**SUPPORTING STATEMENT FOR EPA INFORMATION COLLECTION REQUEST NUMBER**  **2513 .01**  **REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE PROPOSED HAZARDOUS WASTE GENERATOR**  **IMPROVEMENTS RULE** 

June 2015i **TABLE OF CONTENTS** 1. ID ENTIFICATION 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 -AGEN CY 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 COLLEC TION ..................... 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) Re asons for Change in Burden
................................ ................................ ........................ 21 6(g) Burden Statement
................................ ................................ ................................ ............ 3 5ii **EXHIBITS** Exhibit 1: Organizations Contacted for Information Supporting the Development of

this ICR (October
-November 2012)
................................ ................................ ........ 3 Exhibit 2: Estimated Universe of Facilities Affected b y the Hazardous Waste

Generator Improvements Rule (High
- end)
................................ ............................ 2 2 Exhibit 3 A : Respondent Burden and Cost Estimates for Private Entities by Generator Status (High
- end)
................................ ................................ ................................ ... 23 Exhibit 3 B : Respondent Burden and Cost Savings Estimates for Private Entities by

Generator Status (High
- end)
................................ ................................ .................. 2 4 Exhibit 4A: Respondent Burden and Cost Estimates f or Large Quantity

Generators (High
- end)
................................ ................................ ................................ .............. 2 5 Exhibit 4B: Respondent Burden and Cost Estimates f or Small Quantity

Generators (High
- end)
................................ ................................ ................................ .............. 2 7 Exhibit 4C: Respondent Burden and Cost Estimates f or Conditionally

Exempt Small Quantity Generators (High
- end)
................................ ................................ ............ 2 9 Exhibit 5A : Respondent Burden and Cost Savings Estimates f or Small Quantity Generators (High
- end)
................................ ................................ ........................... 31 Exhibit 5B : Respondent Burden and Cost Savings Estimates f or 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)
................................ ................................ ................................ ... 341

**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 IC R Number 2513.01, OMB Number 2050
-NEW . **1(b) Short Characterization**  Under the statutory

authority of the Resource Conservation and Recovery Act (RCRA), EPA originall y 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 ty pes 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 Generat ors”.2

(LQGs)
. Requiring CESQGs or SQGs that rarel y 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 relativel y minor on an individual basis yet address a wide range of issues
. S pecificall y, 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 b ystanders. **3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Nonduplication** None of the information required by the Proposed Rule would duplicate information required b y 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 the3

comment p eriod, 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 indu stry and States
. Specificall y, 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 c onsulted 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 carefull y 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 strongl y 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 IC R 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 c overing 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) Sen**  **sitive 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 affecte d 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 Services5

**4(b) Information Requested**  This section describes information collection requirements applicable to entities that would be affected b y the Proposed R ule
. 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
. F acilities 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 R

ule, 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 the ir re -notification, f acilities would be required to provide the fo llowing 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 faci lity;  In formation 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, LQ Gs 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 o f 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 content s 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 3 0 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 cl osed as a landfill
. Under existing regulations, LQGs must already compl y 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 m aintenance and prevent post
- closure release of hazardous waste or constituents into the environment
. LQ Gs storing or treating waste in tanks,7

drip pads, and containment buildings are also subject to closure requirements specific to these ty pes 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 emergenc y response, LQGs must prepare a contingency p lan 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 the se 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 likel y to have active arrangements with local authorities and will only incur costs to document these arrangements . Currentl y, 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. **Tra nsfer 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, would8

assure that all hazardous wastes that transfer facilities receive from SQGs and LQGs me et 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) Resp ondent 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 ye ar, 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 onl y those months that they were LQGs . Second, the rule would require LQGs to report all hazardous waste generated during the reporting ye ar, regardless of whether the waste was transported off
- site during the reporting ye ar or the following ye ar . Although the current BR instructions state that generators should report the total quantity of hazardous waste generated during the reporting ye ar, Federal regulations do not specificall y address cases where a facility generates hazardous waste during the reporting year but ships it off

- site during the next calendar ye ar. (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 ye ar. **Prohibiti ons 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 us e 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 compl y 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 compl y with certain conditions
. The CESQG conditions are as follows:  A participating CESQG must label containers with the words “C ESQG 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 ye ar and would be subject to the following conditi ons:  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, explos ion, 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 appl icable 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 ty pes 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 fo llowing 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 relativel y s mall 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 re
notifications 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 Requirement**

**s** 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 in spections. **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, ent er 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 anal yz ing 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) S**  **mall Entity Flexibility** Some respondents will be small organizations
. Incertain cases, they will be able to complete application, labeling, manifest, recordkeeping, and reporting requirements in less time than large organizations because they c arry 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 estimate s for these variables
. 3 **6(a) Estimating Respondent Burden**  Exhibit 3 summarize s 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 ye ars is estimated to be about 304,300 hours
. The expected annual respondent burden consist s 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
- ye ar 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 ye ar 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. Insum, the average annual total burden costs during the first three years of the Proposed R ule ’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 ye ars 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 hourl y 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 hourl y l abor 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 generall y include any produced phys ical 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 s ystems to carry out the information requirements of the Proposed Rule
. LQGs ty pically purchase this software from third
-party vendors or rely on s ystems 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 one
ounce letter b y certified mail ($0.45 for first
- class postage + $2.95 certified
-mail fee + $0.09 for a catalog envelope = $3.4 2) ; 8 (3) photocop ying ($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 o f Commercial Activities, accessed at http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.html on September 3, 2013. 6 Wage information obtained fro m 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 previo usly adequate to meet current RCRA requirements is estimated to be $0.40 (or $0.46 less $0.06 for a standard label). 8 These O&M costs were obtained from Supporting Statement for EPA Information Collection Request Number 0976.16, "2013 Hazardou s Waste Repo rt, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification, September 2012. 9 Average cost of photocopying based on advertised price by FedEx Office, accessed at http://www.fedex.com/us/office/ as of June 26, 2013. 10 Based on Supporting Statement for EPA Information Collection Request 1573.13 "Part B Permit Application, Permit Modifications , and Special Permits," February 2013. 11 U.S. Office of Personnel Manag ement, Salary Table 2014 - GS, Incorporating the 1% General Schedule Increase, Effective January 2014, Hourly Basic Rates by Grade and Step, accessed at https://www.opm.gov/policy - data - oversight/pay - leave/salaries - wages/ February 21, 2014.16  Legal Staff: GS - 15, Step 5 ($ 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 hourl y rates above reflect base salary plus standard fringe benefit and overhead factors. 12 **Re -** **notification** The burden realized b y 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 b y 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 episodi c 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, 45 0 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, l ocal authorities would have to review an executive summary o f the contingency

p lans 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, 8 00 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 c oncentrated in the metropolitan areas of states with a large number of LQ Gs . This IC R estimates it would require approximately 3 0 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 LQG s and SQG s . 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 reflect s base salary

p lus standard fringe benefit and overhead factors as reported b y 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 76 0 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 p lans 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

**Responden t 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 5 A B . 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 ye ar 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 s ystems, 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 co st 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 r ule. 15 The cost of developing an enhanced labeling system for a single facility is about 10 hours of a software developer’s time ($6 5.04/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 ye ar 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 $3 34 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 **B R 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 S QGs, and 20 CESQGs (the lower generator status categories are included due to episodic generat ion ). 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 -** **organiza tional 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 la beling 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 ye ars)
. **Episodic Generation** This ICR estimates that approximately 837 SQGs and 1,707 CESQGs would voluntarily take advantage of the episodic generation flexibility provided b y the Proposed Rule each ye ar . 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 report ing requirements ( 7 hours and $ 400 per facility in even - numbered years). 22 T he number of affected facilities is based on the number of facilities in states with landfill bans, plus the 10 percent of CE SQGs in other states that manage hazardous waste at a TSDF. This 10 percent estimate is based on the p rofessional 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 a nalysis 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 pe r 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 appl y 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 one
time 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 low
end estimate, only

four LQGs would be affected by this requirement in the first year and about one facility per ye ar 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 3 A present s the estimated average burden hours and costs per respondent per ye ar for each of the public reporting and recordkeeping requirements associated with the Proposed Rule, which are reported separately for LQGs, SQGs, and CESQGs. Exhibit 3 B similarly presents the estimate d cost savings per respondent per year . Exhibits 4A - C then provide additional detail on the burden and cost estimates and Exhibits 5 A - 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. Finall y, Exhibit 8 summarizes the total average annual costs of the Proposed Rule for the first three ye ars b y 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 b y 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 h igh - 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 l ow - 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 com ply with the property line requirement.22

**Exhibit 2: Estimated Universe of Facilities Affected by the Hazardous Waste Generator Improvements Rule (** **High -**  **end)**

**Inform ation 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 9,69923 **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 c ost 31,896 $1,1 09 ,000 56,532 $1,9 65 ,000 0 $0 88,428 $3,074,000 Annual c ost 1 9,323 $3 24 ,000 17,902 $622,000 0 $0 27,225 $9 47 ,000 **Re -**  **notification** Annual co st 1 0 $0 20,306 $ 946 ,000 0 $0 20,306 $946,000 **Labeling/Marking** One - time c ost 0 $9,276,000 0 $0 0 $0 0 $9,276,000 Annual c ost 0 $0 126,867 $5,660,000 0 $0 126,867 $5,660,000 **Closure** Annual c ost ( one - time c ost for LQGs ) 638 $29,000 0 $0 0 $0 638 $29,000 **Em ergency Response Preparedness**  One - time cost 1,654 $35,000 6,925 $146,000 0 $0 8,580 $180,000 Annual c ost ( one - time c ost for new LQGs and SQGs ) 10,024 $7 90 ,000 261 $ 5,500 0 $0 10 , 285 $7 9 5,000 **Transfer Facility Requirements** Annual c ost 12,008 $536,000 152 $7,000 152 $7,000 12,311 $549,000 **Special Requirements for Ignitable and Reactive Waste** One - time c ost for existing LQGs 8,438 $401,000 0 $0 0 $0 8,438 $401,000 Annual c ost ( one - time c ost for new LQGs) 1 1,3 2 3 $6 3 ,000 0 $0 0 $0 1,3 23 $6 3 ,000 **BR Requirements** Annual c ost 1 17,342 $911,000 63 $3,000 57 $3,000 17,462 $918,000 **Intra -**  **organizational Transfers** One - time c ost 22,389 $1,011,000 0 $0 0 $0 22,389 $1,011,000 Annual c ost 1 19,280 $986,000 0 $0 7,463 $333,000 26,743 $1,319,000 **Episodic Generation** Annual cost ( o ne - time c ost per f

acility per episodic event) 0 $0 6,244 $322,000 12,303 $578,000 18,547 $900,000 **TOTAL ONE -**  **TIME COSTS 6**  **4 ,** **377 $11,**  **832 ,000**  **63,457 $**  **2 ,**  **111 ,000**  **0 $0**  **1 27**  **, 834**  **$13, 94**  **2 ,000**  **TOTAL ANNUAL COSTS 69,**  **938 $3,6**  **39 ,000**  **171, 794**  **$7,56 7**  **,000 19,975**  **$921,000 261,**  **707 $12,1**  **2 6,000**  **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 Cost Savings**  **Total Hours Total Cost**  **Savings Total Hours**  **Total Cost Savings**  **Drip Pad and Containment Building Requirements** One - time c ost savings 0 $0 0 $0 0 $0 0 $0 Annual c ost savings 1 0 $0 102 $6,600 0 $0 102 $6,600 **Episodic Generation** One - time c ost savings 0 $0 0 $0 0 $0 0 $ 0 Annual c ost savings 1 0 $0 8,567 $ 539,000 5,394 $33 9 ,000 13,961 $ 878,000

**TOTAL ONE -**  **TIME COST SAVING**  **S 0**  **$ 0**  **0 $**  **0 0**  **$0 0**  **$ 0**  **TOTAL ANNUAL COST**  **SAVING S**  **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 f**  **or 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 streams 1 (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 Administrator 1 (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 **Em ergency 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 (one
time cost) 0.00 0.20 0.57 0.10 $0.00 $0.00 9,699 8,438 $401,000 $0 $401,00026 **Exhibit 4A: Respondent Burden and Cost Estimates f**  **or 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 LQG 1 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 off
site 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 p repare 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 form 1 (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**  **6 4**  **, 377**  **$2,4 69**  **,000 $9,363,000**  **$11, 832**  **,000 TOTAL ANNUAL COSTS**  **N/A 69,**  **938 $3,57**  **6 ,000**  **$63,000 $3,63**  **9 ,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 f**  **or 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 streams 1 (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 Administrator 1 (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 **Em ergency 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 $ 1,0 00 $7,000 **Special Requirements for Ignitable and Reactive Waste** Submit waiver application to local emergency management authority (one
time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $028 **Exhibit 4B: Respondent Burden and Cost Estimates f**  **or 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 LQG 1 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0 **BR Requirements** Gather information and p repare GM forms for waste generated but not transported off
site 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 p repare 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 form 1 (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 ,**  **0 00**  **$1 8**  **, 000**  **$ 2**  **, 111**  **, 000**  **TOTAL ANNUAL COSTS N/A**  **171, 794**  **$6,8 60**  **, 000**  **$70 7**  **, 000**  **$7,56 7**  **, 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 f**  **or 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 streams 1 (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 Administrator 1 (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 **Em ergency 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 $ 1,0 00 $7,000 **Special Requirements for Ignitable and Reactive Waste** Submit waiver application to local emergency management authority (one
time cost) 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $030 **Exhibit 4C: Respondent Burden and Cost Estimates f**  **or 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 LQG 1 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0 $0 $0 $0 **BR Requirements** Gather information and p repare GM forms for waste generated but not transported off
site 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 p repare 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 form 1 (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 $87** **3 ,**  **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**  **Saving s**  **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, 2 00 $0 $4, 2 00 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 $**  **5 43**  **, 000**  **$ 2**  **, 5**  **00 $**  **5 45**  **, 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 Ac** **tivity Total Hours and Cost**  **Saving s**  **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 $**  **1 ,**  **6 00**  **$ 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 even
numbered years) 1 , 2 0.00 0.00 0. 3 5 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. 3 5 0.00 $0.00 $0.00 319 112 $ 5 ,000 **Intra -**  **organizational Transfers** Review submitted notification (one
- time cost) 0.00 0.00 0. 3 5 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. 3 5 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 59 7 $ 24 ,000 Generate EPA ID number and send EP A 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 Es**  **timates 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 Em** **ergency 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 LQGs 1 0.50 $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 $3,94**  **4 ,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 annuall y), 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 CESQG s. Burden means the total time, effort, or financial resources expended b y 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 s ystems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any 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 sp onsor, 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 do cket, 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 Th is burden represents costs incurred by all entities. However, not all entities will be affected by the information collection requireme nts in this ICR (e.g., not all LQGs will experience a closure event). The ave rage 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 one time basis and 69.6 ho urs 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.