### SUPPORTING ST ATEMENT FOR INFORMATION COLLECTION REQUEST NUMBER 1935.04

"STANDARDIZED PERMIT FOR RCRA HAZARDOUS WASTE

MANAGEMENT FACILITIES"

January 2012

### Table of Contents

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

2. NEED FOR AND USE OF THE COLLECTION 2(a) Need and Authority for the Collection .......................................................... 6 2(b) Practical Utility and Users of the Data ........................................................ 12

3. NONDUPLICATION, CONSULTA TIONS, AND OTHER COLLECTION

CRITERIA 3(a) Nonduplication ............................................................................................ 15 3(b) Public Notice ............................................................................................... 15 3(c) Consultations ............................................................................................... 15 3(d) Effects of Less Frequent Collection ............................................................ 16 3(e) General Guidelines ...................................................................................... 16 3(f) Confidentiality ............................................................................................. 16 3(g) Sensitive Questions ..................................................................................... 16

4. THE RESPONDENTS AND TH E INFORMATION REQUESTED 4(a) Respondents a nd NAICS Codes .................................................................. 16 4(b) Information Requested ................................................................................ 17

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND IN FORMATION MANAGEMENT 5(a) Agency Activities ........................................................................................ 63 5(b) Collection Methodology and Management ................................................. 65 5(c) Small Entity Flexibility ............................................................................... 65 5(d) Collection Schedule ..................................................................................... 65

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6(a) Estimating Respondent Burden ................................................................... 67 6(b) Estimating Respondent Costs ...................................................................... 67 6(c) Estimating Agency Bu rden and Costs ......................................................... 68 6(d) Estimating the Respondent Universe and Total Burden and Cost .............. 70 6(e) Bottom Line Burden Hours and Costs ........................................................ 76 6(f) Reasons for Change in Burden .................................................................... 76 6(g) Burden Statement ........................................................................................ 771 1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

“Standardized Permit for RCRA Hazardous Wa ste Management Facilities (Renewal)”, ICR Number 1935.04, OMB Number 2050-0182.

1(b) Short Characterization

Under the authority of sections 3004, 3005, 3008 and 3010 of the Resource Conservation and Recovery Act (RCRA), as amended, the U.S. Environmental Protection Agency (EPA) is finalizing revisions to the RCRA hazardous wast e permitting program to allow a “standardized permit”. The standardized permit would be availabl e to facilities that ge nerate hazardous waste and routinely manage the waste on-site in non-thermal units su ch as tanks, containers, and containment buildings. In addition, the standardized permit is available to facilities that receive hazardous waste generated off-site by a generator under the same ownership as the receiving facility, and then store or non-thermally trea t the hazardous waste in containers, tanks, or containment buildings. The RCR A standardized permit would c onsist of two components: a uniform portion that is included in all cases, and a supplemental portion that the Director of a regulatory agency would include at his or her discretion. The uni form portion would consist of terms and conditions, relevant to the unit(s) at the permitted facility, and would be established on a national basis. The Director, at his or her discretion, may al so issue a supplemental portion on a case-by-case basis. The supplemental porti on would impose site-specific permit terms and

conditions that the Director determines necessa ry to institute correc tive action under section 264.101 (or State equivalent), or otherwise ne cessary to protect human health and the environment. Owners and operators would have to comply with the terms and conditions in the supplemental portion, in addition to those in the uniform portion.

This ICR presents a comprehensive desc ription of the information collection requirements for owners and operators submitting applications for a standardized permit or a standardized permit modification. This ICR also estimates the total annual burden and cost to respondents and government agencies.

APPLYING FOR A STAN DARDIZED PERMIT

Under 40 CFR 124.202, an owner or operator wish ing to apply for a standardized permit

must submit to the Director a written notice of hi s or her intent to opera te under the standardized permit. Along with this notice of intent, sec tion 270.275 requires that the applicant submits to the permitting agency information (e.g., summary of the pre-application public meeting, a signed certification of the facility’s compliance with pa rt 267) that will be used as the basis of the standardized permit application. Owners and ope rators whose facilities are not in compliance with part 267 at the time they submit their noti ce of intent must submit a schedule of compliance

to the Director. This schedule must include an enforceable sequence of actions with milestones,2 leading to compliance with the requirements for which the facility is in noncompliance at the time the notice of intent is submitted (section 270.285).

40 CFR 270.290 requires owners and operators operating under a standardized permit to keep general types of information at their faci lities. This information includes, among other things, a general description of the facility; a co py of the waste analysis plan and chemical and physical analyses of the hazardous waste and hazar dous debris handled at the facility; a copy of the general inspection schedule; a copy of the contingency pl an; a description of employee training programs; a copy of the closure plan ; and documentation showing compliance with liability requirements. The unit-specif ic record keeping requirements are:

• Owners and operators that store or treat hazardous waste in c ontainers must keep at their facility information on the design and operati on of the container storage area, including its containment system. In addition, they must keep information demonstrating compliance with special requirements for ignita ble or reactive waste and for incompatible wastes, as specified in section 267.174 and section 267.175, respectively. (section 270.300)

• Owners and operators that stor e or treat hazardous waste in tanks must keep at their facility tank system information. This in formation deals with design, construction, and operation parameters. (section 270.305)

• Owners and operators of facilities with equipment subject to part 264, subpart BB requirements (air emissions standards for equi pment leaks) must keep at their facility information required for that type of equipm ent. These information requirements concern emission standards for equipment that contains or comes in contact with hazardous waste with organic concentrations of at le ast 10 percent by weight. (section 270.310)

• Owners and operators of facilities with tanks or containers must keep at their facility information required for tanks and containe rs subject to part 264, subpart CC (air emission standards for tanks, surface impoundment s, and containers). These information requirements concern compliance with air em ission controls that apply to facilities managing hazardous waste in tanks and containers. (section 270.315)

Finally, section 270.10(h) requires owners a nd operators wishing to reapply for a standardized permit to submit a notice of intent under 270.10(b)(1) at least 180 days before the expiration date of the effective permit.

MAINTAINING A STA NDARDIZED PERMIT

Sections 124.211, 124.212, 124.213, and 124.214 specify procedures for making routine, routine with prior approval, a nd significant changes to the sta ndardized permit. Sections 124.212 requires owners and operators seeking to make routine changes (Class 1 permit modification not requiring prior approval under 40 CFR 270.42, Appendi x I) to their standardized permits to3 submit to the Director the revised information; and, in cases where the routine change amends information submitted under section 270.275, to provide notice of the changes to the facility mailing list and to state and local governments, in accordance with the procedures in sections 124.10(c)(1)(ix) and (x). Section 124.213 requires owners and operato rs seeking to make routine changes with prior approval to submit their reques ts to the Director for approval and follow the procedures in section 124.212(b )(1) - (2). Section 124.214 re quires owners and operators seeking to make significant cha nges to their standardized permits to provide notice and conduct a public meeting. After holding the public meeting, the owner or operator of the facility must submit a modification reque st to the Director.

GENERAL FACILITY STANDARDS

40 CFR part 267, subpart B (sections 267.10 th rough 267.18) specifies general facility standards that apply to owners and operators of facilities who treat or store hazardous waste under a standardized permit. To comply with th is subpart, owners and operators must obtain an EPA identification number (section 267.12) and follo w requirements for wa ste analyses (section 267.13); security (section 267.14); inspections (section 267.15); employee training (section 267.16); management of ignitable, reactive, or in compatible wastes (section 267.17); and facility location (section 267.18). EPA enab les owners and operators to apply for a waiver from the security requirements if they believe that phys ical contact with the waste, structures, or equipment within the active portion of the facility will not injure people or livestock, or that disturbing the waste or the equipment will not cause a violation of the requirements of part 267 (section 267.14(a)).

PREPAREDNESS AND PREVENTION

Under 40 CFR part 267, subpart C, owners and op erators of facilities that treat or store hazardous waste under a standardized permit must design, construct, maintain, and operate their facilities to minimize the possibi lity of a fire, explosion, or any unplanned sudden or non-sudden

release of hazardous waste or hazardous waste co nstituents to air, soil, or surface water that

could threaten human health or the environmen t. Specifically, secti on 267.36 states that the owners and operators of these faci lities must attempt to make arrangements with the police, fire departments, emergency response teams, and hosp itals, as appropriate fo r the type of waste handled at the facility and the pot ential need for services of these organizations. If State or local authorities decline to enter into such arrangemen ts, the owner or operator of the facility must document the refusal in the operating record.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

40 CFR part 267, subpart D (sections 267.50 through 267.58) requires owners and operators of a facility under a standardized permit to prep are and maintain updated contingency plans and comply with emergency reporting and r ecord keeping requirements. The contingency plan describes the actions facility personnel will take should a fire, expl osion, or any unplanned sudden or non-sudden release of hazardous waste constituents to air, soil, or surface water occur. Local emergency response teams use the information required in the contingency plan to4 minimize unanticipated damage from the treatment, storage, or di sposal of hazardous waste. The contingency plan also enables EPA to assess the effectiveness of facility responses to incidents that may threaten human health or the environment.

Other emergency reporting and record keeping requirements under 40 CFR part 267, subpart D, include notifying State and local aut horities of an imminent or actual emergency situation (267.56(a)(2), and notifying local aut horities of the need to evacuate local areas (267.56(c)(1)). If a release, fire , or explosion occurs, the owne r or operator must notify the onscene coordinator or the National Response Cent er (267.56(c)(2)). Owners and operators also must notify the Regional Administrator that a faci lity is in compliance with specific regulations before operations resume in any area affected by an emergency situation (267.58(a)), and submit a report to the Regional Administra tor containing details of any em ergency situation that requires implementation of the con tingency plan (267.58(b)).

RECORD KEEPING, REPORTING, AND NOTIFYING

40 CFR part 267, subpart E (sections 267.70 through 267.74) directs owners and operators of facilities th at treat or store hazardous waste under a standardized permit to keep written operating records at their facilities. Si nce the operating record is not submitted to EPA but must be available for inspection, maintaining an operating record is a r ecord keeping activity. The operating record contains in formation regarding general operat ing practices conducted at the facility. Other record keep ing requirements under 40 CFR part 267, subpart E, include maintaining records of the location of each haza rdous waste within the facility and the quantity at each location (267.71(b)(2)). In addition, 40 CF R 267.36(b) requires facilities to document in the operating record any refusal of State or loca l authorities to enter into arrangements for emergency situations. Information collected pur suant to these regulations is used by EPA and the owner or operator to assure safe operation of the facility.

Section 267.73 requires owners and operators to prepare a nd submit a single copy of a biennial report to the Regional Administrator by March 1 of each even numbered year. In addition to submitting the biennial reports, owne rs and operators must report to the Regional Administrator releases, fires, and explosions; facility closures; and as otherwise required by subparts I, J, and DD of 40 CFR part 267 and subparts BB and CC of 40 CFR part 264.

Section 267.76 requires that, before transfer ring ownership or operation of a facility during its operating life, an ow ner or operator must notify the new owner or operator in writing of the requirements of parts 267 and 270.

CLOSURE

40 CFR part 267, subpart G (sections 267.110 through 267.117) specifies the procedures that owners and operators of a facility that treat hazardous wa ste under a standardized permit must follow when closing storage and treatment un its and/or when closing the facility. Storage5 and treatment units must be closed in a manner that minimizes need for further maintenance and controls, minimizes, or eliminates, to the exte nt necessary to protec t human health and the environment, post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated runoff, or hazardous waste decomp osition products to the ground or surface waters or to the atmosphere (section 267.111 ). To close a facility, the ow ner or operator must have an approved closure plan and follow notificati on requirements (section 267.112). In addition, owners and operators are required to submit to the Director a cer tification of closure within 60 days of the completion of final closure of each unit under a standa rdized permit (section 267.117).

EPA uses closure plans to ensure that hazardous waste management facilities close in accordance with the Congressional mandate of pr otecting human health and the environment.

EPA reviews closure cer tifications to determine whether cl osure took place in accordance with the approved closure plan and EPA, local authoriti es, and potential purchasers of a closed facility

review closure notices to ensure that future uses of the site will not lead to a release of hazardous

waste.

FINANCIAL REQUIREMENTS

40 CFR part 267, subpart H (sections 267.140 through 267.150) establishes financial responsibility requirements for owners and opera tors who treat or store hazardous waste under a standardized permit. Owners and operators must prepare a closure cost estimate (section 267.142), demonstrate financial assurance fo r closure (section 267.143), and demonstrate financial assurance for liability (section 267.147). Owners and operators al so are required to

submit a notification of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the owner or operator as debtor (if the guarantor is named as the debtor, the collection of this data is the guarantor's respons ibility) (section 267.148). Finally, owners and operators are required to notify EPA when a State assumes legal responsibility or assures availabi lity of funds for an owner's or operator's compliance with the closure, post-closure care, or liability requirements of this part (section 267.150).

USE AND MANAGEMENT OF CONTAINERS

40 CFR part 267, subpart I (sections 267.170 th rough 267.177) specifies the standards for the use and management of containers under a st andardized permit. These standards apply to, for example, the condition of the containers, to the compatibility of waste with the containers, and to the management of the containers, and the control of air emissi ons from containers. Section 267.172 requires owners and operators that store or treat hazardous waste in containers to inspect areas where they store containers, at least weekly. During th ese inspections, owners and operators should look for leaking containers and for deterioration of containers and the containment system caused by co rrosion or other factors.

TANK SYSTEMS6 40 CFR part 267, subpart J (sections 267.190 th rough 267.204) specifies the standards for above-ground and on-ground tanks used for the tr eatment or storage of hazardous waste under a standardized permit. These st andards require record keeping and reporting associated with demonstrations for secondary containment waivers (section 267.190), design and construction standards (section 267.191), inst allation requirements (section 267.194), inspection requirements (section 267.199), leaks and spills (section 267.200), closure of tanks (section 267.201), special requirements for reactive, ignitable, and in compatible wastes (sections 267.202 and 267.203),

and control of air em issions (section 267.204).

CONTAINMENT BUILDINGS

40 CFR part 267, subpart DD (sections 267.1100 through 267.1108) specifies standards applicable to containment buildi ngs under a standardized permit. These standards require record keeping and reporting associated with inspec tions (section 267.1103); demonstrations for secondary containment requirement waiver s (section 267.1104); containment buildings containing areas both with and without seconda ry containment (section 267.1105); and detection of releases (section 267.1106).

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

This section describes the need and author ity for each type of information collection analyzed in this ICR. Information collecti on requirements for the standardized permit are authorized by sections 2002 and 3007 of RCRA, as amended. In particular, section 2002 gives the Administrator the authority to promulgate such regulations as are necessary to carry out the functions of this subchapter. Section 3007 gi ves EPA the authority to compel anyone who generates, stores, treats, transports, disposes of or otherwise handles or has handled hazardous

wastes to furnish information related to such wa stes and make such information available to the government for the purposes of enforcing the prov isions of this chapte r. EPA believes the information collection requirements are necessary to balance the reductio n in regulatory burden with the Agency’s responsibility to pr otect human health and the environment.

APPLYING FOR A STAN DARDIZED PERMIT

Section 270.275 requires that applicants fo r a standardized permit submit to the permitting agency information that will be used as the basis of the standardized permit application. This in formation includes:

• Part A permit information required by section 270.13;

• A summary of the pre-application public m eeting and other materials required by section 124.31;7 • Documentation of compliance with the lo cation standards of sections 267.18 and 270.14(b)(11);

• Information that allows the Director to carry out his obligations unde r other Federal laws required in section 270.3;

• Solid waste management unit inform ation required by s ection 270.14(d); and

• A signed certification of the facility’s complia nce with part 267, as specified at section

270.280.

• A report documenting the results of the co mpliance audit as required by section 270.280.

• A closure plan prepared in accord ance with part 267 subpart G.

• The most recent closure cost estimate fo r your facility prepared under §267.142 and a copy of the documentation required to dem onstrate financial assurance under §267.143. For a new facility, you may gather the require d documentation 60 days before the initial receipt of hazardous wastes.

• A waste analysis plan, if you mana ge wastes generated off-site

• Documentation showing that the same pe rson owns both the waste generator and receiving facility, if you manage wast e generated off-site

EPA needs this information to comprehensiv ely evaluate the potential risk posed by facilities seeking permits. This information aids EPA in meeting its goal of ascertaining and minimizing risks to human health and the e nvironment from hazardous waste management

facilities.

In addition, facilities that stor e or treat hazardous waste unde r a standardized permit must keep at their facilities genera l types of information (section 270.290), as well as unit-specific information for containers (section 270.300), tank s (section 270.305), equipment subject to part 264, subpart BB (section 270.310), and tanks and c ontainers subject to part 264, subpart CC (section 270.315). EPA anticipates that the owner or operator will use this information to ensure that tanks, containers, and othe r equipment are in good condition and that operating requirements are being satisfied, and to prevent placing in prox imity wastes that are incompatible with other wastes that are likely to ignite or explode. EPA needs this info rmation to evaluate compliance of facilities with the permitting standards. These re quirements contribute to EPA’s goal of insuring that hazardous waste management facilities are operated in a manner fu lly protective of human

health and the environment.

MAINTAINING A STA NDARDIZED PERMIT8 Sections 124.211, 124.212, 124.213, and 124.214 specify procedures for making routine and significant changes to the standardized permit. Section 124.212 requires owners and operators seeking to make routine changes (C lass 1 permit modification not requiring prior approval under 40 CFR 270.42, Appendix I) to their standardized permits to submit to the

Director the revised informati on; and, in cases where the routine change amends information submitted under section 270.275, to provide notice of the changes to the f acility mailing list and to state and local governments, in accordance wi th the procedures in sections 124.10(c)(1)(ix) and (x). Sections 124.213 requires owners and op erators seeking to make routine changes with prior approval to submit their re quests for changes to the Direct or for approval and follow the procedures in section 124.212( b)(1) - (2). Section 124.214 re quires owners and operators seeking to make significant cha nges to their standardized permits to provide notice and conduct a public meeting. After holding the public meeting, the owner or operator of the facility must submit a modification reque st to the Director.

EPA needs this information to comprehensivel y evaluate whether requests for routine or significant changes should be gr anted. The permit modification pr ocedures contribute to EPA’s goal of providing a role for the public in the perm itting process. In general, these informational requirements aid in meeting EPA’s goal of ascer taining and minimizing risks to human health and the environment from hazardous waste management facilities.

GENERAL FACILITY STANDARDS

40 CFR part 267, subpart B (sections 267.10 th rough 267.18) specifies general facility standards that apply to owners and operators of facilities who treat or store hazardous waste under a standardized permit. To comply with this subpart, owners and operators must follow record keeping and reporting requirements for wa ste analyses (section 26 7.13); security (section 267.14); inspections (section 267.15); employee training (section 267.16); management of ignitable, reactive, or inco mpatible wastes (section 267.17); and facility location (section 267.18).

(1) Waste Analyses

EPA and owners and operators use informati on obtained in waste analysis results to determine: (1) whether the facility can adequately handle the waste, and (2) whether the waste is really what the generator claims it to be. The owner or operator also uses information obtained from the waste analysis to determine whether th ere are any potential da ngers from handling the

waste.

(2) Security

EPA uses information on security to ensure th at the owner and operato r of the facility has taken the necessary measures to ensure that there is no physical contact with the waste, structures, or equipment within the active portion of the facility that would injure people or

livestock.9 (3) Inspections

EPA and owners and operators use informa tion in the inspection log to determine whether facility equipment is safe for handli ng hazardous waste. The inspection requirement contributes to EPA's goal of preventing hazardous waste constituents from being released into the environment due to faulty or deteriorated equipment.

(4) Employee Training

Both EPA and owners and operators use info rmation in employee training records to determine whether employees have acquired the n ecessary expertise to pe rform their jobs. EPA also reviews personnel records to determine whet her employees are receiving a level of training that is commensurate with their duties and respon sibilities as well as their ability to respond to any emergency situations at the facility. Requiring owners and operators to maintain personnel training documents decreases the likelihood that employees are unqualified to handle hazardous waste or respond to emergencies. The personne l record keeping requirement contributes to EPA's goal of minimizing the poten tial for employee-related mistakes that may threaten human

health and the environment.

(5) Demonstration of Compliance for Ignitable, Reactive, or Incompatible Wastes

EPA uses information in the documentation of compliance for ignitable, reactive, or incompatible wastes to determine whether facil ities are operating in a ma nner that is protective

of human health and the environment. The doc umentation requirement c ontributes to EPA's goal of minimizing unanticipated damage from the treatm ent, storage, or disposal of hazardous waste.

(6) Facility Location

EPA and owners and operators use site-spe cific information to determine whether a location is suitable for conducting hazardous waste management activities in a manner that does not pose a threat to human health or the environment..

EPA needs all the information described above to evaluate the compliance of facilities with the permitting standards. These requirements contribute to EPA’s goal of insuring that hazardous waste management facilities are operated in a manner fully protective of human health

and the environment.

PREPAREDNESS AND PREVENTION

Sections 267.30 through 267.36 require owners and operators to design, construct, maintain, and operate their facilities in a manner that minimizes threats to human health and the environment caused by the release of waste from a fire, explosion, or any unplanned event. Section 267.36(b) specifi cally requires owners an d operators to document any refusal on the part of any local authorities to enter into an arrangement to handle emergencies. EPA and the owner10 and operator of a facility use this information to ensure that adequate emergency response personnel are available, if needed, and to documen t that all necessary arra ngements with State or

local authorities have been made.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Section 3004(a)(5) of RCRA, as amended, re quires EPA to develop standards for contingency plans for effective action to minimize unanticipated damage from any treatment, storage, or disposal of any such hazardous waste. Sections 267.50 through 267.58 require all owners and operators of hazardous waste facilities to prepare a nd maintain contingency plans, and to notify State and local authorities and prepare and emergency reports whenever an imminent or actual emergency situation occu rs. EPA reviews the contingency plan and emergency reports to determine whether a facility has developed adequate procedures to respond to unplanned sudden or non-sudden releases of hazar dous waste or hazardous constituents to air, soil, or surface water. Notifications to State a nd local authorities facilit ate remedial actions and evacuations, if necessary. Requi ring facilities to develop and ma intain contingency plans and prepare emergency response reports and notificat ions contributes to EPA's goal of minimizing unanticipated damage from the treatment, st orage, or disposal of hazardous waste.

RECORD KEEPING, REPORTING, AND NOTIFYING

Section 267.70 through 267.74 direct owners or oper ators of facilities that treat or store hazardous waste under a standardized permit to keep an operating record at the facility. The operating record must include, among other thin gs, a description and the quantity of each hazardous waste received, and the method(s) and date(s ) of its treatment, storage, or disposal at the facility; records and results of waste analyses performed; su mmary reports and details of all incidents that require implementing the continge ncy plan; and records an d results of inspection reports. EPA uses information collected pursuan t to these regulations to select appropriate corrective action and cleanup measures should an unanticipated release of hazardous waste occur. EPA compliance officials refer to the operating record to determine the following: (1) what cleanup measures are appropriate and (2) whether operating requirements can be better tailored to the needs of a partic ular site. EPA anticipates that the owner or operator will use information included in the operating record to prevent receiving, or placing in proximity, wastes that are incompatible with other wastes that are li kely to ignite or explod e. Requiring facilities to develop and maintain an operating record and co nduct the record keeping activities contributes to EPA's goal of minimizing damage to the en vironment due to the treatment, storage, or disposal of hazardous waste.

CLOSURE

40 CFR part 267, subpart G (sections 267.110 through 267.117) requires owners and operators to develop closure pl ans, amend these plans when appropriate, and submit to EPA

closure certifications. EPA reviews informati on in the closure plans to determine whether closure activities will comply with the regulator y requirements. EPA uses information in the11 closure certifications to determine that closur e took place in accordance with the approved closure plan.

FINANCIAL REQUIREMENTS

Section 3004(a)(6) of the Re source Conservation and Rec overy Act of 1976 (RCRA), as amended, requires EPA to promulgate regulations that include requirements respecting "the maintenance of operations of such facilities and requiring such additional qu alifications as to ... financial responsibility (including financial re sponsibility for correctiv e action) as may be necessary or desirable."

The need for financial assurance of closure ca re is indicated by th e numerous instances of environmental damage resulting from abandonment of hazardous waste management facilities and other failures by owners and operators to provide adequately for closure care. The

likelihood of such failure is increa sed by the fact that the costs fo r closure care are expected to

commence when the economic value of the facility is either at a minimum or nonexistent.

EPA believes that significant numbers of owners and operators would lack the ability to provide for closure care without effective requirements for financ ial assurance. Consequently, the Agency developed 40 CFR part 267, subpart H financial responsibility requirements for

closure care.

The liability requirements are designed to a ssure that funds will be available during the operating life of a facility from which third par ties can seek compensation for bodily injury and property damage arising from the operation of the facility. The liability requirements are necessary for several reasons. Fi rst, the requirements provide pr otection to human health and the environment by assuring that funds are available to owners and operators to compensate for damage caused by accidents at hazardous waste f acilities, including paymen ts for bodily injury and property damage. In addition, the Agency believes that without liability coverage requirements, there would be less public conf idence in and greater opposition to proposed and existing hazardous waste faciliti es. The liability requirements also result in other potential

benefits for human health and the environment: the incentive, in the form of lower insurance premiums, to improve design and operation of the f acility, and the oversight that insurers provide over facility operations.

USE AND MANAGEMENT OF CONTAINERS

Sections 267.172 and 267.15(d) require owners a nd operators that store or treat hazardous waste in containers to inspect areas where they store containers, at least weekly, and record the inspection results. EPA needs this information to evaluate the compliance of facilities with the permitting standards and ensure that containers used for the storage and treatment of hazardous waste, under the standardized permit, do not pose a threat to human health and the environment. These requirements contribute to EPA’s goal of safe management of hazardous waste.

TANK SYSTEMS12 40 CFR part 267, subpart J specifies reco rd keeping and reporting requirements associated with demonstrations for secondary containment waivers (section 267.190), design and construction standards (secti on 267.191), installation requirem ents (section 267.194), inspection requirements (section 267.199), and leaks and spills (section 267.200). EPA needs this information to evaluate the compliance of facilities with the permitting standards and ensure that tank systems used for the storage and treatmen t of hazardous waste, under the standardized permit, do not pose a threat to human health and the environment. These requirements contribute to EPA’s goal of safe management of hazardous waste.

CONTAINMENT BUILDINGS

40 CFR part 267, subpart DD specifies reco rd keeping and reporting requirements associated with inspections (section 267.1103); demonstrations for secondary containment requirement waivers (section 267.1104); containmen t buildings containing areas both with and without secondary containment (section 267.1105); and detection of releases (section 267.1106). EPA needs this information to evaluate the compliance of facilities with the permitting standards and ensure that containment buildings used for the storage and treatmen t of hazardous waste, under the standardized permit, do not pose a threat to human health and the environment. These requirements contribute to EPA’s goal of safe management of hazardous waste.

2(b) Practical Utility and Users of the Data

APPLYING FOR A STAN DARDIZED PERMIT

EPA uses information submitted by facilities to evaluate exposure potential and minimize any risks to human health from hazardous waste management facilitie s. If EPA determines that a facility poses a substantial risk to human hea lth, EPA may request that the Agency for Toxic Substances and Disease Registry conduct a health assessment.

EPA uses information regarding specific units at facilities to evaluate the adequacy of each unit to manage hazardous wastes. Additional information is required because each of the different types of hazardous waste management un its present different risks to the environment and consequently requires different standards. EPA reviews the submittals of each type of hazardous waste management unit to evaluate wh ether it is designed, c onstructed, and operated in a manner protective of human health and the e nvironment. EPA uses the information required by part 264, subparts BB and CC to ensure compliance with air emission standards.

MAINTAINING A STA NDARDIZED PERMIT

EPA uses permit information to evaluate the initial permit application and any subsequent request for modification. The public may also use draft EPA permit and permit modification determinations, which incorporate data submitted by facilities, to assess hazardous waste management facilities being developed in their communities.13 GENERAL FACILITY STANDARDS

EPA uses the information requirements in 40 CFR parts 267 and 270 for owners and operators submitting standardized permit applica tions to evaluate compliance with various elements of the regulations. The waste analysis and waste analysis plan, as well as the inspection schedule and documentation of comp liance for ignitable or incompatible wastes, are primarily internal record keeping requirements used by owne rs and operators of facilities to assure that they can adequately handle the waste, to assu re that the incoming waste is really what the generator claims it to be, and to prevent undetect ed releases or reactions of hazardous waste onsite. Much of the information in the waste analys is plan will also be used to provide a quality assurance check on both the genera tor and the owners' and operators ' facilities. Both EPA and owners and operators use information in the empl oyee training records to ensure that employees acquire the necessary expertise to perform thei r jobs. During inspections, EPA reviews job descriptions and training documents to determin e whether each person is receiving a level of training that is commensurate with the person's du ties and responsibilities as well as the ability to respond to any emergency situations at the facility.

PREPAREDNESS AND PREVENTION

The facility owner or operator uses the documented refusal on the part of the State or local authorities to enter in emergency response arrangements to demonstrate that he or she has undertaken all the necessary activ ities to minimize threats to hu man health and the environment caused by the release of waste from a fi re, explosion, or any unplanned event.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Local emergency response teams, facility ow ners or operators, and EPA use information included in the contingency plan to assure an appropriate response to any unplanned release of

hazardous waste or hazardous waste constituents. EPA reviews information in the contingency plan and emergency report to determine whethe r additional site-specific emergency provisions

are necessary.

RECORD KEEPING, REPORTING, AND NOTIFYING

The facility owner or operat or uses information included in the operating record and waste disposal location and quantity records to prevent the facility from placing in proximity wastes that are incompatible or that are likely to ig nite or explode. If an unanticipated release of hazardous waste occurs, the owner or operator may review information in the operating record to determine the composition of the waste. Revi ewing information in the operating record facilitates the owner's or opera tor's selection of an appropria te corrective action and cleanup measure. By providing facility-specific data, the operating record also enables EPA compliance officials to determine whether operating require ments can be better tailored to the needs of a particular site.

CLOSURE14 EPA uses information contained in closure plans to determine whether an owner or operator's planned closure activities will comply with environmental regulations. EPA officials

use information contained in clos ure certifications to ensure that the owner or operator closed his/her facility according to the specifications out lined in the approved closure plan. EPA uses

information contained in demonstrations to en sure that any activitie s taking place during the closure period are protective of human health and the environment.

FINANCIAL REQUIREMENTS

EPA uses the financial insurance informati on requirements to evaluate the facility owner’s financial ability to clos e the facility and to respond to any contingencies. The closure and liability coverage financial instruments su bmitted by the owner or operator are reviewed by EPA to determine compliance with the applicable subpart H regulations. This review involves determinations of the validity of the instrument , acceptability of the fina ncial assurance provider, adequacy of the instrument amount, and fulfillment of the other regulatory requirements. The

information is also used to direct funds for clos ure and liability coverage in the event of default or bankruptcy of a facility owner or operator.

USE AND MANAGEMENT OF CONTAINERS

EPA uses information on containers obtained du ring facility inspections to evaluate the adequacy of each container to manage hazardous wastes, and ensure that containers are being used in a manner protective of human health and the environment.

TANK SYSTEMS

EPA uses information on tank systems obtained dur ing facility inspections to evaluate the adequacy of each tank to manage hazardous wastes , and ensure that tank systems are being used in a manner protective of human h ealth and the environment.

CONTAINMENT BUILDINGS

EPA uses information on containment buildings obtained during facility inspections to evaluate the adequacy of each c ontainment building to manage hazardous wastes, and ensure that containment buildings are being used in a manner protective of human health and the

environment.

3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

In finalizing the standard ized permit rule, EPA streamlined the permit process by allowing certain types of facili ties to obtain and modify permits more easily while maintaining15 the protectiveness currently existing in the indi vidual RCRA permit process. Thus, facility owners and operators are relieved of certain RCRA record keeping and reporting requirements that currently exist under the RCRA permitting process.

3(b) Public Notice

In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on August 9, 2011 (76 FR 48857) and provided a 60 day comment period

for this ICR. No comments were received.

3(c) Consultations

With only 5 states authorized for the standard ized permit rule, we found only one facility that had been issued a standardized permit. A consultation was conducted w ith that one facility, BP Exploration in Alaska which received a st andardized permit from EPA Region 10. A call was conducted on December 1, 2011 with Ms. Coll een Burg of BP. When asked about the reporting and recordkeeping burden estimates as presented in the supporting statement, she commented that the “annual reporting burden” estimates of 53 to 57 hours were low. Her experience with BP’s permit indica ted burden hours of at least twice those estimates. Ms. Burg

said the burden was more on the order of 80 to 100 hours. The increased burden was in three areas: the community meetings, the 3 rd party facility audit, and pr eparing the closure plan. She commented that the “record keeping burden” range of 31 to 178 hours was within reason.

3(d) Effects of Less Frequent Collection

The standardized permit applica tion procedures are less cumbersome than the procedures for an individual permit. Owners and operators do not have to submit the amount of information needed to support an individual pe rmit application, although they need to keep the information at their facility. In addition, the procedures for modifying standardized permits would allow owners and operators to make certain types of routine changes without prior approval, provided that they inform both the regulatory agency a nd the public of the changes. EPA believes the collection frequencies specified in this ICR are ne cessary to ensure protection of human health

and the environment.

3(e) General Guidelines

This ICR adheres to the guidelines stat ed in the Paperwork Reduction Act of 1995, OMB's implementing regulations, EPA's Info rmation Collection Review Handbook, and other applicable OMB guidance.

3(f) Confidentiality

Section 3007(b) of RCRA and 40 CFR part 2, subpart B, which define EPA's general policy on public disclosure of information, cont ain provisions for confidentiality. EPA does not anticipate requesting any confidential information.16 3(g) Sensitive Questions

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

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The following is a list of North American Industrial Classifica tion System (NAICS) codes associated with industries most likely aff ected by the information collection requirements

covered under this ICR.

323110 Commercial Lithographic Printing 323114 Quick Printing 325131 Inorganic Dye and Pigment Manufacturing 325188 All Other Basic Inorganic Chemical Manufacturing

325998 All Other Miscellaneous Chem ical Product Manufacturing 331311 Alumina refining 325211 Plastics Material and Resins Manufacturing 32551 Paint and Coating Manufacturing 32511 Petrochemical Manufacturing 32512 Industrial Gas Manufacturing 325188 All Other Inorganic Chemical Manufacturing 325193 Ethyl Alcohol Manufacturing 325199 All Other Basic Organi c Chemical Manufacturing

325998 All Other Miscellaneous Chem ical Product Manufacturing 311942 Spice and Extract Manufacturing

32411 Petroleum Refineries 332813 Electroplating, Plating, Polis hing, Anodizing and Coloring 33271 Machine Shops

332991 All Other Miscellaneous Fabric ated Metal Product Manufacturing

333319 Other Commercial or Service I ndustry Machinery Manufacturing

Accessories 333999 All Other General Purpose Machinery Manufacturing 336399 All Other Motor Vehicle Part Manufacturing 334 Computer and Electr onic Product Manufacturing 336 Transportation Equipment Manufacturing 48422 Specialized Freight (excep t Used Goods) Trucking, Local

56211 Waste Collection

22111 Electric Power Generation

22112 Fossil Fuel Electric Power Generation 22132 Sewage Treatment Facilities 56292 Materials Recovery Facilities17 56221 Waste Treatment and Disposal

42271 Petroleum Bulk Stations and Terminals

45431 Fuel Dealers

4411 Automobile Dealers

4471 Gasoline Stations 811111 General Automotive Repair

4(b) Information Requested

This section describes information collection requ irements applicable to facilities that are affected by this ICR.

APPLYING FOR A STAN DARDIZED PERMIT

(1) General Information Requirements

(i) Data items

Sections 124.202, 270.275, 270.280, and 270.285 require owners and operators wishing to obtain a standardized permit to provide the following data items:

• A written notice to the Director that the ow ner or operator intends to operate under a standardized permit;

• The Part A information required by section 270.13 (this information is described and

burdened under the Part A Permit Application ICR);

• A meeting summary and other mate rials required by section 124.31;

• Documentation of compliance with the lo cation standards of sections 267.18 and 270.14(b)(11), including:

-- An identification of the political jurisdic tion in which the facility is proposed to be located;

-- If the facility is proposed to be locate d in an area listed in Appendix VI of part 264, a demonstration of compliance with the seismic standard as defined under section 264.18(a). This demonstration may be made using either published geologic data or data obtained from fi eld investigations carried out by the applicant;

-- An identification of whether the facility is located within a 100-year floodplain18 • Information that allows the Director to carry out his obligations unde r other Federal laws required in section 270.3;

• Solid waste management unit informati on required by section 270.14(d), including:

-- The location of each unit on the topographic map required under section 270.14(b)(19);

-- Designation of the type of each unit;

-- General dimensions and struct ural description of each unit;

-- Dates when each unit was operated;

-- Specification of all wastes that have been managed at each unit, to the extent available;

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

hazardous constituents from each unit (section 270.14(d)(2));

-- Results of sampling and analysis, wh ere the Director as certains that a RCRA Facility Assessment is necessary.

• A signed certification of the facility’s complia nce with part 267, as specified at section 270.280; and

• A closure plan prepared in accord ance with part 267 subpart G.

• The most recent closure cost estimate fo r your facility prepared under §267.142 and a copy of the documentation required to dem onstrate financial assurance under §267.143. For a new facility, you may gather the require d documentation 60 days before the initial receipt of hazardous wastes.

• Results of a compliance audit, as required by section 270.280.

• A waste analysis plan, if you ma nage waste generated off-site.

• Documentation showing that the same pers on owns both the waste generator and the receiving facility, if you manage waste generated off-site.

(ii) Respondent activities

In order to obtain a standardized permit, ow ners and operators will have to perform the following activities:19 • Read the regulations;

• Prepare a written notice of intent to operate under a standardized permit;

• Obtain the Part A information;

• Obtain the meeting summary and other materials required by section 124.31;

• Develop documentation of complia nce with location standards;

• Prepare information that allows the Director to carry out his ob ligations under other Federal laws;

• Prepare the solid waste mana gement unit information;

• Prepare and sign the certification of compliance with part 267;

• If necessary, prepare a schedule of compliance with part 267;

• Prepare a closure plan;

• Prepare a closure cost estimate.

• Prepare documentation to demonstrate financial assurance under §267.143; and,

• Conduct a compliance audit and prepare a report of the results of the audit.

• If you manage waste generated off-s ite, prepare a waste analysis plan.

• If you manage waste generated off-site, pr epare documentation showing that the same person owns both the waste generato r and the receiving facility.

• Submit the above information to the Director.

(2) Record Keeping Requirements

(i) Data items

Section 270.290 requires owners and operators ap plying for a standardi zed permit to keep the following information at their facilities:

• A general description of the facility;20 • Chemical and physical analyses of the hazar dous waste and hazardous debris handled at the facility. At a minimum, these analyses must contain all the in formation required to treat or store the wastes properly under the requireme nts of part 267;

• A copy of the waste analysis pl an required by section 267.13(b);

• A description of the security procedures and equipment required by section 267.14, or a justification demonstrating the reasons for a waiver from these requirements;

• A copy of the general inspection schedule re quired by section 267.15(b), as well as the applicable inspection schedule re quirements of sections 267.174, 267.193, 267.195, 267.1033, 267.1052, 267.1053, 267.1058, and 267.1088;

• A justification for any modification of the preparedness and preven tion requirements of part 267, subpart C;

• A copy of the contingency plan re quired by part 267, subpart D;

• A description of the procedures, structures , or equipment used at the facility to:

-- Prevent hazards in unloading operations;

-- Prevent runoff from hazardous waste handli ng areas to other areas of the facility or environment, or to prevent flooding;

-- Prevent contamination of water supplies;

-- Mitigate effects of equipment failure and power outages;

-- Prevent undue exposure of pe rsonnel to hazardous waste; and

-- Prevent releases to the atmosphere;

• A description of precautions to prevent accid ental ignition or reaction of ignitable, reactive, or incompatible wast es as required by section 267.17;

• A description of traffic patte rns, estimated volumes, and co ntrols near the facility;

• An outline of both the introductory and continuing programs you will use to prepare employees to operate or maintain the fac ility safely, as requ ired by section 267.16;

• A brief description of how training will be designed to meet actual job tasks under section 267.16(a)(3) requirements;21 • A copy of the closure plan required by secti on 267.112. Specific requirements in sections 267.178, 267.197, and 267.1102 should be included, where applicable, as part of the plans;

• The most recent closure cost estimate for the facility prepared under section 267.142, and a copy of the documentation required to dem onstrate financial assurance under section 267.143. For new facilities, this documentation must be gathered at least 60 days prior to the initial receipt of hazardous wastes;

• Where applicable, a copy of the insurance policy or other docume ntation that complies with the liability requirem ents of section 267.147. For a new facility, documentation showing the amount of insurance meeting the specification of sec tion 267.147(a) that the owner or operator plans to have in effect before initial receipt of hazardous waste for

treatment or storage;

• Where appropriate, proof of coverage by a State financial mechanism, as required by section 267.149 or section 267.150; and

• A topographic map that meets the require ments specified at section 270.290(s).

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will have to perform the following activities:

• Read the regulations;

• Prepare and maintain a general description of the facility;

• Maintain documentation of chemical and phys ical analyses of the hazardous waste and hazardous debris handled at the facility (t his activity is covered under section 267.13(a));

• Maintain a copy of the waste analys is plan required by section 267.13(b);

• Prepare and maintain a description of the s ecurity procedures and equipment required by section 267.14, or a justification demonstra ting the reasons for a waiver from these requirements;

• Maintain a copy of the app licable inspection schedules;

• Prepare and maintain a justification for any modification of the preparedness and prevention requirements of part 267, subpart C;

• Maintain a copy of the contingency plan;22 • Prepare and maintain a description of the proc edures, structures, or equipment used at the facility to:

-- Prevent hazards in unloading operations;

-- Prevent runoff from hazardous waste handli ng areas to other areas of the facility or environment, or to prevent flooding;

-- Prevent contamination of water supplies;

-- Mitigate effects of equipment failure and power outages;

-- Prevent undue exposure of pe rsonnel to hazardous waste; and

-- Prevent releases to the atmosphere;

• Maintain a description of precautions to pr event accidental ignition or reaction of ignitable, reactive, or incompatible wastes;

• Prepare and maintain a description of traffi c patterns, estimated volumes, and controls near the facility;

• Maintain an outline of both the introducto ry and continuing programs you will use to prepare employees to operate or maintain the facility safely, as required by section
267.16;

• Maintain a brief description of how training will be designed to meet actual job tasks;

• Maintain a copy of the closure plan;

• Maintain records of most recent closure co st estimate and a copy of the documentation required to demonstrate financial assurance;

• Where applicable, maintain a copy of the in surance policy or other documentation that complies with the liability requirements of section 267.147;

• Where appropriate, maintain proof of cove rage by a State financial mechanism; and

• Obtain and maintain a topographic map.

(3) Container Information Requirements

(i) Data items23 In addition to the general information re quirements listed at section 270.290, section 270.300 requires owners and operato rs of facilities with contai ners to keep the following

information at their facilities:

• A description of the containment system to demonstrate compliance with section 267.173;

• For storage areas that store c ontainers holding wastes that do not contain free liquids, a demonstration of compliance with section 267.173. This description must show the following:

-- Basic design parameters, dimensi ons, and materials of construction;

-- How the design promotes drainage or how containers are kept from contact with standing liquids in th e containment system;

-- The capacity of the containment syst em relative to the number and volume of containers to be stored;

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

-- How accumulated liquids can be analy zed and removed to prevent overflow;

• For storage areas that store c ontainers holding wastes that do not contain free liquids, a demonstration of compliance with section 267.173(c) , including:

-- Test procedures and results of other documentation or information to show that the wastes do not contain free liquids; and

-- A description of how the storage area is designed or operated to drain and remove liquids or how containers are kept from contact with standing liquids;

• Sketches, drawings, or data demonstrating compliance with secti on 267.174 (location of

buffer zone and containers holding ignitable or reactive wastes) and section 267.175(c) (location of incompatible wastes), where applicable;

• Where incompatible wastes are stored or ot herwise managed in containers, a description of the procedures used to ensure complia nce with sections 267.175(a) and (b); and

• Information on air emission control e quipment, as required by section 270.315.

(ii) Respondent activities24 In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Prepare and maintain a descrip tion of the containment system;

• For storage areas that store containers holding wastes that do not contain free liquids, prepare and maintain a demonstration of compliance with section 267.173(c);

• Where applicable, obtain and maintain sk etches, drawings, or data demonstrating compliance with sections 267.174 and 267.175(c);

• Where incompatible wastes are stored or ot herwise managed in containers, prepare and maintain a description of the procedures used to ensure compliance with sections 267.175(a) and(b); and

• Maintain information on air emission control equipment;

(4) Tank Information Requirements

(i) Data items

In addition to the general information re quirements listed at section 270.290, section 270.305 requires owners and operators of facilities with tanks to keep the following information

at their facilities:

• A written assessment that is reviewed and certified by an independent, qualified, registered professional engineer on the struct ural integrity and suitability for handling hazardous waste of each tank system, as required under sections 267.191 and 267.192;

• The dimensions and capacity of each tank;

• A description of feed systems, safety cu toff, bypass systems, and pressure controls;

• A diagram of piping, instrumentation, and a process flow for each tank system;

• A description of materials and equipment us ed to provide extern al corrosion protection, as required under section 267.192;

• For new tank systems, a detailed description of how the tank system(s) will be installed in compliance with section 267.194;25 • Detailed plans and a description of how th e secondary containment system for each tank system is or will be designed, constructed, and operated to meet the requirements of sections 267.195 and 267.196;

• A description of controls and practices to pr event spills and overflow s, as required under section 267.198;

• For tank systems in which ignitable, reactive, or incompatible wastes are to be stored or treated, a description of how operating procedures and ta nk system and facility design will achieve compliance with the requir ements of sections 267.202 and 267.203; and

• Information on air emission control e quipment as required by section 270.315.

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Maintain an engineer’s written assessment on the structural integrity and suitability for handling hazardous waste of each tank system;

• Document and maintain the dimensions and capacity of each tank;

• Prepare and maintain a description of feed systems, safety cutoff, bypass systems, and pressure controls;

• Prepare and maintain a diagram of piping, in strumentation, and a process flow for each tank system;

• Maintain a description of materials and e quipment used to provide external corrosion protection;

• For new tank systems, prepare and maintain a detailed description of how the tank system(s) will be installed in compliance with section 267.194;

• Prepare and maintain detailed plans and a de scription of how the secondary containment system for each tank system is or will be designed, constructed, and operated to meet the requirements of sections 267.195 and 267.196;

• Prepare and maintain a description of cont rols and practices to prevent spills and overflows;26 • For tank systems in which ignitable, reactive, or incompatible wastes are to be stored or treated, prepare and maintain a description of how operating proce dures and tank system and facility design will achieve complianc e with the requirements of sections 267.202 and 267.203; and

• Maintain information on air emission control equipment.

(5) Equipment Information Requirements

(i) Data items

In addition to the general information re quirements listed at section 270.290, section 270.310 requires owners and operators of facilities with equipment to which subpart BB of part 264 applies to keep the following in formation at their facilities:

• For each piece of equipment to whic h subpart BB of part 264 applies:

-- Equipment identification number and hazardous waste management unit identification;

-- Approximate locations within the facility;

-- Type of equipment;

-- Percent by weight of total organics in the hazardous waste stream at the equipment;

-- Hazardous waste state at the equi pment (e.g., gas/vapor or liquid); and

-- Method of complian ce with the standard;

• For facilities that cannot insta ll a closed-vent system and cont rol device to comply with 40 CFR part 264 subpart BB on the effective date th at the facility becomes subject to the subpart BB provisions, an implementation schedule as specified in se ction 264.1033(a)(2);

• For owners and operators who apply for permi ssion to use a control device other than a thermal vapor incinerator, catalytic vapor incinera tor, flare, boiler, process heater, condenser, or carbon adsorption system and choose to use test data to determine the organic removal efficiency or the total organic compound con centration achieved by the control device, a performance test plan as speci fied in section 264.1035(b)(3);

• Documentation that demonstrates compliance with the equipment standards in sections 264.1052 and 254.1059; and27 • Documentation to demonstrate compliance w ith section 264.1060. This documentation must include the following information:

-- A list of all information references and sources used in preparing the documentation;

-- Records, including the dates, of each compliance test required by section 264.1033(j);

-- A design analysis, specifications, drawings, schematics, and piping and instrumentation diagrams. The design an alysis must address the vent stream characteristics and control device operat ion parameters as specified in section 260.1035(b)(4)(iii);

-- A statement, signed and dated by the owner or operator, certifying that the operating parameters used in the desi gn analysis reasonably represent the

conditions that exist when the hazardous waste management unit is operating at the highest load or capacity level reasonably expected to occur; and

-- A statement, signed and dated by the owne r or operator, certifying that the control device is designed to operate at an effi ciency of 95 weight percent or higher.

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• For each piece of equipment to which subpart BB of section 264 applies:

-- Maintain the equipment identificatio n number and hazardous waste management unit identification;

-- Prepare and maintain approximate locations within the facility;

-- Prepare and maintain a descri ption of the type of equipment;

-- Prepare and maintain a description of th e percent by weight of total organics in the hazardous waste stream at the equipment;

-- Prepare and maintain a description of the hazardous waste state at the equipment (e.g., gas/vapor or liquid); and28 -- Prepare and maintain a description of the method of compliance with the standard;

• For facilities that cannot insta ll a closed-vent system and cont rol device to comply with 40 CFR part 264 subpart BB on the effective date that the facility becomes subject to the subpart BB provisions, prepare and ma intain an implementation schedule;

• For owners and operators who apply for permi ssion to use a control device other than a thermal vapor incinerator, catalytic vapor in cinerator, flare, boiler, process heater, condenser, or carbon adsorption system and choo se to use test data to determine the organic removal efficiency or the total organic compound concentration achieved by the control device, develop and maintain a performance test plan as specified;

• Develop and maintain documentation that de monstrates compliance with the equipment

standards in secti ons 264.1052 and 254.1059; and

• Develop and maintain documentation to de monstrate compliance with section 264.1060.

(6) Air Emissions Control Requirements

(i) Data items

In addition to the general information re quirements listed at section 270.290, section 270.315 requires owners and operators of facilities with equipment subject to subpart CC of part 264 to keep the following info rmation at their facilities:

• Documentation for each floating roof cover installed on a tank subject to sections 264.1084(d)(1) or (d)(2) that includes informati on prepared by the owner or operator or provided by the manufacturer de scribing the cover design;

• A certification that the cover meets applicable design specifications listed in sections 264.1084(e)(1) or (f)(1);

• Identification of each containe r area subject to the requireme nts of part 264, subpart CC, and a certification that the require ments of this subpart are met;

• Documentation for each enclosure used to cont rol air pollutant emissions from tanks or containers under requirements of sec tions 264.1084(d)(5) or 264.1086(e)(1)(ii). This

documentation must include records for the most recent set of calculations and measurements performed to verify that the enclosure meets the criteria of a permanent enclosure as specified in section 52.741, appendix B;29 • Documentation for each closed-vent syst em and control device installed under requirements of section 264.1087 that includes design and performance information as specified in section 270.24(c) and (d); and

• An emission monitoring plan for both Met hod 21 in 40 CFR part 60, appendix A, and control device monitoring methods. This plan must include monitoring points, monitoring methods for control devices, monitoring frequency, procedures for documenting exceedences, and procedures for mitigating noncompliances.

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Prepare and maintain documentation for each floating roof cover installed on a tank subject to sections 264.1084(d)(1) or (d)(2);

• Prepare and maintain a certification that the cover meets applicable design specifications

listed in sections 264.10 84(e)(1) or (f)(1);

• Prepare and maintain an identification of each container area subjec t to the requirements of part 264, subpart CC, and a certification that the requirements of this subpart are met;

• Prepare and maintain documentation for each enclosure used to control air pollutant

emissions from tanks or containers under requirements of sections 264.1084(d)(5) or 264.1086(e)(1)(ii);

• Prepare and maintain documentation for each closed-vent system and control device installed under requiremen ts of section 264.1087; and

• Develop and maintain an emission monitori ng plan for both Method 21 in 40 CFR part 60, appendix A, and control device monitoring methods.

(7) Switching from an Individual RCR A Permit to a Standardized Permit

(i) Data items

Section 124.203 allows owners and operators to switch their individual RCRA permits to standardized permits by submitting a request to the Director requesting that their individual permits be revoked and reissued as a standa rdized permit, in accordance with section 124.5.

(ii) Respondent activities30 In order to provide the data item listed a bove, owners and operators seeking to switch from a RCRA individual permit to a standardi zed permit will need to perform the following

activities:

• Read the regulations; and

• Prepare and submit the request to the Director.

(8) Reapplying for a Standardized Permit

(i) Data items

Section 270.10(h) requires owne rs and operators wishing to reapply for a standardized permit to submit a notice of inte nt under 270.10(b)(1) at least 180 days before the expiration date of the effective permit.

(ii) Respondent activities

Owners and operators reapplying for a standardized permit will need to perform the following activities:

• Read the regulations;

• Prepare and submit th e notice of intent.

MAINTAINING A STA NDARDIZED PERMIT

(1) Making Routine Changes

(i) Data items

Sections 124.212 and 270.320 require owners an d operators seeking to make routine changes (class 1 modifications under 40 CFR 270.42 Appendix I that do not require prior approval from the Director) to their standardized permits to provide the following data items:

• The revised information pursuan t to section 270.2 67(b)(1); and

• A notice of changes to the facility mailing list and to state and local governments in accordance with the procedures in sections 124.10(c)(1)(ix) and (x).

(ii) Respondent activities31 In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Prepare and submit the revised in formation to the Director; and

• Submit the revised information to the f acility mailing list and local governments.

(2) Making Routine Changes Requiring Prior Approval from the Director (124.212, 270.320(b))

(i) Data items

Section 124.213 and 270.320 require owners and operators seeking to make routine changes to their standardized permits to provide the following data items:

• The revised information pursuant to s ection 270.267(b)(1) requesting approval; and

• A notice of changes to the facility mailing list and to state and local governments in accordance with the procedures in sections 124.10(c)(1)(ix) and (x).

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Prepare and submit the revised informati on to the Director requesting approval

• After approval, submit the revised information to the facility mailing list and local

governments.

(3) Making Significant Changes (124.214, 270.320)

(i) Data items

Sections 124.214 and 270.320 require owners and operators seeking to make significant changes (based on the criteria specified in section 270.320(b)(1)-(3)) to their standardized permits to provide the following data items:32 • A public meeting (with prior notice);

• A modification request to the Director that:

-- Describes the exact change(s) desi red, and whether they are changes to information provided under section 270.275 or to terms and conditions in the supplemental portion of the standardized permit;

-- Explains why the modification is needed; and

-- Includes a summary of the public meeti ng described above, along with the list of attendees and their addresses and copies of any written comments or materials submitted at the meeting.

(ii) Respondent activities

In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Read the regulations;

• Provide notice of and hold a public meeting; and

• Prepare and submit the modification request to the Director (after holding the public meeting).

GENERAL FACILITY STANDARDS

(1) Obtaining an Identification Number

(i) Data items

Section 267.12 requires owners a nd operators of facilities to obtain an EPA identification

number.

(ii) Respondent activities

In order to obtain an EPA identification number, owners and operators will need to perform the following activities:

• Read the regulations; and

• Obtain, fill out, and submit an applica tion for an EPA identification number.33 (2) Waste Analysis

(i) Data items

Section 267.13(a) requires an owner or opera tor to obtain a detailed chemical and physical analysis of any hazardous waste he or she intends to treat or store. The analysis may include data, either existing or published, deve loped under 40 CFR part 261, as well as existing

data on the hazardous waste or hazardous wa ste generated from similar processes.

(ii) Respondent activities

In order to comply with section 267. 13, respondents must perform the following

activities:

• Read the regulations;

• Collect data; and

• Perform waste analysis (sampling, testing).

(3) Waste Analysis Plan

(i) Data items

Section 267.13(b) states that an owner or ope rator of a hazardous waste facility must develop and follow a written waste analysis plan that describes the procedures to be used in obtaining a detailed chemical a nd physical analysis of the waste. The owner or operator is required to keep the waste analysis plan at the f acility. If you receiv e wastes generated from off-site, and are eligible for a standardized permit, you also must have submitted the waste analysis plan with the Notice of Intent. At a minimum, the plan must include the following

information:

• Parameters for which each hazardous waste will be analyzed and the rationale for the selection of these parameters;

• Test methods used to test for the parameters;

• Sampling method used to obtain a representative sample of the waste to be analyzed;

• Frequency with which the initia l analysis of the waste will be reviewed or repeated to ensure that the analysis is accurate and up to date;34 • Where applicable, the methods which will be used to meet additional waste analysis requirements for specific waste management methods as specified in sections 264.17, 264.1034(d), 264.1063(d), and 264.1083

(ii) Respondent activities

To meet the requirements outlined in sect ion 267.13(b), owners or operators must perform the following activities:

• Read the regulations;

• Collect the data required in the waste analysis plan;

• Write the waste analysis plan; and

• Maintain the plan (e.g., photocopying and filing).

If you receive wastes generated from off-site, and are eligible for a standardized permit, you submit the waste analysis plan with the Notice of Intent.

(4) Inspections

(i) Data items

Section 267.15 requires owners and operators to develop and follow a written schedule for monitoring equipment that is important in preventing, detecting, or responding to

environmental or human health hazards. This sc hedule must be kept at the facility; and must identify the equipment and devices to be inspected, as well as the problems to be looked for. The frequency of inspections must be based on the ra te of deterioration of the equipment and the probability of an environmental or human health incident if the deterior ation, malfunction, or any operator error goes undetected be tween inspections. At a minimum, the inspection schedule must include the items and frequenc ies required in sections 267.174, 267.193, 267.195, 264.1033, 264.1052, 264.1053, 264.1058, and 264.1083 through 264.1089, where applicable.

Section 267.15(d) states that an owner or operator must record inspections conducted according to the written schedule developed pursuan t to section 267.15(b) in an inspection log or summary that is to be maintained at the facilit y. The inspection log or summary must contain, at a minimum, the date and time of the inspection, the name of the inspec tor, a notation of the observations made, and the date and nature of any repairs or ot her remedial actions.

(ii) Respondent activities

To meet the requirements outlined in s ections 267.15(b) and 267.15(d), the owner or operator must conduct th e following activities:35 • Read the regulations;

• Prepare the inspection schedule; and

• Record the results of inspec tions in the inspection log.

(5) Employee Training

(i) Data items

Section 267.16(d) requires an ow ner or operator to maintain copies of personnel training documents and records at the facility. These doc uments should include th e following data items:

• Job title for each position at the facility re lated to hazardous waste management, and the name of the employee filling each job;

• Written job description for each position, whic h includes the necessary skill, education, or other qualifications and duties of employees as signed to each position;

• Written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; and

• Records that document that the training or j ob experience required have been given to, and completed by, facility personnel.

(ii) Respondent activities

Respondent activities associated with section 267.16 (d) incl ude reading the regulations, collecting the data items listed above, and ma intaining (e.g., photocopying and filing) the information at the facility.

(6) Ignitable, Reactive, or Incompatible Wastes

(i) Data items

Section 267.17(c) states that the owner or ope rator of a hazardous waste facility must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. The owner or operator of a permitted facility must document compliance with the requirements outlined in sections 267.17(a) and (b). The documentation may be based on references to published scientific or engineering literature, data from trial tests (e.g., bench scale or pilot scale tests), waste analyses (a s specified in section 267.13), or the results of the trea tment of similar wastes by similar treatment processes a nd under similar operating conditions.36 (ii) Respondent activities

Respondent activities associated with section 267.17(c) incl ude reading the regulations, collecting and documenting th e data items mentioned above, and maintaining (e.g., photocopying and filing) docum entation at the facility.

PREPAREDNESS AND PREVENTION

(1) Arrangements with Local Authorities

(i) Data items

Section 267.36(b) requires owne rs and operators to document any refusal on the part of

local authorities to enter into an arrangement to handle emergencies.

(ii) Respondent activities

Respondent activities associated with section 267.36(b) incl ude reading the regulations, documenting any refusals, and placing this docum entation into the facility operating record.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

(1) Contingency Plan

(i) Data items

Section 267.51 requires owners or operators to have a contingency plan for their facilities and section 267.53 requires the owne r or operator to maintain a copy of an updated contingency plan at the facility. Section 267.52 outlines the data elements that should be included in this plan:

• A description of the actions facility personnel will take to comply with sections 267.51 and 267.56 in response to fires, explosions, or any unplanned releases of hazardous waste from the facility;

• A description of the arrangements agreed to by local police departments, fire departments, hospitals, contractors, and St ate and local emergency response teams to coordinate emergency services;

• An updated list of the names, addresses, and phone numbers (office and home) of all persons qualified to act as emergency coordinators;37 • An updated list of all emergency equipment at the facility and the location, physical description, and capabilities of the emergenc y equipment. The contingency plan should also indicate where the emergency equipment will be required; and

• An evacuation plan for facility personnel wher e there is a possibility that evacuation may be necessary.

Section 267.53(b) requires owne r and operators to submit a c opy of the contingency plan and all revisions to all local pol ice departments, fire department s, hospitals, and State and local emergency response teams that may be cal led upon to provide emergency services.

Section 267.54 requires owners and operators to review and, if n ecessary, immediately amend the contingency plan whenever:

• The facility permit is revised;

• The plan fails in an emergency;

• The facility is changed in a way that increa ses the potential for an emergency or changes the response necessary in an emergency;

• The list of emergency coordinators is changed; or

• The list of emergency equipment is changed.

(ii) Respondent activities

In order to comply with contingency plan re quirements, owners or operators ar e required to perform the following activities:

• Read the regulations;

• Collect the data required in the contingency plan;

• Write the contingency plan;

• Submit the contingency plan to State and local authorities;

• Maintain (e.g., photocopy and file ) the contingency plan; and

• Amend the contingency plan when appropriate.

(2) Emergency Reporting38 (i) Data items

Section 267.56(c)(1) requires owners and opera tors to immediately notify State and local authorities with designated re sponse roles of an imminent or actual emergency situation.

Section 267.56(c)(2) th e facility emergency coordi nator to notify the on-scene coordinator or the National Respons e Center of any release, fire, or explosion that could threaten

human health or the environment outside the faci lity. The emergency no tification report must include the following information:

• Name and telephone number of reporter;

• Name and address of facility;

• Time and type of incident;

• Name and quantity of material(s) involved;

• The extent of injuries; and

• Possible hazards to human health or the environment outside the facility.

Section 267.58(a) states that the owner or operator should notify the Regional Administrator and appropriate State and local authorities that their facility is in compliance with section 267.57(b) before resuming operations in the affected area(s ) of the facility.

Within 15 days of the incident, owners and operators are required, under section 267.58(b) to submit a written report on the incident to the Regional Administrator. The report must include the following data items:

• Name, address, and telephone num ber of the owner or operator;

• Name, address, and telephone number of the facility;

• Date, time, and type of incident;

• Name and quantity of material(s) involved;

• The extent of any injuries;

• An assessment of actual or pot ential hazards to human hea lth or the environment; and

• Estimated quantity and disposition of recovere d material that resulted from the incident.39 Section 267.58(b) also requires ow ners and operators to note th e time, date, and details of any incident that requires implementing the contingency plan in the operating record.

(ii) Respondent activities

In order to comply with the reporting requi rements of section 267.58(c)(1), owners and operators must submit the required notification of an imminent or actual emergency situation to

State and/or local authorities.

In order to comply with the reporting requi rements of section 267.56(c)(2), owners and operators must perform the following activities:

• Notify the on-scene coordinato r or the National Response Center of any release.

• Collect the information required in the emergency report; and

• Write the emergency notification report.

In order to prepare an owner/operator's em ergency report under section 267.58(a), owners and operators must conduct the following activities:

• Read the regulations;

• Collect the information required in the emergency report; and

• Write the emergency report.

In addition to preparing an emergency repor t, the owner or oper ator must notify the Regional Administrator that the facility is in compliance with section 267.57(b) before resuming operations in affected areas of the facility. Respondent activities a ssociated with this requirement include the following:

• Compiling information that dem onstrates that all affected areas are in compliance; and

• Preparing a letter notifying the Regional Administrator of this compliance.

To comply with the requirements of sect ion 267.58, owners and ope rators must record the details of any incident that requires impl ementing the contingency plan in the operating

record.

RECORD KEEPING, REPORTING, AND NOTIFYING

(1) Record Keeping40 (i) Data items

Section 267.71 requires owners and operators to record and maintain the following information, as it becomes availabl e, in the facility operating reco rd until the facili ty is closed:

• A description and the quantity of each h azardous waste received, and the method(s) and date(s) of its treatment, storag e, or disposal at the facili ty as required by Appendix I of part 264;

• The location of each hazardous waste within th e facility and the quant ity at each location;

• Records and results of waste analyses performed;

• Summary reports and details of all incident s that require implementing the contingency plan;

• Records and results of inspection reports (which must be kept for three years);

• Monitoring, testing, or analytical data and corrective action where required;

• All closure cost estimates;

• A certification by the permittee, no less ofte n than annually, that the permittee has a program in place to reduce the volume and toxi city of hazardous waste that he generates to the degree determined by the permittee to be economically practicable; and the proposed method of treatment, storage, or disposal that is the practicable method currently available to the permittee which mi nimizes the present and future threat to human health and the environment;

• For an on-site treatment facility, the info rmation contained in the notice (except the manifest number), and the certification a nd demonstration requi red under section 268.7 or section 268.8;

• For an on-site storage facility, the informati on in the notice (except the manifest number),

and the certification and demonstration if applicable, required under section 268.7 or

section 268.8.

(ii) Respondent activities

In order to comply with section 267.71, owners or operators are required to maintain a written operating record at the fa cility. Respondent activities a ssociated with maintaining an operating record include maintaining (e.g., photoc opying and filing) the data items listed above.

(2) Reports41 (i) Data items

Section 267.73(a) requires owners and operato rs to submit a single copy of a biennial report to the Regional Administrator by March 1 of each even numbered year. This requirement is covered in the The Hazardous Waste Report ICR.

Section 267.73(b) requires owne rs and operators to report to the Regional Administrator:

• Releases, fires, and explosions as specified in section 267.58(b);

• Facility closures specif ied in section 267.117; and

• As otherwise required by subparts I, J, a nd DD of part 267 and subparts BB and CC of part 264.

(ii) Respondent activities

As discussed above, the requirements at section 267.73(a) are covered under another ICR, and therefore are not burdened here. A dditionally, the reports described in section 267.73(b) are burdened under the applicable sections for each individual report.

(3) Notifications

(i) Data items

Section 267.74 requires that, before transfer ring ownership or operation of a facility during its operating life, an ow ner or operator must notify the new owner or operator in writing of the requirements of parts 267 and 270.

(ii) Respondent activities

In order to meet the requirement described above, owners and opera tors must prepare a written notification informing the new owner or operator of the requirements of parts 267 and

270.

CLOSURE

(1) Closure Plan

(i) Data items42 Owners and operators are required by section 267.112 to submit a written closure plan with the Notice of Intent. The plan must identi fy steps necessary to perform partial and/or final closure of the facility, and must include at least the following items:

• A description of how each hazardous waste mana gement unit at the faci lity will be closed in accordance with section 267.111;

• A description of how final closure of the f acility will be conducted in accordance with section 267.111 The description must identify the maximum ex tent of operations which will be unclosed during the activ e life of the facility;

• An estimate of the maximum inventory of h azardous wastes ever on-site over the active life of the facility. This should include a de tailed description of the methods to be used during partial closures and final closure such as met hods for removing, transporting, treating, storing, or disposing of all hazardous wastes, and identificati on of the type(s) of off-site hazardous waste management units to be used, if applicable;

• A detailed description of the steps needed to remove or decontaminate all hazardous

waste residues and contaminated containment system components, equipment, structures, and soils during partia l and final closure;

• A detailed description of other activities ne cessary during the closure period to ensure that all partial closures and final closure satisfy the closur e performance standards; and

• A schedule for closure of each hazardous waste management unit and for final closure of the facility. The schedule must include, at a minimum:

-- The total time required to close each hazardous waste management unit; and

-- The time required for intervening closur e activities which will allow tracking of the progress of partia l and final closure.

(ii) Respondent activities

The respondent activities associated with th e closure plan descri bed above include:

• Reading the regulations;

• Conducting an inventory of the hazardous waste present;

• Recording results of inventory; Writing de scriptions for the necessary activities;

• Estimating final closure; and43 • Writing the closure schedule.

(2) Notification Before Partial Closure and Final Closure

(i) Data items

Section 267.112(c) requires owners and operators to notify the Director in writing at least 45 days before beginning final closure of a tr eatment or storage tank, container storage, or containment building.

(ii) Respondent activities

To meet the above requirement, respondents must read the regulations, and prepare a

written notification.

(3) Certification of Closure

(i) Data items

Section 267.117 requires owners and operators to submit to the Direct or a certification of closure within 60 days of the completion of fina l closure of each unit under a part 270 subpart J standardized permit. This certification must se nt by registered mail; must certify that each hazardous waste management unit or facility has been closed following the specifications in the closure plan; and must be signed by the owner or operator and an independent registered engineer.

(ii) Respondent activities

The respondent activities associated with the certification of closure include:

• Reading the regulations;

• Preparing the certification; and

• Submitting the certification.

FINANCIAL REQUIREMENTS

(1) Cost Estimate for Closure

(i) Data items44 Section 267.142(a) requires owners and operators to develop a detailed written estimate, in current dollars, of the cost of closing the facility in accordance with the requirements in sections 267.111 through 267.115 and applicable closure requirements in sections 267.178, 267.197, 267.1102. Section 267.142(b) specifies that this estimate must be updated annually for inflation. Section 267.142(c) specifies that owners and operators must keep the latest closure cost estimate (adjusted to the current year) at the facility.

(ii) Respondent activities

The requirements described above w ill entail the follo wing activities:

• Reading the regulations;

• Preparing a detailed esti mate of closure costs;

• Updating the estimate fo r inflation annually; and

• Maintaining the estimate at the facility.

(2) Closure Trust Fund

(i) Data items

Section 267.143(a) explains that owners and operators may use a closure trust fund to meet the financial assurance requirements of section 267.143. Data items for this mechanism

include:

• A trust agreement in compliance with se ctions 264.143(a)(1) and (2), and 264.143(a)(6)- (11). The wording of this agreement must follow the wording specified in section 264.151(a)(1);

• For new facilities, a receipt from the trustee must be submitted to the Regional Administrator prior to the initial storage of waste;

(ii) Respondent activities

Owners and operators establishing a trust fund to meet the financial assurance requirements for closure will perform the following activities:

• Reading the regulations;

• Establishing a closure trust fund;45 • Submitting an originally signe d duplicate of the trust agreement to the EPA Regional Administrator;

• For owners and operators of new facilities, submitting a receipt for the first payment under the trust agreement before the initial receipt of hazardous wastes.

(3) Surety Bond Guaranteeing Payment into a Closure Trust Fund

(i) Data items

Section 267.143(b) allows owners and opera tors to meet the financial assurance requirements for closure by obtaining a surety bond guaranteeing payment into a closure trust

fund. The data items associated with this mechanism are:

• A surety bond instrument, as specified at section 264.151(b); and

• A standby trust agreement, as specified at section 264.143(b)(3).

(ii) Respondent activities

In collecting these data items, owners and opera tors will need to engage in the following respondent activities:

• Reading the regulations;

• Establishing a surety bond and trust agreement that comply with the financial assurance requirements of section 267.143(b); and

• Submitting originally signed dup licates of the surety bond a nd trust agreement to the Regional Administrator.

(4) Surety Bond Guaranteeing Performance of Closure

(i) Data items

Section 267.143(c) allows owners and opera tors to meet the financial assurance requirements for closure by obtaining a surety bond guaranteeing the perfor mance of closure.

The data items for this instrument include:

• A surety bond instrument spec ified at secti on 264.151(c); and

• A standby trust agreement, as specified at section 264.143(c)(3).

(ii) Respondent activities46 The respondent activities associated with th is financial assurance instrument include:

• Reading the regulations;

• Obtaining a surety bond and trust agreement th at comply with the financial assurance requirements of section 267.143(c); and

• Submitting originally signed dup licates of the surety bond a nd trust agreement to the Regional Administrator.

(5) Closure Letter of Credit

(i) Data items

Section 267.143(d) specifies that owners or operators may obtain an irrevocable standby letter of credit in order to satisfy financial assurance requirements for closure. Data items for

this information collection include:

• A letter of credit from an issuing institution au thorized to issue letters of credit and whose letter-of-credit operations are regulated and examined by a Federal or State agency; and

• A trust agreement indicating the conditions of payment into the standby trust fund specified in sect ion 264.143(d)(3).

(ii) Respondent activities

Owners or operators will need to engage in the following activities in order to satisfy the financial assurance requirements w ith a closure letter of credit:

• Reading the regulations;

• Obtaining a letter of credit from an issuing institution and establis hing the stand-by trust fund; and

• The letter of credit and an originally si gned duplicate of the tr ust agreement to the Regional Administrator.

(6) Closure Insurance

(i) Data items

Owners or operators may satisfy the financ ial assurance requirements for closure by establishing closure insuran ce according to section 267.143(e) . The data item for this47 information collection is a closure insurance policy (identified by a certificate of insurance) that meets the requirements speci fied in section 264.143(e).

(ii) Respondent activities

The following activities are necessary to meet the above requirement:

• Reading the regulations;

• Obtaining a closure or post-closure insurance policy that satisfies the requirements of section 264.143(e); and

• Submitting a certificate of this insurance policy to the Regional Administrator.

• Corporate Financial Test and Corporate Guarantee

(i) Data items

Section 267.143(f) allows owners and operators to satisfy closure financial assurance requirements by demonstrating financ ial strength using the financial te st specified in this section.

Data items for this demonstration include:

• A letter signed by the owner's or operator's chie f financial officer as specified in section 267.143(f)(2)(i)(A);

• A copy of an independent certified public accountant's report on examination of the owner's or operator's financial statements for the latest completed fiscal year;

• A special report from the owner's or operator' s independent certified public accountant to the owner or operator covering the specificati ons outlined in sections 267.143(f)(2)(i)(c) and (d);

• Annual updates of the above data items;

• A notice of intent to establish alternative fi nancial assurance, if the owner or operator fails the financial test and no longer meet s the requirements of section 267.143(f)(1);

• Reports of financial conditions as required by the Regional Admini strator under section 267.143(f)(2)(v)(A); and

• If applicable, a written guarantee from the parent corporation of the owner or operator that satisfies the requirem ents at section 267.143(g)(1).

(ii) Respondent activities48 Owners and operators will need to perform the following activ ities to provide the data

items listed above:

• Reading the regulations;

• Writing the letter signed by the chief financial officer;

• Submitting the following documents to the Regional Administrator (for new facilities, these documents must be submitted at least sixty days prior to placing waste in the facility):

-- The letter signed by th e chief financial officer;

-- A copy of the independent certifie d public accountant's report; and

-- The special report from the inde pendent certified public accountant;

• Submitting updated information annually;

• If applicable, writing and submitting a notice, by certified mail, to the Regional

Administrator of intent to estab lish other financial assurance; and

• Writing and submitting additional reports of fina ncial condition at any time, as directed by the Regional Administrator; and

• If applicable, submitting the corporate guarantee from the parent corporation of the

owner or operator.

(8) Use of a Financial Assurance Instrument for Multiple Facilities

(i) Data items

Section 267.143(i) allows owners and operators to use a sing le financial mechanism for multiple facilities, as specified in section 264.143(h) . In such cases, the owner and operator must provide the following data items for each facility:

• EPA identification number, name, and address; and

• The amount of funds for closure or post-c losure care assured by the mechanism.

(ii) Respondent activities49 In order to provide the data items listed above , owners and operators will need to perform the following activities:

• Reading the regulations;

• Submitting the data items listed above to the Regional Administrator; and

• If the facilities covered by the mechanism are located in more than one Region, submitting identical evidence of financial assurance to all the applicable Regional

Administrators.

(9) Trust Fund for Liability Coverage

(i) Data items

Section 267.147(a)(3) allows owners or operato rs to satisfy financ ial requirements for liability by establishing a trust agreement that c onforms to the requirements specified in section 264.147(j).

(ii) Respondent activities

Owners or operators using this option to satisf y financial assurance for liability will need to engage in the following activities:

• Reading the regulations;

• Establishing the trust fund described above; and

• Submitting an originally signed duplicate of the trust agreement to the Regional

Administrator.

(10) Surety Bond for Liability Coverage

(i) Data items

Section 267.147(a)(2) allows owners or operato rs to satisfy financ ial requirements for liability. The owner/ope rator must obtain a surety bond (and other information, where applicable) that conforms to the requ irements specified in section 264.147(i).

(ii) Respondent activities

Owners or operators using this option to satisf y financial assurance for liability will need to engage in the following activities:50 • Reading the regulations;

• Obtaining the surety bond described above; and

• Submitting a copy of this surety bond to the Regional Administrator.

(11) Letter of Credit for Liability Coverage

(i) Data items

Section 267.147(a)(3) allows owners or operato rs to satisfy financ ial requirements for liability by obtaining an irrevocable standby letter of credit that conforms to the requirements of section 264.147(h).

(ii) Respondent activities

Owners or operators using this option to satisf y financial assurance for liability will need to engage in the following activities:

• Reading the regulations;

• Obtaining the standby letter of credit described above; and

• Submitting a copy of this letter of cr edit to the Regional Administrator.

(12) Liability Insurance

(i) Data items

Section 267.147 allows owners or operators to satisfy financial requir ements for liability by obtaining liability insurance that conforms to the requirements of section 264.147(h). The following data items are required:

• A duplicate of the endorsement or certificate of insurance; and

• A duplicate of the insurance policy, if re quested by the Regional Administrator.

(ii) Respondent activities

Owners or operators will need to engage in the following activities to complete the requirements for this option:

• Reading the regulations;51 • Obtaining an insurance policy amended by at tachment of the H azardous Waste Facility Liability Endorsement or evidenced by a Cer tificate of Liability Insurance and meeting other specifications outlined in se ctions 264.147(a)(1) a nd 264.147(b)(1);

• Submitting a signed duplicate original of the endorsement or the certificate of insurance to the Regional Administrator, or Regional Admi nistrators if the fac ilities are located in more than one Region; and

• If requested by the Regional Administrator, submitting a signed duplicate original of the insurance policy (for new facilities this must be submitted at least sixty days before receiving hazardous waste for treatment or storage).

(13) Financial Test for Liability Coverage

(i) Data items

Section 267.147(a)(5) allows owners or operato rs to satisfy liabili ty requirements by passing a financial test, as speci fied at section 267.147(f). Data items for this option include:

• A letter signed by the owner's or operator's chie f financial officer and worded as specified in section 264.151(g); if the fi nancial test is also being used to demonstrate closure financial assurance, the lette r specified in section 264.151(g) must be submitted to cover both forms of financial responsibility;

• A copy of an independent certified public accountant's report on examination of the owner's or operator's financial statements for the latest completed fiscal year;

• A special report from the owner's or operator' s independent certified public accountant to the owner or operator cove ring the specifications of section 267.147(f)(2)(i)(C);

• Annual updates of the a bove data items; and

• Should the owner or operator fail the test a nd no longer meet the requirements of section 267.147(f)(1), evidence of alternat e financial assurance obtained for the entire amount of required liability coverage specified in section 267.147.

(ii) Respondent activities

Owners or operators will need to engage in the following respondent ac tivities in order to collect the data requi red by these sections:

• Reading the regulations;

• Writing the letter signed by the chief financial officer;52 • Submitting the following documents to the Regional Administrator (for new facilities, these documents must be submitted at least sixty days prior to receiving hazardous waste for treatment or storage):

-- The letter signed by th e chief financial officer;

-- A copy of an independent certifie d public accountant's report; and

-- The special report from an inde pendent certified public accountant;

• Submitting updated information annually; and

• Should the owner or operator fail the test and no longer meet section 267.147 requirements, submitting evidence to the Regional Administrator of alternate financial

assurance for the entire amount of required liability coverage specified in this section.

(14) Corporate Guarant ee for Liability Coverage

(i) Data items

Section 267.147(g) allows owners or opera tors to meet liability requirements by obtaining a written guarantee, under the conditions specified in secti on 267.147(g)(2). Data items for this option include:

• A certified copy of a written guarant ee from the direct or highe r-tier parent corporation of the owner or operator, a firm whose parent co rporation is the parent corporation of the owner or operator, or a firm with a "substant ial business relationship" with the owner or

operator;

• In the case of corporations incorporated in the United States, a written statement from applicable Attorney(s) General or Insuran ce Commissioners to EPA indicating that a guarantee executed as described in the regulations is a legally valid and enforceable obligation in that State;

• In the case of corporations incorporated outside the United States , identification by the non-U.S. corporation of a registered agent for service of process in each State in which the facility covered by the gua rantee is located and in the State in which it has its principal place of business, and a written st atement from applicable Attorney(s) General or Insurance Commissioner of each applicable State indicating that a guarantee executed as described in the regulations is a legally va lid and enforceable oblig ation in that State;

and53 • A letter from the guarantor's chief fina ncial officer as specified in section 267.147(f)(2)(A) that demonstrates that the guarantor has passed the financial test.

(ii) Respondent activities

Owners or operators will need to engage in the following respondent ac tivities in order to collect the data requi red by these sections:

• Reading the regulations;

• Obtaining a written guarantee from the direct or higher-tier parent corporation of the owner or operator, a firm whose parent corpor ation is the parent corporation of the owner or operator, or a firm with a "substantia l business relationship" with the owner or

operator;

• Submitting a certified copy of this written guarantee to the Regional Administrator along with the items specified in section 267.147(f)(2); and

• Submitting a letter from the guarantor's chief financial officer as specified in section 264.147(f)(2)(i)(A) that demonstrates that the guaranto r has passed the financial test.

(15) Incapacity of Owners or Operators , Guarantors, or Financial Institutions

(i) Data items

Section 267.148 requires owners or operat ors to submit a notification of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the owner or operator as debtor (if the guarantor is named as the debtor, the collection of this data is the guarantor's responsibility).

(ii) Respondent activities

Activities for this data collection will include:

• Reading the regulations; and

• Submitting, by certified mail, a notice to th e Regional Administrator indicating the commencement of bankruptcy proceedings in wh ich the owner or operator or guarantor is

named as debtor.

(16) State Assumption of Responsibility

(i) Data items54 Section 267.150 requires owners or operators to notify EPA when a State assumes legal responsibility or assures availabi lity of funds for an owner's or operator's compliance with the closure, post-closure care, or liab ility requirements of this part. Data items to be collected in

this case include:

• A letter from the owner or operator reque sting that the State's assumption of responsibility be considered acceptable for meeting the requirements of this subpart;

• A letter from the State describing the nature of the State's assumption of responsibility, including the following information:

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

-- The amount of funds for closure or post-c losure care or liabilit y coverage that are guaranteed by the State; and

• Any additional information which the Regiona l Administrator deems necessary to make the determination whether the State's assumption of responsibility is acceptable.

(ii) Respondent activities

Activities for this data collection will include:

• Reading the regulations; and

• Submitting to the Regional Administrator:

-- The letter from the owner or operator; and

-- The letter from the State describing th e State's assumption of responsibility and including the information specified above; and

• Submitting any additional information requested by the Regional Administrator.

USE AND MANAGEMENT OF CONTAINERS

(i) Data items

Section 267.172 requires owners and operators of facilities that stor e or treat hazardous waste in containers to inspect areas where they store containers, at least weekly.

(ii) Respondent activities55 In order to provide the above data item, owners and operato rs will need to perform the following activities:

• Read the regulations;

• Inspect the areas where they store contai ners, at least weekly (section 267.172); and

• Record the results of the inspection (section 267.15(d)).

In addition, section 267.177 requires owners and operators to manage all hazardous waste placed in containers according to the air emi ssion requirements established in subparts BB and CC of part 264. These requirements, however, ar e not addressed in this ICR since they are already covered in the Hazardous Waste Specific Unit Re quirements, and Special Waste Processes and Types ICR and in the Standards of Performance for Air Emission Standards for Tanks, Surface Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart CC ICR.

TANK SYSTEMS

(1) Applicability

(i) Data items

Section 267.190 allows owners and operator s to exempt their facilities from the secondary containment requirements in section 267.195 if they can demons trate that their tank systems do not contain free liquids and are situated inside a building with an impermeable floor. To obtain this exemption, owners and operators must demonstrate the absence or presence of free liquids in the stored/treated waste, us ing Method 9095 (Paint Fi lter Liquids Test) as

described in Test Methods fo r Evaluating Solid Waste, P hysical/Chemical Methods, EPA

Publication SW-846.

(ii) Respondent activities

Respondent activities associated w ith the above data item include:

• Reading the regulations; and

• Preparing the no free liq uids demonstration.

(2) Design and Construction Standards

(i) Data items56 Section 267.191 requires owners and operators to obtain a written assessment, reviewed and certified by an independent, qualified regist ered professional engineer, following section 270.11(d), attesting that the tank syst em has sufficient structural integrity and is acceptable for the storing and treating of hazardous waste. This assessment must include at least the following

information:

• Design standard(s) for the construction of tank(s) and/or the ancillary equipment;

• Hazardous characteristics of th e waste(s) to be handled;

• Factors affecting the potential for corrosion and the type and degree of external corrosion protection needed to ensure the integrity of the tank system; and

• Design considerations to ensure that the tank foundations will maintain the load of a full tank, will be anchored to prevent flotation or dislodgement, and will withstand the effects

of frost heave.

(ii) Respondent activities

In order to provide the data items describe d above, owners and operators will need to perform the following activities:

• Read the regulations; and

• Obtain a written assessment from an inde pendent, qualified registered professional engineer.

(3) Installation Requirements

(i) Data items

Section 267.194 requires owners and operators to obtain, and keep at the facility, written statements by those persons require d to certify the design of the ta nk system and to supervise the installation of the tank system as require d in sections 267.192, 267.193, and 267.194(a) and (b).

(ii) Respondent activities

In order to provide the data items describe d above, owners and operators will need to perform the following activities:

• Reading the regulations;

• Obtaining the written statements; and57 • Maintaining the statements at the facility.

(4) Inspection Requirements

(i) Data items

Section 267.199 requires owners and operators to provide the following data items:

• A schedule and procedure for inspecting overfill controls; and

• The results of inspections carri ed out pursuant to 267.199(a)-(c).

(ii) Respondent activities

In order to comply with section 267.199 re quirements, owners and operators must perform the following activities:

• Reading the regulations;

• Developing and follow a schedule and pro cedure for inspecting overfill controls;

• Inspecting the following at least once each operating day:

-- Aboveground portions of the tank system to detect corrosion or releases of waste;

-- Data gathered from monitoring and leak detection equipment to ensure that the tank system is being operated according to its design; and

-- The construction materials and the ar ea immediately surrounding the externally accessible portion of the tank system, including the secondary containment system to detect erosion or signs of releases of hazardous waste;

• Inspecting cathodic protection systems, if present, according to, at a minimum, the following schedule to ensure that they are functioning properly:

-- Confirm that the cathodic protection sy stem is operating properly within six

months after initial installa tion and annually thereafter;

-- Inspect and/or test all so urces of impressed current, as appropriate, at least every other month; and

• Documenting in the facility operating record the results of the above required inspections.

(5) Leaks and Spills58 (i) Data items

Section 267.200 requires owners and operators to provide the following data items if there has been a leak or spill from a tank system or secondary containment system, or if either system is unfit for use:

• A report informing the Regional Administrato r of the release w ithin 24 hours of its detection; and

• A report to the Regional Admini strator, within 30 days of detection, containing the following information:

-- The likely route of mi gration of the release;

-- The characteristics of the surrounding soil;

-- The results of any monitoring or sa mpling conducted in connection with the release;

-- The proximity to downgradient drin king water, surface water, and populated areas; and

-- A description of respons e actions taken or planned.

Section 267.200(f) requires owners and operators who have made extensive repairs to a tank system in accordance with section 267.200(e) to obtain and submit a certification from an independent, qualified, registered, pr ofessional engineer that the re paired system is capable of handling hazardous waste without release for the intended life of the system.

(ii) Respondent activities

The data items above will require the following respondent activities:

• Reading the regulations;

• Preparing and submitting a report to the Regiona l Administrator within 24 hours of leak detection;

• Preparing and submitting a report to the Regiona l Administrator within 30 days of leak detection; and

• Obtaining and submitting an engineer’s certification.59 In addition, section 267.204 requires owners a nd operators to manage all hazardous waste placed in a tank according to the air emission requ irements established in subparts BB and CC of part 264. These requirements, however, are not a ddressed in this ICR since they are already

covered in the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and Types ICR and in the Standards of Performance for Air Em ission Standards for Tanks, Surface Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart

CC ICR.

CONTAINMENT BUILDINGS

(1) Additional Standa rds for Liquid Storage

(i) Data items

Section 267.1103(d) requires owners and operators to inspect and record in the facility’s operating record, at least once ev ery seven days, data gathered from monitoring equipment and leak detection equipment as well as the c ontainment building and the area immediately surrounding the containment building to detect signs of releases of hazardous waste.

(ii) Respondent activities

In order to provide the above data items, owners and operato rs will have to perform the following activities:

• Read the regulations;

• Inspect data at least once every seven days; and

• Record the results in the f acility’s operating record.

(2) Waiver from Secondary Containment Requirements

(i) Data items

Section 267.1104 allows owners and operators to obtain a waiver from secondary containment requirements by demonstrating that the only free liquids in the unit are limited amounts of dust suppression liquids required to meet occupational health and safety requirements.

(ii) Respondent activities

Owners and operators wishing to waive the secondary containment requirements must perform the following activities:60 • Reading the regulations; and

• Preparing the demonstration.

(3) Containment Buildings with Area s Both with and Without Secondary

Containment

(i) Data items

Section 267.1105 requires owners an d operators of containment buildings that have areas both with and without secondary containment to ma intain in the facility’s operating log a written description of the operating procedures used to ma intain the integrity of areas without secondary

containment.

(ii) Respondent activities

Respondent activities associated w ith the above data items include:

• Reading the regulations; and

• Preparing and maintaining a written de scription of the operating procedures.

(4) Releases of Hazardous Waste

(i) Data items

Section 267.1106 requires owners an d operators that detect a c ondition that could lead to or has caused a release of hazardous waste to provide the following:

• A record of the discovery in the facility operating record;

• A notification to the Director of the condition;

• A written notice to the Director with a desc ription of the steps taken to repair the containment building, and the schedule for accomplishing the work; and

• Upon completion of all repairs and cleanup, a written notificati on to the Director providing verification, signed by a qualified, regi stered, professional engineer, that the repairs and cleanup have been completed accord ing to the written plan described above.

(ii) Respondent activities

In order to provide the above data items, owners and operato rs will need to perform the following activities:61 • Reading the regulations;

• Entering a record of the disc overy in the operating record;

• Preparing and submitting a notification to the Director within 7 days of the discovery;

• Preparing and submitting the written notice to th e Director within 14 working days of the discovery; and

• Preparing and submitting the writte n verification to the Director.

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

The following section discusses how EPA and implementing agencies would collect and manage the information received from respondents. This section also includes a discussion of how EPA would take steps to ensu re that the information collections are not overly burdensome

on small entities.

5(a) Agency Activities

APPLYING FOR A STAN DARDIZED PERMIT

Agency activities associated with a standard ized permit application and renewal include reviewing the incoming notice of intent and supporting inform ation, determining whether the facility is eligible for the standardized permit, and entering the information into a database.

MAINTAINING A STA NDARDIZED PERMIT

(1) Routine Changes

Agency activities associated with routine changes to a standardized permit include reviewing the information submitted by the permit holder.

(2) Routine Changes with Prior Approval of the Director

Agency activities associated with routine changes to a standardized permit include reviewing the information submitted by the permit holder, and approving/disapproving the

request.

(3) Significant Changes62 Agencies activities associated with significan t changes to a standardized permit include reviewing the incoming modifica tion request and supporting inform ation, reviewing the proof of public notice, and entering the in formation into a database.

GENERAL FACILITY STANDARDS

Agency activities associated with general facility standards re quirements include:

• Issuing an identification number to new fac ilities, and entering the facility in the hazardous waste facility data system.

• During inspection of the facility, reviewing the security procedures and determining if the components of the security system ar e in place and in working order.

• Reviewing information submitted by permit holders seeking for a waiver from security requirements, and deciding whet her to grant the request.

• Reviewing demonstration of compliance with location factors submitted by permit

holders.

• Reviewing information submitted by permit holders seeking for a waiver from location

standards.

PREPAREDNESS AND PREVENTION

Although the information is not formally submitted to the permitting agency, the permitting agency may review documentation on any refusal on the part of local authorities to enter into an arrangement to handle emergencies.

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Agency activities associated with the deve lopment and amendment of the contingency plan include: reviewing the contingency plan dur ing on-site inspections and reviewing revisions to the contingency plan.

Agency activities associated with emergenc y reporting requirements include reviewing documents in the owners' or operators' and em ergency coordinators' emergency reports.

RECORD KEEPING, REPORTING, AND NOTIFYING

Only one Agency activity is associated with the operating record requirements: on-site

review of the record.

CLOSURE63 Agency activities associated with closure in clude reviewing closure plans, closure plan amendment notifications, partial/ final closure notifications, and closure certifications. In addition, the permitting agency must issue a public notice for comments on the closure plan and make a determination whether to approve, modi fy, or disapprove the closure plan.

FINANCIAL REQUIREMENTS

Agency activities pertaining to financial requirements include:

• Reviewing closure cost estimates, demonstratio ns of financial assurance for closure, and

demonstrations of financia l assurance for liability.

• Entering the information into the RCRAInfo database.

USE AND MANAGEMENT OF CONTAINERS

Although the information is not formally submitted to the permitting agency, the permitting agency may review inspection records during site inspections.

TANK SYSTEMS

Agency activities pertaining to tank systems requirements include reviewing notifications and detailed reports on any releas es to the environment. In addition, the permitting agency may review inspection records during site inspections.

CONTAINMENT BUILDINGS

Agency activities pertaining to tank systems requirements include reviewing notifications on any releases to the environment and docum entation submitted to support requests for secondary containment requirements waivers. In addition, the permitting agency may review inspection records during site inspections.

5(b) Collection Methodology and Management

The permitting agency will rece ive and keep records of th e notifications and supporting documentation submitted by facility owners and ope rators applying for, renewing, or modifying a standardized permit. The permitting agency will also collect and keep records of closure plans and closure certifications submitted by facilities operating under a standardized permit. In collecting and reviewing this information, the permitting agency would use state-of-the-art electronic equipment such as personal com puters and applicable data software, when appropriate.64 5(c) Small Entity Flexibility

The standardized permit provides regulatory re lief from parts of RCRA hazardous waste permitting program for facilities with tanks, contai ners, and containment buildings that apply and obtain a standardized permit. Thus, small facilit ies, among others, would see relief. In addition, the final regulations would allow these facilities to maintain most information in facility records rather than in submittals to EPA, thus reduci ng time and costs for providing information. Since small facilities conduct operations that are equa lly as hazardous to the environment as those conducted by larger facilities, EPA determined that small businesses should be required to comply with the same regulations as large busin esses. As a result of this interpretation, no specific requirements are outli ned for smaller facilities.

5(d) Collection Schedule

Under section 124.204, the permitting agency is required to collect, review, and keep records of notices of intent and supporting information submitted by facility owners and operators applying for standardi zed permits. This information is used to determine whether a facility is or is not eligible to operate under a standardized permit. Once the permitting agency makes the preliminary decision to either grant or deny coverage under the standardized permit, section 124.207 requires the permitting agency to provide public notice of the draft permit decision, including any proposed site-specific conditions in a supplemental portion, and to provide an opportunity for the pub lic to submit comments and reque st a hearing on that decision. The public notice issued by the permitting agency must allow at least 45 days for people to submit written comments on the draft permit decision (section 124.208(a)). Information collected during the public commen t period is considered when making a final determination on whether to grant or deny coverage to a facility to operate under the standardized permit. If coverage is granted, the permitting agency consid ers the public comments when specifying terms and conditions in the supplemental porti on of the standardized permit, if any.

Under section 267.112, facility owners and opera tors must submit a written closure plan with the Notice of Intent. Once the permitting agen cy receives this information, it must review and approve the closure plan. In addition, th e permitting agency must provide the public an opportunity to comment on the plan. The comme nt period will be open for 30 days. The permitting agency will also, in response to a request or at its own discretion, hold a public hearing whenever such a hearing might clarify one or more issues concerning the closure plan. After review of the public comments, the perm itting agency will approve, modify, or disapprove the plan. If the permitting agency does not approve the closure plan, it must provide the facility owner or operator with a detailed written statement of reasons for the refusal. The permitting agency then will approve or modify the new closure plan. Once closure is completed, the permitting agency must collect and review a certification submitted by the facility owner or operator stating that each hazardous waste manageme nt unit or facility, as applicable, has been closed following the specifications in the closure plan.65 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

EPA estimated respondent burden associated with all of the requirements covered in this ICR in Exhibits 1 through 9. The exhibits esti mate the number of hours required to conduct each

individual information collec tion activity and the cost a ssociated with that activity.

6(b) Estimating Respondent Costs

Labor Costs

EPA estimates an average hourly respondent labor cost (including overhead) of $104.18 for legal staff, $84.86 for manage rial staff, $40.68 for technical staff, and $22.73 for clerical

staff. These wage rates are based on actual Bureau of Labor Statis tics (BLS) mean rates, plus overhead and fringe benefits. These rates are lower than those previously used. Previous estimates reflected updates with a straight inflat ion factor applied to pr evious respondent hourly

estimates.

Capital Costs

EPA estimates that only new facilities will incu r capital costs associated with purchasing file storage systems for maintaining records. EPA realizes that facilities will likely use different and various file storage systems (e.g., file cabinet s, CD-ROM, off-site st orage, etc) and store their files on different media (pap er, microfiche, electronic files, etc). For purposes of estimating these capital costs across all facilities, EPA ha s made the conservative assumption that every new facility will store their files in paper form in file cabinets.

EPA estimates that each new facility will need to purchase one 5-drawer lateral file cabinet to maintain their application materi als over the ten-year life of their permit. 1 The current market price for such a file cabinet is $549. EPA has annualized this cost at a discount rate of 7 percent over ten years (based on the average lif e of the permit). Thus, EPA estimates the annualized net present value of this capital cost to be $78 per facility. In Exhibit 19, EPA has included the annualized capital cost for the two new facilities exp ected to apply for and obtain a standardized permit each year ($156 per year).

Operation and Maintenance Costs

EPA estimates that respondents may incu r annual operations and maintenance costs

associated with the information collection re quirements. EPA estimates that sending a

1 EPA assumes existing permitted and interim-stat us facilities have already compiled much of the materials required in the standardized permit appl ication; and thus, they have already purchased the

file cabinets needed.66 notification to EPA under sections 124.202, 270.275, 270.280, and 270.285 would cost about $4.00 for the mailing expense (e.g., for certified mail with return receipt).

In this ICR, EPA also estimates costs to respondents for obtaining contractor-related services, such as preparing compliance demons trations for containers and tank systems.

6(c) Estimating Agency Burden and Costs

EPA estimates Agency burden hours and costs associated with all the requirements

covered in this ICR in Exhibit 20. EPA estimat es an average hourly Agency labor cost of $76.38 for Regional legal staff, $54.94 for Regional ma nagerial staff, $38.56 for Regional technical staff, and $23.44 for Regional clerical staff. EPA used the 2012 Federal Pay Schedule salary figures to estimate annual compensation of Regiona l legal, managerial, t echnical, and clerical staff. For purposes of this ICR, EPA assigne d Regional staff the following government service

levels:

Legal staff GS-15, Step 1 Managerial staff GS-13, Step 1 Technical staff GS-11, Step 1 Clerical staff GS-06, Step 1

EPA divided annual compensation estimates by 2,080, the number of hours in a Federal work year, and multiplied the rates by the standa rd government overhead factor of 1.6 to derive hourly rates.

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

Table 1 presents the estimated universe of tr eatment, storage, and disposal facilities (TSDFs) that currently store or non-thermally trea t hazardous waste in containers, tanks, and/or containment buildings.

Table 1

Facilities that Treat and/or Store Hazardous Waste in Containers, Tanks, and Containment Buildings a

Type of facility Number facilities Permitted

facilities Interim status

Facilities with storage and/or non-thermal treatment units only

Containers 717 490 227

Tanks 514 326 188

Containment buildings 13 6 7

All storage and/or treatment

facilities b 740 512 228

Facilities with storage, non-thermal treatment, and other type of units67 Containers 221 123 98

Tanks 228 125 103

Containment buildings 18 3 15

All storage and/or treatment

facilities b 259 162 97

Total

Containers 938 613 325

Tanks 742 451 291

Containment buildings 31 9 22

All storage and/or treatment

facilities b 1,000 674 325

a Estimates are from the Permitting Program Accomplishments Report (PAR) for the period October 1, 1980 to October 4, 1999. Estimated number s of facilities presented in this table do not include federally owned and operated facilities.

b Note that certain facilities own or operate mo re than one type of unit (e.g., containers and tanks). Therefore, the number of facilities with containers, tanks, and containment buildings in

the table are not additive.

As shown in the table, the total number of TSDFs with storage and/or non-thermal treatment units is estimated to be 1000 (674 perm itted and 325 interim stat us). The estimate of 1000 was derived by taking the mid-point of the range of facilities potenti ally eligible for the standardized permit ((onsite + off-site) / 2). Of these 1000 TSDFs, 740 (512 permitted and 228 interim status) facilities ha ve storage and/or non-thermal treatment units only and 259 (162 permitted and 97 interim status) facilities have st orage, non-thermal treatment, and other type of

units.

Of the 740 TSDFs that have storage and/or non-thermal treatment units only, 717

facilities have at least one containe r, 514 facilities have at least one tank, and 13 facilities have at least one containment building. Of the 259 TSDFs th at have storage, non-thermal treatment, and other type of units, 221 facilities have at least one container, 228 facilitie s have at least one tank,

and 18 facilities have at least one containment building. In order to determine the number of TSDFs that would apply for a standardized permit within the three-year period of this ICR, EPA made the following assumptions:

Operating, fully permitted facilities

• For facilities with storage and non-thermal treatment units only, the annual number of permit renewals is expected to be approximate ly 13. All of these f acilities are expected to apply for a standardized permit. 2

2 Based on analysis of permitting data from th e Permitting Program Accomplishments Report (PAR) for the period October 1, 1980 to October 4, 1999 and EPA ’ s best professional judgment.68 • Of the facilities with storage and/or non-thermal treatment units only that are not up for permit renewal, 50 percent are expected to apply for a standardized permit (71 facilities per year). 3

• For facilities with storage, non-thermal treatment, and othe r type of units, the annual number of permit renewals is expected to be 2. All of these fac ilities are expected to apply for a standardized permit. 4

• For facilities that have storage, non-thermal tr eatment, and other type of units that are not up for permit renewal, 25 percent are expect ed to apply for a standardized permit (12 facilities per year). 5

Operating, interim-status facilities

• All facilities with st orage and non-thermal treatment units only are expected to apply for a standardized permit (69 facilities per year). 6

• 50 percent of the facilities that have storag e, non-thermal treatment, and other type of units are expected to apply for a standardized permit (15 facilities per year). 7

New facilities

• 2 new facilities per year are expected to apply for a standardized permit each year. 8

The universe data for facilities expected to apply for a standardized permit are

summarized in Table 2.

Table 2 Treatment and/or Storage Facilities Expected to Apply for a St andardized Permit Annually a

Type of facility Permitted facilities Interim New Total

3 Ibid.

4 Ibid.

5 Ibid.

6 Ibid.

7 Ibid.

8 EPA ’ s best professional judgment.69 Permit

renewals Permitted facilities switching to a standardized permit prior to permit

renewal status
facilities facilities

b

Facilities with storage and/or non-thermal treatment units only

Containers 11 67 68 C 146

Tanks 7 44 55 C 106

Containment buildings 0 1 2 C 3

All storage and/or treatment

facilities c 13 71 69 C 153

Facilities with storage, non-thermal treatment, and other type of units

Containers 1 9 15 C 25

Tanks 1 9 15 C 25

Containment buildings 0 0 2 C 2

All storage and/or treatment

facilities c 2 12 15 C 29

Total

Containers 12 76 83 2 173

Tanks 8 53 70 1 132

Containment buildings 0 1 4 0 5

All storage and/or treatment

facilities c 15 83 84 2 184

a Estimates are from the Permitting Program Accomplishments Report (PAR) for the period October 1, 1980 to October 4, 1999. Estimated number s of facilities presented in this table do not include federally owned and operated faciliti es. In addition, total actions are based on midpoint of the lower and upper-bound estimates of annual actions presen ted in the economics background document (e.g., (166 + 202) / 2 ), where the total for onsite is 166 and on+offsite is 202).

b EPA is uncertain whether new facilities will own storage and treatment only or storage, nonthermal treatment, and other type of units. Ho wever, this issue has no bearing on this ICR.

c Note that certain facilities own or operate mo re than one type of unit (e.g., containers and tanks). Therefore, the number of facilities with containers, tanks, and containment buildings in

the table are not additive.

Respondent Burden and Costs

Based on the universe data presented in Ta ble 2, EPA estimated respondent burden and

costs associated with all of th e requirements covered in this I CR in Exhibits 1 through 9. A discussion of the burden estimates pr esented in these exhibits follows.70 APPLYING FOR A STAN DARDIZED PERMIT

(1) General Information Requirements

EPA estimates that a total of 184 (permitted, interim status, and new) TSDFs per year will apply for a standardized permit (see Table 2). A ll of these facilities are expected to read the regulations and submit a written notice of intent to operate under a standardized permit, a public meeting summary, and a certification of compliance with part 267.

For permitted facilities, EPA estimates that 98 facilities per year (i.e., 15 permit renewals and 83 permitted facilities switching to a standard ized permit prior to permit renewal) will apply for the standardized permit within the three-year period of this ICR. EPA assumes that all of these facilities already have coll ected most of the required informa tion as part of their previous permitting process (e.g., Part A information, documentation of compliance with location standards, waste management unit information). Permitted facilities will only need to collect those data items not already required at part 264 or 270, e.g., notice of in tent to operate under a standardized permit.

EPA assumes that interim status and new facili ties (i.e., a total of 86 facilities per year) will have to prepare and mainta in all general information, with two exceptions. One exception pertains to submitting the Part A application. EPA assumes that only new facilities will incur burden for this activity, since interim status facilities should already have submitted this

information to EPA.

The other exception pertains to compliance schedules. EPA assumes that, of the 98 permitted facilities and the 84 interim status facilitie s, 5 percent of the facilities (i.e., a total of 9 facilities) will not be in compliance with gene ral information requirements of part 264 or 265. 9
These facilities would have to prepare and subm it a schedule of compliance with part 267 as part of their standardized permit application.

Of the 1000 TSDFs, approximately 134 may be e xpected to receive waste from off-site facilities, and therefore, are re quired to submit documentation that the off-site facility is under the same ownership as the receiving facility. Ba sed on the estimated 184 total actions (out of the 1000 facilities) per year, approximately 25 faciliti es annually may be affected (apply for a permit and submit ownership documentation). The 134 number comes from subtracting the lower bound estimate of eligible facilities (866) from th e total for this ICR (1000) and multiplying that result by the ratio of (184/1000).

9 The 5-percent estimate is based on EPA ’ s experience under the RCRA program.71 (2) Record Keeping Requirements

With few exceptions, EPA assumes that only inte rim-status and new facilities (i.e., a total of 82 facilities per yea r) will have to incur burden for r ecord keeping information. The exceptions pertain to the record keeping of partic ular data items. Specifically, EPA assumes that only new facilities will incur burden for prepar ing a general descripti on of the facility and obtaining a topographic map (i.e., 2 facilities). EPA also assumes that, of the 98 permitted facilities and the 84 interim status facilities, 5 percent will have to prepare a justification for modifications of the preparedne ss and prevention requirements (i .e., a total of 9 facilities). 10

(3) Container Information Requirements

EPA assumes permitted facilities will not incu r burden in compiling information on their

containers. EPA also assumes that interim stat us and new facilities will need to collect information on containers, under section 270.300. EPA estimates that the affected universe will include approximately 85 facilities with containe rs (i.e., 83 interim status facilities and 2 new facilities).

(4) Tank Information Requirements

EPA assumes permitted facilities will not incu r burden in compiling information on their

tanks. EPA also assumes that interim status an d new facilities will need to collect information on tanks, under section 270.305. EPA estimates that the affected universe will include approximately 71 facilities with tanks (i.e., 70 inte rim status facilities and 1 new facility). In addition, EPA estimates that 10 percent of the pe rmitted and interim status facilities and one new facility owning tank systems (i.e., 0.10 x [61 permitted facilities + 70 interim status facilities] + 1 new facility = 14 facilities in to tal) will need to prepare a detailed description of how new tank systems will be installed in compliance with section 267.194. 11

(5) Equipment Information Requirements

EPA assumes permitted and interim status faci lities will not incur burden in compiling information on their equipment. All permitted and in terim status facilities are already required to have this information under 40 CFR part 270. Ho wever, EPA assumes that the one new facility owning tank systems will be subject to the equipment standards.

(6) Air Emissions Control Requirements

10 Ibid.

11 The 10-percent estimate is based on EPA ’ s experience under the RCRA program.72 EPA assumes permitted and interim status faci lities will not incur burden in compiling information on their air emission controls. All permitted and interim status facilities are already required to have this information under 40 CFR part 270. However, EPA assumes that the two new facilities will be subject to th e air emission control standards.

(7) Switching from an Individual RCR A Permit to a Standardized Permit

For permitted facilities switching to a standard ized permit prior to permit renewal (i.e., 76 facilities), EPA has added the burden of reading the regulations and preparing and submitting a request to the permitting agency.

(8) Reapplying for a Standardized Permit

For the purposes of this ICR, EPA assumes that no facilities will be reapplying for a standardized permit during the th ree-year period of this ICR.

MAINTAINING A STA NDARDIZED PERMIT

EPA estimates that approximately 10 percen t of the TSDFs (i.e., 0.10 x 184 facilities =18 facilities) operating under a st andardized permit will have to make routine changes to their permits each year. Approximately 4 percen t of the TSDFs (i.e., 0.04 x 184 facilities = 7 facilities) operating under a standa rdized permit are expected to ma ke significant changes to their permits each year. 12

GENERAL FACILITY STANDARDS

Information collection requirements pertaining to general facility standards are already

covered in the General Hazardous Waste Facility Standards ICR and the Part B Permit Application, Permit Modificatio ns, and Special Permits ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a standard ized permit with these requirements in this ICR, i.e., the number of respondents or activitie s is equal to zero. (Note that the two new facilities expected to apply for and obtain a standardized permit are covered in the above mentioned ICRs.)

PREPAREDNESS AND PREVENTION

12 EPA is unsure of the percent of facilities that will seek a standardized permit modification.

EPA referred to the Supporting Statement for EPA Information Collection Request Number 1573.05, "Part B Permit Application, Permit Modifications, and Special Permits" to identify the percent of facilities seeking Class I, II, and III permit modificatio ns. EPA used these percentages as a surrogate for estimating the percent of facilities expected to make routine and significant changes to a standardized permit.73 Information collection requirements pertai ning to preparedness and prevention are already covered in the General Hazardous Waste Facility Standards ICR. Thus, EPA has chosen not to burden TSDFs applying fo r and obtaining a standardized permit with these requirements in this ICR, i.e., the number of respondents or acti vities is equal to zero. (Note that the two new facilities expected to apply for and obtain a standardized permit are covered in the above mentioned ICR.)

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Information collection requirements pertaini ng to the contingency plan and emergency procedures are already covered in the General Hazardous Waste Facility Standards ICR and the Part B Permit Application, Permit M odifications, and Special Permits ICR. Thus, EPA has chosen not to burden TSDFs applying for a nd obtaining a standardized permit with these requirements in this ICR, i.e., the number of res pondents or activities is equal to zero. (Note that the two new facilities expected to apply for and obtain a standard ized permit are covered in the above mentioned ICRs.)

RECORD KEEPING, REPORTING, AND NOTIFYING

Information collection requirements pertaini ng to record keepi ng and reporting are already covered in the General Hazardous Waste Facility Standards ICR. Thus, EPA has chosen not to burden TSDFs applying fo r and obtaining a standardized permit with these requirements in this ICR, i.e., the number of respondents or acti vities is equal to zero. (Note that the two new facilities expected to apply for and obtain a standardized permit are covered in the above mentioned ICR.)

CLOSURE

Information collection requirements pertaini ng to closure are alre ady covered in the General Hazardous Waste Facility Standards ICR and the Part B Permit Application, Permit Modifications, and Special Permits ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a standardized permit with these requirements in this ICR, i.e., the number of respondents or activities is equal to zero. (Note that the two new facilities expected to apply for and obtain a standardized permit are c overed in the above mentioned ICRs.)

FINANCIAL REQUIREMENTS

Information collection requirements pertaining to financial assuranc e are already covered

in the General Hazardous Waste Facility Standards ICR and the Part B Permit Application, Permit Modifications, an d Special Permits ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a standardized permit w ith these requirements in this ICR, i.e., the number of respondents or activities is equal to zero. (Note that th e two new facilities expected to apply for and obtain a standard ized permit are covered in the above mentioned ICRs.)

USE AND MANAGEMENT OF CONTAINERS74 Information collection requirements pertaining to the use and management of containers are already covered in the Part B Permit Application, Permit M odifications, and Special Permits
ICR, the Hazardous Waste Specific Unit Requirement s, and Special Waste Processes and Types
ICR, and the Standards of Performance for Air Emi ssion Standards for Tanks, Surface Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart

CC ICR. Thus, EPA has chosen not to burden TSDF s applying for and obtaining a standardized permit with these requirements in this ICR, i.e ., the number of respondents or activities is equal to zero. (Note that the two new facilities expect ed to apply for and obtain a standardized permit are covered in the above mentioned ICRs.)

TANK SYSTEMS

Information collection requirements pertaining to tank systems are already covered in the Part B Permit Application, Permit Mod ifications, and Special Permits ICR, the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and Types ICR, and the Standards of Performance for Air Emission Standards for Tanks, Surface Impoundments and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265, Subpart CC ICR. Thus, EPA has chosen not to burden TSDFs applying for and obtaining a standardized permit with these requirements in this ICR, i.e., the number of res pondents or activities is equal to zero. (Note that the two new facilities expected to apply for and obtain a standard ized permit are covered in the above mentioned ICRs.)

CONTAINMENT BUILDINGS

Information collection requirements pertaini ng to containment buildings are already

covered in the Hazardous Waste Specific Unit Requirements, and Special Waste Processes and Types ICR. Thus, EPA has chosen not to burde n TSDFs applying for and obtaining a standardized permit with these requirements in this ICR, i.e., the number of respondents or activities is equal to zero. (Note that the two new facilities e xpected to apply for and obtain a standardized permit are covered in the above mentioned ICR.)

6(e) Bottom Line Burden Hours and Costs

Respondent Tally

Exhibit 19 summarizes the total annual respond ent burden and cost asso ciated with all the requirements covered in this ICR. As shown in the exhibit, EPA estimates that the annual respondent burden to be approximately 15,045 hours, at an annual cost of $1,307,837.

Agency Tally

Exhibit 20 summarizes the estimated Agency burden associated with all activities covered in this ICR. As shown in the exhibit, EPA estimates that the annual agency burden is approximately 11,779 hours, at an annual cost of $616,306.

6(f) Reasons for Change in Burden75 The Operations and Maintenance (O&M) costs increased by $310 due to updates in

current fees.

The Agency costs have decreased from $758,92 0 to $616,306. This is due to an update in

current salaries.

6(g) Burden Statement

The annual reporting burden for the new inform ation collection requirements in this ICR is estimated to range from 53 to 57 hours per re spondent. This burden includes time for facility owners and operators to submit to the perm itting agency a notice of intent and supporting materials for a standardized permit application, if required, and permit mo dification requests for significant changes. The average time per re sponse for reporting is about 37 hours.

The annual record keeping burden for the new in formation collection requirements in this ICR is estimated to range from 31 to 178 hours pe r respondent. This in cludes time for reading the regulations and keeping records under section 270.290 and, if requi red, under sections 270.300 to 270.315 for containers, tanks, equipment, and air emission controls. The average time per response for record keeping is about 45 hours. In total, the combined average for burden hours is about 82 hours per response.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete 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 re spond 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 CF R 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-2011-0624 , which is available for online viewing at www.regulations.gov, or in person viewing at th e RCRA Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitu tion Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 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,76 select “search,” then key in the Docket ID Number identified above. Also, you can send

comments to the Office of Information and Re gulatory Affairs, Offi ce of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please

include the EPA Docket ID Number EPA-HQ-RCRA-2011-0624 and O MB Control Number

2050-0182 in any correspondence

.7778EXHIBIT 1STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTAP P LYING FOR A STANDARDIZED P ERM ITRead the regulations 0.00 0.50 0.50 0.00 1.00 $62.77 $0.00 184 184 $11,550Prepare a written notice of intent to operate under a standardized permit 0.10 0.10 0.25 0.17 0.62 $32.94 $0.00 184 114 $6,061Obtain the Part A information 1.50 3.00 9.00 1.50 15.00 $811.07 $0.00 2 30 $1,622Obtain the meeting summary and other materials required by section 124.31 0.00 4.00 12.00 2.00 18.00 $873.06 $0.00 184 3,312 $160,643Develop documentation of compliance with location standards 0.00 0.00 2.00 0.50 2.50 $92.73 $0.00 86 215 $7,975Prepare information allowing the Director to carry out other Federalobligations0.00 1.00 4.00 2.00 7.00 $293.04 $0.00 86 602 $25,201Prepare the solid waste management unit information 0.00 0.25 4.00 0.25 4.50 $189.62 $0.00 86 387 $16,307Prepare and sign the certification of compliance with part 267 0.10 0.10 0.10 0.17 0.47 $26.84 $0.00 184 86 $4,939If receiving waste from off-site, obtain infomration documenting sameownership0.17 0.10 0.00 0.10 0.37 $28.47 $0.00 25 9 $712Prepare a schedule of compliance with part 267 0.17 0.25 2.00 0.50 2.92 $131.65 $0.00 9 26 $1,185Submit the above information to the Director 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 184 92 $2,828Read the regulations 0.00 0.50 0.50 0.00 1.00 $62.77 $0.00 86 86 $5,398Prepare and maintain a general description of the facility 0.00 2.00 15.00 2.00 19.00 $825.38 $0.00 2 38 $1,651Prepare and maintain a justification for any modification of the preparednessand prevention requirements 0.00 0.00 0.50 0.50 1.00 $31.71 $0.00 9 9 $285Prepare and maintain a description of the procedures, structures, andequipment used at the facility 0.00 0.25 4.00 0.50 4.75 $195.30 $0.00 86 409 $16,796Prepare and maintain a description of traffic patterns, estimated volumes,and controls near the facility 0.00 0.10 1.00 0.15 1.25 $52.58 $0.00 86 108 $4,522Obtain and maintain a topographic map 0.00 0.00 11.00 0.50 11.50 $458.85 $20.00 2 23 $958Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 85 43 $2,668Prepare and maintain a description of the containment system 0.00 1.00 4.80 0.40 6.20 $289.22 $1,233.33 85 527 $129,417Prepare and maintain a demonstration of compliance with Section267.175(c)0.00 0.30 2.40 0.20 2.90 $127.64 $500.00 85 247 $53,349Obtain and maintain sketches, drawings, or data demonstrating compliancewith Sections 267.174 & 267.175(c) 0.00 1.00 5.00 0.50 6.50 $299.63 $500.00 85 553 $67,969Prepare and maintain a description of the procedures used to ensurecompliance with Sections 267.175(a) & (b) 0.00 1.30 16.80 1.30 19.40 $823.29 $700.00 85 1,649 $129,480Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 71 36 $2,229Document and maintain the dimensions and capacity of each tank 0.00 3.00 12.00 1.00 16.00 $765.47 $2,000.00 71 1,136 $196,348Prepare and maintain a description of feed systems, safety cutoff, bypasssystems, and pressure controls 0.00 0.00 3.00 1.00 4.00 $144.77 $500.00 71 284 $45,779Prepare and maintain a diagram of piping, instrumentation, and a processflow of each tank system 0.00 3.00 12.00 1.00 16.00 $765.47 $500.00 71 1,136 $89,848Prepare and maintain a detailed description of how new tank systems will beinstalled in compliance with Section 267.194 0.00 0.00 4.00 0.50 4.50 $174.09 $500.00 14 63 $9,437Prepare and maintain detailed plans for containment systems 0.00 1.00 5.00 0.40 6.40 $297.35 $1,200.00 71 454 $106,312Prepare and maintain a description of controls and practices to preventspills and overflows0.00 0.00 3.00 0.50 3.50 $133.41 $0.00 71 249 $9,472Prepare and maintain a description of operating procedure compliance forignitable, reactive, or incompatible wastes 0.00 2.00 15.00 2.00 19.00 $825.38 $0.00 71 1,349 $58,602Total Hours and CostsO&MCost/YearNumber ofRespondentsTotalHours/ YearHours and Costs per RespondentLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearINFORM ATION COLLECTION ACTIVITYContainer Information Requirements (270.300)Total Costs/YearGeneral Info rmatio n R equirements (124.202, 270.275, 270.280, & 270.285)Tank Information Requirements (270.305)Record Keeping Requirements (270.290)79EXH IB IT 1 C o n't.STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTAP P LYING FOR A STANDARDIZED P ERM ITTotal Hours and CostsO&MCost/YearNumber ofRespondentsTotalHours/ YearHours and Costs per RespondentLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearINFORM ATION COLLECTION ACTIVITYTotal Costs/YearRead the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 1 1 $31M aintain the equipment identification number and hazardous wastemanagement unit identification 0.00 0.25 0.25 0.10 0.60 $33.66 $0.00 1 1 $34Prepare and maintain approximate locations within the facility 0.00 0.25 0.25 0.10 0.60 $33.66 $0.00 1 1 $34Prepare and maintain descriptions of the type of equipment 0.00 0.50 3.00 0.50 4.00 $175.84 $0.00 1 4 $176Prepare and maintain descriptions of the percent by weight of total organicsin the hazardous waste stream at the equipment 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 1 2 $68Prepare and maintain descriptions of the hazardous waste state at theequipment0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 1 2 $68Prepare and maintain descriptions of the methods of compliance 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 1 2 $68Prepare and maintain an implementation schedule for compliance with Part264 subpart BB requirements 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 1 2 $68Develop and maintain a performance test plan 0.00 1.00 7.00 2.00 10.00 $415.08 $0.00 1 10 $415Develop and maintain documentation that demonstrates compliance withequipment standards 0.00 1.00 16.00 2.00 19.00 $781.20 $0.00 1 19 $781Develop and maintain documentation to demonstrate compliance withSection 264.10600.00 0.50 2.00 0.50 3.00 $135.16 $0.00 1 3 $135Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 2 1 $63Prepare and maintain documentation for floating roof covers 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 2 1 $63Prepare and maintain a certification that covers meet applicable designspecifications0.00 0.25 0.50 0.00 0.75 $41.56 $0.00 2 2 $83Prepare and maintain identification and certifications for container areas 0.00 0.25 0.50 0.00 0.75 $41.56 $0.00 2 2 $83Prepare and maintain documentation for enclosures used to control airpollutant emissions from tanks or containers 0.00 0.10 0.15 0.00 0.25 $14.59 $0.00 2 1 $29Prepare and maintain documentation for closed-vent systems and controldevices0.00 0.10 0.15 0.00 0.25 $14.59 $0.00 2 1 $29Develop and maintain emission monitoring plans and control devicemonitoring methods 0.00 3.00 6.00 2.00 11.00 $544.12 $0.00 2 22 $1,088Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 83 42 $2,605Prepare and submit the request to the Director 0.50 1.00 2.00 0.50 4.00 $229.68 $4.00 83 332 $19,395Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 0 $0Prepare and submit the notice of intent 0.50 1.00 2.00 0.50 4.00 $229.68 $4.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 2,612 13,907 $ 1,194,859Equipment Info rmatio n R equirements (270.310)R eapplying fo r a Standardized P ermit (270.10(h))A ir Emissio ns C o ntro l R equirements (270.315)Switching fro m an Individual R C R A P ermit to a Standardized P ermit (124.203)80EXHIBIT 2STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTM AINTAINING A STANDARDIZED P ERM ITRead the regulations 2.00 1.00 1.00 0.00 4.00 $333.90 $0.00 18 72 $6,010Prepare and submit revised information to the Director 1.00 1.00 8.00 2.00 12.00 $559.94 $4.00 18 216 $10,151Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 18 27 $1,288Read the regulations 2.00 1.00 1.00 0.00 4.00 $333.90 $0.00 18 72 $6,010Prepare and submit modification request to the Director 1.00 1.00 8.00 2.00 12.00 $559.94 $4.00 18 216 $10,151Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 18 27 $1,288Read the regulations 2.00 1.00 1.00 0.00 4.00 $333.90 $0.00 7 28 $2,337Prepare and submit proof of public notice 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 7 11 $501Prepare and submit the modification request to the Director 5.00 15.00 80.00 12.00 112.00 $5,320.96 $8,000.00 7 784 $93,247TotalVaries Varies Varies Varies Varies Varies Varies 75 1,138 $ 130,983Hours and Costs per RespondentTotal Costs/YearTotalHours/ YearTotal Hours and CostsCler.$ 22.73/HrO&MCost/YearNumber ofRespondentsRespondentHours/YearLaborCost/YearINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrM aking R o utine C hanges (124.212 & 270.320(a))M aking Significant C hanges (124.213 & 270.320(b))M aking R o utine C hanges R equiring P rio r A ppro val (124.213 & 270.320)81EXHIBIT 3STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTGENERAL FACILITY STANDARDSRead the regulations 0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Obtain, fill out, and submit an application for an EPA identification number 0.00 0.25 0.50 0.25 1.00$47.24$4.00 0 0 $0Read the regulations 0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Collect data0.00 0.00 3.00 0.50 3.50$133.41$0.00 0 0 $0Perform waste analysis 0.00 0.00 10.00 0.00 10.00$406.80$1,500.00 0 0 $0Read the regulations 0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Collect the data required for the waste analysis plan 0.0010.00 90.00 9.00 109.00 $4,714.37$0.00 0 0 $0Write the waste analysis plan 0.00 10.00 60.009.00 79.00 $3,493.97$0.00 0 0 $0M aintain the waste analysis plan 0.00 0.00 0.00 1.00 1.00$22.73$0.00 0 0 $0Read the regulations 0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Collect the required documents 0.00 0.00 1.00 0.50 1.50$52.05$0.00 0 0 $0M aintain the required documents 0.00 0.00 0.00 1.00 1.00$22.73$0.00 0 0 $0Read the regulations 0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Prepare the inspection schedule 0.00 8.00 80.00 1.00 89.00$3,956.01$0.00 0 0 $0Record the results of inspections in the inspection log 0.00 0.00 100.00 0.00 100.00$4,068.00$0.00 0 0 $0M aintain the inspection schedule 0.00 0.00 0.00 1.00 1.00$22.73$100.00 0 0 $0Read the regulations 0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Prepare outline of employee training program 0.00 3.00 18.00 3.00 24.00 $1,055.01Collect employee training documentation 0.00 0.50 2.00 0.50 3.00$135.16$0.00 0 0 $0M aintain the employee training documentation 0.00 0.00 0.00 80.00 80.00$1,818.40$100.00 0 0 $0Read the regulations 0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Collect and document compliance 0.00 1.00 40.00 1.00 42.00$1,734.79$0.00 0 0 $0M aintain the compliance documentation 0.00 0.00 0.00 1.00 1.00$22.73$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearObtaining an Identificatio n N umber (267.12)Emplo yee T raining (267.16(d))Ignitable, R eactive, o r Inco mpatible Wastes (267.17(c))Waste A nalysis (267.13(a))Waste A nalysis P lan (267.13(b))Security (267.14(b))Inspectio ns (267.15)82EXHIBIT 4STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTP REP AREDNESS AND P REVENTIONRead the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 0 0 $0Document any refusals of local authorities and place in operating record 0.00 0.25 1.00 0.50 1.75 $73.26 $0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearA rrangements with Lo cal A utho rities (267.36(b))Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrEXHIBIT 5STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTCONTINGENCY P LAN AND EM ERGENCY P ROCEDURESRead the regulations0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Collect the data required in the contingency plan0.00 0.00 12.00 3.00 15.00$556.35$0.00 0 0 $0Write the contingency plan0.00 1.00 60.00 4.00 65.00$2,616.58$0.00 0 0 $0Submit the contingency plan to State and local authorities 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0M aintain the contingency plan0.00 0.00 0.00 1.00 1.00$22.73$0.00 0 0 $0Read the regulations0.00 0.25 0.75 0.00 1.00$51.73$0.00 0 0 $0Submit the notification of an imminent or actual emergency situation to State and/or local authorities 0.00 0.50 0.00 0.00 0.50$42.43$0.00 0 0 $0Notify the on-scene coordinator or the National Response Center of any release 0.00 0.50 0.00 0.00 0.50$42.43$0.00 0 0 $0Collect the information required in the emergency report 0.00 0.00 2.50 0.50 3.00$113.07$0.00 0 0 $0Write the emergency notification report0.00 1.00 0.00 0.00 1.00$84.86$0.00 0 0 $0Collect the information required in the emergency report 0.00 0.00 8.00 0.50 8.50$336.81$0.00 0 0 $0Write the emergency report0.00 0.25 4.00 0.50 4.75$195.30$0.00 0 0 $0Compile information that demonstrates that all affected areas are in compliance 0.00 0.00 2.50 0.50 3.00$113.07$0.00 0 0 $0Prepare a letter notifying the Regional Administrator of compliance 0.00 0.25 1.50 0.25 2.00$87.92$0.00 0 0 $0Record the details of any incident that requires implementing the contingency plan in the operating record 0.00 0.00 0.50 0.25 0.75$26.02$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Tech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearEmergency R epo rting (267.56(c), 267.58(a) & (b))Number ofRespondentsTotalHours/ YearTotal Costs/YearC o ntingency P lan (267.51-54)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/Hr83EXHIBIT 6STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTRECORD KEEP ING, REP ORTING, AND NOTIFYINGM aintain documents in the facility operating record 0.00 0.00 50.00 100.00 150.00 $4,307.00 $0.00 0 0 $0Read the regulations 0.00 0.10 0.25 0.00 0.35 $18.66 $0.00 0 0 $0Prepare and submit written notification to new owner or operator 0.00 0.00 0.50 0.13 0.63 $23.29 $0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Tech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNotifications (267.74)Number ofRespondentsTotalHours/ YearTotal Costs/YearR eco rd Keeping (267.71)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrEXHIBIT 7STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTCLOSURERead the regulations 0.00 0.50 3.00 0.00 3.50$164.47$0.00 0 0 $0Conduct a hazardous waste inventory 0.00 0.00 8.00 0.00 8.00$325.44$0.00 0 0 $0Record the results of the hazardous waste inventory 0.00 0.00 2.00 0.50 2.50$92.73$0.00 0 0 $0Write a description for the necessary closure activities 0.00 1.00 20.00 3.00 24.00$966.65$0.00 0 0 $0Estimate final closure 0.001.00 8.00 1.00 10.00 $433.03$0.00 0 0 $0Write the closure schedule 0.00 0.50 1.00 0.50 2.00$94.48$0.00 0 0 $0Read the regulations 0.00 0.10 0.25 0.00 0.35$18.66$0.00 0 0 $0Prepare the written notification of closure 0.00 0.25 0.50 0.25 1.00$47.24$4.00 0 0 $0Submit the closure plan 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Read the regulations 0.00 0.10 0.25 0.00 0.35$18.66$0.00 0 0 $0Prepare the certification 0.00 0.00 11.00 2.00 13.00$492.94$500.00 0 0 $0Submit the certification 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0C lo sure P lan (267.112)N o tificatio n B efo re P artial C lo sure and F inal C lo sure (267.112(c))O&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearCertification of ClosureHours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/Year84EXHIBIT 8STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTFINANCIAL REQUIREM ENTSRead the regulations covering financial requirements8.00 2.00 8.00 0.00 18.00$1,328.60$0.00 0 0 $0Prepare a detailed estimate of closure costs0.00 0.00 10.00 3.00 13.00$474.99$0.00 0 0 $0Update the estimate for inflation annually0.00 0.00 0.50 0.00 0.50$20.34$0.00 0 0 $0M aintain the estimate at the facility (under record keeping)0.00 0.00 0.00 0.00 0.00$0.00$0.00 0 0 $0Establish a closure trust fund4.00 1.50 2.00 0.50 8.00$636.74$0.00 0 0 $0Submit a signed duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Submit a receipt for the first payment to the Regional Administrator 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Establish a surety bond and trust agreement4.00 1.50 2.00 0.50 8.00$636.74$0.00 0 0 $0Submit originally signed duplicates of the surety bond and trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Obtain a surety bond and trust agreement4.00 1.50 2.00 0.50 8.00$636.74$0.00 0 0 $0Submit signed duplicates of the surety bond and trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Obtain a letter of credit and establish a stand-by trust fund4.00 1.50 2.00 0.50 8.00$636.74$0.00 0 0 $0Submit the letter of credit and a duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Obtain a closure insurance policy4.00 1.50 2.00 0.50 8.00$636.74$0.00 0 0 $0Submit a certificate of the insurance policy to the Regional Administrator 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Prepare and submit the letter signed by the chief financial officer 1.00 0.25 2.00 0.75 4.00$223.80$4.00 0 0 $0Submit a copy of the independent certified public accountant's report and special report 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Submit updated information annually0.00 0.00 0.00 4.00 4.00$90.92$4.00 0 0 $0Prepare and submit a notice of intent to establish alternate financial assurance to the Regional Administrator 3.25 0.25 0.00 0.50 4.00$371.17$4.00 0 0 $0Write and submit additional reports of the facility's financial condition, as directed by the Regional Administrator 2.25 0.25 1.00 0.50 4.00$307.67$4.00 0 0 $0Submit the corporate guarantee from the parent corporation 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearReading the RegulationsC o st Estimate fo r C lo sure (267.142(a)-(c))C lo sure T rust F und (267.143(a))Surety B o nd Guaranteeing P ayment into a C lo sure T rust F und (267.143(b))Surety B o nd Guaranteeing P erfo rmance o f C lo sure (267.143(c))C lo sure Letter o f C redit (267.143(d))C o rpo rate F inancial T est and C o rpo rate Guarantee (267.143(f) & (g))C lo sure Insurance (267.143(e))85EXHIBIT 8 Con't.STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTFINANCIAL REQUIREM ENTSHours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearSubmit required information to the Regional Administrator0.50 1.00 0.50 2.00 4.00$202.75$4.00 0 0 $0Submit evidence of financial assurance to all other applicable Regional Administrators 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Establish a trust fund4.50 1.50 1.00 1.00 8.00$659.51$0.00 0 0 $0Submit a duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Obtain a surety bond and submit a copy to the Regional Administrator 4.00 1.00 2.00 1.00 8.00$605.67$4.00 0 0 $0Obtain a standby letter of credit and submit a copy to the Regional Administrator 4.00 1.00 2.00 1.00 8.00$605.67$4.00 0 0 $0Obtain an insurance policy and submit documentation to the Regional Administrator 4.00 1.00 2.00 1.00 8.00$605.67$4.00 0 0 $0Prepare, write, and submit the letter signed by the chief financial officer 1.00 0.25 2.00 0.75 4.00$223.80$4.00 0 0 $0Obtain and submit the report and special report from the independent certified public accountant 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Submit updated information annually0.00 0.00 0.00 4.00 4.00$90.92$4.00 0 0 $0Prepare and submit a notice of intent to establish alternate financial assurance to the Regional Administrator 3.25 0.25 0.00 0.50 4.00$371.17$4.00 0 0 $0Obtain and submit a written guarantee to the Regional Administrator 0.50 0.50 0.50 0.50 2.00$126.23$4.00 0 0 $0Submit a letter from the guarantor's chief financial officer0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Submit updated information annually0.00 0.00 0.00 4.00 4.00$90.92$4.00 0 0 $0Submit by certified mail a notice of bankruptcy to the Regional Administrator 0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Prepare and submit a letter from the owner or operator to the Regional Administrator 1.00 5.00 2.00 0.50 8.50$621.21$4.00 0 0 $0Obtain and submit the letter from the State0.00 0.00 0.00 1.00 1.00$22.73$4.00 0 0 $0Prepare and submit any additional information requested by the Regional Administrator 0.75 0.25 0.75 0.25 2.00$135.54$4.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Use o f a F inancial A ssurance Instrument fo r M ultiple F acilities (267.143(i))Incapacity o f Owners o r Operato r, Guaranto rs, o r F inancial Institutio ns (267.148)State A ssumptio n o f R espo nsibility (267.150)T rust F und fo r Liability C o verage (267.147(a)(3))Surety B o nd fo r Liability C o verage (267.147(a)(2))Letter o f C redit fo r Liability C o verage (267.147(a)(3))Liability Insurance (267.147(a)(4))F inancial T est fo r Liability C o verage (267.147(a)(5) & 267.147(f))C o rpo rate Guarantee fo r Liability C o verage (267.147(g)86EXHIBIT 9STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTSP ECIFIC UNIT REQUIREM ENTSRead the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Prepare the no free liquids demonstration 0.00 0.00 1.50 0.00 1.50$61.02$475.00 0 0 $0Perform weekly inspections and record results 0.00 0.00 100.00 0.00 100.00$4,068.00$0.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Obtain an engineer's written assessment 0.00 3.00 12.00 1.00 16.00$765.47$2,000.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Obtain the written statements0.00 0.00 7.00 1.50 8.50$318.86$1,000.00 0 0 $0M aintain the written statements at the facility 0.00 0.00 0.00 0.10 0.10$2.27$4.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Develop an inspection schedule0.00 8.00 80.00 1.00 89.00$3,956.01$0.00 0 0 $0Perform daily inspections and record the results 0.00 0.00 100.00 0.00 100.00$4,068.00$0.00 0 0 $0Perform annual inspections of cathodic protection system and record the results 0.00 0.00 20.00 0.00 20.00$813.60$0.00 0 0 $0Perform bimonthly inspections of sources of impressed current and record the results 0.00 0.00 40.00 0.00 40.00$1,627.20$0.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Prepare and submit a report to the Regional Administrator (within 24 hours of leak detection) 0.00 0.00 0.25 0.00 0.25$10.17$4.00 0 0 $0Prepare and submit a report to the Regional Administrator (within 30 days of leak detection) 0.00 1.00 7.50 1.00 9.50$412.69$4.00 0 0 $0Obtain and submit an engineer's certification 0.00 0.00 0.00 0.50 0.50$11.37$4.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Inspect data weekly and record the results 0.00 0.00 26.00 0.00 26.00$1,057.68$0.00 0 0 $0Read the regulations0.00 0.25 0.25 0.50 1.00$42.75$0.00 0 0 $0Prepare the free liquids demonstration1.00 1.00 2.00 0.50 4.50$281.77$1,500.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Prepare and maintain a written description of operating procedures 0.00 0.00 1.00 0.25 1.25$46.36$0.00 0 0 $0Read the regulations0.00 0.25 0.25 0.00 0.50$31.39$0.00 0 0 $0Enter a record of the discovery in the operating record 0.00 0.00 0.50 0.00 0.50$20.34$0.00 0 0 $0Prepare and submit a notification to the Director within 7 days 0.00 0.00 0.50 0.00 0.50$20.34$4.00 0 0 $0Prepare and submit a written notification within 14 days 0.00 0.00 0.50 0.25 0.75$26.02$4.00 0 0 $0Prepare and submit the written verification to the Director 0.00 0.50 0.00 0.25 0.75$48.11$4.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearInspectio n R equirements (267.199)Number ofRespondentsTotalHours/ YearTotal Costs/YearInspectio n R equirements (267.172 & 267.15(d))CONTAINERSTANK SYSTEM SA pplicability (267.190)D esign and C o nstructio n Standards (267.191)Installatio n R equirements (267.194)CONTAINM ENT BUILDINGSR eleases o f H azardo us Waste (267.1106)Leaks and Spills (267.200)A dditio nal Standards fo r Liquid Sto rage (267.1103(d))Waiver fro m Seco ndary C o ntainment R equirements (267.1104)C o ntainment B uildings with A reas B o th with and witho ut Seco ndary C o ntainment (267.1105)87EXH IB IT 10STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTAP P LYING FOR A STANDARDIZED P ERM ITReview the notice of intent and supporting information, and make a determination 20.00 1.00 40.00 0.00 61.00$3,125.02$0.00 184 11,224$575,004Enter information into a database 0.00 0.00 0.00 0.50 0.50$11.72$0.00 184 92$2,156TotalVaries Varies VariesVaries Varies Varies Varies 368 11,316$577,160Tech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearA pplying fo r a Standardized P ermit (124.204, 270.275, 270.280, & 270.285)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrEXH IB IT 11STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTM AINTAINING A STANDARDIZED P ERM ITReview the information submitted by the permittee 0.00 0.25 1.00 0.00 1.25$52.30$0.00 18 23$941Review the modification request and supporting information 20.00 1.00 20.00 30.00$2,353.827 427$16,477Review the modification request and supporting information 20.00 1.00 40.00 0.00 61.00$3,125.02$0.00 7 427$21,875Review proof of public notice 0.00 0.25 1.00 0.00 1.25$52.30$0.00 7 9$366Enter information into a database 0.00 0.00 0.00 0.50 0.50$11.72$0.00 7 4$82Total Varies Varies VariesVaries Varies Varies Varies 39 463$39,741Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearSignificant C hanges (124.213 & 270.320(b))Number ofRespondentsTotalHours/ YearTotal Costs/YearR o utine C hanges (124.212 & 270.320(a))R o utine C hanges with prio r appro val (124.213 & 270.320)88EXH IB IT 12STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTGENERAL FACILITY STANDARDSIssue an identification number (to new facilities) and enter the facility into the hazardouswaste facility data system0.00 0.25 2.00 0.50 2.75$102.58$0.00 0 0 $0Review the security procedures and inspect the security system during an on-siteinspection0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0Review the information submitted by permittees seeking a waiver from the securityrequirements and make a determination0.00 0.25 0.50 0.00 0.75$33.02$0.00 0 0 $0Review the demonstration of compliance with location factors0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0Review information submitted by permittees seeking a waiver from the location standardsand make a determination0.00 0.25 2.00 0.00 2.25$90.86$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/H rRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotalCosts/ YearGeneral F acility Standards (267.12, 267.14, & 267.18)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/H rM gr.$ 84.86/H rTech.$ 40.68/H rEXH IB IT 13STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTP REP AREDNESS AND P REVENTIONIf necessary, review during inspections the documentation of anyrefusals of local authorities to enter into emergency arrangements0.00 0.00 0.25 0.00 0.25$9.64$0.00 0 0 $0Total Varies Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearA greements with Lo cal A utho rities (267.36)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/Hr89EXH IB IT 14STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTCONTINGENCY P LAN AND EM ERGENCY P ROCEDURESReview the contingency plan during on-site inspections0.00 0.00 0.50 0.00 0.50$19.28$0.00 0 0 $0Review emergency reports0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearC o ntingency P lan and Emergency R epo rting (267.51-54, 267.55, & 267.58)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrEXH IB IT 15STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTRECORD KEEP ING, REP ORTING, AND NOTIFYINGReview the facility operating record during on-site inspections0.00 0.00 2.00 0.00 2.00$77.12$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearR eco rd keeping (267.71)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/Hr90EXH IB IT 16STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTCLOSUREReview all closure plans, closure plan amendment notifications, partial/finalclosure notifications, and closure certifications0.00 0.00 15.00 0.00 15.00$578.40$0.00 0 0 $0Review the closure plan amendment notifications 0.00 0.00 2.00 0.00 2.00$77.12$0.00 0 0 $0Review the partial/final closure notifications 0.00 0.00 2.00 0.00 2.00$77.12$0.00 0 0 $0Review the closure certifications 0.00 0.00 4.00 0.00 4.00$154.24$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearC lo sure (267.112)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/Hr91EXH IB IT 17STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTFINANCIAL REQUIREM ENTSReview closure cost estimates, demonstrations of financial assurance forclosure, and demonstrations of financial assurance for liability4.00 1.00 16.00 0.00 21.00$977.44$0.00 0 0 $0Enter the information into the RCRIS database 0.00 0.00 0.00 0.25 0.25$5.86$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Cler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearNumber ofRespondentsTotalHours/ YearTotal Costs/YearF inancial R equirements (267.142, 267.143, 267.147, 267.148, & 267.150)Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrEXH IB IT 18STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTSP ECIFIC UNIT REQUIREM ENTSReview inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0Review notifications and detailed reports on releases to the environment 0.00 0.00 4.00 0.00 4.00$154.24$0.00 0 0 $0Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0Review notifications on any releases to the environment 0.00 0.00 0.25 0.00 0.25$9.64$0.00 0 0 $0Review documentation submitted to support requests for secondarycontainment requirement waivers0.00 0.25 1.00 0.25 1.50$58.16$0.00 0 0 $0Review inspection records, if necessary, during on-site inspections0.00 0.00 1.00 0.00 1.00$38.56$0.00 0 0 $0TotalVaries Varies Varies Varies Varies Varies Varies 0 0 $ 0Hours and Costs per Respondent Total Hours and CostsINFORM ATION COLLECTION ACTIVITYLeg.$ 104.18/ H rM gr.$ 84.86/HrTech.$ 40.68/HrCler.$ 22.73/HrRespondentHours/YearLaborCost/YearO&MCost/YearT ank Systems (267.200)C o ntainment B uildings (267.1104 & 267.1106)Number ofRespondentsTotalHours/ YearTotal Costs/YearUse and M anagement o f C o ntainers (267.15 & 267.172)92 EXH IB IT 19

STANDARDIZED P ERM ITS

TOTAL ESTIM ATED ANNUAL RESP ONDENT BURDEN AND COST SUM M ARY

Exhibit T itle Annual

Burden Annual

Labor Cost Annual Capital/ Startup Cost Annual

O&M Cost Total

Annual

Cost

Exhibit 1 Applying for a Standardized Permit 13,907 $638,506 $156 $555,641 $1,194,303

Exhibit 2 M aintaining a Standardized Permit 1,138 $57,362 $0 $56,172 $113,534

Exhibit 3 General Facility Standards 0 $0 $0 $0 $0 Exhibit 4 Preparedness and Prevention 0 $0 $0 $0 $0 Exhibit 5 Contingency Plan and Emergency Procedures 0 $0 $0 $0 $0 Exhibit 6 Record Keeping, Reporting, and Notifying 0 $0 $0 $0 $0
Exhibit 7 Closure 0 $0 $0 $0 $0 Exhibit 8 Financial Requirements 0 $0 $0 $0 $0 Exhibit 9 Specific Unit Requirements 0 $0 $0 $0 $0

Annual Total 15,045 $695,868 $156 $611,813 $1,307,837

EXHIBIT 20

STANDARDIZED P ERM ITS

TOTAL ESTIM ATED ANNUAL AGENCY BURDEN AND COST SUM M ARY

Exhibit T itle Annual

Burden Annual

Labor Cost Annual Capital/ Startup

Cost Annual

O&M Cost Total

Annual

Cost

Exhibit 10 Applying for a Standardized Permit 11,316 $577,160 $0 $0 $577,160

Exhibit 11 M aintaining a Standardized Permit 463 $39,146 $0 $0 $39,146

Exhibit 12 General Fac ility Standards 0 $0 $0 $0 $0 Exhibit 13 Preparedness and Prevention 0 $0 $0 $0 $0 Exhibit 14 Contingency Plan and Emergency Procedures 0 $0 $0 $0 $0 Exhibit 15 Record Keeping, Reporting, and Notifying 0 $0 $0 $0 $0
Exhibit 16 Closure 0 $0 $0 $0 $0 Exhibit 17 Financial Requirements 0 $0 $0 $0 $0 Exhibit 18 Specific Unit Requirements 0 $0 $0 $0 $0

Annual Total 11,779 $616,306 $0 $0 $616,306