SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.15

“2011 HAZARDOUS WASTE REPORT, NOTIFICATION OF 

REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS

WASTE PERMIT APPLICATION AND MODIFICATION” 

August 2011

Office of Resource Conservation and Recovery

United States Environmental Protection Agency

Washington, D.C. 20460
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION.......................................................3

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION ......................................3

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION.....................................3

2. NEED FOR AND USE OF THE COLLECTION ............................................................................11

2(a) NEED AND AUTHORITY FOR THE COLLECTION.........................................................11

2(b) PRACTICAL UTILITY AND USERS OF THE DATA........................................................12

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA..............15

3(a) NONDUPLICATION .............................................................................................................15

3(b) PUBLIC NOTICE...................................................................................................................15

3(c) CONSULTATIONS................................................................................................................18

3(d) EFFECTS OF LESS FREQUENT COLLECTION................................................................20

3(e) GENERAL GUIDELINES......................................................................................................21

3(f) CONFIDENTIALITY.............................................................................................................21

3(g) SENSITIVE QUESTIONS......................................................................................................22

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ..............................................23

4(a) RESPONDENTS AND NAICS CODES ................................................................................23

4(b) INFORMATION REQUESTED.............................................................................................23

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT ......................................................38

5(a) AGENCY ACTIVITIES .........................................................................................................38

5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................41

5(c) SMALL ENTITY FLEXIBILITY...........................................................................................41

5(d) COLLECTION SCHEDULE..................................................................................................42

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ..............................46

6(a) ESTIMATING RESPONDENT BURDEN HOURS..............................................................46

6(b) ESTIMATING RESPONDENT COSTS ................................................................................51

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN ....................................................54

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR

AND COST BURDEN............................................................................................................55

6(e) BOTTOM LINE HOUR AND COST BURDEN ...................................................................65

6(f) REASONS FOR CHANGE IN BURDEN..............................................................................65

6(g) PUBLIC BURDEN STATEMENT.........................................................................................68
3

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “2011 Hazardous Waste Report,

Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and 

Modification,” EPA ICR Number 0976.15.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

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

Protection Agency (EPA):

 “Notification of Regulated Waste Activity and 2009 Hazardous Waste Report,”

EPA ICR Number 0976.14 (OMB Control Number 2050-0024). EPA ICR 

Number 0976.14 addresses the following information collection requirements:

 Notification requirements under RCRA Section 3010; 40 CFR 260.42 

(hazardous secondary material activity); 40 CFR Part 262, Subpart K 

(alternative generator standards for academic laboratories); 40 CFR Part 273, 

Subpart C (universal waste activity); and 40 CFR Part 279 (used oil activity). 

EPA Form 8700-12 is used by facilities to satisfy this requirement.

 Hazardous Waste Report requirements of Sections 3002 and 3004 of RCRA, 

as amended, which require reporting to EPA or to authorized States at least 

every two years. The Hazardous Waste Report [EPA Form 8700-13 Form 

A/B], or comparable State report, is used by generators and treatment, storage, 

and disposal facilities (TSDFs) to satisfy this requirement.

 “RCRA Hazardous Waste Permit Application and Modification, Part A,” EPA 

ICR Number 0262.12 (OMB Control Number 2050-0034). Sections 3004 and 

3005 of RCRA, as amended, require anyone who owns or operates a facility 

where hazardous waste is treated, stored, or disposed to have a RCRA hazardous 

waste permit issued by EPA. There are two parts to a RCRA hazardous waste 

permit application: Part A and Part B. Part A consists of EPA Form 8700-23, or 

comparable State form, along with maps, drawings, and photographs, as required 

by 40 CFR 270.13. Part B contains detailed, site-specific information. There is

no form for the Part B Permit Application; rather, the Part B Permit Application 

must be submitted in narrative form and contain the information described in 

applicable sections of 40 CFR 270.14 through 270.27. EPA ICR Number 0262.12 

addresses the requirements of completing and submitting a Part A Permit 

Application or modifying a hazardous waste permit by submitting a revised 

application. The information collection requirements associated with the Part B 

Application are covered under a separate ICR.
4

EPA integrated the above two ICRs into this current ICR, EPA ICR Number 0976.15, to 

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

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

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

Site ID Form). Specifically, the Notification and Hazardous Waste Report ICR addresses: 

(1) the requirements for all regulated entities to submit the Site ID Form (or alternative 

document, if specified) to notify EPA or the authorized State; and (2) the requirements for large 

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

Hazardous Waste Report. The Part A ICR addresses the requirements for all owner/operators of 

TSDFs to submit the Site ID Form as part of their Part A Permit Applications or Part A Permit 

Modifications. Incorporating these two ICRs into this current ICR has allowed EPA to more 

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

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

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

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

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

requirements. 

The following paragraphs briefly summarize the information collection requirements 

covered in this ICR. NOTE: As used in this document, the term “respondent” includes:

 Hazardous waste facilities complying with the Hazardous Waste Report, 

notification, and Part A Permit Application requirements covered in this ICR. 

This includes:

 Private sector entities; and

 State and local government agencies that are regulated entities2.

 State agencies administering the RCRA hazardous waste program3. 

(1) Hazardous Waste Report

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

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

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

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

 

1

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

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

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

month.

2

 Addressing State and local government agencies as “respondents” is consistent with EPA’s interpretation 

of the definition of respondent in the Paperwork Reduction Act (PRA).

3

 Ibid.
5

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

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

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

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

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

States for programmatic and regulatory needs. 

(2) Notification of Regulated Waste Activity

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

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

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

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

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

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

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

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

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

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

then subsequently stops managing hazardous secondary materials in accordance with the 

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

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

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

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

hazardous secondary materials for at least one year.

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

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

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

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

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

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

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

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

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

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

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

storing, transporting, offering for transport, or disposing of hazardous waste.
6

Table 1

Hazardous Waste Notification Requirements

40 CFR 

Regulatory 

Citation

Regulated Entity

§262.12 Hazardous Waste Generators

§263.11 Hazardous Waste Transporters

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

(TSDFs)

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

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

Constituting Disposal

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

§266.23 Users of Recyclable Materials in a Manner Constituting Disposal

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

Precious Metal Recovery

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

Batteries that are to be Regenerated) before Reclamation

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

that are to be Regenerated) before Reclamation

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

for Metal Recovery

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

Recovery of Significant Amounts of Certain Precious Metals

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

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

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

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

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

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

Industrial Furnaces 

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

Wastes

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

Hazardous Waste

§273.60(a) Universal Waste Destination Facilities
7

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

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

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

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

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

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

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

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

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

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

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

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

requirements.

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

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

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

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

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

requirements of RCRA Section 3010.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(identifying and listing hazardous wastes), generators and transporters of hazardous waste, and 
8

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

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

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

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

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

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

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

requirements and procedures. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

requirements of Subpart K.

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

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

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

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

Subpart K.

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

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

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

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

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

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

to Subpart K.
9

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

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

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

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

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

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

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

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

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

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

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

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

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

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

notification.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

the option of using a letter in lieu of submitting EPA Form 8700-12 (i.e., the Site ID Form).
10

Table 2

Used Oil Notification Requirements

40 CFR 

Regulatory 

Citation

Regulated Entity

§279.42 Used Oil Transporters and Transfer Facilities

§279.51 Used Oil Processors and Re-Refiners

§279.62 Burners of Off-Specification Used Oil

§279.73 Used Oil Fuel Marketers

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

40 CFR Part 270 contains requirements for submitting and modifying a Part A Permit 

Application. The Part A Permit Application contains the general information required in 

§270.13. That information includes names and addresses of the owner and operator of the 

facility and the activities conducted at the facility that requires a RCRA permit. The applicant 

must also provide information on the location of the facility, including a map, and what 

hazardous wastes are being managed and the processes involved in the waste management. 

Section 270.11 specifies the signature requirements for Part A Permit Applications and reports. 

(b) Revised Part A Permit Applications and Associated Justifications and 

Subpart H Compliance Demonstrations

Section 270.72 identifies the types of changes requiring interim status facilities or 

owners/operators of permitted facilities with newly regulated units to submit a revised Part A 

Permit Application, associated justifications, and compliance demonstrations. The changes that 

require a revised Part A include managing wastes not listed on the original Part A, increasing the 

design capacity of the facility, and changing the processes or adding new units for treating, 

storing, or disposing of the waste. In all cases, the owner must include justification for the 

change, and the Director must approve the changes. If the owner or operator changes, which 

also requires a revised Part A, both the old and new owner or operator must demonstrate that the 

financial responsibility requirements of 40 CFR part 265, subpart H will continue uninterrupted 

during the change.
11

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

(1) Hazardous Waste Report

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

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

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

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

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

reporting by the respondents.

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

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

year and (2) disposition of these hazardous wastes.

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

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

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

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

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

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

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

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

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

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

monitoring, and enforcement. 

(2) Notification of Regulated Waste Activity

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

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

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

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

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

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

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

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

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

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

amended.
12

(3) Part A Hazardous Waste Permit Application and Modification

EPA promulgated regulations at 40 CFR 270.1 requiring owners or operators of TSDFs 

to submit a Part A Permit Application. EPA needs information contained in the Part A Permit 

Application to identify the person(s) legally responsible for hazardous waste activity, to 

determine which facilities require permits under more than one program, to assess potential for 

the facility to pollute nearby ground and surface waters, to identify the time frame available for 

EPA to process permit applications, and to define the specific wastes a facility is legally allowed 

to handle for different purposes. 

EPA promulgated regulations at 40 CFR 270.72 outlining changes that require owners or 

operators to submit revised Part A Permit Applications. Section 270.72(a)(1)-(3) requires 

owner/operators to submit both a revised Part A Permit Application and a written justification for 

changes in the design capacity of processes used at the facility, and/or changes or additions in a 

facility's hazardous waste treatment, storage, or disposal processes. Under Section 270.72(a)(4), 

if an owner or operator changes ownership, or operational control of a facility, the new owner or 

operator is required to submit a revised Part A Permit Application, and a Subpart H compliance 

demonstration. EPA needs revised permit applications, justifications, and compliance 

demonstrations to determine whether desired changes are acceptable or should be more closely 

reviewed as part of a full permit issuance process. 

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Hazardous Waste Report

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

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

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

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

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

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

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

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

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

of this information. 

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

on the data for each odd number reporting year. The reports for 1991 to 2009 are available on 

the Internet at http://www.epa.gov/waste/inforesources/data/biennialreport/index.htm.
13

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

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

generated waste types and quantities.

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

recycled and the quantities managed by each method.

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

and disposal, recycling, and source reduction.

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

State.

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

wastes.

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

developing regulations; regulation development depends on descriptions and quantities of 

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

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

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

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

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

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

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

monitoring compliance, and carrying out enforcement.

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

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

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

hazardous waste generators and TSDFs.

(2) Notification of Regulated Waste Activity

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

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

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

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

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

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

upheld, and that regulations are adhered to by facility owners or operators.
14

(3) Part A Hazardous Waste Permit Application and Modification

EPA uses information in the Part A Permit Application to define which processes can be 

used and which wastes can be handled at newly regulated facilities subject to permitting 

requirements for the first time and permitted facilities with newly regulated units. This includes 

defining allowable changes in facility operations and applies to new facilities not yet 

constructed; newly regulated facilities subject to RCRA permitting requirements for the first 

time; permitted facilities with newly regulated units; and interim status facilities. EPA uses 

information in the Part A Permit Application to:

 Set priorities for processing permit applications;

 Respond to requests from hazardous waste generators for the names and locations 

of facilities where they can send their waste for storage, treatment, or disposal; 

 Respond to public and Congressional inquiries regarding particular hazardous 

waste management facilities; and

 Ensure that facilities are not operating in a manner unprotective of human health 

and the environment.

EPA uses information from revised Part A Permit Applications and associated 

justifications and Subpart H compliance demonstrations to determine whether desired changes 

are acceptable under interim status or whether the change should be more closely reviewed as 

part of a full permit issuance process. In addition, modifying the Part A Permit Application 

allows inspectors to have up-to-date information on major aspects of the facility, including the 

size of the operation, the hazardous wastes handled, and the types of processes used. Without 

this documentation, EPA would be unable to determine the owner or operator's compliance with 

the management standards of 40 CFR Parts 264 or 265 or the rules governing changes during 

interim status. This documentation is also useful for both EPA and the owner or operator in an 

enforcement action.
15

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) NONDUPLICATION

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

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

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

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

Subtitle C Site Identification Form―for the Hazardous Waste Report, the Notification of 

Regulated Waste Activity, and the RCRA Hazardous Waste Part A Permit Application. A 

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

verifies and updates the site identification information.

3(b) PUBLIC NOTICE

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

the Federal Register on March 29, 2011 (76 FR 17414). The notice indicated that this ICR 

would combine the ‘‘Notification of Regulated Waste Activity and 2011 Hazardous Waste 

Report’’ ICR and the ‘‘RCRA Hazardous Waste Permit Application and Modification, Part A’’ 

ICR. The notice also requested comments on some proposed changes to the Hazardous Waste 

Report form and instructions designed to clarify long-standing points of confusion. The public 

comment period extended through May 31, 2011. 

EPA received four written comments in response to the Federal Register notice. These 

comments were submitted by the following organizations: 

1. Idaho Department of Environmental Quality;

2. Illinois Environmental Protection Agency;

3. Ohio Environmental Protection Agency; and

4. Texas Commission on Environmental Quality.

The following paragraphs summarize the comments submitted by the above 

organizations, along with EPA’s responses.

(1) Scope of Hazardous Waste Reporting for Episodic Generators

In the Federal Register notice, EPA explained that episodic generators are those 

generators that fluctuate between one generator status and another (e.g., move from a SQG to a 

LQG) one or more times within a calendar year. However, it is unclear whether an episodic 

generator is required to report only the hazardous waste they generated during the months they

were an LQG or whether they are required to report all hazardous waste they generated during 

the reporting year. EPA requested public comment on modifying the Hazardous Waste 

instructions to better clarify that LQGs submitting a Hazardous Waste Report must report 

hazardous wastes they generated for all months of the reporting year. 
16

Summary of Comments: Two commenters indicated that interpretation of the current 

LQG regulations is that facilities are subject to the LQG requirements for the months of the year 

in which they are a LQG. They stated that a site should not be required to report waste 

generation activities for the months in which the site is a SQG, CESQG, or Inactive. One of 

these commenters also indicated that, in order to implement the proposed change, EPA would 

have to change the regulations for biennial reporting rather than change requirements in the 

Hazardous Waste Report instructions. The commenter further stated that Hazardous Waste 

Report instructions are supplemental and should complement, not contradict, the regulations.

EPA’s Response: EPA agrees with the concerns raised by commenters and therefore,

has eliminated the proposed change from the 2011 Hazardous Waste Report instructions and 

forms.

(2) Enhancement of Waste Minimization Code List

In the Federal Register notice, EPA explained that, in response to both existing and 

expanding objectives along with the regulatory reporting requirement, the Agency initiated an 

effort in the 2009 Hazardous Waste Report cycle to collect waste minimization data. After the 

2009 data reporting cycle was complete, some States felt that there were too few waste 

minimization codes to conduct meaningful analyses. Adding more detailed codes will help 

provide a better understanding of the dynamics, and trends associated with waste minimization 

and sustainable materials management nationally, regionally and by State, by industrial sector 

and by waste stream. 

Summary of Comments: Three commenters raised questions and concerns on various 

issues associated with the enhancement of the waste minimization code list. A summary of their 

comments, by issue, is presented below: 

Use of the waste minimization data

Two commenters indicated that EPA does not give a clear description of the proposed use 

of the waste minimization data and that, without a planned use, the additional reporting 

burden is not justifiable. One of these commenters also indicated that it appears that the 

current waste minimization code list satisfies the regulatory requirement and that an 

expanded code list would not improve compliance. 

One commenter indicated that they have completed analyses using Toxic Release 

Inventory (TRI) source reduction activity codes data that are similar to the waste 

minimization codes being proposed. Based on these analyses, the commenter feels that 

the limited scope of the 2009 waste minimization codes provides an inaccurate 

description of the overall waste reduction effort completed by a generator since most 

waste reduction efforts include a combination of activities that often change within the 

course of the reporting period. The commenter further states that the proposed reporting 

system fails to account for the complexity and process-specific nature of most hazardous 

waste generation processes.
17

Data on new and on-going waste minimization efforts

One commenter indicated that the emphasis should be on recognizing newly 

implemented or expanded projects, as opposed to reporting continuing projects that have 

permanently changed a production process or operating practice and result in no further 

waste minimization beyond the initial implementation. This commenter recommended 

changing the language in the Hazardous Waste Report instructions to make it clear that 

data on new efforts is being sought. The commenter also suggested that, if information 

will be collected on both new and on-going waste minimization efforts, the reporting 

system needs to be revised in order to distinguish between new and on-going efforts for a 

given reporting year or over numerous reporting years. This would require a new data 

field, which means that companies that translate their data into the reporting software are 

going to have to alter their software. The commenter believes it is necessary to weigh the 

burden versus benefit. 

Another commenter recommended that, in order to make the data useful, EPA should 

define a new baseline and require all ongoing and new projects to be reported for that 

year. In subsequent years, EPA should only collect new waste minimization projects. 

The commenter also recommended that all ongoing and new waste minimization 

activities be reported and that a waste minimization code be added which is descriptive of 

successful ongoing activity and the addition of new activities.

The third commenter indicated that, since all hazardous waste generators are required to 

have a waste minimization “program in place,” requiring the reporting of ongoing waste 

minimization efforts is somewhat redundant. Requiring the reporting of new waste 

minimization efforts might be useful in demonstrating an increase or decrease in the 

amount of waste minimization occurring. However, these data would provide little 

information beyond what could be obtained from measuring the total amount of 

hazardous waste generated and dividing this by the number of generators. Therefore, the 

need for reporting of whether the waste minimization activity is new or ongoing is of 

limited use and should be discontinued.

Definition of “source reduction” and “waste minimization” 

One commenter indicated that EPA should clarify the terms “source reduction” and 

“waste minimization.” The proposed definitions may lead to confusion as they do not 

define the difference between source reduction (pollution prevention) and waste 

minimization. The commenter also recommended excluding waste minimization codes 

A, B, C, D, F, G, and H to minimize the confusion of “source reduction” and “waste 

minimization” and to ensure that the codes used are reflective of data being collected on 

Form GM (i.e., waste generated).
18

Use of waste minimization data in trends analyses 

One commenter indicated that, if the waste minimization codes are going to be used for 

trend analysis as suggested in the background paper, EPA should provide at least one 

example of trend analysis that has been done already for other information on the reports 

(e.g., source codes, form codes).

EPA’s Response: EPA thanks the commenters for their suggestions and feedback. EPA 

has deferred revisions, if any, to the waste minimization code list until the 2013 Hazardous

Waste Report cycle in order to have adequate time to consider comments and conduct detailed 

analyses of the waste minimization data currently being collected. 

3(c) CONSULTATIONS

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

industry and States, or data from the Resource Conservation and Recovery Act Information 

(RCRAInfo) system4. In developing this current ICR, EPA carefully reviewed all of the ICR’s 

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

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

the Hazardous Waste Report. 

In conducting the consultations, EPA contacted the three State organizations identified in 

Table 3. 

Table 3

Organizations EPA Contacted during the Development of this ICR (June 2011)

Organization Contact Name Phone Number

Florida Department of Environmental Protection Jack Griffith (850) 245-8748

Illinois Environmental Protection Agency Hope Wright (217) 785-2361

Ohio Environmental Protection Agency Paula Canter (614) 644-2917

The following paragraphs summarize the feedback obtained on the burden associated 

with various Hazardous Waste Report activities.

 Reading the instructions. EPA was informed that, generally, the ICR’s original 

burden for reading the Hazardous Waste Report instructions (i.e., 2 hours per 

facility) was a realistic industry average. However, some revisions to this burden 

estimate were provided. Suggested burdens ranged from 1.25 hours to 5 hours. 

 

4

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

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

management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.
19

Based on the consultation information, the average burden for reading the 

Hazardous Waste Report instructions was estimated to be 2.76 hours per facility. 

 Gathering information and preparing Form GM manually. EPA was informed 

that, generally, the ICR’s original burden for gathering information and preparing 

a Form GM manually (i.e., 62 minutes per form) was not a realistic industry

average. Suggested burdens ranged from 75 minutes to 90 minutes. Based on the 

consultation information, the average burden for gathering data (e.g., review 

manifests and/or other compiled data) and completing Form GM by hand, by 

typewriter, or by key entering the data using a computer was estimated to be 72 

minutes per form. 

 Gathering information and preparing Form GM by automated method. EPA 

was informed that, generally, the ICR’s original burden for gathering information 

and preparing a Form GM by automated method (i.e., 10 minutes per form) was a 

realistic industry average. However, some revisions to this burden estimate were 

provided. Suggested burdens ranged from less than 1 minute to 15 minutes. 

Based on the consultation information, the average burden for completing Form 

GM using an in-house, commercial, or State-provided data system (e.g., computer 

software) was estimated to be 17 minutes per form. 

 Gathering information and preparing Form WR manually. EPA was informed 

that the ICR’s original burden for gathering information and preparing a Form 

WR manually (i.e., 48 minutes per form) was not a realistic industry average. 

Suggested burdens ranged from 15 minutes to 75 minutes. Based on the 

consultation information, the average burden for gathering data (e.g., review 

manifests and/or other compiled data) and completing Form WR by hand, by

typewriter, or by key entering the data using a computer was estimated to be 54 

minutes per form. 

 Gathering information and preparing Form WR by automated method. EPA 

was informed that, generally, the ICR’s original burden for gathering information 

and preparing a Form WR by automated method (i.e., 10 minutes per form) was a 

realistic industry average. However, some revisions to this burden estimate were 

provided. Suggested burdens ranged from less than 1 minute to 20 minutes. 

Based on the consultation information, the average burden for completing Form 

WR using an in-house, commercial, or State-provided data system (e.g., computer 

software) was estimated to be 19 minutes per form.

 Revisions to in-house or commercial data system. EPA was informed that the 

ICR’s original burden for revising in-house or commercial data systems to include 

new Hazardous Waste Report data items that are not part of a facility’s general 

business operations (i.e., 1 hour per facility) was a realistic industry average. 

Based on the consultation information, the average burden for revising in-house 

or commercial data systems for purposes of the Hazardous Waste Report was 

estimated to be 1 hour per facility.
20

 Submitting report to EPA or State. EPA was informed that, generally, the ICR’s 

original burden for submitting the Hazardous Waste Report to EPA or the State 

(i.e., 5 minutes per facility) was not a realistic industry average. Suggested hourly

burdens ranged from 10 minutes to 2 hours. Based on the consultation 

information, the average hourly burden for submitting the Hazardous Waste 

Report was estimated to be 1.34 hours per facility. 

The above feedback is reflected in the burden assumptions of this ICR, as appropriate. 

Detailed information on EPA’s assumptions regarding these and other activities are fully 

discussed in Section 6 of this document. 

3(d) EFFECTS OF LESS FREQUENT COLLECTION

EPA has carefully considered the information collection burden imposed by the 

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

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

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

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

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

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

human health and the environment.

(1) Hazardous Waste Report

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

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

frequent data collection.

(2) Notification of Regulated Waste Activity

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

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

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

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

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

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

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

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

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

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

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

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

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

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

notified EPA, as provided by section 273.32(a)(2) or 273.32(a)(3). Under sections 279.42, 
21

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

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

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

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

the statutory requirements of RCRA Section 3010.

(3) Part A Hazardous Waste Permit Application and Modification

A respondent's provision of information on a Part A Permit Application is essentially a 

one-time exercise that must occur when a facility is new or if an existing facility becomes subject 

to new permitting requirements. Subsequent revisions to the Part A Permit Application are 

necessary only if an interim status facility changes its ownership and/or process or management 

of wastes. EPA strongly believes that if the minimum requirements specified under the 

regulations are not met, neither the facilities nor EPA can ensure that hazardous wastes are being 

properly managed, and do not pose a serious threat to human health and the environment. 

3(e) GENERAL GUIDELINES

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

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

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

Quality Guidelines.

3(f) CONFIDENTIALITY

(1) Hazardous Waste Report

The Hazardous Waste Report requires businesses to provide information on various 

aspects of hazardous waste generation and management. Some businesses consider some of their 

hazardous waste information to be Confidential Business Information (CBI). A business may, if 

it desires, protect its Hazardous Waste Report information from public disclosure by asserting a 

claim of confidentiality covering all or part of its information. If a confidentiality claim were 

asserted, EPA will treat the information in accordance with the confidentiality regulations at

40 CFR Part 2, Subpart B. EPA also will ensure that the information collection procedures 

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

(2) Notification of Regulated Waste Activity

The Agency does not anticipate that businesses will assert a claim of confidentiality

covering all or part of the information submitted as part of their notifications. However, if a 

confidentiality claim were asserted, EPA will treat the information in accordance with the 

confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also will ensure that the 

information collection procedures comply with the Privacy Act of 1974 and the OMB 

Circular 108.
22

(3) Part A Hazardous Waste Permit Application and Modification

All information submitted in a Part A Permit Application or revision will be subject to 

public disclosure, without notice to the facility, in accordance with the Freedom of Information 

Act, 5 U.S.C. Section 552, and EPA Freedom of Information Regulations, 40 CFR Part 2. 

Because of the general nature of the information requested, only a few Part A Permit 

Applications to date have qualified for exemption to disclosure under the business confidentiality

exception. Claims of confidentiality must be clearly indicated on the forms and attachments, and 

must be accompanied, at the time of filing, by a written substantiation of the claim in accordance 

with 40 CFR Part 2, Subpart B (particularly the information described at 40 CFR 2.204(e)). 

Information that is determined to be confidential is placed in a secured "confidential file" for 

future use. Only persons with special clearance for confidential information have access to these 

files.

3(g) SENSITIVE QUESTIONS

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

requirements covered in this ICR.
23

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

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

associated with industries most likely affected by the information collection requirements 

covered in this ICR.

NAICS Code Description NAICS Code

Agriculture, Forestry, Fishing, and Hunting 11

Mining 21

Utilities 22

Construction 23

Manufacturing 31-33

Wholesale Trade 42

Retail Trade 44-45

Transportation and Warehousing 48-49

Information 51

Finance and Insurance 52

Real Estate, Rental, Leasing 53

Professional, Scientific, and Technical Services 54

Management of Companies and Enterprises 55

Administrative Support, Waste Management, and Remediation 56

Educational Services 61

Health Care and Social Assistance 62

Arts, Entertainment, Recreation 71

Accommodation and Food Services 72

Other Services 81

Public Administration 92

4(b) INFORMATION REQUESTED

(1) Hazardous Waste Report

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

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

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

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

Hazardous Waste Report.

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

is delegated to the States. States provide respondents with either the Federal form or a State 
24

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

State employs electronic methods for preparation and submittal of reports by regulated entities) 

into a database using off-the-shelf software packages which have been developed to support the 

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

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

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

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

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

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

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

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

(i) Data Items:

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

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

form collects information such as site name, EPA Identification Number, 

address, contact, and type of hazardous waste generation and management 

activities taking place at the site; it verifies their information, especially

the site’s generator status as the date of submission of the report. It

requires a certification signature for the submission of the report.

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

submitted by all respondents that generated or shipped large quantity

generator amounts of RCRA hazardous waste during the reporting year. 

This form collects information on each generated waste, including a 

narrative waste description, a waste characterization (waste codes, source, 

and form), quantity generated, and the method of waste management 

(whether managed on-site or shipped off-site).

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

by all sites that received RCRA hazardous waste from off-site during the 

reporting year. This form collects information on each waste received 

from off-site, including a narrative description of the waste, a brief waste 

characterization (e.g., waste codes), the EPA Identification Number of the 

off-site generator, the quantity of waste received, and the method of waste 

management.

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

rather, it is provided as an option for States to collect the names and 

addresses of transporters, generators that ship waste, and receivers of 

waste reported on Forms GM and WR where only the EPA Identification 

Number is listed.
25

(ii) Respondent Activities:

Facilities (i.e., LQGs and TSDFs) must perform the following activities, as 

applicable:

 Read the Hazardous Waste Report instructions.

 Gather information and complete Site ID Form.

 Gather information and complete Form GM.

 Gather information and complete Form WR.

 Gather information and complete Form OI if required by the State (Stateoptional form, not a Federal form).

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

and Territories).

 Maintain a copy of each form for three years.

State agencies must perform the following activities:

 Distribute Hazardous Waste Report forms and instructions. 

 Assist respondents. 

 Key entry of report submissions. 

 Perform quality assurance. 

(2) Notification of Regulated Waste Activity

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

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

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

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

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

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

RCRA Subtitle C Site Identification Form (EPA Form 8700-12) that includes the specified 

information at section 260.42(a)(1)-(10). 

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

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

then subsequently stops managing hazardous secondary materials in accordance with the 
26

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

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

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

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

hazardous secondary materials for at least one year

(i) Data Items:

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

information:

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

- The name and telephone number of a contact person; 

- The NAICS code of the facility;

- The exclusion under which the hazardous secondary materials will be 

managed (e.g., section 261.2(a)(2)(ii), section 261.4(a)(23), (24), 

and/or (25));

- For reclaimers and intermediate facilities managing hazardous 

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

whether the reclaimer or intermediate facility has financial assurance 

(not applicable for persons managing hazardous secondary materials 

generated and reclaimed under the control of the generator); 

- When the facility expects to begin managing the hazardous secondary

materials in accordance with the exclusion;

- A list of hazardous secondary materials that will be managed 

according to the exclusion (reported as the EPA hazardous waste 

numbers that would apply if the hazardous secondary materials were 

managed as hazardous wastes); 

- For each hazardous secondary material, whether the hazardous 

secondary material, or any portion thereof, will be managed in a landbased unit;

- The quantity of each hazardous secondary material to be managed 

annually; and

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

an authorized representative of the facility.

(ii) Respondent Activities:

Facilities must perform the following activities, as applicable:

 Complete and submit EPA Form 8700-12 prior to operating under 

exclusion(s).

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

numbered year thereafter.
27

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

secondary materials are no longer managed in accordance with the 

exclusion, if applicable. 

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

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

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

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

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

complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12).

(i) Data Item:

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

information:

- Name of the facility;

- Facility mailing address;

- Facility location;

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

be contacted regarding information on the form;

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

of the facility;

- Information on the type of hazardous waste activity;

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

notification;

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

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

representative.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700-12.

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

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

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

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

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

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

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

must notify that it is electing to be subject to the requirements of Subpart K for all the 
28

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

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

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

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

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

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

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

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

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

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

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

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

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

Subpart K.

(i) Data Items:

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

out, at a minimum:

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;

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

the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

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

university, as specified under section 262.203(d). 

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

university, as specified under section 262.203(e). 
29

(ii) Respondent Activities:

Facilities must perform the following activities, as applicable:

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

Subpart K must perform the following:

- Complete and submit EPA Form 8700-12; and

- Keep a copy of the notification on file.

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

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

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

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

must:

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

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

laboratories are subject to Subpart K.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

notification.

(i) Data Items:

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

- Reason for submittal;

- Site EPA Identification Number (except for CESQGs);

- Site name;

- Site location information;

- Site land type;
30

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

the site;

- Site mailing address;

- Site contact person;

- Operator and legal owner of the site;

- Type of regulated waste activity; and

- Certification.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Complete and submit EPA Form 8700-12.

 Keep a copy of the withdrawal notice on file.

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

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

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

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

quantity handlers of universal waste must complete and submit the RCRA Subtitle C Site 

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

EPA Identification Number. 

(i) Data Items:

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

- Name of the facility;

- Facility mailing address;

- Facility location;

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

be contacted regarding information on the form;

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

of the facility;

- Information on the type of hazardous waste activity;

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

notification;

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

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

representative.

Or
31

 A letter that includes:

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

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

contacted regarding the universal waste management activities;

- Address or physical location of the universal waste management 

activities;

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

and

- A statement indicating that the handler is accumulating more than 

5,000 kilograms of universal waste at one time and the types of

universal waste (e.g., batteries, pesticides, thermostats) the handler is 

accumulating above this quantity.

(ii) Respondent Activities:

Facilities must perform the following activities:

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

Identification Number.

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

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

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

order to comply with these requirements, used oil handlers must complete and submit the RCRA 

Subtitle C Site Identification Form (EPA Form 8700-12), or complete and submit a letter to EPA 

requesting an EPA Identification Number. 

(i) Data Items:

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

information:

- Name of the facility;

- Facility mailing address;

- Facility location;

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

be contacted regarding information on the form;

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

of the facility;

- Information on the type of hazardous waste activity;

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

notification;

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

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

representative.
32

Or

 A letter that includes:

- Company name;

- Owner of company;

- Mailing address of company;

- Name and telephone number of company contact;

- Type of used oil management activity(ies);

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

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

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

(ii) Respondent Activities:

Facilities must perform the following activities:

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

Identification Number.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

(a1) Contents of the Part A Permit Application

40 CFR 270.1 requires owners or operators of newly regulated facilities subject to 

permitting requirements for the first time and permitted facilities with newly regulated units to 

prepare and submit a Part A Permit Application (EPA Form 8700-23). 

(i) Data Items:

 A list of the activities conducted by the applicant that require the owner or 

operator to obtain a RCRA permit.

 Name, mailing address, and location, including latitude and longitude of 

the facility for which the application is submitted.

 Up to four NAICS codes that best reflect the principal products or services 

provided by the facility.

 Operator's name, address, telephone number, ownership status, and status 

as Federal, State, private, public or other entity.

 Name, address, and phone number of the owner of the facility.

 Whether the facility is located on Indian lands.
33

 An indication of whether the facility is new or existing and whether it is a 

first or revised application.

 For existing facilities, the following information:

 A scale drawing of the facility showing the location of all past, 

present, and future treatment, storage, and disposal areas and

 Photographs of the facility clearly delineating all existing structures; 

existing treatment, storage and disposal areas; and sites of future 

treatment, storage, and disposal areas;

 A description of the processes to be used for treating, storing, and 

disposing of hazardous waste, and the design capacity of these items.

 A specification of the hazardous wastes listed or designated under 40 CFR 

Part 261 to be treated, stored, or disposed of at the facility; an estimate of 

the quantity of such wastes to be treated, stored, or disposed annually; and 

a general description of the processes to be used for such wastes.

 A listing of all permits or construction approvals received or applied for 

under any of the following programs:

 Hazardous Waste Management program under RCRA

 Underground Injection Control (UIC) Program under the Safe 

Drinking Water Act (SDWA)

 National Pollutant Discharge Elimination System (NPDES) program 

under the Clean Water Act (CWA)

 Prevention of Significant Deterioration (PSD) program under the 

Clean Air Act (CAA)

 Nonattainment program under the CAA

 National Emission Standards for Hazardous Air Pollutants 

(NESHAPS) preconstruction approval under the CAA

 Ocean dumping permits under the Marine Protection Research and 

Sanctuaries Act

 Dredge or fill permits under section 404 of the CWA

 Other relevant environmental permits, including State permits.

 A topographic map (or other map if a topographic map is unavailable) 

extending one mile beyond the property boundaries of the source, 

depicting the following aspects of the facility:

 Each of its intake and discharge structures; 

 Each of its hazardous waste treatment, storage, or disposal facilities; 

 Each well where fluids from the facility are injected underground; and 

 Wells, springs, other surface water bodies, and drinking water wells 

listed in public records or otherwise known to the applicant within 1/4 

mile of the facility property boundary.
34

 A brief description of the nature of the business.

 For hazardous debris, a description of the debris category(ies) and 

containment category(ies) to be treated, stored, or disposed of at the 

facility.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Read the regulations and instructions.

 Prepare the Site ID Form.

 Prepare the Hazardous Waste Permit Information Form and reports.

(a2) Signatories to Permit Applications and Permit Application Reports

40 CFR 270.11(a) requires operators of facilities to obtain the necessary signatures and 

certifications for the Part A Permit Application, reports, and other information requested by 

EPA. Additionally, operators must obtain new authorization for authorizations deemed invalid.

(i) Data Items:

 Signatures required on Part A Permit Applications:

 For a corporation, the signature of a responsible corporate officer as 

defined at 40 CFR 270.11(a)(1).

 For a partnership or sole proprietorship, the signature of a general 

partner or proprietor as defined at 40 CFR 270.11(a)(2).

 For a municipality, State, Federal, or other public agency, the signature 

of either a principal executive officer or ranking elected official as 

defined at 40 CFR 270.11(a)(3).

 Signatures for reports required by permits and other information requested 

by the Director:

 For a corporation, the signature of a responsible corporate officer as 

defined at 40 CFR 270.11(a)(1).

 For a partnership or sole proprietorship, the signature of a general 

partner or proprietor as defined at 40 CFR 270.11(a)(2).

 For a municipality, State, Federal, or other public agency, the signature 

of either a principal executive officer or ranking elected official as 

defined at 40 CFR 270.11(a)(3).

 Signature of a duly authorized representative of one of the persons 

listed above as defined at 40 CFR 270.11(b).
35

 New authorization satisfying the requirements of 40 CFR 270.11(b) if an 

authorization under 40 CFR 270.11(b) is no longer accurate because a 

different individual or position has responsibility for the overall operation 

of the facility. Data items for this requirement are the same as those under 

40 CFR 270.11(b).

 Certification:

I certify under penalty of law that this document and all attachments were 

prepared under my direction or supervision in accordance with a system 

designed to assure that qualified personnel properly gather and evaluate 

the information submitted. Based on my inquiry of the person or persons 

who manage the system, or those persons directly responsible for 

gathering the information, the information submitted is to be the best of 

my knowledge and belief, true, accurate, and complete. I am aware that 

there are significant penalties for submitting false information, including 

possibility of fine and imprisonment for knowing violations.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Obtain signatures and certifications for the Part A Permit Application, 

reports, and other information requested by EPA.

 Obtain a new authorization for invalid authorizations.

(a3) Submittal of Part A Permit Application

40 CFR 270.70(b) requires owners and operators who submit a Part A Permit Application 

to EPA, to explain or cure an alleged deficiency in the Part A Permit Application, if EPA notifies 

the applicant that the application fails to meet the requirements of 40 CFR 270.13.

(i) Data Items:

 Part A Permit Application and reports.

 Explanation of alleged deficiency in the Part A Permit Application.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Submit the Part A Permit Application and reports.
36

 Explain or cure an alleged deficiency in the Part A Permit Application, if 

required.

State agencies must perform the following activities:

 Review information contained in the application.

 Ensure that the Part A Permit Application and associated reports are 

signed by the appropriate person.

 Review newly authorized signatures when a different individual or 

position gains responsibility for the overall operation of a facility.

 Review signature certifications.

 Enter information into the RCRAInfo database. 

 Notify applicant of deficiency in the Part A Permit Application.

(b) Revised Part A Permit Applications and Associated Justifications and 

Subpart H Compliance Demonstrations

Under 40 CFR 270.72, interim status facilities must prepare and submit a revised Part A 

Permit Application if the Agency promulgates a rulemaking that affects the facility, or if the 

owner/operator otherwise modifies the facility. Interim status facilities who modify their Part A 

Permit Application are required to submit a revised Part A Permit Application.

(i) Data Items:

 Part A application using EPA Form 8700-23.

(ii) Respondent Activities:

Facilities must perform the following activities:

 Read the regulations and instructions in preparation for revising a Part A 

Permit Application in response to an Agency rulemaking or a facility

modification.

 Prepare and submit a revised Part A Permit Application in response to an 

Agency rulemaking or facility modification.

 Prepare and submit justifications for changes, if needed.

 Submit Subpart H compliance demonstrations, if needed.
37

State agencies must perform the following activities:

 Review information revised Part A Permit Application.

 Enter revised Part A Permit Application information into the RCRAInfo 

database.

 Review justifications for changes.

 Review Subpart H compliance demonstrations.
38

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Hazardous Waste Report

As discussed in Section 4(b) of this document, the Hazardous Waste Report data 

collection process is delegated to the States. However, EPA is involved throughout this process. 

The extent of EPA’s involvement depends on the activities performed by the States in the data 

collection process. The following paragraphs briefly describe EPA’s participation in the data 

collection process.

In some cases, the EPA Region performs all of the State roles. That is, EPA Regions,

where the Region implements the RCRA hazardous waste program for a State, provide 

respondents with the Federal form, collect the responses, contact non-respondents, enter the data 

into a database using off-the-shelf software packages which have been developed to support the 

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

Headquarters.

In other cases, the EPA Region provides direct processing support for some, but not all, 

of the collection activities. For example, the EPA Region may support the State in data 

gathering and data quality assessment. 

In still other cases, the EPA Regions provide additional resources to the States. For 

example, the EPA Region may provide technical support to States for the transfer of their files to 

EPA for incorporation into the national database. 

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

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

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

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

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

EPA activities for the Hazardous Waste Report include the following:

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

copies.

 Distribute Hazardous Waste Report forms and instructions. EPA Headquarters 

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

prepare mailing lists, mail forms and instructions, record receipt of completed 

forms, and contact sites that fail to respond within the specified time period. 
39

 Develop computer capabilities required to compile national data. EPA 

Headquarters develops the computer capabilities required to load data into the 

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

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

 Assist respondents. EPA Regions and Headquarters provide assistance to 

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

respondent questions and assistance, where applicable.

 Key entry of report submissions. EPA Regions and the regulated entities, key

enter or electronically load the data into a database they select and maintain. The 

data entry function was privatized for the 1999 Hazardous Waste Report process. 

Many States, Regions, and the regulated community use one of the private 

vendor’s software packages for data entry and recordkeeping. Some reports are 

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

on diskettes.

 Perform quality assurance. EPA Regions and Headquarters perform data quality

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

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

instructions); verification of exceptional responses (e.g., data reported by a 

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

respondent universe) and identification of significant response changes between 

reporting years. The national software supports these activities with a variety of 

data editing functions.

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

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

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

correct data type and within allowed ranges).

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

identify any potential over or under reporting (exception reports support 

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

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

shipments of wastes to identify potential discrepancies between reports submitted 

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

of the waste.

Based on the assessments, EPA Regions identify cases where accuracy may be 

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

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

the site intends to submit an amended report to correct discrepancies. 
40

 Prepare the national report. EPA Headquarters will prepare The National 

Biennial RCRA Hazardous Waste Report that will be made available to the 

Congress and the public.

 Store the data. The Hazardous Waste Reports will be stored by the EPA Regions 

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

The national database is maintained by EPA Headquarters in RCRAInfo.

(2) Notification of Regulated Waste Activity

EPA activities are the same for all of the notification requirements covered in this ICR. 

These activities include:

 For initial notifications:

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

Identification Number, as specified.

- Entering information into the EPA national data system.

- Generating an EPA Identification Number and sending the EPA Identification 

Number to the facility.

 For subsequent notifications:

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

Identification Number, as specified.

- Entering information into the EPA national data system.

(3) Part A Hazardous Waste Permit Application and Modification

EPA activities associated with Part A Permit Applications include the following:

 For Part A Permit Applications:

 Reviewing information contained in the application.

 Ensuring that the Part A Permit Application and associated reports are signed 

by the appropriate person.

 Reviewing newly authorized signatures when a different individual or position 

gains responsibility for the overall operation of a facility.

 Reviewing signature certifications.

 Entering information into the RCRAInfo database. 

 Notifying applicant of deficiency in the Part A Permit Application.

 For revised Part A Permit Applications, justifications, and compliance 

demonstrations:

 Review information revised Part A Permit Application.

 Enter revised Part A Permit Application information into the RCRAInfo 

database.

 Review justifications for changes.

 Review Subpart H compliance demonstrations.
41

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

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

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

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

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

5(c) SMALL ENTITY FLEXIBILITY

(1) Hazardous Waste Report

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

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

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

requirements.

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

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

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

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

(2) Notification of Regulated Waste Activity

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

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

requirements of RCRA.

(3) Part A Hazardous Waste Permit Application and Modification

Interim status is statutorily conferred without regard to facility size. Therefore, EPA 

believes that requirements regarding Part A submissions and revisions must apply equally to 

large and small businesses. Although the legal requirements for Part A Permit Application 

information are the same for large and small businesses, the Agency believes that in practice the 

small entities will find it easier to provide the required information. In many instances, a small 

organization will be able to complete or revise the Part A Permit Application in less time than 

larger organizations because they use fewer processes for the management of hazardous wastes 

and they manage fewer types of wastes. As a rule of thumb, the complexity of preparing a Part 

A Permit Application depends upon the complexity of the processes of a hazardous waste facility

and the wastes managed at the facility. Therefore, if a small organization operates a complex 

facility (e.g., a chemical landfill that manages a very large number of waste streams), then the 

time to complete the Part A Permit Application will necessarily be greater. Again, EPA has 

taken steps to minimize the burden on all respondents by providing detailed instructions for 

completion of the Part A Permit Application form and by requiring short answer responses to 

most of the items of the application. 
42

It also should be noted that the reporting requirements for changes are brief. Therefore, 

owners or operators can easily comply with these requirements. In addition, most of the 

revisions to Part A Permit Applications will entail merely checking boxes or filling in numbers 

to indicate the type of new activity or new waste to be handled at the facility. Any written 

justification entails a short letter from the owner or operator. EPA, therefore, estimates that the 

potential burden on small businesses caused by this information collection is minimal.

5(d) COLLECTION SCHEDULE

(1) Hazardous Waste Report

EPA’s 2011 Hazardous Waste Report national implementation schedule is outlined in 

Table 4.

Table 4

2011 Hazardous Waste Report National Implementation Schedule

Activity Completion Date

Implementers begin loading 2011 Hazardous Waste Report data into RCRAInfo

Biennial Report National Data Quality Reports & National Exhibit Reports 

available for use in performing additional data quality checks

April 2, 2012

DEADLINE for implementers to load complete data into RCRAInfo for EPA 

Headquarter’s national data quality check

Review work and publication of the Preliminary 2011 National Biennial Report

July 2, 2012

EPA Headquarters publishes Preliminary 2011 National Biennial Report (only 

posted in RCRAInfo) August 6, 2012

Last day to request a State Summary Report from EPA Headquarters October 1, 2012

DEADLINE for implementers to load FINAL data into RCRAInfo for EPA 

Headquarters to perform final quality assurance/quality control of final data November 5, 2012

EPA Headquarters makes Final 2011 National Biennial Report data available on 

RCRAInfo Web (public Web site)

December 10, 2012
43

(2) Notification of Regulated Waste Activity

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

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

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

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

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

must submit notification to EPA within 30 days.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

eligible academic entity must submit a separate notification (Site ID Form) for each EPA 
44

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

Subpart K. This is a one-time notification.

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

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

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

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

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

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

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

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

Subpart K.

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

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

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

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

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

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

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

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

Subpart K. This is a one-time notification.

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

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

notification.

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

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

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

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

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

273.32(a)(3).

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

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

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

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

and obtain an EPA Identification Number.
45

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

Owners or operators of new hazardous waste management facilities that are not yet 

constructed are required to submit their Part A Permit Application, including signatures and 

certifications at least 180 days before physical construction is expected to commence. For 

existing facilities newly subject to RCRA permitting requirements due to promulgation of a new 

regulation or listing of hazardous waste, the new regulation typically specifies the date by which 

Part A Permit Applications, including signatures and certifications, must be submitted.

(b) Revised Part A Permit Applications and Associated Justifications and 

Subpart H Compliance Demonstrations

The time frame in which owners or operators must submit a revised Part A Permit 

Application varies according to the nature of changes at the facility. For the following types of 

changes, the owner or operator must submit revised Part A Permit Applications and justifications 

prior to making the changes:

 Treating, storing, or disposing of hazardous wastes not previously identified in the 

Part A Permit Application.

 Increasing the design capacity of processes used at the facility.

 Changing or adding processes for treating, storing, or disposing of hazardous 

wastes. 

For changes in ownership or operational control of a facility, the new owner or operator 

must submit a revised Part A Permit Application no later than 90 days prior to the scheduled 

change. Subpart H compliance demonstrations must be submitted within six months of the date 

of the change in ownership or operational control of the facility.
46

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibits 1 through 3 provide estimates of the respondent hourly burden associated with 

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

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

The majority of the hour estimates in Exhibits 1 through 3 are based on consultations with 

industry and States.

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

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

(1) Hazardous Waste Report

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

States

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

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

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

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

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

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

(i.e., completing a blank form manually) to be 1 hour per respondent.

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

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

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

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

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

derive an overall weighted-average burden. 

Table 5

Assumptions and Weighted-Average Equation Used in Estimating Burden to

Complete the Site Identification Form of the Hazardous Waste Report

Assumptions Weighted-Average Equation

0.33 hours to complete pre-populated form; 

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

= 0.56 hours 1 hour to complete blank form;

35 percent of the forms are blank
47

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

Reporting

During consultations conducted during the development of this ICR, State and facility 

representatives indicated that Forms GM and WR often can be completed from databases that 

track manifests or other information for billing purposes. Based on these consultations, EPA 

estimated the hourly burden for the Forms GM and WR submitted electronically to be 

significantly less than for forms submitted on paper.

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

EPA used information gained from consultations and 2009 Hazardous Waste Report data. For 

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

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

likely to do so electronically. Using 2009 Hazardous Waste Report data5, EPA identified sites 

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

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

EPA estimates that 92 percent of Forms GM are submitted electronically, while the remaining 

8 percent are sent manually.

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

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

submit Hazardous Waste Report data electronically. Using 2009 Hazardous Waste Report data6, 

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

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

WR are submitted electronically. 

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

used the weighted-average calculations in Table 6. EPA multiplied the percentage of both forms 

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

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

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

burden for both forms. 

 

5

 2009 Hazardous Waste Report (i.e., 2009 Biennial Report) data used in this analysis are current as of 

April 12-29, 2011.

6

 2009 Hazardous Waste Report (i.e., 2009 Biennial Report) data used in this analysis are current as of 

April 12-29, 2011.
48

Table 6

Assumptions and Weighted-Average Equations Used in Estimating Burden to

Complete Form GM and Form WR of the Hazardous Waste Report

Activity Assumptions Weighted-Average Equation

Complete

Form GM

0.28 hour to complete electronically; 

92 percent of the forms are completed electronically

1.20 hours to complete manually; 

8 percent of the forms are completed manually

(0.28 hr x 0.92) + (1.20 hrs x 0.08)

= 0.36 hour

Complete

Form WR

0.12 hour to complete electronically; 

100% of the forms are completed electronically

0.12 hr x 1

= 0.12 hour

(2) Notification of Regulated Waste Activity

During consultations conducted during the development of previous versions of this ICR, 

EPA contacted industry representatives to ascertain their burden for completing the Site ID Form 

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

Form for each notification and their burdens ranged from 5 minutes to 3 hours per submittal. 

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

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

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

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

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

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

Item 14-Certification.

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

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

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

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

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

collected, are discussed in the paragraphs below.

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

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

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

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

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

State prior to operating under the exclusion and by March 1 of each even numbered year. EPA 
49

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

complying with these notification requirements. 

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

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

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

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

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

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

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

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

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

to be 20 minutes (0.33 hour) per respondent. 

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

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

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

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

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

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

Table 7

Assumptions and Weighted-Average Equation

Used in Estimating Burden to Complete the Notification of

Hazardous Secondary Material Activity under 40 CFR 260.42

Assumptions Weighted-Average Equation

Notification Prior to Operating under Exclusion AND

Notification Submitted by March 1 of Each Even Numbered Year Thereafter

1.5 hours to complete blank form;

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

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

50 percent of the facilities

Notification Indicating that Hazardous Secondary Materials are no Longer Managed in 

Accordance to the Exclusion

1 hour to complete blank form;

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

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

50 percent of the facilities
50

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

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

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

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

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

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

requirements. 

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

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

(0.33 hour) per respondent. 

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

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

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

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

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

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

Table 8

Assumptions and Weighted-Average Equation

Used in Estimating Burden to Complete the Notification of

Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Assumptions Weighted-Average Equation

1 hour to complete blank form;

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

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

50 percent of the facilities

(c) Other Notifications Covered in this ICR

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

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

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

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

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

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

per respondent. 
51

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

derived the weighted averages using the calculations in Table 9 below. EPA multiplied the 

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

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

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

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

Table 9

Assumptions and Weighted-Average Equation Used in

Estimating Burden to Complete Other Notifications Covered in this ICR

Assumptions Weighted-Average Equation

1 hour to complete blank form;

50 percent of the facilities

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

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

50 percent of the facilities

(3) Part A Hazardous Waste Permit Application and Modification

In estimating the hourly burden for preparing the Site ID Form of the Part A Permit 

Application, EPA assumes that all of the facilities submitting a Part A Permit Application or 

Modification during the two-year period covered by this ICR have already submitted the Site ID 

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

ID Form and the remaining 50 percent will use their most recently submitted Site ID Form. 

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

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

per respondent. 

The above burden estimates are reflected in Exhibit 3 as weighted-averages. EPA 

derived the weighted averages using the calculations in Table 10 below. EPA multiplied the 

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

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

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

contained in the form. Then, EPA added up these two products to derive an overall weightedaverage burden. 
52

Table 10

Assumptions and Weighted-Average Equation Used in Estimating

Burden to Complete the Site Identification Form of the Part A Permit Application

Assumptions Weighted-Average Equation

1 hour to complete blank form;

50 percent of the facilities

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

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

50 percent of the facilities

6(b) ESTIMATING RESPONDENT COSTS

Exhibits 1 through 3 provide estimates of the annual respondent costs associated with the 

information collection requirements covered in this ICR. These costs are based on the cost of 

labor, capital, and operation and maintenance (O&M). 

(1) Labor Costs

Using the total burden hours discussed in Section 6(a) and the hourly labor costs outlined 

in this section, Exhibits 1 through 3 illustrate the labor costs associated with the information 

collection requirements covered in this ICR.

(a) Private Sector Facilities

EPA estimates an average hourly respondent labor cost (including fringe and overhead) 

of $122.72 for legal staff, $72.54 for managerial staff, $54.04 for technical staff, and $32.51 for 

clerical staff. These respondent labor costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.14, dated September 10, 2009), and updated to 2011 levels using 

Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.7

 

7

 Bureau of Labor Statistics, “Table 4. Employment Cost Index for total compensation, for civilian 

workers, by occupational and industry,” Employment Cost Index - Historical Listing, March 2011. Available online 

at: http://www.bls.gov/web/eci/ecicois.pdf, last accessed on May 16, 2011. Civilian Workers, All Workers, 

June 2009=110.2 and March 2011=114.0.
53

(b) State and Local Government Facilities and Agencies

EPA estimates an average hourly respondent labor cost (including fringe and overhead) 

of $57.54 for legal staff, $54.02 for managerial staff, $32.32 for technical staff, and $20.62 for 

clerical staff. These respondent labor costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.14, dated September 10, 2009), and updated to 2011 levels using 

Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.8

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. EPA does not anticipate that 

respondents will incur capital costs in carrying out the information collection requirements 

covered in this ICR.

(3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement 

incurred continually over the life of the ICR. For this ICR, O&M costs include mailing costs:

 EPA estimates that facilities submitting a Hazardous Waste Report or a Part A 

Permit Application to EPA or States will incur a cost of $5.82 to mail an 11-ounce 

large envelope by certified mail ($2.88 for postage, $2.85 for the certified-mail 

fee, and $0.09 for a catalog envelope).9, 10, 11

 EPA estimates that facilities submitting a notification to EPA will incur a cost of 

$3.31 to mail a one-ounce letter by certified mail (i.e., $0.44 for first-class letter 

postage, $2.85 for the certified-mail fee, and $0.02 for standard business 

envelope).12, 13, 14

 

8

 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation, for State and local 

government workers, by occupational and industry,” Employment Cost Index - Historical Listing, March 2011. 

Available online at: http://www.bls.gov/web/eci/ecicois.pdf, last accessed on May 16, 2011. State and Local 

Government Workers, All Workers, June 2009=112.8 and March 2011=116.6.

9

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on July 7, 2011.

10

 U.S. Postal Service; “Extra Services Prices.” Available online at: http://www.usps.com/prices/extraservices-prices.htm, last accessed on July 7, 2011.

11

 Catalog envelope cost based on current market price, as of July 7, 2011 (i.e., box of 100 catalog 

envelopes with gummed closure at $8.79). 

12

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on July 7, 2011.

13

 U.S. Postal Service; “Extra Services Prices.” Available online at: http://www.usps.com/prices/extraservices-prices.htm, last accessed on July 7, 2011.

14

 Standard business envelope cost based on current market price, as of July 7, 2011 (i.e., box of 500 

standard business envelopes with gummed closure at $8.99). 
54

 EPA estimates that State agencies distributing the Hazardous Waste Report to 

facilities will incur a cost of $2.97 to mail an 11-ounce large envelope ($2.88 for 

postage and $0.09 for a catalog envelope).15, 16

The above O&M costs are shown in Exhibits 1 through 3 for all applicable respondent 

activities.

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN

EPA estimates the Agency hour and cost burden associated with the information 

collection requirements covered in this ICR in Exhibits 4 through 6. As shown in the exhibits, 

EPA estimates an average hourly labor cost of $86.56 for legal staff (GS15, Step 5), $76.38 for 

managerial staff (GS-15, Step 1), $54.94 for technical staff (GS-13, Step 1), and $23.44 for 

clerical staff (GS-06, Step 1). To derive these hourly estimates, EPA referred to the General

Schedule (GS) Salary Table 2011. This publication summarizes the unloaded (base) hourly rate 

for various labor categories in the Federal Government. EPA then applied the standard 

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

EPA does not anticipate that the Agency will incur capital costs in carrying out the 

information collection requirements covered in this ICR.

O&M costs are associated with Hazardous Waste Report activities. In particular, EPA 

estimates that the Agency will incur a cost of $20,920 in printing paper and CD copies of the 

Hazardous Waste Report forms and instructions, $261,500 in developing computer capabilities 

required to compile national data, $52,300 in preparing the National Report, and $36,610 in 

storing the national data. These O&M costs were obtained from the previously approved ICR 

(i.e., EPA ICR Number 0976.14, dated September 10, 2009), and updated to 2011 levels using 

Consumer Price Indexes developed by the Bureau of Labor Statistics.17 EPA O&M costs are

shown in Exhibit 4 for all applicable activities.

 

15

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: http://www.usps.com/prices/firstclass-mail-prices.htm, last accessed on July 7, 2011.

16

 Catalog envelope cost based on current market price, as of July 7, 2011 (i.e., box of 100 catalog 

envelopes with gummed closure at $8.79). 

17

 Bureau of Labor Statistics, Table Containing History of CPI-U U.S. All Items Indexes and Annual 

Percent Changes From 1913 to Present, June 15, 2011. Available online at: 

ftp://ftp.bls.gov/pub/special.requests/cpi/cpiai.txt, last accessed on July 7, 2011. All items, September 

2009=215.969 and May 2011=225.964.
55

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND 

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then 

estimates the annual burden to respondents under the information collection requirements 

covered in this ICR. 

EPA notes that, as used in this document, the term “respondent” includes:

 Hazardous waste facilities complying with the Hazardous Waste Report, 

notification, and Part A Permit Application requirements covered in this ICR. 

This includes:

 Private sector entities; and

 State and local government agencies that are regulated entities18.

 State agencies administering the RCRA hazardous waste program19. 

(1) Respondent Universe

(a) Hazardous Waste Report

Based on 2009 Hazardous Waste Report data20, EPA estimates that the total number of 

respondents to the 2011 Hazardous Waste Report will be 21,066, which annualized over the twoyear report cycle equals 10,533 per year (i.e., 21,066/2). Table 11 presents information on the 

total number of forms associated with the 2011 Hazardous Waste Report. In estimating annual 

respondent burden and cost, EPA annualized these numbers over the two-year report cycle.

 

18

 Addressing State and local government agencies as “respondents” is consistent with EPA’s 

interpretation of the definition of respondent in the Paperwork Reduction Act (PRA).

19

 Ibid.

20

 2009 Hazardous Waste Report (i.e., 2009 Biennial Report) data used in this analysis are current as of 

April 12-29, 2011.
56

Table 11

Total Number of 2011 Hazardous Waste Report Forms

Hazardous Waste Report Form

Number of Forms a

Private 

Sector

State and 

Local 

Government

Total

Site Identification (Site ID) Form 18,976 2,090 21,066

Form GM - Generation and Management 189,528 16,504 206,032

Form WR - Waste Received from Offsite 1,018,988 18,011 1,036,999

Total 1,227,492 36,605 1,264,097

a

 Based on 2009 Hazardous Waste Report (i.e., 2009 Biennial Report) data current as of April 12-29, 2011.

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

Exhibit 1. These estimates assume that all forms are submitted in accordance with the 

Hazardous Waste Report instructions. Exhibit 1 also estimates the annual respondent burden and 

cost for the activities examined.

(b) Notification of Regulated Waste Activity

In estimating the number of respondents subject to the notification requirements covered 

in this ICR, EPA referred to RCRAInfo. EPA estimated the annual number of notifications 

tracked by RCRAInfo. EPA then averaged the number of notifications submitted in 2009 and 

2010. These estimates are presented in Table 12 and used to estimate the total respondent 

burden and costs per information collection activity shown in Exhibit 2 of this ICR.

(c) Part A Hazardous Waste Permit Application and Modification

In estimating the number of respondents subject to the Part A Permit Application 

requirements covered in this ICR, EPA referred to the RCRAInfo system. EPA estimated the 

annual number of Part A Permit Applications tracked by RCRAInfo. EPA then averaged the 

number of applications submitted in 2009 and 2010. These estimates are presented in Table 13

and used to estimate the total respondent burden and costs per information collection activity

shown in Exhibit 3 of this ICR.
Table 12

Annual Number of Respondents Subject to the Notification Requirements Covered in this ICR a

Respondent Universe

Year 2009 Year 2010 Average of Years 2009 and 2010

Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Number of facilities submitting notification prior 

to operating under exclusion 23 0 23 23 2 25 23 1 24

Number of small quantity generators (SQGs) and 

conditionally-exempt small quantity generators 

(CESQGs) submitting notification by March 1 of 

each even numbered year thereafter

0 0 0 7 0 7 4 0 4

Number of facilities submitting notification 

indicating that they will no longer manage 

hazardous secondary materials in accordance 

with the exclusion

0 0 0 3 0 3 2 0 2

Notification of Hazardous Waste Activity under RCRA Section 3010

Number of facilities submitting initial notification 7,760 1,695 9,455 8,158 1,313 9,471 7,959 1,504 9,463

Number of facilities submitting subsequent 

notification 34,641 2,288 36,929 33,295 1,889 35,184 33,968 2,089 36,057

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

Number of eligible academic entities submitting 

notification of intent to comply with Subpart K 

and recordkeeping of agreements

Not 

Available

Not

Available

Not

Available 6 2 8 6 2 8

Number of teaching hospitals not owned by a 

college or university opting into Subpart K

Not 

Available

Not

Available

Not

Available 0 0 0 0 0 0

Number of non-profit research institutes not 

owned by a college or university opting into 

Subpart K

Not 

Available

Not

Available

Not

Available 1 0 1 1 0 1

Number of eligible academic entities submitting 

notification of withdrawal from 40 CFR Part 262, 

Subpart K

Not 

Available

Not

Available

Not

Available 0 0 0 0 0 0
Table 12 (continued)

Annual Number of Respondents Subject to the Notification Requirements Covered in this ICR a

58

Respondent Universe

Year 2009 Year 2010 Average of Years 2009 and 2010

Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total

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

Number of facilities submitting initial notification 54 20 74 68 17 85 61 19 80

Number of facilities submitting subsequent 

notification 80 3 83 60 5 65 70 4 74

Notification of Used Oil Activity under 40 CFR Part 279

Number of facilities submitting initial notification 99 1 100 122 4 126 111 3 114

Number of facilities submitting subsequent 

notification 180 5 185 217 12 229 199 9 208

a

 Based on data from two RCRAInfo tables: (1) “Hhandler,” (2) “Howner_operator,” (3) “Huniversal_waste,” and (4) “Hhsm_basic.” All tables contain data current as of April 27, 2011.

b

 Includes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facility cannot be owned or operated by a Federal, State, or local 

government. For example, a facility owned by a State government and operated by a private entity would qualify as a “State and local government” facility, not as a “private” facility.

c

 Includes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in order to qualify as “State and local government,” the facility cannot 

be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Municipal government would qualify as a “Federal 

government” facility, not a “State and local government” facility.
59

Table 13

Annual Number of Respondents Subject to the Part A Permit Application Requirements Covered in this ICR a

Respondent

Universe

Year 2009 Year 2010 Average of Years 2009 and 2010

Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total Private

Sector b

State and

Local

Government c

Total

Number of facilities submitting 

initial Part A Permit Application 4 0 4 2 1 3 3 1 4

Number of facilities submitting 

Part A Permit Modification 21 1 22 19 2 21 20 2 22

a

 Based on data from two RCRAInfo tables: (1) “Hhandler” and (2) “Howner_operator.” Both tables contain data current as of April 27, 2011.

b

 Includes facilities owned and/or operated by “private” or “other.” Note that, in order to qualify as “private,” the facility cannot be owned or operated by a Federal, State, 

or local government. For example, a facility owned by a State government and operated by a private entity would qualify as a “State and local government” facility, not as 

a “private” facility.

c

 Includes facilities owned and/or operated by a “County,” “District,” “Indian,” “Municipal,” or “State.” Note that, in order to qualify as “State and local government,” the 

facility cannot be owned or operated by the Federal government. For example, a facility owned by the Federal government and operated by a Municipal government would 

qualify as a “Federal government” facility, not a “State and local government” facility.
60

(2) Annual Respondent Burden

(a) Hazardous Waste Report - Facilities (Exhibits 1A and 1B)

(a1) Read the Hazardous Waste Report Instructions

EPA estimates that all 21,066 respondents will read the Hazardous Waste Report 

instructions. Annualized over the two-year report cycle, this results in 10,533 respondents 

reading the instructions each year (i.e., 9,488 private sector facilities and 1,045 State and local 

government facilities). 

(a2) Revise In-House or Commercial Data System

EPA estimates that all 7,858 electronic reporters will revise their in-house or commercial 

data system to include new Hazardous Waste Report data items that are not part of the facility’s 

general business operations. Annualized over the two-year report cycle, this results in 3,929 

respondents revising their in-house or commercial data systems each year (i.e., 3,707 private 

sector facilities and 222 State and local government facilities). 

(a3) Gather Information and Complete Site Identification Form

EPA estimates that all 21,066 respondents will complete and submit a Site ID Form with 

the 2009 Hazardous Waste Report. Annualized over the two-year report cycle, this results in 

10,533 respondents preparing and submitting a Site ID Form each year (i.e., 9,488 private sector 

facilities and 1,045 State and local government facilities). 

(a4) Gather Information and Complete Form GM

EPA estimates that respondents will submit a total of 206,032 Forms GM with the 

2009 Hazardous Waste Report. Annualized over the two-year report cycle, this results in 

103,016 Forms GM each year (i.e., 94,764 forms from private sector facilities and 8,252 forms 

from State and local government facilities).

(a5) Gather Information and Complete Form WR

EPA estimates that respondents will submit a total of 1,036,999 Forms WR with the 

2009 Hazardous Waste Report. Annualized over the two-year report cycle, this results in 

518,500 Forms WR each year (i.e., 509,494 forms from private sector facilities and 9,006 forms 

from State and local government facilities). 

Note that the number of Forms WR represents the number of blocks on Form WR that 

have been completed; the paper form actually contains three blocks of the same WR information 

(i.e., the same questions, repeated three times on the same page). 
61

(a6) Gather Information and Complete Form OI

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

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

(a7) Submit the Biennial Report to State/Region

EPA expects each respondent, 10,533 facilities per year (i.e., 9,488 private sector 

facilities and 1,045 State and local government facilities), to submit the report to the appropriate 

State or Region.

(a8) Maintain a Copy of Each Form 

EPA expects facilities to retain an estimated 632,049 (i.e., 10,533 Site ID Forms + 

103,016 Forms GM + 518,500 Forms WR) forms each year (i.e., 613,746 forms from private 

sector facilities and 18,303 forms from State and local government facilities).

(b) Hazardous Waste Report – State Agencies (Exhibit 1C)

(b1) Distribute Hazardous Waste Report Forms and Instructions

EPA estimates that State agencies will distribute Hazardous Waste Report forms and 

instructions to 20,887 respondents. Annualized over the two-year report cycle, this results in 

10,444 respondents each year. 

(b2) Assist Respondents

EPA expects State agencies to provide assistance to all 20,887 respondents. Annualized 

over the two-year report cycle, this results in 10,444 respondents each year. 

(b3) Key Entry of Report Submissions

EPA estimates that State agencies will need to key enter data for 24,480 Hazardous 

Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) completed manually by the 

facilities. Annualized over the two-year report cycle, this results in 12,240 respondents each 

year. 

 

(b4) Perform Quality Assurance

EPA expects State agencies to perform data quality assurance on all 1,261,900 Hazardous 

Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) submitted by facilities. 

Annualized over the two-year report cycle, this results in 630,950 respondents each year. 
62

(c) Notification of Regulated Waste Activity (Exhibits 2A and 2B)

(c1) Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

EPA estimates that, each year, 24 entities (i.e., 23 private sector facilities and 1 State and 

local government facility) will notify EPA under section 260.42 prior to operating under the 

exclusion and be required to complete the information laid out at section 260.42(a). 

In addition, entities must re-notify EPA using the Site ID Form by March 1 of each even 

numbered year thereafter. Note that the Hazardous Waste Report regulations already require the 

submittal of the Site ID Form by March 1 of each even numbered year by LQGs (40 CFR Part 

262) and TSDFs (40 CFR Part 264 and 265). Hence, this section of the ICR estimates burden for 

SQG and CESQG re-notifications only. For purposes of this ICR, EPA estimates that, each year, 

a total of four SQGs and CESQGs will re-notify EPA (i.e., 4 private sector facilities and 0 State 

and local government facilities).

EPA estimates that, each year, two entities will re-notify because they stopped operating 

under the exclusion (i.e., 2 private sector facilities and 0 State and local government facilities).

(c2) Notification of Hazardous Waste Activity under RCRA Section 3010

EPA estimates that, each year, 9,463 facilities (i.e., 7,959 private sector facilities and 

1,504 State and local government facilities) will submit an initial notification of hazardous waste 

activity under RCRA Section 3010. EPA also estimates that, each year, 36,057 facilities 

(i.e., 33,968 private sector facilities and 2,089 State and local government facilities) will submit 

a subsequent notification associated with these requirements. 

(c3) Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

Intent to Comply with Subpart K and Recordkeeping of Agreements

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

authorized State that it is electing to be subject to Subpart K for all laboratories owned by the 

eligible academic entity under the same EPA Identification Number. An eligible academic entity

that is a CESQG and does not have an EPA Identification Number must notify for all 

laboratories that are owned or operated by the eligible academic entity that are on-site. EPA 

estimates that, each year, eight forms will be completed, submitted, and retained (i.e., 6 forms 

from private sector entities and 2 forms from State and local government entities).

Teaching hospitals opting into Subpart K must keep a copy of their formal written 

affiliation agreement with a college or university on file if they are not owned by a college or 

university. EPA does not expect any eligible teaching hospital to opt into Subpart K during the 

two-year period covered by this ICR.
63

Non-profit research institutes not owned by a college or university opting into Subpart K 

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

EPA estimates that, each year, one site will retain the agreement on file.

Withdrawal from 40 CFR Part 262, Subpart K

EPA does not expect any eligible academic entity to submit a withdrawal notification 

during the two-year period covered by this ICR.

(c4) Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

EPA estimates that, each year, 80 facilities (i.e., 61 private sector facilities and 19 State 

and local government facilities) will submit an initial notification of universal waste activity

under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent (i.e., 80 x 0.75 = 60) will use 

the Site ID Form and 25 percent (i.e., 80 x 0.25 = 20) will prepare and submit a letter requesting 

an EPA Identification Number. 

EPA also estimates that, each year, 74 facilities (i.e., 70 private sector facilities and 

4 State and local government facilities) will submit a subsequent notification of universal waste 

activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent (i.e., 74 x 0.75 = 56) 

will use the Site ID Form and 25 percent (i.e., 74 x 0.25 = 18) will prepare and submit a letter 

requesting an EPA Identification Number. 

(c5) Notification of Used Oil Activity under 40 CFR Part 279

EPA estimates that, each year, 114 facilities (i.e., 111 private sector facilities and 3 State 

and local government facilities) will submit an initial notification of used oil activity under 

40 CFR Part 279. Of these facilities, 75 percent (i.e., 114 x 0.75 = 85) will use the Site ID Form

and 25 percent (i.e., 114 x 0.25 = 29) will prepare and submit a letter requesting an EPA 

Identification Number. 

EPA also estimates that, each year, 208 facilities (i.e., 199 private sector facilities and 

9 State and local government facilities) will submit a subsequent notification of universal waste 

activity under 40 CFR Part 273, Subpart C. Of these facilities, 75 percent (i.e., 208 x 0.75 = 

156) will use the Site ID Form and 25 percent (i.e., 208 x 0.25 = 52) will prepare and submit a 

letter requesting an EPA Identification Number. 

(d) Part A Hazardous Waste Permit Application and Modification - Facilities

(Exhibits 3A and 3B)

(d1) Part A Permit Application

EPA estimates that, each year, four facilities (i.e., 3 private sector facilities and 1 State 

and local government facility) will submit a new Part A Permit Application. All facilities will 

need to obtain signatures for the Part A Permit Application, Part A Permit Application reports, 
64

and other information requested by the Director. In addition, all facilities will need to obtain 

certifications from persons signing permit documentation. 

EPA also estimates that, each year, 10 percent of the facilities submitting Part A Permit 

Applications will have authorizations that are no longer accurate because a different individual 

or position has responsibility for the overall operation of the facility. Therefore, each year, 

one (1) facility will need to obtain a new authorization.

(d2) Revised Part A Permit Applications and Associated Justifications and Subpart H 

Compliance Demonstrations

EPA estimates that, each year, 22 facilities (i.e., 20 private sector facilities and 2 State 

and local government facilities) will need to revise their Part A Permit Application. Of these, 

EPA expects that approximately one-third (7 facilities) will submit a revised Part A Permit 

Application in response to an EPA rulemaking, and two-thirds (15 facilities) will submit a 

revised Part A Permit Application for a facility modification. 

EPA further estimates that, each year, one-third of facilities submitting revised Part A 

Permit Applications (7 facilities) will need to submit justifications due to either changes in the 

design capacity of processes used at the facility and/or changes or additions in a facility's 

hazardous waste treatment, storage, or disposal processes. In addition, EPA estimates that, each 

year, one-third of facilities submitting revised Part A Permit Applications (7 facilities) will need 

to submit a Subpart H compliance demonstration due to changes in ownership or operational 

control of a facility.

(e) Part A Hazardous Waste Permit Application and Modification – State 

Agencies (Exhibit 3C)

(e1) Part A Permit Application

EPA estimates that, each year, State agencies will receive four Part A Permit 

Applications. State agencies will need to review the applications, review the signatories to the 

permit applications and reports, and enter the Part A Permit Application information into the 

RCRAInfo database.

EPA also estimates that, each year, 10 percent of the Part A Permit Applications will 

have authorizations that are no longer accurate because a different individual or position has 

responsibility for the overall operation of the facility. Therefore, each year, State agencies will 

need to notify one (1) applicant of a deficiency in the Part A Application and review the newly 

authorized signature.
65

(e2) Revised Part A Permit Applications and Associated Justifications and Subpart H 

Compliance Demonstrations

EPA estimates that, each year, State agencies will receive 22 revised Part A Permit 

Applications. State agencies will need to review the applications and enter the Part A Permit 

Application information into the RCRAInfo database.

 

EPA further estimates that, each year, one-third of the revised Part A Permit Applications 

(7 applications) will be accompanied by justifications due to either changes in the design 

capacity of processes used at the facility and/or changes or additions in a facility's hazardous 

waste treatment, storage, or disposal processes. In addition, EPA estimates that, each year, onethird of the revised Part A Permit Applications (7 applications) will be accompanied by a 

Subpart H compliance demonstration due to changes in ownership or operational control of a 

facility. State agencies will need to review all justifications and Subpart H compliance 

demonstrations.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibit 7 summarizes the total annual respondent hour and cost burden associated with 

all the requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual 

respondent burden to be 440,243 hours and $18,267,341. The bottom line burden to respondents 

over two years is estimated to be 880,486 hours and $36,534,682.

(2) Agency Tally

Exhibit 8 summarizes the total annual EPA hour and cost burden associated with all the 

requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual EPA 

burden to be 120,882 hours and $6,306,439. The bottom line burden to EPA over two years is 

estimated to be 241,764 hours and $12,612,878.

6(f) REASONS FOR CHANGE IN BURDEN

Following is a discussion of reasons for change in burden. Note that this ICR burden 

changed solely because of adjustments. There were no program changes. 

(1) Hazardous Waste Report

(a) Facility Burden

For facilities, the annual burden estimate for the 2009 Hazardous Waste Report (EPA 

ICR Number 0976.14) was 169,780 hours. The annual burden estimate for the 2011 Hazardous 

Waste Report is 171,280 hours. This represents an increase of 1,500 hours. 
66

This increase in burden has occurred for three primary reasons. First, there was an 

increase in the annualized number of respondents, from 8,242 projected for 2009 to 10,533

projected for 2011. Second, there was an increase in the number of Hazardous Waste Report 

forms projected for 2009 versus the number of forms projected for 2011. Table 14 compares the 

projected number of forms for the 2009 and the 2011 Hazardous Waste Reports. 

Third, in developing this ICR, EPA carefully reviewed the respondent activities 

associated with the Hazardous Waste Report requirements. Based on consultations with industry

and States, EPA increased some of the hourly and cost burden estimates associated with the 

Hazardous Waste Report. EPA believes that the revised burden estimates included in this ICR 

reflect a realistic industry average.

Table 14

Comparison of Projected Number of Forms

for the 2009 and 2011 Hazardous Waste Report

Hazardous Waste Report Form

Projected Number of Forms

Difference 2009

Hazardous

Waste Report

2011

Hazardous

Waste Report

Site Identification (Site ID) Form 16,483 21,066 4,583

Form GM - Generation and Management 205,994 206,032 38

Form WR - Waste Received from Offsite 861,640 1,036,999 175,359

Total 1,084,117 1,264,097 179,980

(b) State Agency Burden

For State agencies, the annual burden estimate for the 2009 Hazardous Waste Report 

(EPA ICR Number 0976.14) was 215,828 hours. The annual burden estimate for the 2011

Hazardous Waste Report is 234,647 hours. This represents an increase of 18,819 hours. 

This increase in burden has occurred because EPA projects an increase in the number of 

respondents and Hazardous Waste Report forms from 2009 to 2011. Refer to Table 14 for a 

comparison of the projected number of forms for the 2009 and the 2011 Hazardous Waste 

Reports.

(2) Notification of Regulated Waste Activity

For facilities, the annual burden estimate in the previously approved ICR (EPA ICR 

Number 0976.14) was 36,525 hours. The annual burden estimate for the same notification 

requirements covered in this current ICR is 33,826 hours. This represents a decrease of 2,699 

hours. 
67

This decrease in burden has occurred primarily because there was a decrease in the total 

number of notifications covered in the ICR. As shown in Table 15, the total number of 

notifications decreased from 48,255 in the previously approved ICR (EPA ICR Number 0976.14) 

to 46,035 in this ICR (EPA ICR Number 0976.15). Note that, in estimating the number of 

notifications in this ICR, EPA used the average of the number of notifications submitted in 2009 

and 2010 (see Table 12). In each of these years, there was a decrease in the total annual number 

of notifications submitted to EPA, when compared to the annual number of notifications in the 

previously approved ICR. Thus, EPA believes that the number of notifications included in this 

current ICR is consistent with the respondent universe subject to these notification requirements.

Table 15

Comparison of Projected Number of Notifications in the

Previously Approved ICR (EPA ICR Number 0976.14) and

this ICR (EPA ICR Number 0976.15). 

Type of Notification

Projected Number of Notifications

Difference a

EPA ICR 

Number 0976.14

EPA ICR 

Number 0976.15

Notification of Hazardous Secondary 

Material Activity under 40 CFR 260.42 2,029 30 -1,999

Notification of Hazardous Waste Activity 

under RCRA Section 3010 45,899 45,520 -379

Notification of Hazardous Waste Activity 

under 40 CFR Part 262, Subpart K 40 9 -31

Notification of Universal Waste Activity 

under 40 CFR Part 273, Subpart C 44 154 110

Notification of Used Oil Activity under 

40 CFR Part 279 243 322 79

Total 48,255 46,035 -2,220

a

 Negative value indicates a decrease in the number of forms.

(3) Part A Hazardous Waste Permit Application and Modification

(a) Facility Burden

For facilities, the annual burden estimate in the previously approved Part A Permit 

Application ICR (EPA ICR Number 0262.12) was 402 hours. The annual respondent burden 

estimate for the same permit application requirements covered in this ICR is 389 hours. This 

represents a decrease of 13 hours. 

The decrease in hourly burden occurred primarily because there was a decrease in the 

number of new Part A Permit Applications. The number of new Part A Permit Applications

decreased from eight in the previously approved ICR to four in this ICR. Note that, in estimating 

the number of new Part A Permit Applications in this ICR, EPA used the average of the number 

of new Part A Permit Applications submitted in 2009 and 2010 (see Table 13). In each of these
68

years, there was a decrease in the annual number of new Part A Permit Applications submitted to 

EPA, when compared to the annual number of new Part A Permit Applications in the previously

approved ICR. Thus, EPA believes that the number of new Part A Permit Applications included 

in this ICR is consistent with the respondent universe subject to these permitting requirements.

(b) State Agency Burden

For State agencies, the annual burden estimate in the previously approved Part A Permit 

Application ICR (EPA ICR Number 0262.12) was 95 hours. The annual respondent burden 

estimate for the same permit application requirements covered in this ICR is 101 hours. This 

represents an increase of 6 hours. 

The increase in hourly burden occurred primarily because there was an increase in the 

number of revised Part A Permit Applications and associated justifications and Subpart H 

compliance demonstrations. The number of revised Part A Permit Applications increased from 

15 in the previously approved ICR to 22 in this ICR. Note that, in estimating the number of 

revised Part A Permit Applications in this ICR, EPA used the average of the number of Part A 

Permit Applications submitted in 2009 and 2010 (see Table 13). In each of these years, there 

was an increase in the annual number of revised Part A Permit Applications submitted to EPA, 

when compared to the annual number of revised Part A Permit Applications in the previously

approved ICR. Thus, EPA believes that the number of revised Part A Permit Applications 

included in this ICR is consistent with the respondent universe subject to these permitting 

requirements.

6(g) PUBLIC BURDEN STATEMENT

(1) Hazardous Waste Report

The reporting burden is estimated to be 12 hours for a facility to gather data, complete 

and review the forms, and submit the Hazardous Waste Report. The recordkeeping burden is 

estimated to be 5 hours to read the instructions, and file and store the Hazardous Waste Report 

submission for three years.

The reporting burden is estimated to be 22 hours per facility for a State agency to 

distribute Hazardous Waste Report forms and instructions, assist respondents, key entry report 

submissions, and perform quality assurance. There are no recordkeeping requirements 

associated with this requirement, and as such, there is no recordkeeping burden.
69

(2) Notification of Regulated Waste Activity

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

The reporting burden associated with hazardous secondary material notification 

requirements is estimated to be 1 hour for a facility to notify EPA under section 260.42. There 

are no recordkeeping requirements associated with this requirement, and as such, there is no 

recordkeeping burden.

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

The reporting burden associated with RCRA Section 3010 notification requirements 

(initial and subsequent) is estimated to be 45 minutes for a facility to complete and submit the 

form. There are no recordkeeping requirements associated with this requirement, and as such, 

there is no recordkeeping burden.

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

The reporting burden associated with notification requirements under 40 CFR Part 262, 

Subpart K is estimated to be 40 minutes for a facility to prepare and submit a Site ID Form to opt 

into or withdraw from Subpart K. The recordkeeping burden is estimated to be 5 minutes to 

keep copies of notification and affiliation agreements on-site.

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

The reporting burden associated with 40 CFR Part 273, Subpart C notification 

requirements (initial and subsequent) is estimated to be 45 minutes for a facility to complete the 

Site ID Form or prepare a letter requesting an EPA Identification Number, and submit the 

completed Site ID Form or letter. There are no recordkeeping requirements associated with this 

requirement, and as such, there is no recordkeeping burden.

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

The reporting burden associated with 40 CFR Part 279 notification requirements (initial 

and subsequent) is estimated to be 45 minutes for a facility to complete the Site ID Form or 

prepare a letter requesting an EPA Identification Number, and submit the completed Site ID 

Form or letter. There are no recordkeeping requirements associated with this requirement, and as 

such, there is no recordkeeping burden.
70

(3) Part A Hazardous Waste Permit Application and Modification

(a) Part A Permit Application

The reporting burden associated with the Part A Permit Application requirements is 

estimated to be 20 hours for a facility to prepare and submit a Part A Permit Application. The 

recordkeeping burden is estimated to be 6 hours to read the regulations.

The reporting burden associated with the Part A Permit Application requirements is 

estimated to be 10 minutes for a State agency to notify an applicant of a deficiency in the Part A 

Permit Application. The recordkeeping burden is estimated to be 5 hours to review an 

application and signatories to the permit applications and reports, and enter the Part A Permit 

Application information into the RCRAInfo database.

(b) Revised Part A Permit Applications and Associated Justifications and 

Subpart H Compliance Demonstrations

The reporting burden associated with revising a Part A Permit Applications is estimated 

to be 10 hours for facilities to prepare and submit a revised Part A Permit Application, prepare 

and submit justifications for changes, and prepare and submit Subpart H compliance 

demonstrations. The recordkeeping burden is estimated to be 3 hours to read the regulations.

The recordkeeping burden associated with revising a Part A Permit Applications is 

estimated to be 4 hours for State agencies to review a Part A Permit Application, justification, 

and Subpart H compliance demonstration, and enter the Part A Permit Application information 

into the RCRAInfo database. There are no reporting requirements associated with this 

requirement, and as such, there is no reporting burden.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

To comment on EPA 's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-RCRA-2011-0280, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 
71

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic version 

of the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. When in the system, 

select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-RCRA-2011-0280 and OMB Control Number 

2050-0024 in any correspondence.
72

EXHIBIT 1A

2011 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $122.72/ $72.54/ $54.04/ $32.51/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $169.13 $0.00 $0.00 9,488 26,186.88 $1,604,705.44

Revise in-house or commercial data system to include 

new Hazardous Waste Report data items that are not 

part of the facility’s general business operations

0.00 0.33 0.67 0.00 1.00 $60.15 $0.00 $0.00 3,707 3,707.00 $222,976.05

Gather information and prepare Site Identification Form 0.00 0.08 0.40 0.08 0.56 $30.02 $0.00 $0.00 9,488 5,313.28 $284,829.76

Gather information and prepare Form GM 0.00 0.14 0.18 0.04 0.36 $21.18 $0.00 $0.00 94,764 34,115.04 $2,007,101.52

Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $7.35 $0.00 $0.00 509,494 61,139.28 $3,744,780.90

Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0.00

Submit report to the State or EPA Regional Office 0.00 0.82 0.32 0.20 1.34 $83.28 $0.00 $5.82 9,488 12,713.92 $845,380.80

Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $1.19 $0.00 $0.00 613,746 18,412.38 $730,357.74

TOTAL varies varies varies varies varies varies varies varies varies 161,587.78 $9,440,132.21

a Exhibit includes rounding.

Hazardous Waste Report
73

EXHIBIT 1B

2011 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $57.54/ $54.02/ $32.32/ $20.62/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the Hazardous Waste Report instructions 0.00 1.08 1.68 0.00 2.76 $112.64 $0.00 $0.00 1,045 2,884.20 $117,708.80

Revise in-house or commercial data system to include 

new Hazardous Waste Report data items that are not 

part of the facility’s general business operations

0.00 0.33 0.67 0.00 1.00 $39.48 $0.00 $0.00 222 222.00 $8,764.56

Gather information and prepare Site Identification Form 0.00 0.08 0.40 0.08 0.56 $18.90 $0.00 $0.00 1,045 585.20 $19,750.50

Gather information and prepare Form GM 0.00 0.14 0.18 0.04 0.36 $14.21 $0.00 $0.00 8,252 2,970.72 $117,260.92

Gather information and prepare Form WR 0.00 0.07 0.03 0.02 0.12 $5.16 $0.00 $0.00 9,006 1,080.72 $46,470.96

Gather information and prepare Form OI 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 0 0.00 $0.00

Submit report to the State or EPA Regional Office 0.00 0.82 0.32 0.20 1.34 $58.76 $0.00 $5.82 1,045 1,400.30 $67,486.10

Maintain a copy of each form for three years 0.00 0.00 0.01 0.02 0.03 $0.74 $0.00 $0.00 18,303 549.09 $13,544.22

TOTAL varies varies varies varies varies varies varies varies varies 9,692.23 $390,986.06

a Exhibit includes rounding.

Hazardous Waste Report
74

EXHIBIT 1C

2011 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $57.54/ $54.02/ $32.32/ $20.62/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Distribute Hazardous Waste Report forms and instructions 0.00 0.01 0.25 0.50 0.76 $18.93 $0.00 $2.97 10,444 7,937.44 $228,723.60

Assist respondents 0.00 0.01 0.50 0.50 1.01 $27.01 $0.00 $0.00 10,444 10,548.44 $282,092.44

Key entry of report submissions 0.00 0.01 0.08 0.25 0.34 $8.28 $0.00 $0.00 12,240 4,161.60 $101,347.20

Perform quality assurance 0.00 0.02 0.16 0.16 0.34 $9.33 $0.00 $0.00 630,950 211,999.20 $5,886,763.50

TOTAL varies varies varies varies varies varies varies varies varies 234,646.68 $6,498,926.74

a

 Exhibit includes rounding.

Hazardous Waste Report
75

EXHIBIT 2A

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $122.72/ $72.54/ $54.04/ $32.51/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Complete and submit EPA Form 8700-12 prior to operating 

under exclusion(s) 0.00 0.08 1.01 0.08 1.17 $62.71 $0.00 $3.31 23 26.80 $1,518.46

Complete and submit EPA Form 8700-12 by March 1 of

each even numbered year thereafter

0.00 0.08 1.01 0.08 1.17 $62.71 $0.00 $3.31 4 4.66 $264.08

Complete and submit EPA Form 8700-12 indicating that the 

hazardous secondary materials are no longer managed in 

accordance w ith the exclusion

0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 2 1.33 $78.00

Subtotal varies varies varies varies varies varies varies varies varies 32.79 $1,860.54

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $53.80 $0.00 $3.31 7,959 7,959.00 $454,538.49

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 33,968 22,588.72 $1,324,752.00

Subtotal varies varies varies varies varies varies varies varies varies 30,547.72 $1,779,290.49

Prepare and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 6 3.99 $234.00

Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $2.60 $0.00 $0.00 6 0.48 $15.60

Keep a copy of their formal w ritten affiliation agreement 

w ith college or university on file w hile its laboratories are 

subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $2.60 $0.00 $0.00 0 0.00 $0.00

Keep a copy of the formal w ritten affiliation agreement 

w ith a college or university on file at the non-profit 

research institute w hile its laboratories are subject to 

Subpart K

0.00 0.00 0.00 0.08 0.08 $2.60 $0.00 $0.00 1 0.08 $2.60

Prepare and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 0 0.00 $0.00

Keep a copy of the w ithdraw al notice on file 0.00 0.00 0.00 0.08 0.08 $2.60 $0.00 $0.00 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 4.55 $252.20

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $53.80 $0.00 $3.31 46 46.00 $2,627.06

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $26.78 $0.00 $3.31 15 7.50 $451.35

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 53 35.25 $2,067.00

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $26.78 $0.00 $3.31 17 8.50 $511.53

Subtotal varies varies varies varies varies varies varies varies varies 97.25 $5,656.94

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $53.80 $0.00 $3.31 83 83.00 $4,740.13

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $26.78 $0.00 $3.31 28 14.00 $842.52

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $3.31 149 99.09 $5,811.00

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $26.78 $0.00 $3.31 50 25.00 $1,504.50

Subtotal varies varies varies varies varies varies varies varies varies 221.09 $12,898.15

TOTAL varies varies varies varies varies varies varies varies varies 30,903.40 $1,799,958.32

a

 Exhibit includes rounding.

Initial Notification

Subsequent Notification

EPA Form 8700-12

Letter

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Notification of Hazardous Waste Activity under RCRA Section 3010

Subsequent Notification

Notification of Used Oil Activity under 40 CFR Part 279

Initial Notification

EPA Form 8700-12

Letter

Eligible Academic Entities

Letter

Non-Profit Research Institutes

EPA Form 8700-12

Initial Notification

Subsequent Notification

EPA Form 8700-12

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

Intent to Comply with Subpart K and Recordkeeping of Agreements

Letter

Withdrawal from 40 CFR Part 262, Subpart K

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

Teaching Hospitals
76

EXHIBIT 2B

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $57.54/ $54.02/ $32.32/ $20.62/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Complete and submit EPA Form 8700-12 prior to operating 

under exclusion(s) 0.00 0.08 1.01 0.08 1.17 $38.45 $0.00 $3.31 1 1.17 $41.76

Complete and submit EPA Form 8700-12 by March 1 of

each even numbered year thereafter

0.00 0.08 1.01 0.08 1.17 $38.45 $0.00 $3.31 0 0.00 $0.00

Complete and submit EPA Form 8700-12 indicating that the 

hazardous secondary materials are no longer managed in 

accordance w ith the exclusion

0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 1.17 $41.76

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $33.12 $0.00 $3.31 1,504 1,504.00 $54,790.72

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 2,089 1,389.19 $53,478.40

Subtotal varies varies varies varies varies varies varies varies varies 2,893.19 $108,269.12

Prepare and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 2 1.33 $51.20

Keep a copy of the notification on file 0.00 0.00 0.00 0.08 0.08 $1.65 $0.00 $0.00 2 0.16 $3.30

Keep a copy of their formal w ritten affiliation agreement 

w ith college or university on file w hile its laboratories are 

subject to Subpart K

0.00 0.00 0.00 0.08 0.08 $1.65 $0.00 $0.00 0 0.00 $0.00

Keep a copy of the formal w ritten affiliation agreement 

w ith a college or university on file at the non-profit 

research institute w hile its laboratories are subject to 

Subpart K

0.00 0.00 0.00 0.08 0.08 $1.65 $0.00 $0.00 0 0.00 $0.00

Prepare and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 0 0.00 $0.00

Keep a copy of the w ithdraw al notice on file 0.00 0.00 0.00 0.08 0.08 $1.65 $0.00 $0.00 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 1.49 $54.50

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $33.12 $0.00 $3.31 14 14.00 $510.02

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $16.96 $0.00 $3.31 5 2.50 $101.35

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 3 2.00 $76.80

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $16.96 $0.00 $3.31 1 0.50 $20.27

Subtotal varies varies varies varies varies varies varies varies varies 19.00 $708.44

Complete and submit EPA Form 8700-12 0.00 0.08 0.84 0.08 1.00 $33.12 $0.00 $3.31 2 2.00 $72.86

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $16.96 $0.00 $3.31 1 0.50 $20.27

Complete and submit EPA Form 8700-12 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $3.31 7 4.66 $179.20

Prepare and submit letter requesting an EPA Identification 

Number

0.00 0.08 0.34 0.08 0.50 $16.96 $0.00 $3.31 2 1.00 $40.54

Subtotal varies varies varies varies varies varies varies varies varies 8.16 $312.87

TOTAL varies varies varies varies varies varies varies varies varies 2,923.01 $109,386.69

a

 Exhibit includes rounding.

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Subsequent Notification

EPA Form 8700-12

Teaching Hospitals

Non-Profit Research Institutes

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

Withdrawal from 40 CFR Part 262, Subpart K

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

Intent to Comply with Subpart K and Recordkeeping of Agreements

EPA Form 8700-12

Letter

Subsequent Notification

Notification of Used Oil Activity under 40 CFR Part 279

Initial Notification

Notification of Hazardous Waste Activity under RCRA Section 3010

Initial Notification

Letter

EPA Form 8700-12

Eligible Academic Entities

EPA Form 8700-12

Initial Notification

Letter

Subsequent Notification

Letter
77

EXHIBIT 3A

PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - PRIVATE FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $122.72/ $72.54/ $54.04/ $32.51/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the regulations and instructions 2.00 1.00 3.00 0.00 6.00 $480.10 $0.00 $0.00 3 18.00 $1,440.30

Prepare the Site Identification Form 0.00 0.08 0.51 0.08 0.67 $35.69 $0.00 $0.00 3 2.00 $107.07

Prepare the Hazardous Waste Permit Information Form and 

reports

1.33 2.67 7.16 1.32 12.48 $786.74 $0.00 $0.00 3 37.44 $2,360.22

Obtain signatures and certifications for Part A permit 

applications, reports, and other information requested by

EPA

0.00 0.50 1.00 1.00 2.50 $122.82 $0.00 $0.00 3 7.50 $368.46

Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $106.57 $0.00 $0.00 1 2.00 $106.57

Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $139.08 $0.00 $5.82 3 9.00 $434.70

Explain or cure an alleged deficiency in Part A application, 

if required 0.00 0.50 2.00 1.00 3.50 $176.86 $0.00 $0.00 1 3.50 $176.86

Subtotal varies varies varies varies varies varies varies varies varies 79.44 $4,994.18

Read the regulations and instructions (for Agency 

rulemaking) 0.00 1.00 2.00 0.00 3.00 $180.62 $0.00 $0.00 7 21.00 $1,264.34

Read the regulations and instructions (for facility 

modification) 0.00 1.00 2.00 0.00 3.00 $180.62 $0.00 $0.00 13 39.00 $2,348.06

Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $471.68 $0.00 $5.82 7 47.25 $3,342.50

Prepare and submit revised Part A (for facility modification) 1.75 1.40 1.78 1.82 6.75 $471.68 $0.00 $5.82 13 87.75 $6,207.50

Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $335.85 $0.00 $5.82 7 35.00 $2,391.69

Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $335.85 $0.00 $5.82 7 35.00 $2,391.69

Subtotal varies varies varies varies varies varies varies varies varies 265.00 $17,945.78

TOTAL varies varies varies varies varies varies varies varies varies 344.44 $22,939.96

a

 Exhibit includes rounding.

Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

Part A Permit Application

Signatories to Permit Applications and Permit Application Reports

Contents of the Part A Permit Application

Submittal of Part A Permit Application
78

EXHIBIT 3B

PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE AND LOCAL GOVERNMENT FACILITIES a

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number Total Total

 $57.54/ $54.02/ $32.32/ $20.62/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Read the regulations and instructions 2.00 1.00 3.00 0.00 6.00 $266.06 $0.00 $0.00 1 6.00 $266.06

Prepare the Site Identification Form 0.00 0.08 0.51 0.08 0.67 $22.29 $0.00 $0.00 1 0.67 $22.29

Prepare the Hazardous Waste Permit Information Form and 

reports

1.33 2.67 7.16 1.32 12.48 $479.39 $0.00 $0.00 1 12.48 $479.39

Obtain signatures and certifications for Part A permit 

applications, reports, and other information requested by

EPA

0.00 0.50 1.00 1.00 2.50 $79.95 $0.00 $0.00 1 2.50 $79.95

Obtain a new authorization for invalid authorizations 0.00 0.50 1.00 0.50 2.00 $69.64 $0.00 $0.00 0 0.00 $0.00

Submit Part A Permit Application and reports 0.00 0.50 1.00 1.50 3.00 $90.26 $0.00 $5.82 1 3.00 $96.08

Explain or cure an alleged deficiency in Part A application, 

if required 0.00 0.50 2.00 1.00 3.50 $112.27 $0.00 $0.00 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 24.65 $943.77

Read the regulations and instructions (for Agency 

rulemaking) 0.00 1.00 2.00 0.00 3.00 $118.66 $0.00 $0.00 0 0.00 $0.00

Read the regulations and instructions (for facility 

modification) 0.00 1.00 2.00 0.00 3.00 $118.66 $0.00 $0.00 2 6.00 $237.32

Prepare and submit revised Part A (for rulemaking) 1.75 1.40 1.78 1.82 6.75 $271.38 $0.00 $5.82 0 0.00 $0.00

Prepare and submit revised Part A (for facility modification) 1.75 1.40 1.78 1.82 6.75 $271.38 $0.00 $5.82 2 13.50 $554.40

Prepare and submit justifications for changes, if needed 1.00 1.00 2.00 1.00 5.00 $196.82 $0.00 $5.82 0 0.00 $0.00

Submit Subpart H compliance demonstrations, if needed 1.00 1.00 2.00 1.00 5.00 $196.82 $0.00 $5.82 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 19.50 $791.72

TOTAL varies varies varies varies varies varies varies varies varies 44.15 $1,735.49

a

 Exhibit includes rounding.

Signatories to Permit Applications and Permit Application Reports

Submittal of Part A Permit Application

Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

Contents of the Part A Permit Application

Part A Permit Application
79

EXHIBIT 3C

PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN - STATE GOVERNMENT AGENCIES a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $57.54/ $54.02/ $32.32/ $20.62/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $102.12 $0.00 $0.00 4 13.00 $408.48

Ensure that Part A Permit Application and Reports have 

been signed by appropriate person

0.00 0.00 0.25 0.00 0.25 $8.08 $0.00 $0.00 4 1.00 $32.32

Review new ly authorized signatures w hen a different 

individual or position gains responsibility for the overall 

operation of a facility

0.00 0.00 0.25 0.00 0.25 $8.08 $0.00 $0.00 1 0.25 $8.08

Review signature certifications 0.00 0.00 0.25 0.00 0.25 $8.08 $0.00 $0.00 4 1.00 $32.32

Enter Part A Application information into RCRAInfo

Database

0.00 0.00 0.00 1.00 1.00 $20.62 $0.00 $0.00 4 4.00 $82.48

Notify applicant of deficiency in the Part A Permit 

Application 0.00 0.00 0.50 0.10 0.60 $18.22 $0.00 $0.00 1 0.60 $18.22

Subtotal varies varies varies varies varies varies varies varies varies 19.85 $581.90

Review revised Part A Permit Application 0 0 2 0.25 2.25 $69.80 $0.00 $0.00 22 49.50 $1,535.60

Enter revised Part A Permit Application information into 

RCRAInfo Database

0 0 0 0.5 0.50 $10.31 $0.00 $0.00 22 11.00 $226.82

Review justifications for changes 0.5 0.25 0.75 0 1.50 $66.52 $0.00 $0.00 7 10.50 $465.64

Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $66.52 $0.00 $0.00 7 10.50 $465.64

Subtotal varies varies varies varies varies varies varies varies varies 81.50 $2,693.70

TOTAL varies varies varies varies varies varies varies varies varies 101.35 $3,275.60

a

 Exhibit includes rounding.

Part A Permit Application

Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations
80

EXHIBIT 4

2011 HAZARDOUS WASTE REPORT

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $86.56/ $76.38/ $54.94/ $23.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Develop Hazardous Waste Report forms and instructions 0.00 8.00 80.00 20.00 108.00 $5,475.04 $0.00 $20,920.00 0.50 54.00 $13,197.52

Distribute Hazardous Waste Report forms and instructions 0.00 0.01 0.25 0.50 0.76 $26.22 $0.00 $0.00 116 88.16 $3,041.52

Develop computer capabilities required to compile national data 0.00 8.00 80.00 0.00 88.00 $5,006.24 $0.00 $261,500.00 0.50 44.00 $133,253.12

Assist respondents 0.00 0.01 0.50 0.50 1.01 $39.95 $0.00 $0.00 116 117.16 $4,634.20

Key entry of report submissions 0.00 0.01 0.08 0.25 0.34 $11.02 $0.00 $0.00 89 30.26 $980.78

Perform quality assurance 0.00 0.02 0.16 0.16 0.34 $13.76 $0.00 $0.00 1,099 369.26 $15,122.24

Prepare the National Report 0.00 8.00 200.00 40.00 248.00 $12,536.64 $0.00 $52,300.00 0.50 124.00 $32,418.32

Store the data 0.00 0.00 80.00 0.00 80.00 $4,395.20 $0.00 $36,610.00 0.50 40.00 $20,502.60

TOTAL varies varies varies varies varies varies varies varies varies 866.84 $223,150.30

a

 Exhibit includes rounding.

Hazardous Waste Report
81

EXHIBIT 5

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $86.56/ $76.38/ $54.94/ $23.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 24 6.00 $329.76

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 24 54.00 $2,777.76

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 4 1.00 $54.96

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 4 9.00 $462.96

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 2 0.50 $27.48

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 2 4.50 $231.48

Subtotal varies varies varies varies varies varies varies varies varies 75.00 $3,884.40

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 9,463 2,365.75 $130,021.62

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 9,463 21,291.75 $1,095,247.62

Generate EPA Identification Number and send EPA

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.72 $0.00 $0.46 9,463 4,731.50 $115,259.34

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 36,057 9,014.25 $495,423.18

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 36,057 81,128.25 $4,173,237.18

Subtotal varies varies varies varies varies varies varies varies varies 118,531.50 $6,009,188.94

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 8 2.00 $109.92

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 8 18.00 $925.92

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 0 0.00 $0.00

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 0 0.00 $0.00

Subtotal varies varies varies varies varies varies varies varies varies 20.00 $1,035.84

a

 Exhibit includes rounding.

Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

Notification of Hazardous Waste Activity under RCRA Section 3010

Initial Notification

Subsequent Notification

Notification prior to operating under exclusion(s)

Notification by March 1 of each even numbered year thereafter

Notification indicating that the hazardous secondary materials are no longer managed in accordance with the exclusion

Eligible Academic Entities

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

Intent to Comply with Subpart K and Recordkeeping of Agreements

Withdrawal from 40 CFR Part 262, Subpart K
82

EXHIBIT 5 (continued)

NOTIFICATION OF REGULATED WASTE ACTIVITY

ESTIMATED ANNUAL FEDERAL AGENCY HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $86.56/ $76.38/ $54.94/ $23.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 60 15.00 $824.40

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 60 135.00 $6,944.40

Generate EPA Identification Number and send EPA

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.72 $0.00 $0.46 60 30.00 $730.80

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 20 5.00 $274.80

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 20 45.00 $2,314.80

Generate EPA Identification Number and send EPA

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.72 $0.00 $0.46 20 10.00 $243.60

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 56 14.00 $769.44

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 56 126.00 $6,481.44

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 18 4.50 $247.32

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 18 40.50 $2,083.32

Subtotal varies varies varies varies varies varies varies varies varies 425.00 $20,914.32

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 85 21.25 $1,167.90

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 85 191.25 $9,837.90

Generate EPA Identification Number and send EPA

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.72 $0.00 $0.46 85 42.50 $1,035.30

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 29 7.25 $398.46

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 29 65.25 $3,356.46

Generate EPA Identification Number and send EPA

Identification Number to facility 0.00 0.00 0.00 0.50

0.50 $11.72 $0.00 $0.46 29 14.50 $353.22

Review completed EPA Form 8700-12 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 156 39.00 $2,143.44

Enter EPA Form 8700-12 information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 156 351.00 $18,055.44

Review letter requesting EPA Identification Number 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 52 13.00 $714.48

Enter letter information into database 0.00 0.00 2.00 0.25 2.25 $115.74 $0.00 $0.00 52 117.00 $6,018.48

Subtotal varies varies varies varies varies varies varies varies varies 862.00 $43,081.08

TOTAL varies varies varies varies varies varies varies varies varies 119,913.50 $6,078,104.58

a

 Exhibit includes rounding.

Letter

Letter

Notification of Used Oil Activity under 40 CFR Part 279

Initial Notification

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

EPA Form 8700-12

Letter

Subsequent Notification

EPA Form 8700-12

Subsequent Notification

EPA Form 8700-12

Letter

EPA Form 8700-12

Initial Notification
83

EXHIBIT 6

PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Hours and Costs Per Agency Activity Total Hours and Costs

Leg. Mgr. Tech. Cler. Agency Labor Capital/ Number Total Total

 $86.56/ $76.38/ $54.94/ $23.44/ Hours/ Cost/ Startup O & M Respon./ Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Year Year Year Year Year Year Cost Cost Activ. Year Year

Review Part A Permit Applications 0.00 0.00 3.00 0.25 3.25 $170.68 $0.00 $0.00 4 13.00 $682.72

Ensure that Part A Permit Application and Reports have 

been signed by appropriate person

0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 4 1.00 $54.96

Review new ly authorized signatures w hen a different 

individual or position gains responsibility for the overall 

operation of a facility

0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 1 0.25 $13.74

Review signature certifications 0.00 0.00 0.25 0.00 0.25 $13.74 $0.00 $0.00 4 1.00 $54.96

Enter Part A Application information into RCRAInfo

Database

0.00 0.00 0.00 1.00 1.00 $23.44 $0.00 $0.00 4 4.00 $93.76

Notify applicant of deficiency in the Part A Application 0.00 0.00 0.50 0.10 0.60 $29.81 $0.00 $0.00 1 0.60 $29.81

Subtotal varies varies varies varies varies varies varies varies varies 19.85 $929.95

Review revised Part A Permit Application 0 0 2 0.25 2.25 $115.74 $0.00 $0.00 22 49.50 $2,546.28

Enter revised Part A Permit Application information into 

RCRAInfo Database

0 0 0 0.5 0.50 $11.72 $0.00 $0.00 22 11.00 $257.84

Review justifications for changes 0.5 0.25 0.75 0 1.50 $103.58 $0.00 $0.00 7 10.50 $725.06

Review Subpart H compliance demonstrations 0.5 0.25 0.75 0 1.50 $103.58 $0.00 $0.00 7 10.50 $725.06

Subtotal varies varies varies varies varies varies varies varies varies 81.50 $4,254.24

TOTAL varies varies varies varies varies varies varies varies varies 101.35 $5,184.19

a

 Exhibit includes rounding.

Part A Permit Application

Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations
84

EXHIBIT 7

2011 HAZARDOUS WASTE REPORT, NOTIFICATION OF REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

TOTAL ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN SUMMARYa

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Information Collection Requirement Year Year Costs Costs Year

Hazardous Waste Report (Exhibit 1A) 161,587.78 $9,384,912.05 $0.00 $55,220.16 $9,440,132.21

Notification of Regulated Waste Activity (Exhibit 2A) 30,903.40 $1,659,604.39 $0.00 $140,353.93 $1,799,958.32

Part A Hazardous Waste Permit Application and Modification (Exhibit 3A) 344.44 $22,724.62 $0.00 $215.34 $22,939.96

Subtotal 192,835.62 $11,067,241.06 $0.00 $195,789.43 $11,263,030.49

Hazardous Waste Report (Exhibit 1B) 9,692.23 $384,904.16 $0.00 $6,081.90 $390,986.06

Notification of Regulated Waste Activity (Exhibit 2B) 2,923.01 $97,368.08 $0.00 $12,018.61 $109,386.69

Part A Hazardous Waste Permit Application and Modification (Exhibit 3B) 44.15 $1,718.03 $0.00 $17.46 $1,735.49

Subtotal 12,659.39 $483,990.27 $0.00 $18,117.97 $502,108.24

Hazardous Waste Report (Exhibit 1C) 234,646.68 $6,467,908.06 $0.00 $31,018.68 $6,498,926.74

Part A Hazardous Waste Permit Application and Modification (Exhibit 3C) 101.35 $3,275.60 $0.00 $0.00 $3,275.60

Subtotal 234,748.03 $6,471,183.66 $0.00 $31,018.68 $6,502,202.34

Hazardous Waste Report 405,926.69 $16,237,724.27 $0.00 $92,320.74 $16,330,045.01

Notification of Regulated Waste Activity 33,826.41 $1,756,972.47 $0.00 $152,372.54 $1,909,345.01

Part A Hazardous Waste Permit Application and Modification 489.94 $27,718.25 $0.00 $232.80 $27,951.05

Total 440,243.04 $18,022,414.99 $0.00 $244,926.08 $18,267,341.07

2-Year Total 880,486 $36,044,830 $0 $489,852 $36,534,682

a

 Exhibit includes rounding.

Private Facilities

State and Local Government Facilities

All Respondents

State Agencies
85

EXHIBIT 8

2011 HAZARDOUS WASTE REPORT, NOTIFICATION OF REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS WASTE PERMIT APPLICATION AND MODIFICATION

TOTAL ESTIMATED ANNUAL EPA HOUR AND COST BURDEN SUMMARYa

Total Total Annual Annual Total

Hours per Labor Cost per Capital/Startup O & M Cost per

Information Collection Requirement Year Year Costs Costs Year

Hazardous Waste Report (Exhibit 4) 866.84 $37,485.30 $0.00 $185,665.00 $223,150.30

Notification of Regulated Waste Activity (Exhibit 5) 119,913.50 $6,073,662.36 $0.00 $4,442.22 $6,078,104.58

Part A Hazardous Waste Permit Application and Modification (Exhibit 6) 101.35 $5,184.19 $0.00 $0.00 $5,184.19

Total 120,881.69 $6,116,331.85 $0.00 $190,107.22 $6,306,439.07

2-Year Total 241,764 $12,232,664 $0 $380,214 $12,612,878

a

 Exhibit includes rounding.