SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 2513.01

REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE PROPOSED 

HAZARDOUS WASTE GENERATOR IMPROVEMENTS RULE

June 2015
i

TABLE OF CONTENTS

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

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

1(b) Short Characterization.......................................................................................................1

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

2(a) Need and Authority for the Collection ..............................................................................2

2(b) Practical Utility and Users of the Data..............................................................................2

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA .................................................................................................................................2

3(a) Nonduplication ..................................................................................................................2

3(b) Public Notice .....................................................................................................................2

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

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

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

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

3(g) Sensitive Questions...........................................................................................................4

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

4(a) Respondents and NAICS Codes........................................................................................4

4(b) Information Requested ......................................................................................................5

5. THE INFORMATION COLLECTED-AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT.............................................12

5(a) Agency Activities............................................................................................................12

5(b) Collection Methodology and Management.....................................................................13

5(c) Small Entity Flexibility ...................................................................................................13

5(d) Collection Schedule.........................................................................................................13

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION.....................14

6(a) Estimating Respondent Burden .......................................................................................14

6(b) Estimating Respondent Costs..........................................................................................14

6(c) Estimating Agency Burden and Costs.............................................................................15

6(d) Estimating the Respondent Universe and Total Burden and Costs.................................17

6(e) Bottom Line Burden Hours and Cost Tables ..................................................................21

6(f) Reasons for Change in Burden ........................................................................................21

6(g) Burden Statement ............................................................................................................35
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EXHIBITS

Exhibit 1: Organizations Contacted for Information Supporting the Development of 

this ICR (October-November 2012) ........................................................................3

Exhibit 2: Estimated Universe of Facilities Affected by the Hazardous Waste 

Generator Improvements Rule (High-end)............................................................22

Exhibit 3A: Respondent Burden and Cost Estimates for Private Entities by Generator 

Status (High-end)...................................................................................................23

Exhibit 3B: Respondent Burden and Cost Savings Estimates for Private Entities by

Generator Status (High-end)..................................................................................24

Exhibit 4A: Respondent Burden and Cost Estimates for Large Quantity Generators 

(High-end)..............................................................................................................25

Exhibit 4B: Respondent Burden and Cost Estimates for Small Quantity Generators 

(High-end)..............................................................................................................27

Exhibit 4C: Respondent Burden and Cost Estimates for Conditionally Exempt Small 

Quantity Generators (High-end) ............................................................................29

Exhibit 5A: Respondent Burden and Cost Savings Estimates for Small Quantity

Generators (High-end) ...........................................................................................31

Exhibit 5B: Respondent Burden and Cost Savings Estimates for Conditionally Exempt 

Small Quantity Generators (High-end)..................................................................31

Exhibit 6: Agency Burden and Cost Estimates (High-end)....................................................32

Exhibit 7: Burden and Cost Estimates for State and Local Authorities (High-end)...............33

Exhibit 8: Total Average Respondent Burden and Cost Estimates for the First Three 

Years (High-end) ...................................................................................................34
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This information Collection Request (ICR) is entitled “Reporting and Recordkeeping 

Requirements for the Proposed Hazardous Waste Generator Improvements Rule,” EPA ICR 

Number 2513.01, OMB Number 2050-NEW.

1(b) Short Characterization

Under the statutory authority of the Resource Conservation and Recovery Act (RCRA), 

EPA originally promulgated the hazardous waste generator regulatory program in 1980. Since 

that time, the basic regulatory framework of the program has remained intact except for three 

major changes. First, pursuant to the Hazardous and Solid Waste Amendments (HSWA) of 1984, 

the Agency established regulations in 1986 that distinguished between generators generating 

more than 100 kilograms and less than 1,000 kilograms of hazardous waste in a calendar month 

(small quantity generators, or SQGs) and generators generating 100 kilograms or less in a 

calendar month (conditionally exempt small quantity generators, or CESQGs).1 Prior to the 

1986 rule, CESQGs did not exist as a separate generator class, and all facilities generating less 

than 1,000 kilograms of hazardous waste in a calendar month were subject to the same 

requirements. Second, and also as a result of HSWA, EPA established Land Disposal Restriction 

(LDR) regulations. The Agency’s LDR program established treatment standards for hazardous 

wastes, and specified requirements that generators, transporters, and owners or operators of 

treatment, storage, and disposal facilities (TSDFs) that manage restricted wastes destined for 

land disposal must meet. Third, EPA modified the Uniform Hazardous Waste Manifest 

regulations in 2005 to standardize the content and appearance of the manifest form, make the 

forms available from a greater number of sources, and adopt new procedures for tracking certain 

types of hazardous waste shipments.

Over the course of the last 30 years, the Agency has become aware of ambiguities and 

gaps in the regulations, which, if corrected, could make the program more effective in protecting 

human health and the environment. For example, the current regulations do not require small and 

large quantity generators to document situations where they generated a solid waste, as defined 

at 40 CFR 262.11, that is not a hazardous waste. However, generators often fail to accurately 

make a hazardous waste determination which can lead to the mismanagement of hazardous 

waste. In addition, current regulations do not require that hazardous waste container labels 

include information on the specific hazards of container contents or what risk these wastes could 

pose to human health and the environment when such waste is being accumulated on-site.

EPA has also become increasingly aware of certain inflexibilities in the generator 

regulations over the last 30 years. For example, some generators, particularly those located in 

urban environments, may find it infeasible to meet the requirement that containers holding 

ignitable or reactive waste be placed at least 15 meters (~50 feet) back from the facility’s 

property line. In addition, current regulations require that a CESQG or SQG that experiences a 

one-time generation event resulting in the generation of more than 1,000 kilograms of hazardous 

waste in a calendar month comply with the regulatory requirements for large quantity generators 

 

1 At the time, facilities in this category were referred to as, “Very Small Quantity Generators”.
2

(LQGs). Requiring CESQGs or SQGs that rarely exceed their normal regulatory status to meet 

the full LQG requirements as a result of such episodic events may be burdensome. 

To address these shortcomings in the current generator regulations, EPA is proposing 

several specific changes to the hazardous waste generator program. These improvements are 

relatively minor on an individual basis yet address a wide range of issues. Specifically, EPA 

proposes to (1) revise different components of the hazardous waste regulatory program; (2) 

address gaps in the current regulations; (3) provide greater flexibility for hazardous waste 

generators to manage their hazardous waste in a cost-effective manner; (4) reorganize the 

hazardous waste generator regulations to improve their usability among regulated facilities; and 

(5) make technical corrections and conforming changes to address inadvertent errors, remove 

obsolete programs, and improve the readability of the regulations. In aggregate, the proposed 

changes to the program are expected to significantly improve regulatory efficiency and provide 

further protection of human health and the environment.

This ICR is a description of the information collection requirements for all facilities that 

generate hazardous waste.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

The requirements covered in this ICR are necessary for EPA to oversee the generation 

and management of hazardous waste. EPA is proposing the establishment of these information 

collection requirements under the authority of RCRA Subtitle C.

2(b) Practical Utility and Users of the Data

EPA and State Agencies will use the collected information to ensure that hazardous 

wastes are managed in a cost-effective manner that minimizes risks to human health and the 

environment. Local emergency response organizations will also use the collected information to 

prepare contingency plans to reduce risks to emergency responders and bystanders. 

 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

3(a) Nonduplication

None of the information required by the Proposed Rule would duplicate information 

required by existing RCRA regulations.

3(b) Public Notice

In compliance with the Paperwork Reduction Act of 1995, EPA will open a 60-day

public comment period at the time that this Proposed Rule is published in the Federal Register. 

To assist the public in commenting on the proposal, EPA has raised a number of issues in the 

preamble to the Proposed Rule and asked for the public to comment on them. At the end of the 
3

comment period, EPA will review public comments received in response to the notice and will 

address comments received, as appropriate.

3(c) Consultations

Many of the data and assumptions in this ICR are based on consultations with industry

and States. Specifically, EPA consulted state agencies on the ICR’s assumptions regarding 

hazardous waste generation quantities and the number waste streams managed by facilities in the 

potentially affected universe. The state agencies with whom EPA consulted are identified in 

Exhibit 1.

Exhibit 1: Organizations Contacted for Information Supporting the Development 

of this ICR (October-November 2012)

Organization Contact

Connecticut Department of Energy and Environmental Protection Ross Bunnell

Idaho Department of Environmental Quality Rene Anderson

Maine Department of Environmental Protection Cherie Plummer

New Jersey Department of Environmental Protection Mike Hastry

Washington Department of Ecology Jean Newman

3(d) Effects of Less Frequent Collection

EPA has carefully considered the burden imposed upon the regulated community by the 

Proposed Rule. EPA is confident that those activities required of respondents are necessary, and 

to the extent possible, the Agency has attempted to minimize the burden imposed. EPA strongly 

believes that, if the minimum information collection requirements of the Proposed Rule are not 

met, neither industry nor EPA will be able to ensure that hazardous waste is managed in a 

manner that is protective of human health and the environment.

3(e) General Guidelines

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

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

3(f) Confidentiality

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

policy on public disclosure of information, contain provisions for confidentiality. However, the 

Agency does not anticipate that businesses will assert a claim of confidentiality covering all or 

part of the Proposed Rule. If such a claim is asserted, EPA must and will treat the information in 

accordance with the regulations cited above. EPA also will assure that this information collection 

complies with the Privacy Act of 1974 and OMB Circular 108.
4

3(g) Sensitive Questions

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

associated with the Proposed Rule.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

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

codes associated with the facilities most likely to be affected by the information collection 

requirements covered in this ICR. This table is not intended to be exhaustive, but rather provides 

a guide for readers regarding entities likely to be impacted by this action. 

NAICS NAICS CATEGORY

115 Support Activities for Agriculture and Forestry

211 Oil and Gas Extraction

236 Construction of Buildings

237 Heavy and Civil Engineering Construction

313 Textile Mills

314 Textile Product Mills

321 Wood Product Manufacturing

322 Paper Manufacturing

323 Printing and Related Support Activities

324 Petroleum and Coal Products Manufacturing

325 Chemical Manufacturing

326 Plastics and Rubber Products Manufacturing

327 Nonmetallic Mineral Product Manufacturing

331 Primary Metal Manufacturing

424 Merchant Wholesalers, Nondurable Goods

483 Water Transportation

484 Truck Transportation

532 Rental and Leasing Services

541 Professional, Scientific, and Technical Services

561 Administrative and Support Services

562 Waste Management and Remediation Services

622 Hospitals

712 Museums, Historical Sites, and Similar Institutions

713 Amusement, Gambling, and Recreation Industries

811 Repair and Maintenance

812 Personal and Laundry Services
5

4(b) Information Requested

This section describes information collection requirements applicable to entities that 

would be affected by the Proposed Rule. While the majority of the requirements are mandatory, 

three provisions of the rule (intra-organizational transfers, episodic generation, and special 

requirements for ignitable and reactive waste) are intended to provide greater flexibility to 

certain classes of hazardous waste generators and are thus voluntary.

Negative Hazardous Waste Determinations

(i) Data items: 

The Proposed Rule would require that LQGs and SQGs document and maintain records 

of negative or non-hazardous waste determinations. Under existing regulations, facilities must 

already determine whether they generate RCRA hazardous waste. Facilities must also document 

and maintain records when they determine that they have generated a hazardous waste, while no 

such documentation is required for negative determinations. However, several states already 

require facilities to document negative determinations.

(ii) Respondent activities: 

LQGs and SQGs in states that do not already require documentation of negative 

hazardous waste determinations would have to (1) document non-hazardous waste 

determinations, and (2) maintain this information in their records for a minimum of three years 

from the date that the waste was last sent for on-site or off-site treatment, storage, or disposal.

Re-notification

(i) Data items: 

Under the Proposed Rule, SQGs and LQGs would be required to re-notify EPA of their 

hazardous waste generation activities every other year. LQGs are already required to re-notify

EPA of their hazardous waste generator status through the BR. Twelve states and the District of 

Columbia also already require SQGs to re-notify. Facilities would be required to review their 

previous notification and either make changes, if necessary, or confirm that the information 

remains accurate.

As part of their re-notification, facilities would be required to provide the following 

information to EPA:

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

 The name and telephone number of a contact person;

 The NAICS code of the facility;

 The owner and operator of the facility;

 The generator status of the facility;

 Information on the type of hazardous waste activity; and

 A description of the hazardous wastes handled at the facility.
6

(ii) Respondent activities: 

Facilities would be required to complete and re-submit EPA Form 8700-12 by March 1 of 

each even-numbered year.

Labeling/Marking

(i) Data items: 

Under the Proposed Rule, LQGs and SQGs must label containers with the following 

information:

 The words “Hazardous Waste”;

 Other words that identify the contents of the containers (e.g., paint solvent waste);

 An indication of the hazards of a container’s contents (e.g., the applicable hazardous 

waste characteristic).

In addition, under the proposed rule, LQGs and SQGs must mark areas near drip pads 

and containment buildings with the words “Hazardous Waste” and use their inventory logs to 

document:

 The date the waste was first placed on the drip pad or in the containment building;

 Other words that identify the contents of the waste (e.g., paint solvent waste);

 An indication of the hazards of the waste (e.g., the applicable hazardous waste 

characteristic).

(ii) Respondent activities: 

LQGs and SQGs would be required to label containers with the following information: 

(1) the words “Hazardous Waste”; (2) other words that identify the contents of the containers; 

and (3) an indication of the hazards of a container’s contents. LQGs and SQGs that accumulate 

hazardous waste on drip pads or in containment buildings must also marks these areas with the 

words “Hazardous Waste” and use their inventory logs to document: (1) the date the waste was 

first placed on the drip pad or in the containment building; (2) other words that identify the 

contents of the waste; and (3) an indication of the hazards of the waste.

Closure

(i) Data items: 

Under the Proposed Rule, LQGs would be required to notify EPA or an authorized state 

agency at least 30 days prior to closure and subsequently within 90 days after closure that they

have either clean closed, or if they cannot clean close, that they have closed as a landfill. Under 

existing regulations, LQGs must already comply with general closure provisions (§265.111 and 

§265.114), which require removing and decontaminating all contaminated equipment, structures, 

and soil to minimize the need for further maintenance and prevent post-closure release of 

hazardous waste or constituents into the environment. LQGs storing or treating waste in tanks, 
7

drip pads, and containment buildings are also subject to closure requirements specific to these 

types of units. 

(ii) Respondent activities: 

Facilities must submit to EPA or an authorized state agency notification at least 30 days 

prior to closure and subsequent documentation within 90 days after closure that they have either 

clean closed, or if they cannot clean close, that they have closed as a landfill.

Emergency Response Preparedness

(i) Data items: 

Under the existing RCRA requirements for prevention, preparedness, and emergency 

response, LQGs must prepare a contingency plan and coordinate with their local emergency 

planning committee or other emergency responders. SQGs must also make arrangements with 

emergency responders to familiarize themselves with the site. Under the proposed rule, LQGs 

and SQGs will also be required to maintain records documenting these arrangements with local 

emergency responders. This documentation must include a certified letter or any other 

documentation that confirms such arrangements actively exist. Most LQGs and SQGs are likely 

to have active arrangements with local authorities and will only incur costs to document these 

arrangements. Currently, EPA estimates that 10 percent of facilities have failed to make 

arrangements with local emergency authorities. In addition, the proposed rule would require all 

new LQGs to submit an executive summary of their contingency plan to emergency management 

authorities to improve the ability of emergency response teams to respond to an emergency. 

(ii) Respondent activities: 

Existing LQGs and SQGs that have active arrangements with their local emergency

management authorities would have to document these arrangements. Existing LQGs and SQGs 

that do not have active arrangements would have to ensure such arrangements exist. If there is no 

local emergency planning committee in the area or it does not respond or is unwilling to enter an 

agreement, the generator must enter into an agreement with the local fire department and other 

emergency responders. All new LQGs would have to submit an executive summary of their 

contingency plan to local emergency management authorities. All new SQGs would have to 

obtain documentation of their active arrangements with emergency responders, but would not be 

required to develop a separate executive summary of their contingency plan.

Transfer Facility Requirements

(i) Data items:

The proposed rule would change the labeling/marking requirements for transporters 

storing hazardous waste at a transfer facility to be consistent with the proposed requirements for 

generators. While this provision would require transfer facilities to label all hazardous wastes 

that they receive, the proposed rule’s labeling/marking requirements, as outlined above, would 
8

assure that all hazardous wastes that transfer facilities receive from SQGs and LQGs meet these 

labeling requirements. Thus, transfer facilities would incur additional costs under this provision 

only for waste received from CESQGs, which are not otherwise required to comply with the 

labeling/marking provision of the proposed rule.

(ii) Respondent activities: 

Transfer facilities that receive hazardous waste from CESQGs would be required to label 

containers with the following information: (1) the words “Hazardous Waste”; (2) other words 

that identify the contents of the containers; and (3) an indication of the hazards of a container’s 

contents.

BR Requirements

(i) Data items: 

The proposed rule would make two substantive changes to the BR requirements for 

LQGs. First, it would require LQGs to report all of the hazardous waste that they generate for the 

entire reporting year, not just quantities for the month(s) during which they were LQGs. Existing 

regulation is unclear on this issue and a limited number of states currently require LQGs to report 

the amount of hazardous waste generated for only those months that they were LQGs. Second, 

the rule would require LQGs to report all hazardous waste generated during the reporting year, 

regardless of whether the waste was transported off-site during the reporting year or the 

following year. Although the current BR instructions state that generators should report the total 

quantity of hazardous waste generated during the reporting year, Federal regulations do not 

specifically address cases where a facility generates hazardous waste during the reporting year 

but ships it off-site during the next calendar year.

(ii) Respondent activities: 

LQGs potentially affected by the Propose Rule would be required to submit additional 

Waste Generation Management (GM) forms along with their BR submission for each waste 

stream generated, but not currently reported under the existing requirements, including: (1) 

wastes generated during the month(s) the facility was not an LQG, and (2) wastes generated but 

not transported off-site during the reporting year.

Prohibitions on Storage of Restricted Waste

(i) Data items: 

Consistent with the proposed labeling/marking requirements for LQGs and SQGs, the 

proposed rule would require that containers holding hazardous waste restricted from land 

disposal be marked with (1) the words “Hazardous Waste”; (2) other words that identify the 

contents of the containers (e.g., paint solvent waste); and (3) an indication of the hazards of a 

container’s contents (e.g., the applicable hazardous waste characteristic).
9

(ii) Respondent activities: 

The respondent activities associated with prohibition on storage of restricted waste are 

already covered under the Labeling/Marking provision of the proposed rule. Therefore, there are 

no additional respondent activities.

Drip Pad and Containment Building Requirements for SQGs

(i) Data items:

Under the existing regulations, EPA has consistently interpreted the requirements for 

LQGs that accumulate hazardous waste on drip pads or in containment buildings for 90 days or 

less without a permit or interim status to also apply to SQGs. Therefore, SQGs that use drip pads 

or containment buildings must comply with the LQG 90-day accumulation limit (as opposed to 

the SQG 180-day accumulation limit) as well as the requirements that apply to LQGs for 

personnel training, development of a full contingency plan, and biennial reporting. Under the 

proposed rule, EPA believes a more effective and efficient approach is to require SQGs that 

accumulate hazardous waste on drip pads or in containment buildings to comply with the 90-day

accumulation limit, but to otherwise comply with the less stringent requirements for SQGs.

(ii) Respondent activities: 

There are no additional respondent activities associated with the new requirements. SQGs 

that accumulate hazardous waste on drip pads or in containment buildings must already comply 

with the 90-day accumulation limit under the current regulations. Under the proposed rule, SQGs 

would experience a cost savings associated with no longer being subject to the requirements that 

apply to LQGs for personnel training, development of a full contingency plan, and biennial 

reporting.

Intra-organizational Transfers

(i) Data items: 

To afford greater flexibility to CESQGs, the proposed rule would allow CESQGs to send 

their hazardous waste to an LQG under the ownership of the same organization, provided that 

both the CESQG(s) and LQG comply with certain conditions. The CESQG conditions are as 

follows:

 A participating CESQG must label containers with the words “CESQG Hazardous 

Waste,” other words that identify the contents of the containers, and an indication of 

the hazards of a container’s contents (e.g., the applicable hazardous waste 

characteristic).

The proposed conditions for LQGs receiving hazardous waste from one or more CESQGs 

under the same organizational structure include the following:
10

 LQGs must submit a notification to EPA or their authorized state identifying the 

names, addresses, and contact information for the CESQGs that will be transferring 

hazardous waste to the LQG;

 LQGs must maintain records of all hazardous waste received from CESQGs that 

include the name, address, and contact information for each CESQG, as well as a 

description (i.e., quantity and hazardous waste codes) of each waste shipment 

received;

 LQGs mark shipments from CESQGs with the date the hazardous waste was received 

from the CESQG;

 LQGs would be required to manage all incoming CESQG hazardous waste in 

compliance with the regulations applicable to their LQG status;

 Hazardous waste received from CESQGs would need to be included in the receiving 

LQG’s BR submissions (which may result in the inclusion of additional GM forms).

(ii) Respondent activities: 

CESQGs must perform the following activities:

 Label containers with the relevant required information.

LQGs must perform the following activities:

 Notify EPA or their authorized state of any CESQG that will be transferring waste;

 Maintain records of all hazardous waste received from CESQGs;

 Mark the date the hazardous waste was received from the CESQG;

 Complete and submit GM forms for each CESQG waste stream managed along with 

the BR submission.

Episodic Generation

(i) Data items: 

To provide greater flexibility to CESQGs and SQGs that generate much of their 

hazardous waste on an episodic basis, the proposed rule would allow a CESQG or an SQG to 

maintain its existing regulatory status in the event of a planned or unplanned episodic event in 

which the facility generates a quantity of hazardous waste in a calendar month that would 

otherwise elevate the facility to a more stringent regulatory status. To take advantage of this 

provision, an SQG or CESQG may have no more than one episodic event (planned or unplanned) 

per calendar year and would be subject to the following conditions:

 Notification to EPA or the authorized state at least 30 calendar days prior to initiating 

a planned episodic event or within 24 hours of an unplanned episodic event;

 CESQGs must obtain a RCRA ID number;

 Facilities must meet the following accumulation standards: 

o CESQGs must mark containers with the date the episodic event began; label 

containers “Episodic Hazardous Waste;” manage hazardous waste in a manner 

that minimizes the possibility of a fire, explosion, or release of hazardous waste; 

ensure that tanks are in good condition and compatible with the hazardous waste 

stored within; and identify an emergency coordinator for the duration of the event;
11

o SQGs must mark the container or tank log book with the date the episodic event 

began; label the container or write in the tank log book “Episodic Hazardous 

Waste”; mark the container or write in the tank log book words that identify the 

contents and indicate the hazards of the contents; and comply with the applicable 

accumulation conditions for SQGs;

 Hazardous waste generated from the episodic event must be managed on-site or 

manifested and shipped off-site to a permitted TSDF;

 Facilities must complete and maintain records that include (1) the beginning and end 

dates of the event, (2) a description of the event, (3) the types and quantities of 

hazardous wastes generated at the event, (4) a description of how the hazardous waste 

was managed, and (5) name(s) of hazardous waste transporters that transported the 

waste to a permitted TSDF.

(ii) Respondent activities: 

CESQGs must perform the following activities:

 Notify EPA or authorized state of an episodic event;

 Complete and submit a 8700-12 form to obtain a RCRA ID number;

 Identify emergency coordinator(s) to EPA or the authorized state;

 Label containers with the relevant required information;

 Complete manifests for hazardous wastes managed off-site;

 Complete and maintain records of all hazardous wastes managed during the episodic 

event.

SQGs must perform the following activities:

 Notify EPA or their authorized state of an episodic event; and

 Complete and maintain records of all hazardous wastes managed during the episodic 

event.

Special Requirements for Ignitable and Reactive Wastes

(i) Data items: 

Current RCRA regulations require that LQGs must locate containers holding ignitable or 

reactive waste at least 15 meters from the facility’s property line. In urban environments, LQGs 

may experience difficulty meeting this requirement due to the relatively small footprint of many

properties in these areas. To provide flexibility to LQGs, EPA is proposing to allow LQGs to 

apply for a facility-specific waiver from their local fire department if they are unable to meet the 

hazardous waste accumulation property line requirement.

(ii) Respondent activities: 

Facilities seeking an exemption would be required to submit a waiver to their local fire 

department.
12

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities 

Negative Hazardous Waste Determinations

There are no Agency activities associated with generator waste determinations. EPA may

review results of such determinations during site inspections.

Re-notification

The Agency activities associated with re-notification include reviewing submitted renotifications and entering this information into a database.

Labeling/Marking

There are no Agency activities associated with labeling. EPA may review container 

labeling during site inspections.

Closure

The Agency activities associated with closure include reviewing and maintaining records 

of closure notifications. EPA may also conduct site inspections before or after closure.

Emergency Response Preparedness

There are no Agency activities associated with emergency response preparedness.

Transfer Facility Requirements

There are no Agency activities associated with transfer facility requirements. EPA may

review container labeling during site inspections.

BR Requirements

There are no Agency activities associated with the clarification of BR requirements.

2

Prohibitions on Storage of Restricted Waste

There are no Agency activities associated with prohibitions on storage of restricted waste.

 

2 This ICR assumes the Agency burden to review and maintain electronic records is not dependent on the size of BR submissions (e.g., the number of 

GM forms).
13

Drip Pad and Containment Building Requirements for SQGs

There are no Agency activities associated with requirements for SQGs that accumulate 

hazardous waste on drip pads or in containment buildings for 90 days or less.

Intra-organizational Transfers

The Agency activities associated with intra-organizational transfers include reviewing 

submitted notifications that facilities are voluntarily consolidating waste. LQGs may also have to 

report additional waste streams in their BR submissions (e.g., fill out additional GM forms); 

however, this ICR does not estimate the Agency burden for reviewing this information will 

increase relative to the baseline. EPA may also review container labeling during site inspections.

Episodic Generation

The Agency activities associated with episodic generation include reviewing facility

notifications during episodic events. In addition, for initial episodic events at CESQGs, the 

Agency would need to review letters requesting an EPA ID number, enter this information into a 

database, and generate an EPA ID number and send this EPA ID number to the facility.

Special Requirements for Ignitable and Reactive Wastes

There are no Agency activities associated with special requirements for ignitable and 

reactive wastes.

5(b) Collection Methodology and Management

In collecting and analyzing the information required by the proposed hazardous waste 

generator improvements rule, the Agency will rely upon hard copy forms, electronic 

submissions, and applicable database software, where appropriate. The Agency will also be 

required to maintain a copy of closure notifications.

5(c) Small Entity Flexibility

Some respondents will be small organizations. In certain cases, they will be able to 

complete application, labeling, manifest, recordkeeping, and reporting requirements in less time 

than large organizations because they carry out fewer of these activities. However, the size of the 

organization does not always reflect the amount of time needed to submit reports, label 

containers, or maintain records. EPA believes that the information to be collected is the 

minimum amount necessary to fulfill the purpose of the proposed rule.

5(d) Collection Schedule

The submission of information under this collection is initiated by the respondents. 
14

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

To address uncertainties regarding the number of facilities in the potentially affected 

universe, the amount of hazardous waste that they generate, and several additional cost-related

inputs for this analysis the economic assessment for the Proposed Rule estimates costs as a 

range. This ICR presents the upper end of this range based on the high-end estimates for these 

variables.

3

6(a) Estimating Respondent Burden

Exhibit 3 summarizes the respondent burden associated with the new paperwork 

requirements in the Proposed Rule. As shown in the exhibit, the total one-time respondent 

burden is approximately 127,800 hours and the total expected annual respondent burden is 

approximately 261,700 hours. Thus, the average annual number of burden hours during the first 

three years is estimated to be about 304,300 hours. The expected annual respondent burden 

consists of three cost components over different time periods: (a) recurring annual costs, (b) 

recurring annual costs that are incurred only after the first year of the rule, and (c) biennial costs. 

For reporting purposes, this ICR sums these costs over a 20-year horizon and divides the total by

20 to estimate an average annual cost. This implies that biennial costs are divided by two (since 

they are incurred every other year) and costs incurred only after the first year of the rule are 

multiplied by a factor of 0.95 (19/20 = 0.95).

6(b) Estimating Respondent Costs

Exhibits 4A-C estimate the total costs of the information collection activities associated 

with the Proposed Rule by requirement and respondent generator status. Where applicable, these 

cost estimates reflect the cost of labor and capital as well as operations and maintenance (O&M) 

costs. In sum, the average annual total burden costs during the first three years of the Proposed 

Rule’s implementation is $16.8 million. Of this $16.8 million, $12.8 million is the total burden 

for labor costs and $3.9 million is for capital and O&M costs. Exhibits 5A-B estimate the total 

cost savings for avoided information collection activities related to the Proposed Rule. In the first 

three years of the Proposed Rule’s implementation, the average annual cost savings is 

approximately $884,000. Of this $884,000, $880,000 represents labor cost savings and $4,100 is 

capital and O&M cost savings. 

Labor Costs 

For purposes of this analysis, this ICR estimates an average hourly respondent labor cost 

(including fringe benefits and overhead costs) of $94.09 for legal staff, $82.56 for managerial 

staff, $39.82 for technical staff, and $21.04 for clerical staff. These hourly labor costs were 

obtained from the following sources:

 

3 The low-end and high-end estimates are discussed in greater detail in U.S. EPA, Assessment of the Potential Costs, Benefits, and Other Impacts of 

the Improvements to the Hazardous Waste Generator Regulatory Program, as Proposed, May 2015.
15

 Hourly Wage: Bureau of Labor Statistics, occupational earnings data for May 2012.4

 Fringe Benefit and Overhead Cost Factors: Office of Management and Budget, 

Circular A-76.5

Capital and Operation & Maintenance Costs

Capital costs generally include any produced physical good necessary to provide the 

required information, such as machinery, computers, and other equipment. For this ICR, capital 

costs may include the purchase of software for enhanced labeling systems to carry out the 

information requirements of the Proposed Rule. LQGs typically purchase this software from 

third-party vendors or rely on systems developed by waste management firms that handle some 

of the facility’s operations. The cost of developing an enhanced labeling system for a single 

facility is about 10 hours of a software developer’s time ($65.04/hr) or approximately $650.41.6

O&M costs are those costs associated with materials and services procured for the 

information collection requirements included in the ICR. For this ICR, O&M costs include the 

following: (1) hazardous waste labels ($0.46 per complex label);

7

(2) postage to mail a oneounce letter by certified mail ($0.45 for first-class postage + $2.95 certified-mail fee + $0.09 for 

a catalog envelope = $3.42);

8

(3) photocopying ($0.11 per page);

9

and (4) mail submission for 

RCRA Part B permit renewal ($4.00).10

6(c) Estimating Agency Burden and Costs

The Agency burden hours and costs associate with all the requirements covered in this 

ICR are reported in Exhibit 5. This ICR uses the 2014 Federal Pay Schedule salary figures to 

estimate hourly compensation of EPA legal, managerial, technical, and clerical staff.11 For 

purposes of this ICR, the following government services levels were assigned:

 

4

Bureau of Labor Statistics, May 2012 National Occupational Employment and Wage Estimates, accessed at 

http://www.bls.gov/oes/current/oes_nat.htm#00-0000 on September 3, 2013.

5

Loaded wage rate estimated using methodology from Figure C1 of the 29 May 2003 OMB Circular A-76: Performance of Commercial Activities, 

accessed at http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html on September 3, 2013.

6 Wage information obtained from Bureau of Labor Statistics, May 2012 National Occupational Employment and Wage Estimates, accessed at 

http://www.bls.gov/oes/current/oes_nat.htm#00-0000 on September 3, 2013 adjusted for fringe benefit and overhead cost factors. Burden 

estimate based on e-mail communication with Tom Baker of Veolia ES Technical Solutions on June 27, 2013.

7 Average cost of complex labels from JJ Keller and Label Master accessed at http://www.jjkeller.com/ and 

http://www.labelmaster.com/Shop/labels/ on June 26, 2013. The incremental cost for a complex label where a standard label was previously 

adequate to meet current RCRA requirements is estimated to be $0.40 (or $0.46 less $0.06 for a standard label).

8 These O&M costs were obtained from Supporting Statement for EPA Information Collection Request Number 0976.16, "2013 Hazardous Waste 

Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification, September 2012.

9 Average cost of photocopying based on advertised price by FedEx Office, accessed at http://www.fedex.com/us/office/ as of June 26, 2013.

10 Based on Supporting Statement for EPA Information Collection Request 1573.13 "Part B Permit Application, Permit Modifications, and Special 

Permits," February 2013. 

11 U.S. Office of Personnel Management, Salary Table 2014-GS, Incorporating the 1% General Schedule Increase, Effective January 2014, Hourly 

Basic Rates by Grade and Step, accessed at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/ February 21, 2014.
16

 Legal Staff: GS-15, Step 5 ($81.00/hr)

 Managerial Staff: GS-13, Step 5 ($58.28/hr)

 Technical Staff: GS-11, Step 5 ($40.89/hr)

 Clerical Staff: GS-06, Step 5 ($24.86/hr)

The hourly rates above reflect base salary plus standard fringe benefit and overhead 

factors.12

Re-notification

The burden realized by the Agency for biennial SQG re-notification under the Proposed 

Rule is approximately 9,040 hours. This ICR estimates that the expected annual cost incurred by 

the Agency for re-notification is approximately $370,000 (or $739,000 in even-numbered years).

Closure

The Agency burden to review closure notifications submitted by LQGs is 112 hours and a 

total annual cost of approximately $5,000.

Intra-organizational Transfers

The one-time Agency burden to review submitted notifications for intra-organizational 

transfers is approximately 4,660 hours and a total cost of $191,000.

Episodic Generation

The annual Agency burden to review submitted notifications for planned and unplanned 

episodic events is approximately 890 hours. In addition, the annual burden realized by the 

Agency to issue EPA ID numbers to CESQGs during an initial episodic event is approximately

1,450 hours. This ICR estimates the total annual cost incurred by the Agency for episodic 

generation is approximately $82,000.

Estimating State and Local Authority Burden and Costs

Exhibit 6 presents the burden and costs of the Proposed Rule’s paperwork requirements 

for non-EPA authorities. Local authorities would have to make emergency response 

arrangements with existing LQGs and SQGs that do not have existing arrangements. Local 

authorities would also have to respond to requests for documentation that active emergency 

response arrangements exist for all LQGs and SQGs. Furthermore, local authorities would have 

to review an executive summary of the contingency plans for new LQGs developed for 

emergency response preparedness under the Proposed Rule. Finally, local authorities would have 

to review waivers pertaining to special requirements for ignitable and reactive waste. According 

 

12 Loaded wage rate estimated using methodology from Figure C1 of the 29 May 2003 OMB Circular A-76: Performance of Commercial Activities, 

accessed at http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html on September 3, 2013.
17

to the National Fire Department Census there are more than 48,800 fire stations in the U.S. and 

its territories.13 The number of fire stations that would be affected by the Proposed Rule is 

uncertain. . Furthermore, the burden associated with the waiver requirement for ignitable and 

reactive wastes would only impact emergency responders in metropolitan areas. Therefore, the 

number of fire stations directly affected by the Proposed Rule is likely small relative to the 

nationwide figure and heavily concentrated in the metropolitan areas of states with a large 

number of LQGs. This ICR estimates it would require approximately 30 minutes of a 

supervisor’s time to review emergency response preparedness and waivers pertaining to special 

requirements for ignitable and reactive waste submitted by hazardous waste generators. It also 

estimates that it would take about 5 minutes of a supervisor’s time to write an e-mail or letter 

documenting that active emergency response arrangements exist for LQGs and SQGs.

Wage information for non-EPA authorities was obtained from the Bureau of Labor 

Statistics as described below:

 First-line Supervisors of Fire Fighting and Prevention Workers ($50.75/hr)

This hourly rate reflects base salary plus standard fringe benefit and overhead factors as 

reported by OMB.

As indicated in Exhibit 6, the waiver requirements for ignitable and reactive waste would 

result in a one-time burden of up to 4,850 hours and a total one-time cost of $246,000. The 

waiver requirement for new LQGs would result in an expected annual burden of approximately 

760 hours and a total cost of $39,000 (for the low-end scenario the expected annual burden is 

less than 1 hour). Under the proposed rule, local emergency management authorities would have 

to make arrangements for emergency response preparedness with existing LQGs and SQGs that 

do not have active arrangements. This would result in a one-time burden of approximately 3,700 

hours and a total one-time cost of $188,000. Local authorities would also have to respond to 

requests for documentation of active arrangements with existing LQGs and SQGs, a one-time 

burden of approximately 5,500 hours and a total one-time cost of $282,000. Finally, local 

authorities would have to review the executive summaries of contingency plans submitted by

new LQGs, resulting in a recurring annual burden of 1,177 hours and a total annual cost of 

$60,000.

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

Respondent Universe

Exhibit 2 reports the estimated annual universe of facilities subject to each of the 

provisions of the Proposed Rule covered in this ICR. Thus, the total estimated annual number of 

respondents is about 96,375.

 

13 U.S. Department of Homeland Security, Federal Emergency Management Agency, U.S. Fire Administration, National Fire Department Census 

Database, accessed at http://apps.usfa.fema.gov/census/ on February 24, 2014. 
18

Respondent Burden and Cost

Based on the universe data presented in Exhibit 2, this section estimates the respondent 

burden associated with all of the new information collection requirements covered in this ICR. 

The total respondent burden and cost are reported in Exhibits 4A-C. The additional flexibility

under the proposed rule afforded SQGs that accumulate hazardous waste on drip pads or in 

containment buildings and SQGs and CESQGs that experience episodic events would result in a 

cost savings for these generators. The total respondent cost savings are reported in Exhibits 5AB. This section describes the assumptions used in developing the burden estimates.

Negative Hazardous Waste Determinations

Under the Proposed Rule, 7,010 LQGs and 26,920 SQGs would be required to document 

non-hazardous waste streams (in addition to those facilities located in states that already require 

negative determinations). During the first year of the rule, the per facility burden is 4.6 hours for 

LQGs and 2.1 hours for SQGs, and the total one-time cost per facility is $158 for LQGs and $73 

for SQGs.14 After the first year, the per facility burden is 1.4 hours for LQGs and 0.7 hours for 

SQGs, and the total per facility cost is $49 for LQGs and $24 for SQGs. Thus, the expected 

annual burden is $46 for LQGs and $23 for SQGs.

Re-notification

This ICR estimates that 51,656 SQGs would have to re-notify EPA every even-numbered 

year and the average facility burden for re-notification is 0.8 hours. Therefore, the expected 

annual cost per facility is $18.

Labeling/Marking

To comply with the enhanced labeling requirements of the Propose Rule, LQGs would 

need to update their computerized labeling systems, while SQGs would likely use a manual 

process to label containers with the additional information. For LQGs, the one-time capital cost 

of software development (for purchase from a third-party vendor or lease from a waste 

management company) is $650 per facility.

15

 For SQGs, the annual burden is 2.1 hours and a 

total cost of $95 per facility.

Closure

This ICR estimates that 319 LQGs close annually. These facilities are required to submit 

two closure notifications to EPA (one 30 days prior to closure and one within 90 days following 

closure), resulting in a burden of 2.0 hours and a total cost of $90 per facility.

 

14 This ICR estimates that LQG generate an average of 13 non-hazardous waste streams each year, of which, about 4 are new waste streams. In 

addition, SQGs generate an average of 6 non-hazardous wastes streams per year, of which, about 2 are new waste streams. New waste streams 

must be documented each year after the first year of the rule.

15 The cost of developing an enhanced labeling system for a single facility is about 10 hours of a software developer’s time ($65.04/hr).
19

Emergency Response Preparedness

Under the Proposed Rule, an existing 1,426 LQGs and 5,970 SQGs that do not have 

active arrangements with local emergency response authorities would have to make such 

arrangements, resulting in a one-time burden of approximately 10 minutes and total one-time 

cost of $3 per facility. In addition, 14,262 existing LQGs and 59,702 existing SQGs would have 

to document their active arrangements with emergency responders, resulting in a one-time 

burden of approximately 6 minutes and a total one-time cost of $2 per facility. Furthermore, an 

estimated 2,353 new LQGs each year would be required to prepare an executive summary of 

their contingency plan, resulting in a burden of 4.2 hours and a total cost of $334 per facility.

16

Finally, an estimated 2,610 new SQGs would have to document their arrangements with 

emergency responders, resulting in a burden of 6 minutes and a total cost of $2 per facility. 

Transfer Facility Requirements

Transfer facilities would also be required to comply with the labeling/marking 

requirements described above. CESQGs are not required to comply with the labeling/marking 

provision of the Proposed Rule. Therefore, transfer facilities would have to label containers 

received from CESQGs to comply with the requirements of the proposed rule. The transfer 

facility requirements represent a 37.9 hour burden (for labeling waste received from an average 

of approximately 114 CESQGs per facility) and a total cost of $1,690 per facility.

17

BR Requirements

The BR requirements would affect all 14,262 LQGs in the potentially affected universe 

as well as less than two dozen SQGs and a similar number of CESQGs located in states that 

require short-term LQGs to submit information to EPA in even-numbered years.

18,19 The 

expected annual burden for LQGs is 2.3 hours and a total annual cost of $60 per facility (or $120 

in even-numbered years).

20 The expected annual burden for SQGs and CESQGs is 5.7 hours and 

a total annual cost of $150 per facility (or $300 in even-numbered years).

Prohibitions on Storage of Restricted Waste

There is no burden estimated for prohibitions on storage of restricted waste.

 

16 For the low-end estimate, the burden is 2.2 hours and a total cost of $169 per facility.

17 For the low-end estimate, the burden is 13.2 hours and a total cost of $589 per facility.

18 Currently, Idaho, West Virginia, and South Carolina require short-term LQGs to report the amount of hazardous waste they generate only for the 

months they are LQGs. U.S. EPA, ASTSWMO Survey Responses, March 2012, provided by Jim O'Leary of EPA's Office of Resource Conservation and 

Recovery on August 26, 2013.

19 This ICR estimates that the number of short-term LQGs in the three affected states includes 374 LQGs, 22 SQGs, and 20 CESQGs (the lower 

generator status categories are included due to episodic generation). If a short-term LQG exceeds the SQG threshold for more than a single 

calendar month, it would become an LQG.

20 The estimated burden for short-term LQGs that become LQGs is similar to the reported burden for short-term LQGs that remain SQGs or CESQGs. 

This ICR conservatively estimates that short-term episodic events last either one or two months in duration, facilities in the latter category become 

LQGs.
20

Drip Pad and Containment Building Requirements for SQGs

There is no burden estimated for SQGs that accumulate hazardous waste on drip pads or 

in containment buildings for 90 days or less. This ICR estimates that 12 SQGs would realize a 

cost savings associated with avoiding the LQG requirements for reviewing, updating, and 

distributing their contingency plan and preparing and submitting biennial reports. The expected 

annual cost savings for these generators is approximately 8.5 hours and $550 per facility (or 

about 12 hours and $760 per facility in even-numbered years).

21

Intra-organizational Transfers

This ICR estimates that 22,411 CESQGs would voluntarily consolidate their waste 

through intra-organizational transfers and 2,410 LQGs would receive this waste (i.e., 

approximately 9.3 CESQGs per LQG).22 For CESQGs, the annual burden for labeling containers 

is 0.33 hours and a total cost of $15 per facility. For LQGs, the one-time burden to notify EPA is 

9.3 hours and a total cost of approximately $420 per facility. The annual recordkeeping burden is 

0.9 hours and a total cost of approximately $37 per facility. The BR expected annual reporting 

burden is 14.1 hours and a total annual cost of $372 per facility (or $744 in even-numbered 

years).

Episodic Generation

This ICR estimates that approximately 837 SQGs and 1,707 CESQGs would voluntarily

take advantage of the episodic generation flexibility provided by the Proposed Rule each year. 

The estimated burden for SQGs is 7.5 hours and a total cost of $385 per facility. The estimated 

burden for CESQGs is 7.2 hours and a total cost of $339 per facility. This ICR also estimates that 

837 SQGs and 527 CESQGs that would avoid becoming an LQG due to an episodic event would 

realize a cost savings associated with avoiding the LQG requirements for reviewing, updating, 

and distributing their contingency plan and preparing and submitting biennial reports. The 

expected annual cost savings for these generators is approximately 10 hours and $640 per facility

(or about 16 hours and $900 per facility in even-numbered years).23

Special Requirements for Ignitable and Reactive Wastes

LQGs that cannot comply with the property line requirement for the storage of ignitable 

 

21 The estimated annual cost savings reflects two components: (1) avoided contingency planning requirements (5 hours and $350 per facility per 

year) and (2) avoided biennial reporting requirements (7 hours and $400 per facility in even-numbered years). 

22 The number of affected facilities is based on the number of facilities in states with landfill bans, plus the 10 percent of CESQGs in other states 

that manage hazardous waste at a TSDF. This 10 percent estimate is based on the professional judgment of Jim O'Leary of EPA’s Office of Resource 

Conservation and Recovery, December 5, 2013, from input provided to EPA by regulated facilities. The percentage of facilities that are part of 

larger organizations that could take advantage of this provision is based on analysis of facility-level data provided by Florida, Maine, Massachusetts, 

New Hampshire, Oregon, and Wisconsin.

23 The estimated annual cost savings reflects two components: (1) avoided contingency planning requirements (5 hours and $350 per facility per 

year) and (2) avoided biennial reporting requirements (10.5 hours and $600 per facility in even-numbered years). 
21

and reactive wastes may voluntarily apply for a waiver from their local emergency management 

authority. The number of affected facilities is highly uncertain; therefore, estimates are presented 

as a range.24 As a high-end estimate, up to 9,700 LQGs in metropolitan areas would incur a onetime burden of 0.9 hours and a total cost of $41 per facility. After the first year, up to 1,600 new 

LQGs would need to apply for permits (an expected annual cost of $39 per facility). As a lowend estimate, only four LQGs would be affected by this requirement in the first year and about 

one facility per year after that.

6(e) Bottom Line Burden Hours and Cost Tables 

Exhibit 2 presents the total number of respondents for this collection of information and 

Exhibit 3A presents the estimated average burden hours and costs per respondent per year for

each of the public reporting and recordkeeping requirements associated with the Proposed Rule, 

which are reported separately for LQGs, SQGs, and CESQGs. Exhibit 3B similarly presents the 

estimated cost savings per respondent per year. Exhibits 4A-C then provide additional detail on 

the burden and cost estimates and Exhibits 5A-B provide additional detail on the cost savings 

estimates. Exhibit 6 presents the Agency burden and Exhibit 7 reports the burden for state and 

local authorities. Finally, Exhibit 8 summarizes the total average annual costs of the Proposed 

Rule for the first three years by respondent type. The public reporting and recordkeeping

requirements in the exhibits include both one-time and recurring activities (including annual 

information collection activities and biennial reporting requirements).

6(f) Reasons for Change in Burden

As described in this ICR, EPA expects that the Proposed Rule will result in an increase in 

burden to generators of hazardous waste. This increase in burden reflects specific paperwork 

requirements established by the Proposed Rule (e.g., closure notification) and existing paperwork 

requirements that will be clarified/modified by the rule for select facilities (e.g., BR reporting, 

enhanced labeling requirements). EPA has determined that these paperwork requirements are 

necessary to improve regulatory efficiency and provide further protection of human health and 

the environment.

 

24 The high-end estimate is based on an analysis of waste codes in EPA’s BR database to identify the number of LQGs that manage ignitable or 

reactive waste and data from the Missouri Census Data Center to match these facility zip codes to U.S. Census metropolitan statistical areas. The 

low-end estimate is based on the average number of facilities that report a change in their physical address to EPA between BR reporting periods 

(every two years). This assumes facilities relocate because they cannot comply with the property line requirement.
22

Exhibit 2: Estimated Universe of Facilities Affected by the Hazardous Waste Generator 

Improvements Rule (High-end)

Information Collection Activity Number of Respondents

LQGs SQGs CESQGs TOTAL

Negative Hazardous Waste Determinations 7,010 26,920 0 33,930

Re-notification 0 51,656 0 51,656

Labeling/Marking 14,262 59,702 0 73,964

Closure 319 0 0 319

Emergency Response Preparedness 14,262 59,702 0 73,964

Transfer Facility Requirements 317 4 4 325

BR Requirements 14,262 22 20 14,304

Prohibitions on Storage of Restricted Waste 0 0 0 0

Drip Pad and Containment Building Requirements 0 12 0 12

Intra-organizational Transfers 2,410 0 22,411 24,821

Episodic Generation 0 837 1,707 2,544

Special Requirements for Ignitable and Reactive Wastes 9,699 0 0 9,699
23

Exhibit 3A: Respondent Burden and Cost Estimates for Private Entities by Generator Status (High-end)

Information Collection Activity

LQGs SQGs CESQGs Total

Total Hours Total Cost Total Hours Total Cost Total Hours Total Cost Total Hours Total Cost

Negative Hazardous Waste Determinations

One-time cost 31,896 $1,109,000 56,532 $1,965,000 0 $0 88,428 $3,074,000

Annual cost19,323 $324,000 17,902 $622,000 0 $0 27,225 $947,000

Re-notification

Annual cost10 $0 20,306 $946,000 0 $0 20,306 $946,000

Labeling/Marking

One-time cost 0 $9,276,000 0 $0 0 $0 0 $9,276,000

Annual cost 0 $0 126,867 $5,660,000 0 $0 126,867 $5,660,000

Closure

Annual cost (one-time cost for LQGs) 638 $29,000 0 $0 0 $0 638 $29,000

Emergency Response Preparedness

One-time cost 1,654 $35,000 6,925 $146,000 0 $0 8,580 $180,000

Annual cost (one-time cost for new LQGs and SQGs) 10,024 $790,000 261 $5,500 0 $0 10,285 $795,000

Transfer Facility Requirements

Annual cost 12,008 $536,000 152 $7,000 152 $7,000 12,311 $549,000

Special Requirements for Ignitable and Reactive Waste

One-time cost for existing LQGs 8,438 $401,000 0 $0 0 $0 8,438 $401,000

Annual cost (one-time cost for new LQGs)11,323 $63,000 0 $0 0 $0 1,323 $63,000

BR Requirements

Annual cost117,342 $911,000 63 $3,000 57 $3,000 17,462 $918,000

Intra-organizational Transfers

One-time cost 22,389 $1,011,000 0 $0 0 $0 22,389 $1,011,000

Annual cost119,280 $986,000 0 $0 7,463 $333,000 26,743 $1,319,000

Episodic Generation

Annual cost

(one-time cost per facility per episodic event) 0 $0 6,244 $322,000 12,303 $578,000 18,547 $900,000

TOTAL ONE-TIME COSTS 64,377 $11,832,000 63,457 $2,111,000 0 $0 127,834 $13,942,000

TOTAL ANNUAL COSTS 69,938 $3,639,000 171,794 $7,567,000 19,975 $921,000 261,707 $12,126,000

TOTAL AVERAGE ANNUAL COSTS FOR THE 

FIRST THREE YEARS 91,397 $7,582,000 192,946 $8,271,000 19,975 $921,000 304,318 $16,774,000

Notes:

Numbers may not sum due to rounding.

1. Annual costs include expected values for costs not incurred every year (e.g., biennial reporting). 
24

Exhibit 3B: Respondent Burden and Cost Savings Estimates for Private Entities by Generator Status (High-end)

Information Collection Activity

LQGs SQGs CESQGs Total

Total Hours Total Cost

Savings Total Hours Total CostSavings Total Hours Total CostSavings Total Hours Total CostSavings

Drip Pad and Containment Building Requirements

One-time cost savings 0 $0 0 $0 0 $0 0 $0

Annual cost savings10 $0 102 $6,600 0 $0 102 $6,600

Episodic Generation

One-time cost savings 0 $0 0 $0 0 $0 0 $0

Annual cost savings10 $0 8,567 $539,000 5,394 $339,000 13,961 $878,000

TOTAL ONE-TIME COST SAVINGS 0 $0 0 $0 0 $0 0 $0

TOTAL ANNUAL COST SAVINGS 0 $0 8,669 $545,000 5,394 $339,000 14,063 $884,000

TOTAL AVERAGE ANNUAL COST SAVINGS FOR 

THE FIRST THREE YEARS 0 $0 8,669 $545,000 5,394 $339,000 14,063 $884,000

Notes:

Numbers may not sum due to rounding.

1. Annual cost savings include expected values for costs not incurred every year (e.g., biennial reporting).
25

Exhibit 4A: Respondent Burden and Cost Estimates for Large Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Negative Hazardous Waste Determinations

Document all nonhazardous waste streams 

(one-time cost) 0.00 0.00 3.25 1.30 $0.00 $1.43 7,010 31,896 $1,099,000 $10,000 $1,109,000

Document new nonhazardous waste 

streams1(annual cost, after first year) 0.00 0.00 1.00 0.40 $0.00 $0.44 7,010 9,323 $321,000 $3,000 $324,000

Re-notification

Notify EPA or Regional Administrator1

(cost incurred in even-numbered years) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Labeling/Marking

Software development for enhanced 

labeling system (one-time cost) 0.00 0.00 0.00 0.00 $650.41 $0.00 14,262 0 $0 $9,276,000 $9,276,000

Label all containers in central and satellite 

accumulation areas 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Closure

Notify EPA or Regional Administrator 0.00 0.16 1.68 0.16 $0.00 $6.84 319 638 $27,000 $2,000 $29,000

Emergency Response Preparedness

Make arrangements with local emergency 

management authorities (one-time cost) 0.00 0.00 0.00 0.16 $0.00 $0.00 1,426 228 $4,800 $0 $4,800

Maintain records documenting active 

arrangements with local emergency 

management authorities (one-time cost)

0.00 0.00 0.00 0.10 $0.00 $0.00 14,262 1,426 $30,000 $0 $30,000

Develop and submit executive summary of 

contingency plan to local emergency 

management authority

0.00 4.00 0.00 0.16 $0.00 $0.00 2,353 9,788 $785,000 $0 $785,000

Maintain records documenting active 

arrangements with local emergency 

management authorities

0.00 0.00 0.00 0.10 $0.00 $0.00 2,353 235 $5,000 $0 $5,000

Transfer Facility Requirements

Label containers for all waste received from 

CESQGs 0.00 0.00 37.88 0.00 $0.00 $181.83 317 12,008 $478,000 $58,000 $536,000

Special Requirements for Ignitable and Reactive Waste

Submit waiver application to local 

emergency management authority (onetime cost)0.00 0.20 0.57 0.10 $0.00 $0.00 9,699 8,438 $401,000 $0 $401,000
26

Exhibit 4A: Respondent Burden and Cost Estimates for Large Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Submit waiver application to local 

emergency management authority as a new 

LQG1

0.00 0.20 0.57 0.10 $0.00 $0.00 1,601 1,323 $63,000 $0 $63,000

BR Requirements

Gather information and prepare GM forms 

for waste generated but not transported offsite during reporting year (cost incurred in 

even-numbered years)1

0.00 0.84 1.08 0.36 $0.00 $0.00 14,262 16,259 $855,000 $0 $855,000

Gather information and prepare GM forms 

for waste generated in months when a 

facility was not an LQG (cost incurred in 

even-numbered years)1

0.00 2.03 2.85 0.91 $0.00 $0.00 374 1,083 $56,000 $0 $56,000

Intra-organizational Transfers

Notify EPA or Regional Administrator

(one-time cost) 0.00 0.74 7.81 0.74 $0.00 $31.80 2,410 22,389 $934,000 $77,000 $1,011,000

Gather information and prepare GM form1

(cost incurred in even-numbered years) 0.00 5.21 6.70 2.23 $0.00 $0.00 2,410 17,039 $896,000 $0 $896,000

Recordkeeping 0.00 0.00 0.93 0.00 $0.00 $0.00 2,410 2,241 $89,000 $0 $89,000

Label all containers in central and satellite 

accumulation areas 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Episodic Generation

Notify EPA or Regional Administrator 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Obtain an EPA ID Number 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Complete and maintain records of episodic 

hazardous waste generated 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Complete manifests 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Identify emergency coordinator(s) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

TOTAL ONE-TIME COSTS N/A 64,377 $2,469,000 $9,363,000 $11,832,000

TOTAL ANNUAL COSTS N/A 69,938 $3,576,000 $63,000 $3,639,000

Notes:

Numbers may not sum due to rounding.

1. Annual costs include expected values for costs not incurred every year (e.g., biennial reporting).
27

Exhibit 4B: Respondent Burden and Cost Estimates for Small Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Negative Hazardous Waste Determinations

Document all nonhazardous waste streams 

(one-time cost) 0.00 0.00 1.50 0.60 $0.00 $0.66 26,920 56,532 $1,948,000 $18,000 $1,965,000

Document new nonhazardous waste 

streams1(annual cost, after first year) 0.00 0.00 0.50 0.20 $0.00 $0.22 26,920 17,902 $617,000 $6,000 $622,000

Re-notification

Notify EPA or Regional Administrator1

(cost incurred in even-numbered years) 0.00 0.08 0.63 0.08 $0.00 $3.42 51,656 20,306 $858,000 $88,000 $946,000

Labeling/Marking

Software development for enhanced 

labeling system (one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Label all containers in central and satellite 

accumulation areas 0.00 0.00 2.13 0.00 $0.00 $10.20 59,702 126,867 $5,051,000 $609,000 $5,660,000

Closure

Notify EPA or Regional Administrator 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Emergency Response Preparedness

Make arrangements with local emergency 

management authorities (one-time cost) 0.00 0.00 0.00 0.16 $0.00 $0.00 5,970 955 $20,000 $0 $20,000

Maintain records documenting active 

arrangements with local emergency 

management authorities (one-time cost)

0.00 0.00 0.00 0.10 $0.00 $0.00 59,702 5,970 $126,000 $0 $126,000

Develop and submit executive summary of 

contingency plan to local emergency 

management authority

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Maintain records documenting active 

arrangements with local emergency 

management authorities

0.00 0.00 0.00 0.10 $0.00 $0.00 2,610 261 $5,500 $0 $5,500

Transfer Facility Requirements

Label containers for all waste received from 

CESQGs 0.00 0.00 37.88 0.00 $0.00 $181.83 4 152 $6,000 $1,000 $7,000

Special Requirements for Ignitable and Reactive Waste

Submit waiver application to local 

emergency management authority (onetime cost)0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0
28

Exhibit 4B: Respondent Burden and Cost Estimates for Small Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Submit waiver application to local 

emergency management authority as a new 

LQG1

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

BR Requirements

Gather information and prepare GM forms 

for waste generated but not transported offsite during reporting year (cost incurred in 

even-numbered years)1

0.00 2.10 2.70 0.90 $0.00 $0.00 22 63 $3,000 $0 $3,000

Gather information and prepare GM forms 

for waste generated in months when a 

facility was not an LQG (cost incurred in 

even-numbered years)1

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Intra-organizational Transfers

Notify EPA or Regional Administrator

(one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Gather information and prepare GM form1

(cost incurred in even-numbered years) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Recordkeeping 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Label all containers in central and satellite 

accumulation areas 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Episodic Generation

Notify EPA or Regional Administrator 0.00 0.08 0.84 0.08 $0.00 $3.42 837 837 $35,000 $3,000 $38,000

Obtain an EPA ID Number 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Complete and maintain records of episodic 

hazardous waste generated 0.00 2.38 3.06 1.02 $0.00 $0.00 837 5,407 $284,000 $0 $284,000

Complete manifests 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Identify emergency coordinator(s) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

TOTAL ONE-TIME COSTS N/A 63,457 $2,093,000 $18,000 $2,111,000

TOTAL ANNUAL COSTS N/A 171,794 $6,860,000 $707,000 $7,567,000

Notes:

Numbers may not sum due to rounding.

1. Annual costs include expected values for costs not incurred every year (e.g., biennial reporting).
29

Exhibit 4C: Respondent Burden and Cost Estimates for Conditionally Exempt Small Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Negative Hazardous Waste Determinations

Document all nonhazardous waste streams 

(one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Document new nonhazardous waste 

streams1(annual cost, after first year) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Re-notification

Notify EPA or Regional Administrator1

(cost incurred in even-numbered years) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Labeling/Marking

Software development for enhanced 

labeling system (one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Label all containers in central and satellite 

accumulation areas 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Closure

Notify EPA or Regional Administrator 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Emergency Response Preparedness

Make arrangements with local emergency 

management authorities (one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Maintain records documenting active 

arrangements with local emergency 

management authorities (one-time cost)

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Develop and submit executive summary of 

contingency plan to local emergency 

management authority

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Maintain records documenting active 

arrangements with local emergency 

management authorities

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Transfer Facility Requirements

Label containers for all waste received from 

CESQGs 0.00 0.00 37.88 0.00 $0.00 $181.83 4 152 $6,000 $1,000 $7,000

Special Requirements for Ignitable and Reactive Waste

Submit waiver application to local 

emergency management authority (onetime cost)0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0
30

Exhibit 4C: Respondent Burden and Cost Estimates for Conditionally Exempt Small Quantity Generators (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Costs

Capital/

Startup 

and O&M 

Costs Total Cost

Submit waiver application to local 

emergency management authority as a new 

LQG1

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

BR Requirements

Gather information and prepare GM forms 

for waste generated but not transported offsite during reporting year (cost incurred in 

even-numbered years)1

0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Gather information and prepare GM forms 

for waste generated in months when a 

facility was not an LQG (cost incurred in 

even-numbered years)1

0.00 2.10 2.70 0.90 $0.00 $0.00 20 57 $3,000 $0 $3,000

Intra-organizational Transfers

Notify EPA or Regional Administrator

(one-time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Gather information and prepare GM form1

(cost incurred in even-numbered years) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Recordkeeping 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0

Label all containers in central and satellite 

accumulation areas 0.00 0.00 0.33 0.00 $0.00 $1.60 22,411 7,463 $297,000 $36,000 $333,000

Episodic Generation

Notify EPA or Regional Administrator 0.00 0.08 0.84 0.08 $0.00 $3.42 1,707 1,707 $71,000 $6,000 $77,000

Obtain an EPA ID Number 0.00 0.08 0.84 0.08 $0.00 $3.42 1,707 1,707 $71,000 $6,000 $77,000

Complete and maintain records of episodic 

hazardous waste generated 0.00 1.51 1.94 0.65 $0.00 $0.00 1,707 6,992 $368,000 $0 $368,000

Complete manifests 0.00 0.00 0.11 0.24 $0.00 $0.00 1,707 600 $16,000 $0 $16,000

Identify emergency coordinator(s) 0.00 0.00 0.40 0.36 $0.00 $0.00 1,707 1,297 $40,000 $0 $40,000

TOTAL ONE-TIME COSTS N/A 0 $0 $0 $0

TOTAL ANNUAL COSTS N/A 19,975 $873,000 $48,000 $921,000

Notes:

Numbers may not sum due to rounding.

1. Annual costs include expected values for costs not incurred every year (e.g., biennial reporting).
31

Exhibit 5A: Respondent Burden and Cost Savings Estimates for SQGs (High-end)

Information Collection Activity

Hours and Cost Savings Per Respondent Per Activity Total Hours and Cost Savings

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

Savings

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Cost 

Savings

Capital/

Startup and 

O&M Cost 

Savings

Total Cost

Savings

Drip Pad and Containment Building Requirements

Review, update, and distribute contingency 

plan 0.00 4.00 0.00 1.00 $0.00 $0.00 12 60 $4,200 $0 $4,200

Prepare and submit Biennial Reports (cost 

avoided in even-numbered years)1 0.00 3.10 3.17 0.78 $0.00 $5.94 12 42 $2,400 $40 $2,400

Episodic Generation

Review, update, and distribute contingency 

plan 0.00 4.00 0.00 1.00 $0.00 $0.00 837 4,185 $294,000 $0 $294,000

Prepare and submit Biennial Reports (cost 

avoided in even-numbered years)1 0.00 4.36 4.79 1.32 $0.00 $5.94 837 4,382 $242,000 $2,500 $245,000

TOTAL ONE-TIME COST SAVINGS N/A 0 $0 $0 $0

TOTAL ANNUAL COST SAVINGS N/A 8,669 $543,000 $2,500 $545,000

Notes:

Numbers may not sum due to rounding.

1. Annual cost savings include expected values for costs not incurred every year (e.g., biennial reporting).

Exhibit 5B: Respondent Burden and Cost Savings Estimates for CESQGs (High-end)1

Information Collection Activity

Hours and Costs Savings Per Respondent Per Activity Total Hours and Cost Savings

Legal

$94.09/hr

Managerial

$82.56/hr

Technical

$39.82/hr

Clerical

$21.04/hr

Capital/

Startup 

Cost

Saving

O&M 

Cost

Number 

of Resp.

Total 

Hours

Labor 

Cost 

Savings

Capital/

Startup and 

O&M Cost 

Savings

Total Cost

Savings

Episodic Generation

Review, update, and distribute contingency 

plan 0.00 4.00 0.00 1.00 $0.00 $0.00 527 2,635 $185,000 $0 $185,000

Prepare and submit Biennial Reports (cost 

avoided in even-numbered years)1 0.00 4.36 4.79 1.32 $0.00 $5.94 527 2,759 $152,000 $1,600 $154,000

TOTAL ONE-TIME COST SAVINGS N/A 0 $0 $0 $0

TOTAL ANNUAL COST SAVINGS N/A 5,394 $338,000 $1,600 $339,000

Notes:

Numbers may not sum due to rounding.

1. Figures in this exhibit reflect cost savings for CESQGs that avoid becoming LQGs during episodic events. There are no avoided reporting requirements for CESQGs that become SQGs.

2. Annual cost savings include expected values for costs not incurred every year (e.g., biennial reporting).
32

Exhibit 6: Agency Burden and Cost Estimates (High-end)

Information Collection Activity

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Legal

$81.00/hr

Managerial

$58.28/hr

Technical

$40.89/hr

Clerical

$24.86/hr

Capital/

Startup 

Cost

O&M 

Cost

Number 

of Resp. Total Hours Total Cost

Re-notification

Review submitted re-notification and enter this 

information into a database (cost incurred in evennumbered years)1, 20.00 0.00 0.35 0.00 $0.00 $0.00 51,656 9,040 $370,000

Closure

Review and maintain records of closure notification 0.00 0.00 0.35 0.00 $0.00 $0.00 319 112 $5,000

Intra-organizational Transfers

Review submitted notification (one-time cost) 0.00 0.00 0.35 0.00 $0.00 $0.00 13,323 4,663 $191,000

Episodic Generation

Review submitted notification of episodic event 0.00 0.00 0.35 0.00 $0.00 $0.00 2,544 890 $36,000

Review letter requesting EPA ID number and enter this 

information into a database 0.00 0.00 0.35 0.00 $0.00 $0.00 1,707 597 $24,000

Generate EPA ID number and send EPA ID number to

facility3 0.00 0.00 0.00 0.50 $0.00 $0.45 1,707 854 $22,000

TOTAL ONE-TIME COSTS N/A 4,663 $191,000

TOTAL ANNUAL COSTS N/A 11,493 $457,000

TOTAL AVERAGE ANNUAL COSTS FOR THE 

FIRST THREE YEARS N/A 13,047 $521,000

Notes:

Numbers may not sum due to rounding.

1. Estimated Agency burden based on information provided by the following states: Connecticut, Idaho, Illinois, Iowa, Massachusetts, New Hampshire, Ohio, Rhode Island, Vermont.

Information provided by Jim O’Leary of EPA’s Office of Resource Conservation and Recovery on March 10, 2014.

2. Annual costs include expected values for costs not incurred every year (e.g., biennial reporting).

3. Supporting Statement for EPA Information Collection Request Number 0976.16, “2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous 

Waste Permit Application and Modification,” September 19, 2012.
33

Exhibit 7: Burden and Cost Estimates for State and Local Authorities (High-end)

Information Collection Activity

Hours and Costs Per Respondent 

Per Activity Total Hours and Costs

Managerial

($50.75/hr)

Capital/

Startup 

Cost

O&M 

Cost

Number of 

Resp. Total Hours Total Cost

Emergency Response Preparedness

Make arrangements with existing LQGs and SQGs

(one-time cost) 0.50 $0.00 $0.00 Unknown 3,698 $188,000

Respond to requests for documentation of active 

arrangements with existing LQGs and SQGs

(one-time cost)

0.083 $0.00 $0.00 Unknown 5,547 $282,000

Review executive summary of contingency plan 

submitted by new LQGs 0.50 $0.00 $0.00 Unknown 1,177 $60,000

Special Requirements for Ignitable and Reactive Waste

Review waiver application for current LQGs 

(one-time cost) 0.50 $0.00 $0.00 Unknown 4,850 $246,000

Review waiver application for new LQGs10.50 $0.00 $0.00 Unknown 760 $39,000

TOTAL ONE-TIME COSTS N/A 14,095 $715,000

TOTAL ANNUAL COSTS N/A 1,937 $98,000

TOTAL AVERAGE ANNUAL COSTS FOR THE 

FIRST THREE YEARS N/A 6,635 $337,000

Notes:

Numbers may not sum due to rounding.

1. Annual costs include expected values for costs not incurred every year.
34

Exhibit 8: Total Average Respondent Burden and Cost Estimates for the First Three Years (High-end)

Respondent Type Total 

Respondents

Total 

Responses Total Hours Total Labor Costs

Total 

Capital/

Startup and 

O&M Costs

Total Cost

Generators (High-end) 96,375 213,915 304,318 $12,830,000 $3,944,000 $16,773,000

State and Local Authorities 48,800 31,762 6,635 $337,000 $0 $337,000

TOTAL AVERAGE ANNUAL COSTS FOR 

THE FIRST THREE YEARS 145,175 245,677 310,953 $13,166,000 $3,944,000 $17,111,000

Notes:

Numbers may not sum due to rounding.
35

6(g) Burden Statement

The average public reporting and recordkeeping burden for this collection of information

is about 1 hour. During the first year of the rule, it is estimated to be 11.9 hours for LQGs (4.5

hours on a one-time basis and 7.4 hours annually), 4.3 hours for SQGs (1.1 hours on a one-time 

basis and 3.2 hours annually), and less than 0.1 hours for CESQGs (no one-time costs).25 Under 

the proposed rule, the annual cost savings related to information collection requirements are 

estimated to be 0.2 hours for SQGs and less than 0.1 hours for CESQGs. 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-2008-0678, 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 Ave., 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-2008-0678 and OMB Control Number 2050-NEW in any 

correspondence.

 

25 This burden represents costs incurred by all entities. However, not all entities will be affected by the information collection requirements in this 

ICR (e.g., not all LQGs will experience a closure event). The average public reporting and recordkeeping burden during the first year of the rule (for 

only affected facilities, assuming a facility has to comply with each requirement of the Proposed Rule) is 84.5 hours for LQGs (15.0 hours on a onetime basis and 69.6 hours annually), 57.1 hours for SQGs (2.4 hours on a one-time basis and 54.8 hours annually), and 51.1 hours for CESQGs (no 

one-time costs). Note, this burden reflects costs to 4 SQG and 4 CESQG transfer facilities. Excluding transfer facilities, the average estimated 

burden is 19.2 hours for SQGs and 13.2 hours for CESQGs.