**Supporting Statement for**  **Collection of Information on Anaerobic Digestion Facilities Processing Wasted Food**

**to Support EPA’s Sustainable Food Management Program EPA Information Collection Request Number**  **2533.01**

**February 16, 2016**

### Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION ................................ ................................ ..... 1 1(a) Title of the Information Collection ................................ ................................ ................................ .... 1 1(b) Short Characterization/Abstract ................................ ................................ ................................ ......... 1 2. NEED FOR AND USE OF THIS COLLECTION ................................ ................................ ................................ ..... 3 2(a) Need/Authority fo r the Collection ................................ ................................ ................................ ...... 3 2(b) Practical Utility/Users of the Data ................................ ................................ ................................ ..... 3 3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ................................ ........ 4 3(a) Nonduplication ................................ ................................ ................................ ................................ .......... 4 3(b) Public Notice Required Prior to ICR Submission to OMB ................................ ................................ 5 4. THE RESPONDENTS AND THE INFORMATION REQUESTED ................................ ................................ ........ 6 4(a) Respondent NAICS Codes ................................ ................................ ................................ ................. 6 4( b) Information Requested ................................ ................................ ................................ ....................... 9 5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT ................................ ................................ ................................ .............. 11 5(a) Agency Activities ................................ ................................ ................................ ............................. 11 5(b) Collection Methodology and Management ................................ ................................ ...................... 11 5(c) Small Entity Flexibility ................................ ................................ ................................ .................... 11 5(d) Collection Schedule ................................ ................................ ................................ ......................... 12 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION ................................ ................................ .. 12 6(a) Estimating Respondent Burden ................................ ................................ ................................ ........ 12 6(b) Estimating Respondent Costs ................................ ................................ ................................ ........... 13 6(c) Estimating Agency Burden and Costs ................................ ................................ .............................. 16 6(d) Estimating the Respondent Universe ................................ ................................ ............................... 18 6(e) Bottom Line Burden Hours and Costs ................................ ................................ ............................. 19 6(f) Reasons for Change in Burden ................................ ................................ ................................ ......... 19 6(g) Burden Statement ................................ ................................ ................................ ............................. 191



### 1. **IDENTIFICATION OF THE INFORMATION COLLECTION 1(a)**  **Title of the Information Collection** This new information collection is entitled “ Collection of Information on Anaerobic Digestion Facilities Processing Wasted Food to support EPA’s Sustainable Food Management Program , ” ICR number 2533.01, OMB control number 2050 -NEW . **1(b) Short Characterization/Abstract**  EPA’s Office of Land and Emergency M anagement Sustainable Food Management (SFM) p rogram is designed to advance sustainable food management practices throughout the United States by

p reventing and diverting waste d food from landfills. The focal point of the SFM program is the Food Recovery C hallenge in which organizations pledge to improve their sustainable food management practices. T he success of the SFM program e fforts to divert wasted food f

rom landfills requires sufficient capacity t o process the diverted materials which includes composting and anaerobic digestion operations. In addition to increasing opportunit y to process wasted food diverted from the municipal solid waste stream, anaerobic digesters achieve social, environmental and economic benefits, such as generation of renewable energy , reduction of methane emissions, and opportunities to improve soil health through the production of soil amendments. The SFM p rogram support s these efforts by e ducating state and local governments and communities about the b enefits of wasted food diversion. T he SFM program also b uilds partnerships with state agencies and other strategic partners interested in developing organics recycling capacit y and provid es tools to assist organizations in developing anaerobic digestion ( AD ) projects. The SFM Program informally track s dat a on anaerobic digesters to quantify and monitor2

the capacity for processing divert ed wasted food in the United States at AD facilities. This AD data consists of information compiled from publicly avail able sources onl y. The information requested by

this ICR is being formall y collected for the first time and would exceed 10 non Federal respondents. This information collection would allow the SFM program to document the capacity for processing wasted foo d at AD facilities, track the growth of this capacity and provide a better understanding of the factors affecting this growth. This knowledge will also help develop future activities designed to further increase capacity . Increasing capacity for digestio n of wasted food will spur growth in the biogas sector as a whole, advance federal goals to reduce methane emissions, increase production of renewable energy and assist state and local governments with their solid waste diversion goals. This information co llection consists of a data collection request to gather details regarding AD facilities for enhancement of the existing data into an AD facility inventory for the SFM program (SFM AD Facility Inventory

). This information collection will include annual up dates to the data set . Respondents will be requested to c omplete a questionnaire for this effort . A key objective of the SFM program is to support beneficial use of wasted food by decreasing barriers to diversion. Providing information on the location and capacity of AD facilities in the United States to receive wasted food and other organic materials can assist with this issue. In order to ensure that the existing AD data is complete and accurate, the SFM program needs to gather information from all stakeholders involved in the development and management of AD facilities accepting organic wastes. Th is includes state and local regulatory officials as well as industry representatives. Annual updates to the SFM AD Facility Inventory will be necessary

to maintain accuracy

over time. This information will allow EPA to estimate and communicate the total capacity and environmental benefits of these projects and enable the3

SFM program to strategically plan future activities to support sustainable food management practices. Additionally , stakeholders can use this information to encourage the diversion of wa sted food and justify

funding resources for AD projects. Respondents for this I CR are: 1) State L iaisons, 2) Industry Representatives, 3) Project Owners/Operators, and 4) Other Stakeholders (e.g. non - profits). This I CR provides a comprehensive descriptio n of information collection efforts to support EPA’s SFM program . Sections 1 through 5 describe the information collection with respect to need, us e and respondent activities. Section 6 estimates the annual hour and cost burden to respondents and the Agen cy under th i s collection.



### 2. NEED FOR AND USE OF THIS COLLECTION

**2(a) Need/Authority for the Collection**  In formation collected from respondents will allow EPA to track, facilitate and measure the increase in capacity to process wasted food (organics) via anaerobic digestion throughout the United States. The success of the Sustainable Food Management Program’s Food Recovery Challenge is dependent on a steady increase of processing capacity over time. At this time, EPA does not have the necessary data to d emonstrate this growth or to document the current baseline processing capacit y. As the practice of organics diversion gains momentum, the rate at which wasted food is diverted from landfills will rapidly increase. This data is essential for EPA to evaluate agency

activities designed to build such capacity and to make adjustments to the overall Sustainable Materials Management (SMM) program, as needed. The importance of this type of data was recently

emphasized in EPA’s SMM Strategic Plan (Fiscal Year 201 7 - 2022). **2(b) Practical Utility/Users of the Data** 4

EPA will use information submitted by respondents to update and expand its inventory of AD facilities. Data on processing capacity and end uses of AD products will be collected as part of the inventory

exp ansion. Data on AD projects will serve as a source of information to inform the public and lawmakers about the environmental benefits, such as renewable energy , derived from anaerobic digesters . The quantitative and qualitative data captured will assist the SFM program with future resource planning. EPA will use information provided by state contacts involved in the review and approval of new or ongoing projects to update the inventory and to identify

barriers and opportunities within the AD sector. Infor mation from industry representatives, project owner/operators, and other stakeholders will increase EPA’s ability to provide technical assistance to states and municipalities related to project design, implementation, cost effectiveness, return on investme nt and successful business models. 

### 3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION **CRITERIA 3(a)**  **Nonduplication** For non - federal respondents, the information to be collected has not been collected previously

by EPA or any

other federal agency

from more than 9 respondents. Comprehensive information about existing and new AD projects is not available through any other mechanism. To avoid requesting information that has already been co mpiled , respondents will receive a spreadsheet , pre -populated with existing AD data . R espondents will be asked to review the information and to provide updates as well as missing or additional information.5

The AD community

often announces the planning or installation of digester operations, so some of the necessary

data are available in publications. The information collection process will allow EPA to collect information from respo ndents related to the unpublished details of AD projects and projects not covered b y existing publications. **3(b) Public Notice Required Prior to ICR Submission to OMB**  This Supporting Statement is associated with the initial Federal Register notice for this ICR. Any

comments received during the first 60 - day public comment period will be documented prior to submittal of the ICR package to OMB. **3(c) Consultations**  SFM staff contacted three respondents to request information on the estimated amount of time r equired to respond to the SFM AD Facility Inventory questionnaire. **Table 1: List of Respondent Consultations for the SFM AD Facility Inventory Update Contact Person, Organization**  **Role Email A** **ddress** Brian Langolf, Director of Biogas Sy stems and Research Development, University of Wisconsin

– Oshkosh AD Operator langolfb@uwosh.edu Dana Kirk, Assistant professor in Biosystems and Agricultural Engineering, Michigan State University AD Operator Kirkdana@anr.msu.edu Dave Baran, Quasar Energy Group, Project Development AD Vendor/Consultant dbaran@quasareg.com **3(d) Effects of Less Frequent Collection**  The SFM AD Facility Inventory and questionnaire will be distributed to potential respondents annuall y . Any reduction in the frequency of this information collection would impede efforts to facilitate anaerobic digestion implementation and track the increased diversion of wasted food and expanded infrastructure capacity in the organics recycling sector.6

**3(e) General Guidelines**  In formation collections performed under this clearance will follow all of OMB’s General Guidelines regarding federal data collection. **3(f) Confidentiality**  Participation in this data collection effort is voluntary . Respondents are not required to reveal confidential business information. Additionally , respondents will be given specific instructions to not provide any information that they

consider confidential. **3(g) Sensitive Questions**  No questions of a sensitive nature are asked as part of this collection effort or included within the pre -populated project data spreadsheet. 

### 4. THE **RESPONDENTS AND THE INFORMATION REQUESTED 4(a)**  **Respondent NAICS Codes** This information collection will encompass a wide variety of respondents. State liaisons include staff from state agencies involved in energy, environment and solid waste management. In dustry representatives include engineering firms, construction companies, environmental consultants, and other companies involved in the logistics of d eveloping anaerobic digesters. Other stakeholders include non -profit groups or non - governmental organizations (NGOs), as well as universities that provide information or other support to the project owners or industry representatives. Table 4 provides a s ummary of the applicable North American Industry Classification S ys tem (NAICS) codes and relevant descriptions for each typ e of respondent. The NAICS description is followed by the relevant sector and Standard Occupational Classification (SOC) code. The SOC code will be used to determine the applicable labor rate for each typ e of respondent.7 **Table 4**  **: Respondents to Information Collection Respondent**  **Type NAICS** 

**Code NAICS Description (Sector and SOC code)**  State Liaison 999200 Public Administration; State Managers (Sector 99: Federal, State and Local government ; SOC code 11 - 9041

– Architectural and Engineering Managers ) Industry Representatives 221100 Electric Power Generation, Transmission and Distribution (Sector 22: Utilities ; SOC code 17 - 2081

– Environmental Engineers ) 333 1 00 Agriculture, Construction, and Mining Machinery Manufacturing (Sector 33: Manufacturing ; SOC code 11 - 9041

– Architectural and Engineering Managers) 54130 0 Engineering Services (Sector 54: Professional, Scientific, and Technical Services ;

SOC code 17 - 2081

– Environmental Engineers ) Project Owners or Operators 541300 Engineering Services (Sector 54: Professional, Scientific, and Technical Services ; SOC code 17 - 2081

– Environmental Engineers) 221300 SOC Code 51 - 8031 : Water and Wastewater Treatment Plant and System Operators 611300 Colleges, Universities, and Professional Schools (Sector 61: Educational Services;

SOC code 17 - 2081

– Environmental Engineers ) Other Stakeholders 813900 Business, Professional, Labor, Political, and Similar Organizations (Sector 81: Other Services ; SOC codes 19 - 4091

– Environmental Science and Protection Technicians (for Conservation non - profit staff; university researchers) Table 5 below provides example respondents under each respondent typ e, the applicable NAICS codes, and the number of potential respondents for the program covered by this ICR. This table shows the number of potential respondents for each NAICS.8 **Table 5**  **: Numbe**  **r of Potential Respondents**  **Respondent Type NAICS**  **Code Example Respondent(s)**  **SFM AD Inventory**  State Liaison 999200 State energy or natural resources official 60 Industry Representatives 221100 Electric cooperative engineer; Energy service providers 10 333 1 00 Manufacturers or distributors of AD

systems 20 541300 Consultants and system developers 25 541300 AD facility operator 75 Project Owners or Operators 221300 Water and Wastewater Treatment Plant and Sy stem Operator 200 611300 University digester operator 15 Other Stakeholders 813900 Conservation non - profits; University researchers 10 **TOTAL (Year 1)**  1 **415 TOTAL (Year 2)**  **458 TOTAL (Year 3)**  **508**

1 Assuming 10% increase in Respondents per year . To calculate this increase, the number of estimated respondents in each category is multiplied by 1.1 then rounded to the nearest whole number. These estimates are then summed to get 458 and 508 respect ively.9

**4(b)** In formation Requested **(i) Data Items, Including Recordkeeping Requirements**  In formation will be collected annuall y for the SFM AD Facility Inventory . Q uestionnaires specific to respondent typ e and a pre -populated electronic spreadsheets will be used to collect information and track updates. As stated above in Section 1(b), colle ction of information on anaerobic digesters for the SFM AD Facility Inventory is intended to provide information on the capacity for recycling of food - based materials and the growth of this capacity over time. During the first year of data collection, r es pondents will be requested to respond to a questionnaire designed to obtain the following information on the facilities that are within their purview:

 Project name, t ype, location, and operational status;

 Feedstock ty

pe and volume processed;

 Digester chara cteristics and capacity , including design specifications; and

 In formation on the end - use of by - products produced. This information is needed to effectivel y track existing AD projects and their capacity for processing food and other organic wastes and to gain a better understanding of the market for AD by- products. Respondents will also be requested to review a spreadsheet of existing information and identify

any additional facilities that they might be aware of or have information about. This information will assist EPA in identifying facilities that are not currentl y part of the data set. To date, the SFM program has compiled preliminary AD facility

data based on publicl y available information. Durin g subsequent year requests, respondents associated with the facilities that are already part of the SFM AD Facility Inventory , will receive a pre - populated electronic10

spreadsheet with the previous years’ data set. These respondents will be requested to review this data and provide n ew or revised information where appropriate. The number of respondents is expected to increase by

10% each year. For data collection during years 2 and 3 of this ICR, completion of the questionnaire will onl y be necessary for respondents associated with newl y identified facilities not previousl y represented in the data set. Project owners and operators may choose to provide information to EPA more frequentl y than annuall y if there are changes to project status, capacity, processing rates etc. However, the SFM program will update information made available to the public on all projects on an annual basis. Participation does not require that any records be kept, although respondents will likely maintain file copies of updates submitted to EPA. **(ii) Resp**  **ondent Activities** Respondents will provide detailed information only on the projects in which they are involved. For the initial data request r espondents will:

 complete the questionnaire (provided b y EPA);

 review the pre - populated spreadsheet (provided by EPA);

 identify

additional facilities, if known;

 email information on new facilities and/or the completed questionnaire to EPA; and

 maintain a filed cop y of the information submitted electronically (optional). To provide annual updates to the SFM AD Facili ty Inventory r espondents will:

 review the spreadsheet with the pre -populated data set ;

 provide updated information on the projects under the respondents’ purview in a separate un - populated spreadsheet (provided b y EPA);11

 identify

additional facilities, if known;

 email information on new facilities and/or newly populated spreadsheet to EPA; and

 maintain a filed cop y of the information submitted electronically (optional) 

### 5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT **5(a)** Agency

Activities In requesting and receiving information under this I CR for development and maintenance of the SFM AD Facility Inventory , EPA will complete the following tasks:

 Collect update s/questionnaires from respondents and maintain cop y of all submitted data;

 Review information provided and follow up with respondent, if necessary ;

 Use information collected to enhanc e the existing data into the SFM AD Facility Inventory (Year 1);

 Enter information into the SFM AD Facility Inventory fi le (Years 2 and 3); and

 Post facility

information on the EPA website **5(b) Collection Methodology and Management**  EPA selected the methods for collecting this information to optimize efficiency and minimize the burden for respondents and EPA. The SFM program will notify respondents by email with an attached spreadsheet and questionnaire . All information received from respondents will be reviewed by

EPA before being finalized and posted on the EPA website. **5(c) Small Entity Flexibility**  The respondent ty

pe identified as “Other Stakeholders” are not classified as small entities due to the non - profit nature of these respondents. Many of the project owner/operators are12

municipalities or cities. Both municipalities and cities as well as state liaisons are conside red government entities. According to the United S tates Small Business Administration (SBA) , government entities are not permitted to be classified as small businesses for the purposes of this anal ys is. B ased on the applicable thresholds for the remaining NAI CS code s as established by the SBA (see: https://www.sba.gov/content/small - business - size - standards ) some industry representatives may

be considered small entities . In p articular, manufacturers or distributors of AD sy stems and consultants and sy stem developers could be classified as small entities. However, the average annual burden and cost per respondent requested under this I CR is estimated to be 30 minutes and $ 74, respectivel y. T he response burden does not require an y capital investments, only

a small amount of labor and EPA ensures that the process for responding to the AD inventory questionnaires and updates is as efficient as possible by providing a pre - populated spreadsheet that respondents can simply review and provide the requested information or updates. This annual burden and cost is not expected to pose a significant burden on small entities. Inaddition, a response is requested by EPA, but not required and r espondents may choose not to respond. **5(d) Collection Schedule**  EPA will collect information annually for the SFM AD Facility Inventory through the use of questionnaires and pre - populated spreadsheets which respondents can review, complete and updat e. 

### 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION **6(a)** Estimating Respondent Burden In order to obtain accurate hourly burden and cost estimates, EPA consulted with three13

stakeholders regarding burden and cost assumptions for this I CR. The total hourly burden estimates for the program (for the entire 3 - ye ar ICR time period) are summarized in Table 7 below. **Table 7**  **: Total Burden Hours for SFM AD Inventory Updates (3 Year Pe**  **riod) Respondent Type**  **NAICS Code Total Burden (hours)**  **October 2016 –**  **September 2019** State Liaisons 999200 100 Industry Representatives 221100 17 333 1 00 34 54130 0 42 Project Owners or Operators 541300 125 221300 331 611300 26 Other Stakeholders 813900 17 **TOTAL 692**  The burden hours listed in the table above are based on the following assumption: each annual inventory

update for the SFM AD Facility Inventory

requires 30 minutes . The burden hour estimates displayed in Table 7 are rounded to the nearest hour. The respondent costs, including wage rate assumptions, are described below. Table 9 presents the estimated total respondent costs during the 3 - ye ar ICR period for each typ e of respondent, using the wage rates outlined in Table 8. **6(b) Estimating Respondent Costs**  **(i) Estimating Labor Costs**  For each respondent t ype and NAICS code, EPA used the mean hourl y wage for the applicable SOC codes, which are listed in Table 8 below. Labor rates were not divided into clerical, legal, or other labor sub - categories for a specific NAI CS code since respondents subject to the information collection effort will be primarily engineers/scientists. Rates were obtained14

from the Bureau of Labor Statistics’ May 2014 National Indus try - Specific Occupational Employ ment and Wage Estimates (see: http://www.bls.gov/oes/current/oessrci.htm#11 ). The total labor rate used to calculate cost was obtained by appl yi ng an overhead rate of 110 percent. **Table 8**  **: Mean Hourly Wages by Respondent Type and SOC Code**  **Respondent Type NAICS** 

**Code SOC code**  **May 2014 Me**  **an Hourly Wage ($)**  **May 2014**

**Me an Hourly**  **Wa ge ($)**  **(+110% overhead)**  **May 2016**

**Me an Hourly**  **Wage ($) (+ 2% annual**  **growth)** State Liaisons 999200 SOC code 11 - 9041: Architectural and Engineering Managers 45.20 94.92 98.75 Industry Representatives 221100 SOC code 17 - 2081: Environmental Engineers 40.43 84.90 88.33 333 1 00 SOC code 11 - 9041: Architectural and Engineering Managers 64.51 135.47 140.94 54130 0 SOC code 17 - 2081: Environmental Engineers 42.35 88.94 92.53 Project Owners or Operators 541300 SOC code 17 - 2081: Environmental Engineers 42.35 88.94 92.53 221300 SOC Code 51 - 8031 : Water and Wastewater Treatment Plant and Sy stem Operators 21.25 44.63 46.43 611300 SOC code 17 - 2081: Environmental Engineers 37.76 79.30 82.50 Other Stakeholders 813900 SOC code 19 - 4091: Environmental Science and Protection Technicians (For Conservation Non - profit staff, university researchers 25.26 53.05 55.19

To ensure that the rates accurately reflect the expected rates at the start of this I CR, May 2016 labor rates were estimated by applying an annualized 2% growth factor from the Employ ment Cost Index to account for increases in wages from May 201 4 to May

2016. This is based on the fact that for both private industry and civilian workers, the Employ ment Cost Index increased b y 2.0 percent in 2015 (see: http://www.bls.gov/news.release/eci.t04.htm ). L abor costs across the 3 - ye ar time period for this I CR are calculated using labor rates that assum e an average15

2% increase each ye ar using the May 2016 rates as a starting point. **(ii) Estimating Capital and Operations and Maintenance Costs**  Because this information collection requires respondents onl y to report information that is already available to them, there are no capital costs. EPA does not expect that the operations and maintenance (O&M) costs of this program will be significant. The total costs for this information collection are summarized in Table 9 below and are rounded to the nearest dollar. The total cost values are based on the fully loaded rates that include overhead and growth as shown in Table 8 (and then increased by

2% each year during the 3 - year time period for this ICR) and the total burden hours in Table 7.16

**Table 9 : Summary of**  **Respondent Burden –**  **Total Cost for SFM AD Inventory (3 Year Period)**  **Respondent Type NAICS Code**  **Total Burden Cost ($): May 2016**  **– April 2019**  State Liaison 999200 10,024 Industry Representatives 221100 1,532 333 1 00 4,817 54130 0 3,964 Project Owners or Operators 541300 11,799 221300 15,676 611300 2,146 Other Stakeholders 813900 957 **TOTAL $5**  **0,915** The total cost for the entire 3 - ye ar I CR time period is $50,915. This represents the total overall cost for the respondent portion of this ICR since there are no capital expenditures or O&M costs. **6(c) Estimating Agency Burden and Costs**  Following i s a summary

of the Agency

burden associated with each activity, as described in Section 5(a).

 Collect updates /questionnaires and maintain copy of all submitted data Clerical: 1 hour per update (updates are annual; 1 hour per ye ar)

 Review the information provided and follow up with respondent if necessary Technical: 40 hours per update (updates are annual; 40 hours per ye ar)

 Develop an updated inventory (Year 1) Technical: 80 hours (Year 1 only)17

 Enter data into the SFM AD Facility Inventory

file (Years 2 and 3 onl y) Clerical: 8 hours per update (8 hour per ye ar; Years 2 and 3 only)

 Post SFM AD Facility Inventory

data on the EPA website Technical: 0.25 hours per update (updates are annual; 0.25 hour per ye ar) Tables 9a and 9b present the estimated total agency burden hours and costs, respectivel y, for the information collection activities associated with this I CR. The burden hours in Table 9a reflect the entire 3 - ye ar time period covered b y this I CR. The totals are rounded to the nearest hour. To obtain an hourly burden estimate for the entire ICR time period, annual time estimates for each relevant labor category as described above were multiplied by the appropriate factor depending on whether the activity will be conducted for one, two or all three years . The totals in Table 9b reflect the associated cost by labor category

based on the total burden hours presented in Table 9a. EPA estimates an average hourly cost using set EPA salary rates for labor plus an additional 60% for overhead. To derive these estimates, EPA used the “Salary Table 2016 - GS” from the Department of Personnel Management (see: http://www.opm.gov/policy - data oversight/pay - leave/salaries - wages/salary - tables/pdf/2016/GS_h.pdf ). For purposes of this I CR, EPA assigned staff the following government service levels: 1) Technical Staff - GS - 12, Step 5; and 2) Clerical Staff - GS - 5, Step 1. The corresponding salary rates are $3 3.72 for technical staff and $13.54 for clerical staff. When the 60% overhead is included the corresponding rates are $53.95 for technical staff and $21.66 for clerical staff. No managerial hours will be spent on implementation of this ICR.18 **Table 9a**  **: Total Agency Burden Hours**  **Labor Category Total Agency Burden (hours):**  **May 2016 –**  **April 2019** Technical (GS - 12, step 5) 216 Clerical (GS - 5, step 1) 4 **TOTAL 220** 

**Table 9b:**  **Total Agency Cost Labor Category**  **Total Agency Cost ($): May 2016**  **– April**  **2019 Total Agency Cost**  **+ 60% Overhead ($):**  **May 2016 –**  **April 2019** Technical (GS - 12, step 5) 7,284 11,654 Clerical (GS - 5, step 1) 54 87 **TOTAL ($)**  **7,3 3**  **8 11,74**  **1** Table 9 b presents the total cost to the Agency as described in Section 5(a) . The total agency burden for the relevant ICR time period is 220 hours and the total cost is $11,74 1. **6(d) Estimating the Respondent Universe**  The number of respondents for each ye ar of this ICR is expected to gradually increase over time. It is anticipate d that the entire number of facilities will increase by approximately 10% per ye ar over the three ye ars of the IC R. Tables 10a and 10b present a summary of the respondent universe b y category for the next 3 - ye ar ICR period for total hours and total costs, respectivel y. The burden estimates are based on the total respondent universe.19 **Table 10a:**  **Total Hours (3 Year Period) Total Hours:**  **May 2016 –**  **April 2019** AGENCY BURDEN 220 RESPONDENT BURDEN 691 **TOTAL BURDEN 911** 

**Table 10b: Total Costs (3 Year**  **Period) Total Cost ($):**  **May 2016 –**  **April 2019** AGENCY COST 11,740 RESPONDENT COST 52,038 O&M/Capital Costs 0 **TOTAL COST ($) 63,778**  **6 (e)**  **Bottom Line Burden Hours and Costs** Over the 3 - ye ar period covered by this ICR, EPA estimates the total respondent burden to be 691 hours and $50,915. There are no O&M or capital costs. EPA estimates the total Agency burden to be 220 hours and $11,74 1 . The annual respondent burden and cost, averaged over the three - ye ar period, is 231 hours and $1 6 , 972 , respectivel y. There are no O&M or capital costs. The annual Agency burden and cost, averaged over the three - year period, is 73 hours and $3,91 4 . The total estimated burden and cost is 304 hours and $2 0 , 886 per year. **6(f) Reasons for Change in Burden**  The change in burden is not applicable in this case since this is a new ICR. **6(g) Burden Statement**  The overall annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 30 minutes and $ 74 per respondent.20

Burden means the total time, effort or financial resources expended b y persons to generate, maintain, retain and disclose or provide information to or for a federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any

previousl y applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. To comment on the a gency ’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID EPA - HQ RCRA - 2015 - 0836 , which is available for online viewing at www.regulations.gov, or in person viewing at the Resource Conservation and Recovery Act Docket in the EPA Docket Center ( EPA/DC ) , EPA West, Room 3334, 1301 Constitution Ave. NW, Washington, DC. The EPA/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is 202 - 566 - 1744, and the telephone numbe r for the Resource Conservation and Recovery Act 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 of21

the public docket and access those documents in the public docket that are available electronically . In the sy stem, select “search,” then key in the Docket ID Number identified above. Alternatively , send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No . EPA - HQ RCRA - 2015 - 0836 in an y corresponden ce .22