1 SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTIO N REQUEST NUMBER 2519.01

“HAZARDOUS WASTE EXPORT -IMPORT REVISIONS RULE”

September 2015

Office of Resource Conservation and Recovery United States Environmental Protection Agency Washington, D.C. 204601 

### TABLE OF CONTENTS

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

2. NEED FOR AND USE OF THE COLLECTION ...................................................7 2(a) Need and Authority for the Collection .........................................................7 2(b) Practical Utility and Users of the Data ........................................................7

3. NONDUPLICATION, CONSULTATI ONS, AND OTHER COLLECTION

CRITERIA ...............................................................................................................7 3(a) Nonduplication .............................................................................................7 3(b) Public Notice ................................................................................................8 3(c) Consultations................................................................................................8 3(d) Effects of Less Frequent Collection .............................................................8 3(e) General Guidelines .......................................................................................8 3(f) Confidentiality .............................................................................................8 3(g) Sensitive Questions ......................................................................................9

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .....................9 4(a) Respondents and NAICS Codes ..................................................................9 4(b) Information Requested ...............................................................................10

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

MANAGEMENT ...................................................................................................18 5(a) Agency Activities .......................................................................................18 5(b) Collection Methodology and Management 19 5(c) Small Entity Flexibility ..............................................................................19 5(d) Collection Schedule ...................................................................................20

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ...20 6(a) Estimating Respondent Burden..................................................................20 6(b) Estimating Respondent Costs ....................................................................21 6(c) Estimating Agency Burden and Costs .......................................................22 6(d) Estimating the Respondent Universe and Total Burden and Costs ...........22 6(e) Bottom Line Burden Hours and Costs .......................................................27 6(f) Reasons for Change in

Burden 28 6(g) Burden Statement .......................................................................................291 1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This information collection request (ICR) is en titled "Hazardous Waste Export-Import Revisions (Proposed Rule)" EPA ICR Nu mber 2519.01, OMB Number 2050-NEW.

1(b) Short Characterization

Since March 1992, OECD member countries have regulated the international movement of hazardous wastes destined for recovery under Council Decision C(92)39/FINAL. EPA’s April 1996 Imports and Exports of Hazardous Waste Final Rule implements OECD’s Council Decision C(92)39/FINAL in the United States under RCRA authority, under 40 CFR Part 262, Subpart H. 1 While that rule codifies the OECD requirements for U.S. imports and exports of hazardous waste with OECD countries, shipments to Canada and Mexico are also covered under separate bilateral agr eements. RCRA regulatory requirements for exports to Canada, Mexico,

and non-OECD countries are under 40 CFR Part 262, Subpart E, and the corresponding import requirements for shipments from these countries are under 40 CFR Part 262, Subpart F. In 2004, in order to improve some of its provisi ons and enhance harmonization with the Basel Convention, OECD updated its rule under Council Decision C(2001)107/FINAL, as amended by C(2004)20 and further amendments in November 2005 and November 2008. In 2008, EPA developed the Proposed Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exports of Sp ent Lead-Acid Batteries from the U.S., and Import Consent Documentation to implement th ese updates and strength en controls on SLABs by making their export subject to subpart E expo rt regulations, if being shipped to Canada,

Mexico, or non-OECD countries, or subject to subpart H OECD regulations, if being shipped to

OECD countries other than Canada or Mexico. Th e final rule for these changes was issued in 2010. Because domestic shipment of SLABs for r ecycling is exempted from RCRA manifest requirements, export shipments of SLABs we re also exempted from RCRA manifest requirements. But export shipments of SLABs s ubject to subpart H OECD requirements were subject to OECD movement document requirements under the changes in the 2010 rule.

Since the 2010 rulemaking, however, EPA and several non-governmental organizations

have raised concerns over the lack of reporting and insufficien t environmental and occupational health controls associated with transboundary movement of hazardous wastes, most notably

1 U.S. EPA Imports and Exports of Hazardous Waste: Implementati on of OECD Council Decision C(92) 39 Concerning the Control of Tra nsfrontier

Movements of Wastes Destined for Reco very Operations, Final Rule, Federal Re gister, Vol. 61, No. 72, April 12, 1996.2 regarding exports of SLABs to Canada and Mexico. 2,3,4 To address these concerns, EPA is proposing to make all U.S. imports and exports of hazardous waste, including those with countries outside of OECD, subject to standards equivalent to those prom ulgated in 40 CFR Part 262, Subpart H in the 2010 rulemaking. In additi on, EPA is proposing to mandate the electronic submission of required documents, which is expect ed to improve data av ailability and quality. Better data will help the United States and other countries control the environmental and health

risks associated with hazardous waste movement, processing, and disposal.

The pertinent details of the proposed rule are outlined below. For further information regarding the historical context a nd details of this rulemaking, please refer to the Preamble to the proposed rule.

REGULATORY CHANGES/AMENDMENTS

A. Changes to 40 CFR Part 262, Subparts E and F

The proposed rule will regulate hazardous waste shipments with Mexico, Canada and non-OECD

countries in a manner more consistent with regulations currently in place for shipments with other OECD

member countries under 40 CFR Part 262, Subpart H. Many of the regulatory changes described below

therefore do not alter the requirements in Subpart H asso ciated with each provision, but rather adjust the

types of entities held to each requirement by ma king entities currently subject to Subpart E and F

requirements subject to Subpart H requirements. Cha nges to requirements for shipments currently subject

to 40 CFR Part 262, Subpart E (i.e., exports to Cana da, Mexico, and non-OECD countries) and Subpart F

(i.e., imports from Canada, Mexico, and non-OECD countries) include the following:

(1) Exporters of hazardous waste to Canada, Mexico, and non-OECD countries will be required to submit additional in formation with each export notice.

This additional information includes an e-ma il address and fax number for each listed party on the notice, all anticipated transpor ters for the shipments, all anticipated export ports in the United States, any interi m facilities to be used during the transfer of waste, and the OECD waste codes and r ecycling or disposal operation codes for all waste streams to be shipped. Exporters to other OECD countries are already required to submit this information, and will therefore experience no change in their cost burden as a result of the proposed rule.

(2) Importers of RCRA hazard ous wastes not treated as hazardous waste exports by the country of export will need to submit notices to EPA on behalf of foreign

2 OECD (2012), Illegal Trade in Environmentally Sensitive Goods , OECD Trade Policy Studies, OECD Publishing, accessed at

http://dx.doi.org/10.1787/9789264174238-en on November 12, 2014.

3 Occupational Knowledge Internat ional and Fronteras Comunes, Exporting Hazards: U.S. shipments of used lead batteries to Mexico take

advantage of lax environmental and worker health regulations , June 2011, accessed at

http://www.okinternational.org/docs /Exporting%20Hazards_Study_100611v5.pdf on November 12, 2014.

4 Secretariat of the Commission for Environmen tal Cooperation, Hazardous Trade? An Exam ination of US-generated Spent Lead-Acid B attery Exports

and Secondary Lead Recycling in Canada, Mexico , and the United States, April 2013, accessed at http://www3.cec.org/isl andora/en/item/11220-

hazardous-trade-examination-us-generated-spent-lead-acid-battery-exports-and on October 21, 2014.3 exporters.

§262.82(a)(2)(ii) requires that hazardous wa ste shipments fulfill all regulatory requirements regardless of the designation of the waste in the country of export. §262.82(a)(2)(ii)(B) specifies th at export notice requireme nts usually assigned to foreign exporters will become the duty of U.S. import facilities receiving shipments of waste. This requirement already applie s to shipments of waste from other OECDcountries and will be required for import shipments from Canada, Mexico, or nonOECD countries. This new U.S. requirement will not affect shipments from Canada as Canadian regulations already require export notices whenev er the country of import controls the proposed shipment as hazardous waste, but will affect import shipments from Mexico and non-OECD countries.

(3) For export annual reports to EPA, exporters to Canada, Mexico, and non-OECD

countries must list OECD waste codes fo r all shipments in addition to RCRA waste codes, and must list DOT/ID numb ers in place of DOT hazard classes.

Exporters of hazardous waste to OECD countri es must already comply with the first requirement in Subpart H. Exporters to Canada, Mexico, and non-OECD counties will be affected by the second requirement, but as it replaces an existing data item being collected, the net impact of the second requirement will be zero.

(4) Contracts must be signed between ex porters and importers of hazardous waste and foreign facilities specifying the part ies relevant to each shipment and the various legal responsibilities of each party involved.

Exporters and importers of hazardous waste w ith OECD countries are already held to this requirement under subpart H. Exporters and importers of hazardous waste with Canada, Mexico and non-OECD countries wi ll now be subject to this new U.S. requirement, but U.S. exporters and importe rs of waste with Canada will not be impacted as Canadian regulations alrea dy require contracts between the Canadian facility and the foreign facility.

(5) Exception reports can be based on either RCRA manifests or OECD movement

documents.

Currently, exception reports under Subpart E are only based off of RCRA manifests. This change will potentially impact export shipments of universal waste and SLABs to Canada, Mexico, and non-OECD countries th at are partially or wholly rejected by the foreign receiving facility.

(6) Exporters and importers must ensure that a movement document accompanies all shipments of hazardous waste.

The movement document must include a signed certification, as well as all information required for notification. For sh ipments to and from Canada, exporters4 and importers may use the existing Canadian movement document they are already required to use under Canadian regulations to fulfill this re quirement. Similarly, exporters to OECD countries and importers receiving waste from OECD countries for recycling (with the exception of Canada and Mexico) are already required to complete this document. Therefore, this requirement will only impact exporters and importers exchanging waste with Me xico and non-OECD countries.

(7) U.S. receiving facilities must se nd a copy of the signed OECD movement document to EPA, the foreign exporter of the waste, and the relevant authorities of the exporting country.

This requirement must be completed within three days of receiving a shipment of hazardous waste. Importers must also maintain a signed copy of the movement document for three years. Importers receivi ng waste from other OECD countries must already comply with this requirement. Si milarly, importers receiving waste from

Canada can use the Canadian movement doc ument they are already required to send to the Canadian exporter under Canadian regula tions to fulfill this requirement, so the expected net burden will be sending copies to EPA and to Environment Canada. Importers receiving shipments from Mexico and non-OECD countri es will experience the full impact of this change, as they currently do not send copies of such a movement document to anyone.

(8) U.S. receiving facilities must prepa re and send a confirmation of recovery or disposal to EPA, the exporter, and th e relevant authority in the country of export for each shipment received.

Importers receiving shipments from OECD countries are already subject to this requirement under existing U.S. regulations , and will therefore not experience a change in burden as a result of the proposed rule. U.S. importers receiving shipments from Canada are already required to prep are and send a confirmation to the foreign exporter, and therefore w ill only incur costs to send confirmations to EPA and Environment Canada. U.S. importers r eceiving shipments from Mexico and nonOECD countries will experience the full im pact of this change as they are not currently required to send c onfirmations of recovery or disposal to anyone.

(9) U.S. exporters must maintain a co py of the movement document and the confirmation of recovery or disposal from the foreign importing facility for three

years.

Exporters to OECD countrie s are already subject to th is requirement under existing regulations, and will therefore not experience a change in burden as a result of the proposed rule. Exporters to Canada, Me xico, and non-OECD countries will be affected by this change.

(10) Return of wastes.5 When a manifested shipment of hazardous waste cannot be completed, the primary exporter must (1) instruct the transporter to either return the shipment to the exporter or to an alternative facility in the United States, and (2) submit an exception report to EPA. The proposed rule does not change any of these requirements with the exception of allowing the alternate facility to be in the country of import if allowed by the country of import, specifying that the instructions to the transporter be made via mail, e-mail, or fax (so that a record of the instructions exist), and requiring that the shipments be returned within 90 days of receiving notification from the country of import or transit.

(11) Transnational shipments with Canada, Mexico, and non-OCED countries that are exempt from export and import requirements as wastes destined for laboratory analysis are subject to additional weight limits.

Under existing regulations in 40 CFR Pa rt 261, domestic shipments of hazardous waste sent for laboratory analysis are exem pt from hazardous waste requirements if they fall within certain weight limits. Ex isting weight limits for exempted waste shipments range from 1kg for acute hazardous waste to 10,000kg of media

contaminated with non-acute hazardous wa ste. Exporters and importers shipping hazardous waste samples for laboratory anal ysis to and from OECD countries are already subject to the additional limitation that the samples weigh no more than 25kg to be exempt from Subpart H export and import requirements (e.g., notice, movement document). The proposed rule makes exporters and importers shipping samples for laboratory analysis to and from Canada, Mexico, and non-OECD countries subject to the additional limitation of samples weighing no more than 25kg to be exempt from export and import requirements. As a re sult, currently-exempt shipments may no longer be exempt. EPA is requesting comment on the number of currently exempt shipments that will be impacted by this change.

(12) Transporter manifesting requirements.

Exporters shipping wastes to any country subject to RCRA manifesting requirements will no longer be required to provide an extra copy of the manifest to the transporter, and the transporter will no longer be required to give that copy to the Customs officer at the port of exit at time of departure. This change will affect all export shipments currently subject to Subpart E or H. Th is paper submittal requirement is being dropped because it will be duplicative to CBP’s Automated Export System (AES) filing and information provided in the eventual submittal of the OECD movement document by the foreign receivi ng facility to confirm receipt.

B. Changes to 40 CFR Part 262, Subpart H

(1) Exporters will no longer be required to submit a copy of EPA’s Acknowledgment of Consent to transporters.

Under existing regulations in Subpart E, exporters shipping to Canada, Mexico, and non-OECD countries must pr ovide a copy of EPA’s Acknowledgment of Consent to6 the transporter for each hazardous waste ship ment. The proposed rule eliminates this requirement. Exports to OECD countries ot her than Canada and Mexico will not be impacted by this change.7 (2) Obtain EPA Identification Numbers

The proposed rule will require all recognized traders involved in the arrangement of transportation of hazardous waste to obtain an EPA ID number. 5 EPA assumes that one percent of all exporters and importe rs are recognized traders, and request comment on the accuracy of this assumption.

(3) Exporters and importers must comply with electronic reporting requirements using EPA’s hazardous waste import/export database.

The proposed rule establishes requirements for electronic reporting for exporters and importers of hazardous waste and exempted waste in part 261 subject to export conditions (i.e., cathode ray t ubes (CRTs) being exported fo r recycling). Many of the activities required for these entities will be determined by instructions associated with EPA’s electronic document receiving system. Under the proposed rule, EPA plans to employ the already developed agency-wid e receiving system, the Central Data Exchange (CDX), for the electronic submittal of required forms. The electronic system guides users through the registra tion and reporting procedures. Electronic submittal is required for all exporters and importers; however, a waiver is available for companies that meet certain conditions specified by EPA (i.e ., lack of access to

broadband internet or other uni que circumstances). Each in dividual entity required to submit documents electronically will need to register to use the system. The proposed rule will require electronic submittal of export notices, import notices (where the shipment is not considered hazardous in the country of export), confirmation of receipt for import manifests, confirma tion of recovery/disposal, movement documents, exception reports, annual reports, and notification for return of wastes. Each submittal will require that the e xporter or importer sign each document electronically.

(4) Exporters must file additional EPA da ta elements as part of their AES filing requirements under 15 CFR 30.4 (this requirement is also being added to the CRT export requirements in 40 CFR 261.39(a)(5)).

Under existing U.S. Census Bureau regulat ions, exporters of waste subject to RCRA consent requirements must enter shipment data into the U.S. Census Bureau’s AES for each shipment. Under the proposed rule, exporters will be required in Subpart H

to fill in two additional fields for the export license and EPA consent number, and conditionally required to fill in three addi tional fields related to the RCRA hazardous waste manifest tracking numb er, exported quantity, and repor ting units if the existing AES-required reporting is not in units of weight (kg) or volume (L). It is unknown what percentage of the filings are expected to require the conditional data fields, so EPA is requesting comment from exporters on what export shipments of waste are not required to report in units of weight or volume in AES.

5 A recognized trader is a person domiciled in the United States , who acts to arrange and facilitate transboundary movements of wastes destined

for recovery or disposal operations, either by purchasing from and subsequently selling to U.S. and foreign facilities, or by a cting under

arrangements with a U.S. waste facility to a rrange for the export or import of the wastes.8 This provision would also set new requi rements for CRTs exported for recycling

under 40 CFR 261.39. EPA estimates that these exporters are already filing in AES for all shipments under current U.S. Census Bureau regulations. This change would require the filing of two to five additiona l fields in AES, as would filings for hazardous waste export shipments subj ect to Part 262 export requirements.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

The requirements covered in this ICR are nece ssary for EPA to oversee the international trade of hazardous wastes. EPA is promulga ting the above regulatory changes/amendments under the authority of Sections 1006, 1007, 2002(a), 3001-3010, 3013-3015, and 3017 of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA), and as amended by the Hazardous and Solid Waste Amendments, 42 U.S.C. 6905, 6906, 6912, 6921-6930, 6934, and 6938.

2(b) Practical Utility and Users of the Data

The Office of Enforcement and Compliance Assurance, U.S. EPA, uses the information provided by each U.S. exporter, receiving facil ity, transporter, and r ecognized trader to determine compliance with th e applicable RCRA regulatory provisions. In addition, the information is used to determine the number, or igin, destination, and type of exports from and imports to the U.S. for tracking purposes and for reporting to the OECD. This information also is used to assess the efficiency of the program.

3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

Most of the information required by the regula tions covered by this ICR is not available from any source but the respondents. In certain o ccasions, such as the notification of intent to export hazardous waste, EPA allows the primar y exporter to submit one notice that covers activities over a peri od of twelve months.

Except as described below, the proposed rule does not result in the collection of duplicate data. Although some of the information require d for the hazardous waste manifest and the movement document is substantively the same, up to six pieces of additional information are required for the movement document. In addition, these two documents serve different purposes. A signed copy of the hazardous waste manifest, which is not valid beyond U.S. borders, is dropped off at the U.S. Customs check point when the shipment leaves the U.S. to verify pertinent information, including po int of departure, date, dest ination, and contents of the shipment. The movement document must accompa ny the shipment until it reaches the foreign recovery facility. The signed movement document is subsequently returned to EPA and the U.S. exporter to acknowledge r eceipt of the shipment.9 In certain cases, some of the information on the tracking document also may be collected by the Department of Commerce in its Census Bu reau form titled "Shipper's Export Declaration" (15 CFR Part 30). This form, which is required fo r all shipments that have a value in excess of $2,500, must be filed at the U.S. port of exit, similar to the current export requirements. However, the information contained in the Cens us Bureau's form is not adequate for EPA's purpose of tracking and identifying the export of hazardous waste from the U.S. For example, the wastes are identified by tariff codes that are le ss precise than the waste codes required by the tracking document.

3(b) Public Notice

In compliance with the Paperwork Re duction Act of 1995, EPA will open a 60-day public comment period at the time that this Propos ed Rule is published in the Federal Register. To assist the public in commenting on the proposal , EPA has raised a number of issues in the preamble to the Proposed Rule and asked for the public to comment on them. At the end of the comment period, EPA will review public comments received in response to the notice and will address comments received, as appropriate.

3(c) Consultations

EPA consulted with U.S. Customs and Border Protection and U.S. Census Bureau on the AES filing requirements. EPA did not consult with any other organizations in the development

of this ICR.

3(d) Effects of Less Frequent Collection

EPA has carefully considered the burden imposed upon the regulated community by the hazardous waste export-import revisions. EPA is confident that the act ivities required of respondents are necessary, and to the extent po ssible, has attempted to minimize the burden imposed. EPA believes strongly that if th e minimum requirements specified under the regulations are not met, EPA cannot ensure that hazardous wastes are properly managed and do not pose a serious threat to human health and the environment.

3(e) General Guidelines

This ICR adheres to the guidelines stat ed in the Paperwork Reduction Act of 1995, OMB’s implementing regulations, OMB’s Inform ation Collection Review Handbook, and other applicable OMB guidance.

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. However, the Agency does not anticipate that businesses will a ssert a claim of confiden tiality covering all or part of the proposed rule. If such a claim were asserted, EPA must and will treat the information in accordance with the regulations cited above. EPA also will assure that this information collection complies with the Privac y Act of 1974 and OMB Circular 108.10 3(g) Sensitive Questions

No questions of a sensitive nature are includ ed in the information collection requirements associated with the proposed rule.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The revisions to the hazardous waste expor t and import requirements under the proposed rule affect all recycling and di sposal facilities who receive imports of hazardous waste and all persons who export or import (or arrange for th e export or import) of hazardous waste being shipped for either recycling or disposal, SLAB s being shipped for reclamation, industrial ethyl alcohol being shipped for reclamation, and hazar dous recyclable materials being shipped for precious metal recovery, and hazardous waste samp les of more than 25 kilograms being shipped

for waste characterization or trea tability studies. Potentially a ffected industries may include, but are not limited to the following:

NAICS Industry Sector

211 Oil and Gas Extraction

212 Mining (except Oil and Gas)

213 Support Activities for Mining

311 Food Manufacturing

324 Petroleum and Coal Products Manufacturing

325 Chemical Manufacturing

326 Plastics and Rubber Products Manufacturing

327 Nonmetallic Mineral Product Manufacturing

331 Primary Metal Manufacturing

332 Fabricated Metal Product Manufacturing

333 Machinery Manufacturing

334 Computer and Electr onic Product Manufacturing

335 Electrical Equipment, Applianc e, and Component Manufacturing

336 Transportation Equipment Manufacturing

339 Miscellaneous Manufacturing

423 Merchant Wholesalers, Durable Goods

424 Merchant Wholesaler s, Nondurable Goods

441 Motor Vehicle and Parts Dealers

482 Rail transportation

483 Water transportation

484 Truck transportation

488 Support Activities for Transportation11 NAICS Industry Sector

531 Real Estate

541 Professional, Scientific , and Technical Services

561 Administrative and Support Services

562 Waste Management and Remediation Services

721 Accommodation

924 Administration of Enviro nmental Quality Programs

This list of potentially affected entities ma y not be exhaustive. The Agency’s aim is to provide a guide for readers regard ing those entities that potentia lly could be affected by this action. However, this action may affect othe r entities not listed in these tables.

4(b) Information Requested

This section describes the information collecti on requirements applicable to entities that would be affected by the Proposed Hazardous Waste Export-Import Revisions Rule.

CDX Registration

(i) Data Items:

The proposed rule establishes requirements for electronic reporting for exporters and importers of hazardous waste. Many of the activities required for these entities will be determined by instructions associated with EP A’s electronic document receiving system. Under the proposed rule, EPA plans to develop enhanc ements to the Waste Import Export Tracking System (WIETS) to receive these submittals, lik ely using the Agency-wide CDX system, which

will facilitate the elect ronic submittal of required documents. WIETS guides users through the registration and reporting procedures. Electronic submittal is required for all exporters and importers, with the exception of companies that meet certain conditions specified by EPA. Each entity required to submit documents electronically will need to register to use the system. To the extent that CROMERR applies, each submittal will require that the exporter or importer provide an electronic signature.

Under the proposed rule, EPA estimates that any staff involved in the reporting of export/import notices, annua l reports, or other required documen ts would have to register using the electronic receiving system. If identity proofing fails, registrants are routed to an “electronic signature agreement” form that is complete d on the computer, printed out, signed, and then mailed to EPA. In addition, EPA estimates that 10 percent of users will have to update their information each year. EPA also estimates that 10 percent of users will have to register as new users due to employee turnover and 1 percent of users will have to re-register due to compromised signatures each year.12 (ii) Respondent Activities:

All users will need to register using EPA’ s electronic receiving system and update their information when necessary. EPA estimates that im porters will have an average of 4.7 users and exporters will have an average of 5 users. 6 If identity proofing fails, the user will need to print and complete a document, si gn it, and mail it to EPA.

Notification

(i) Data Items:

Under the proposed §262.83(b), exporters sendi ng hazardous waste to Canada, Mexico, and non-OECD countries will be required to su bmit additional information with each notice.

This additional informational includes an e-mail address and fax number for each listed party on the notice, all anticipated ports of exit, all anticip ated transporters for the shipments, any interim facilities to be used during the transfer of waste, and the OECD waste codes and recycling or disposal operation codes for all waste streams to be shipped.

Exporters to Canada will not experience an additional burden from listing transporters and interim facilities, as these data elements are already required by Canadian regulations. Exporters to other OECD countries are alrea dy required to submit this information, and will therefore experience no change in their cost burden as a result of the proposed rule.

Once the electronic system becomes fully ope rational, exporters will have the option to use the duplication feature in WIETS (in which data field information is copied from the previous notice), which will reduce this estimated burden for entities that submit identical notices (with the exception of the first and last shipment date fields) from year to year. EPA estimates that 60 percent of exporters will be able to take advantage of this duplic ation feature and incur no additional burden for providing supplemental info rmation in WIETS starting in the second year

after electronic submittal is form ally mandated. The remaining 40 percent of exporters will have

to enter this information for each new export notice.

The proposed rule would require receiving f acilities in the U.S. importing waste from maquiladoras in Mexico to submit import notices on be half of these foreign exporters for any waste shipments not controlled as hazardous waste exports by Me xican authorities.

The proposed rule also requires electronic s ubmittal of notices using WIETS. To the extent that CROMERR applies, this would re quire exporters and importers to provide an electronic signature with each notice.

The proposed rule will eliminate the existi ng §264.12(a)(1) requireme nt that importers notify a regional administrator four weeks prior to receiving a sh ipment of hazardous waste for

the first time. This will result in a cost savings for U.S. importers.

6 EPA estimates that large firms will have 6 employees and small firms will have 3 empl oyees register to use the EPA’s electroni c receiving system.

The estimates of 4.7 and 5 users per entity are based on the distribution of large an d small firms among potentially affected i mporters and

exporters based on data collected from Dun & Bradstreet (D&B).13 (ii) Respondent Activities:

Exporters must prepare and submit an export no tice at least 60 days before the initial shipment is intended to be shipped off site. This notice may cover export activities extending over a 12 month period. If CROMMER applies, they must also electronically sign the notice.

Importers must prepare and submit a notice on behalf on the foreign exporter for shipments from maquiladoras in Mexico that are not controll ed as hazardous waste exports by the foreign authority. The notice must contain de tailed information regard ing the exporter, waste details, transporters, means of transport and co ntainers to be used, all points of entry and departure for each foreign country of transit, receiving facility information, and ultimate management method, and may cover shipments over a 12-month period. If CROMERR applies, importers must also elect ronically sign the notice.

One-time notices identifying the name, addre ss, and contact information for a U.S. receiving facility and every new waste stream they intend to import ar e no longer required.

Re-notification

(i) Data Items:

Under the proposed §262.83(b), as under th e existing §262.53(c), when the conditions specified under the original notification change, the U.S. exporter must provide EPA with a renotification of the change. The proposed rule requires electronic submittal of all re-notifications sent to EPA. This will require e ach exporter to provide an electr onic signature for certain data

elements on each notice submitted.

Also, under the proposed §262.83(e) and (f) where a single shipment cannot be delivered or is rejected for any reason, the transporter or receiving facility must notify the exporter, EPA and the country of import or tran sit of the situation. Then, alte rnate management must be found in the country of import that is acceptable to th e country of import, or the shipment must be returned to the United States; and finally, th e exporter must submit an exception report.

(ii) Respondent Activities:

U.S. exporters must prepare and submit a re-not ification to EPA if they wish to change the terms of the original notice. U.S. exports must submit an exception report if the shipment

cannot be delivered. To the extent that CRO MERR applies, the e xporter must sign these documents electronically.14 Annual Reports

(i) Data Items:

Under the proposed §262.83(g), as under th e existing §262.87(a), LQG exporters must list OECD waste codes for all shipments in addi tion to RCRA waste codes as part of each annual report. The proposed rule will also require electroni c submittal of all annual reports of exports of hazardous waste and CRTs for recycling. This will require each annual report to be signed electronically.

(ii) Respondent Activities:

U.S. exporters must enter OECD waste c odes into each annual report. Exporters must also electronically si gn each annual report.

Additional Reports

(i) Data Items:

Under the proposed §262.83(b)(8), as under th e existing §262.53(d) and §262.83(d)(14), upon request by EPA, an exporter must continue to submit to EPA any additional information which a country of import requests in order to respond to a notificati on. The proposed rule will not change this requirement or the manner through which such information is submitted to EPA.

(ii) Respondent Activities:

U.S. exporters must prepare and submit additional information to EPA upon request. This

is the same as in the baseline.

Contracts

(i) Data Items:

Under the proposed rule, contracts must be si gned between exporters of hazardous waste and receiving facilities specifying the parties rele vant to each shipment and the various legal responsibilities of each party i nvolved. Currently, there are no requirements for contracts in the U.S. under 40 CFR Part 262 Subpart E. However, Canadian regulations require that such

contracts be maintained. EPA therefore assumes that shipments to Canada will not experience any additional burden as a result of this provision. EPA assumes that other entities involved in the foreign trade of hazardous waste currently sign similar co ntracts that would satisfy the proposed requirements, and therefore estimate s no additional incremental burden for these shipments.15 (ii) Respondent Activities:

None.

Acknowledgement of Consent

(i) Data Items:

Under the existing §262.52(c) a nd §266.80(a), exporters are requi red to provide a copy of the EPA Acknowledgment of Consent for each ship ment to the transporter transporting the shipment for export. The proposed rule eliminates this requirement. Thus, this would result in a cost savings for U.S. exporters.

(ii) Respondent Activities:

U.S. exporters no longer need to provide a copy of the EPA Acknowledgment of Consent to the transporter.

Exception Reports

(i) Data Items:

Whereas exception reports fo r Subpart E are currently based on the RCRA manifest, under the proposed §262.83(h), exception reports w ill be based on either RCRA manifests or OECD movement documents for shipments to Canada, Mexico and non-OECD countries. The proposed rule also requires exception reports to be submitted electronically to EPA. To the extent that CROMERR applies, this will re quire that each exception report be signed electronically.

(ii) Respondent Activities:

U.S. exporters must prepare and submit the required exception re port if any of the conditions listed in §262.83(h) occurs.

Movement/Tracking Document

(i) Data Items:

Under the proposed §262.83(d), each time a U. S. exporter ships hazardous waste to a foreign country – including Canada, Mexico, and non-OECD countries – the exporter is required to complete and submit to the carrier a move ment/tracking document. The movement document must include a signed certificat ion, as well as all informati on required for notification. For shipments to and from Canada, exporters may use the existing Canadian movement document to fulfill this requirement. U.S. exporters must main tain copies of the movement documents they receive from foreign receiving facilitie s to confirm receipt for three years.16 Under the proposed rule, U.S. receiving fac ilities must send a copy of the signed OECD movement document to EPA electronically, to th e foreign exporter of the waste, and to the

relevant authorities of the e xporting country and any transit c ountries within three days of receiving a shipment of hazardous waste. Importe rs must also maintain a signed copy of the movement document for three years. Importers re ceiving waste from other OECD countries must already comply with this requirement and will expe rience no increase in cost as a result of this provision. Similarly, importers receiving waste fro m Canada can use the Canadian movement document to fulfill this requirement and will experience no additional cost burden to complete the document, but will incur costs to send a copy to EPA and Environment Canada. To the extent CROMERR applies, U.S. importers must subm it copies of the movement document to EPA electronically with an electronic signature.

(ii) Respondent Activities:

U.S. exporters shipping hazardous waste to Mexico and non-OECD countries must complete and submit a movement/tracking document to the carrier, and maintain copies of the movement document they receive to confirm receipt from the forei gn receiving facility for three years. U.S. importers must send a copy of the signed OECD movement document to EPA electronically, to the foreign e xporter of the waste, and to th e relevant authorities of the exporting country within three days of receiving a shipment of hazardous waste. To the extent CROMERR applies, electronic submittal of the copies must be done with an electronic signature. U.S. importers from Mexico and non-OECD count ries must also maintain a signed copy of the movement document for three years.

Confirmation of Recovery or Disposal

(i) Data Items:

Under the existing §262.83(e), a ll U.S. recovery facilities mu st provide a confirmation of recovery or disposal to the expor ter and send copies to the compet ent authorities of the countries of export and import. The confirma tion of recovery must be provi ded as soon as possible, but no later than 30 days after the co mpletion of recovery and no later than one calendar year following receipt of waste. U.S. importers receiving shipme nts from Canada are alre ady required to prepare and send a confirmation of recovery or dispos al to the foreign exporter under Canadian regulations, and therefore only incur costs to send copies of this document to EPA and Environment Canada. Furthermore, under the proposed §262.83(f)(5) EPA will require export contract terms that specify foreign recei ving facilities sending confirmations of recycling/disposal that will allow use of the Cana dian confirmation of recy cling or disposal, and under the proposed §262.84(g) U.S. importers will be required to provide a confirmation of recovery/disposal and will be able to use the Canadian confirmati on of recycling/disposal to use one document to list multiple shipments identified by their movement document number, waste line number, and the date of recycling or dis posal. The proposed rule will require that U.S. importers submit copies of the c onfirmation of recovery or dispos al to EPA electronically, and to the extent CROMERR applies, will need to include an electronic signature.17 U.S. exporters must also maintain a copy of the confirmation of recovery/disposal from the foreign importing facility for th ree years. U.S. importers will al so need to maintain a copy of the confirmation of recovery/disposal for three years. While exporters and importers exchanging

waste with OECD countries ot her than Canada and Mexico are already subject to this requirement under existing regulatio ns, exporters and importers involved in the foreign trade of hazardous waste with Mexico, Canada, and non-OECD countries will experience an increase in

cost burden as a result of these addi tional recordkeeping requirements.

(ii) Respondent Activities:

U.S. importers must provide a confirmation of recovery to the exporter, EPA, and the competent authority of the country of export. Copies must be submitted to EPA electronically, and to the extent CROMERR applies, will need to include an electronic signature. U.S. exporters

must receive and maintain the confirmation of recovery/disposal provided by the recovery facility for three years, and U.S. importers must maintain a copy of the confirmation of recovery/disposal for three years.

Return of Wastes

(i) Data Items:

Under the existing §262.54(g), when a manifested shipment of hazardous waste cannot be completed, the primary exporter must (1) instruct th e transporter to either return the shipment to the exporter or to an alternative facility in th e United States, and (2) submit an exception report to EPA. The proposed rule does not change any of these requirements with the exception of allowing the alternate facility to be in the count ry of import if allowed by the country of import, specifying that the instructions to the transporte r be made via mail, e-mail, or fax (so that a

record of the instructions exists ), and requiring that the shipments be returned within 90 days of receiving notification from the c ountry of import or transit.

(ii) Respondent Activities:

U.S. exporters must instruct th e transporter to either return the shipment to the exporter or

to an alternative facili ty in the country of import (if allowed by the country of import) or the

United States.

Exemption of Wastes Destined for Laboratory Analysis

(i) Data Items:

Under the existing §262.82(g), import and expo rt shipments of RCRA hazardous wastes

with OECD countries other than Canada a nd Mexico are exempt from the Subpart H requirements if they are explicitly destin ed for laboratory anal ysis to assess their physical/chemical characteristics or to determine their suitability for recovery operations and no more than 25kg. Under existing regulations in 40 CFR Part 261, domestic shipments of18 hazardous waste sent for laboratory analysis ar e exempt from hazardous waste requirements if they fall within certain weight limits. Existing we ight limits for exempted waste shipments range from 1kg for acute hazardous waste to 10,000kg of media contaminated with non-acute hazardous waste. The proposed rule makes exporters and importers shipping samples for laboratory analysis to and from Canada, Me xico, and non-OECD count ries subject to the additional limitation of samples weighing no mo re than 25kg to be exempt from export and import requirements. As a result, currently-exe mpt shipments may no longer be exempt. EPA estimates that four previously-exempted ship ments (two export shipments and two import shipments) will no longer be exempted each year after the implementation of the proposed rule. EPA is requesting comment on the number of current ly exempt shipments that will be impacted by this change.

(ii) Respondent Activities:

U.S. exporters shipping samples less than the domestic limits in 40 CFR Part 261 but greater than 25kg for laboratory analysis to Ca nada, Mexico, or a non-OECD country will now need to comply with the subpart H require ments, including submitting an export notice, obtaining an AOC, filing the additional items in AES to validate consent for the sample shipment, completing and signing a moveme nt/tracking document, and receiving and maintaining a confirmation of rec overy. Transporters of these samp les will need to comply with hazardous waste manifest and movement document requirements to obtain, sign, and maintain a copy of the RCRA manifest a nd obtain and sign the movemen t/tracking document. U.S. importers receiving samples less than the domestic limits in 40 CFR Part 261 but greater than 25kg for laboratory analysis from Canada, Mexic o, or a non-OECD country will now need to comply with the subpart H requirements, in cluding signing the RCRA manifest and submitting the RCRA manifest to EPA, signing the moveme nt/tracking document and providing a copy to the exporter, EPA, and competent authority of the country of export to confirm receipt, and sending a confirmation of recovery to the exporter, EPA, and foreign authority.

EPA ID

(i) Data Items:

The proposed rule will require all recognized traders involved in the arrangement of transportation of hazardous waste to obtain an EP A ID number. EPA assumes that one percent of all importers and exporters are recognized traders, or about four entities, and will be impacted by the proposed rule. EPA also assumes the numbe r of recognized traders is split equally among exporters and importers.

(ii) Respondent Activities:

Recognized traders of hazardous waste must obtain an EPA ID number from their

authorized state or from EPA.19 AES Requirements

(i) Data Items:

Under the proposed rule in subpart H, exporte rs will be required to fill in between two and five additional fields to validate consent as part of their existing filing in CBP’s AES. The proposed rule would also add the same filing requirements for CRTs exported for recycling

under 40 CFR 261.39.

(ii) Respondent Activities:

Exporters of CRTs for recycling and hazardous waste for recycling or disposal must file

between two and five additional fields to valida te consent as part of their existing AES filing.

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

5(a) Agency Activities

WIETS Development

To implement the proposed rule, the most significant cost for EPA will be the development and maintenance of the electronic submittal system. These costs are uncertain; therefore this ICR presents Agency costs as a range. Any costs of the CDX system are not

described in this ICR because it exists now, woul d still exist absent the rule, and was developed

to facilitate electronic submittal of data between EPA data systems and other entities such as the regulated community and other governments. However, EPA estimates that the initial development of enhancements to WIETS to fac ilitate electronic submittal of export and import reports (specifically rela ted to the propose rule) w ill cost between $188,750 and $311,250. 7 EPA also estimates that it will require between approximately 700 and 1,170 labor hours for staff technicians to implement the system at a cost ranging from $39,076 to $65,127. 8 This ICR assumes that the development costs are entirely incurred in the first year of the rule’s promulgation and the system will have a useful lifespan of 20 years. EPA further estimates that the recurring O&M costs for the enhancem ents to WIETS will be between $96,750 and $161,250 per year after its development. Finally, EPA estimates that it will require between approximately 1,500 and 2,500 hours to manage the enhancements to WIETS after their implementation at a cost ranging from $83,015 to $138,359 per year.

Since the electronic submittal system w ill provide technical guidance and tracking information to users, EPA estimates it will no lo nger have to respond to e xporter inquiries related to the submittal of export notices. EPA estimat es that such inquiries require 1,000 hours of

7 EPA cost estimates for the development and operation & maintenance of the electronic system are derived from the Excel Workboo k “EPA FTEs

and Costs for import-export rule RANGES Jan 8 2015.docx” provided by Phuc Phan of EPA’s Office of Resource Conservation and Rec overy on

January 15, 2015.

8 EPA labor costs are estimated using the loaded hourly labor rate s described in Chapter 3 of the Economic Assessment for the pr oposed rule.20 Agency staff time each year. Furthermore, elect ronic submittal will reduce the Agency burden associated with manual entry of export noti ces. EPA receives approximately 1,684 notices per year and requires one hour to manually enter information from each e xport notice into WIETS. Therefore, Agency staff will experience a co st savings of 1,000 hours per year for avoided inquiries and 1,684 hours per year for avoided data entry. EPA also estima tes that electronic

submittal will eliminate the need for staff to manually enter information from export annual reports into WIETS. EPA receives approximately 378 export annual reports each year and takes about four hours to receive and process reports in to a database. Therefore, EPA estimates that Agency staff will also experience a cost savings of 1,512 hours for avoided data entry associated with export annual reports.

Movement/Tracking Document

Under the proposed §262.83 and §262.84, exporters and importers that trade with Canada, Mexico, and non-OECD countries will have to comply with movement document requirements. As discussed above, exporters and im porters that trade with other OECD countries are already required to submit signed movement documents to EPA. EPA will need to receive and record movement documents from importin g countries for U.S. exports and receiving facilities for U.S. imports.

Confirmation of Recovery or Disposal

EPA will need to review and maintain a confirmation of recovery or disposal for hazardous waste shipments between the United States and Canada, Mexico, and non-OECD

countries.

EPA ID

For recognized traders not locate d in authorized states that issue EPA ID numbers, EPA

will need to review letters from recognized traders of hazardous waste requesting EPA identification numbers, enter this information in to a database, generate an EPA ID number, and send it to each requestin g recognized trader.

5(b) Collection Methodology and Management

The collection and management of the information submitted to EPA is stored by EPA in

file cabinets and/or elec tronically to be compiled in an annua l status report. In addition, the information is collected and stored for possibl e future use in enforcement actions. EPA uses electronic equipment such as personal comput ers and applicable database software, when appropriate.

5(c) Small Entity Flexibility

Some respondents will be small or ganizations. In certain cases, they will be able to obtain waivers to avoid reporting require ments associated with electroni c submission of documents to EPA. Small entities may also incur fewer costs be cause they can complete the recordkeeping and reporting requirements in less time than large organizations because they export or import21 smaller quantities of hazardous waste. However, the size of the organization does not always reflect the amount of time needed to complete documents, submit reports, or maintain records.

EPA believes that the information to be collected is the minimum amount necessary to fulfill the purpose of the proposed rule. Furthermore, the de cision to export or im port hazardous waste is voluntary. Thus, no business, small or otherwise, is required to export or import its hazardous waste. Therefore, there is no mandatory burde n on the regulated comm unity, including small

businesses.

5(d) Collection Schedule

Under the proposed rule, export/import notifi cations, exception reports, documentation of EPA’s consent to import, confirmations of rec overy/disposal, and shipment tracking documents are generated and sent to EPA on an occurrence-specific basis for which there is no formalized

schedule. The submission of information under this collection is initiated by the respondents. U.S. exporters must file with EPA a detailed an nual report on hazardous waste exports, including a signed certification, by March 1 st of each year.

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) Estimating Respondent Burden

EPA assessed the potential cost impact s of the proposed rule, including:

 Submittal of notices to EPA on behalf of fo reign exporters by U.S. importers (for

RCRA hazardous wastes not controlled as hazardous waste exports by the country of export).

 Submittal of additional information with each export notice.

 Listing of OECD waste codes for all sh ipments in each export annual report of

hazardous wastes.

 Development of contracts between U.S. exporters of hazardous waste and foreign receiving facilities, and be tween U.S. importers of hazardous waste and foreign

exporters.

 Removal of the requirement for expo rters to provide a copy of EPA’s Acknowledgment of Consent to tran sporters for each shipment.

 Movement document creation for exporters of hazardous waste.

 Transporters signing movement documen ts for import and export shipments.

 U.S. receiving facilities’ signing and distribution of the OECD movement document to EPA, the generator of the wast e, and the relevant authorities of the exporting country.

 U.S. receiving facilities’ preparation and sh ipment of the confirmation of recovery or disposal to EPA, the exporter, and th e relevant authority in the country of origin for each shipment received.

 U.S. exporters’ maintenance of a copy of th e confirmation of recovery or disposal from the foreign importing facility.22  The return of hazardous waste shipments to U.S. exporting facilities or alternate facilities in the country of import (if a llowed by the country of import) or the

United States.

 The exemption of various wastes destined for laboratory analysis from hazardous waste requirements when shipme nts contain no more than 25kg.

 The obtaining of EPA identification nu mbers by recognized traders of hazardous

waste.

 Requirements for exporters of hazardous waste for recycling/disposal and CRTs for recycling to enter new data elements into the existing AES.

 CDX registration.

6(b) Estimating Respondent Costs

Labor Costs

For purposes of this analysis, this ICR estimat es an average hourly respondent labor cost (including fringe benefits and overhead cost s) of $139.53 for managerial staff, $67.40 for technical staff, and $36.05 for cl erical staff. These hourly labo r costs were obtained from the following source:

 Hourly Wage: Bureau of Labor Statistic s, occupational earnings data for May

2013. 9,10

Annual Capital and Operation & Maintenance (O&M) Costs

Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, a nd other equipment. O&M costs are those costs associated with paperwork requirements incurred continually over the life of the ICR. They are defined by the EPA as “the recurring dollar amount of costs associated with O&M or purchasing

services.”

O&M costs are those costs associated with materials and services procured for the information collection requirements included in th is ICR. For this ICR, O&M costs include the following: (1) postage to mail a five-ounce package by certified mail ($2.09 for postage, $3.30 for the certified-mail fee, and $0.16 for a 9 x 12 ma nila envelope = $5.55); (2) postage to mail a standard domestic letter ($0.49 for first class postage and $0.03 for a standard envelope = $0.52); (3) postage for a standard international lette r ($1.15 for first-class postage and $0.03 for a standard envelope = $1.18); (4 ) photocopying ($0.11 per page); and (5) fax services ($0.12 per page).

6(c) Estimating Agency Burden and Costs

9 Bureau of Labor Statistics, Nati onal Occupational Employment and Wa ge Estimates, May 2013, accessed at

http://www.bls.gov/oe s/current/oes_nat.htm on April 24, 2014.

10

To estimate average annua l labor costs, EPA relies on nation al average wage data reported by the U.S. Bureau of Labor Statisti cs for a full time

employee working 40 hours a week multiplied by a loaded wage rate of 150 percent, which represents average private industry fri nge benefits

(e.g. paid time off, health be nefits, retirement benefits, other legally required benefits, and payroll ta xes) and overhead rat es (e.g. general and

administrative, fixed overhead, insurance, and profit).23 For Agency burden and costs, EPA estimates an average hourly labor rate of $65.58 for managerial staff (GS-14, Step 1), $55.50 for technical staff (GS-13, Step 1), and $21.25 for clerical staff (GS-5, Step 1). 11 To derive these hourly es timates, EPA referred to the General Schedule (GS) Salary Table 2014 . This publication summarizes the unloaded (base) hourly rate for various labor categories in the Federal gov ernment. EPA applied the standard government

overhead factor of 1.6 to the unloaded rate to derive loaded hourly labor rates.

6(d) Estimating the Respondent Universe and Total Burden and Costs

In this section, EPA first describes th e respondent universe affected by the new information collection requirements resulting fr om the final action. EPA then estimates the annual aggregate burden to respondents under the proposed ru le and existing RCRA information collection requirements. The universe estimates and assumptions used in the development of this ICR are based on the economic assessment developed for this rulemaking: “Assessment of the Potential Costs, Benefits, and Other Impacts of the Hazardous Waste Export-Import Revisions Rule” (hereinafter referred to as the Cost Assessment document fo r the proposed rule), which is

available in the docket for the rule.

(1) Respondent Universe

In Exhibits 1 and 2 below, EPA provides es timates of the annual number of importers and exporters (and export and import shipments) that will be subject to the paperwork requirements in the proposed rule.

11 See Chapter 3 of the Economic Assessment for the proposed rule.24 Exhibit 1 Number of Importers and Shipments Potent ially Affected by the Proposed Rule

Country of Origin 1 Number of Affected Entities Average Number of Shipments per Year 7,8 U.S. Importers U.S. Transporters 6

Canada 2,3,4,5 35 35 69

Mexico 2,3,5 11 11 31

OECD Countries 2 2 31

Non-OECD Countries 3 3 37

Total 51 51 57

Notes:

1. Four importers received waste from two or more countries. Therefore, there are 45 unique importers, rather than 51 listed above. However, this exhibit parses out the importers that receive from more than one country into each of their respective origins to accurately reflect the average number of shipments sent to each importer. Depending on the context, the remainder of this analysis may similarly parse out importers that receive from more than one country separately to accurately estimate costs asso ciated with receiving from alternative destinations. That is, this assessment often uses the 51 count of importers and not the 45 unique importers.

2. While Canada and Mexico are OECD countr ies, under existing regulations there are different requirements for the foreign trade of hazardous waste with these countries compared with other OECD countries. Ther efore, EPA estimates impacts to importers (and exporters) separately for trade with Canada and Mexico versus other OECD

countries.

3. Two importers received shipment s from Canada and Mexico.

4. A single importer received shipments from England, Germany, and Canada.

5. A single importer received shipments from Malaysia, the Philippines, Canada, Mexico, and Japan.

6. EPA estimates that there is one U.S. transporter for each U.S. importer.

7. Average number of shipments based on EPA RCRA manifests for import shipments for 2011. This is not an average of the number of affected entities columns.

8. EPA estimates that two imported shipments per y ear are destined for laboratory analysis.25 Exhibit 2 Number of Exporters and Shipments Potentially Affected by the Proposed Rule

Destination Country 1 Number of Affected Entities Average Number of Shipments per Year 5,6 U.S. Exporters U.S. Transporters 4

Canada 2,3 326 326 79

Mexico 2,3 24 24 964

OECD Countries 31 31 80

Non-OECD Countries 2 2 13

Total 383 383 134

Notes:

1. Four exporters shipped waste to two or more countries. Therefore, there are 378 unique exporters, rather than 383 listed above. However, this exhibit parses out the exporters that ship to more than one country into each of thei r respective destinations to accurately reflect the average number of shipments sent to each destination. Depending on the context, the remainder of this analysis may similarly parse out exporters that ship to more than one country separately to accurately estimate cost s associated with ship ping to alternative destinations. In other words, this RIA sometimes uses the 383 count of exporters and not the 378 unique exporters where appropriate.

2. While Canada and Mexico are OECD countr ies, under existing regulations there are different requirements for the foreign trade of hazardous waste with these countries compared with other OECD countries. Therefor e, EPA estimates impact s to exporters (and importers) separately for trade with Canada and Mexico versus other OECD countries.

3. One exporter sent shipments to both Canada and Mexico.

4. EPA estimates that there is one U.S. transporter for each U.S. exporter.

5. Average number of shipments based on EPA Export Annual Reports for 2011. This is not an average of the number of affected entities columns.

6. EPA estimates that two exported shipments per year are destined for laboratory analysis.

(2) Annual Respondent Hour and Cost Burden under the Proposed rule

Annual respondent hour and cost burden estima tes are summarized below and itemized in

the exhibits at the end of this document.

(a) Reading the Regulations

EPA expects that all 378 exporters and 45 impo rters will need to familiarize themselves with the requirements of the proposed rule. 12 EPA assumes that reading and understanding the proposed rule will require one hour of a mana ger’s time and 2.5 hours of a technician’s time. 13

This is equivalent to an upf ront cost of $308.03 per facility.

12

For reporting purposes, EPA estimates that if an exporter ship s waste to both Canada and Mexi co, half of the costs are incurre d for shipments to

Canada and half are incurred for shipments to Mexico. Therefore, costs are proportionally distributed (by country) for entities that trade with

more than one country.

13

Page B-1 of the Cost Assessment for the Proposed Rule on Expo rts and Imports of Hazardous Wast e Destined for Recovery Among OE CD Countries,

Exports of Spent Lead-Acid Batteries from th e U.S., and Import Consent Documentation: O ffice of Resource Conservation and Recov ery, Office of

Solid Waste and Emergency Response, U.S. Environmental Protection Agency, May 2009.26 (b) CDX Registration

EPA assumes that exporters and importers will register to us e the CDX system starting in the first year of the rule’s pr omulgation. The average initial re gistration cost per entity is estimated to be $56.91 per exporter (assuming an average of 5 registra nts per exporter) and $53.50 per importer (assuming an average of 4.7 regi strants per importer), including the cost of printing, signing, and mailing an “electronic signat ure agreement” to EPA if the registrant fails the system’s identity-proofi ng requirements. The estimated recurring costs following the promulgation of the rule are $6.94 per exporter and $6.52 per importer, including the cost to register new users due to employ ee turnover and allow existing user s to update their information each year.

(c) Export and Import Notices

Notification cost burdens will vary under the proposed rule for exports to Canada, Mexico, non-OECD countries, and OE CD countries. During the firs t year of the proposed rule, additional data entry costs per U.S. expor ter will be as follows: $56.73 (Canada); $48.04 (Mexico); and $33.70 (non-OECD). In each subsequent year, U.S. exporters will experience the following average costs: $22.69 (Canada), $19.22 (Mexico), and $13.48 (non-OECD). U.S. exporters to all countries w ill incur a cost burden of $0.56 to electronically sign each notice submitted electronically. U.S. importers receiving shipments from Mexico will face incremental notification costs of $1,317.98 per no tice in the first year, and $534.54 in each subsequent year.

The removal of the one-time notification requir ement in the proposed rule will also result in cost savings of $37.48 for each affected U.S. importer. In addition, th e electronic submittal of import manifests to EPA will result in materials -related cost savings of $0.74 per shipment for all U.S. importers.

(d) Re-notification

Under the proposed rule, EPA estimates that 32 percent of export notices per year (approximately 290 in total) will require re-notif ication each year. The average costs per exporter for this activity are as follows: $0.46 (Can ada); $0.26 (Mexico); $0.18 (OECD); and $0.29 (nonOECD). Electronic submittal of re-notifications will result in materials-related cost savings for U.S. importers of $0.52 for each submission.

(e) Annual Reports

Annual reporting requirements under the proposed rule are estimated to result in annual costs per exporter of $0.56 per subm ission (one per year) to provide an electronic signature. In addition, the electronic submittal of annual reports w ill result in materials-related cost savings of $5.55 per notice for all U.S. exporters.27 (f) Additional Reports

EPA estimates no change in exporter burden related to requirements for additional

reports.

(g) Contracts

EPA assumes that other entities involved in the foreign trade of hazardous waste currently sign similar contract s that would satisfy the proposed requirements, and therefore

estimates no additional incrementa l burden for these shipments.

(h) Acknowledgment of Consent to Transporter

The proposed rule eliminates the requirement that exporters provide a copy of the EPA Acknowledgment of Consent to tran sporters. This generates the following per-entity savings for exporters: $725.01 (Canada); $8,896.28 (Mexico); and $120.02 (non-OECD).

(i) Exception Reports

This component of the proposed rule w ill burden exporters with the incremental requirement of an electronic signature for each submission, leading to a cost burden of $0.56 per affected exporter. Electronic submission of exce ption reports will also save U.S. exporters $0.52 in materials-related costs for each report submitted to EPA.

(j) International Movement/Tracking Document

U.S. exporters to Mexico and non-OECD count ries are estimated to incur incremental reporting costs of $52.28 per shipment, for a tota l per-entity cost of: $50,371.32 (Mexico) and $679.58 (non-OECD). U.S. imports from Canada, Mexico, and non-OECD countries will also face an incremental reporting burden, estimated on a per-entity basis to be: $120.17 (Canada), $2,251.39 (Mexico) and $2,671.47 (non-OECD). Elect ronic submission of the movement document by U.S. importers from OECD countries w ill result in materials-related cost savings of $0.52 per submission.

(k) Confirmation of Recovery or Disposal

U.S. exporters to Canada, Mexico, and non- OECD countries are estimated to incur incremental costs per shipment under this requi rement, yielding a per entity cost of: $283.09 (Canada); $3,473.72 (Mexico) ; and $46.87 (non-OECD).

U.S. importers from Canada, Mexico, a nd non-OECD countries will also face an incremental reporting burden to se nd a confirmation of recovery or disposal to the exporter, EPA, and competent authority of the country of export. The average cost burden per entity is estimated as follows: $1,752.88 (Canada); $791.1 6 (Mexico); and $938.78 (non-OECD). All importers will experience an additional cost of $0.56 to electronically sign each confirmation of recovery or disposal.28 (l) Return of Wastes

EPA does not estimate any incremental burden resulting from changes to this provision.

(m) Exemption of Wastes Destined for Laboratory Analysis

EPA estimates that each shipment no longer qualifying for this exemption will cost exporters $55.33, importers $94.90, and transporte rs $4.95. Exporters will also experience $9.01 in cost savings per shipment that is no longer exempt. A total of two import shipments and two export shipments per year are expected to no long er be exempt across all shipments to and from Canada, Mexico, and no n-OECD countries.

(n) Automated Export Syst em Filing Requirements

No change in burden is estimat ed relating to this provision.

(o) Obtain EPA Identification Numbers

Obtaining an EPA identification number is estimated to cost $37.48 for each recognized

trader of hazardous waste.

6(e) Bottom Line Burden Hours and Costs

(1) Respondent Tally

Exhibit 22 reports the number of respondent s that must comply with information

collection activities unde r the proposed rule. Exhibit 23 repor ts the total a nnual respondent

burden and costs associated with the aforementioned new informa tion collection activities. The exhibit shows that the total annual respondent burden under the proposed rule during the first year of its implementation, including the cost of reading the rule, is estimated to be 44,701 hours and $1,249,747. In each subsequent year, the respondent burden is estimated to be 42,467 hours and $1,067,834. In each year, cost savings associated with the proposed rule are estimated to be $454,752.56 across all respondents. For the affected hazardous wast e generator entities, the average number of responses per a ffected entity is estimated to be 7.8 in the first year after the promulgation of the rule and 5.3 per year in each subsequent year. Thus, the average number of responses per entity in the first three years of the rule is 6.1 pe r year. Finally, Exhibit 24 reports the average annual private industry and Agency burden and cost estimates for the first three years of the rule.

Respondents Hours O&M Cost Total Cost Year 1 1,305 44,701 $1,249,747 After Year 1 42,467 $1,067,834 Annual Total 1,305 43,212 $0 $1,128,472

(2) Agency Tally29 The estimated annual cost to the Agency is $908,708.

Total Cost Year 1 (High End) $959,968.66 After Year 1 (High End) $883,078.20 Annual Average Total (High End) $908,708.35

Estimated Agency costs and cost savings for the various information collection activities under the proposed rule, as delineated in Section 5(a) above, are presente d in Exhibits 20 and 21

below. The exhibits show that the total a nnual Agency burden under the proposed rule is estimated to include between $188,750 and $311,250 in development costs for enhancements to WIETS, between $39,076 and $65,127 in development -related labor costs, between $96,750 and $161,250 in annual operations and maintenance costs, and between $83,015 and $138,359 in labor costs required for operation and maintenan ce activities. EPA will also incur additional costs for processing movement documents, confir mations of recovery, and requests for EPA IDs from recognized traders. These costs are estimated to be $583,592 in the first year of the rule, and $583,469 in each subsequent year. EPA is also expected to experience a cost savings of $232,895 each year since the electronic system will e liminate the need to manually enter export notice and export annual report data and answer exporter inquiries via phone.

6(f) Reasons for Change in Burden

As aforementioned, the new paperwork re quirements under the proposed rule are necessary to make existing expor t and import related requirement s more consistent with the current import-export requireme nts required for shipments between OECD member countries;

enable electronic submittal of a ll export and import-related docu ments; and enable electronic

submittal and validation of consent in the AE S for export shipments subject to RCRA export consent requirements prior to exit.30 6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average about 5 hours per respon se. Burden means the total time, effort, or financial resources expended by persons to genera te, maintain, retain, or disclose or provide information to or for a Federal agency. This in cludes the time needed to review instructions; develop, acquire, install, and utilize technology and systems fo r the purposes of collecting, validating, and verifying information, processi ng and maintaining information, and disclosing and providing information; adjust the existing wa ys to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete a nd 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 nu mbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA–HQ– RCRA–2015–0147, which is available for online viewing at www.regulations.gov , or in person viewing at the RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitu tion Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is ope n 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 Dock et 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 ava ilable electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affair s, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503 , Attention: Desk Officer fo r EPA. Please include the EPA

Docket ID Number EPA– HQ–RCRA–2015–0147 and OMB Contro l Number 2050-NEW in any correspondence.31Exhibit 3Reading the Rule(In the first year of Rule Implementation Only)InformationCollection ActivityHours and Costs Per Entity Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost1Number ofRespondents2TotalHoursTotal CostU.S. ExportersReading the rule 1 2.5 0 3.5 $308.03 $0.00 $308.03 378 1,323 $116,430.37U.S. ImportersReading the rule 1 2.5 0 3.5 $308.03 $0.00 $308.03 45 157 $13,858.04TOTAL - YEAR 1423 1,480 $130,288.41Sources:(1) Cost Assessment for the Final Rule on Exports and Imports ofHazardous Waste Destined for Recovery Among OECD Countries, Exports of SpentLead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste andEmergency Response, U.S. Environmental Protection Agency, May 2009.(2) Unique entity counts are based on U.S. EPA Export and Import Annual Reports, 2011.32Exhibit 4CDX Registration CostsInformation Collection ActivityHours and Costs Per Registrant Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCostNumber ofRespondentsNumber ofRegistrants1TotalHoursTotal CostU.S. ExportersInitial registration - Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 378 1,894 284 $19,145.61New registrations - every yearAfter Year 10 0.15 0 0.15 $10.11 $0.00 $10.11 378 208 31 $2,106.02Update information - every yearAfter Year 10 0.02 0 0.02 $1.35 $0.00 $1.35 378 189 4 $255.27Electronic signature if registrantfails identity (proofingrequirements) - Year 10 0.0833 0 0.0833 $5.61 $0.63 $6.24 378 379 32 $2,365.05Electronic signature if registrantfails identity-proofing requirements- After Year 10 0.0833 0 0.0833 $5.61 $0.63 $6.24 378 42 3 $260.16U.S. ImportersInitial registration - Year 1 0 0.15 0 0.15 $10.11 $0.00 $10.11 45 212 32 $2,142.34New registrations - every yearAfter Year 10 0.15 0 0.15 $10.11 $0.00 $10.11 45 23 3 $235.66Update information - every yearAfter Year 10 0.02 0 0.02 $1.35 $0.00 $1.35 45 21 0 $28.56Electronic signature if registrantfails identity (proofingrequirements) - Year 10 0.0833 0 0.0833 $5.61 $0.63 $6.24 45 42 4 $264.64Electronic signature if registrantfails identity-proofing requirements- After Year 10 0.0833 0 0.0833 $5.61 $0.63 $6.24 45 5 0 $29.11TOTAL - YEAR 1423 351 $23,917.64TOTAL - AFTER YEAR 1423 43 $2,914.78Source:(1) EPA estimates that there are 4.7 registrants per respondent for importers and 5 registrants for exporters.33Exhibit 5Notification CostsInformation Collection ActivityHours and Costs Per Notification Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCost1,3O&MCostTotalCostNumberof Resp.2Numberof NoticesTotalHoursTotal CostU.S. Exporters - CanadaSubmit additional data fields as part ofnotice of intent to export - Year 10 0.33 0 0.33 $22.24 $0.00 $22.24 326 2.6 274 $18,495.20Submit additional data fields as part ofnotice of intent to export - After Year 10 0.132 0 0.132 $8.90 0 $8.90 326 2.6 110 $7,398.08Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 2.6 7 $465.18U.S. Exporters – MexicoSubmit additional data fields as part ofnotice of intent to export - Year 10 0.5 0 0.5 $33.70 $0.00 $33.70 24 1.4 17 $1,152.97Submit additional data fields as part ofnotice of intent to export - After Year 10 0.2 0 0.2 $13.48 0 $13.48 24 1.4 7 $461.19Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 1.4 0.3 $19.14U.S. Exporters - non-OECDSubmit additional data fields as part ofnotice of intent to export - Year 10 0.5 0 0.5 $33.70 $0.00 $33.70 2 1.0 1 $67.40Submit additional data fields as part ofnotice of intent to export - After Year 10 0.2 0 0.2 $13.48 0 $13.48 2 1.0 0.4 $26.96Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 1.0 0.0 $1.12U.S. Exporters – OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 1.6 0 $27.88U.S. Exporters - Other4Submit additional data fields as part ofnotice of intent to export - Year 10 varies 0 0 varies $0.00 varies 298 varies 248 $16,706.71Submit additional data fields as part ofnotice of intent to export - After Year 10 varies 0 0 varies $0.00 varies 298 varies 99 $6,682.68Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 298 varies 6 $428.74U.S. Importers - MexicoSubmit export notices on behalf offoreign exporters - Year 10.1 1.8 0.1 2 $138.88 $6.10 $144.98 11 9.1 200 $14,497.75Submit export notices on behalf offoreign exporters - After Year 10.04 0.732 0.04 0.812 $56.36 $2.44 $58.80 11 9.1 81 $5,879.9834Information Collection ActivityHours and Costs Per Notification Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCost1,3O&MCostTotalCostNumberof Resp.2Numberof NoticesTotalHoursTotal CostElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 9.1 1 $55.94TOTAL - YEAR 1692 755 $51,918.04TOTAL - AFTER YEAR 1692 312 $21,446.90Sources:(1) Cost of import notice from: SupportingStatement for EPA Information Collection Request Number0820.11 Hazardous Waste Generator Standards (Renewal), March 30,2011.(2) Import notice totals from EPA's International Compliance Assurance Division (ICAD), sent via e-mail from Phuc Phan on June5, 2014.(3) Electronic signature burden from: Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-MediaElectronic Reporting Rule", June 22, 2011,Office of Environmental Information, U.S. Environmental Protection Agency.(4) This category includes exporters that submit export notices to EPA but do not subsequently export hazardous wastes during the 12-month notice period. Number ofrespondents based on 2013U.S. EPA WIETS data.35Exhibit 6Notification Cost SavingsInformation Collection ActivityHours and Costs Per Notification Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHours1LaborCostO&MCost3TotalCostSavingsNumber ofRespondentsNumber ofNotices2TotalHoursTotalCostSavingsU.S. Importers - CanadaOne-time notice to regionaladministrator stating intent to import0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 35 6 3 $224.56Send copy of import manifest toEPA0.00 0.00 0.00 0 $0.00 $0.74 $0.74 35 2,418 0 $1,789.32U.S. Importers - MexicoOne-time notice to regionaladministrator stating intent to import0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 11 1 1 $48.45Send copy of import manifest toEPA0.00 0.00 0.00 0 $0.00 $0.74 $0.74 11 343 0 $253.82U.S. Importers - non-OECDOne-time notice to regionaladministrator stating intent to import0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 3 0 0 $9.20Send copy of import manifest toEPA0.00 0.00 0.00 0 $0.00 $0.74 $0.74 3 111 0 $82.14U.S. Importers - OECDOne-time notice to regionaladministrator stating intent to import0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 2 0 0 $5.62Send copy of import manifest toEPA0.00 0.00 0.00 0 $0.00 $0.74 $0.74 2 62 0 $45.88TOTAL51 4 $2,458.99Source:(1) Burden estimate based on burden to obtain a new EPA ID number (similar data submittal process), as taken from: Supporting Statement for EPA Information Collection RequestNumber 0976.16, "2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification, September 2012.(2) One-time notices estimated to account for 5 percent of annualimport notices. Based on information received from the EPA Regional Offices provided by Alan Barnosky of EPA'sOffice of Resource Conservation and Recovery.(3) Includes cost for mailing one standard envelope.36Exhibit 7Re-notification CostsInformation CollectionActivityHours and Costs Per Re-notification Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofRenotifications1TotalHoursTotalCostU.S. Exporters - CanadaElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 266 2.2 $148.86U.S. Exporters - MexicoElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 11 0.1 $6.12U.S. Exporters - non-OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 1 0.0 $0.36U.S. Exporters - OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 16 0.1 $8.92TOTAL383 294 2 $164.26Source:(1) 32 percent of respondents are estimated to submit re-notifications annually. Based on data from EPA's International Compliance Assurance Division(ICAD) sent via e-mail from Phuc Phan on June 5, 2014.(2) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 2011, Office of EnvironmentalInformation, U.S. Environmental Protection Agency.37Exhibit 8Re-notification Cost SavingsInformation CollectionActivityHours and Costs Per Re-notification Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofRenotifications1TotalHoursTotalCostU.S. Exporters - CanadaSubmit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 326 266 0.0 $138.37U.S. Exporters - MexicoSubmit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 24 11 0.0 $5.69U.S. Exporters - non-OECDSubmit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 1 0.0 $0.33U.S. Exporters - OECDSubmit re-notification to EPA 0 0 0 0 $0.00 $0.52 $0.52 31 16 0.0 $8.29TOTAL383 294 0 $152.69Source:(1) 32 percent of respondents are estimated to submit re-notifications annually. Based on data from EPA's International Compliance Assurance Division(ICAD) sent via e-mail from Phun Phan on June 5, 2014(2) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 2011, Office of EnvironmentalInformation, U.S. Environmental Protection Agency38Exhibit 9Annual Report CostsInformation Collection ActivityHours and Costs Per Report Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCost1O&MCostTotalCostNumber ofRespondentsTotalHoursTotalCostU.S. ExportersElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 378 3 $211.46TOTAL378 3 $211.46Source:(1) Supporting Statement for EPA Information Collection Request Number 2002.05: "Cross-Media Electronic Reporting Rule", June 22, 2011, Office ofEnvironmental Information, U.S. Environmental Protection Agency39Exhibit 10Acknowledgment of Consent Cost SavingsInformation CollectionActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCostSavings1Number ofRespondentsNumber ofShipmentsTotalHoursTotal CostSavingsU.S. Exporters - CanadaFind consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 326 25,600 4,352 $156,889.60Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 326 25,600 2,048 $79,462.40U.S. Exporters - MexicoFind consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 24 23,126 3,931 $141,727.69Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 24 23,126 1,850 $71,783.10U.S. Exporters - non-OECDFind consent document 0 0 0.17 0.17 $6.13 $0.00 $6.13 2 26 4 $159.34Copy consent document 0 0 0.08 0.08 $2.88 $0.22 $3.10 2 26 2 $80.70TOTAL352 48,752 12,188 $450,102.84Source:(1) Estimated burden derived from Cost Assessment for the Final Rule on Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exportsof Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste and EmergencyResponse, U.S. Environmental Protection Agency, May 2009.40Exhibit 11Exception Report CostsInformation CollectionActivityHours and Costs Per Report Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostU.S. Exporters - CanadaElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 326 10 0.08 $5.59U.S. Exporters - MexicoElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 24 9 0.07 $5.05U.S. Exporters - non-OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 0 0.00 $0.01U.S. Exporters - OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 31 1 0.01 $0.54TOTAL383 20 0.17 $11.17Source:(1) Estimated percentage of shipments requiring an exception report based on e-mail from Phuc Phan on June 5, 2014.(2) Burden estimates from Cost Assessment for the Final Rule on Exports and Imports ofHazardous Waste Destined for Recovery Among OECD Countries, Exportsof Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste andEmergency Response, U.S. Environmental Protection Agency, May 2009.41Exhibit 12Exception Report Cost SavingsInformation Collection ActivityHours and Costs Per Report Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostU.S. Exporters - CanadaMail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 326 10 0.00 $5.19U.S. Exporters - MexicoMail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 24 9 0.00 $4.69U.S. Exporters - non-OECDMail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 2 0 0.00 $0.01U.S. Exporters - OECDMail exception report to EPA 0 0 0 0 $0.00 $0.52 $0.52 31 1 0.00 $0.50TOTAL383 20 0.00 $10.39Source:(1) Estimated percentage of shipments requiring an exception report based on e-mail from Phuc Phan on June 5, 201442Exhibit 13Movement Document CostsInformation CollectionActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCost2TotalCost1, 3Number ofRespondentsNumber ofShipmentsTotalHoursTotal CostU.S. Exporters - MexicoComplete movementdocument0 0.5 0.5 1 $51.73 $0.55 $52.28 24 23,126 23,126 $1,208,911.65U.S. Exporters - non-OECDComplete movementdocument0 0.5 0.5 1 $51.73 $0.55 $52.28 2 26 26 $1,359.15U.S. Importers - CanadaSend a copy of themovement document to EPAand Environment Canada0000$0.00$1.18$1.18352,4180$2,853.24Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 35 2,418 20.07 $1,352.68U.S. Importers - MexicoSign movement documentand send a copy to EPA,exporter, foreign authority0.1 0.5 0.5 1.1 $65.68 $2.36 $68.04 11 343 377 $23,336.86Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 343 2.85 $191.88Maintain a signed copy ofthe movement document0 0 0.1 0.1 $3.61 $0.00 $3.61 11 343 34 $1,236.52U.S. Importers - non-OECDSign movement documentand send a copy to EPA,exporter, foreign authority0.1 0.5 0.5 1.1 $65.68 $2.36 $68.04 3 111 122 $7,552.16Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 3 111 0.92 $62.10Maintain a signed copy ofthe movement document0 0 0.1 0.1 $3.61 $0.00 $3.61 3 111 11 $400.16TOTAL75 26,024 23,721 $1,247,256.3943Source:(1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number0820.11 Hazardous Waste Generator Standards (Renewal), March 30,2011.(2) For importer movement document requirements assume $1.15 for international postage and $0.03 for a standard envelope. Basedon USPS price calculator for 1 oz.envelope sent by first-class international letter.(3) Burden estimates from Cost Assessment for the Final Rule on Exports and Imports ofHazardous Waste Destined for Recovery Among OECD Countries, Exports of SpentLead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste and Emergency Response, U.S.Environmental Protection Agency, May 2009.44Exhibit 14Movement Document Cost SavingsInformation Collection ActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCost2TotalCost1, 3Number ofRespondentsNumber ofShipmentsTotalHoursTotalCostU.S. Importers - OECDSend a copy of the movementdocument to EPA0 0 0 0 $0.00 $0.52 $0.52 2 62 0 $32.24TOTAL2 62 0 $32.24Source:(1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number0820.11 Hazardous Waste Generator Standards (Renewal),March 30, 2011.45Exhibit 15Confirmation of RecoveryInformation Collection ActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCost1O&MCost2TotalCostNumberof Resp.Number ofShipmentsTotalHoursTotal CostU.S. Exporters - CanadaReceive and maintain confirmation ofrecovery provided by the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 326 25,600 2,560 $92,288.00U.S. Exporters - MexicoReceive and maintain confirmation ofrecovery provided by the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 24 23,126 2,313 $83,369.23U.S. Exporters - non-OECDReceive and maintain confirmation ofrecovery provided by the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 2 26 3 $93.73U.S. Importers - CanadaSend a confirmation of recovery to theexporter, EPA and competent authoritiesof the country of export0 0.2 0.25 0.45 $22.49 $2.88 $25.37 35 2,418 1,088 $61,350.71Electronic signature0 0.0083 0 0.0083 $0.56 $0.00 $0.56 35 2,418 20 $1,352.68U.S. Importers - MexicoSend a confirmation of recovery to theexporter, EPA and competent authoritiesof the country of export0 0.2 0.25 0.45 $22.49 $2.88 $25.37 11 343 154 $8,702.77Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 11 343 3 $191.88U.S. Importers - non-OECDSend a confirmation of recovery to theexporter, EPA and foreign authority0 0.2 0.25 0.45 $22.49 $2.88 $25.37 3 111 50 $2,816.35Electronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 3 111 1 $62.10U.S. Importers - OECDElectronic signature 0 0.0083 0 0.0083 $0.56 $0.00 $0.56 2 62 1 $34.68TOTAL403 51,686 6,192 $250,262.12Source:(1) Burden estimates based on Cost Assessment for the Final Rule on Exports and Importsof Hazardous Waste Destined for Recovery Among OECD Countries, Exports of SpentLead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste and Emergency Response, U.S.Environmental Protection Agency, May 2009.(2) Assume $1.15 for international postage and $0.03 for a standard envelope. Based on USPS price calculator for 1 oz. envelopesent by first-class international letter.46Exhibit 16Confirmation of Recovery Cost SavingsInformation CollectionActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCost2TotalCost1, 3Number ofRespondentsNumber ofShipmentsTotalHoursTotalCostU.S. Importers - OECDSend a copy of themovement document to EPA0 0 0 0 $0.00 $0.52 $0.52 2 62 0 $32.24TOTAL2 62 0 $32.24Source:(1) Burden assumptions based on Supporting Statement for EPA Information Collection Request Number0820.11 Hazardous Waste Generator Standards (Renewal),March 30, 2011.47Exhibit 17Laboratory Exemption CostsInformation Collection ActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostU.S. Exporters - CanadaComplete and signmovement/tracking document0 0.5 0.5 1 $51.73 $0.00 $51.73 326 1.1 1.1 $54.32Receive and maintainconfirmation of recovery providedby the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 326 1.1 0.1 $3.79U.S. Exporters - MexicoComplete and signmovement/tracking document0 0.5 0.5 1 $51.73 $0.00 $51.73 24 0.9 0.9 $49.07Receive and maintainconfirmation of recovery providedby the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 24 0.9 0.1 $3.42U.S. Exporters - non-OECDComplete and signmovement/tracking document0 0.5 0.5 1 $51.73 $0.00 $51.73 2 0.0 0.0 $0.06Receive and maintainconfirmation of recovery providedby the recovery facility0 0 0.1 0.1 $3.61 $0.00 $3.61 2 0.0 0.0 $0.0048Exhibit 17 (continued)Laboratory Exemption CostsInformation Collection ActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostU.S. Importers - CanadaSign movement/tracking documentand provide a copy to the exporter,EPA, and competent authorities ofthe country of export0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 35 1.7 1.9 $113.22Maintain a copy of the signedmovement/tracking document0 0 0.1 0.1 $3.61 $0.00 $3.61 35 1.7 0.2 $6.07Send a confirmation of recovery tothe exporter, EPA, and competentauthorities of the country of export0 0.2 0.25 0.45 $22.49 $1.56 $24.05 35 1.7 0.8 $40.50U.S. Importers - MexicoSign movement/tracking documentand provide a copy to the exporter,EPA, and competent authorities ofthe country of export0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 11 0.2 0.3 $16.06Maintain a copy of the signedmovement/tracking document0 0 0.1 0.1 $3.61 $0.00 $3.61 11 0.2 0.0 $0.86Send a confirmation of recovery tothe exporter, EPA, and competentauthorities of the country of export0 0.2 0.25 0.45 $22.49 $1.56 $24.05 11 0.2 0.1 $5.75U.S. Importers - non-OECDSign movement/tracking documentand provide a copy to the exporter,EPA, and competent authorities ofthe country of export0.1 0.5 0.5 1.1 $65.68 $1.56 $67.24 3 0.1 0.1 $5.20Maintain a copy of the signedmovement/tracking document0 0 0.1 0.1 $3.61 $0.00 $3.61 3 0.1 0.0 $0.28Send a confirmation of recovery tothe exporter, EPA, and competentauthorities of the country of export0 0.2 0.25 0.45 $22.49 $1.56 $24.05 3 0.1 0.0 $1.8649Exhibit 17 (continued)Laboratory Exemption CostsInformation Collection ActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCost2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostTransportersUpon obtaining physical custodyof the waste, sign themovement/tracking document0 0.01 0 0.01 $0.67 $0.00 $0.67 564 4.0 0.0 $2.70Maintain a copy of the signedmovement/tracking document0 0 0.1 0.1 $3.61 $0.00 $3.61 564 4.0 0.4 $14.42Upon delivery of the waste,obtain signed copy of themovement/tracking documentfrom the OECD countryrecovery facility0 0.01 0 0.01 $0.67 $0.00 $0.67 564 4.0 0.0 $2.70TOTAL965 6.0 $320.26Source:(1) Affected shipments based on estimates from Cost Assessment for the Final Rule onExports and Imports of Hazardous Waste Destined for Recovery Among OECDCountries, Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Wasteand Emergency Response, U.S. Environmental Protection Agency, May2009. Ratio of OECD imports/exports for lab analysis and total OECD imports/exports.(2) Burden estimates based on Cost Assessment for the Final Rule on Exports and Importsof Hazardous Waste Destined for Recovery Among OECD Countries, Exports ofSpent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Officeof Solid Waste and EmergencyResponse, U.S. Environmental Protection Agency, May 2009.50Exhibit 18Laboratory Exemption Cost SavingsInformation CollectionActivityHours and Costs Per Shipment Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCostO&MCostTotalCostSavings2Number ofRespondentsNumber ofAffectedShipments1TotalHoursTotalCostSavingsU.S. Exporters - CanadaFind and copyacknowledgment of consentdocument0 0 0.25 0.25 $9.01 $0.00 $9.01 326 1.1 0.3 $9.47U.S. Exporters - MexicoFind and copyacknowledgment of consentdocument0 0 0.25 0.25 $9.01 $0.00 $9.01 24 0.9 0.2 $8.55U.S. Exporters - non-OECDFind and copyacknowledgment of consentdocument0 0 0.25 0.25 $9.01 $0.00 $9.01 2 0.0 0.0 $0.01TOTAL352 2 1 $18.03Source:(1) Affected shipments based on estimates from Cost Assessment for the Final Rule onExports and Imports of Hazardous Waste Destined for Recovery AmongOECD Countries, Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office ofSolid Waste and Emergency Response, U.S. Environmental ProtectionAgency, May 2009. Ratio of OECD imports/exports for lab analysis and total OECDimports/exports.(2) Burden estimates based on Cost Assessment for the Final Rule on Exports and Importsof Hazardous Waste Destined for Recovery Among OECD Countries,Exports of Spent Lead-Acid Batteries from the U.S., and Import Consent Documentation: Office of Resource Conservation and Recovery, Office of Solid Waste andEmergency Response, U.S. Environmental Protection Agency, May 2009.51Exhibit 19EPA Identification NumberInformation Collection ActivityHours and Costs Per RecognizedTrader Total Hours and CostsManagerial($139.53/hr)Technical($67.40/hr)Clerical($36.05/hr)TotalHoursLaborCost1O&MCostTotalCostNumber ofRespondents2TotalHoursTotalCostU.S. Recognized TradersObtain an EPA ID number - Year 1 0.08 0.34 0.08 0.5 $36.96 $0.52 $37.48 4 2 $149.93TOTAL - YEAR 14 2 $149.93Source:(1) Hourly burden estimates from: Supporting Statement for EPAInformation Collection Request Number 0976.16, "2013 Hazardous Waste Report,Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification, September 2012.(2) Estimated number of recognized traders based on EPA guidance on methodology table.Note: Recognized traders are estimated to account for 1% of all importers and exporters.52Exhibit 20Agency CostsInformation Collection ActivityHours and Costs Per Respondent Per Activity Total Hours and CostsManagerial($65.58/hr)Technical($55.50/hr)Clerical($21.25/hr)LaborCost1CapitalCostO&MCostNumberof Resp.TotalHoursTotal CostMovement Document2Receive and record trackingdocument from importingcountry (exports)222.6 0.00 0.00 $14,600 $0.00 $0.00 26 5,788 $379,600.19Receive and record trackingdocument from importingfacility (imports)16.21 0.00 0.00 $1,922 $0.00 $0.00 14 227 $14,887.57Confirmation of Recovery/Disposal3Receive and maintain confirmation of recoveryprovided by recovery facility (exports and imports)0.00 0.00 12.87 $273.54 $0.00 $0.00 401 5,162 $109,690.68EPA IDs for Recognized Traders of HazardousWaste4Review letter requesting EPA ID number and enter thisinformation into a database - Year 10.00 0.35 0.00 $19.43 $0.00 $0.00 4 1.40 $77.71Generate EPA ID number and send EPA ID number torecognized trader - Year 10.00 0.00 0.50 $10.62 $0.00 $0.49 4 2.00 $44.46EPA Electronic Reporting System Development5EPA reporting system development costs(low-end) - Year 10.00 0.00 0.00 $0.00 $188,750 $0.00 1 0 $188,750.00EPA reporting system development costs(high-end) - Year 10.00 0.00 0.00 $0.00 $311,250 $0.00 1 0 $311,250.00Labor costs for development, testing, andimplementation (low-end) - Year 10.00 704.025 0.00 $39,076 $0.00 $0.00 1 704 $39,076.20Labor costs for development, testing, andimplementation (high-end) - Year 10.00 1,173.375 0.00 $65,127 $0.00 $0.00 1 1,173 $65,127.01O&M costs (low-end) - After Year 1 0.00 0.00 0.00 $0.00 $0.00 $170,250 1 0 $170,250.00O&M costs (high-end) - After Year 1 0.00 0.00 0.00 $0.00 $0.00 $283,750 1 0 $283,750.00Labor costs for maintenance (low-end) - After Year 1 0.00 1,495.66 0.00 $83,015 $0.00 $0.00 1 1,496 $83,015.22Labor costs for maintenance (high-end) - After Year 1 0.00 2,492.77 0.00 $138,359 $0.00 $0.00 1 2,493 $138,358.71TOTAL (LOW-END) - YEAR 113,094 $811,417.86TOTAL (HIGH-END) - YEAR 113,563 $959,968.66TOTAL (LOW-END) - AFTER YEAR 113,882 $763,234.71TOTAL (HIGH-END) - AFTER YEAR 114,879 $883,078.2053Source:(1) U.S. Office of Personnel Management, Salary Table 2014-GS, Incorporating the 1% General Schedule Increase, Effective January 2014, Hourly Basic Rates by Grade and Step,accessed at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/GS_h.pdfon August 18, 2014.(2) Supporting statement for EPA information collection request number 0820.11, hazardous waste generator standards (renewal),March 30, 2011.(3) Cost Assessment for the Final Rule on Exports and Imports ofHazardous Waste Destined for Recovery Among OECD Countries, Exports of Spent Lead-Acid Batteries fromthe U.S., and Import Consent Documentation.Office of Resource Conservation and Recovery, Office of Solid Waste and Emergency Response, U.S. Environmental ProtectionAgency. May 2009.(4) Supporting Statement for EPA Information Collection Request Number 0976.16, “2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part AHazardous Waste Permit Application and Modification,” September 19, 2012.(5) EPA reporting system development and operation & maintenance costs from the Word Document “EPA FTEs and Costs for import-export rule RANGES Jan 8 2015.docx”provided by Phuc Phan of EPA’s Office of Resource Conservation and Recovery on January 15, 2015.54Exhibit 21Agency Cost SavingsInformation Collection ActivityHours and Costs Total Hours and CostsManagerial($65.58/hr)Technical($55.50/hr)Clerical($21.25/hr)TotalHoursLaborCostO&MCostCostSavingsNumber ofRespondentsNotices perRespondentTotalHoursTotal CostSavingsEPAAvoided data entry for exportnotifications0 1 0 1 $55.50 $0.00 $55.50 701 2.4 1,684 $93,468.74Avoided hours answeringexport notice inquiries viatelephone0 1,000 0 1,000 $55,504 $0.00 $55,504 1 N/A 1,000 $55,504.00Avoided data entry for annualreports0 4 0 4 $222.02 $0.00 $222.02 378 N/A 1,512 $83,922.05TOTAL3,213 $232,894.7855Exhibit 22(please note some entities are counted in multiple columns)Estimated Number of Respondents Affected by the Proposed Hazardous Waste Export-Import RuleInformation CollectionActivityNumber of RespondentsU.S.Exporters(Canada)U.S.Exporters(Mexico)U.S.Exporters(non-OECD)U.S.Exporters(OECD)U.S.Exporters(Other)U.S.Importers(Canada)U.S.Importers(Mexico)U.S.Importers(non-OECD)U.S.Importers(OECD)TransportersTOTALReading the Rule 326 24 2 31 0 35 11 3 2 0 423CDX Registration 326 24 2 31 0 35 11 3 2 0 423Notification 326 24 2 31 318 0 11 0 0 0 707Re-notification 104 8 1 10 0 0 0 0 0 0 123Annual Report 326 24 2 31 0 0 0 0 0 0 378ProvideAcknowledgment ofConsent to Transporter0 0 0 0 0 0 0 0 0 0 0Exception Report 326 24 2 31 0 0 0 0 0 0 378Movement Document 0 0 0 0 0 35 11 3 2 0 45Confirmation ofRecovery or Disposal0 0 0 0 0 35 11 3 2 0 45Exemption for WastesDestined for LaboratoryAnalysis326 24 2 0 0 35 11 3 0 564 960Obtain EPA ID 1 1 0 0 0 1 1 0 0 0 4TOTAL 326 24 2 31 318 35 11 3 2 564 1,30556Exhibit 23Total Annual Estimated Respondent Burden by Rule ProvisionProvision Total HoursTotal Hours(Cost Savings)1Total Costs Total Cost Savings Total Net Costs2Reading the Rule - Year 1 1,480 0 $130,288.41 $0.00 $130,288.41EPA Reporting System Registration - Year 1 351 0 $23,917.64 $0.00 $23,917.64EPA Reporting System Registration - After Year 1 43 0 $2,914.78 $0.00 $2,914.78Notification - Year 1 755 0 $51,918.04 $2,458.99 $49,459.06Notification - After Year 1 754 0 $21,446.90 $2,458.99 $18,987.91Re-notification 2 0 $164.26 $0.00 $164.26Annual Report 3 0 $211.46 $2,097.84 ($1,886.39)Provide Acknowledgment of Consent to Transporter 0 12,188 $0.00 $450,102.84 ($450,102.84)Exception Report 0.17 0 $11.17 $10.39 $0.79Movement Document 23,721 0 $1,247,256.39 $32.24 $1,247,224.15Confirmation of Recovery or Disposal 6,192 0 $250,262.12 $32.24 $250,229.88Exemption for Wastes Destined for Laboratory Analysis 6 1 $320.26 $18.03 $302.24Obtain EPA IDs (Recognized Traders) - Year 1 2 0 $149.93 $0.00 $149.93TOTAL - YEAR 1 32,513 12,188 $1,704,499.69 $454,752.56 $1,249,747.12TOTAL - AFTER YEAR 1 30,279 12,188 $1,522,587.34 $454,752.56 $1,067,834.78AVERAGE TOTAL IN THE FIRST THREE YEARS 31,024 12,188 $1,583,224.79 $454,752.56 $1,128,472.23Note:(1)For the first three years, there are a totalof 43,212 burden hours associated with the proposed rule. Of this, 31,024 hours isthe incremental cost burden and 12,188 hours isthe incremental cost savings of the proposed rule.(2)Numbers in parentheses indicate a net cost savings.57Exhibit 24Total Average Annual Respondent Burden andCost Estimates for the First Three YearsRespondent TypeTotalRespondentsTotalResponsesNumber ofResponsesperRespondentTotalHoursTotal LaborCostsTotalCapital/Startupand O&M CostsTotal CostPrivate Industry 1,305 7,984 6.1 43,212 $1,128,472 $0 $1,128,472Agency (Low-end) N/A 480 N/A 13,622 $651,878 $127,417 $779,296Agency (High-end) N/A 480 N/A 14,443 $697,458 $211,251 $908,708