) quantities and nature of hazardo us wastes that have been generated during the year and (2) disposition of these hazardous wastes.

Section 3004(a) requires EPA to issue regula tions establishing performance standards applicable to owners and operators of facilities for the treatment, storage, or disposal of hazardous waste that include reporting and maintain ing records of all hazardous wastes treated, stored, or disposed and the manner in which su ch wastes were treated, stored, or disposed.

There are a number of uses of the Hazardous Waste Report data. EPA uses these data for planning and developing regulations. In a ddition, Hazardous Waste Report data allows the Agency to determine whether its regulations ar e having the desired effect on the generation and management of hazardous waste. For exam ple, Hazardous Waste Report data provides

information on whether wastes have shifted from one method of dis posal to another. Some State uses of Hazardous Waste Report data include: support of planning, fee assessment, compliance monitoring, and enforcement.10 2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Notification of Regulated Waste Activity

EPA enters notification information submitte d by respondents into an EPA national data system and assigns EPA Identification Numbers. EPA uses the information primarily for tracking purposes, and secondarily for a variety of enforcement and inspection purposes. In addition, EPA uses this informa tion to identify the universe of regulated waste generators, handlers, and managers and their specific regulated waste activi ties. Finally, EPA uses this information to ensure that regulated waste is managed properly, that st atutory provisions are upheld, and that regulations are adhered to by facili ty owners or operators.

(2) Hazardous Waste Report

Implementation of the RCRA program require s the collection of information on the characteristics of the regulated community genera lly (e.g., number of generators and TSDFs), as well as the specific characteristics of individual sites (e.g., waste ha ndling activities undertaken).

This information is used for waste activit y monitoring, compliance monitoring, technical assistance, program planning, waste minimizatio n, and other program activities taken by EPA

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

The Hazardous Waste Report also provides info rmation to States for tracking shipments of waste. Many States do not collect or track manifests, which provide, information on off-site shipments of hazardous waste; therefore, the Ha zardous Waste Report serves as the only source

of this information.

EPA compiles and publishes the National Biennial RCRA Hazardous Waste Report based on the data for each odd number reporting year . The reports for 1991 to 2007 are available on

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

.

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

• Describing the various source activities th at generate hazardous waste and the generated waste type s and quantities.

• Describing the management methods by whic h the waste is treated, disposed, or recycled and the quantities managed by each method.

• Providing information for analysis of tre nds in waste generation, waste treatment and disposal, recycli ng, and source reduction.

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

State.11 • Estimating available capacity for treati ng, recycling, and disposing hazardous

wastes.

Additionally, EPA utilizes th e Hazardous Waste Report information for planning and developing regulations; regulati on development depends on desc riptions and quantities of generated hazardous waste and management methods used for treatment, recycling, and disposal. The information allows the Agency to determ ine whether regulations are having the desired effect on the generation and management of haza rdous waste; for example, the report provides

information on whether the treatment of wastes has shifted from one method to another. EPA also uses the information for conducting technical assistance, planning f acility inspections, and carrying out regulatory enforcement. States use the information for many of the same purposes as EPA; other State uses include planning, se tting waste minimization goals, assessing fees, monitoring compliance, and carrying out enforcement.

EPA and States receive requests for the information from many public and private organizations including government agencies, busi nesses, public interest groups, and interested citizens. Many requests come from businesses that supply chemicals, equipment, and services to hazardous waste generators and TSDFs.12 3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) NONDUPLICATION

The information collected under this ICR is not available from any source other than respondents. EPA’s ORCR is the only office with in the Agency requiring the recordkeeping or reporting of this information. No other Federal ag ency or department collects this information.

The RCRA site identification informa tion is collected on one common form

― the RCRA

Subtitle C Site Identification Form

― for the Notification of Regul ated Waste Activity, the RCRA Hazardous Waste Part A Permit Application, and the Hazardous Waste Report. A respondent may submit a copy of a previously reported Site ID Form and note any change s; this verifies and updates the site identification information.

3(b) PUBLIC NOTICE

As indicated in Section 1(b) , this is a request to renew two currently approved ICRs. EPA integrated these two ICRs into this current ICR, “Notification of Regulated Waste Activity and 2009 Hazardous Waste Report,” EPA ICR Nu mber 0976.14, to ensure consistency and minimize duplication in its burden assumptions and estimates. Information on public notices associated with each of the currently approved ICRs is presented below.

• “Notification of Regulated Waste Activity,” EPA ICR Number 0261.15. In compliance with the Paperwork Reduction Act of 1995, EPA issued a public

notice in the Federal Register on March 13, 2009 (74 FR 10909). The public comment period extended through May 12, 2009. EPA received no comments on this ICR in response to the Federal Register notice. A second Federal Register notice was issued on June 29, 2009 (74 FR 31028) announcing that the ICR had been forwarded to the Office of Manage ment and Budget (OMB) for review and approval.

• “2007 Hazardous Waste Report ,” EPA ICR Number 0976.13. In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on May 15, 2009 (74 FR 22922). The public comment period extended through July 14, 2009. EPA received no comments on this ICR in response to the Federal Register notice.13 3(c) CONSULTATIONS

Most of the data and assumptions in th is ICR are based on EPA consultations with industry or data from the Resource Conservati on and Recovery Act Information (RCRAInfo)

system 2 . In developing this current ICR, EPA caref ully reviewed all of the ICR’s data and assumptions and determined that a few should be strengthened based on additional consultations. Specifically, EPA conducted cons ultations on the ICR’s assumpti ons regarding respondents’ hourly and cost burden for completing and submitting the Site ID Form.

Table 3 identifies the seven or ganizations contacted. All se ven organizations indicated that they used a blank Site ID Form to make thei r initial and subsequent no tifications. They also indicated that, individually, they spent betw een 5 minutes and 3 hours reading the form instructions, completing the form, and submitting it to EPA or the authorized State. Based on the information provided by these organizations, th e average hourly burden for completing a blank

Site ID Form for initial and subs equent notifications was estimated to be 1 hour. Of the seven organizations, four submitted th eir notification via certified mail, two submitted the completed form electronically, and one ha nd delivered the notification.

The feedback provided by the organizations id entified in Table 3 is reflected in the burden assumptions of this ICR, as appropriate . Detailed information on EPA’s assumptions regarding these and other activi ties are fully discussed in Sec tion 6 of this document.

Table 3 Organizations EPA Contacted during the Development of this ICR (August 2009)

Organization Contact Name Phone Number

Avista Utilities Kettle Falls Pamela Kish

Environmental Coordinator (509) 495-4948

Weill Cornell Medical College Evan Alberts Environmental Specialist (646) 962-5098

Johnson Oil USA, LLC Jimmy Johnson

President (229) 378-5100

Recycle San Diego Inc. Jeff Harding

President (858) 569-1807

Rexnord Industries, LLC Thomas Frost Environmental Engineer (414) 937-4332

Siemens Energy, Inc. Amy Gray Senior HSE Engineer (407) 736-5183

Southwest Petroleum Waste Management LLC Lore Parker Office Manager (623) 772-5992

2 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA (i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.14 3(d) EFFECTS OF LESS FREQUENT COLLECTION

EPA has carefully considered the information collection burden imposed by the information collection requirements covered in this ICR. EPA is confident that those activities required of respondents are necessary, and to the extent possible, the Agency has attempted to minimize the burden imposed. A number of the required activities, for example, will be performed once (e.g., one-time notifications). EPA believes strongly that, if the minimum information collection requirements are not met, EPA will not be able to ensure that hazardous waste and hazardous secondary material is being properly managed and do not pose a threat to

human health and the environment.

(1) Notification of Regulated Waste Activity

New hazardous waste generators, transpor ters, or TSDFs must submit EPA Form 8700-12 (i.e., the Site ID Form) and obtain an EPA Identification Number prior to treating (including recycling), storing, tr ansporting, offering for transport, or disposing of hazardous waste. Existing hazardous waste generators, tr ansporters, or TSDFs ar e required to notify the Agency of their hazardous waste activity(ies) not later than 90 days af ter the promulgation or revision of regulations in 40 CFR Part 261 (ide ntification and listing of hazardous wastes). Owners or operators of smelting, melting, and refi ning furnaces that process hazardous waste either solely for metals recovery or for recove ry of economically signifi cant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site bu rner exemption under section 266.108(d) must provide a written, one-time notification of th eir hazardous waste activ ities. Under Section 273.32(a), large quantity handlers of universal waste must submit a written, one-time notification of universal waste management to the Regional Administrator and obtain an EPA Identification Number before meeting or exceeding the 5,000 kilogr am storage limit, unless they already have notified EPA, as provided by section 273.32(a) (2) or 273.32(a)(3). Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who have not previously complied with the notification requirement (under 40 CFR Part 266, Subpart E) must submit a written, one-time notification of used oil manage ment activities and obtain an EP A Identification Number. Any reduction in the frequency of this information co llection would prevent the Agency from meeting the statutory requirement s of RCRA Section 3010.

(2) Hazardous Waste Report

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

some States collect information on an annual or quarterly basis, EPA does not require more frequent data collection.15 3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stat ed in the Paperwork Reduction Act of 1995, OMB’s implementing regulations, applicable OMB guidance, and EP A’s ICR Handbook. In addition, this information collection complies with EPA’s Data Standards and Information Quality Guidelines.

3(f) CONFIDENTIALITY

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which defines EPA’s general policy on public disclosure of information, cont ain provisions for confidentiality. The Agency does not anticipate that businesses will assert a clai m of confidentiality cove ring all or part of the information submitted as part of their notifications. However, the Hazardous Waste Report requires businesses to provide information on vari ous aspects of hazardous waste generation and management. Some businesses consider some of their hazardous wast e information to be Confidential Business Information (CBI). A busin ess may, if it desires, protect its Hazardous Waste Report information from public disclosure by asserting a claim of confidentiality covering all or part of its information. If a confidentiality claim were asserted for any of the information collections covered in this ICR, EPA will treat the information in accordance with the regulations cited above. EPA also will ensure that the informati on collection procedures comply with the Privacy Act of 1974 and the OMB Circular 108.

3(g) SENSITIVE QUESTIONS

No questions of a sensitive nature are in cluded in any of the information collection requirements covered in this ICR.16 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

The following is a list of North American Industry Classification System (NAICS) codes associated with industries most likely affect ed by the information collection requirements

covered in this ICR.

NAICS Code Description NAICS Code

Agriculture, Forestry, Fishing, and Hunting 11

Mining 21

Utilities 22

Construction 23

Manufacturing 31-33

Wholesale Trade 42

Retail Trade 44-45

Transportation and Warehousing 48-49

Information 51

Finance and Insurance 52

Real Estate, Rental, Leasing 53

Professional, Scientific, and Technical Services 54

Management of Companies and Enterprises 55

Administrative Support, Waste Management, and Remediation 56

Educational Services 61

Health Care and Social Assistance 62

Arts, Entertainment, Recreation 71

Accommodation and Food Services 72

Other Services 81

Public Administration 92

4(b) INFORMATION REQUESTED

(1) Notification of Regulated Waste Activity

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

40 CFR 260.42(a) provides that hazardous secondary material generators, tolling contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous secondary materials which are excluded from re gulation under section 261.2( a)(2)(ii) or section 261.4(a)(23), (24), or (25) must send a notificatio n prior to operating unde r the exclusion(s) and by March 1 of each even numbered year thereaf ter to the Regional Administrator using EPA Form 8700-12 that includes the specified information at section 260.42(a)(1)-(10).17 Section 260.42(b) provides that, if a hazardous secondary material generator, tolling contractor, toll manufacturer, recl aimer or intermediate facility has submitted a notification, but then subsequently stops managing hazardous se condary materials in accordance with the exclusion(s), the facility must notify the Regional Administrator w ithin thirty (30) days using EPA Form 8700-12. For purposes of this secti on, a facility has stopped managing hazardous secondary materials if the facility no longer ge nerates, manages and/or reclaims hazardous secondary materials under the ex clusion(s) and does not exp ect to manage any amount of hazardous secondary materials for at least one year

(i) Data Items :

• Notification using EPA Form 8700-12, whic h includes the following information:

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

- The name and telephone number of a contact person;

- The NAICS code of the facility;

- The exclusion under which the hazardous secondary materials will be managed (e.g., section 261.2(a)(2)(ii), sect ion 261.4(a)(23), (24), and/or (25));

- For reclaimers and intermediate facilities managing hazardous secondary

materials in accordance with secti on 261.4(a)(24) or (25), whether the reclaimer or intermediate facility has financial assurance (not applicable for persons managing hazardous secondary materials generated and reclaimed

under the control of the generator);

- When the facility expects to be gin managing the hazardous secondary materials in accordance with the exclusion;

- A list of hazardous secondary materials that will be managed according to the exclusion (reported as the EPA hazardous waste numbers that would apply if the hazardous secondary materials were managed as hazardous wastes);

- For each hazardous secondary material, whether the hazardous secondary material, or any portion thereof, w ill be managed in a land-based unit;

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

and

- The certification (included in EPA Form 8700-12) signed and dated by an authorized representative of the facility.

(ii) Respondent Activities :

• Complete and submit EPA Form 8700-12 pr ior to operating under exclusion(s).

• Complete and submit EPA Form 8700-12 by March 1 of each even numbered year thereafter.

• Complete and submit EPA Form 8700-12 i ndicating that the hazardous secondary materials are no longer managed in accordan ce with the exclusion, if applicable.18 (b) Notification of Hazardous Was te Activity under RCRA Section 3010

Facilities that generate , transport, recycle, treat, store, or dispose of hazardous waste as defined by 40 CFR Part 261 must notify EPA of th eir hazardous waste ac tivities and obtain an

EPA Identification Number. These notification requirements are codified at 40 CFR Parts 262, 263, 264, 265, 266, 270, and 273. In order to comply w ith these requirements, facilities must complete and submit EPA Form 8700-12.

(i) Data Item :

• Notification using EPA Form 8700-12, whic h includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be contacted regarding information on the form;

- Ownership information, including the lega l status of the current owner of the facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the in itial notification or a subsequent notification;

- A description of the hazardous wast es handled at the facility; and

- A certification signed by the facility owner, ope rator, or authorized representative.

(ii) Respondent Activities :

• Complete and submit EPA Form 8700-12.

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

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

40 CFR 262.203(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subj ect to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG a nd does not have an EPA Identification Number must notify that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity th at are on-site. An eligible academic entity must submit a separate notification (Site ID Fo rm) for each EPA Identification Number (or site, for CESQGs) that is electing to be subj ect to the requirements of Subpart K.

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

out the fields on the form that are specified at section 262.203(b)(1)-(11).19 Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laborat ories are subject to Subpart K.

Section 262.203(d) provides that a teaching hos pital that is not ow ned by a college or university must keep a copy of its formal wr itten affiliation agreement with a college or university on file at the teach ing hospital while its laboratorie s are subject to Subpart K.

Section 262.203(e) provides th at a non-profit research inst itute that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the non- profit research institute while its laboratories are subject to Subpart K.

(i) Data Items :

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

minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

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

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

• A copy of the formal written affiliation ag reement with a colleg e or university, as specified under section 262.203(d).

• A copy of the formal written affiliation ag reement with a colleg e or university, as specified under section 262.203(e).

(ii) Respondent Activities :

• Eligible academic entities electing to be subject to the requirements of Subpart K must perform the following:

- Complete and submit EPA Form 8700-12; and

- Keep a copy of the notification on file.

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

- Keep a copy of their formal written affiliation agreement with college or university on file while its laborato ries are subject to Subpart K.

• Non-profit research institutes that are not owned by a college or university must:20 - Keep a copy of the formal written af filiation agreement with a college or university on file at the non-profit research institute while its laboratories are subject to Subpart K.

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

40 CFR 262.204(a) provides that an eligible a cademic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all the laboratories owned by the eligible ac ademic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify that it is withdrawing from the requireme nts of Subpart K for all the laboratories owned by the eligible academic entity th at are on-site. An eligible academic entity must submit a separate notification (Site ID Fo rm) for each EPA Identification Number (or site, for CESQGs) that is withdrawing fr om the requirements of Subpart K.

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

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

Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the

notification.

(i) Data Items :

• A Site ID Form with the following fi elds filled out, at a minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

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

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

(ii) Respondent Activities :

• Complete and submit EPA Form 8700-12.

• Keep a copy of the withdrawal notice on file.21 (d) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

Large quantity handlers of uni versal waste must notify EP A of their universal waste

activities and obtain an EPA Identification Nu mber. These notification requirements are codified at 40 CFR Part 273, Subpart C. In or der to comply with these requirements, large quantity handlers of universal waste must complete and submit a notification (EPA Form 8700-12), or complete and submit a letter to EPA requesting an EPA Identification Number.

(i) Data Items :

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

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be contacted regarding information on the form;

- Ownership information, including the lega l status of the current owner of the facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the in itial notification or a subsequent notification;

- A description of the hazardous wast es handled at the facility; and

- A certification signed by the facility owner, ope rator, or authorized representative.

Or

• A letter that includes:

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

- Name and business telephone number of the person who should be contacted regarding the universal wa ste management activities;

- Address or physical location of the un iversal waste management activities;

- A list of all of the type s of universal waste ma naged by the handler; and

- A statement indicating that the handl er is accumulating more than 5,000 kilograms of universal waste at one time and the types of universal waste (e.g., batteries, pesticides, thermostats) the handler is accu mulating above this quantity.

(ii) Respondent Activities :

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

Identification Number.22 (e) Notification of Used Oil Activity under 40 CFR Part 279

Used oil handlers must notify EPA of th eir used oil activitie s and obtain an EPA

Identification Number. These no tification requirements are codifi ed at 40 CFR Part 279. In order to comply with these requirements, used oil handlers must complete and submit EPA Form 8700-12, or complete and submit a letter to EPA requesting an EPA Identification Number.

(i) Data Items :

• Notification using EPA Form 8700-12, whic h includes the following information:

- Name of the facility;

- Facility mailing address;

- Facility location;

- Name, title, and business telephone number of the person who should be contacted regarding information on the form;

- Ownership information, including the lega l status of the current owner of the facility;

- Information on the type of hazardous waste activity;

- Information on whether this is the in itial notification or a subsequent notification;

- A description of the hazardous wast es handled at the facility; and

- A certification signed by the facility owner, ope rator, or authorized representative.

Or

• A letter that includes:

- Company name;

- Owner of company;

- Mailing address of company;

- Name and telephone number of company contact;

- Type of used oil management activity(ies);

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

- Name and telephone number of each cont act at each transfer facility, if applicable (for used oil transporte rs and transfer facilities only).

(ii) Respondent Activities :

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

Identification Number.23 (2) Hazardous Waste Report

The Hazardous Waste Report consists of four forms: RCRA Subtitle Site Identification Form, Waste Generation and Management (Form GM), Waste Received from Off-Site (Form WR), and Off-Site Identificat ion (Form OI; used only by States). Only Large Quantity Generators and Treatment, Storage, and Dispos al Facilities are requi red to complete the Hazardous Waste Report.

(i) Data Items :

• RCRA Subtitle C Site Identification Form. The Site ID Form must be submitted by all sites required to file the Hazar dous Waste Report. This form collects information such as site name, EPA Iden tification Number, address, contact, and type of hazardous waste ge neration and management activ ities taking place at the site; it verifies their information, especially the site’s generator status as the date of submission of the report. It requires a certification signature for the submission of the report.

• Form GM - Waste Generation and Management

. Form GM must be submitted by all respondents that generated or shi pped large quantity generator amounts of RCRA hazardous waste during the reporting y ear. This form collects information on each generated waste, including a narrative waste description, a waste characterization (waste c odes, source, and form), quantity generated, and the method of waste management (whether ma naged on-site or shipped off-site).

• Form WR - Waste Received From Off-Site

. Form WR must be submitted by all

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

This form collects information on each wa ste received from off-site, including a narrative description of the waste, a brief waste characterization (e.g., waste codes), the EPA Identification Number of the off-site generator, the quantity of waste received, and the method of waste management.

• Form OI - Off-Site Identification

. Form OI is not required by EPA; rather, it is provided as an option for States to collect the names and addresses of transporters, generators that ship waste, and receivers of waste reported on GM and WR Forms where only the EPA Identification Number is listed.

(ii) Respondent Activities :

• Read the Hazardous Waste Report instructions.

• Gather information and complete Site ID Form.

• Gather information and complete Form GM.

• Gather information and complete Form WR.24 • Gather information and complete Form OI if required by the St ate (State-optional form, not a Federal form).

• Submit the report to the State (or EPA Regional Office for some States and Territories).

• Maintain a copy of each form for three years.25 5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Notification of Regulated Waste Activity

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

ICR. These activities include:

• For initial notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.

- Entering information into the EPA national data system.

- Generating an EPA Identification Numb er and sending the EPA Identification Number to the facility.

• For subsequent notifications:

- Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.

- Entering information into the EPA national data system.

(2) Hazardous Waste Report

As with most of the RCRA program, the Hazar dous Waste Report data collection process is delegated to the States. Br iefly, the process is as follows.

States (or EPA Regions where the Region implements the RCRA hazardous waste program for a State) provide respondents with e ither the Federal form or a State equivalent, collect the responses, cont act non-respondents, enter the data (o r load files if the State employs electronic methods for preparation and submittal of reports by regulat ed entities) into a database using off-the-shelf software packages which ha ve been developed to support the collection of Hazardous Waste Report data, assure data quality, and forward the data to EPA.

States have discretion on the methods used to identify entities to whom they distribute forms and the subsequent tracking of reports rece ived. Most States gene rate mailing lists based on previous report submittals, augmented by recent notifications of regulated activity. Many States levy fees based on the natu re and extent of regulated activit y identified in the report. EPA makes all reported data (except any that may be claimed as CBI) available to the public on the Internet. This provides further incentive for sites (and also for States and EPA) to ensure the information is complete and accurate because th e public regularly accesses this information.

The Regions support States in data gatheri ng and data quality assessment. Regions may also provide technical support to States for the tr ansfer of their files to EPA for incorporation

into the national database. All files are subm itted to the Agency through EPA’s Central Data Exchange.26 EPA Headquarters produces and distribute s the Federal forms and related guidance, defines the data and file format for data, esta blishes the schedule for submitting data, manages the incorporation of State data into the natio nal database, coordinate s national data quality review, maintains the national database, and prep ares a national report listing major facts about the national picture of hazardous waste genera tion and management for the reporting year.

In practice, this distribution of activities does not always follow this path. In some cases, the Region performs all of the State roles. In others, the Region pr ovides direct processing support for some, but not all, of the collection acti vities. In still other cases, the Regions provide

additional resources to the States.

Agency activities for the Hazardous Waste Report include the following:

• Develop Hazardous Waste Report forms and instructions. Print paper and CD copies.

• Distribute Hazardous Waste Re port forms and instructions. EPA Headquarters

distributes the form and instruction booklet s to the States and Regions. States (or Regions) prepare mailing lists, mail forms and instructions, record receipt of completed forms, and contact sites that fail to respond within the specified time period. Some States may pre-populate Si te ID Forms prior to distribution to reduce the effort needed by respondents as well as to ensure accuracy.

• Develop computer capabilities required to compile national data. EPA Headquarters develops the computer capabi lities required to load data into the national database, the reports which s upport data quality assessment and other programmatic use of the data, and pr eparation of the national report.

• Assist respondents. States, Regions, and Headqua rters provide assistance to respondents. States are, however, the first point of contact for answering respondent questions and assistance.

• Key entry of report submissions. States or EPA Regions, and the regulated entities, key enter or electr onically load the data into a database they select and maintain. The data entry function wa s privatized for the 1999 Hazardous Waste Report process. Many States, Regions, and the regulated community use one of the private vendor’s software packages fo r data entry and recordkeeping. Some reports are entered directly on State or vendor hosted Internet sites and some are

submitted on diskettes.27 • Perform quality assurance. States, Regions, and Hea dquarters all perform data quality assurance. This includes: fo llow-up to non-respondents, detection and correction of unacceptable responses (e.g., in cases where the respondent misunderstood the instructions); verifica tion of exceptional responses (e.g., data reported by a respondent that differ significantly from data reported by the rest of the respondent universe) and identifica tion of significant response changes between reporting years. The national so ftware supports thes e activities with a variety of data editing functions.

Once reports are received, the QA/QC procedures include a hierarchy of assessments. First, system procedures en sure the data has fundamental internal consistency (e.g., required data fields are populated and the values are of the correct data type and within allowed ranges).

Second, the information content of the data for individual sites is evaluated to identify any potential over or unde r reporting (exception reports support identification of extremes and significant variance from one cycle to another).

Third, assessment reports support evalua tion of intra-Stat e and inter-State shipments of wastes to identify potential discrepancies between reports submitted by generators and the TSDF’s who were identified by the generator as receivers

of the waste.

Based on the assessments, States identify cases where accuracy may be questionable. For those cases, they gene rally contact the site to review the information received; and site respondent confirms that th e data are correct or that

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

• Prepare the national report. EPA will prepare The National Biennial RCRA Hazardous Waste Report that will be made availa ble to the Congress and the public.

• Store the data. The Hazardous Waste Reports wi ll be stored by the States or Regions for three years a nd an electronic database may be maintained by each State or Region. The national database is maintained by EPA Headquarters in

RCRAInfo.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

In collecting and analyzing the information asso ciated with this ICR, EPA and authorized States may use a telephone system, personal comput ers, and applicable database software. They will ensure the accuracy and completeness of coll ected information by reviewing the submittals. They will keep records of this information in file cabinets and/or computer systems.28 5(c) SMALL ENTITY FLEXIBILITY

(1) Notification of Regulated Waste Activity

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

that the information to be collected is the minimum amount necessary to fulfill the statutory requirements of RCRA.

(2) Hazardous Waste Report

EPA uses the quantity of waste generated per month to determine the extent to which a firm should be regulated. EPA categorizes generators of less than 1,000 kilograms of non-acute hazardous waste per month as small quantity gene rators (SQGs) and relieves them of specific requirements.

SQGs are not required to file the Hazar dous Waste Report. A SQG who is sent the Hazardous Waste Report booklet due to a change in generator status or error need not respond. They must return a completed RCRA Subtitle C Site Identification Form to update their generator status to ensure they are not subj ect to follow-up contact for biennial reporting.

5(d) COLLECTION SCHEDULE

(1) Notification of Regulated Waste Activity

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

A claimant must prepare and submit a notif ication to EPA prior to operating under the exclusion(s). In addition, the claimant must update and submit notification to EPA by March 1 of each even numbered year thereafter. A cl aimant that submitted a notification but then subsequently stops managing hazardous secondary materials in accordance with the exclusion(s) must submit notification to EPA within 30 days.

(b) Notification of Hazardous Was te Activity under RCRA Section 3010

Under sections 262.12, 263.11, 264.11 and 265.11, all new hazardous waste generators, transporters, and TSDFs must notify EPA of thei r hazardous waste activities and obtain an EPA

Identification Number before tr eating, storing, transporting, offeri ng for transport, or disposing of hazardous waste. Under section 270.1(b), thes e hazardous waste generators, transporters, and TSDFs, are also subject to newly promulgate d or revised regulations at 40 CFR Part 261 (identification and listing of hazardous wastes) and must notify EPA of new or revised hazardous waste activities no later than 90 days after promulgation or revision. In addition, other generators; transporters; recyclers; and treatment, storage and disposal fa cilities that are subject to notification requirements under sectio ns 266.21, 266.22, 266.23, 266.70(b)(1 ), 266.80(b)(1)(i), 266.80(b)(2)(i), 266.101(a), 266.101(b), 266.101(c), 266.102(a)(2)(ii), 266.103(a)(4)(ii), and 273.60(a) must notify EPA of their hazardous waste activities within the same time frame. Under section 273.54, universal waste transporters who determine that any material resulting29 from a release of universal waste is a hazardous waste are subject to 40 CFR Part 262. As a result, these transporters may also be subjec t to, under these circum stances, the section 262.12 notification requirements and procedures. As suc h, these transporters must, at that time, notify

EPA of their hazardous waste activities and ob tain an EPA Identification Number before treating, storing, transporting, offering for transpor t, or disposing of hazardous waste. Finally, owners or operators of smelting, melting, and re fining furnaces that process hazardous waste either solely for metals recovery or for recove ry of economically signifi cant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site bu rner exemption under section 266.108(d) must provide a written, one-time notificati on of their hazardous waste activities.

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

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

Under 40 CFR 262.203(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Iden tification Form (EPA Form 8700-12), that it is electing to be subject to the requirem ents of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG a nd does not have an EPA Identification Number must notify for all the laboratories owned by the eligible academic entity that are on-site. An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is electing to be subject to the requirements of Subpart K. This is a one-time notification.

Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laborator ies are subject to Subpart K.

Section 262.203(d) provides that a teaching hos pital that is not ow ned by a college or university must keep a copy of its formal wr itten affiliation agreement with a college or university on file at the teachi ng hospital while its la boratories are subject to Subpart K.

Section 262.203(e) provides th at a non-profit research inst itute that is not owned by a college or university must keep a copy of the formal written affiliation agreement with a college or university on file at the non- profit research institute while its laboratories are subject to Subpart K.

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

Under 40 CFR 262.204(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Iden tification Form (EPA Form 8700-12), that it is electing to no longer be subject to the re quirements of Subpart K for all the laboratories owned by the eligible academ ic entity under the same EPA Identification Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all the laboratories owne d by the eligible academic entity that are onsite. An eligible academic entity must subm it a separate notification (Site ID Form) for each30 EPA Identification Number (or si te, for CESQGs) that is withdr awing from the requirements of Subpart K. This is a one-time notification.

Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the

notification.

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

Under Section 273.32(a)(1), larg e quantity handlers of universal waste must submit a written, one-time notification of universal waste activity to the Regional Administrator and

obtain an EPA Identification Number before m eeting or exceeding the 5,000 kilogram storage limit, unless they already have notified EP A, as provided by section 273.32(a)(2) or 273.32(a)(3).

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

Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who were not previously required to comply with the no tification requirements (under 40 CFR Part 266, Subpart E) must submit a written, one-time notifi cation of their used oil management activities

and obtain an EPA Identification Number.

(2) Hazardous Waste Report

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

Table 4.31 Table 4 2009 Hazardous Waste Report National Implementation Schedule

Activity Completion Date

Implementers begin loading 2009 Hazar dous Waste Report data into RCRAInfo

Biennial Report National Data Quality Reports & National Exhibit Reports available for use in performing additional DQ checks April 5, 2010

DEADLINE for Implementers to load Co mplete Data into RCRAInfo for HQ’s national DQ

Review work and publication of the Pr eliminary 2009 National Biennial Report June 7, 2010

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

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

each State’s data is loaded into RCRAIn fo and provides results to States and Regions for use in completing FINAL DQ corrections September, 6, 2010

DEADLINE for Implementers to load FINAL Data into RCRAInfo for development of Final 2009 National Biennial Report October 4, 2010

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

Source: EPA, 2009 Biennial Report National Implementation Schedule. Available online at: http://www.epa.gov/waste/inforesources/data/biennialreport/index.htm , last accessed on August 14, 2009.32 6. ESTIMATING THE HO UR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibits 1 and 2 provide estimates of the re spondent hourly burden associated with the information collection requirements covered in this ICR. The exhibits include burden hours (total and by labor type) per res pondent, as well as the overall burden hours for all respondents. The majority of the hour estimates in Exhibits 1 and 2 are based on indus try consultations that EPA performed in renewing this ICR.

In the following paragraphs, EPA describe s the methodologies used to estimate the hourly burden associated with the informa tion collections covered in this ICR.

(1) Notification of Regulated Waste Activity

EPA contacted seven industry representative s to ascertain their burden for completing the Site ID Form for initial and subsequent notifications . All of them indicated that they complete a

blank Site ID Form for each notification and th eir burdens ranged from 5 minutes to 3 hours per submittal. Refer to Section 3(c) of this document for additional information on the data

collected.

None of the industry representatives used the Site ID Form’s optiona l procedures to use a previously submitted Site ID Form to make a s ubsequent notification. Sp ecifically, the Site ID Form’s instructions indicate that, after a faci lity has submitted the form once, the State may allow the facility to attach a copy of the facility’s most recen tly submitted form. If so, the facility must circle item numbers for which any information has changed. Then, circle the item numbers in the new form, enter the new inform ation, and provide the required signatures in

Item 14-Certification.

Although none of the industry representatives used a previously submitted form to notify, the Agency believes that a number of responde nts do so. This is based on the Agency’s knowledge of common industry practices. For pur poses of this ICR, EPA has estimated the percentage of respondents that use a previously submitted form to make a subsequent notification and their burden for doing so. Thes e estimates, along with the consultation data collected, are discussed in the paragraphs below.

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

For purposes of this ICR, EPA anticipates th at all of the facilities electing to operate under the hazardous secondary material excl usion under 40 CFR 260.42 during the two-year period covered by this ICR have already submitted the Site ID Form at least once. Of these facilities, EPA estimates that 50 percent will comp lete a blank Site ID Form to notify EPA or the State prior to operating under the exclusion and by March 1 of each even numbered year. EPA estimates that the other 50 percent will use th eir most recently submitted Site ID Form in complying with these notification requirements.33 EPA estimates the burden for completing a blank Site ID Form under section 260.42 to be 1.5 hours per respondent and the burden for using a previously submitted form to be 50 minutes (0.83 hour) per respondent. EPA not es that section 260.42 imposes several new, substantive requirements specific to the exclusio ns that must be completed (e.g., quantity of secondary material to be managed annually) in addition to the rest of the Site ID Form.

For the notification submitted indicating that the hazardous secondary materials are no longer managed in accordance to the exclusion, EPA estimates the average hourly burden for completing the Site ID Form in its entirety (i.e., a blank form) to be 1 hour per respondent. EPA also estimates the average hourly burden for updating the most recently submitted Site ID Form to be 20 minutes (0.33 hour) per respondent.

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 5 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 5 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete the Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Assumptions Weighted-Average Equation

Notification Prior to Operating under Exclusion AND Notification Submitted by March 1 of Each Even Numbered Year Thereafter

1.5 hours to complete blank form; 50 percent of the facilities (1.5 hrs x 0.50) + (0.83 hr x 0.50)

= 1.17 hours 0.83 hour to update most recently submitted form; 50 percent of the facilities

Notification Indicating that Hazardous S econdary Materials are no Longer Managed in

Accordance to the Exclusion

1 hour to complete blank form; 50 percent of the facilities (1 hr x 0.50) +(0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form; 50 percent of the facilities34 (b) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

For purposes of this ICR, EPA anticipates that all of the facilities opting into Subpart K during the two-year period covered by this ICR have already submitted the Site ID Form at least once. Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form in opting into Subpart K and in w ithdrawing from Subpart K. EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

EPA estimates the burden for completing a bl ank Site ID Form under Subpart K to be 1 hour per respondent and the burden for using a previously submitted form to be 20 minutes (0.33 hour) per respondent.

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 6 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 6 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete the Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Assumptions Weighted-Average Equation

1 hour to complete blank form; 50 percent of the facilities (1 hr x 0.50) + (0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form; 50 percent of the facilities35 (c) Other Notifications Covered in this ICR

For purposes of this ICR, EPA anticipates th at 50 percent of the facilities submitting initial notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 will complete a blank Site ID Form. EPA estim ates that the other 50 percent will use their most recently submitted Site ID Form in comply ing with these notification requirements.

EPA estimates the burden for completing a blank Site ID Form to be 1 hour per respondent and the burden for using a previous ly submitted form to be 20 minutes (0.33 hour) per respondent.

The above burden estimates are reflected in Exhibit 1 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 7 below. EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form. EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form. Then, EPA added up thes e two products to derive an overall weightedaverage burden.

Table 7 Assumptions and Weighted-Average Equation Used in Estimating Burden to Complete Oth er Notifications Covered in this ICR

Assumptions Weighted-Average Equation

1 hour to complete blank form; 50 percent of the facilities (1 hr x 0.50) + (0.33 hr x 0.50)

= 0.67 hour 0.33 hour to update most recently submitted form; 50 percent of the facilities

(2) Hazardous Waste Report

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

States

In estimating the hourly burden for preparing the Site ID Form of the Hazardous Waste Report, EPA assumes that 65 percent of all the Site ID Forms will be pre-populated by States prior to distribution to responde nts or by vendor software used by the respondents. EPA also assumes that the remaining 35 percent of all th e Site ID Forms will be completed manually.

EPA estimates the burden for updating a pre-pop ulated Site ID Form to be 20 minutes (0.33 hour) per respondent and the burden for completing a Site ID Form in its entirety (i.e., completing a blank form manually) to be 1 hour per respondent.36 The above burden estimates are reflected in Exhibit 2 as weighted-averages. EPA derived the weighted averages using the calcul ations in Table 8 below. EPA multiplied the percentage of pre-populated Site ID Forms by the average burd en for updating the information contained in the form. EPA also multiplied the percentage of blank Site ID Forms by the average burden for completing the blank form. Then, EPA added up these two products to

derive an overall wei ghted-average burden.

Table 8 Assumptions and Weighted-Average Equati on Used in Estimating Burden to Complete the Site Identification Fo rm of the Hazardous Waste Report

Assumptions Weighted-Average Equation

0.33 hours to complete pre-populated form; 65 percent of the forms are pre-populated (0.33 hrs x 0.65) + (1 hr x 0.35)

= 0.56 hours 1 hour to complete blank form; 35 percent of the forms are blank

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

During consultations conducted during the deve lopment of previous versions of the Hazardous Waste Report ICR, State and facility representatives indicat ed that GM and WR Forms often can be completed from databases th at track manifests or other information for billing purposes. Based on these consultations, EPA estimated the hourly burden for the GM and WR Forms submitted electronically to be signifi cantly less than for forms submitted on paper.

To estimate the percentage of facilities th at submit GM and WR Forms electronically, EPA used information gained from consultations and 2007 Hazardous Waste Report data. For GM Form submissions, EPA estimated that, ba sed on consultations a nd best professional judgment, facilities submitting five (5) or mo re GM Forms for the Hazardous Waste Report are likely to do so electronically. Using 2007 Hazardous Waste Report data 3 , EPA identified sites submitting GM Forms, counted their GM Forms submitted, and calculated the percentage that their GM Forms represented of the total number of GM Forms. Based on this methodology, EPA estimates that 48 percent of GM Forms are submitted electronically, while the remaining 52 percent are sent manually.

3 2007 Hazardous Waste Report (i.e., 2007 Biennial Re port) data used in this analysis are current as of September 6, 2009.37 For WR Forms, EPA believes that TSDFs r eceiving large numbers of off-site shipments are more likely to have systems in place to track waste stream data, and as a consequence, to submit Hazardous Waste Report data electronica lly. Using 2007 Hazardous Waste Report data 4

, EPA reviewed the list of WR Forms reporte d to the Hazardous Waste Report by facility and, based on its own professional j udgment and consultations, estima tes that 100 percent of WR Forms are submitted electronically.

To estimate the average burden per respondent in preparing a GM or WR Form, EPA used the weighted-average calculations in Table 9. EPA multiplied the percentage of both forms submitted electronically by their respective burden fo r electronic reporting and the percentage of both forms submitted manually by their respective burden for manual reporting. Then, EPA added the two products for each form, respectivel y, to calculate an overall weighted-average burden for both forms. These weighted-average burden estimates are used in Exhibit 2 to estimate total respondent burden for the GM and WR Forms.

Table 9 Assumptions and Weighted-Average Equati ons Used in Estimating Burden to Complete Form GM and Form WR of the Hazardous Waste Report

Activity Assumptions Weighted-Average Equation

Complete

Form GM 0.16 hour to complete electronically; 48% of the forms are completed electronically

1.04 hours to complete manually; 52% of the forms are completed manually (0.16 hr x 0.48) + (1.04 hrs x 0.52)

= 0.61 hour

Complete

Form WR 0.16 hour to complete electronically; 100% of the forms are completed electronically 0.16 hr x 1= 0.16 hour

4 2007 Hazardous Waste Report (i.e., 2007 Biennial Re port) data used in this analysis are current as of September 6, 2009.38 6(b) ESTIMATING RESPONDENT COSTS

Exhibits 1 and 2 provide estimates of the annual respondent costs associated with the information collection requirements covered in this ICR. These costs are based on the cost of labor, capital, and operation and maintenance (O&M).

(1) Labor Costs

EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $118.68 for legal staff, $70.15 for managerial staff, $52.26 for technica l staff, and $31.44 for clerical staff. These respondent labor costs were obtained from a pr eviously approved ICR (i.e., “Revisions to the RCRA Definition of Solid Waste,” EPA ICR Number 2310.01, dated October 28, 2008), and updated to 2009 levels us ing Employment Cost Indexes developed by the

U.S. Bureau of Labor Statistics. 5

Using the total burden hours discussed in S ection 6(a) and the hourly labor costs outlined in this section, Exhibits 1 and 2 illustrate th e labor costs associated with the information collection requirements covered in this ICR.

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, and ot her equipment. EPA doe s not anticipate that respondents will incur ca pital costs in carrying out the information collection requirements

covered in this ICR.

(3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement incurred continually over the life of the ICR. For this ICR, O&M costs include mailing costs. In particular, EPA estimates that respondents will incur a cost of $3.25 to mail a one-ounce package by certified mail ($0.44 for postage, $2.80 for the certified-mail fee, and $0.01 for standard-size envelope). These O&M costs are shown in E xhibits 1 and 2 for all applicable respondent

activities.

5 Bureau of Labor Statistics, “Table 4. Employment Cost Index for total compensation, for civilian workers, by occupational group and industry,” Employment Cost Index-June 2009 , June 31, 2009. Available online

at: http://www.bls.gov/news.release/pdf/eci.pdf , last accessed on August 14, 2009. Civilian Workers, All Workers,

June 2008=108.3 and June 2009=110.3.39 6(c) ESTIMATING AGEN CY HOUR AND COST BURDEN

(1) Federal Agency

EPA estimates the Federal agency hour and co st burden associated with the notification and Hazardous Waste Report information colle ction requirements in Exhibits 3 and 4, respectively. As shown in the exhibits, EPA es timates an average hourly labor cost of $85.28 for legal staff (GS15, Step 5), $75.25 for managerial staff (GS-15, Step 1), $54.14 for technical staff (GS-13, Step 1), and $23.09 for cler ical staff (GS-06, Step 1). To derive these hourly estimates, EPA referred to the General Schedule (GS) Salary Table 2009. This publication summarizes the unloaded (base) hourly rate for various labor ca tegories in the Federal Government. EPA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly rates.

(2) State Agency

EPA estimates the State agency hour and co st burden associated with the Hazardous Waste Report information collection requirements in Exhibit 5. As shown in the exhibit, EPA estimates an average hourly State agency labor cost (including fringe and overhead) of $57.43 for legal staff, $53.91 for manage rial staff, $32.26 for technical staff, and $20.58 for clerical staff. These State agency labor costs were obt ained from a previously approved ICR (i.e., “2007 Hazardous Waste Report,” EPA ICR Number 0976.13, dated Se ptember 18, 2007), and updated to 2009 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor

Statistics. 6

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then estimates the annual burden to respondents under the information co llection requirements

covered in this ICR.

(1) Respondent Universe

(a) Notification of Regulated Waste Activity

(a1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

In estimating the number of respondents s ubject to the notific ation of hazardous secondary material activity under 40 CFR 260.42, EPA referred to the ICR developed for the recently promulgated rule: “Revisions to the RCRA Definition of Solid Waste,” EPA ICR

6 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation1, for State and local government workers, by occupational group and industry,” Employment Cost Index-June 2009 , June 31, 2009.

Available online at: http://www.bls.gov/news.release/pdf/eci.pdf , last accessed on August 14, 2009. State and Local Government Workers, All Workers, June 2008=109.4 and June 2009=112.9.40 Number 2310.01. These estimates are presented in Table 10 and used to estimate the total respondent burden and costs per information collect ion activity shown in E xhibit 1 of this ICR.

Table 10 Annual Number of Respondents Subject to the Notification of Hazardous Secondary Material Activity under 40 CFR 260.42 a

Respondent Universe Number of Respondents

State and Local

Government Private Sector Total

Total number of facilities submitting notification prior to operating under exclusion 111 1,601 1,712

Number of small quantity generators (SQGs) submitting notification by March 1 of each even numbered year

thereafter 15 216 231

a Based on information contained in currently approved EPA IC R Number 2310.01, “Revisions to the RCRA Definition of Solid Waste,” dated October 28, 2008.

(a2) Notification of Hazardous Waste Ac tivity under 40 CFR Part 262, Subpart K

In estimating the number of respondents subj ect to the notificati on of hazardous waste activity under 40 CFR Part 262, Subpart K, EPA re ferred to the ICR developed for the recently promulgated rule: “Generator Standards App licable to Laboratories Owned by Eligible Academic Entities,” EPA ICR Number 2317.01. Th ese estimates are presented in Table 11 and used to estimate the total respondent burden and costs per information collection activity shown

in Exhibit 1 of this ICR.

Table 11 Annual Number of Respondents Subject to the Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K a

Respondent Universe Number of Respondents

State and Local

Government Private Sector Total

Number of eligible academic entities submitting notification of intent to comply with Subpart K and recordkeeping of

agreements 11 26 37

Number of teaching hospitals not owned by a college or university opting into Subpart K 1 1 2

Number of non-profit research institutes not owned by a college or university opting into Subpart K 0 1 1

Number of eligible academic entities submitting notification of withdrawal from 40 CFR Part 262, Subpart K 0 0 0

a Based on information contained in currently approved EP A ICR Number 2317.01, “Generator Standards Applicable to Laboratories Owned by Eligible Academ ic Entities,” dated July 14, 2008.41 (a3) Other Notifications Covered in this ICR

In estimating the number of respondents subj ect to the notificati on requirements covered under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279, EPA referred to the Resource Conservation and Recovery Act Information (RCRAInfo) system 7 . EPA estimated the annual number of initial and subsequent notifications tracked by RCRAInfo. EPA then averaged the number of notifications submitte d in 2007 and 2008. These estimates are presented in Table 12 and used to estimate the total respon dent burden and costs per information collection activity shown in Exhibit 1 of this ICR.

7 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA (i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.42Table 12Annual Number of Respondents Subjectto the Notification Requirementsunder RCRA Section 3010; 40 CFR Part273, Subpart C; and 40 CFR Part 279aRespondentUniverseYear 2007 Year 2008 Average of Years 2007 and 2008State andLocalGovernmentbPrivateSectorcTotalState andLocalGovernmentbPrivateSectorcTotalState andLocalGovernmentbPrivateSectorcTotalNotification of Hazardous WasteActivity under RCRA Section 3010Number of facilitiessubmitting initialnotification1,619 8,806 10,425 2,156 7,930 10,086 1,888 8,368 10,256Number of facilitiessubmitting subsequentnotification1,535 32,585 34,120 1,739 35,426 37,165 1,637 34,006 35,643Notification of Universal Waste Activity under 40 CFR Part 273, Subpart CNumber of facilitiessubmitting initialnotification2 21 23 9 37 46 6 29 35Number of facilitiessubmitting subsequentnotification1 10 11 0 6 6 1 8 9Notification of Used Oil Activity under 40 CFR Part 279Number of facilitiessubmitting initialnotification5 102 107 12 115 127 8 109 117Number of facilitiessubmitting subsequentnotification4 109 113 4 134 138 4 122 126aBased on data from two RCRAInfo tables: (1) “Hhandler” and (2) “Howner_operator2.” Both tables contain data current as of July 10, 2009.bIncludes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in orderto qualify as “State and local government,” the facilitycannot be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated bya Municipal government would qualify as a“Federal government” facility, not a“State and local government” facility.cIncludes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facilitycannot be owned or operated bya Federal, State, or localgovernment. For example, a facility owned bya State government and operated by a private entity would qualify as a “State andlocal government” facility, not as a “private”facility.43

(b) Hazardous Waste Report

Based on 2007 Hazardous Waste Report data 8 , EPA estimates that the total number of respondents to the 2009 Hazardous Waste Report wi ll be 16,483, which annualized over the twoyear report cycle equals 8,242 pe r year (i.e., 16,483/2). Table 13 presents information on the

total number of forms associated with the 2009 Hazardous Waste Report. In estimating annual respondent burden and cost, EPA annualized thes e numbers over the two- year report cycle.

Table 13 Total Number of 2009 Hazardous Waste Report Forms

Hazardous Waste Report Form Number of Forms a

State and

Local

Government Private

Sector Total

Site Identification (Site ID) Form 1,347 15,136 16,483

Form GM - Generation and Mana gement 16,873 189,121 205,994

Form WR - Waste Received from Offsite 13,668 847,972 861,640
Total 31,888 1,052,229 1,084,117

a Based on 2007 Hazardous Waste Report (i.e., 2007 Biennial Report) data current as of September 6,

2009.

The number of respondents and forms for each respondent activity is presented in

Exhibit 2. These estimates assume that all forms are submitted in accordance with the Hazardous Waste Report instructions. Exhibit 2 al so estimates the annual respondent burden and

cost for the activities examined.

(2) Annual Respondent Burden

(a) Notification of Regulated Waste Activity (Exhibit 1)

(a1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

EPA estimates that, each year, 1,712 entitie s will notify EPA under section 260.42 prior to operating under the exclusion and be required to complete the information laid out at section 260.42(a). This includes 1,579 hazardous secondary ma terials generators, tolling contractors and toll manufacturers; 80 intermediate facilities; and 53 reclaimers.

In addition, entities must re-notify EPA using the Site ID Form by March 1 of each even numbered year thereafter. Note that the Hazar dous Waste Report regulations already require the submittal of the Site ID Form by March 1 of each even numbered year by large quantity generators (40 CFR Part 262) and treatment, stor age and disposal facilities (40 CFR Part 264 and

8 2007 Hazardous Waste Report (i.e., 2007 Biennial Re port) data used in this analysis are current as of September 6, 2009.44

265). Hence, this section of the ICR estimates burden for SQG re-notifications only. For purposes of this ICR, EPA estimates that a to tal of 462 SQGs will re- notify over the two-year period covered by this ICR. Because each of th ese entities will perfor m this re-notification activity once during the two-peri od covered by this ICR, EPA has annualized the number of entities by dividing them by two (i .e., 462/2 = 231 SQGs annually). 9

EPA estimates that, each year, five percent of entities (i.e., 1,712 x 0.05 = 86) will re-notify because they stopped operating under th e exclusion.

(a2) Notification of Hazardous Wast e Activity under RCRA Section 3010

EPA estimates that, each year, 10,256 facilitie s will submit an ini tial notification of hazardous waste activity under RCRA Section 3010. EPA also estimates that, each year, 35,643 facilities will submit a subsequent notificati on associated with these requirements.

(a3) Notification of Hazardous Waste Ac tivity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

An eligible academic entity must submit th e Site ID Form to notify EPA or the

authorized State that it is elec ting to be subject to Subpart K for all laboratories owned by the eligible academic entity under the same EPA Identif ication Number. An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all laboratories that are owned or operated by the eligible academic entity that are on-site. EPA estimates that, each year, 37 forms will be completed, submitted, and retained.

Teaching hospitals opting into Subpart K mu st keep a copy of their formal written affiliation agreement with a college or university on file if they are not owned by a college or university. EPA estimates that, each year, two (2 ) sites will retain the agreements on file.

Non-profit research institutes not owned by a college or university opting into Subpart K must keep a copy of the formal written affiliation agreement with a college or university on file. EPA estimates that, each year, one (1) si te will retain the agreement on file.

Withdrawal from 40 CFR Part 262, Subpart K

EPA does not expect any eligible academic entity to submit a withdrawal notification during the two-year period covered by this ICR.

9 Even though these 462 SQGs are expected to re-notify once during the period covered by this ICR, EPA has annualized them over two years to estimate the average annual burden of the requirements. Note that this approach is taken with other one-time activities in this ICR, as applicable.45

(a4) Notification of Universal Wast e Activity under 40 C FR Part 273, Subpart C

EPA estimates that, each year, 35 facilities will submit an initial notification of universal waste activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent (i.e., 35 x 0.75 = 26) will use the Site ID Form and 25 percent (i .e., 35 x 0.25 = 9) will prepare and submit a letter requesting an EPA Identification Number.

EPA also estimates that, each year, 9 facilitie s will submit a subsequent notification of universal waste activity under 40 CFR Part 273, S ubpart C. Of these facilities, 75 percent (i.e., 9 x 0.75 = 7) will use the Site ID Form and 25 percent (i.e., 9 x 0.25 = 2) will prepare and submit a letter requesting an EPA Identification Number.

(a5) Notification of Used Oil Activity under 40 CFR Part 279

EPA estimates that, each year, 117 facilities will submit an initial notification of used oil activity under 40 CFR Part 279. Of these facili ties, 75 percent (i.e., 117 x 0.75 = 88) will use the Site ID Form and 25 percent (i.e., 117 x 0.25 = 29) will prepare and submit a letter requesting an

EPA Identification Number.

EPA also estimates that, each year, 126 facili ties will submit a subsequent notification of universal waste activity under 40 CFR Part 273, S ubpart C. Of these facilities, 75 percent (i.e., 126 x 0.75 = 95) will use the Site ID Form and 25 percent (i.e., 126 x 0.25 = 31) will prepare and submit a letter requesting an EPA Identification Number.

(b) Hazardous Waste Report (Exhibit 2)

(b1) Gather Information and Comp lete Site Identification Form

EPA estimates that all 16,483 respondents will complete and submit a Site ID Form with the 2009 Hazardous Waste Report. Annualized over th e two-year report cycle, this results in 8,242 respondents preparing and submitting a Site ID Form each year.

(b2) Gather Information and Complete Form GM

EPA estimates that respondents will subm it a total of 205,994 GM Forms with the 2009 Hazardous Waste Report. Annualized over the two-y ear report cycle, this results in 102,997 GM Forms each year.

(b3) Gather Information and Complete Form WR

EPA estimates that respondents will subm it a total of 861,640 WR Forms with the 2009 Hazardous Waste Report. Annualized over the two-y ear report cycle, this results in 430,820 WR Forms each year.46

Note that the number of WR Forms represen ts the number of blocks on Form WR that have been completed; the paper form actually cont ains three blocks of th e same WR information (i.e., the same questions, repeated three times on the same page).

(b4) Gather Information and Complete Form OI

Because this form is a State-optional form, EP A does not expect any facilities to submit

Form OI and therefore does not ca lculate the burden for this form.

(b5) Submit the Biennial Report to State/Region

EPA expects each respondent, 8,242 facilities per year, to submit the report to the appropriate State or Region.

(b6) Maintain a Copy of Each Form

EPA expects facilities to re tain an estimated 542,059 (i.e., 8,242 Site ID Forms + 102,997 GM Forms + 430,820 WR Forms) forms each year.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibit 6 summarizes the tota l annual respondent hour and cost burden associated with all the requirements covered in this ICR. As shown in the ex hibit, EPA estimates the annual respondent burden to be 206,305 hours and $10,598,875. The bottom line burden to respondents over two years is estimated to be 412,610 hours and $21,197,750.

(2) Agency Tally

(a) Federal Agency

Exhibit 7 summarizes the tota l annual Federal agency hour and cost burden associated with all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual Federal agency burden to be 126,245 hours and $6,477,984. The bottom line burden to the Federal agency over two years is estimated to be 252,490 hours and $12,955,968.

(a) State Agency

Exhibit 8 summarizes the total annual State agency hour and cost burden associated with all the requirements covered in this ICR. As shown in the ex hibit, EPA estimates the annual State agency burden to be 215,828 hours and $5,911,150. The bottom line burden to State agencies over two years is estimated to be 431,656 hours and $11,822,300.47

6(f) REASONS FOR CHANGE IN BURDEN

(1) Notification of Regulated Waste Activity

The currently approved Notification I CR (EPA ICR Number 0261.15) covers the notification requirements under RCRA Section 3010 (i.e., for hazardou s waste activities); 40 CFR Part 273, Subpart C (i.e., for universal wa ste activities); and 40 CFR Part 279 (i.e., for used oil activities). The annual respondent burden estimate in the currently approved Notification ICR was 100,307 hours, w ith a total cost of $234,843 for capital/start-up and O&M. The annual respondent burden estimate for the sa me notification requirements covered in this current ICR is 34,176 hours, with a total cost of $150,105 for capital/start-up and O&M. This represents a decrease of 66,131 hours and $84,738 in total cost for capital/start-up and O&M.

This decrease in burden for respondents has occurred for two primary reasons. First,

there was a decrease in the to tal number of notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279. The total nu mber of initial notificat ions decreased from 13,487 in the currently approved ICR to 10,408 in this current ICR. The total number of subsequent notifications decreased from 42,428 in the currently approved ICR to 35,778 in this current ICR. Note that, in estimating the number of initial and subsequent notifications in this current ICR, EPA used the average of the number of notifications submitted in 2007 and 2008 (see Table 12). In each of these years, ther e was a decrease in the total annual number of notifications submitted to EPA, when compared to the annual number of notifications in the currently approved ICR. Thus, EPA believes that the number of notificati ons included in this current ICR is consistent with the respondent uni verse subject to these no tification requirements.

Second, the burden associated with the notif ication activities decreased because of adjustments made to the hourly burden estimates fo r the Site ID Form. These adjustments were based, in part, on consultations with industry repres entatives. Refer to Sec tion 3(c) for additional information on consultations. In addition, adjust ments were made to the hourly burden estimates for the Site ID Form based on EPA’s best judgm ent to take into account the option given to respondents in the Site ID Form’s instructions to use their most recently submitted form in making a subsequent notification. These optiona l procedures relieve them of the need to complete the form from in its entirety (i.e ., complete a blank form), saving time. These adjustments do not reflect any change in requir ements; they represent instead a more accurate representation of the burden that respondents will incur as a result of this in formation collection.

(2) Hazardous Waste Report

(a) Respondent Burden

The annual respondent burden estimate for the 2007 Hazardous Waste Report (EPA ICR Number 0976.13) was 267,974 hours, with a total cost of $47,713 for capital/start-up and O&M. The annual respondent burden estimate for the 2009 Hazardous Waste Report is 169,780 hours, with a total cost of $26,787 for cap ital/start-up and O&M. This represents a decrease of 98,194 hours and $20,926 in total cost for capital/start-up and O&M.48

This decrease in burden for respondents has occurred for two primary reasons. First,

there was a decrease in the a nnualized number of respondents, from 12,619 projected for 2007 to 8,242 projected for 2009. Second, there was a decr ease in the number of Hazardous Waste Report forms projected for 2007 versus the num ber of forms projected for 2009. Table 14 compares the projected number of forms fo r the 2007 and the 2009 Hazardous Waste Reports.

Table 14 Comparison of Projected Number of Forms for the 2007 and 2009 Hazardous Waste Report

Hazardous Waste Report Form Projected Number of Forms

Difference a 2007

Hazardous Waste Report 2009

Hazardous Waste Report

Site Identification (Site ID) Form 25,238 16,483 -8,755

Form GM - Generation and Mana gement 254,660 205,994 -48,666

Form WR - Waste Received from Offsite 851,540 861,640 10,100
Total 1,131,438 1,084,117 -47,321

a Negative value indicates a decrease in the number of forms.

(b) State Agency Burden

The annual State agency burden estimate for the 2007 Hazardous Waste Report (EPA ICR Number 0976.13) was 417,222 hours, with a tota l cost of $18,929 for capital/start-up and O&M. The annual State agency burden esti mate for the 2009 Hazardous Waste Report is 215,828 hours, with a total cost of $17,061 for capita l/start-up and O&M. This represents a decrease of 201,394 hours and $1,868 in total co st for capital/start-up and O&M.

This decrease in burden for State agencies has occurred because th ere was a decrease in the number of respondents and Hazardous Wast e Report forms projected for 2007 versus the number of forms projected for 2009. Refer to Ta ble 14 for a comparison of the projected number of forms for the 2007 and the 2009 Hazardous Waste Reports.49

6(g) PUBLIC BURDEN STATEMENT

(1) Notification of Regulated Waste Activity

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

The average annual public reporting burde n associated with hazardous secondary material notification requirements is estimated to be approximately 1.36 hours. This includes time to notify EPA under section 260.42. There ar e no recordkeeping requirements associated with hazardous secondary material notifica tion requirements, and as such, there is no recordkeeping burden.

(b) Notification of Hazardous Was te Activity under RCRA Section 3010

The average annual public reporting bur den associated with RCRA Section 3010 notification requirements (initial and subsequent ) is estimated to be approximately 0.74 hour. This includes time for reading the Site ID Form instructions, completing the form, and submitting the form. There are no recordkeep ing requirements associated with the RCRA Section 3010 notification requirements, and as such, there is no recordkeeping burden.

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

The average annual public reporting burden a ssociated with notif ication requirements under 40 CFR Part 262, Subpart K is estimated to be 0.67 hour per respondent. This includes time for preparing and submitting a Site ID Form to opt into or withdraw from Subpart K.

The average annual public recordkeeping burden associated with notification requirements under 40 CFR Part 262, Subpart K is estimated to be 0.08 hour per respondent. This includes time for keeping copies of notif ication and affiliation agreements on-site.

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

The average annual public reporting burden a ssociated with 40 CFR Part 273, Subpart C notification requirements (initial and subsequent ) is estimated to be approximately 0.82 hour. This includes time for reading the Site ID Fo rm instructions or applicable regulations, completing the Site ID Form or preparing a lett er requesting an EPA Identification Number, and submitting the completed Site ID Form or letter. There are no recordkeeping requirements associated with the 40 CFR Part 273, Subpart C no tification requirements, and as such, there is no recordkeeping burden.50

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

The average annual public reporting burden a ssociated with 40 CFR Part 279 notification requirements (initial and subsequent) is estima ted to be approximately 0.75 hour. This includes time for reading the Site ID Form instructions or applicable regulations, completing the Site ID Form or preparing a letter requesting an EPA Identification Number, and submitting the completed Site ID Form or letter. There are no recordkeeping requirements associated with the 40 CFR Part 279 notification requirements, and as such, there is no recordkeeping burden.

(2) Hazardous Waste Report

The reporting burden is estimated to av erage 16.63 hours per respondent, and includes time for reviewing instructions, gathering da ta, completing and reviewing the forms, and submitting the report. The record keeping requirement is estimated to average 3.97 hours per response and includes the time for filing and st oring the Hazardous Waste Report submission for three years.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to re spond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CF R 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 mini mizing respondent burden, including the use of automated collection techniques, EPA has establis hed a public docket for this ICR under Docket

ID Number EPA-HQ- RCRA-2008-0912, which is available for online viewing at www.regulations.gov, or in person viewing at th e RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Consti tution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566- 1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic version of the public docket is available at www.regulations .gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send

comments to the Office of Information and Re gulatory Affairs, Offi ce of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please

include the EPA Docket ID Number EPA-HQ-RCRA-2008-0912 and O MB Control Number

2050-0024 in any correspondence.51E X H IB IT 1-aN O T I F IC AT I O N O F R E G U L AT ED W A S T E A C T I VI T YE S T IM A T E D A N N U A L P R IV A T E -S E C T O R R E S P O N D E N T H O U R A N D C O S T B U R D E NH o u r s a n d C o s ts P er R e s p o n d e n t P e r A c tiv ity T o tal H o u rs a n d C o stsL e g . M g r . T e ch . C le r. R es p o n . L a b o r C a p i ta l / N u m b e r T o t a l T o t al$ 1 18 . 68 / $ 7 0 .1 5 / $ 5 2. 2 6/ $ 31 . 44 / H o u rs / C o s t/ S ta rtu p O & M R e sp o n . / H o u rs / C o s t/I N F O R M A T I O N C O L L E C T I O N A C T I VI T Y Y e a r Y ea r Ye a r Y ea r Y e ar Y e ar C o s t C o s t A c tiv . Ye a r Y e arC o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 p r io r too p e ra t in g u n d er ex c lu s io n( s )0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $ 0 .0 0 $ 3. 2 5 1, 6 01 1 ,8 6 5 .1 7 $ 1 0 2, 30 3 .9 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 b y M a rc h 1 o fe a c h e v e n n u m b e re dyea r t h ere a ft er0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $ 0 .0 0 $ 3. 2 5 2 16 2 5 1 .6 4 $ 1 3, 80 2 .4 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 in d ic a tin g t ha tt he ha z a r d ou s s e c on d a ry m a t er ia ls ar e n o lo n ge rm an a g ed in ac c o r da n c e w it h t he e x c lus ion0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 80 5 3 .2 0 $ 3, 02 1 .6 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 2 ,1 7 0 .0 1 $ 1 1 9, 12 7 .9 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 8, 3 68 8 ,3 6 8 .0 0 $ 4 6 2, 58 3 .0 4C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 3 4, 0 06 22 ,6 1 3 .9 9 $ 1 ,2 8 4, 40 6 .6 2S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 30 ,9 8 1 .9 9 $ 1 ,7 4 6, 98 9 .6 6P r e pa r e a n d s u b m it E P A F o rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 26 1 7 .2 9 $ 98 2 .0 2K e e p a co pyof t he no tif ic a tio n o n f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 26 2 .0 8 $6 5 .5 2K e e p a c o p y of t he ir f or m al w r it te n a ff iliat io n a gr e e m e ntw it h c o lle ge or un iv e r s it y o n f ile w hile it s lab o r at o rie s a res ub je ct to Su b p art K0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 1 0 .0 8 $ 2 .5 2K e e p a c o p y of t he fo r m a l w r itt en af filia tio n a g re e m e n t w it ha c o lle g e o r u n iv e rs ity o n file a t th e n o n- p r o fit r es e ar c hin s t itu te w hile it s la b o r at or ie s a re s u bje c t t o S ub p a r t K0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 1 0 .0 8 $ 2 .5 2P r e pa r e a n d s u b m it E P A F o rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 0 0 .0 0 $ 0 .0 0K e e p a co pyof t he w it h dr a w a l n o tic e on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 0 0 .0 0 $ 0 .0 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 1 9 .5 3 $ 1, 05 2 .5 8C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 22 2 2 .0 0 $ 1, 21 6 .1 6P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 7 3 .5 0 $ 20 4 .0 5C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 6 3 .9 9 $ 22 6 .6 2P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 3 0 .4 9 $ 1, 70 5 .1 3C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 82 8 2 .0 0 $ 4, 53 2 .9 6P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 27 1 3 .5 0 $ 78 7 .0 5C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 92 6 1 .1 8 $ 3, 47 4 .8 4P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 30 1 5 .0 0 $ 87 4 .5 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 1 7 1 .6 8 $ 9, 66 9 .3 5T O T A L v a rie s va ri e s v a ri es v ar ie s v a rie s v a rie s v ar ie s va r ie s v a rie s 3 3 ,3 7 4 $ 1 ,8 78 , 54 5L e tt erN o tific a tio n o f H az a rd o u s S ec o n d a ry M a ter ia l A cti vi ty u n d e r 4 0 C F R 26 0 .4 2N o t if ic a t io n o f H az a rd o u s W a s t e Ac t i vi t y u n d e r R C R A S e c ti o n 3 01 0I n iti al N o tific a tio nS u b se q u en t N o t i fi c at i o nL e tt erE P A Fo rm 8 7 0 0-1 2L e tt erS u b se q u en t N o t i fi c at i o nN o t if ic a t io n o f U se d O il A ct i vi t y u n d e r 4 0 C F R P ar t 2 79I n iti al N o tific a tio nE P A Fo rm 8 7 0 0-1 2E lig ible A c ad e m ic En t itie sT ea ch in g H o sp ita lsN o n - P ro f it R es ea r c h In s t it u te sE P A Fo rm 8 7 0 0-1 2I n iti al N o tific a tio nS u b se q u en t N o t i fi c at i o nE P A Fo rm 8 7 0 0-1 2L e tt erW ith d r a w a l fro m 40 C F R P a rt 26 2 , S u b p a rt KN o tific a tio n o f U n iv e rs a l W a ste A c tiv ity u n d e r 4 0 C F R P a rt 2 7 3 , Su b p a rt CN o t if ic a t io n o f H az a rd o u s W a s t e Ac t i vi t y u n d e r 40 C F R P a rt 26 2 , S u b p a r t KI n t e n t t o C o m p ly w i th S u b p ar t K an d R e c o r d k ee p i n g o f A g r ee m e n t s52E X H IB IT 1-bN O T I F IC AT I O N O F R E G U L AT ED W A S T E A C T I VI T YE S T IM A T ED A N N U A L S T AT E A N D L O C A L G O V E R N M E N T R E S PO N D E N T H O U R AN D C O S T B U R D E NH o u r s a n d C o s ts P er R e s p o n d e n t P e r A c tiv ity T o tal H o u rs a n d C o stsL e g . M g r . T e ch . C le r. R es p o n . L a b o r C a p i ta l / N u m b e r T o t a l T o t al$ 1 18 . 68 / $ 7 0 .1 5 / $ 5 2. 2 6/ $ 31 . 44 / H o u rs / C o s t/ S ta rtu p O & M R e sp o n . / H o u rs / C o s t/I N F O R M A T I O N C O L L E C T I O N A C T I VI T Y Y e a r Y ea r Ye a r Y ea r Y e ar Y e ar C o s t C o s t A c tiv . Ye a r Y e arC o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 p r io r too p e ra t in g u n d er ex c lu s io n( s )0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $ 0 .0 0 $ 3. 2 5 1 11 1 2 9 .3 2 $ 7, 09 2 .9 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 b y M a rc h 1 o fe a c h e v e n n u m b e re dyea r t h ere a ft er0 .0 0 0 .0 8 1 . 01 0 .0 8 1 .1 7 $ 60 . 65 $ 0 .0 0 $ 3. 2 5 15 1 7 .4 8 $ 95 8 .5 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 in d ic a tin g t ha tt he ha z a r d ou s s e c on d a ry m a t er ia ls ar e n o lo n ge rm an a g ed in ac c o r da n c e w it h t he e x c lus ion0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 6 3 .9 9 $ 22 6 .6 2S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 1 5 0 .7 9 $ 8, 27 8 .0 2C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 1, 8 88 1 ,8 8 8 .0 0 $ 1 0 4, 36 8 .6 4C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 1, 6 37 1 ,0 8 8 .6 1 $ 6 1, 82 9 .4 9S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 2 ,9 7 6 .6 1 $ 1 6 6, 19 8 .1 3P r e pa r e a n d s u b m it E P A F o rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 11 7 .3 2 $ 41 5 .4 7K e e p a co pyof t he no tif ic a tio n o n f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 11 0 .8 8 $2 7 .7 2K e e p a c o p y of t he ir f or m al w r it te n a ff iliat io n a gr e e m e ntw it h c o lle ge or un iv e r s it y o n f ile w hile it s lab o r at o rie s a res ub je ct to Su b p art K0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 1 0 .0 8 $ 2 .5 2K e e p a c o p y of t he fo r m a l w r itt en af filia tio n a g re e m e n t w it ha c o lle g e o r u n iv e rs ity o n file a t th e n o n- p r o fit r es e ar c hin s t itu te w hile it s la b o r at or ie s a re s u bje c t t o S ub p a r t K0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 0 0 .0 0 $ 0 .0 0P r e pa r e a n d s u b m it E P A F o rm 8 7 00 - 1 2 0 .0 0 0. 0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 0 0 .0 0 $ 0 .0 0K e e p a co pyof t he w it h dr a w a l n o tic e on f ile 0 .0 0 0. 0 0 0 . 00 0 .0 8 0 .0 8 $ 2 .5 2 $ 0 .0 0 $ 0. 0 0 0 0 .0 0 $ 0 .0 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 8 .2 8 $ 44 5 .7 1C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 4 4 .0 0 $ 22 1 .1 2P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 1 0 .6 7 $3 7 .7 7P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 0 0 .0 0 $ 0 .0 0S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 5 .6 7 $ 31 7 .1 9C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 84 0 .0 8 1 .0 0 $ 52 . 03 $ 0 .0 0 $ 3. 2 5 6 6 .0 0 $ 33 1 .6 8P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 2 1 .0 0 $5 8 .3 0C o m ple te an d s ub m it E P A F o r m 87 0 0 -1 2 0 .0 0 0 .0 8 0 . 51 0 .0 8 0 .6 7 $ 34 . 52 $ 0 .0 0 $ 3. 2 5 3 2 .0 0 $ 11 3 .3 1P re pa re a n d su b m it le tte r re q ue s tin g a n E PA Id e nt ifica t ionN u m be r0 .0 0 0 .0 8 0 . 34 0 .0 8 0 .5 0 $ 25 . 90 $ 0 .0 0 $ 3. 2 5 1 0 .5 0 $2 9 .1 5S u b to ta l v a r ie s v a rie s v ar ie s v a rie s v a r ie s v a r ie s v a r ies v a r ie s v a r ie s 9 .5 0 $ 53 2 .4 4T O T A L v a rie s va ri e s v a ri es v ar ie s v a rie s v a rie s v ar ie s va r ie s v a rie s 3 ,1 5 1 $ 1 75 , 77 1N o t if ic a t io n o f H az a rd o u s W a s t e Ac t i vi t y u n d e r 40 C F R P a rt 26 2 , S u b p a r t KI n t e n t t o C o m p ly w i th S u b p ar t K an d R e c o r d k ee p i n g o f A g r ee m e n t sL e tt erW ith d r a w a l fro m 40 C F R P a rt 26 2 , S u b p a rt KN o tific a tio n o f U n iv e rs a l W a ste A c tiv ity u n d e r 4 0 C F R P a rt 2 7 3 , Su b p a rt CN o n - P ro f it R es ea r c h In s t it u te sE P A Fo rm 8 7 0 0-1 2I n iti al N o tific a tio nS u b se q u en t N o t i fi c at i o nE P A Fo rm 8 7 0 0-1 2E lig ible A c ad e m ic En t itie sT ea ch in g H o sp ita lsL e tt erS u b se q u en t N o t i fi c at i o nN o t if ic a t io n o f U se d O il A ct i vi t y u n d e r 4 0 C F R P ar t 2 79I n iti al N o tific a tio nE P A Fo rm 8 7 0 0-1 2L e tt erE P A Fo rm 8 7 0 0-1 2L e tt erN o tific a tio n o f H az a rd o u s S ec o n d a ry M a ter ia l A cti vi ty u n d e r 4 0 C F R 26 0 .4 2N o t if ic a t io n o f H az a rd o u s W a s t e Ac t i vi t y u n d e r R C R A S e c ti o n 3 01 0I n iti al N o tific a tio nS u b se q u en t N o t i fi c at i o n53EXHIBIT 2-A2009 HAZARDOUS WASTE REPORTESTIMATED ANNUAL PRIVATE-SECTOR RESPONDENT HOUR AND COST BURDENHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$118.68/ $70.15/ $52.26/ $31.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the Hazardous Waste Report instructions 0.00 1.00 1.00 0.00 2.00 $122.41 $0.00 $0.00 7,568 15,136.00 $926,399Gather information and prepare Site Identification Form0.00 0.08 0.40 0.080.56 $29.03 $0.00 $0.00 7,568 4,238.08 $219,699Gather information and prepare Form GM 0.00 0.10 0.47 0.040.61 $32.83 $0.00 $0.00 94,561 57,681.91 $3,104,421Gather information and prepare Form WR 0.00 0.00 0.12 0.04 0.16 $7.53 $0.00 $0.00 423,986 67,837.76 $3,192,615Gather information and prepare Form OI 0.00 0.00 0.00 0.000.00 $0.00 $0.00 $0.00 0 0.00 $0Submit report to the State or Regional EPA Office 0.00 0.00 0.00 0.08 0.08 $2.52 $0.00 $3.25 7,568 605.44 $43,667Maintain a copy of each form for three years 0.00 0.00 0.01 0.020.03 $1.15 $0.00 $0.00 526,115 15,783.44 $605,032TOTAL varies varies varies varies varies varies varies varies varies 161,282.63 $8,091,833Hazardous Waste ReportEXHIBIT 2-b2009 HAZARDOUS WASTE REPORTESTIMATED ANNUAL STATE AND LOCAL GOVERNMENT RESPONDENT HOUR AND COST BURDENHours and Costs Per Respondent Per Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total$118.68/ $70.15/ $52.26/ $31.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearRead the Hazardous Waste Report instructions 0.00 1.00 1.00 0.00 2.00 $122.41 $0.00 $0.00 674 1,347.00 $82,443Gather information and prepare Site Identification Form0.00 0.08 0.40 0.080.56 $29.03 $0.00 $0.00 674 377.16 $19,552Gather information and prepare Form GM 0.00 0.10 0.47 0.040.61 $32.83 $0.00 $0.00 8,437 5,146.27 $276,970Gather information and prepare Form WR 0.00 0.00 0.12 0.04 0.16 $7.53 $0.00 $0.00 6,834 1,093.44 $51,460Gather information and prepare Form OI 0.00 0.00 0.00 0.000.00 $0.00 $0.00 $0.00 0 0.00 $0Submit report to the State or Regional EPA Office 0.00 0.00 0.00 0.08 0.08 $2.52 $0.00 $3.25 674 53.88 $3,886Maintain a copy of each form for three years 0.00 0.00 0.01 0.020.03 $1.15 $0.00 $0.00 15,944 478.32 $18,336TOTAL varies varies varies varies varies varies varies varies varies 8,496.07 $452,647Hazardous Waste Report54EXHIBIT 3NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$85.28/ $75.25/ $54.14/ $23.09/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 1,712 428.00 $23,180.48Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 1,712 3,852.00 $195,253.60Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 231 57.75 $3,127.74Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 231 519.75 $26,345.55Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 86 21.50 $1,164.44Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 86 193.50 $9,808.30Subtotal varies varies varies varies varies varies varies varies varies 5,072.50 $258,880.11Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 10,256 2,564.00 $138,866.24Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 10,256 23,076.00 $1,169,696.80Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.00 0.500.50 $11.55 $0.00 $0.45 10,256 5,128.00 $123,072.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 35,643 8,910.75 $482,606.22Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 35,643 80,196.75 $4,065,084.15Subtotal varies varies varies varies varies varies varies varies varies 119,875.50 $5,979,325.41Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 37 9.25 $500.98Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 37 83.25 $4,219.85Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 0 0.00 $0.00Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 0 0.00 $0.00Subtotal varies varies varies varies varies varies varies varies varies 92.50 $4,720.83aExhibit includes rounding.Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart KIntent to Comply with SubpartK and Recordkeeping of AgreementsWithdrawal from 40 CFR Part 262, Subpart KEligible Academic EntitiesNotification of Hazardous Secondary Material Activity under 40 CFR 260.42Notification of Hazardous Waste Activity under RCRA Section 3010Initial NotificationSubsequent NotificationNotification prior to operating under exclusion(s)Notification by March 1 of each even numbered year thereafterNotification indicating that the hazardous secondary materialsare no longer managed in accordance with the exclusion55EXHIBIT 3 (continued)NOTIFICATION OF REGULATED WASTE ACTIVITYESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$0.00/ $0.00/ $0.00/ $0.00/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year YearYear Year Year Year Cost Cost Activ. Year YearReview completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 26 6.50 $352.04Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 26 58.50 $2,965.30Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.00 0.500.50 $11.55 $0.00 $0.45 26 13.00 $312.00Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 9 2.25 $121.86Enter letter information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 9 20.25 $1,026.45Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.00 0.500.50 $11.55 $0.00 $0.45 9 4.50 $108.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 7 1.75 $94.78Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 7 15.75 $798.35Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 2 0.50 $27.08Enter letter information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 2 4.50 $228.10Subtotal varies varies varies varies variesvaries varies varies varies 127.50 $6,033.96Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 88 22.00 $1,191.52Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 88 198.00 $10,036.40Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.00 0.500.50 $11.55 $0.00 $0.45 88 44.00 $1,056.00Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 29 7.25 $392.66Enter letter information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 29 65.25 $3,307.45Generate EPA Identification Number and send EPAIdentification Number to facility0.00 0.00 0.00 0.500.50 $11.55 $0.00 $0.45 29 14.50 $348.00Review completed EPA Form 8700-120.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 95 23.75 $1,286.30Enter EPA Form 8700-12 information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 95 213.75 $10,834.75Review letter requesting EPA Identification Number0.00 0.00 0.25 0.000.25 $13.54 $0.00 $0.00 31 7.75 $419.74Enter letter information into database0.00 0.00 2.00 0.252.25 $114.05 $0.00 $0.00 31 69.75 $3,535.55Subtotal varies varies varies varies variesvaries varies varies varies 666.00 $32,408.37TOTAL varies varies varies varies varies varies varies varies varies 125,834 $6,281,369aExhibit includes rounding.Notification of Universal Waste Activity under 40 CFR Part 273, Subpart CInitial NotificationSubsequent NotificationEPA Form 8700-12LetterSubsequent NotificationEPA Form 8700-12Notification of Used Oil Activity under 40 CFR Part 279Initial NotificationLetterEPA Form 8700-12LetterEPA Form 8700-12Letter56EXHIBIT 42009 HAZARDOUS WASTE REPORTESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$85.28/ $75.25/ $54.14/ $23.09/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearDevelop Hazardous Waste Report forms and instructions 0.00 8.00 80.00 20.00108.00 $5,395.00 $0.00 $20,000.00 0.50 54.00 $12,697.50Distribute Hazardous Waste Report forms and instructions 0.00 0.01 0.25 0.500.76 $25.83 $0.00 $0.00 50 38.00 $1,291.50Develop computer capabilities required to compile national data0.00 8.00 80.00 0.0088.00 $4,933.20 $0.00 $250,000.00 0.50 44.00 $127,466.60Assist respondents 0.00 0.01 0.50 0.501.01 $39.37 $0.00 $0.00 50 50.50 $1,968.50Key entry of report submissions 0.00 0.01 0.08 0.250.34 $10.86 $0.00 $0.00 29 9.86 $314.94Perform quality assurance 0.00 0.02 0.16 0.160.34 $13.56 $0.00 $0.00 150 50.40 $2,034.00Prepare the National Report 0.00 8.00 200.00 40.00248.00 $12,353.60 $0.00 $50,000.00 0.50 124.00 $31,176.80Store the data 0.00 0.00 80.00 0.0080.00 $4,331.20 $0.00 $35,000.00 0.50 40.00 $19,665.60TOTAL varies varies varies varies varies varies varies varies varies 411 $196,615aExhibit includes rounding.Hazardous Waste ReportEXHIBIT 52009 HAZARDOUS WASTE REPORTESTIMATED ANNUAL STATE AGENCY HOUR AND COST BURDENaHours and Costs Per Agency Activity Total Hours and CostsLeg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total$57.43/ $53.91/ $32.26/ $20.58/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year YearDistribute and collect Report forms and instructions 0.00 0.01 0.25 0.50 0.76 $18.89 $0.00 $2.07 8,242 6,263.92 $172,752.32Assist respondents 0.00 0.01 0.50 0.501.01 $26.96 $0.00 $0.00 8,242 8,324.42 $222,204.32Key entry of report submissions 0.00 0.01 0.08 0.250.34 $8.26 $0.00 $0.00 56,199 19,107.66 $464,203.74Perform quality assurance 0.00 0.02 0.16 0.16 0.34 $9.32 $0.00 $0.00 542,059 182,131.82 $5,051,989.88TOTAL varies varies varies varies varies varies varies varies varies 215,828 $5,911,150aExhibit includes rounding.Hazardous Waste Report57EXHIBIT 6NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORTTOTAL ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN SUMMARYaTotal TotalAnnualAnnual TotalHours per Labor Cost per Capital/Startup O & M Cost perInformation Collection Requirement Year Year Costs Costs YearNotification of Regulated Waste Activity (Exhibits 1-a and 1-b) 36,525 $1,897,497 $0 $156,819 $2,054,316Hazardous Waste Report - Respondents (Exhibits 2-a and 2-b) 169,780 $8,517,772 $0 $26,787 $8,544,559TOTAL 206,305 $10,415,269 $0 $183,606 $10,598,875aExhibit includes rounding.EXHIBIT 7NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORTTOTAL ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN SUMMARYaTotal TotalAnnualAnnual TotalHours perLabor Cost per Capital/Startup O & M Cost perInformation Collection RequirementYearYearCosts CostsYearNotification of Regulated Waste Activity (Exhibit 3) 125,834 $6,276,685 $0 $4,684 $6,281,369Hazardous Waste Report (Exhibit 4) 411 $19,115 $0 $177,500 $196,615TOTAL 126,245 $6,295,801 $0 $182,184 $6,477,984EXHIBIT 8NOTIFICATION OF REGULATED WASTE ACTIVITY AND 2009 HAZARDOUS WASTE REPORTTOTAL ESTIMATED ANNUAL STATE AGENCY HOUR AND COST BURDEN SUMMARYaTotal TotalAnnualAnnual TotalHours perLabor Cost per Capital/Startup O & M Cost perInformation Collection RequirementYearYearCosts CostsYearHazardous Waste Report (Exhibit 5) 215,828 $5,894,089 $0 $17,061 $5,911,150TOTAL 215,828 $5,894,089 $0 $17,061 $5,911,150aExhibit includes rounding.