SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 1573.13

"PART B PERMIT APPLICATION, PERMIT MODIFICATIONS,

AND SPECIAL PERMITS"

February 2013
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection..........................................................................1

1(b) Short Characterization/Abstract...............................................................................1

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection ...........................................................................3

2(b) Practical Utility/Users of the Data ...........................................................................9

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication.......................................................................................................11

3(b) Public Notice Required Prior to ICR Submission to OMB ...................................11

3(c) Consultations..........................................................................................................11

3(d) Effects of Less Frequent Collection.......................................................................12

3(e) General Guidelines.................................................................................................12

3(f) Confidentiality .......................................................................................................12

3(g) Sensitive Questions................................................................................................12

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes.........................................................................................12

4(b) Information Requested...........................................................................................14

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities...................................................................................................84

5(b) Collection Methodology and Management............................................................93

5(c) Small Entity Flexibility..........................................................................................93

5(d) Collection Schedule ...............................................................................................93

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden..............................................................................97

6(b) Estimating Respondent Costs ................................................................................97

6(c) Estimating State Agency Burden and Cost............................................................98

6(d) Estimating the Respondent Universe and Total Burden and Costs .......................99

6(e) Bottom Line Burden Hours and Cost Tables.......................................................111

6(f) Reasons for Change in Burden ............................................................................130

6(g) Burden Statement.................................................................................................130

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This ICR is titled "Part B Permit Application, Permit Modifications, and Special 

Permits," ICR number 1573.13, OMB Control Number 2050-0009.

1(b) Short Characterization
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The Resource Conservation and Recovery Act (RCRA) of 1976, as amended by the 

Hazardous and Solid Waste Amendments (HSWA) of 1984, requires EPA to establish a national 

regulatory program to insure that hazardous wastes are managed in a manner protective of 

human health and the environment. Specifically, the statute requires EPA to promulgate 

regulations that establish performance standards and permitting requirements applicable to 

hazardous waste treatment, storage, and disposal facilities (TSDFs). Section 3004 of Subtitle C 

establishes performance standards applicable to these facilities. Section 3005 requires EPA to 

promulgate regulations requiring these facilities to obtain a permit. In the event permit 

modifications are proposed by an applicant or EPA, modifications must conform to the 

requirements under Sections 3004 and 3005. The regulations implementing these requirements 

are codified at 40 CFR Parts 264 and 270.

This ICR provides a comprehensive discussion of the requirements for owner/operators 

of TSDFs submitting applications for a Part B permit or permit modification. The information 

collections contained in this ICR are divided into three sections: demonstrations and exemptions 

from requirements (40 CFR Part 264), contents of the Part B application (40 CFR Part 270), and 

permit modifications and special permits (40 CFR Part 270).

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

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

analyzed in this ICR.

Demonstrations and Exemptions from Requirements

Releases from Regulated Units and Specific Unit Requirements

EPA promulgated a number of regulations in 40 CFR Part 264 providing owner/operators 

the opportunity to submit demonstrations to exempt their facilities from certain requirements. In 

§264.90, EPA promulgated regulations allowing owner/operators to obtain an exemption from 

the Subpart F requirements regarding releases into the uppermost aquifer. In §§264.193, 

264.221, 264.251, 264.272, 264.301, and 264.344, EPA promulgated regulations outlining the 

requirements for owner/operators petitioning to exempt units (tank systems, surface 

impoundments, waste piles, land treatment, landfills, and incinerators) at their facilities from 

specific requirements. EPA needs this information to evaluate the accuracy and completeness of 

petitions for exemptions submitted by owner/operators. These requirements insure that only

facilities fully protective of human health and the environment are granted exemptions, and 

contribute to EPA’s goal of preventing contamination of the environment from hazardous waste 

treatment, storage, and disposal practices.

Contents of the Part B Application
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General Information

EPA promulgated regulations in §270.1(c)(5) allowing owner/operators of surface 

impoundments, land treatment units, and waste piles closing by removal or decontamination 

under Part 265 standards to petition the Regional Administrator for a determination that a 

post-closure permit is not required. The owner/operator will need to demonstrate that the 

particular unit does not require a post-closure permit because its closure met the applicable Part 

264 closure standards. Similar to the exemption provisions in CFR Part 264 (discussed in 

previous section), EPA needs this information to evaluate the accuracy and completeness of the 

claims made in the petitions for exemptions submitted by owner/operators. These requirements 

contribute to EPA’s goal of ensuring that hazardous waste management facilities are closed in a 

manner fully protective of human health and the environment.

Permit Application

Section 3019 of RCRA requires EPA to promulgate regulations requiring 

owner/operators of facilities that store, treat, or dispose of hazardous waste in a surface 

impoundment or landfill to submit information on the potential for the public to be exposed to 

hazardous wastes or hazardous constituents through releases related to the unit (40 CFR 

§270.10(j)). EPA needs this information to comprehensively evaluate the potential risk posed by 

facilities seeking permits. This information aids EPA’s in meeting its goal of ascertaining and 

minimizing risks to human health and the environment from hazardous waste management 

facilities.

General Requirements, General Facility Standards, Financial Assurance, Ground-Water 

Protection, Regulated Units, and Other Requirements

RCRA Section 3005 requires EPA to promulgate regulations detailing informational 

requirements for owner/operators submitting Part B permit applications. EPA promulgated these 

requirements in 40 CFR Parts 264 and 270:

 Section 270.14(a) allows owner/operators to petition EPA for relief from 

submission of information prescribed in Part B on a case-by-case basis by

demonstrating that such information cannot be provided to the extent required.

 Section 270.14(b)(1)-(14) requires owner/operators of hazardous waste 

management facilities to submit information on compliance with general facility

standards in their Part B permit applications.

 Sections 270.14 - .16 require owner/operators of new facilities to submit detailed 

written estimates of the cost of facility closure and post-closure care in 

accordance with the requirements of §§264.142(a) and 264.144(a), respectively.
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 Sections 270.14 - .16 also require owner/operators to establish and provide 

evidence of financial assurance for facility closure (§264.143) and post-closure 

(§264.145). Owner/operators can establish financial assurance with a number of 

financial instruments.

 Section 264.14(b)(17) requires owner/operators to document the amount of 

insurance meeting specifications detailed in §264.147(a) and, if applicable, 

§264.147(b), that are in effect before initial receipt of hazardous waste for 

treatment, storage, or disposal.

 Section 270.14(b)(18) requires owner/operators to provide proof of coverage by a 

State financial mechanism in compliance with §§264.149 or 264.150, where 

appropriate. Section 264.149 allows owner/operators to use State-required 

financial assurance mechanisms to meet §§264.143, 264.145, or 264.147 

requirements. Section 264.150 requires owner/operators to notify EPA when a 

State assumes legal responsibility or assures availability of funds for an 

owner/operator’s compliance with the closure, post-closure care, or liability

requirements of this part.

 Section 270.14(b)(19) requires owner/operators to provide a topographic map 

showing a distance of 1000 feet around the facility. EPA also promulgated 

regulations in §270.14(b)(21) requiring owner/operators of land disposal facilities 

that have received approval for a case-by-case extension under §268.5 or a 

petition under §268.6 to submit a copy of the notice of approval for the extension 

or petition with their Part B permit application.

 Section 270.14(c)(1) - (5) requires owner/operators to submit additional 

information to EPA regarding protection of ground water when applying for a 

Part B permit. The information required includes information on site-specific 

characteristics, and a ground-water monitoring program as required under 

§264.97. The monitoring program must include sampling and analysis 

procedures, sampling intervals, and statistical methods to be used in evaluating 

ground-water monitoring data.

 Section 270.14(c)(6) requires that if the presence of hazardous constituents has 

not been detected in the ground water at the time of permit application, the 

owner/operator must submit to EPA sufficient information, supporting data, and 

analyses to establish a detection monitoring program meeting the requirements of 

§264.98. This information includes information required by EPA to determine 

the parameters or constituents to be monitored under the detection monitoring 

program, as well as information for determining appropriate time periods for 

identifying contamination.

 Section 270.14(c)(7) requires that if the presence of hazardous constituents has 
6

been detected in the ground water at the point of compliance at the time of the 

permit application, the owner/operator must submit to EPA sufficient information, 

supporting data, and analyses to establish a compliance monitoring program 

meeting the requirements of §264.99. Section 264.99 requires owner/operators to 

submit to EPA all information necessary to determine a reasonable time period for 

identifying significant evidence of increased contamination during compliance 

monitoring.

 Section 270.14(c)(8) requires that if hazardous constituents have been measured 

in the ground water which exceed the concentration limits established under 

§264.94 Table 1, or if ground-water monitoring conducted at the time of permit 

application under §§265.90 through 265.94 at the waste boundary indicates the 

presence of hazardous constituents from the facility in ground water over 

background concentrations, the owner/operator must submit to EPA sufficient 

information, supporting data, and analyses to establish a corrective action 

program which meets the requirements of §264.100.

 Section 270.14(d) establishes Part B information requirements for solid waste 

management units.

EPA needs the various Part B permit information to evaluate the compliance of facilities 

with the permitting standards. These requirements contribute to EPA’s goal of insuring that 

hazardous waste management facilities are operated in a manner fully protective of human health 

and the environment.

Specific Part B Information Requirements

EPA promulgated regulations in 40 CFR Part 270 requiring owner/operators to submit 

specific additional information for various units at their facilities. These requirements are 

specified for owner/operators of facilities that perform the following activities:

 Store containers of hazardous waste (§270.15);

 Use tanks to store or treat hazardous waste (§270.16);

 Store, treated or dispose of hazardous waste in surface impoundments (§270.17);

 Store or treat hazardous waste in waste piles (§270.18);

 Incinerate hazardous waste (§270.19);

 Use land treatment to dispose of hazardous waste (§270.20);

 Dispose of hazardous waste in landfills (§270.21);
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 Treat, store, or dispose of hazardous waste in miscellaneous units (§270.23);

 Release organic emissions from process vents and leaks from equipment 

(§§270.24 and 270.25); and

 Collect, treat, or store hazardous waste on drip pads (§270.26).

EPA needs this information to evaluate each of the facility units included in permit 

applications. This information contributes to EPA’s goal of safe management of hazardous 

waste.

Schedules of Compliance

EPA promulgated regulations in §270.33 detailing informational requirements for 

owner/operators developing schedules of compliance leading to compliance with the Act and 

regulations. EPA needs this information to determine whether schedules of compliance are 

reasonable.

Permit Modifications and Special Permits

Permit Modifications

EPA promulgated regulations in 40 CFR Part 270 outlining procedures for modification 

and transfer of permits:

 Compliance with Class 1 modification requirements and submittal of specific 

financial and contractual information before transferring ownership or operational 

control of a facility (§270.40(b));

 Specified procedures for owner/operators submitting permit modifications at the 

request of the Agency (§270.41);

 Specified procedures for owner/operators applying for Class 1 permit 

modifications (§270.42(a)), and owner/operators applying for Class 2 or 3 permit 

modifications (§270.42(b) - (c));

 Specified procedures for owner/operators requesting a classification of a permit 

modification (§270.42(d)); and

 Specified procedures for owner/operators applying for temporary authorization 

(§270.42(e)), and for owner/operators handling newly regulated wastes hazardous 

or managing waste in newly regulated units (§270.42(g)).
8

EPA needs this information to comprehensively evaluate whether requests for 

modifications or transfer of ownership should be granted. The permit modification procedures 

contribute to EPA’s goal of providing a role for the public in the permitting process. In general, 

these informational requirements aid in meeting EPA’s goal of ascertaining and minimizing risks 

to human health and the environment from hazardous waste management facilities.

In 40 CFR Part 264, Subpart S, EPA promulgated regulations for corrective action 

management units (CAMUs). EPA needs to collect information from facilities that are engaged 

in, or will be initiating, corrective action to effectively designate CAMUs.

Expiration and Continuation of Permits

EPA promulgated regulations in §§270.50 and 270.51 requiring owner/operators to renew 

their Part B permit. In order to renew an expiring permit, owner/operators must submit an 

application containing the information required under §270.14 and the applicable sections of 

§§270.15 through 270.29. The permit renewal process provides EPA with an opportunity to 

complete an extensive review of the facility permit to determine whether the terms of the permit 

continue to provide the most appropriate mechanism for protecting human health and the 

environment.

Special Forms of Permits

EPA promulgated regulations in §270.60 and §§270.62 through 270.65 creating 

additional forms of permits. Informational requirements are specified for these permits in the 

following sections:

 Permits by rule (§270.60);

 Hazardous waste incinerator permits (§270.62);

 Permits for land treatment demonstrations using filed test or laboratory analyses 

(§270.63);

 Interim permits for UIC wells (§270.64); and

 Research, development, and demonstration permits (§270.65).

EPA needs this information to comprehensively evaluate permit applications. These 

informational requirements contribute EPA’s goal of ascertaining and minimizing risks to human 

health and the environment from hazardous waste management facilities.

Interim Status

Termination of Interim Status
9

EPA promulgated regulations at 40 CFR Part 270, Subpart G covering interim status 

facilities. Section 270.73 requires land disposal facilities that become subject to permit 

requirements as a result of statutory or regulatory amendments to submit within 12 months a Part 

B permit application and a certification that the facility is in compliance with all applicable 

ground-water monitoring and financial responsibility requirements. EPA needs this information 

to ensure that such facilities come under permit conditions and are operated in a manner 

protective of human health and the environment.

2(b) Practical Utility and Use and Users of Data

This section describes the users of the collected data and how the information will be 

used.

Demonstrations and Exemptions from Requirements

Releases from Regulated Units and Specific Unit Requirements

EPA uses the information submitted by owner/operators in their exemption petitions to 

evaluate these demonstrations fully. Owner/operators of facilities must establish that they do not 

need to comply with the applicable requirements to be protective of human health and the 

environment.

Contents of the Part B Application

General Information

EPA uses the required information to fully evaluate petitions submitted by

owner/operators for their exemptions from post-closure permit requirements. Owner/operators 

of facilities must establish that the facility was closed in a manner protective of human health 

and the environment.

Permit Application

EPA uses information on exposure potential to minimize any risks to human health from 

hazardous waste management facilities. If EPA determines that a facility poses a substantial risk 

to human health, EPA may request that the Agency for Toxic Substances and Disease Registry

conduct a health assessment.

General Requirements, General Facility Standards, Financial Assurance, Ground-Water 

Protection, Regulated Units, and Other Requirements

EPA uses the information requirements in 40 CFR Parts 264 and 270 for owner/operators 

submitting Part B applications to evaluate compliance with various elements of the regulations. 

For example, the general facility standards informational requirements provide EPA with 
10

information demonstrating compliance with standards regarding the facility’s contingency plan, 

the inspection schedule, and security procedures. EPA uses the financial assurance information 

requirements to evaluate the facility owner’s financial ability to close the facility, to maintain the 

facility after closure, and to respond to any contingencies. Both EPA and the owner/operators 

use the ground-water protection information to evaluate the state of the underlying ground water, 

the adequacy of the monitoring program, and whether hazardous constituents are present in the 

ground water.

Specific Part B Information Requirements

EPA uses information regarding specific units at facilities to evaluate the adequacy of 

each unit to manage hazardous wastes. Additional information is required because each of the 

different types of hazardous waste management units presents different risks to the environment 

and consequently requires different standards. EPA reviews the submittals of each type of 

hazardous waste management unit to evaluate whether it is designed, built, and operated in a 

manner protective of human health and the environment. EPA uses the information required for 

process vents and equipment leaks to ensure compliance with air emissions standards.

Schedules of Compliance

Owner/operators use schedules of compliance to develop a list of activities needed to 

come into compliance with the applicable regulations. EPA uses performance test plans and 

documentation of compliance to ensure that design and operating procedures are in accordance 

with air emissions standards.

Permit Modifications and Special Permits

Permit Modifications

EPA uses permit information to evaluate the initial permit applications and any

subsequent requests for modifications. The public may also use draft EPA permit and permit 

modification determinations which incorporate data submitted by facilities to assess hazardous 

waste management facilities being developed in their communities.

EPA reviews data collected from facilities undergoing or scheduled to undergo corrective 

action to designate CAMUs at the facility.

Expiration and Continuation of Permits

EPA uses permit renewal applications to ensure that the terms of the facility permit 

remain protective of human health and the environment.

Special Forms of Permits

EPA uses the information requirements for these permits to determine compliance with 

the regulations. EPA needs this information to comprehensively evaluate whether applicant 
11

facilities are protective of human health and the environment.

Interim Status

Termination of Interim Status

EPA uses certifications collected from land disposal facilities to ensure that the facility

can satisfy ground-water monitoring and financial responsibility requirements and be operated in 

a manner protective of human health and the environment.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

There are no other Federal agencies with a permit program for hazardous waste facilities. 

Authorized States must modify their programs only after EPA promulgates Federal standards 

that are more stringent than the existing Federal standards. Section 3009 of RCRA allows States 

to impose standards more stringent than or in addition to those in the Federal program. In order 

to obtain authorization, a State must agree to have reporting requirements that are equivalent to 

EPA’s requirements. Facilities in authorized States will need to maintain records and submit 

reports to comply only with the States’ requirements; there is no parallel information submitted 

to EPA.

3(b) Public Notice Required Prior to ICR Submission to OMB

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

the Federal Register on October 31, 2012 (77 FR 65875) and provided a 60 day comment period 

for this ICR. No comments were received.

3(c) Consultations

The burden hours and cost estimates for this ICR have been well established, and were 

verified through the renewal of ICR 2050-0024. No additional consultations were made for this 

ICR.

3(d) Effects of Less Frequent Collection

EPA has sought to reduce the reporting frequency to the minimum that is necessary to 

ensure compliance with the rules. It would not be possible to collect this information less 

frequently and still assure that the requirements of permit regulations are met by 

owner/operators. The reporting frequency is essential to assure that the effect of any changes in 

the permit contents are made known to EPA.
12

3(e) General Guidelines

This ICR adheres to the guidelines stated in the 1980 Paperwork Reduction Act, as 

amended, OMB’s implementing regulations, EPA’s Information Collection Request Handbook, 

and other applicable OMB guidance.

3(f) Confidentiality

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which define EPA’s general 

policy on public disclosure of information, contain provisions for confidentiality. EPA does not 

anticipate requesting any confidential information.

3(g) Sensitive Questions

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

requirements.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The following is a list of NAICS codes associated with the facilities most likely to be 

affected by the Part B permit application and permit modifications under this ICR:

22132 Sewage Treatment Facilities

32411 Petroleum Refineries

32511 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

32551 Paint and Coating Manufacturing

32551 Paint and Coating Manufacturing

33271 Machine Shops

33422 Radio and Television Broadcasting and Wireless Communications 

Equipment Manufacturing

33633 Motor Vehicle Steering and Suspension Components (except Spring) 

Manufacturing

33634 Motor Vehicle Brake System Manufacturing

33635 Motor Vehicle Transmission and Power Train Parts Manufacturing

42271 Petroleum Bulk Stations and Terminals

44111 New Car Dealers

44711 Gasoline Stations with Convenience Store

44719 Other Gasoline Stations

48411 General Freight Trucking, Local

48421 Used Household and Office Goods Moving

48422 Specialized Freight (except Used Goods) Trucking, Local
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56292 Materials Recovery Facilities

221111 Hydroelectric Power Generation

221112 Fossil Fuel Electric Power Generation

221113 Nuclear Electric Power Generation

221119 Other Electric Power Generation

221121 Electric Bulk Power Transmission and Control

221122 Electric Power Distribution

311942 Spice and Extract Manufacturing

323110 Commercial Lithographic Printing

323114 Quick Printing

325131 Inorganic Dye and Pigment Manufacturing

325188 All Other Basic Inorganic Chemical Manufacturing

325188 All Other Inorganic Chemical Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325211 Plastics Material and Resin Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing

325998 All Other Miscellaneous Chemical Product Manufacturing

331311 Alumina Refining

332813 Electroplating, Plating, Polishing, Anodizing, and Coloring

332999 All Other Miscellaneous Fabricated Metal Product Manufacturing

333319 Other Commercial and Service Industry Machinery Manufacturing

333999 All Other General Purpose Machinery Manufacturing

334418 Printed Circuit/Electronics Assembly Manufacturing

334419 Other Electronic Component Manufacturing

336211 Motor Vehicle Body Manufacturing

336312 Gasoline Engine and Engine Parts Manufacturing

336322 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing

336322 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing

336399 All Other Motor Vehicle Part Manufacturing

336399 All Other Motor Vehicle Parts Manufacturing

454311 Heating Oil Dealers

454312 Liquefied Petroleum Gas (Bottled Gas) Dealers

562111 Solid Waste Collection

562111 Solid Waste Collection

562112 Hazardous Waste Collection

562112 Hazardous Waste Collection

562119 Other Waste Collection

562119 Other Waste Collection

562211 Hazardous Waste Treatment and Disposal

562212 Solid Waste Landfills

562213 Solid Waste Combustors and Incinerators

562219 Other Nonhazardous Waste Treatment and Disposal
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811111 General Automotive Repair

4(b) Information Requested

Demonstrations and Exemptions from Requirements

Releases from Regulated Units

(i) Data items:

40 CFR 264.90 allows owner/operators of facilities that treat, store, or dispose of 

hazardous waste to obtain an exemption from the Subpart F requirements regarding releases into 

the uppermost aquifer. Owner/operators must submit one of the following demonstrations to 

EPA in order to obtain an exemption:

 A demonstration that the unit meets the conditions of §§264.90(b)(2) (i) - (vii); or

 A demonstration, pursuant to §264.280(d), that the treatment zone of a land 

treatment unit that qualifies as a regulated unit does not contain levels of 

hazardous constituents that are above background levels of those constituents by

an amount that is statistically significant, and that an unsaturated zone monitoring 

program meeting the requirements of §264.278 has not shown a statistically

significant increase in hazardous constituents below the treatment zone during the 

operating life of the unit (§264.90(b)(3)) ; or

 A demonstration that there is no potential for migration of liquid from a regulated 

unit to the uppermost aquifer during the active life of the regulated unit (including 

the closure period) and the post-closure care period specified under §264.117 

(§264.90(b)(4)). This demonstration must be certified by a qualified geologist or 

geotechnical engineer.

(ii) Respondent activities:

In order to provide these demonstrations, owner/operators must perform the following 

activities:

 Read the regulations;

 Prepare and submit the appropriate demonstration;

 If submitting a no-migration demonstration under §264.90(b)(4), obtain 

certification from a qualified geologist or geotechnical engineer; and
15

 File a copy of the demonstration at the facility.

Specific Unit Requirements

(1) Tank Systems

(i) Data Items:

Section 264.193 requires that certain tank systems, including all new tank systems, be 

equipped with a secondary containment system in order to prevent the release of hazardous waste 

or hazardous waste constituents to the environment. Owner/operators may obtain a variance 

from the secondary containment requirements of this section by submitting a notification and 

demonstration in accordance with §§264.193(h)(1) and 264.193(g), respectively. 

Owner/operators may also submit demonstrations for a variance from the 24-hour leak detection 

requirements (§§264.193(c)(3) and 264.193(e)(3)(iii)) and the 24-hour waste removal 

requirement (§264.193(c)(4)). In addition, owner/operators must submit information for an 

equivalent secondary containment device, where appropriate. Data items associated with these 

requirements include the following:

 A notification of intent to conduct and submit a demonstration for a variance from 

the secondary containment requirements (§264.193(h)(1)). The notification must 

include a description of the steps necessary to conduct the demonstration and a 

timetable for completing each of the steps;

 A demonstration that alternate design and operating practices, together with 

location characteristics, will prevent the migration of any hazardous waste or 

hazardous waste constituent into the ground water or surface water at least as 

effectively as secondary containment during the active life of the tank system. 

This demonstration must include the information required under 

§264.193(g)(1)(i)-(iv); or

 A demonstration that in the event of a release that does migrate to ground water or 

surface water, no substantial present or potential hazard will be posed to human 

health or the environment. Because new tank systems cannot obtain exemption 

from the secondary containment requirements by submitting this demonstration, 

this ICR assumes that no respondents will submit this demonstration 

(§264.193(g)(2));

 For secondary containment systems (§264.193(c)(3)) and double-walled tanks 

(§264.193(e)(3)(iii)), a demonstration that existing detection technologies or site 

conditions will not allow detection of a release within 24 hours;
16

 A demonstration that removal of the released waste or accumulated precipitation 

cannot be accomplished within 24 hours (§264.193(c)(4));

 A written description of an equivalent secondary containment device if such a 

device is to be used in lieu of those listed under §264.193(d)(1) through (3); and

 Records of the assessments conducted in accordance with §§264.193(i) (1)-(3) 

(§264.193(i)(4)). This recordkeeping requirement is included in the General 

Facility Standards ICR (OMB Control No. 2050-0120).

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the notification of intent to make a demonstration;

 Prepare and submit the demonstration under §264.193(g)(1);

 Prepare and submit the demonstration for exemption from the 24-hour leak 

detection requirement;

 Prepare and submit the demonstration for exemption from the 24-hour waste 

removal requirement;

 Prepare and submit a written description of the equivalent secondary containment 

device; and

 File copies of the demonstrations at the facility.
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(2) Surface Impoundments

(i) Data items:

40 CFR 264.221 provides owner/operators of surface impoundments with the opportunity

to obtain an exemption from the liner and double liner requirements of §§264.221(a) and (c), 

respectively. An owner or operator of a leak detection system that is not located completely 

above the seasonal high table must submit a demonstration under §264.221(c)(4). 

Owner/operators may also obtain a waiver of the double liner requirements for any monofill 

under §264.221(e). In addition, owner/operators of any replacement surface impoundment unit 

may submit information under §264.221(f) in support of an exemption from §264.221(c). Data 

items associated with the requirements of this section include the following:

 To obtain an exemption from the liner requirements of §264.221(a), a 

demonstration that alternative design and operating practices, together with 

location characteristics, will prevent the migration of any hazardous constituents 

into the ground water or surface water at any future time. This demonstration 

must contain the information required under §264.221(b)(1)-(4). Because all 

surface impoundments are now required to have double liners, this ICR assumes 

that no respondents will submit this demonstration;

 For a leak detection system that is not located completely above the seasonal high 

water table, a demonstration that the operation of the leak detection system will 

not be adversely affected by the presence of ground water, as required under 

§264.221(c)(4);

 To obtain an exemption from the double liner and leachate collection and removal 

system requirements of §264.221(c), a demonstration that alternative design and 

operating practices, together with location characteristics, will prevent the 

migration of any hazardous constituent into the ground water or surface water at 

least as effectively as the double liner collection system (§264.221(d));

 To obtain a waiver of the double liner requirement for monofills (§264.221(e)), 

the owner/operator must demonstrate to the EPA that:

-- The monofill contains only hazardous wastes from foundry furnace 

emission controls or metal casting molding sand, and such wastes do not 

contain constituents which would render the wastes hazardous for reasons 

other than the toxicity characteristic; and

-- The monofill possesses the following qualities:

o At least one liner for which there is no evidence that such liner is 
18

leaking;

o Located more than one quarter mile from an underground source of 

drinking water as defined in ‘144.3; and

o Complies with generally applicable ground-water monitoring 

requirements for facilities with permits under RCRA section 

3005(c); or

-- The monofill is located, designed and operated so as to assure that there 

will be no migration of any hazardous constituent into ground water or 

surface water at any future time; and

 For a replacement surface impoundment unit for which an exemption from 

§264.221(c) is sought, information demonstrating that the unit was constructed in 

compliance with the design standards of RCRA sections 3004(o)(1)(A)(i) and 

(o)(5), and information supporting the claim that the liner is functioning as 

designed (§264.221(f)).

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the demonstration supporting an exemption from the liner 

requirement of §264.221(a);

 Prepare and submit the demonstration for the leak detection system 

(§264.221(c)(4);

 Prepare the demonstration for exemption from the §264.221(c) double liner and 

leachate collection and removal system requirements (§264.221(d);

 Prepare and submit the demonstration for a waiver of the double liner 

requirements for monofills;

 Prepare and submit the information supporting an exemption for a replacement 

unit; and

 File a copy of the demonstrations at the facility.

(3) Waste Piles
19

(i) Data items:

40 CFR 264.251(b) allows owner/operators of existing waste piles to obtain an exemption 

from the liner and leachate collection system requirements of §264.251(a). 40 CFR 

264.251(c)(5) requires owner/operators of a leak detection system that is not located completely 

above the seasonal high water table to demonstrate that the operation of the leak detection 

system will not be adversely affected by the presence of ground water. 40 CFR 264.251(d) 

allows owner/operators of new waste pile units, lateral expansions, replacement units constructed 

after January 29, 1992 to obtain an exemption from the double liner and leachate collection 

system requirements of §264.251(c). In addition, owner/operators of any replacement waste pile 

unit may submit information under §264.251(f) in support of an exemption from §264.251(c). 

Data items associated with the requirements of this section include:

 To obtain an exemption from the liner requirements of §264.251(a), a 

demonstration that includes the following information:

-- Information regarding the nature and quantity of the wastes;

-- The proposed alternative design and operation;

-- The facility’s hydrogeologic setting, including attenuative capacity and 

thickness of the liners and soils present between the pile and ground water 

or surface water; and

-- All other factors that would influence the quality and mobility of the 

leachate produced and the potential for it to migrate to ground water or 

surface water.

 For owner/operators of leak detection systems that are not located completely

above the seasonal high water table, a demonstration that the operation of the leak 

detection system will not be adversely affected by the presence of ground water;

 To obtain an exemption from the double liner and leachate collection and removal 

system requirements of §264.251(c), a demonstration that alternative design and 

operating practices, together with location characteristics will: (1) prevent the 

migration of any hazardous constituents into the ground water or surface water at 

least as effectively as the liners and leachate collection and removal systems; and 

(2) allow detection of leaks of hazardous constituents through the top liner at least 

as effectively; and

 For a replacement waste pile unit for which an exemption from §264.251(c) is 

sought, information demonstrating that the unit was constructed in compliance 
20

with the design standards of RCRA sections 3004(o)(1)(A)(i) and (o)(5), and 

information supporting the claim that the liner is functioning as designed 

(§264.251(f)).

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the demonstration supporting an exemption from the liner 

requirement of §264.251(a);

 Prepare and submit the demonstration for the leak detection system;

 Prepare and submit the demonstration for exemption from the double liner and 

leachate collection and removal system requirements of §264.251(c);

 Prepare and submit the information supporting an exemption for a replacement 

unit; and

 File a copy of the demonstration(s) at the facility.

(4) Land Treatment

(i) Data items:

40 CFR 264.272 requires owner/operators of land treatment units to submit a treatment 

demonstration to EPA, prior to application of the waste to the treatment zone, showing that 

hazardous constituents in the waste can be completely degraded, transformed, or immobilized 

(§264.272(a)). In making this demonstration, the owner/operator may use field tests, laboratory

analyses, available data, or, in the case of existing units, operating data.

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the demonstration; and
21

 File a copy of the demonstration at the facility.

(5) Landfills

(i) Data items:

40 CFR 264.301 provides owner/operators of landfills with the opportunity to obtain an 

exemption from the liner and/or double liner and leachate collection and removal system 

requirements of §§264.301(a) and (c), respectively. 40 CFR 264.301(c)(5) requires 

owner/operators of a leak detection system that is not located completely above the seasonal high 

water table to demonstrate that the operation of the leak detection system will not be adversely 

affected by the presence of ground water. Owner/operators may also obtain a waiver of the 

double liner requirements for any monofill under §264.301(e). In addition, owner/operators of 

any replacement waste pile unit may submit information under §264.301(f) in support of an 

exemption from §264.301(c). Data items associated with the requirements of this section include 

the following:

 To obtain exemption from the liner requirements of §264.301(a), a demonstration 

that alternative design and operating practices, together with location 

characteristics, will prevent the migration of any hazardous constituents into the 

ground water or surface water at any future time (§264.301(b)). Because landfills 

are now required to have double liners, this ICR assumes that no respondents will 

submit this demonstration;

 For owner/operators of leak detection systems that are not located completely

above the seasonal high water table, a demonstration that the operation of the leak 

detection system will not be adversely affected by the presence of ground water 

(§264.301(c)(5));

 To obtain exemption from the double liner and leachate collection and removal 

system requirements of §264.301(c), a demonstration that alternative design and 

operating practices, together with location characteristics, will prevent the 

migration of any hazardous constituent into the ground water or surface water at 

least as effectively as the double liner collection system (§264.301(d)); and

 To obtain a waiver of the double liner requirement for a monofill (§264.301(e)), 

the owner/operator must demonstrate to the EPA that:

-- The monofill contains only hazardous wastes from foundry furnace 

emission controls or metal casting molding sand, and such wastes do not 

contain constituents which would render the wastes hazardous for reasons 

other than the toxicity characteristic; and
22

-- The monofill possesses the following qualities:

o At least one liner for which there is no evidence that such liner is 

leaking;

o Located more than one quarter mile from an underground source of 

drinking water as defined in ‘144.3; and

o Complies with generally applicable ground-water monitoring 

requirements for facilities with permits under RCRA section 

3005(c); or

-- The monofill is located, designed and operated so as to assure that there 

will be no migration of any hazardous constituent into ground water or 

surface water at any future time; and

 For a replacement landfill unit for which an exemption from §264.301(c) is 

sought, information demonstrating that the unit was constructed in compliance 

with the design standards of RCRA sections 3004(o)(1)(A)(i) and (o)(5), and 

information supporting the claim that the liner is functioning as designed 

(§264.301(f)).

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the demonstration for an exemption from the liner 

requirement of §264.301(a);

 Prepare and submit the demonstration for the leak detection system;

 Prepare and submit the demonstration for an exemption from the double liner and 

leachate collection and removal system requirements of §264.301(c);

 Prepare and submit the demonstration for a waiver of the double liner 

requirements for monofills;

 Prepare and submit the information supporting an exemption for a replacement 

unit; and
23

 File a copy of the demonstration(s) at the facility.

(6) Incinerators

(i) Data items:

40 CFR 264.344 requires that the period beginning with initial introduction of hazardous 

waste to the incinerator and ending with initiation of the trial burn not exceed a duration of 720 

hours operating time for treatment of hazardous waste. However, EPA may extend the duration 

of this period once for up to 720 additional hours if the owner/operator can demonstrate good 

cause for the extension.

(ii) Respondent activities:

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the demonstration; and

 File a copy of the demonstration at the facility.

Contents of the Part B Application

General Information

(i) Data items:

Under 40 CFR 270.1(c)(5), owner/operators of surface impoundments, land treatment 

units, and waste piles closing by removal or decontamination under Part 265 standards who have 

not submitted a Part B application for a post-closure permit may petition EPA for a 

determination that a post-closure permit is not required because the closure meets the applicable 

Part 264 closure standards. The petition must include the following information:

 Data demonstrating that closure by removal or decontamination standards were 

met; or

 Data demonstrating that the unit closed under State requirements that met or 

exceeded the applicable Part 264 closure-by-removal standard.

(ii) Respondent activities:
24

Respondent activities associated with §270.1(c)(5) include reading the regulations, 

developing and submitting the petition, and filing a copy of the petition at the facility.

Permit Application

(i) Data items:

40 CFR 270.10(j) requires that Part B permit applications submitted by owner/operators 

of facilities that store, treat, or dispose of hazardous waste in a surface impoundment or landfill 

be accompanied by information on the potential for the public to be exposed to hazardous wastes 

or hazardous constituents through releases related to the unit. The data items for this 

requirement include the following information:

 Potential for releases from both normal operations and accidents at the unit, 

including releases associated with transportation to or from the unit;

 The potential pathways of human exposure to hazardous wastes or constituents 

resulting from the releases described above; and

 The potential magnitude and nature of the human exposure resulting from such 

releases.

(ii) Respondent activities:

Respondent activities associated with §270.10(j) include reading the regulations, 

collecting and submitting the required data, and filing the data at the facility.

General Requirements

(i) Data items:

Under 40 CFR 270.14(a), owner/operators may obtain from EPA relief from submission 

of information prescribed in Part B on a case-by-case basis by demonstrating that such 

information cannot be provided to the extent required.

(ii) Respondent activities:

Respondent activities associated with the demonstration submitted under §270.14(a) 

include reading the regulations, preparing and submitting the demonstration, and filing the 

demonstration at the facility.

General Facility Standards
25

(i) Data items:

Under 40 CFR 270.14(b) (1)-(14), owner/operators of hazardous waste management 

facilities must submit in their Part B permit applications information on compliance with general 

facility standards. Data items required under these sections include the following:

 A general description of the facility (§270.14(b)(1));

 Chemical and physical analyses of the hazardous waste to be handled at the 

facility. At a minimum, these analyses should contain all the information that 

must be known to treat, store, or dispose of the wastes properly in accordance 

with Part 264 (§270.14(b)(2));

 A waste analysis plan describing the procedures that will be carried out to comply

with §264.13(a). The plan should contain information required under §264.13(b) 

(1)-(7) and, for off-site facilities, the information required under §264.13(c) 

(§270.14(b)(3));

 A description of the security procedures and equipment required by §264.14, or a 

justification demonstrating the reasons for requesting a waiver of this requirement 

(§270.14(b)(4)). To obtain a waiver, owner/operators must demonstrate to EPA 

that:

-- Physical contact with the waste, structures, or equipment within the active 

portion of the facility will not injure unknowing or unauthorized persons 

or livestock which may enter the active portion of the facility; and

-- Disturbance of the waste or equipment, by the unknowing or unauthorized 

entry of persons or livestock onto the active portion of a facility, will not 

cause a violation of the requirements of this part;

 A general inspection schedule, as required under §264.15(b), for monitoring 

equipment that is important in preventing, detecting, or responding to 

environmental or human health hazards (§270.14(b)(5)). Where applicable, the 

inspection schedule should include the specific requirements in §§264.174, 

264.193(i), 264.195, 264.226, 264.254, 264.273, 264.303 and 264.602, and should 

identify the types of problems that are to be investigated during the inspection;

 If an exemption from special equipment requirements is sought under §264.32, a 

demonstration that none of the hazards posed by waste handled at the facility

could require the use of equipment required under §§264.32(a) through (d) 
26

(§270.14(b)(6));

 If an exemption from the aisle space requirements of §264.35 is sought, a 

demonstration that the aisle space is not needed to allow the unobstructed 

movement of personnel, fire protection equipment, spill control equipment, and 

decontamination equipment to any area of the facility operating in an emergency

(§270.14(b)(6));

 A contingency plan as required under sections 264.51, 264.52 and 264.53(a). 

Data elements that should be included in this plan are listed below:

-- A description of the arrangements agreed to by local police departments, 

fire departments, hospitals, contractors, and State and local emergency

response teams to coordinate emergency services;

-- An updated list of the names, addresses, and phone numbers (office and 

home) of all persons qualified to act as emergency coordinators;

-- An updated list of all emergency equipment at the facility and the location, 

physical description, and capabilities of the emergency equipment. The 

contingency plan should also indicate where the emergency equipment 

will be required; and

-- An evacuation plan for facility personnel where there is a possibility that 

evacuation may be necessary;

 A description of procedures, structures, or equipment used at the facility for the 

following purposes:

-- To prevent hazards in unloading operations;

-- To prevent runoff from hazardous waste handling areas to other areas of 

the facility or environment, or to prevent flooding;

-- To prevent contamination of water supplies;

-- To mitigate effects of equipment failure and power outages; and

-- To prevent undue exposure of personnel to hazardous waste;

 A description of precautions taken under §264.17 to prevent accidental ignition or 
27

reaction of ignitable, reactive, or incompatible wastes, including documentation 

demonstrating compliance with §264.17(c) (§270.14(b)(9)). The documentation 

may be based on references to published scientific or engineering literature, data 

from trial tests, waste analyses, or the results of the treatment of similar wastes by

similar treatment processes and under similar operating conditions;

 A description of traffic patterns, estimated volume, and control (§270.14(b)(10));

 Facility location information (§270.14(b)(11)). At a minimum, the location 

information provided must include:

-- An identification of the political jurisdiction in which the facility is 

proposed to be located;

-- If the facility is proposed to be located in an area listed in Appendix VI of 

Part 264, a demonstration of compliance with the seismic standard as 

defined under §264.18(a). This demonstration may be made using either 

published geologic data or data obtained from field investigations carried 

out by the applicant;

-- An identification of whether the facility is located within a 100-year 

floodplain. The identification must include the following information:

o The source of data for the determination;

o A copy of the relevant Federal Insurance Administration (FIA) 

flood map, if used, or the calculations and maps used where an FIA 

map is not available; and

o An identification of the 100-year flood level and any other special 

flooding factors which must be considered in designing, 

constructing, operating, or maintaining the facility to withstand 

washout from a 100-year flood;

-- Facilities located in a 100-year floodplain may submit a demonstration for 

exemption from design and operating standards under §264.18(b). The 

demonstration must establish the following:

o Procedures are in effect which will cause the waste to be removed 

safely, before flood waters can reach the facility, to a location 

where the wastes will not be vulnerable to flood waters; or

o For existing surface impoundments, waste piles, land treatment 

units, landfills, and miscellaneous units, no adverse effects on 

human health or the environment will result if washout occurs;
28

-- Owner/operators of facilities located in the 100-year floodplain that are not 

exempt from the design and operating standards under §264.18(b) must 

provide the following information:

o Engineering analysis to indicate the various hydrodynamic and 

hydrostatic forces expected to result at the site as consequence of a 

100-year flood; and

o Structural or other engineering studies showing the design of 

operational units and flood protection devices at the facility and 

how these will prevent washout; or

o If applicable, a detailed description of procedures to be followed to 

remove hazardous waste to safety before the facility is flooded;

-- Existing facilities not in compliance with §264.18(b) must provide a plan 

showing how the facility will be brought into compliance, along with a 

schedule for compliance;

 An outline of both the introductory and continuing training programs used to 

prepare persons to operate or maintain the facility in a safe manner as required to 

demonstrate compliance with §264.16, and a brief description of how training will

be designed to meet actual job tasks in accordance with the requirements in 

§264.16(a)(3) (§270.14(b)(12));

 A closure plan as required under §§264.112 and 264.197 (§270.14(b)(13)). The 

closure plan must include the information required under §264.112(b) (1)-(7). 

Owner/operators must also submit a written post-closure plan under §§264.118 

and 264.197, where applicable, which contains the information required under 

§264.118(b) (1)-(3). In addition, certain owner/operators of tanks, surface 

impoundments, waste piles, and drip pads may also need to submit a contingent 

closure and contingent post-closure plan under sections 264.197(c), 264.228(c), 

264.258(c), and 264.575(c), respectively; and

 For hazardous waste disposal units that have been closed, documentation that the 

post-closure notices required under §264.119 have been filed (§270.14(b)(14)).

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following 

activities:

 Read the regulations;

 Prepare a written description of the facility;
29

 Collect the analytical information required under §270.14(b)(2) and prepare a 

written report of the analyses conducted;

 Collect the data required in the waste analysis plan;

 Write the waste analysis plan;

 Prepare the description of security procedures and equipment; or

 Prepare a demonstration for a waiver of the security procedures and equipment 

requirements;

 Develop an inspection schedule;

 If applicable, prepare a demonstration for exemption from special equipment 

requirements;

 If applicable, prepare a demonstration for exemption from aisle space 

requirements;

 Collect the data required in the contingency plan;

 Write the contingency plan;

 Prepare the description of procedures, structures, or equipment;

 Prepare a description of precautions to prevent accidental ignition or reaction of 

ignitable, reactive, or incompatible wastes;

 Prepare a description of traffic patterns, estimated volume, and control;

 Compile and document the facility location information required under 

§270.14(b)(11);

 If the facility is proposed to be located in an area listed in Appendix VI, prepare a 

demonstration of compliance with the seismic standard;

 For facilities in a 100-year floodplain, prepare a demonstration for exemption 

from design and operating standards under §264.18(b);
30

 For facilities in a 100-year floodplain that are not exempt from §264.18(b), 

prepare an engineering analysis and engineering studies;

 For facilities not in compliance with §264.18(b), a compliance plan and schedule 

of compliance;

 Prepare outline of personnel training programs and description of training design;

 Write descriptions of the necessary closure activities;

 Estimate final closure;

 Write the closure schedule;

 Collect the necessary information for post-closure requirements;

 Write the post-closure plan;

 Prepare and submit documentation that post-closure notices have been submitted;

 Submit the general facility standards information; and

 File a copy of the documentation at the facility.

Financial Assurance

(1) Cost Estimates for Closure and Post-Closure Care

(i) Data items:

Sections 270.14(b)(15) and (16) require owner/operators to submit a detailed written 

estimate of the cost of facility closure and post-closure care in accordance with the requirements 

of §§264.142(a) and 264.144(a), respectively. These estimates must include the following data 

items:

 A written estimate containing:

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

extent and manner of its operation would make closure the most 

expensive, as indicated by its closure plan (§264.142(a)(1));
31

-- The annual cost of post-closure monitoring and maintenance of the facility

in accordance with the applicable post-closure regulations specified in 

§264.144(a);

-- The costs for tanks under §264.197(c)(3), for surface impoundments under 

§264.228(c)(2), for waste piles under §264.258(c)(2), and drip pads under 

§264.575(c)(2), of contingent closure and post-closure, if required; and

 Costs to the owner or operator of hiring a third party to conduct closure or 

post-closure care at the facility (or on-site disposal costs, if owner/operator can 

demonstrate that on-site disposal capacity will exist at all times throughout the 

facility’s life (§264.142(a)(2)).

(ii) Respondent activities:

Since cost estimates for closure and post-closure care are submitted with the Part B 

permit application, activities associated with developing the estimates are discussed in this ICR. 

However, prior to submitting a permit application, interim status facilities must prepare closure 

and post-closure cost estimates under §§265.142 and 265.144, respectively. Therefore, 

preparation of the closure and post-closure cost estimates for interim status facilities are 

discussed in the General Facility Standards ICR (OMB Control No. 2050-0120).

Owner/operators will need to engage in the following activities in order to collect the data 

required by §§264.142 and 264.144:

 Read the regulations;

 Collect data; and

 Prepare the written cost estimates.

(2) Financial Assurance for Closure and Post-Closure Care

(i) Data items:

Sections 270.14(b) (15) and (16) also require owner/operators to establish, and provide 

evidence of, financial assurance for facility closure (§264.143) and post-closure care (§264.145). 

Because evidence of financial assurance is submitted with the Part B permit application, 

activities associated with obtaining financial assurance are discussed in this ICR. However, prior 

to submitting a Part B permit application, interim status facilities must prepare evidence of 

financial assurance for closure and post-closure care under §§265.143 and 265.145, respectively. 

Therefore, the activities associated with preparing evidence of closure and post-closure financial 
32

assurance for interim status facilities are discussed in the General Facility Standards ICR (OMB 

Control No. 2050-0120).

Several financial instruments may be used for the purpose of establishing financial 

assurance for closure and post-closure care. These financial instruments include the following:

 Closure or post-closure trust fund (§§264.143(a) and 264.145(a));

 Surety bond guaranteeing payment into a closure or post-closure trust fund 

(§§264.143(b) and 264.145(b));

 Surety bond guaranteeing performance of closure or post-closure care 

(§§264.143(c) and 264.145(c));

 Closure or post-closure letter of credit (§§264.143(d) and 264.145(d));

 Closure or post-closure insurance (§§264.143(e) and 264.145(e)); and

 Financial test and corporate guarantee for closure or post-closure care 

(§§264.143(f) and 264.145(f)).

(ii) Respondent activities:

In order to comply with the requirements concerning financial assurance for closure and 

post-closure care, respondents must perform the following activities:

 Read the regulations; and

 Obtain and submit documentation of financial assurance.

(3) Use of a Financial Mechanism for Multiple Facilities

(i) Data items:

Sections 264.143(h) and 264.145(h) specify that owner/operators may use one of the 

above financial assurance mechanisms to meet the requirements of §§264.143 or 264.145 for 

more than one facility. In such cases, the owner/operator must provide the following data items 

for each facility:

 EPA identification number, name, and address; and

 The amount of funds for closure or post-closure care assured by the mechanism.
33

(ii) Respondent activities:

The information required under this section will be submitted with the information 

provided by the owner/operator to establish one of the financial assurance mechanisms listed 

above. Therefore, this ICR assumes that any respondent activities related to the requirements of 

this section are already covered under the previous sections.

(4) Liability Requirements

Section 270.14(b)(17) requires owner/operators of new facilities to provide 

documentation showing the amount of insurance meeting the specification of §264.147(a) and, if 

applicable, §264.147(b), that the owner/operator plans to have in effect before initial receipt of 

hazardous waste for treatment, storage, or disposal.

(a) Coverage for Sudden or Nonsudden Accidental Occurrences

(i) Data items:

Section 264.147(a) requires owner/operators of hazardous waste TSDFs, or a group of 

such facilities, to demonstrate financial responsibility for bodily injury and property damage to 

third parties caused by sudden accidental occurrences arising from operations at the facility or 

group of facilities. Section 264.147(b) requires owner/operators of surface impoundments, 

landfills, and land treatment facilities managing hazardous wastes, or combinations of such 

facilities to demonstrate financial responsibility for bodily injury and property damage to third 

parties caused by nonsudden accidental occurrences rising from facilities’ operations. In order to 

comply with these requirements, owner/operators will need to gather the following data items:

 A liability insurance policy (§§264.147(a)(1) and 264.147(b)(1)), accompanied by

a signed duplicate original of a Hazardous Waste Facility Liability Endorsement 

or a Certificate of Liability Insurance;

 Written evidence of passing a financial test or a written guarantee for liability 

coverage from the owner/operator’s parent corporation (§§264.147(a)(2) and 

264.147(b)(2));

 A letter of credit for liability coverage (§§264.147(a)(3) and 264.147(b)(3));

 A surety bond for liability coverage (§§264.147(a)(4) and 264.147(b)(4));

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

 A combination of insurance, financial test, guarantee, letter of credit, surety bond, 
34

and trust fund (§§264.147(a)(6) and 264.147(b)(6)).

(ii) Respondent activities:

To comply with the requirements of these sections, owner/operators will need to perform 

the following activities:

 Read the regulations; and

 Obtain and submit documentation of liability coverage using one of the financial 

instruments listed above.

(b) Request for Variance

(i) Data item:

Section 264.147(c) allow owner/operators to obtain a variance from EPA if they can 

demonstrate that the levels of financial responsibility required for sudden and nonsudden 

accidental occurrences are not consistent with the degree and duration of risk associated with 

treatment, storage, or disposal at the facility or group of facilities. The data item for this 

demonstration is:

 A request for a variance submitted as part of the permit application under 

§270.14(b)(17) for new facilities, or pursuant to the procedures for permit 

modification under §§270.41(a)(5) and 124.5. This request may include technical 

and engineering information as deemed necessary by EPA.

(ii) Respondent activities:

Owner/operators will need to engage in the following activities in requesting a 

variance:

 Read the regulations; and

 Prepare and submit the request for variance, including any technical or 

engineering information required by EPA.

(c) Adjustments by the Regional Administrator

(i) Data items:

Section §264.147(d) allows EPA to adjust the level of financial responsibility required 

under §264.147 in order to protect human health and the environment. Respondents will need to 
35

furnish the following data items should EPA decide to make such a determination:

 Any information that EPA requests to determine whether cause exists for such 

adjustments of level or type of coverage; and

 If the Regional Administrator decides to adjust the level or type of coverage, the 

data elements necessary for a permit modification. The activities and estimated 

burden and cost associated with permit modifications are included under the 

section on permit modifications below.

(ii) Respondent activities:

Owner/operators will need to engage in the following activities in order to satisfy the 

information collection requirements of this section:

 Read the regulations; and

 Prepare and submit to EPA any requested information.

(5) Coverage by a State Financial Mechanism

(i) Data items:

Section 270.14(b)(18) requires owner/operators to provide proof of coverage by a State 

financial mechanism in compliance with §§264.149 or 264.150, where appropriate. Section 

264.149 allows owner/operators to use State-required financial assurance mechanisms to meet 

§§264.143, 264.145, or 264.147 requirements. Section 264.150 requires owner/operators to 

notify EPA when a State assumes legal responsibility or assures availability of funds for an 

owner/operator’s compliance with the closure, post-closure care, or liability requirements of this 

part. Data items associated with these requirements include the following:

 A letter from the owner/operator requesting the following:

-- The State-required mechanism be considered acceptable for meeting the 

requirements of this subpart; or

-- The State’s assumption of responsibility be considered acceptable for 

meeting the requirements of this subpart;

 Evidence of the establishment of a State-required mechanism or a letter from the 

State describing the nature of the State’s assumption of responsibility. Each of 

these data items should include the following information:
36

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

-- The amount of funds for closure or post-closure care or liability

coverage assured by the mechanism; and

 Any additional information required by EPA in order to make the determination.

(ii) Respondent activities:

Respondent activities associated with the requirements of §264.149 include the 

following:

 Read the regulations;

 Submit the letter from the owner/operator;

 Submit written evidence of the establishment of a State-required financial 

assurance mechanism or letter from the State describing the State’s assumption of 

responsibility and including the information specified above; and

 Submit any additional information requested by EPA.

Other Requirements

(1) Topographical Map

(i) Data items:

Section 270.14(b)(19) requires owner/operators to provide a topographic map showing a 

distance of 1000 feet around the facility. The map shall clearly show the following information:

 Map scale and date;

 100-year floodplain area;

 Surface waters including intermittent streams;

 Surrounding land uses;

 A wind rose;
37

 Orientation of the map;

 Legal boundaries of the facility site;

 Access control;

 Injection and withdrawal wells both on-site and off-site;

 Buildings; treatment, storage, or disposal operations; or other structure;

 Barriers for drainage or flood control; and

 Location of operational units within the facility site, where hazardous waste is (or 

will be) treated, stored, or disposed (including equipment cleanup areas);

(ii) Respondent activities:

Respondents must perform the following activities in order to provide the topographic 

map:

 Read the regulations;

 Collect the necessary information; and

 Develop and submit the map.

(2) Case-By-Case Extensions and Petitions to Allow Land Disposal of a Waste 

Prohibited Under Subpart C of Part 268

(i) Data items:

Under §270.14(b)(21), owner/operators of land disposal facilities that have received 

approval for a case-by-case extension under §268.5 or a petition under §268.6 must submit a 

copy of the notice of approval for the extension or petition with their Part B permit application.

(ii) Respondent activities:

The burden associated with developing the extension application or petition is addressed 

in Land Disposal Restrictions ICR (OMB Control No. 2050-0085). To provide a copy of these 

documents for the Part B permit application, owner/operators must perform the following 

activities:
38

 Read the regulations; and

 Prepare and submit copy of the notice of approval.

Ground-Water Protection

(1) General Ground-Water Monitoring Requirements

(i) Data items:

Sections 270.14(c) (1)-(5) require owner/operators to submit additional information to

EPA regarding protection of ground water when applying for a Part B permit. The information 

required includes information on site-specific characteristics, and a ground-water monitoring 

program as required under §264.97. The monitoring program must include sampling and 

analysis procedures, sampling intervals, and statistical methods to be used in evaluating 

ground-water monitoring data. To fulfill the requirements of these sections, owner/operators 

must submit the following data items:

 A summary of the ground-water monitoring data obtained during the interim 

status period under §§265.90 through 265.94, where applicable (§270.14(c)(1));

 Identification of the uppermost aquifer and aquifers hydraulically interconnected 

beneath the facility property, including ground-water flow direction and rate, and 

the basis for such identification (§270.14(c)(2));

 On the topographic map required under §270.14(b)(19), a delineation of the 

following:

-- The waste management area;

-- The property boundary;

-- The proposed "point of compliance" as defined under §264.95;

-- The proposed location of ground-water monitoring wells as required under 

§264.97; and

-- Identification of aquifers, as required above;

 A description of any plume of contamination that has entered the ground water 

from a regulated unit at the time the application is submitted (§270.14(c)(4)). The 
39

description should:

-- Delineate the extent of the plume on the topographic map required under 

§270.14(b)(19); and

-- Identify the concentration of each Appendix IX (40 CFR Part 264) 

constituent throughout the plume or identify the maximum concentrations 

of each Appendix IX constituent in the plume;

 A description of the proposed ground-water sampling and analysis procedures as 

required under §264.97. At a minimum these procedures must include:

-- Procedures and techniques for sample collection, sample preservation and 

shipment, analytical procedures, and chain of custody control 

(§264.97(d));

-- Sampling and analytical methods appropriate for ground-water sampling 

and accurate measurement of hazardous constituents in ground-water 

samples (§264.97(e)); and

-- Procedures for determining the ground-water surface elevation each time 

ground water is sampled (§264.97(f));

 A statistical method to be used in evaluating ground-water monitoring data for 

each hazardous constituent. The method specified will be one of those listed 

under §264.97(h)(1) through (4), or another statistical test method submitted in 

accordance with §264.97(h)(5). In specifying the type of statistical method to be 

used, the owner/operator may also be required to supply the following 

information:

-- Where practical quantification limits (pql’s) are used, the pql must be 

submitted to EPA for approval;

-- If a control chart approach is used to evaluate ground-water monitoring 

data, the specific type of control chart and its associated parameter values 

shall be submitted to EPA for approval; and

-- If a tolerance interval or a prediction interval is used to evaluate 

ground-water monitoring data, the levels of confidence and, for tolerance 

intervals, the percentage of the population that the interval must contain 

shall contain must be submitted to EPA for approval; and
40

 A record of all ground-water monitoring data collected in accordance with 

§264.97(g). This information must be recorded in the facility operating record. 

Therefore, the burden associated with this requirement is included in the General 

Facility Standards ICR (OMB Control No. 2050-0120).

(ii) Respondent activities:

Respondents must perform the following activities to provide the information required in 

these sections:

 Read the regulations;

 Summarize ground-water monitoring data obtained during the interim status 

period under §§265.90 through 265.94;

 Collect and document the hydrogeologic information required under 

§270.14(c)(2);

 Add the required information to the topographical map required under 

§270.14(b)(19);

 Prepare a description of plume contamination, where applicable;

 Develop a ground-water sampling and analysis procedure;

 Determine the appropriate statistical method to be used;

 Submit the ground-water monitoring program; and

 File copies of the submitted information on file at the facility.

(2) Detection Monitoring Program

(i) Data items:

Section 270.14(c)(6) requires that if the presence of hazardous constituents has not been 

detected in the ground water at the time of permit application, the owner/operator must submit to 

EPA sufficient information, supporting data, and analyses to establish a detection monitoring 

program meeting the requirements of §264.98. This information includes data required by EPA 

to determine the parameters or constituents to be monitored under the detection monitoring 

program, as well as information for determining appropriate time periods for identifying 

contamination. The information submitted should include the following items:
41

 Information required to determine the parameters or constituents to be monitored 

under the detection monitoring program, including:

-- The types, quantities, and concentrations of constituents in wastes 

managed at the regulated unit;

-- The mobility, stability, and persistence of waste constituents or their 

reaction products in the unsaturated zone beneath the waste management 

area;

-- The detectability of indicator parameters, waste constituents, and reaction 

products in ground water; and

-- The concentrations or values and coefficients of variation of proposed 

monitoring parameters or constituents in the ground-water background;

 Detailed plans and an engineering report describing the proposed ground-water 

monitoring system, in accordance with the requirements of §264.97;

 Background values for each proposed monitoring parameter or constituent, or 

procedures to calculate such values (§270.14(c)(6)(iii));

 A description of proposed sampling, analysis and statistical comparison 

procedures to be utilized in evaluating ground-water monitoring data 

(§270.14(c)(6)(iv)). The requirements associated with providing this information 

are discussed in the previous section on General Ground-Water Monitoring 

Requirements; and

 Information required to determine a reasonable time period for identifying 

significant evidence of contamination, including information on the complexity of 

the statistical test and the availability of laboratory facilities for performing the 

analysis of ground-water samples (§264.98(f)(2)).

[Note: If the owner or operator determines pursuant to paragraph (f) that there is statistically

significant evidence of contamination for chemical parameters or hazardous constituents at any

monitoring well at the compliance point, he or she must submit to EPA an application for a Class 

2 or 3 permit modification to establish a compliance monitoring program under section 264.99. 

This activity is currently burdened in the Facility Ground-Water Monitoring Requirements ICR 

(OMB Control No. 2050-0033).]

(ii) Respondent activities:
42

To comply with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Compile the information required to determine monitoring parameters or 

constituents;

 Prepare the plans and engineering report describing the proposed ground-water 

monitoring system;

 Establish background values for each proposed monitoring parameter or 

constituent, or procedures for determining such values;

 Compile the information required to determine a reasonable time period for 

identifying significant evidence of contamination;

 Submit the required information; and

 Maintain copies of all submitted information on file at the facility.

(3) Compliance Monitoring Program

(i) Data items:

Section §270.14(c)(7) requires that if the presence of hazardous constituents has been 

detected in the ground water at the point of compliance at the time of the permit application, the 

owner/operator must submit to EPA sufficient information, supporting data, and analyses to 

establish a compliance monitoring program meeting the requirements of §264.99. Section 

264.99 requires owner/operators to submit to EPA all information necessary to determine a 

reasonable time period for identifying significant evidence of increased contamination during 

compliance monitoring. The information submitted to EPA should include the following items:

 A description of the wastes previously handled at the facility (§270.14(c)(7)(i));

 A characterization of the contaminated ground water, including concentrations of 

hazardous constituents (§270.14(c)(7)(ii));

 A list of hazardous constituents for which compliance monitoring will be 

undertaken in accordance with §§264.97 and 264.99 (§270.14(c)(7)(iii));
43

 Proposed concentration limits for each hazardous constituent, based on the criteria 

set forth in §264.94(a), including a justification for establishing any alternate 

concentration limits (§270.14(c)(7)(iv));

 Detailed plans and an engineering report describing the proposed ground-water 

monitoring system, in accordance with the requirements of §264.97 

(§270.14(c)(7)(v));

 A description of proposed sampling, analysis and statistical comparison 

procedures to be used in evaluating ground-water monitoring data 

(§270.14(c)(7)(vi)). The requirements associated with providing this information 

are discussed in the previous section on General Ground-Water Monitoring 

Requirements;

 Information necessary to determine a reasonable time period for identifying 

significant evidence of increased contamination, including information on the 

complexity of the statistical test and the availability of laboratory facilities for 

performing the analysis of ground-water samples (§264.99(d)(2)); and

 An engineering feasibility plan for a corrective action program necessary to meet 

the requirements of §264.100 (§270.14(a)).

(ii) Respondent activities:

Respondents must perform the following activities to provide the information required in 

this section:

 Read the regulations;

 Provide a description of wastes previously handled at the facility;

 Provide a characterization of contaminated ground water;

 Develop a list of hazardous constituents for which compliance monitoring will be 

undertaken in accordance with §§264.97 and 264.99;

 Develop proposed concentration limits for each hazardous constituent, and a 

justification for establishing any alternate concentration limits;

 Prepare plans and engineering report describing the proposed ground-water 

monitoring system;
44

 Compile the information necessary to determine a reasonable time period for 

identifying significant evidence of increased contamination;

 Develop an engineering feasibility plan for corrective action;

 Submit the required information; and

 Maintain copies of all submitted information on file at the facility.

(4) Corrective Action Program

(i) Data items:

Section 270.14(c)(8) requires that if hazardous constituents have been measured in the 

ground water which exceed the concentration limits established under §264.94 Table 1, or if 

ground-water monitoring conducted at the time of permit application under §§265.90 through 

265.94 at the waste boundary indicates the presence of hazardous constituents from the facility in 

ground water over background concentrations, the owner/operator must submit to EPA sufficient 

information, supporting data, and analyses to establish a corrective action program which meets 

the requirements of §264.100. The information submitted should include the following:

 A characterization of the contaminated ground water, including concentrations of 

hazardous constituents;

 The concentration limit for each hazardous constituent found in the ground water 

as set forth in §264.94;

 Detailed plans and an engineering report describing the corrective action to be 

taken;

 A description of how the ground water monitoring program will demonstrate the 

adequacy of the corrective action;

 If applicable, a schedule for submittal of the information required in 

§§270.14(c)(8)(iii) and (iv) in the permit. The owner/operator must obtain written 

authorization from EPA prior to submittal of the complete permit application; and

 A demonstration that alternate concentration limits will protect human health and 

the environment. The demonstration should include the information listed under 

§270.14(c)(8) (i)-(v). Owner/operators that submit such a demonstration are not 

required to submit information to establish a corrective action program. Instead, 

these owner/operators must submit sufficient information to establish a 
45

compliance monitoring program meeting the requirements of §264.99 and 

§270.14(c)(6).

(ii) Respondent activities:

Respondents must perform the following activities to provide the information required in 

this section:

 Read the regulations;

 Prepare a characterization of the contaminated ground water;

 Develop a concentration limit for each hazardous constituent;

 Prepare the detailed plans and engineering report describing corrective action;

 Prepare a description of how the ground-water monitoring program will 

demonstrate the adequacy of the corrective action;

 If applicable, prepare a schedule for submittal of the information required in 

§§270.14(c)(8)(iii) and (iv) in the permit;

 If applicable, prepare a demonstration that alternate concentration limits will 

protect human health and the environment;

 Submit the required information; and

 File copies of the submitted information at the facility.

Solid Waste Management Units

(i) Data items:

Section 270.14(d) establishes Part B information requirements for solid waste 

management units. Data items associated with these requirements are listed below:

 Information on each solid waste management unit, including the following:

-- The location of the unit on the topographic map required under 

§270.14(b)(19);
46

-- Designation of the type of unit;

-- General dimensions and structural description;

-- When the unit was operated; and

-- Specification of all wastes that have been managed at the unit, to the 

extent available;

 All available information pertaining to any release of hazardous wastes or 

hazardous constituents from such unit or units (§270.14(d)(2)); and

 Results of sampling and analysis, where the Director ascertains that a RCRA 

Facility Assessment is necessary.

(ii) Respondent activities:

In order to provide the data items listed above, respondents must perform the following 

activities:

 Read the regulations;

 Compile the information required for each solid waste management unit under 

§270.14(d)(1);

 Compile information pertaining to any releases from the unit(s);

 Prepare and submit results of sampling and analysis;

 Submit the required information; and

 File copies of the submitted information at the facility.

Specific Part B Information Requirements

(1) Containers

(i) Data items:

40 CFR 270.15 requires owner/operators of facilities that store containers of hazardous 

waste to provide the following additional information:
47

 A description of the containment system to demonstrate compliance with 

§264.175 (§270.15(a)). This description must, at a minimum, include the 

following information:

-- Basic design parameters, dimensions, and materials of construction;

-- How the design promotes drainage or how containers are kept from 

contact with standing liquids in the containment system;

-- Capacity of the containment system relative to the number and volume of 

containers to be stored;

-- Provisions for preventing or managing run-on; and

-- How accumulated liquids can be analyzed and removed to prevent 

overflow;

 For storage areas that store containers holding wastes that do not contain free 

liquids, a demonstration of compliance with §264.175(c) (§270.15(b)). The 

demonstration must include:

-- Test procedures and results or other documentation or information to show 

that the wastes do not contain free liquids; and

-- A description of how the storage area is designed or operated to drain and 

remove liquids or how containers are kept from contact with standing 

liquids;

 Sketches, drawings, or data demonstrating compliance with §264.176 (location of 

buffer zone and containers holding ignitable or reactive wastes) and §264.177(c) 

(location of incompatible wastes), where applicable (§270.15(c)); and

 Where incompatible wastes are stored or otherwise managed in containers, a 

description of the procedures used to ensure compliance with §§264.177 (a) and 

(b), and 264.17 (b) and (c) (§270.15(d)).

(ii) Respondent activities:

To comply with the requirements of §270.15, owner/operators must perform the 

following activities:

 Read the regulations;
48

 Prepare a written description of the containment system;

 Prepare the no free liquids demonstration;

 Document compliance with §264.176 and §264.177;

 Provide a written description of procedures used to ensure compliance with 

§§264.177 (a) and (b), and 264.17 (b) and (c);

 Submit the required information; and

 File copies of the submitted information at the facility.

(2) Tank Systems

(i) Data items:

40 CFR 270.16 requires owner/operators of facilities that use tanks to store or treat 

hazardous waste to provide the following additional information:

 An assessment of existing tank system’s integrity (§270.16(a)). Section 264.191 

requires that an owner/operator of an existing tank system that does not have 

secondary containment meeting the requirements of §264.193 must provide a 

written assessment of their tank system’s integrity. The assessment must include 

the information required under §264.191(b) (1)-(5) and must be certified by an 

independent, qualified engineer in accordance with §270.11(d); or

 An assessment of new tank system’s integrity (§270.16(a)). Section 264.192 

requires owner/operators of a new tank system or component to provide EPA with 

a written assessment, in accordance with §270.11(d), attesting that the tank system 

has sufficient structural integrity and is acceptable for the storing and treating of 

hazardous waste. The assessment should include the information required under 

§264.192(a) (1)-(5) and must be certified by an independent, qualified registered 

professional engineer;

 Dimensions and capacity of each tank (§270.16(b));

 Description of feed systems, safety cutoff, bypass systems, and pressure controls 

(e.g., vents) (§270.16(c));

 A diagram of piping, instrumentation, and process flow for each tank system 
49

(§270.16(d));

 A description of materials and equipment used to provide external corrosion 

protection, as required under §264.192(a)(3)(ii) (§270.16(e));

 For new tank systems, a detailed description of how the tank system(s) will be 

installed in compliance with §264.192(b), (c), (d), and (e) (§270.16(f));

 Detailed plans and description of how the secondary containment system for each 

tank system is or will be designed, constructed, and operated to meet the 

requirements of §264.193(a), (b), (c), (d), (e), and (f) (§270.16(g));

 A description of controls and practices to prevent spills and overflows, as required 

under §264.194(b) (§270.16(i)); and

 For tank systems in which ignitable, reactive, or incompatible wastes are to be 

stored or treated, a description of how operating procedures and tank system and 

facility design will achieve compliance with the requirements of §§264.198 and 

264.199 (§270.16(j)).

(ii) Respondent activities:

To comply with the requirements of §270.16, owner/operators must perform the 

following activities:

 Read the regulations;

 Conduct an assessment of the new or existing tank system;

 Write the assessment;

 Compile the information required under §270.16 (b)-(e);

 Provide a description of tank system installation;

 Prepare a description of how the secondary containment system for each tank 

system is or will be designed, constructed, and operated to meet the requirements 

of §264.193(a), (b), (c), (d), (e), and (f);

 Prepare a description of controls and practices to prevent spills and overflows;
50

 Prepare a description of how operating procedures and tank system and facility

design will achieve compliance with the requirements of §§264.198 and 264.199;

 Submit the required information; and

 File copies of the submitted information at the facility.

(3) Surface Impoundments

(i) Data items:

40 CFR 270.17 requires owner/operators of facilities that store, treat or dispose of 

hazardous waste in surface impoundments to provide the following additional information:

 A list of the hazardous wastes places or to be placed in each surface impoundment 

(§270.17(a));

 Detailed plans and an engineering report describing how the surface impoundment 

is or will be designed, constructed, operated and maintained to meet the 

requirements of §264.221 (§270.17(b)). This submission must address the 

following items as specified in §264.221:

-- The liner system;

-- The double liner and leak (leachate) detection, collection, and removal 

system, if required;

-- For a leak detection system located in a saturated zone, the system’s 

design, operation, and location in relation to the saturated zone;

-- The construction quality assurance plan (§264.19);

-- Proposed action leakage rate;

-- Response action plan;

-- Prevention of overtopping; and

-- Structural integrity of dikes;

 A description of how each surface impoundment, including the liner and cover 
51

systems and appurtenances for control of overtopping, will be inspected in order 

to meet the requirements of §264.226(a) and (b) (§270.17(c)). This information 

should be included in the inspection plan submitted under §270.14(b)(5);

 A certification by a qualified engineer which attests to the structural integrity of 

each dike, as required under §264.226(c) (§270.17(d)). For new units, the 

owner/operator must submit a statement by a qualified engineer that he or she will 

provide such a certification upon completion of construction in accordance with 

the plans and specifications;

 A description of the procedure to be used for removing a surface impoundment 

from service, as required under §264.227(b) and (c) (§270.17(e)). This 

information should be included in the contingency plan submitted under 

§270.14(b)(7);

 A description of how hazardous waste residues and contaminated materials will 

be removed from the unit at closure, as required under §264.228(a)(1). For any

wastes not to be removed from the unit upon closure, the owner/operator must 

submit detailed plans and an engineering report describing how §264.228(a)(2) 

and (b) will be complied with (§270.17(f)). This information should be included 

in the closure plan and, where applicable, the post-closure plan submitted under 

§270.14(b)(13);

 If ignitable or reactive wastes are to be placed in a surface impoundment, an 

explanation of how §264.229 will be complied with (§270.17(g));

 If incompatible wastes, or incompatible wastes and materials, will be placed in a 

surface impoundment, an explanation of how §264.230 will be complied with 

(§270.17(h)); and

 A waste management plan for EPA Hazardous Waste Nos. F020, F021, F022, 

F023, F026, and F027 describing how the surface impoundment is or will be 

designed, constructed, operated, and maintained to meet the requirements of 

§264.231. This submission must address the following items as specified in 

§264.231:

-- The volume, physical, and chemical characteristics of the wastes, 

including their potential to migrate through soil or to volatilize or escape 

into the atmosphere;

-- The attenuative properties of underlying and surrounding soils or other 

materials;
52

-- The mobilizing properties of other materials co-disposed with these 

wastes; and

-- The effectiveness of additional treatment, design, or monitoring 

techniques.

(ii) Respondent activities:

To comply with the requirements of §270.17, owner/operator must perform the following 

activities:

 Read the regulations;

 Develop plans and an engineering report describing how the surface impoundment 

will be designed, constructed, operated and maintained;

 Prepare a description of inspection procedures and incorporate the description into 

the inspection plan;

 Obtain a certification or statement from a qualified engineer;

 Prepare a description of procedures for removing the surface impoundment from 

service, and incorporate the description into the contingency plan;

 Prepare a description of how hazardous waste residues and contaminated 

materials will be removed from the unit at closure, and incorporate the description 

into the closure and post-closure plans;

 Provide plans and an engineering report describing how §§264.228(a)(2) and (b) 

will be complied with, and incorporate the description into the closure and 

post-closure plans;

 Prepare an explanation of how §264.229 will be complied with for ignitable or 

reactive wastes;

 Prepare an explanation of how §264.230 will be complied with for incompatible 

wastes;

 Prepare a waste management plan for F-wastes;
53

 Submit the required information; and

 File a copy of the required information at the facility.

(4) Waste Piles

(i) Data items:

40 CFR 270.18 requires owner/operators of facilities that store or treat hazardous waste in 

waste piles to provide the following additional information:

 A list of hazardous wastes placed or to be placed in each waste pile (§270.18(a));

 If an exemption from §264.251 (liner and leachate collection requirements) or 

Subpart F of Part 264 (ground-water monitoring) is sought as provided by 

§264.250(c) or §264.90(b)(2), respectively, an explanation of how the standards 

of §264.250(c) will be complied with or detailed plans and an engineering report 

describing how the requirements of §264.90(b)(2) will be complied with 

(§270.18(b));

 Detailed plans and an engineering report describing how the pile is or will be 

designed, constructed, operated and maintained to meet the requirements of 

§264.251 (§270.18(c)). This submission must address the following items:

-- The liner system;

-- The double liner and leak (leachate) detection, collection, and removal 

system, if required;

-- For a leak detection system located in a saturated zone, the system’s 

design, operation, and location in relation to the saturated zone;

-- The construction quality assurance plan;

-- Proposed action leakage rate;

-- Response action plan;

-- Control of run-on and run-off;

-- Management of collection and holding units associated with run-on and 
54

run-off control systems; and

-- Control of wind dispersal of particulate matter, where applicable;

 A description of how each waste pile, including the liner and appurtenances for 

control of run-on and run-off, will be inspected in order to meet the requirements 

of §264.254(a) and (b) (§270.18(d)). This information should be included in the 

inspection plan submitted under §270.14(b)(5);

 If treatment is carried out on or in the pile, details of the process and equipment 

used, and the nature and quality of the residuals (§270.18(e));

 If ignitable or reactive wastes are to be placed in a waste pile, an explanation of 

how the requirements of §264.256 will be complied with (§270.18(f));

 If incompatible wastes, or incompatible wastes and materials, will be placed in a 

waste pile, an explanation of how §264.257 will be complied with (§270.18(g));

 A description of how hazardous waste residues and contaminated materials will 

be removed from the waste pile at closure, as required under §264.258(a). For 

any waste not to be removed from the waste pile upon closure, the owner/operator 

must submit detailed plans and an engineering report describing how §264.310(a) 

and (b) will be complied with (§270.18(h)). This information should be included 

in the closure plan and, where applicable, the post-closure plan submitted under 

§270.14(b)(13); and

 A waste management plan for EPA Hazardous Waste Nos. F020, F021, F022, 

F023, F026, and F027 describing how a waste pile that is not enclosed (as defined 

in §264.250(c)) is or will be designed, constructed, operated, and maintained to 

meet the requirements of §264.259 (§270.18(i)). This submission must address 

the following items as specified in §264.259:

-- The volume, physical, and chemical characteristics of the wastes to be 

disposed in the waste pile, including their potential to migrate through soil 

or to volatilize or escape into the atmosphere;

-- The attenuative properties of underlying and surrounding soils or other 

materials;

-- The mobilizing properties of other materials co-disposed with these 

wastes; and
55

-- The effectiveness of additional treatment, design, or monitoring 

techniques.

(ii) Respondent activities:

To comply with the requirements of §270.18, owner/operator must perform the following 

activities:

 Read the regulations;

 Prepare a list of hazardous wastes placed or to be placed in each waste pile;

 If an exemption from §264.251 is sought, prepare an explanation of how 

§264.250(c) will be complied with;

 If an exemption under §264.90(b) is sought, prepare an engineering report 

describing how §264.90(b)(2) will be complied with;

 Develop plans and an engineering report describing how the waste pile is or will 

be designed, constructed, operated and maintained;

 Prepare a description of inspection procedures and incorporate the description into 

the inspection plan;

 If applicable, describe the process and equipment used to treat the pile, and 

identify the nature and quality of residuals;

 Prepare an explanation of how §264.256 will be complied with for ignitable or 

reactive wastes;

 Prepare an explanation of how §264.257 will be complied with for incompatible 

wastes;

 Prepare a description of hazardous waste residues and contaminated materials that 

will be removed from the pile at closure, and incorporate the description into the 

closure and post-closure plans;

 Provide plans and an engineering report describing how §§264.310(a) and (b) will 

be complied with, and incorporate the description into the closure and 

post-closure plans;
56

 Prepare a waste management plan for F-wastes;

 Submit the required information; and

 File a copy of the required information at the facility.

(5) Incinerators

(i) Data items:

40 CFR 270.19, 270.62(b)(2), and 270.62(b)(6)-(8) require owner/operators of facilities 

that incinerate hazardous waste to provide the following additional information:

 When seeking an exemption under §264.340 (b) or (c) for ignitable, corrosive, or 

reactive wastes:

-- Documentation that the waste is listed as a hazardous waste in 40 CFR 

Part 261, Subpart D solely because it is ignitable or corrosive, or both 

(§270.19(a)(1)); or

-- Documentation that the waste is listed as a hazardous waste in 40 CFR 

Part 261, Subpart D solely because it is reactive for characteristics other 

than those listed in §261.23(a) (4) and (5), and will not be burned when 

other hazardous wastes are present in the combustion zone 

(§270.19(a)(2)); or

-- Documentation that the waste is a hazardous waste solely because it 

possesses the characteristic of ignitability, corrosivity, or both, as 

determined by the tests for characteristics of hazardous waste under 40 

CFR Part 261, Subpart C (§270.19(a)(3)); or

-- Documentation that the waste is a hazardous waste solely because it 

possesses the reactivity characteristics listed in §261.23(a) (1), (2), (3), (6), 

(7), or (8), and that it will not be burned when other hazardous wastes are 

present in the combustion zone (§270.19(a)(4)); or

 A trial burn plan or the results of a trial burn, in accordance with §270.62 

(§270.19(b)). The information required includes:

-- A proposed trial burn plan. The plan must include the information listed 

under §270.62(b)(2) (i)-(viii) (§270.19(b)); or
57

-- The results of a trial burn, including certified documentation of the results 

of the trial burn (§270.62(b)(6)) and certification that the trial burn has 

been carried out in accordance with the approved trial burn plan 

(§270.62(b)(7)); and

-- All data collected during any trial burn (§270.62(b)(8)); or

 In lieu of a trial burn, the following information as required under §270.19(c):

-- An analysis of each waste or mixture of wastes to be burned, including:

o Heat value of the waste in the form and composition in which it will be 

burned;

o Viscosity (if applicable), or description of physical form of the waste;

o An identification of any hazardous organic constituents listed in 40 CFR 

Part 261, Appendix VIII, which are present in the waste to be burned, 

except that the applicant need not analyze for constituents listed in 40 CFR 

Part 261, Appendix VIII which would reasonably not be expected to be 

found in the waste. The constituents excluded from the analysis must be 

identified and the basis for their exclusion stated;

o An approximate quantification of the hazardous constituents identified in 

the waste, within the precision produced by the analytical methods 

specified in "Test Methods for the Evaluation of Solid Waste, 

Physical/Chemical Methods"; and

o A quantification of those hazardous constituents in the waste which may

be designated as Principal Organic Hazardous Constituents (POHCs) 

based on data submitted from other trial or operational burns which 

demonstrate compliance with the performance standards in §264.343.

-- A detailed engineering description of the incinerator, including:

o Manufacturer’s name and model number of incinerator, and type of 

incinerator;

o Linear dimension of incinerator unit including cross sectional area of 

combustion chamber;

o Description of auxiliary fuel system;

o Capacity of prime mover;

o Description of automatic waste feed cutoff system(s);

o Stack gas monitoring and pollution control monitoring system;

o Nozzle and burner design;

o Construction materials; and

o Location and description of temperature, pressure, and flow indicating 

devices and control devices.
58

-- A description and analysis of the waste to be burned compared with the 

waste for which data from operational or trial burns are provided to 

support the contention that a trial burn is not needed. The data should 

include those items listed in §270.19(c)(1). This analysis should specify

the POHCs which the applicant has identified in the waste for which a 

permit is sought, and any differences from the POHCs in the waste for 

which burn data are provided;

-- The design and operating conditions of the incinerator unit to be used, 

compared with that for which comparative burn data are available;

-- A description of the results submitted from any previously conducted trial 

burn(s) including:

o Sampling and analysis techniques used to calculate performance 

standards in §264.343; and

o Methods and results of monitoring temperatures, waste feed rates, 

carbon monoxide, and an appropriate indicator of combustion gas 

velocity (including a statement concerning the precision and accuracy

of this measurement);

-- The expected incinerator operation information to demonstrate compliance 

with §§264.343 and 264.345, including:

o Expected carbon monoxide level in the stack exhaust gas;

o Waste feed rate;

o Combustion zone temperature;

o Indication of combustion gas velocity;

o Expected stack gas volume, flow rate, and temperature;

o Computed residence time for waste in the combustion zone;

o Expected hydrochloric acid removal efficiency;

o Expected fugitive emissions and their control procedures; and

o Proposed waste feed cut-off limits based on the identified significant 

operating parameters;

-- Waste analysis data, including that submitted in §270.19(c)(1), sufficient 

to allow EPA to specify as permit POHCs those constituents for which 

destruction and removal efficiencies will be required.

(ii) Respondent activities:
59

To comply with the requirements of §270.19, owner/operator must perform the following 

activities:

 Read the regulations;

 Prepare documentation for ignitable, corrosive, or reactive wastes as required 

under §270.19(a) (1)-(4); or

 Prepare a trial burn plan; or

 Prepare a report on the results of a trial burn; or

 Prepare an analysis of each waste or mixture of wastes to be burned;

 Prepare a detailed engineering description of the incinerator;

 Prepare a description and analysis of the waste to be burned and compare the data 

with data collected from operational or trial burns are provided to support the 

contention that a trial burn is not needed;

 Document the design and operating conditions of the incinerator unit to be used 

compared with that for which comparative burn data are available;

 Prepare a description of the results submitted from any previously conducted trial 

burn(s);

 Compile the expected incinerator operation information to demonstrate 

compliance with §§264.343 and 264.345;

 Provide waste analysis data sufficient to allow EPA to identify permit POHCs;

 Submit the required information; and

 File a copy of the required information at the facility.

(6) Land Treatment

(i) Data items:

40 CFR 270.20 requires owner/operators of facilities that use land treatment to dispose of 

hazardous waste to provide the following additional information:
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 A description of plans to conduct a treatment demonstration as required under 

§264.272 (§270.20(a)). The description must include the following information:

-- The wastes for which the demonstration will be made and the potential 

hazardous constituents in the waste;

-- The data sources to be used to make the demonstration; and

-- Any specific laboratory or field test that will be conducted, including the 

information required under §270.20(a)(3) (i)-(iv).

 A description of the land treatment program, as required under §264.271 

(§270.20(b)). This information must be submitted with the plans for the treatment 

demonstration, and updated following the treatment demonstration. The land 

treatment program must address the following items:

-- The wastes to be land treated;

-- Design measures and operating practices necessary to maximize treatment 

in accordance with §264.273(a), including the information required under 

§270.20(b)(2) (i)-(iv);

-- Provisions for unsaturated zone monitoring, including the information 

required under §270.20(b)(3) (i)-(vii);

-- A list of hazardous constituents reasonably expected to be in, or derived 

from, the wastes to be land treated based on waste analysis performed 

pursuant to §264.13; and

-- The proposed dimensions of the treatment zone;

 A description of how the unit is or will be designed, constructed, operated, and 

maintained in order to meet the requirements of §264.273 (§270.20(c)). This 

submission must address the following items:

-- Control of run-on;

-- Collection and control of run-off;

-- Minimization of run-off of hazardous constituents from the treatment 
61

zone;

-- Management of collection and holding facilities associated with run-on 

and run-off control systems;

-- Periodic inspection of the unit. This information should be included in the 

inspection plan submitted under §270.14(b)(5); and

-- Control of wind dispersal of particulate matter, if applicable;

 If food-chain crops are to be grown in or on the treatment zone of the land 

treatment unit, a description of how the demonstration required under §264.276(a) 

will be conducted (§270.20(d)). This submission should include the following 

information:

-- Characteristics of the food-chain crop for which the demonstration will be 

made;

-- Characteristics of the waste, treatment zone, and waste application method 

and rate to be used in the demonstration;

-- Procedures for crop growth, sample collection, sample analysis, and data 

evaluation; and

-- Characteristics of the comparison crop including the location and 

conditions under which it was or will be grown;

 If food-chain crops are to be grown, and cadmium is present in the land-treated waste, 

a description of how the requirements of §264.276(b) will be complied with 

(§270.20(e));

 A description of the vegetative cover to be applied to closed portions of the facility, 

and a plan for maintaining such cover during the post-closure care period, as required 

under §264.280(a)(8) and §264.280(c)(2) (§270.20(f)). This information should be 

included in the closure plan and, where applicable, the post-closure care plan 

submitted under §270.14(b)(13);

 If ignitable or reactive wastes will be placed in or on the treatment zone, an 

explanation of how the requirements of §264.281 will be complied with (§270.20(g));

 If incompatible wastes, or incompatible wastes and materials, will be placed in or on 

the same treatment zone, an explanation of how §264.282 will be complied with 

(§270.20(h)); and
62

 A waste management plan for EPA Hazardous Waste Nos. F020, F021, F022, F023, 

F026, and F027 describing how a land treatment facility is or will be designed, 

constructed, operated, and maintained to meet the requirements of §264.283 

(§270.20(i)). This submission must address the following items as specified in 

§264.283:

-- The volume, physical, and chemical characteristics of the wastes, 

including their potential to migrate through soil or to volatilize or escape 

into the atmosphere;

-- The attenuative properties of underlying and surrounding solids or other 

materials;

-- The mobilizing properties of other materials co-disposed with these 

wastes; and

-- The effectiveness of additional treatment, design, or monitoring 

techniques.

(ii) Respondent activities:

To comply with the requirements of §270.20, owner/operator must perform the following 

activities:

 Read the regulations;

 Prepare a description of plans to conduct a treatment demonstration;

 Prepare a description of a land treatment program;

 Prepare a description of how the unit is or will be designed, constructed, operated, 

and maintained;

 If applicable, prepare a description of how the demonstration under §264.276(a) will 

be conducted;

 If applicable, prepare a description of how the requirements of §264.276(b) will be 

complied with;

 Prepare a description of the vegetative cover to be applied to closed portions of the 
63

facility and incorporate this information into the post-closure care plan;

 Develop a plan for maintaining the vegetative cover during post-closure care period 

and incorporate this plan into the post-closure plan;

 Prepare an explanation of how §264.281 will be complied with for ignitable and 

reactive wastes;

 Prepare an explanation of how §264.282 will be complied with for incompatible 

wastes;

 Prepare a waste management plan for F-wastes;

 Submit the required information; and

 File a copy of the required information at the facility.

(7) Landfills

(i) Data items:

40 CFR 270.21 requires owner/operators of facilities that dispose of hazardous waste in 

landfills to provide the following additional information:

 A list of the hazardous wastes placed or to be placed in each landfill or landfill cell 

(§270.21(a));

 Detailed plans and an engineering report describing how the landfill is or will be 

designed, constructed, operated and maintained to comply with the requirements of 

§264.301 (§270.21(b)). This submission must address the following items as 

specified in §264.301:

-- The liner system and leachate collection and removal system (except for 

an existing portion of a landfill);

-- The double liner and leak (leachate) detection, collection, and removal 

system, if required;

-- For a leak detection system located in a saturated zone, the system’s 

design, operation, and location in relation to the saturated zone;
64

-- The construction quality assurance plan;

-- Proposed action leakage rate;

-- Response action plan;

-- Control of run-on and run-off;

-- Management of collection and holding facilities associated with run-on 

and run-off control systems; and

-- Control of wind dispersal of particulate matter, where applicable;

 If an exemption from Subpart F of Part 264 is sought, as provided by §264.302(a), the 

owner/operator must submit detailed plans and an engineering report explaining the

location of the saturated zone in relation to the landfill, the design of a double-liner 

system that incorporates a leak detection system between the liners, and a leachate 

collection and removal system above the liners (§270.21(c));

 A description of how each landfill, including the liner and cover systems, will be 

inspected in order to meet the requirements of §264.303 (a) and (b) (§270.21(d)). 

This information should be included in the inspection plan submitted under 

§270.14(b)(5);

 Detailed plans and an engineering report describing the final cover which will be 

applied to each landfill or landfill cell at closure in accordance with §264.310(a), and 

a description of how each landfill will be maintained and monitored after closure in 

accordance with §264.310(b) (§270.21(e)). This information should be included in 

the closure and post-closure plans submitted under §270.14(b)(13);

 If ignitable or reactive wastes will be landfilled, an explanation of how the standards 

of §264.312 will be complied with (§270.21(f));

 If incompatible wastes, or incompatible wastes and materials will be landfilled, an 

explanation of how §264.313 will be complied with (§270.21(g));

 If containers of hazardous waste are to be landfilled, an explanation of how the 

requirements of §264.315 or §264.316, as applicable, will be complied with 

(§270.21(i)); and

 A waste management plan for EPA Hazardous Waste Nos. F020, F021, F022, F023, 
65

F026, and F027 describing how a landfill is or will be designed, constructed, 

operated, and maintained to meet the requirements of §264.317 (§270.21(j)). This 

submission must address the following items as specified in §264.317:

-- The volume, physical, and chemical characteristics of the wastes, 

including their potential to migrate through soil or to volatilize or escape 

into the atmosphere;

-- The attenuative properties of underlying and surrounding solids or other 

materials;

-- The mobilizing properties of other materials co-disposed with these 

wastes; and

-- The effectiveness of additional treatment, design, or monitoring 

techniques.

(ii) Respondent activities:

To comply with the requirements of §270.21, owner/operator must perform the following 

activities:

 Read the regulations;

 Prepare a list of hazardous wastes places or to be placed in each landfill or landfill 

cell;

 Prepare plans and an engineering report describing how the landfill is or will be 

designed, constructed, operated and maintained;

 If applicable, prepare the plans and an engineering report required under §270.21(c);

 Prepare a description of how the landfill will be inspected, and incorporate this 

description into the inspection plan;

 Prepare plans and an engineering report describing the final cover which will be 

applied to each landfill or landfill cell at closure, and incorporate this description into 

the closure and post-closure plans;

 Prepare a description of how each landfill will be maintained and monitored after 

closure, and incorporate this description into the closure and post-closure plans;
66

 Prepare an explanation of how the standards of §264.312 will be complied with for 

ignitable or reactive wastes;

 Prepare an explanation of how §264.313 will be complied with for incompatible 

wastes;

 Prepare an explanation of how §264.315 or §264.316 will be complied with for 

landfilled containers of hazardous waste;

 Prepare a waste management plan for F-wastes;

 Submit the required information; and

 File a copy of the required information at the facility.

(8) Miscellaneous Units

40 CFR 270.23 requires owner/operators of facilities that treat, store, or dispose of 

hazardous waste in miscellaneous units to provide the following additional information:

 A detailed description of the unit being used or proposed for use, including the 

following:

-- Physical characteristics, materials of construction, and dimensions of the 

unit;

-- Detailed plans and engineering reports describing how the unit will be 

located, designed, constructed, operated, maintained, monitored, 

inspected, and closed to comply with the requirements of §§264.601 and 

264.602; and

-- For disposal units, a detailed description of the plans to comply with the 

post-closure requirements of §264.603;

 Detailed hydrologic, geologic, and meteorologic assessments and land-use maps for 

the region surrounding the site that address and ensure compliance of the unit with 

each factor in the environmental performance standards of §264.601 (§270.23(b));

 Information on the potential pathways of exposure of humans or environmental 

receptors to hazardous waste or hazardous constituents and on the potential 

magnitude and nature of such exposures (§270.23(c)); and
67

 For any treatment unit, a report on a demonstration of the effectiveness of the 

treatment based on laboratory or field data (§270.23(d)).

(ii) Respondent activities:

To comply with the requirements of §270.23, owner/operator must perform the following 

activities:

 Read the regulations;

 Prepare a detailed description of the unit being used or proposed for use;

 Prepare hydrologic, geologic, and meteorologic assessments and land-use maps;

 Compile information on the potential exposure pathways of humans or environmental 

receptors to hazardous waste or hazardous constituents and on the potential 

magnitude and nature of exposure;

 Prepare a report on a demonstration of the effectiveness of treatment;

 Submit the required information; and

 File a copy of the required information at the facility.

(9) Process Vents and Equipment Leaks

(i) Data items:

Sections 270.24 and 270.25 require owner/operators of facilities that have process vents 

subject to Subpart AA of Part 264 and/or equipment subject to Subpart BB of Part 264 to provide 

EPA with additional information in their Part B application. Owner/operators of facilities with 

process vents subject to Subpart AA must provide the following information:

 For facilities that cannot install a closed-vent system and control device to comply

with Part 264 Subpart AA on the effective date that the facility becomes subject to the 

provisions of Parts 264 or 265 Subpart AA, an implementation schedule as specified 

in §264.1033(a)(2) (270.24(a));

 Documentation of compliance with the process vents standards in §264.1032. 

Documentation of compliance should include the information listed in 

§270.24(b)(1)-(3);
68

 Where an owner/operator applies for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, 

condensator, or carbon adsorption system to comply with §264.1032, and chooses to 

use test data to determine the organic removal efficiency or the total organic 

compound concentration achieved by the control device, a performance test plan as 

specified in §264.1035(b)(3) (§270.24(c)); and

 Documentation of compliance with §264.1033, that includes the information 

contained in §270.24(d)(1)-(5).

Owner/operators of facilities with equipment subject to Subpart BB must provide the 

following information:

 For each piece of equipment to which Subpart BB of Part 264 applies, provide the 

following information (§270.25(a)(1)-(6)):

-- Equipment identification number and hazardous waste management unit 

identification;

-- Approximate equipment locations within the facility;

-- Type of equipment;

-- Percent by weight total organics in the hazardous waste stream at the 

equipment;

-- Hazardous waste state at the equipment; and

-- Method of compliance with the standard;

 For facilities that cannot install a closed-vent system and control device to comply

with the provisions of Part 264 Subpart BB on the effective date that the facility

becomes subject to the provisions of Parts 264 or 265 Subpart BB, an implementation 

schedule as specified in §264.1033(a)(2) (§270.25(b));

 Where an owner/operator applies for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, 

condenser, or carbon adsorption system and chooses to use test data to determine the 

organic removal efficiency or the total organic compound concentration achieved by

the control device, a performance test plan as specified in §264.1035(b)(3) 

(§270.25(c));
69

 Documentation to demonstrate compliance with §264.1052 through §264.1059, 

which includes records required under §264.1064; and

 Documentation to demonstrate compliance with §264.1060, which includes the 

information contained in §270.25(e)(1)-(5).

(ii) Respondent activities:

To comply with the requirements of §§270.24 and 270.25, owner/operators must perform 

the following activities:

 Read the regulations;

 Write and submit an implementation schedule;

 Prepare and submit documentation of compliance with process vent standards in 

§§264.1032 and 264.1033;

 Write and submit a performance test plan;

 Compile and submit equipment information;

 Prepare and submit documentation of compliance with §§264.1052 through 

§264.1059; and

 Prepare and submit documentation of compliance with §264.1060.

(10) Drip Pads

(i) Data items:

40 CFR 270.26(a)-(c) requires owner/operators of facilities that use drip pads to collect, 

treat, or store hazardous waste to provide the following additional information:

 A list of hazardous wastes placed or to be placed on each drip pad;

 If an exemption is sought to 40 CFR Part 264, subpart F, as provided by §264.90, 

detailed plans and an engineering report describing how the requirements of 

§264.90(b)(2) will be met. [This requirement has already been burdened in this ICR. 

See "Releases from Regulated Units"];
70

 Detailed plans and an engineering report describing how the drip pad is or will be 

designed, constructed, operated, and maintained to meet the requirements of 

§264.573, including as-built drawings and specifications. This submission must 

address the following items as specified in §264.571:

-- The design characteristics of the drip pad;

-- The liner system;

-- The leakage detection system;

-- Practices designed to maintain drip pads;

-- The associated collection system;

-- Control of run-on and run-off to the drip pad;

-- The interval at which drippage and other materials will be removed from 

the associated collection system and a statement demonstrating that the 

interval will be sufficient to prevent overflow onto the drip pad;

-- Procedures for cleaning the drip pad at least once every seven days to 

ensure the removal of accumulated waste residues and other materials;

-- Operating practices and procedures that will be followed to ensure that 

tracking of hazardous waste or waste constituents off the drip pad due to 

activities by personnel or equipment is minimized;

-- Procedures for ensuring that, after removal from the treatment vessel, 

treated wood is held on the drip pad until drippage has ceased, including 

recordkeeping practices;

-- Provisions for ensuring that collection and holding units associated with 

the run-on and run-off control systems are emptied or otherwise managed 

as soon as possible after storms to maintain design capacity of the system;

-- Details of any treatment process used, and the nature and quality of the 

residuals;

-- A description of how each drip pad will be inspected;
71

-- A certification, signed by an independent, qualified registered professional 

engineer, stating that the drip pad design meets the requirements of 

§264.573(a)-(f); and

-- A description of how hazardous waste residues and contaminated 

materials will be removed from the drip pad at closure.

(ii) Respondent activities:

To comply with the requirements of §270.26, the owner or operator must perform the 

following activities:

 Read the regulations;

 Prepare and submit a list of hazardous wastes; and

 Develop and submit plans and an engineering report that include the items listed 

above.

Schedules of Compliance

(i) Data items:

40 CFR 270.33 requires owner/operators to specify in the permit a schedule of 

compliance leading to compliance with the Act and regulations, where appropriate. Data items 

required under this section include the following:

 A schedule of compliance (§270.33(a)). The schedule must include the following 

information:

-- A requirement for compliance as soon as possible;

-- Interim requirements and the dates for their achievement, if the permit 

establishes a schedule of compliance which exceeds 1 year from the date 

of permit issuance;

-- Interim dates for the submission of reports of progress toward completion 

of the interim requirements and a projected completion date, if the time 

necessary for completion of any interim requirement is more than 1 year 

and is not readily divisible into stages for completion; and
72

-- A requirement that no later than 14 days following each interim date and 

the final date of compliance, the permittee shall notify EPA in writing of 

compliance or noncompliance with the interim or final requirements;

 If the permittee decides to cease conducting regulated activities at a given time within 

the term of a permit which has already been issued, an application for a permit 

modification that contains a new or additional schedule leading to timely cessation of 

activities (§270.33(b)(1)). Permit modifications are discussed in the permit 

modification section of this ICR;

 If the decision to cease conducting regulated activities is made before issuance of a 

permit whose term will include the termination date, a schedule leading to 

termination which will ensure timely compliance with applicable requirements 

(§270.33(b)(2));

 If the permittee is undecided whether to cease conducting regulated activities, he or 

she may apply for a permit or submit an application for a permit modification to 

establish two schedules of compliance. The two schedules shall contain information 

as outlined in §270.33(b)(3) (i)-(iv). Permit modifications are discussed in the permit 

modification section of this ICR; and

 If the permittee decides to cease conducting regulated activities, written evidence of a 

firm public commitment to cease conducting regulated activities.

(ii) Respondent activities:

In order to comply with the requirements of §270.33, owner/operators must perform the 

following activities:

 Read the regulations;

 Develop and submit a schedule of compliance;

 Develop and submit an alternative schedule of compliance under §270.33(b)(2));

 Develop and submit an application for two schedules of compliance; and

 Document and submit evidence of firm public commitment to cease conducting 

regulated activities.

Permit Modifications and Special Permits
73

Permit Modifications

(1) Transfer of Permits

(i) Data items:

40 CFR 270.40(b) explains that changes in the ownership or operational control of a 

facility may be made as a Class 1 modification with prior written approval of EPA. The 

requirements associated with applying for a Class 1 modification are discussed in this ICR under 

§270.42(a). In addition to the Class 1 modification requirements, owner/operators must also 

submit the following information in order to transfer ownership or operational control of a 

facility:

 A written agreement containing a specific date for transfer of permit responsibility

between the current and new permittees; and

 A demonstration that the new owner/operator is complying with the requirements of 

Subpart H (financial requirements), within 6 months of the date of the change of 

ownership or operational control of the facility. The requirements associated with 

this demonstration are discussed in this ICR under §§270.14(b) (15) and (16).

(ii) Respondent activities:

In complying with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations; and

 Prepare and submit the written agreement.

(2) Permit Modification at the Request of the Agency

(i) Data items:

EPA has the authority under §270.41 to modify any permit when certain causes for 

modification exist, including substantial alterations to the facility, new information not available 

at the time of permitting, new statutory requirements or regulations, and events over which the 

permittee has little or no control and for which there is no reasonable remedy. Facilities required 

to submit a Agency-initiated permit modification will submit a Class 2 or Class 3 permit 

modification as described under §270.42. 

(ii) Respondent activities:
74

In complying with the requirements for Agency-initiated permit modifications, 

respondents must perform the following activities:

 Read the regulations;

 Prepare and submit the modification request;

 Prepare and submit proof of public notice; and

 File a record of the permit modification request at the facility.

(3) Permit Modification at the Request of the Permittee

(a) Class 1 Modifications

(i) Data items:

In making an application for a Class 1 permit modification under §270.42(a), 

owner/operators must provide the following information:

 A notification to EPA concerning the permit modification within 7 calendar days after 

the change is put into effect (§270.42(a)(i)). The notice should specify the changes 

being made to the permit conditions or supporting documents referenced by the 

permit and must explain why these changes are necessary;

 Applicable information required by §§270.13 through 270.21, 270.62, and 270.63 

(§270.42(a)(i)); and

 A written notification of the modification to all persons on the facility mailing list and 

the appropriate units of State and local governments (§270.42(a)(ii)). This 

notification must be made within 90 calendar days after the change is put into effect. 

For the Class 1 modifications that require prior EPA approval, the notification must 

be made within 90 calendar days after EPA approves the request.

(ii) Respondent activities:

In complying with the requirements for Class 1 permit modifications, owner/operators 

must perform the following activities:

 Read the regulations;

 Prepare and submit the notification required under §270.42(a)(i);
75

 Prepare and submit the applicable information required by §§270.13 through 270.21, 

270.62, and 270.63;

 Prepare and submit written notification to all persons on the mailing list and the 

appropriate units of State and local governments; and

 File a record of the permit modification request and supporting documents at the 

facility.

(b) Class 2 and 3 Modifications

(i) Data items:

In making an application for a Class 2 or 3 permit modification under §270.42(b) or 

§270.42(c), respectively, owner/operators must provide the following information:

 A modification request, submitted to EPA, that:

-- Describes the exact change to be made to the permit conditions and 

supporting documents referenced by the permit;

-- Identifies that the modification is a Class 2 modification;

-- Explains why the modification is needed; and

-- Provides the applicable information required by §§270.13 through 270.21, 

270.62, and 270.63;

 A written notification of the modification request to all persons on the facility mailing 

list and the appropriate units of State and local governments, and publication of the 

notice in a major local newspaper of general circulation. The notice must be mailed 

and published within 7 days before or after the date of submission of the modification 

request, and must contain the information listed in §270.42(b)(2) (i)-(vi) or 

§270.42(c)(2) (i)-(vi). In addition, the permittee must provide to EPA evidence of the 

mailing and publication; and

 A record of the permit modification request and supporting documents, placed in a 

location accessible to the public in the vicinity of the permitted facility.

(ii) Respondent activities:
76

In complying with the requirements for Class 2 or 3 permit modifications, 

owner/operators must perform the following activities:

 Read the regulations;

 Prepare and submit the modification request;

 Prepare and distribute a written notification of the modification request;

 Provide for newspaper publication of the notice;

 Prepare and submit to EPA proof of public notice; and

 File a record of the permit modification request and supporting documents.

(c) Request for Classification of a Permit Modification

(i) Data item:

For modifications that are not explicitly listed in appendix I of section 270.42(d)(1), the 

permittee may submit a Class 3 modification request, or he or she may request that the Director 

review the modification and classify it as a Class 1 or Class 2 modification. For such a request, 

the permittee must provide the Agency with the necessary information to support the requested 

classification.

(ii) Respondent activities:

To request a classification for a permit modification, the permittee must perform the 

following activities:

 Read the regulations; and

 Prepare and submit information to support the requested classification.

(4) Temporary Authorizations

(i) Data items:

In making an application for temporary authorization under 40 CFR 270.42(e), 

owner/operators must supply the following information:

 A temporary authorization request containing the following information listed under 
77

§270.42(e)(2)(ii) (A)-(C):

-- A description of the activities to be conducted under the temporary

authorization;

-- An explanation of why the temporary authorization is necessary; and

-- Sufficient information to ensure compliance with 40 CFR Part 264 

standards; and

 A written notification of the temporary authorization request to all persons on the 

facility mailing list and to the appropriate units of State and local governments 

(§270.42(e)(2)(iii). This notification must be made within 7 days of submission of 

the authorization request.

(ii) Respondent activities:

In complying with the requirements for temporary authorization, owner/operators must 

perform the following activities:

 Read the regulations;

 Prepare and submit a temporary authorization request; and

 Prepare and distribute notification of the temporary authorization request to all 

persons on the facility mailing list and to the appropriate units of State and local 

governments.

(5) Newly Listed or Identified Wastes

(i) Data items:

40 CFR 270.42(g) allows owner/operators of facilities to continue to manage hazardous 

wastes listed or identified under Part 261, or to continue to manage hazardous waste in units 

newly regulated as hazardous waste management units if they meet specific conditions and 

submit the following information:

 A Class 1 permit modification on or before the date of the waste or unit becomes subject

to the new requirement;

 A Class 2 or 3 permit modification request within 180 days of the effective date of the 

rule listing or identifying the waste, or subjecting the unit to RCRA Subtitle C 
78

management standards; and

 In the case of land disposal units, a certification that the unit is in compliance with all 

applicable Part 265 ground-water monitoring and financial assurance requirements 12 

months after the effective date of the rule listing or identifying the waste, or subjecting 

the unit to RCRA Subtitle C management standards.

(ii) Respondent activities:

To comply with these requirements, owner/operators must perform the following 

activities:

 Read the regulations;

 Submit a Class 1 permit modification;

 Submit a Class 2 or 3 permit modification request within 180 days of the effective date of 

the rule; and

 For land disposal units, submit a certification that the unit is in compliance with all 

applicable standards 12 months after the effective date of the rule.

(6) Corrective Action Management Units

(i) Data item:

In 40 CFR Part 264, Subpart S, EPA promulgated regulations for corrective action 

management units (CAMUs). Section 264.552(d) requires owner/operators to prepare and 

submit information to EPA, upon request, that enables EPA to designate a CAMU. Section 

264.552(g) provides for owner/operators of permitted facilities to modify their permit to 

incorporate a CAMU.

(ii) Respondent activities:

In order to comply with section 264.552(d), owner/operators must perform the following 

activities:

 Read the regulations; and

 Prepare and submit information to enable EPA to designate a CAMU.

Expiration and Continuation of Permits
79

(i) Data items:

40 CFR 270.50 explains that all RCRA permits must be renewed no later than 10 years 

after the date of issuance. Under §270.51, owner/operators renewing an expiring permit must 

submit an application containing the information required under §270.14 and the applicable 

sections of §§270.15 through 270.29.

(ii) Respondent activities:

Owner/operators submitting a Part B permit renewal application must perform the same 

activities as owner/operators of new facilities submitting their first permit application, as 

described above.

Special Forms of Permits

(1) Permits By Rule

40 CFR 270.60 states that ocean disposal barges or vessels, injection wells, and publicly

owned treatment works (POTWs) will be deemed to have a RCRA permit if the conditions listed 

under §270.60 (a)-(c) are met. In complying with these sections, owner/operators of POTWs or 

ocean disposal barges or vessels must submit all information required under §§264.11, 264.71, 

264.72, 264.73(a) and (b)(1), 264.75, and 264.76. In addition, owner/operators of POTWs must 

submit the information required under §264.101. Owner/operators of injection wells must also 

submit the information required under §264.101, as well as the information required under 

§270.14(d). The specific information requirements of these sections and the respondent burden 

associated with them are discussed in the Notification ICR (OMB Control No. 2050-0028), the 

Manifests ICR (OMB Control No. 2050-0039), the General Facility Standards ICR (OMB 

Control No. 2050-0120), or in other sections of this ICR.

(2) Hazardous Waste Incinerator Permits

(i) Data items:

40 CFR 270.62 requires owner/operators of hazardous waste incinerators to provide a 

proposed trial burn plan and trial burn results as part of the Part B permit application. Specific 

requirements associated with the proposed trial burn and its results are included in this ICR 

under the requirements for §270.19. In addition to these requirements, applicants for a 

hazardous waste incinerator permit must also submit the following information with their Part B 

application:

 For an extension of the operational period beyond 720 hours, a request demonstrating 

why good cause exists for such an extension (270.62(a));

 A statement suggesting the conditions necessary to operate in compliance with the 
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performance standards of §264.343 during the period following completion of physical 

construction (§270.62(a)(1)). This statement should include, at a minimum, restrictions 

on waste constituents, waste feed rates and the operating parameters identified in 

§264.345;

 A statement identifying the conditions necessary to operate in compliance with the 

performance standards of §264.343 during the period following completion of the trial 

burn period and prior to final modification of the permit conditions to reflect the trial 

burn results (§270.62(c)(1)). The statement should include, at a minimum, restrictions on 

waste constituents, waste feed rates, and the operating parameters in §264.345; and

 A certification, in the form of a signature, on behalf of the applicant must be provided on 

all submissions by a person authorized to sign a permit application or report under 

§270.11 (§270.62(b)(9).

(ii) Respondent activities:

In complying with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the extension request;

 Provide on all submissions the signature of a person authorized to sign a permit 

application or a report; and

 Prepare and submit the required statements.

(3) Permits for Land Treatment Demonstrations Using Field Test or Laboratory 

Analyses

(i) Data items:

40 CFR 270.63 allows owner/operators to obtain a treatment demonstration permit for the 

purpose of meeting the requirements of §264.272. The permit may be issued either as a 

treatment or disposal permit covering only the field test or laboratory analyses, or as a two-phase 

facility permit covering the field tests, or laboratory analyses, and design construction, operation 

and maintenance of the land treatment unit. When owner/operators who have been issued a 

two-phase permit have completed the treatment demonstration, they must submit the following 

information in accordance with §270.63(c):
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 A certification, signed by a person authorized to sign a permit application report 

under §270.11, that the field tests or laboratory analyses have been carried out in 

accordance with the conditions specified in phase one of the permit for conducting 

such tests or analyses; and

 All data collected during the field tests or laboratory analyses. This information must 

be submitted to EPA within 90 days of completion of those tests and analyses unless 

EPA approves a later date.

(ii) Respondent activities:

In complying with the requirements of this section, owner/operators must perform the 

following activities:

 Read the regulations;

 Prepare and submit the certification; and

 Compile and submit the data collected during the field tests or laboratory analyses.

(4) Interim Permits for UIC Wells

40 CFR 270.64 states that EPA may issue a permit to any Class I UIC well injecting 

hazardous wastes within a State in which no UIC program has been approved or promulgated. 

Any such permit shall apply and insure compliance with all applicable requirements of 40 CFR 

Part 264, Subpart R. However, these Subpart R regulations have not yet been promulgated. 

Therefore, there are no activities associated with this section.

(5) Research, Development, and Demonstration Permits

(i) Data items:

40 CFR 270.65 allows EPA to issue a research, development, and demonstration permit 

for any hazardous waste treatment facility which proposes to utilize an innovative and 

experimental hazardous waste treatment technology or process for which permit standards for 

such experimental activity have not been promulgated under Part 264 or 266. Applicants for this 

type of permit must submit the same information required for a Part B permit, as discussed 

above.

(ii) Respondent activities:

Owner/operators applying for a research, development, and demonstration permits must 

perform the same activities as owner/operators applying for a Part B permit, as described above.
82

Interim Status

Termination of Interim Status

(i) Data item:

40 CFR section 270.73(d) states that interim status terminates 12 months after an existing 

land disposal facility comes under permit requirements resulting from statutory or regulatory

amendments, unless the facility submits a Part B application before the 12-month period expires 

and certifies that the facility is in compliance with all applicable ground-water monitoring and 

financial responsibility requirements. The submittal of the Part B application has already been 

burdened in this ICR.

(ii) Respondent activities:

In order to comply with section 270.73(d), owner/operators must perform the following 

activities:

 Read the regulations; and

 Prepare and submit the certification.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Demonstrations and Exemptions from Requirements

Releases from Regulated Units

Agency activities associated with demonstrations for the exemption of facility

owner/operators from Subpart F requirements regarding releases into the uppermost aquifer 

include reviewing and evaluating demonstrations, reviewing certifications (from qualified 

biologists or geotechnical engineers) of no-migration demonstrations under §264.90(b)(4), and 

entering the information into a data base.

Specific Unit Requirements

(1) Tank Systems

Agency activities associated with tank system requirements include reviewing 

notifications of intent to make a demonstration, demonstrations under §264.193(g)(1), 
83

demonstrations for exemption from the 24-hour leak detection requirement and/or the 24-hour 

waste removal requirement, and written descriptions of equivalent secondary containment 

devices; and entering the information into a data base.

(2) Surface Impoundments

Agency activities associated with surface impoundment requirements include reviewing 

demonstrations for exemption from the double liner requirement (§264.221(d)), and 

demonstrations for a waiver of double liner requirements for monofills, and entering the 

information into a data base.

(3) Waste Piles

Agency activities associated with waste pile requirements include reviewing 

demonstrations for exemption from the liner and leachate collection system requirements of 

§264.251(b) and demonstrations for exemption from the double liner and leachate collection 

system requirements of §264.251(d), and entering the information into a data base.

(4) Land Treatment

Agency activities associated with land treatment requirements include reviewing and 

evaluating demonstrations and entering the information into a data base.

(5) Landfills

Agency activities associated with landfill requirements include reviewing and evaluating 

demonstrations and entering the information into a data base.

(6) Incinerators

Agency activities associated with incinerator requirements include reviewing 

demonstrations and entering the information into a data base.

Contents of the Part B Application

General Information

Agency activities associated with petitioning the Regional Administrator for a 

determination that a post-closure permit is not required because the closure (of surface 

impoundments, land treatment units, and waste piles closing by removal or decontamination 

under Part 265 standards) meets applicable Part 264 closure standards include reviewing and 

approving petitions and entering the information into a data base.

Permit Application
84

Agency activities associated with the requirement that Part B permit applications 

submitted by owner/operators of facilities that store, treat, or dispose of hazardous waste in a 

surface impoundment of landfill be accompanied by information on the potential for the public to 

be exposed to hazardous wastes or hazardous constituents through releases related to the unit 

include reviewing the required data and entering the information into a data base.

General Requirements

Agency activities associated with demonstrations by owner/operators to obtain allowance 

from Regional Administrators to submit information prescribed in Part B on a case-by-case basis 

include reviewing and approving demonstration and entering the information into a data base.

General Facility Standards

Agency activities associated with the requirement that owner/operators of hazardous 

waste management facilities submit in their Part B permit applications information on 

compliance with general facility standards include reviewing the required information and 

entering it into a data base.

Financial Assurance

(1) Cost Estimates for Closure and Post-Closure Care

Agency activities associated with cost estimates for closure and post-closure care include 

reviewing written cost estimates and entering the information into a data base. Agency activities 

associated with post-closure cost estimates for interim status facilities are discussed in the 

General Facility Standards (OMB Control No. 2050-0120).

(2) Financial Assurance for Closure and Post-Closure Care

Agency activities associated with the requirements for financial assurance for closure and 

post-closure care include reviewing the documentation of financial assurance submitted by the 

respondent and entering the information into a data base.

(3) Use of a Financial Mechanism for Multiple Facilities

The information required under this section will be submitted with the information 

provided by the owner/operator to establish financial assurance mechanisms. Therefore, this 

ICR assumes that any agency activities related to the requirements of this section are already

covered under the previous sections.

(4) Liability Requirements

(a) Coverage for Sudden or Nonsudden Accidental Occurrences
85

Agency activities associated with the establishment of liability coverage for sudden or 

nonsudden accidental occurrences include reviewing the information submitted and entering 

information into a data base.

(b) Request for Variance

Agency activities associated with allowing owners/operators to obtain a variance from 

EPA include reviewing requests for variance, including any technical or engineering information 

required by EPA.

(c) Adjustments by the Regional Administrator

Agency activities associated with allowing the Agency to adjust the level of financial 

responsibility required under §264.147 to protect human health and the environment include 

reviewing any information requested by the Agency and, if the Agency decides to adjust the 

level or type of coverage, permit modifications. The Agency burden associated with permit 

modifications is discussed below under the section entitled "Permit Modifications."

(5) Coverage by a State Financial Mechanism

Agency activities associated with establishing coverage by State financial mechanisms 

include reviewing letters from owner/operators, written evidence of the establishment of 

State-required financial assurance mechanisms, or letters from the State describing the State’s 

assumption of responsibility and including the information specified above, and any additional 

information requested by EPA.

Other Requirements

(1) Topographical Map

Agency activities associated with the requirement that owner/operators must provide a 

topographical map include reviewing the topographical map.

(2) Case-By-Case Extensions and Petitions to Allow Land Disposal of a Waste 

Prohibited Under Subpart C of Part 268

Agency activities associated with the requirement that owner/operators of land disposal 

facilities that have received approval for a case-by-case extension under §268.5 or a petition 

under §268.6 submit a copy of the notice of approval for the extension or petition with their Part 

B permit application include reviewing the notice of approval.

Ground-Water Protection

(1) General Ground-Water Monitoring Requirements
86

Agency activities associated with general ground-water monitoring requirements include 

reviewing and approving the ground-water monitoring program.

(2) Detection and Monitoring Programs

Agency activities associated with the requirement that owner/operators develop a 

detection monitoring program if the presence of hazardous constituents has not been detected in 

the ground water at the time of permit application include reviewing all information submitted, 

and entering the information into a data base.

(3) Compliance Monitoring Program

Agency activities associated with the requirement that owner/operators develop a 

detection monitoring program if the presence of hazardous constituents has been detected in the 

ground water at the point of compliance at the time of permit application include reviewing all 

information submitted, and entering the information into a data base.

(4) Corrective Action Program

Agency activities associated with the establishment of a corrective action program 

include reviewing all information submitted, and if applicable, reviewing schedules of 

information required in §§270.14(c)(8)(iii) and (iv) in the permit and demonstrations that 

alternate concentration limits will protect human health and the environment. EPA will also 

enter the information into a data base.

Solid Waste Management Units

Agency activities associated with Part B information requirements for solid waste 

management units include reviewing all required information and entering it into a data base.

Specific Part B Information Requirements

(1) Containers

Agency activities associated with information requirements for owner/operators of 

facilities that store containers of hazardous waste include reviewing written descriptions of 

containment systems, no free liquids demonstrations, documentation of compliance with 

§264.176 and §264.177, and written descriptions of procedures used to ensure compliance with 

§264.177(a) and (b), and 264.17(b) and(c); and entering the information into the data base.

(2) Tank Systems

Agency activities associated with information requirements for owner/operators of 

facilities that use tanks to store or treat hazardous waste include reviewing assessments of new or 
87

existing tank systems, information required under §270.16(b)-(e), descriptions of tank system 

installations, descriptions of how the secondary containment system for each tank system is or 

will be designed, constructed, and operated, descriptions of controls and practices to prevent 

spills and overflows, and descriptions of how operating procedures and tank system and facility

design will achieve compliance with the requirements of §§264.198 and 264.199; and entering 

the information into a data base.

(3) Surface Impoundments

Agency activities associated with information requirements for owner/operators of 

facilities that store, treat, or dispose of hazardous waste in surface impoundments include 

reviewing the following information: plans and engineering reports describing how surface 

impoundments will be designed, constructed, operated, and maintained; descriptions of 

inspection procedures that are included in inspection plans; certifications or statements from 

qualified engineers; in contingency plans, descriptions of procedures for removing surface 

impoundments from service; in closure and post-closure plans, descriptions of hazardous waste 

residues and contaminated materials that will be removed from the unit at closure and plans and 

engineering reports describing compliance with §§264.228(a)(2) and (b); explanations of how 

§264.229 will be complied with for ignitable or reactive wastes; explanations of how §264.230 

will be complied with for incompatible wastes; and waste management plans for F-wastes. The 

Agency will also enter the information into a data base.

(4) Waste Piles

Agency activities associated with information requirements for owner/operators of 

facilities that store or treat hazardous waste in waste piles include reviewing the following 

information: explanations of how §264.250(c) will be complied with if an exemption from 

§264.251 is sought; engineering reports describing how §264.90(b)(2) will be complied with if 

an exemption from Subpart F of Part 264 is sought; plans and engineering reports describing 

how the waste pile will be designed, constructed, operated, and maintained; in inspection plans, 

descriptions of inspection procedures; if applicable, descriptions of processes and equipment 

used to treat piles, and descriptions of the nature and quantity of residuals; explanations of how 

§264.256 will be complied with for ignitable or reactive wastes; explanations of how §264.257 

will be complied with for incompatible wastes; in post-closure plans, descriptions of hazardous 

waste residues and contaminated materials to be removed from piles at closure; in closure and 

post-closure plans, plans and engineering reports describing how §§264.310(a) and (b) will be 

complied with; and waste management plans for F-wastes. The Agency will also enter the 

information into a data base.

(5) Incinerators

Agency activities associated with information requirements for owner/operators of 

facilities that incinerate hazardous wastes include reviewing the following information: 

documentation for ignitable, corrosive, or reactive wastes as required under §270.19(a) (1)-(4); 

trial burn plans; reports on results of trial burns; and information submitted in lieu of a trial burn. 
88

The Agency will also enter the information into a data base.

(6) Land Treatment

Agency activities associated with information requirements for owner/operators of 

facilities that use land treatment to dispose of hazardous waste include reviewing the following 

information: descriptions of plans to conduct treatment demonstrations; descriptions of land 

treatment programs; descriptions of how the units are or will be designed, constructed, operated, 

and maintained; if applicable, descriptions of how demonstrations under §264.276(a) will be 

conducted; if applicable, descriptions of how the requirements of §264.276(b) will be complied 

with; in post-closure care plans, descriptions of vegetative cover to be applied to closed portions 

of facilities; in post-closure plans, plans for maintaining vegetative cover during the post-closure 

care period; explanations of how §264.281 will be complied with for ignitable and reactive 

wastes; explanations of how §264.282 will be complied with for incompatible wastes; and waste 

management plans for F-wastes. The Agency will also enter the information into a data base.

(7) Landfills

Agency activities associated with information requirements for owner/operators of 

facilities that dispose of hazardous waste in landfills include reviewing the following 

information: list of hazardous wastes in each landfill or landfill cell; plans and engineering 

reports describing how the landfill is or will be designed, constructed, operated, and maintained; 

if applicable, plans and engineering reports required under §270.21(c); in inspection plans, 

descriptions of how landfills will be inspected; in closure and post-closure plans, plans and 

engineering reports describing the final cover which will be applied to each landfill or landfill 

cell at closure; in closure and post-closure plans, descriptions of how each landfill will be 

maintained and monitored after closure; explanations of how standards of §264.312 will be 

complied with for ignitable or reactive wastes; explanations of how §264.313 will be complied 

with for incompatible wastes; explanations of how §264.315 or §264.316 will be complied with 

for landfilled containers of hazardous waste; and waste management plans for F-wastes. The 

Agency will also enter the information into a data base.

(8) Miscellaneous Units

Agency activities associated with information requirements for owner/operators of 

facilities that treat, store, or dispose of hazardous waste in miscellaneous units include reviewing 

the following information: detailed descriptions of units being used or proposed for use; 

hydrologic, geologic, and meteorologic assessments and land-use maps; information on the 

potential exposure pathways of humans or environmental receptors to hazardous waste or 

hazardous constituents and on the potential magnitude and nature of exposure; and reports on 

demonstrations of the effectiveness of treatment. The Agency will also enter the information 

into a data base.

(9) Process Vents and Equipment Leaks
89

Agency activities associated with the requirements for process vents and equipment leaks 

include reviewing implementation schedules, documentation of compliance with 

§§264.1052-.1059, 264.1060, .1032 and .1033, performance test plans, and equipment 

information. The Agency will also enter the information into a data base.

(10) Drip Pads

Agency activities associated with the requirements for drip pads include reviewing lists of 

hazardous wastes placed or to be placed on each drip pad, reviewing plans and engineering 

reports, and entering the information into a data base.

Schedules of Compliance

Agency activities associated with the requirement that owner/operators specify in permits 

a schedule of compliance leading to compliance with the Act and regulations, where appropriate, 

include reviewing the following information: schedules of compliance, alternative schedules of 

compliance under §270.33(b)(2), applications for two schedules of compliance, and evidence of 

firm public commitment to cease conducting regulated activities. The Agency will also enter the 

information into a data base.

Permit Modifications and Special Permits

Permit Modifications

(1) Transfer of Permits

Agency activities associated with the transfer of permits includes reviewing written 

agreements and entering the information into a data base.

(2) Permit Modification at the Request of the Agency

Agency activities associated with Agency-initiated permit modifications include 

reviewing the modification request and entering the information into a data base.

(3) Permit Modification at the Request of the Permittee

(a) Class 1 Modifications

Agency activities associated with applications for Class 1 permit modifications include 

reviewing notifications required under §270.42(a)(i), and applicable information required by 

§§270.13 through 270.21, 270.62, and 270.63, and entering the information into a data base.

(b) Class 2 and 3 Modifications
90

Agency activities associated with applications for Class 2 or 3 permit modifications 

include reviewing modifications requests and written notifications, and entering the information 

into a data base.

(c) Request for Classification of a Permit Modification

Agency activities associated with requests for classification of a permit modification 

include reviewing the information submitted in support of a request, making a determination on 

the request, and entering the information into a data base.

(4) Temporary Authorizations

Agency activities associated with applications for temporary authorization include 

reviewing temporary authorization requests and entering the information into a data base.

(5) Newly Regulated Wastes and Units

Agency activities associated with the requirement that to be authorized to continue 

managing wastes listed or identified under 40 CFR Part 261 owner/operators of land disposal 

units certify that units are in compliance with all applicable Part 265 ground-water monitoring 

and financial responsibility requirements include reviewing certifications.

(6) Corrective Action Management Units

EPA must review information submitted for the designation of a CAMU.

Expiration and Continuation of Permits

Agency activities associated with renewing existing permits include conducting the same 

activities as they would for initial permit applications.

Special Forms of Permits

(1) Permits By Rule

The specific information requirements and agency activities for this section are discussed 

in the Notification ICR (OMB Control No. 2050-0028), the Manifests ICR (OMB Control No. 

2050-0039), and the General Facility Standards ICR (OMB Control No. 2050-0120).

(2) Hazardous Waste Incinerator Permits

Agency activities associated with the requirement that owner/operators of hazardous 

waste incinerators applying for permits submit information in addition to the trial burn plan 

include reviewing requests to extend the operational period, reviewing the required statements 

and certifications, and entering the information into a data base.
91

(3) Permits for Land Treatment Demonstrations Using Field Test or Laboratory 

Analyses

Agency activities associated with the requirement that owner/operators who have been 

issued a two-phase permit and have completed treatment demonstrations submit information in 

accordance with §270.63(c) include reviewing certifications and data collected during field tests 

or laboratory analyses, and entering the information into a data base.

(4) Interim Permits for UIC Wells

There are no Agency activities associated with this section.

(5) Research, Development, and Demonstration Permits

Agency activities associated with research, development, and demonstration permits for 

hazardous waste treatment facilities proposing to utilize innovative and experimental treatment 

technologies or processes for which permit standards for such experimental activity have not 

been promulgated under Part 264 or 266 conduct the same activities as they would for a Part B 

permit.

Interim Status

Termination of Interim Status

Agency activities associated with interim status facilities include reviewing each 

certification that an interim status facility is in compliance with all applicable ground-water 

monitoring and financial responsibility requirements.

5(b) Collection Methodology and Management

In collecting and analyzing the information required for Part B permit applications, 

permit modifications and special permits, EPA uses state-of-the-art electronic equipment such as 

personal computers and applicable data base software, when appropriate.

5(c) Small Entity Flexibility

Some respondents will be small organizations. In certain cases they will be able to 

complete recordkeeping, reporting, and application requirements in less time than large 

organizations because their permits will not be as detailed, or they will not be required to 

conduct as many monitoring activities or submit as many reports because they have fewer 

activities requiring monitoring and reporting. However, a parallel does not always exist between 

the size of an organization and the amount of time needed to maintain records or submit reports. 

For example, a chemical landfill may be classified as a small business, but the facility employs
92

numerous processes that necessitate a detailed application and supporting records and reporting. 

EPA has taken steps to minimize the burdens for all facilities whether they are small businesses 

or not.

5(d) Collection Schedule

Demonstrations and Exemptions from Requirements

Because the regulations do not provide a specific time frame for submitting exemption 

demonstrations, this ICR assumes that all demonstrations are submitted along with the Part B 

application. However, tank system owner/operators must notify EPA of their intent to submit a 

demonstration for a variance from secondary containment as follows:

$ For existing tank systems, at least 24 months prior to the date that secondary 

containment must be provided; and

$ For new tank systems, at least 30 days prior to entering into a contract for 

installation.

In addition, the demonstration for a variance must be completed within 180 days after 

notifying the Regional Administrator of an intent to conduct the demonstration.

Contents of the Part B Application

Owner/operators of existing TSDFs may be required to submit their Part B application at 

any time after promulgation of Phase II. Owner/operators may voluntarily submit their Part B 

application at any time. Owner/operators of new TSDFs must submit their Part B application at 

least 180 days before physical construction is expected to commence.

This ICR assumes that all information required under §270.14 through §270.29 is 

submitted along with the Part B application, with the following exceptions:

General Information

Owners/operators of surface impoundments, land treatment units, and waste piles closing 

by removal or decontamination under Part 265 standards may submit a petition to EPA for a 

determination that a post-closure permit is not required. If the owner/operator has not submitted 

a Part B application for a post-closure permit, the owner/operator may petition the EPA for a 

determination that a post-closure permit is not required. If the owner/operator has submitted a 

Part B application for a post-closure permit, the owner/operator may request a determination 

based on information contained in the application. The collection schedule for these activities 

will vary, but submissions should be made to EPA within a reasonable time frame.
93

Financial Assurance

(1) Cost Estimates for Closure and Post-Closure Care

Cost estimates and documentation of financial instruments for closure and post-closure 

care must be submitted to EPA at least 60 days prior to the initial receipt of hazardous waste for 

treatment, storage, or disposal. Insurance documentation must be submitted within the same 

time frame. Respondents must also submit any requested information and permit modifications 

to EPA within a reasonable time, if EPA decides that an adjustment is necessary.

Owner/operators of new facilities must submit proof of coverage by a State financial 

mechanism to EPA at least 60 days before the date on which hazardous waste is first received for 

treatment, storage, or disposal. If a State assumes legal responsibility for a facility’s compliance 

with the closure, post-closure care, or liability requirements, the owner/operator must submit 

evidence of this to EPA within a reasonable time.

Permit Modifications and Special Permits

Permit Modifications

(1) Transfer of Permits

Upon a change of ownership or operational control of a facility, the new owner/operator 

must submit a revised permit application to EPA no later than 90 days prior to the scheduled 

change. When a transfer of ownership or operational control occurs, the old owner/operator will 

comply with the requirements of 40 CFR Part 264, Subpart H until the new owner/operator has 

demonstrated that he or she is complying with the requirements of that Subpart. The new 

owner/operator must demonstrate compliance with Subpart H requirements within six months of 

the date of the change of ownership or operational control of the facility.

(2) Permit Modification at the Request of the Agency

Permit modifications made at the request of the Agency are submitted according to the 

time frame discussed below for permit modifications made at the request of the permittee.

(3) Permit Modification at the Request of the Permittee

(a) Class 1 Modifications

The permittee must notify EPA concerning the Class 1 modification by certified mail or 

other means that establishes proof of delivery within seven calendar days after the change is put 

into effect. The permittee must also send a notice of the modification to all persons on the 

facility mailing list within 90 calendar days after the change. For Class 1 modifications that 

require prior EPA approval, the notification must be made within 90 calendar days after EPA 

approves the request.
94

(b) Class 2 and 3 Modifications

The permittee must send a notice of the Class 2 or 3 modification request to all persons 

on the facility mailing list and publish the notice in a major newspaper of general circulation 

within seven days before or after the date of submission of the modification request.

(c) Requests for Classification of a Permit Modification

For permit modifications that are not specifically listed in appendix I of section 270.42, a 

permittee may submit information in support of a request for a Class 1 or Class 2 permit 

modification. The permittee must submit this information and receive the Agency’s 

determination before making the modification.

(4) Temporary Authorizations

The permittee must send a notice regarding the temporary authorization request to all 

persons on the facility mailing list. This notification must be made within seven days of the 

submission of the authorization request.

(5) Newly Listed or Identified Wastes

The permittee is authorized to continue managing wastes listed or identified as hazardous 

waste if the owner/operator submits a Class 1 modification request on or before the date on 

which the waste becomes subject to the new requirements. In the case of Class 2 and 3 

modifications, owner/operators must submit a complete permit modification request within 180 

days after the effective date of the listing or the waste identification in order to maintain the 

permit authorization.

(6) Corrective Action Management Units

EPA collects information used to designate a CAMU for the purpose of implementing 

corrective action requirements under section 264.101 and RCRA section 3008(h). There is no 

specific collection schedule.

Special Forms of Permits

(1) Hazardous Waste Incinerator Permits

An owner or operator must submit a request for extension of the operational period if he 

or she believes that an incinerator unit requires more than 720 hours of operating time to bring it 

to the point of readiness for a trial burn.

(2) Permits for Land Treatment Demonstrations Using Field Test or Laboratory 
95

Results

Owners/operators must submit a certification that the field tests or laboratory analyses 

have been carried out to EPA within 90 days of the completion of those tests or analyses, unless 

EPA approves a later date.

Interim Status

Termination of Interim Status

An owner or operator of a land disposal facility that becomes subject to permit 

requirements must submit, within 12 months of becoming subject to regulation, a Part B 

application and a certification that the facility is in compliance with all applicable ground-water 

monitoring and financial responsibility requirements.

6. ESTIMATING THE BURDEN AND COST OF COLLECTION

6(a) Estimating Respondent Burden

EPA estimates annual respondent burden hours associated with all of the information 

collection requirements covered in this ICR in Exhibits 1 through 3. These exhibits detail the 

number of hours required to conduct each discrete information collection activity. Exhibit 4 

provides the annual bottom-line respondent burden associated with all information collection 

requirements included in this ICR.

6(b) Estimating Respondent Cost

(i) Estimating Labor Costs

EPA estimates an average hourly respondent labor cost (including overhead) of $104.18

for legal staff, $84.86 for managerial staff, $40.68 for technical staff, and $22.73 for clerical 

staff. These wage rates are based on actual Bureau of Labor Statistics (BLS) mean rates, plus 

overhead and fringe benefits. These rates are lower than those previously used. Previous 

estimates reflected updates with a straight inflation factor applied to previous respondent hourly 

estimates. 

(ii) Estimating Capital Costs

EPA estimates that facilities complying with Part 270 will incur capital costs associated 

with some of the respondent activities. These capital costs include the cost of purchasing 

equipment, such as file cabinets, photocopiers, and monitoring equipment. Exhibits 1 through 3 

detail these costs, if any, for each discrete information collection activity. Exhibit 4 provides the 

annual bottom-line respondent capital cost associated with all information collection 

requirements included in this ICR.
96

(iii) Estimating Operations and Maintenance (O&M) Costs

In complying with Part 270 requirements, facilities may incur operations and 

maintenance (O&M) costs associated with some respondent activities. O&M costs include mail 

submittals, purchased materials costs, and certain lump-sum purchased service costs. Exhibits 1 

through 3 detail these costs, if any, for each discrete information collection activity. Exhibit 4 

provides the annual bottom-line respondent O&M cost associated with all information collection 

requirements included in this ICR.

6(c) Estimating State Agency Burden and Costs

Forty-eight (48) States are authorized for the Part B permit program. The two States that 

are not authorized, Alaska and Iowa, have not received any Part B permits for the last 15 years. 

EPA estimates the State Agency hour and cost burden associated with all information collection 

requirements covered in this ICR in Exhibit 3. As shown in the exhibit, EPA estimates an 

average hourly labor cost of $58.52 for legal staff, $54.94 for managerial staff, $32.87 for 

technical staff, and $20.97 for clerical staff. 

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

Table 1 presents the estimated annual universe of facilities subject to the various types of 

RCRA permitting requirements covered in this ICR. Table 2 presents the estimated annual 

universe of facilities and units covered by RCRA Part B permit applications. Table 3 presents 

the estimated annual universe estimates of facilities and units covered by a RCRA post-closure 

permit applications. 
97

Table 1

Estimated Annual Universe of Facilities Affected by RCRA Part B and Post-Closure Permit 

Applications, Permit Modification, and Special Permit Requirements

Description Number of Facilities

PART B PERMIT APPLICATIONS

Total facilities submitting Part B permit applications 2

Interim facilities submitting Part B permit applications 0

New facilities submitting Part B permit applications 2

POST-CLOSURE PERMIT APPLICATIONS

Facilities applying for post-closure permits 31

PERMIT MODIFICATIONS AND SPECIAL TYPES OF PERMITS

Total facilities submitting Part B permit modifications 99

Permit transfers 1

Agency-initiated modifications 5

Permittee-initiated modifications (Class 1) 61

Permittee-initiated modifications (Class 2 or 3) 32

Table 2

Estimated Annual Universe of Facilities and Units Affected by RCRA Part B Permit 

Application Requirements

Unit Type Number of Facilities Number of Units

Containers 44 93

Tank Systems 49 147

Incinerators 5 8

Land Disposal Units 21 34

Surface Impoundments 3 5

Waste Piles 0 0

Land Treatment Units 0 0

Landfills 7 8

Miscellaneous. Units 11 21
98

Table 3

Estimated Annual Universe of Facilities and Units Affected by RCRA PostClosure Permit Application Requirements

Unit Type Number of Facilities Number of Units

Containers 1 2

Tank Systems 1 8

Incinerators 0 0

Land Disposal Units 7 10

Surface Impoundments 2 3

Waste Piles 0 0

Land Treatment Units 0 0

Landfills 5 7

Miscellaneous Units 0 0

Demonstrations and Exemptions from Requirements

Exhibit 1 details the universe of facilities affected by each discrete information collection 

activity associated with this group of requirements. In addition, Exhibit 1 presents the total 

burden and cost for each of these information collection activities based on this number of 

affected facilities and the burden and cost estimates developed under Sections 6(a) and 6(b). 

Contents of the Part B Application 

Exhibit 2 details the universe of facilities affected by each discrete information collection 

activity associated with this group of requirements. In addition, Exhibit 2 presents the total 

burden and cost for each of these information collection activities based on this number of 

affected facilities and the burden and cost estimates developed under Sections 6(a) and 6(b). 

Permit Modifications and Special Permits

Exhibit 3 details the universe of facilities affected by each discrete information collection 

activity associated with this group of requirements. In addition, Exhibit 3 presents the total 

burden and cost for each of these information collection activities based on this number of 

affected facilities and the burden and cost estimates developed under Sections 6(a) and 6(b). 
99
100

EXHIBIT 1

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

RELEASES FROM REGULATED UNITS (264.90)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the appropriate demonstration 

264.90(b) - 1.00 16.00 2.00 19.00 $ 781.20 $ - $ 8,000.00 0 0 $0

Obtain certification for no-migration demonstration - 0.50 1.00 0.50 2.00 $ 94.48 $ - $ 340.00 0 0 $0

File a copy of the demonstration at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS (264.193 - 264.344)

Tank Systems (264.193)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the demonstration notification - 0.10 0.90 0.50 1.50 $ 56.46 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration under264.193(g)(1) - 1.00 16.00 2.00 19.00 $ 781.20 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration from the 24-hour 

leak detection requirement - 0.50 8.00 1.50 10.00 $ 401.97 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration from the 24-hour 

waste removal requirement - 0.50 8.00 1.50 10.00 $ 401.97 $ - $ 4.00 0 0 $0

Prepare and submit a written description of the equivalent

secondary containment device - 0.50 8.00 1.50 10.00 $ 401.97 $ - $ 4.00 0 0 $0

File a copy of the demonstrations at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Surface Impoundments (264.221)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the demonstrations for an exemption 

from the liner requirements of 264.221(a) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for an exemption 

from the double liner and leachate collection system

requirements of 264.221(c) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration that the leak 

detection system will not be adversely affected by the 

presence of ground water - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the monofill waiver demonstration - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for exemption for 

replacement units - 0.25 4.00 0.25 4.50 $ 189.62 $ - $ 4.00 0 0 $0

File a copy of the demonstrations at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Waste Piles (264.251)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the demonstration for an exemption 

from the liner and leachate collection system requirements 

of 264.251(a) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration that the leak 

detection system will not be adversely affected by the 

presence of ground water - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for an exemption 

from the double liner and leachate collection system

requirements of 264.251(c) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for exemption for 

replacement units - 0.25 4.00 0.25 4.50 $ 189.62 $ - $ 4.00 0 0 $0

File a copy of the demonstrations at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Land Treatment (264.272)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the demonstration - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

File a copy of the demonstration at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 0 0 $0
101

EXHIBIT 1 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS (CONTINUED) (264.193 - 264.344)

Landfills (264.301)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Prepare and submit the demonstration for an exemption 

from the liner requirements of 264.301(a) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration that the leak 

detection system will not be adversely affected by the 

presence of ground water - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for an exemption 

from the double liner and leachate collection and removal 

system requirements of 264.301(c) - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for a waiver of the 

double liner requirements for monofills - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 4.00 0 0 $0

Prepare and submit the demonstration for exemption for 

replacement units - 0.25 4.00 0.25 4.50 $ 189.62 $ - $ 4.00 0 0 $0

File a copy of the demonstrations at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Incinerators (264.344)

Read the regulations - 0.25 2.00 - 2.25 $ 102.58 $ - $ - 0 0 $0

Prepare and submit the demonstration for an extension of

the pre-trial burn period - 0.50 8.00 2.00 10.50 $ 413.33 $ - $ 4.00 0 0 $0

File a copy of the demonstration at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 0 0 $0
102

EXHIBIT 2

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

Legal Review

Review completed permit application 100.00 - - - 100.00 $ 10,418.00 $ - $ - 33 3,300 $343,794

General Information (270.1)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 0 0 $0

Develop and submit the petition for exemption from the postclosure permitting requirements - 0.25 4.00 0.50 4.75 $ 195.30 $ - $ 4.00 0 0 $0

File a copy of the petition at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

Permit Application (270.10(j))

Read the regulations 1.00 - 1.00 - 2.00 $ 144.86 $ - $ - 0 0 $0

Collect and submit the required data 1.00 0.25 8.00 0.75 10.00 $ 467.88 $ - $ 4.00 0 0 $0

File the data at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

General Requirements (270.14(a))

Read the regulations 1.00 1.00 0.25 - 2.25 $ 199.21 $ - $ - 0 0 $0

Prepare and submit the demonstration 1.00 1.00 4.00 0.50 6.50 $ 363.13 $ - $ 4.00 0 0 $0

File a copy of the demonstration at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 0 0 $0

General Facility Standards (270.14(b)(1)-(14))

Read the regulations - 0.50 8.00 - 8.50 $ 367.87 $ - $ - 33 281 $12,140

Prepare a written description of the facility - 2.00 15.00 2.00 19.00 $ 825.38 $ - $ 3,750.00 33 627 $150,988

Collect the analytical information required 

under270.14(b)(2) and prepare a written report of the 

analyses conducted - - 40.00 2.00 42.00 $ 1,672.66 $ - $ 11,650.00 2 84 $26,645

Collect the data required in the waste analysis plan - 10.00 90.00 9.00 109.00 $ 4,714.37 $ - $ 4,000.00 2 218 $17,429

Write the waste analysis plan - 10.00 60.00 9.00 79.00 $ 3,493.97 $ - $ 1,560.00 2 158 $10,108

Prepare a description of security procedures and 

equipment requirements - - 1.50 0.25 1.75 $ 66.70 $ - $ - 2 4 $133

Prepare a demonstration for an exemption from the security 

procedures and equipment requirements - - 0.50 0.50 1.00 $ 31.71 $ - $ - 0 0 $0

Develop an inspection schedule - 8.00 80.00 1.00 89.00 $ 3,956.01 $ - $ - 2 178 $7,912

Prepare demonstration for exemption from special 

equipment requirements - 0.25 0.50 0.25 1.00 $ 47.24 $ - $ - 0 0 $0

Prepare demonstration for exemption from aisle space 

requirements - 0.25 0.50 0.25 1.00 $ 47.24 $ - $ - 0 0 $0

Collect the data required in the contingency plan - - 5.00 - 5.00 $ 203.40 $ - $ 3,250.00 2 10 $6,907

Write the contingency plan - 4.00 30.00 5.00 39.00 $ 1,673.49 $ - $ 1,000.00 2 78 $5,347

Prepare the description of procedures, structures, or 

equipment - 2.00 16.00 2.00 20.00 $ 866.06 $ - $ 4,600.00 2 40 $10,932

Prepare a description of precautions to prevent accidental 

ignition or reaction of ignitable, reactive, or incompatible 

wastes - 1.00 9.00 1.00 11.00 $ 473.71 $ - $ 2,000.00 1 11 $2,474

Prepare description of traffic patterns, volume, and control - 0.10 1.00 0.15 1.25 $ 52.58 $ - $ - 2 3 $105

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 118 4,992 $594,914
103

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

General Facility Standards (Continued) (270.14(b)(1)-(14))

Compile and document the facility location information - - 2.00 0.50 2.50 $ 92.73 $ - $ - 2 5 $185

For facilities located in a Part 264, Appendix VI area, 

prepare demonstration of compliance with the seismic 

standard - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ - 0 0 $0

For facilities located in a 100-year floodplain, prepare 

demonstration for exemption from design and operating 

standards under 264.18(b) - 0.25 4.00 0.75 5.00 $ 200.98 $ - $ - 0 0 $0

For facilities located in a 100-year floodplain, prepare 

engineering analysis and studies - 5.00 44.00 6.00 55.00 $ 2,350.60 $ - $ 13,800.00 31 1,705 $500,669

Prepare compliance plan and schedule of compliance - 1.00 4.00 1.00 6.00 $ 270.31 $ - $ - 0 0 $0

Prepare outline of personnel training programs and 

description of training design - 3.00 18.00 3.00 24.00 $ 1,055.01 $ - $ 3,333.00 2 48 $8,776

Write descriptions for the necessary closure activities - 2.00 16.00 2.00 20.00 $ 866.06 $ - $ 5,000.00 2 40 $11,732

Estimate final closure cost - 1.00 8.00 1.00 10.00 $ 433.03 $ - $ 1,700.00 2 20 $4,266

Write the closure schedule - 0.25 1.00 - 1.25 $ 61.90 $ - $ - 2 3 $124

Collect the necessary information for post-closure 

requirements - 1.00 12.00 7.00 20.00 $ 732.13 $ - $ - 7 140 $5,125

Write the post-closure plan - 1.00 11.00 1.00 13.00 $ 555.07 $ - $ 3,600.00 7 91 $29,085

Prepare documentation that the post-closure notices

required under §264.119 have been filed - 0.25 4.00 0.75 5.00 $ 200.98 $ - $ 2,500.00 0 0 $0

Submit the general facility standards information - - - 0.10 0.10 $ 2.27 $ - $ 4.00 33 3 $207

File copies of all required documentation at the facility - - - 0.50 0.50 $ 11.37 $ 1.00 $ - 33 17 $408

FINANCIAL ASSURANCE (270.14(b) (15)-(16))

Cost Estimates for Closure and Post-Closure Care (264.142 and 264.144)

Read the regulations - - 1.00 - 1.00 $ 40.68 $ - $ - 33 33 $1,342

Collect data - - 5.00 1.00 6.00 $ 226.13 $ - $ - 33 198 $7,462

Prepare and submit the written cost estimates - - 5.00 2.00 7.00 $ 248.86 $ - $ 4.00 33 231 $8,344

Financial Assurance for Closure/Post Closure Care(264.143 and 264.145)

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 33 33 $2,071

Obtain and submit documentation of financial assurance - - 2.00 1.00 3.00 $ 104.09 $ - $ 4.00 33 99 $3,567

Coverage for Sudden or Nonsudden Accidental Occurrences (264.147(a) and (b))

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 0 0 $0

Obtain and submit documentation of liability coverage - - 2.00 1.00 3.00 $ 104.09 $ - $ 4.00 0 0 $0

Request for Variance (264.147(c))

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 0 0 $0

Prepare and submit request for variance 2.00 0.50 2.00 1.00 5.50 $ 354.88 $ - $ 4.00 0 0 $0

Adjustments by the Regional Administrator (264.147(d)

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 0 0 $0

Prepare and submit to EPA any requested information - 0.50 1.00 0.50 2.00 $ 94.48 $ - $ 4.00 0 0 $0

Coverage by a State Financial Mechanism (264.147(b)(18)

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 0 0 $0

Submit letter from owner or operator 1.00 0.50 1.00 0.50 3.00 $ 198.66 $ - $ 4.00 0 0 $0

Submit written evidence of establishment of State-required 

financial assurance mechanism or letter from the State 

describing assumption of responsibility - - 0.50 0.50 1.00 $ 31.71 $ - $ 4.00 0 0 $0

Submit additional information requested by EPA - 0.50 1.00 0.50 2.00 $ 94.48 $ - $ 4.00 0 0 $0
104

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

OTHER PART B REQUIREMENTS (270.14(b)(19), (21))

Topographical Map (270.14(b)(19))

Read the regulations - - 0.50 - 0.50 $ 20.34 $ - $ - 2 1 $41

Collect the necessary information - - 10.00 0.25 10.25 $ 412.48 $ - $ - 2 21 $825

Develop and submit the map - - 1.00 0.25 1.25 $ 46.36 $ - $ 20.00 2 3 $133

Case-by-Case Extensions and Petitions to Allow Land Disposal of a Waste Prohibited Under Subpart C of Part 268 (270.14(b)(21))

Read the regulations - - 0.15 - 0.15 $ 6.10 $ - $ - 0 0 $0

Prepare and submit copy of the notice of approval - 0.10 0.40 0.10 0.60 $ 27.03 $ - $ 4.00 0 0 $0

GROUND-WATER PROTECTION (270.14(c)(1)-(8))

General Ground-Water Monitoring Requirements(270.14(c) (1)-(5))

Read the regulations - - 0.50 - 0.50 $ 20.34 $ - $ - 7 4 $142

Summarize interim status ground-water monitoring data - 4.00 30.00 4.00 38.00 $ 1,650.76 $ - $ 12,000.00 7 266 $95,555

Collect and document hydrogeologic information - 4.00 25.00 4.00 33.00 $ 1,447.36 $ - $ 4,000.00 7 231 $38,132

Add required information to topographical map - - 2.00 - 2.00 $ 81.36 $ - $ 10.00 7 14 $640

Prepare a description of plume contamination - 1.00 50.00 1.00 52.00 $ 2,141.59 $ - $ 16,000.00 1 52 $18,142

Develop ground-water sampling and analysis procedure - - 40.00 - 40.00 $ 1,627.20 $ - $ 15,000.00 0 0 $0

Determine appropriate statistical method - - 3.00 0.50 3.50 $ 133.41 $ - $ - 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 7 4 $108

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 7 1 $23

Detection Monitoring Program (270.14(c)(6))

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 7 7 $439

Compile information to determine monitoring constituents - - 6.00 1.00 7.00 $ 266.81 $ - $ 11,000.00 4 28 $45,067

Prepare the plans and engineering report - 0.50 10.00 1.00 11.50 $ 471.96 $ - $ 300.00 4 46 $3,088

Establish background values - - 80.00 - 80.00 $ 3,254.40 $ - $ 35,000.00 4 320 $153,018

Determine a reasonable time period for identifying 

contamination - - 2.00 - 2.00 $ 81.36 $ - $ - 4 8 $325

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 4 2 $61

File copies of the required information at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 4 0 $13

Compliance Monitoring Program (270.14(c)(7))

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 7 7 $439

Provide a description of wastes previously handled at the 

facility - 0.50 1.00 0.50 2.00 $ 94.48 $ - $ - 1 2 $94

Provide characterization of contaminated ground water - 20.00 120.00 15.00 155.00 $ 6,919.75 $ - $ 39,000.00 1 155 $45,920

Develop list of hazardous constituents for compliance 

monitoring - 0.50 3.00 0.50 4.00 $ 175.84 $ - $ - 1 4 $176

Develop proposed concentration limits and justification for 

alternate concentration limits - 2.00 16.00 2.00 20.00 $ 866.06 $ - $ 25,000.00 1 20 $25,866

Prepare description and engineering report describing the 

proposed ground-water monitoring system - 2.00 16.00 2.00 20.00 $ 866.06 $ - $ - 1 20 $866

Determine a reasonable time period for identifying 

increased contamination - - 2.00 - 2.00 $ 81.36 $ - $ - 1 2 $81

Develop an engineering feasibility plan for corrective action - 2.00 80.00 2.00 84.00 $ 3,469.58 $ - $ 40,000.00 1 84 $43,470

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 1 1 $15

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 1 0 $3

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 96 1,303 $472,682
105

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

GROUND-WATER PROTECTION (CONTINUED) (270.14(c)(1)-(8))

Corrective Action Program (270.14(c)(8))

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 7 7 $439

Provide characterization of the contaminated groundwater - 1.00 20.00 3.00 24.00 $ 966.65 $ - $ 50,000.00 3 72 $152,900

Develop concentration limits - 1.00 20.00 - 21.00 $ 898.46 $ - $ 25,000.00 3 63 $77,695

Prepare detailed plans and engineering report for corrective 

action - 2.00 8.00 2.00 12.00 $ 540.62 $ - $ 5,000.00 3 36 $16,622

Prepare description of how the ground-water monitoring 

program will demonstrate the adequacy of the corrective 

action - 0.50 3.50 1.00 5.00 $ 207.54 $ - $ 10,000.00 3 15 $30,623

Prepare a schedule for submittal of information under 

270.14(c)(8)(iii) and (iv) - 0.50 1.00 0.25 1.75 $ 88.79 $ - $ - 0 0 $0

Prepare demonstration for alternate concentration limits - 2.00 16.00 2.00 20.00 $ 866.06 $ - $ - 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 3 2 $46

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 3 0 $10

SOLID WASTE MANAGEMENT UNITS (270.14(d))

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 33 8 $481

Compile information on solid waste management units - 0.25 4.00 0.25 4.50 $ 189.62 $ - $ - 8 36 $1,517

Compile information on releases from the unit(s) - 0.25 4.00 0.25 4.50 $ 189.62 $ - $ - 8 36 $1,517

Prepare results of sampling and analysis where the 

Director ascertains that a RCRA Facility Assessment is

necessary - 1.00 32.00 3.00 36.00 $ 1,454.81 $ 5,000.00 $ 10,000.00 8 288 $131,638

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 8 4 $123

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ 1.00 $ - 8 1 $26

SPECIFIC PART B INFORMATION REQUIREMENTS (270.15-.21, 270.23-.25)

Containers (270.15)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 34 17 $1,067

Prepare a written description of the containment system - 1.00 4.80 0.40 6.20 $ 289.22 $ - $ 1,200.00 48 298 $71,483

Prepare the no free liquids demonstration - - 1.50 - 1.50 $ 61.02 $ - $ 475.00 2 3 $1,072

Document compliance with §§264.176 and 264.177 - 0.30 2.40 0.20 2.90 $ 127.64 $ - $ 500.00 0 0 $0

Provide a written description of procedures used to ensure 

compliance with §§264.177(a) and (b), and 264.17(b) and 

(c) - 1.30 16.80 1.30 19.40 $ 823.29 $ - $ 700.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 34 17 $523

File copies of the submitted information at the facility - - - 1.00 1.00 $ 22.73 $ - $ 4.00 34 34 $909

Tank Systems (270.16)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 0 0 $0

Conduct assessment of new or existing tank system - 2.00 8.00 1.00 11.00 $ 517.89 $ - $ 1,500.00 0 0 $0

Prepare and certify the assessment - 1.00 4.00 - 5.00 $ 247.58 $ - $ 340.00 0 0 $0

Compile information required under §270.16(c)-(e) - - 3.00 1.00 4.00 $ 144.77 $ - $ 500.00 0 0 $0

Provide a description of tank system installation - - 4.00 0.50 4.50 $ 174.09 $ - $ 500.00 0 0 $0

Prepare a description of the secondary containment system - 1.00 5.00 0.40 6.40 $ 297.35 $ - $ 1,200.00 0 0 $0

Prepare description of controls and practices to prevent

spills and overflows - - 3.00 0.50 3.50 $ 133.41 $ - $ - 0 0 $0

Prepare description of how operating procedures and tank 

system and facility design will achieve compliance with the 

requirements of §§264.198 and 264.199 - 2.00 15.00 2.00 19.00 $ 825.38 $ - $ 700.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 0 0 $0

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 0 0 $0
106

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SPECIFIC PART B INFORMATION REQUIREMENTS (CONTINUED) (270.15-.21, 270.23-.25)

Surface Impoundments (270.17)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 2 1 $63

Develop plans and engineering report - 0.50 20.00 3.00 23.50 $ 924.22 $ - $ 20,000.00 0 0 $0

Prepare description of inspection procedures - - 6.00 1.50 7.50 $ 278.18 $ - $ - 0 0 $0

Obtain a certification or statement from a qualified engineer - - 1.00 0.50 1.50 $ 52.05 $ - $ 340.00 0 0 $0

Develop a pump operating level - - 4.00 - 4.00 $ 162.72 $ - $ - 0 0 $0

Prepare a description of procedures for removing the surface

impoundment from service - 0.50 6.00 0.50 7.00 $ 297.88 $ - $ - 0 0 $0

Prepare a description of hazardous w aste residues and 

contaminated materials to be removed from the unit at closure - 0.50 6.00 0.50 7.00 $ 297.88 $ - $ - 0 0 $0

Provide plans and engineering report - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 1,000.00 0 0 $0

Prepare explanation for ignitable and reactive w astes - 1.30 16.80 1.30 19.40 $ 823.29 $ - $ 700.00 0 0 $0

Prepare explanation for incompatible w astes - 0.50 8.00 0.50 9.00 $ 379.24 $ - $ 350.00 0 0 $0

Prepare a w aste management plan for F-w astes - 0.50 6.00 0.50 7.00 $ 297.88 $ - $ - 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 2 1 $31

File copies of the submitted information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 2 0 $13

Waste Piles (270.18)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 0 0 $0

Prepare a list of hazardous w astes placed or to be placed in each 

w aste pile - - 1.00 0.25 1.25 $ 46.36 $ - $ - 0 0 $0

Prepare explanation of compliance w ith 264.250(c) - - 3.00 0.50 3.50 $ 133.41 $ - $ - 0 0 $0

Prepare engineering report describing compliance w ith 

264.90(b)(2) - 0.50 20.00 3.00 23.50 $ 924.22 $ - $ 8,000.00 0 0 $0

Develop plans and engineering report describing w aste pile design, 

construction, operation and maintenance - 1.00 9.00 - 10.00 $ 450.98 $ - $ 16,600.00 0 0 $0

Prepare description of inspection procedures and incorporate 

description into the inspection plan - - 6.00 1.50 7.50 $ 278.18 $ - $ - 0 0 $0

Describe treatment processes and equipment, and identify the 

nature and quantity of residuals - - 1.00 0.50 1.50 $ 52.05 $ - $ - 0 0 $0

Prepare explanation of compliance w ith requirements for ignitable 

or reactive w astes - 0.25 3.00 0.25 3.50 $ 148.94 $ - $ - 0 0 $0

Prepare explanation of compliance w ith 264.257 for incompatible 

w astes - 0.25 3.00 0.25 3.50 $ 148.94 $ - $ - 0 0 $0

Prepare a description of hazardous w aste residues and 

contaminated materials that w ill be removed from the pile at 

closure, and incorporate the description into the closure and postclosure plans - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ - 0 0 $0

Provide plans and an engineering report describing compliance 

w ith 264.310(a) and (b), and incorporate the description into the 

closure and post-closure plans - - 3.00 0.50 3.50 $ 133.41 $ - $ 16,000.00 0 0 $0

Prepare w aste management plan for F-w astes - 0.50 6.00 0.50 7.00 $ 297.88 $ - $ 8,000.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 0 0 $0

File a copy of the required information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 0 0 $0

Incinerators (270.19 and 270.62(b))

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 0 0 $0

Prepare documentation for ignitable, corrosive, or reactive w astes - 5.00 20.00 5.00 30.00 $ 1,351.55 $ - $ 20,000.00 0 0 $0

Prepare a trial burn plan - 20.00 150.00 20.00 190.00 $ 8,253.80 $ - $ 38,750.00 0 0 $0

Perform the trial burn - 50.00 200.00 50.00 300.00 $ 13,515.50 $ - $ 318,750.00 0 0 $0

Document results of a trial burn in accordance w ith 270.62(b)(6) 

and (8) - 20.00 50.00 20.00 90.00 $ 4,185.80 $ - $ 112,500.00 0 0 $0
107

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SPECIFIC PART B INFORMATION REQUIREMENTS (CONTINUED) (270.15-.21, 270.23-.25)

Incinerators (Continued) (270.19 and 270.62(b))

Prepare analysis of each waste or mixture of wastes to be 

burned - 10.00 50.00 5.00 65.00 $ 2,996.25 $ - $ 30,000.00 0 0 $0

Prepare detailed engineering description of the incinerator - 4.00 30.00 4.00 38.00 $ 1,650.76 $ - $ 17,500.00 0 0 $0

Prepare a description and analysis of the waste to be 

burned and make comparisons to support claim that trial 

burn is not needed - 5.00 20.00 5.00 30.00 $ 1,351.55 $ - $ 20,000.00 0 0 $0

Document and compare the design and operating 

conditions of the incinerator - 5.00 25.00 5.00 35.00 $ 1,554.95 $ - $ 25,000.00 0 0 $0

Prepare and submit results from previous trial burn(s) - 0.50 0.50 1.00 2.00 $ 85.50 $ - $ 4.00 0 0 $0

Compile information on compliance with 264.343 

and264.345 - 5.00 20.00 5.00 30.00 $ 1,351.55 $ - $ 20,000.00 0 0 $0

Provide waste analysis data to identify POHCs - 2.50 20.00 2.50 25.00 $ 1,082.58 $ - $ 10,000.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 0 0 $0

File a copy of the required information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 0 0 $0

Land Treatment (270.20)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 0 0 $0

Prepare treatment demonstration plans - 1.00 10.00 2.00 13.00 $ 537.12 $ - $ - 0 0 $0

Prepare description of a land treatment program - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ - 0 0 $0

Prepare description of unit design, construction, operation 

and maintenance - 1.00 5.00 1.00 7.00 $ 310.99 $ - $ - 0 0 $0

Prepare a description of how demonstration will be 

conducted - - 6.00 1.00 7.00 $ 266.81 $ - $ - 0 0 $0

Prepare description of compliance with 264.276(b) - - 1.00 0.25 1.25 $ 46.36 $ - $ - 0 0 $0

Prepare description of vegetative cover and incorporate the 

description in to the post-closure plan - - 1.00 0.50 1.50 $ 52.05 $ - $ - 0 0 $0

Develop maintenance plan for the vegetative cover and 

incorporate the plan into the post-closure permit - - 0.50 0.25 0.75 $ 26.02 $ - $ 1,000.00 0 0 $0

Prepare explanation of compliance with requirements for 

ignitable and reactive wastes - - - - - $ - $ - $ 700.00 0 0 $0

Prepare explanation of compliance with requirements - - - - - $ - $ - $ 350.00 0 0 $0

Prepare a waste management plan for F-wastes - - - - - $ - $ - $ 8,000.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 0 0 $0

File a copy of the required information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 0 0 $0

Landfills (270.21)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 5 3 $157

Prepare list of wastes placed or to be placed in each landfill 

or landfill cell - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ - 0 0 $0

Prepare plans and an engineering report describing landfill 

design, construction, operation and maintenance - 1.00 20.00 3.00 24.00 $ 966.65 $ - $ 25,000.00 0 0 $0

Prepare plans and an engineering report under 270.21(c) - 1.00 6.00 1.00 8.00 $ 351.67 $ - $ 8,000.00 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 5 3 $157
108

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SPECIFIC PART B INFORMATION REQUIREMENTS (CONTINUED) (270.15-.21, 270.23-.25)

Landfills (Continued) (270.21)

Prepare description of how the landfill inspection 

procedures and incorporate this description into the 

inspection plan - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ - 0 0 $0

Develop a pump operating level - - 4.00 - 4.00 $ 162.72 $ - $ 1,000.00 0 0 $0

Prepare plans and engineering report describing the final 

cover, and incorporate this description into the closure and 

post-closure plans - 1.00 16.00 3.00 20.00 $ 803.93 $ - $ 350.00 7 140 $8,078

Prepare a description of how each landfill will be 

maintained and monitored after closure, and incorporate 

this description into the closure and post-closure plans - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ 350.00 7 14 $3,003

Prepare explanation of compliance for ignitable and 

reactive wastes - 0.25 2.00 0.75 3.00 $ 119.62 $ - $ 700.00 0 0 $0

Prepare an explanation of compliance for incompatible 

wastes - 0.25 2.00 0.75 3.00 $ 119.62 $ - $ 350.00 0 0 $0

Prepare explanation of compliance with landfilled 

containers of hazardous waste - 0.25 1.00 0.75 2.00 $ 78.94 $ - $ 350.00 0 0 $0

Prepare a waste management plan for F-wastes - 0.50 6.00 0.50 7.00 $ 297.88 $ - $ 8,000.00 0 0 $0

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 5 3 $77

File a copy of the required information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 5 1 $31

Miscellaneous Units (270.23)

Read the regulations - 0.50 0.50 - 1.00 $ 62.77 $ - $ - 11 11 $690

Prepare detailed description of unit or proposed unit - 1.00 5.00 0.50 6.50 $ 299.63 $ - $ 1,200.00 21 137 $31,492

Prepare hydrologic, geologic, and meteorologic 

assessments and land-use maps - 1.50 13.30 1.90 16.70 $ 711.52 $ - $ 6,000.00 21 351 $140,942

Compile and prepare information on potential exposure - 3.80 30.00 3.80 37.60 $ 1,629.24 $ - $ 15,000.00 21 790 $349,214

Prepare report on demonstration of treatment effectiveness - 1.00 16.00 2.00 19.00 $ 781.20 $ - $ - 11 209 $8,593

Submit the required information - - - 0.50 0.50 $ 11.37 $ - $ 4.00 11 6 $169

File a copy of the required information at the facility - - - 0.10 0.10 $ 2.27 $ - $ 4.00 11 1 $69

Process Vents and Equipment Leaks (270.24 and 270.25)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 0 0 $0

Write and submit an implementation schedule - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 0 0 $0

Prepare and submit documentation of compliance with 

process vent standards in 264.1032 and 264.1033 - 0.50 16.00 2.00 18.50 $ 738.77 $ - $ 4.00 0 0 $0

Write and submit a performance test plan - 1.00 7.00 2.00 10.00 $ 415.08 $ - $ 4.00 0 0 $0

Compile and submit equipment information - 0.50 3.00 0.50 4.00 $ 175.84 $ - $ 4.00 0 0 $0

Prepare and submit documentation of compliance with 

264.1052 through 264.1059 - 1.00 16.00 2.00 19.00 $ 781.20 $ - $ 4.00 0 0 $0

Prepare and submit documentation of compliance with 

264.1060 - 0.50 2.00 0.50 3.00 $ 135.16 $ - $ 4.00 0 0 $0

Drip Pads (270.26)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 0 0 $0

Prepare and submit a list of hazardous waste placed or to 

be placed on each drip pad - 1.00 6.00 1.00 8.00 $ 351.67 $ - $ 4.00 0 0 $0

Develop and submit plans and an engineering report 

describing the design, construction, operation, and 

maintenance of each drip pad - 1.00 6.00 1.00 8.00 $ 351.67 $ - $ 16,600.00 0 0 $0
109

EXHIBIT 2 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SCHEDULES OF COMPLIANCE (270.33)

Read the regulations - 0.25 0.25 - 0.50 $ 31.39 $ - $ - 2 1 $63

Develop and submit a schedule of compliance - 0.50 2.00 0.50 3.00 $ 135.16 $ - $ 4.00 0 0 $0

Develop and submit alternative schedule of compliance - 0.50 2.00 0.50 3.00 $ 135.16 $ - $ 4.00 0 0 $0

Develop and submit application for two compliance 

schedules - 0.50 2.00 0.50 3.00 $ 135.16 $ - $ 4.00 0 0 $0

Document and submit evidence of firm public commitment

to cease conducting regulated activities - 0.50 1.00 0.50 2.00 $ 94.48 $ - $ 4.00 0 0 $0
110

EXHIBIT 3

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

PERMIT MODIFICATIONS AND SPECIAL PERMITS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

PERMIT MODIFICATIONS (270.40 - .42)

Transfer of Permits (270.40(b))

Read the regulations 0.50 0.10 0.15 - 0.75 $ 66.68 $ - $ - 1 1 $67

Prepare and submit the written agreement 1.00 1.00 0.50 0.50 3.00 $ 220.75 $ - $ 4.00 1 3 $225

Permit Modifications at the Request of the Agency (270.41)

Read the regulations 0.50 0.50 0.50 - 1.50 $ 114.86 $ - $ - 5 8 $574

Prepare and submit the modification request 1.00 1.00 16.00 2.00 20.00 $ 885.38 $ - $ 4.00 5 100 $4,447

Prepare and submit proof of public notice - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 5 8 $358

File a record of the modification request - - - 0.10 0.10 $ 2.27 $ - $ 4.00 5 1 $31

Permit Modifications at the Request of the Permittee (270.42(a)-(d))

Read the regulations for Class 1, 2, or 3permit

modifications (270.42(a)) 2.00 1.00 1.00 - 4.00 $ 333.90 $ - $ - 93 372 $31,053

Prepare and submit the notification under 270.42(a)(i) - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 61 92 $4,366

Prepare and submit information required under 270.13 

through 270.21, 270.62 and 270.63 for Class 1 

modifications 1.00 1.00 8.00 2.00 12.00 $ 559.94 $ - $ 4.00 61 732 $34,400

Prepare and submit written notification to the public and 

appropriate governments - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 61 92 $4,366

Prepare and submit the Class 2 or 3 modification 5.00 15.00 80.00 12.00 112.00 $ 5,320.96 $ - $ 25,000.00 32 3,584 $970,271

Prepare and distribute written notification of the Class 2 or

3 modification request - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ - 32 48 $2,163

Provide for newspaper publication of the notice - - 1.00 0.50 1.50 $ 52.05 $ - $ - 93 140 $4,841

Prepare and submit proof of public notice - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 93 140 $6,657

File a record of the Class 1-3 modification requests - - - 0.10 0.10 $ 2.27 $ - $ 4.00 93 9 $583

Prepare and submit information in support of a request for 

a classification of a permit modification (270.42(d)) - - 2.00 - 2.00 $ 81.36 $ - $ 4.00 93 186 $7,938

Temporary authorizations (270.42(e))

Read the regulations 0.50 0.10 0.15 - 0.75 $ 66.68 $ - $ - 8 6 $533

Prepare and submit temporary authorization request 1.00 0.50 6.00 1.00 8.50 $ 413.42 $ - $ 4.00 8 68 $3,339

Prepare and distribute notification of request - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ - 8 12 $541

Newly Regulated Wastes and Units (270.42(g))

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 1 0 $15

Submit the Class 1, 2 or 3 permit modification 1.00 1.00 16.00 2.00 20.00 $ 885.38 $ - $ 1,000.00 1 20 $1,885

Prepare and submit certification of compliance - - 0.50 0.25 0.75 $ 26.02 $ - $ 4.00 1 1 $30

Permit Modifications for CAMU designation (264.552(d) and (g))

Prepare and submit information for designation of a CAMU

and related permit modification 5.00 15.50 83.00 13.10 116.60 $ 5,510.43 $ - $ 25,000.00 0 0 $0

EXPIRATION AND CONTINUATION OF PERMITS (270.50 - .51)

Read the regulations 0.50 0.10 0.15 - 0.75 $ 66.68 $ - $ - 0 0 $0

Complete and submit the Part B renewal application 5.00 15.00 80.00 12.00 112.00 $ 5,320.96 $ - $ 4.00 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 761 5,623 $1,078,683
111

EXHIBIT 3 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL RESPONDENT BURDEN AND COST

PERMIT MODIFICATIONS AND SPECIAL PERMITS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 104.18 $ 84.86 $ 40.68 $ 22.73

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$104.18/ $84.86/ $40.68/ $22.73/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SPECIAL FORMS OF PERMITS (270.60, .62 - .65)

Hazardous waste incinerator permits (270.62)

Read the regulations - 0.10 0.50 - 0.60 $ 28.83 $ - $ - 0 0 $0

Prepare and submit request for extension of operational 

period - 0.25 1.00 0.25 1.50 $ 67.58 $ - $ 4.00 0 0 $0

Prepare certification of all submissions - - 0.50 0.10 0.60 $ 22.61 $ - $ 350.00 0 0 $0

Prepare and submit the required statements - 0.50 1.00 0.25 1.75 $ 88.79 $ - $ 4.00 0 0 $0

Permits for land treatment demonstrations using field test or laboratory analyses (270.63)

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 0 0 $0

Prepare and submit the certification - 0.50 - 0.50 1.00 $ 53.80 $ - $ 350.00 0 0 $0

Compile and submit the data collected - 0.25 0.50 0.25 1.00 $ 47.24 $ - $ 4.00 0 0 $0

Research, development, and demonstration permits (270.65)

Read the regulations - 0.10 0.50 - 0.60 $ 28.83 $ - $ - 1 1 $29

Prepare and submit the permit application - 13.50 118.50 27.00 159.00 $ 6,579.90 $ - $ 4.00 1 159 $6,584

INTERIM STATUS (270.70 - .73)

Termination of interim status (270.73)

Read the regulations - 0.10 0.15 - 0.25 $ 14.59 $ - $ - 0 0 $0

Prepare and submit certification that an interim status 

facility is in compliance with ground-water monitoring and 

financial responsibility requirements - 2.50 13.00 4.00 19.50 $ 831.91 $ - $ 350.00 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 2 160 $6,613
112

EXHIBIT 4

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

TOTAL ESTIMATED ANNUAL RESPONDENT BURDEN AND COST SUMMARY

Exhibit Title

Annual 

Activities

Annual

Burden

Annual

Labor

Cost

Annual Capital/

Startup Cost

Annual

O&M

Cost

Total

Annual

Cost

Exhibit 1 Demonstrations and Exemptions from Requirements 0 0 $0 $0 $0 $0

Exhibit 2 Contents of the Part B Application 894 11,567 $693,479 $40,056 $1,948,800 $2,682,335

Exhibit 3 Permit Modifications and Special Permits 763 5,623 $275,735 $0 $802,948 $1,078,683

Annual Total 1,657 17,190 $969,214 $40,056 $2,751,748 $3,761,018
113

EXHIBIT 5

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL STATE AGENCY BURDEN AND COST

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 58.52 $ 54.94 $ 32.87 $ 20.97

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$58.52/ $54.94/ $32.87/ $20.97/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

RELEASES FROM REGULATED UNITS (264.90)

Review and evaluate demonstrations - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Review certification - - 0.20 - 0.20 $ 6.57 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

DEMONSTRATIONS AND EXEMPTIONS FROM REQUIREMENTS (264.193 - 264.344)

Tank Systems (264.193)

Review the information submitted - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Surface Impoundments (264.221)

Review demonstrations for exemption - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Review demonstration for adequacy of leak detection - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Review demonstrations for waiver - - 3.00 - 3.00 $ 98.61 $ - $ - 0 0 $0

Review demonstration for replacement unit exemption - - 3.00 - 3.00 $ 98.61 $ - $ - 0 0 $0

Enter information into data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Waste Piles (264.251)

Review and evaluate demonstrations - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Land Treatment (264.272)

Review demonstrations - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Landfills (264.301)

Review demonstration for adequacy of leak detection - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Review and evaluate demonstrations for exemption - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Incinerators (264.344)

Review demonstrations - - 5.00 - 5.00 $ 164.35 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 0 0 $0
114

EXHIBIT 6

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL STATE AGENCY BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 58.52 $ 54.94 $ 32.87 $ 20.97

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$58.52/ $54.94/ $32.87/ $20.97/ Hours/ Cost/ Startup O & M or Hours/ Cost/

Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

GENERAL INFORMATION (270.1)

Review and approve petitions - 0.50 3.00 - 3.50 $ 126.08 $ - $ - 0 0 $0

Enter information into a data base - - - 0.50 0.50 $ 10.49 $ - $ - 0 0 $0

PERMIT APPLICATION (270.10(j))

Review required data - - 3.00 - 3.00 $ 98.61 $ - $ - 0 0 $0

Enter information into a data base - - - 0.50 0.50 $ 10.49 $ - $ - 0 0 $0

GENERAL REQUIREMENTS (270.14(a))

Review and approve demonstrations - 0.25 0.75 - 1.00 $ 38.39 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

GENERAL FACILITY STANDARDS (270.14(b) (1)-(14))

Review required information - - 40.00 - 40.00 $ 1,314.80 $ - $ - 33 1,320 $43,388

Enter information into a data base - - - 3.00 3.00 $ 62.91 $ - $ - 33 99 $2,076

FINANCIAL ASSURANCE (270.14(b) (15)-(16))

Review financial estimates and instruments 4.00 1.00 16.00 - 21.00 $ 814.94 $ - $ - 33 693 $26,893

Enter information into a data base - - - 0.25 0.25 $ 5.24 $ - $ - 33 8 $173

OTHER PART B REQUIREMENTS (270.14(b) (19),(21))

Review topographical map - - 2.00 - 2.00 $ 65.74 $ - $ - 2 4 $131

Review approved land disposal extensions/petitions - - 1.00 - 1.00 $ 32.87 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 2 0 $4

GROUND-WATER PROTECTION (270.14(c) (1)-(8))

Review ground-water monitoring program information - - 40.00 - 40.00 $ 1,314.80 $ - $ - 7 280 $9,204

SOLID WASTE MANAGEMENT UNITS (270.14(d))

Review all required information - - 24.00 - 24.00 $ 788.88 $ - $ - 8 192 $6,311

Enter information into a data base - - - 0.50 0.50 $ 10.49 $ - $ - 8 4 $84

Review information submitted for a RCRA Facility 

Assessment - - 4.00 0.50 4.50 $ 141.97 $ - $ - 8 36 $1,136

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 167 2,636 $89,400
115

EXHIBIT 6 (CONTINUED)

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL STATE AGENCY BURDEN AND COST

CONTENTS OF THE PART B APPLICATION

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 58.52 $ 54.94 $ 32.87 $ 20.97

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$58.52/ $54.94/ $32.87/ $20.97/ Hours/ Cost/ Startup O & M or Hours/ Cost/

Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

SPECIFIC PART B INFORMATION REQUIREMENTS (270.15 - .21, 270.23 - .25) 

Containers (270.15)

Review the submitted data - - 6.00 - 6.00 $ 197.22 $ - $ - 34 204 $6,705

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 34 3 $71

Tank Systems (270.16)

Review the submitted data - - 16.00 - 16.00 $ 525.92 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Surface Impoundments (270.17)

Review the submitted data - - 40.00 - 40.00 $ 1,314.80 $ - $ - 2 80 $2,630

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 2 0 $4

Waste Piles (270.18)

Review the submitted data - - 40.00 - 40.00 $ 1,314.80 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Incinerators (270.19)

Review the submitted data - - 80.00 - 80.00 $ 2,629.60 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Land Treatment (270.20)

Review the submitted data - - 40.00 - 40.00 $ 1,314.80 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Landfills (270.21)

Review the submitted data - - 40.00 - 40.00 $ 1,314.80 $ - $ - 5 200 $6,574

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 5 1 $11

Miscellaneous Units (270.23)

Review the submitted data - - 60.00 - 60.00 $ 1,972.20 $ - $ - 11 660 $21,694

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 11 1 $23

Process Vents and Equipment Leaks (270.24 & .25)

Review the submitted data - - 6.00 - 6.00 $ 197.22 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Drip pads (270.26)

Review the submitted data - - 6.00 - 6.00 $ 197.22 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

SCHEDULES OF COMPLIANCE(270.33)

Review the submitted data - 0.25 1.00 - 1.25 $ 46.61 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 104 1,149 $37,712
116

EXHIBIT 7

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

ESTIMATED ANNUAL STATE AGENCY BURDEN AND COST

PERMIT MODIFICATIONS AND SPECIAL PERMITS

Hours and Costs Per Respondent Per Activity Total Hours and Costs

$ 58.52 $ 54.94 $ 32.87 $ 20.97

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Respon. Total Total

$58.52/ $54.94/ $32.87/ $20.97/ Hours/ Cost/ Startup O & M or Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Year Year Cost Cost Activities Year Year

PERMIT MODIFICATIONS (270.40 - .42)

Transfer of Permits (270.40(b))

Review written agreements 1.00 0.50 1.00 - 2.50 $ 118.86 $ - $ - 1 3 $119

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 1 0 $2

Permit Modifications at the Request of the Agency (270.41)

Review the modification 20.00 1.00 40.00 - 61.00 $ 2,540.14 $ - $ - 5 305 $12,701

Review the proof of public notice - 0.25 1.00 - 1.25 $ 46.61 $ - $ - 5 6 $233

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 5 1 $11

Permit Modifications at the Request of the Permittee (270.42(a)-(d))

Review the Class 1 modification - 0.25 1.00 - 1.25 $ 46.61 $ - $ - 61 76 $2,843

Review the Class 2 or Class 3 modification 20.00 1.00 40.00 - 61.00 $ 2,540.14 $ - $ - 32 1,952 $81,284

Review the proof of public notice - 0.25 1.00 - 1.25 $ 46.61 $ - $ - 93 116 $4,335

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 93 9 $195

Review information submitted in support of a request for a

modification classification, and make a determination 

(270.42(d)) - 0.25 1.00 - 1.25 $ 46.61 $ - $ - 93 116 $4,335

Temporary Authorizations (270.42(e))

Review temporary authorization requests - 1.00 6.00 - 7.00 $ 252.16 $ - $ - 8 56 $2,017

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 8 1 $17

CAMU Requirements

Review information for designation of a CAMU - 0.25 1.00 0.10 1.35 $ 48.70 $ - $ - 0 0 $0

EXPIRATION AND CONTINUATION OF PERMITS (270.50 - 270.51)

Review the permit application - 1.00 20.00 - 21.00 $ 712.34 $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ 2.10 $ - $ - 0 0 $0

SPECIAL FORMS OF PERMITS (270.61 - .65)

Hazardous Waste Incinerator Permits (270.62)

Review request to extend the operational period - 0.50 1.00 0.25 1.75 $ 65.58 $ - $ - 0 0 $0

Review required statements and certifications - - 9.00 - 9.00 $ 295.83 $ - $ - 0 0 $0

Enter information into a data base - - - 0.01 0.01 $ 0.21 $ - $ - 0 0 $0

Permits for Land Treatment Demonstrations Using Field Test or Laboratory Analyses (270.63)

Review certifications - - 9.00 - 9.00 $ - $ - $ - 0 0 $0

Review data collected - - 5.00 - 5.00 $ - $ - $ - 0 0 $0

Enter information into a data base - - - 0.10 0.10 $ - $ - $ - 0 0 $0

Research, Development, and Demonstration (RD&D) Permits

Review application for a RD&D permit - 1.00 50.00 - 51.00 $ - $ - $ - 1 51 $0

Issue or deny a permit - 0.50 1.00 0.50 2.00 $ - $ - $ - 1 2 $0

INTERIM STATUS (270.70 - .73)

Termination of Interim Status (270.73)

Review certification that an interim status facility is in 

compliance with ground-water monitoring and financial 

responsibility requirements - 0.50 10.00 - 10.50 $ - $ - $ - 0 0 $0

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies 407 2,694 $108,092
117

EXHIBIT 8

PART B PERMIT APPLICATION, PERMIT MODIFICATIONS, AND SPECIAL PERMITS

TOTAL ESTIMATED ANNUAL STATE AGENCY BURDEN AND COST SUMMARY

Exhibit Title

Annual 

Activities

Annual

Burden

Annual

Labor

Cost

Annual Capital/

Startup Cost

Annual

O&M

Cost

Total

Annual

Cost

Exhibit 5 Demonstrations and Exemptions from Requirements 0 0 $0 $0 $0 $0

Exhibit 6 Contents of the Part B Application 271 3,785 $127,112 $0 $0 $127,112

Exhibit 7 Permit Modifications and Special Permits 407 2,694 $108,092 $0 $0 $108,092

Annual Total 678 6,479 $235,204 $0 $0 $235,204
118

6(f) Reasons for Change in Burden

The overall annual burden associated with the Part B requirements is 23,669 hours, 

represents a decrease of 9,591 hours under the previous version of this ICR. This decrease is due 

to the smaller number of affected facilities.

 These revisions do not reflect any change in the Part B requirements; they represent 

instead a more accurate and updated representation of the number of respondents submitting 

renewal applications. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 206 hours per response. 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 the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-RCRA-2012-0757, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA 

Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, 

excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the 

telephone number for the RCRA Docket is (202) 566-0270. An electronic version of the public 

docket is available at www.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-2012-0757and OMB Control Number 2050-0009 in any 

correspondence.