SUPPORTING STATEMENT 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, CONSULTATIONS, 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 THE INFORMATION REQUESTED 

4(a) Respondents and NAICS Codes .................................................................. 16 

4(b) Information Requested ................................................................................ 17 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION 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 Burden 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 ........................................................................................ 77
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1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title and Number of the Information Collection 

 “Standardized Permit for RCRA Hazardous Waste 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 waste permitting program to allow a “standardized 

permit”. The standardized permit would be available to facilities that generate hazardous waste 

and routinely manage the waste on-site in non-thermal units such 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 treat the hazardous waste in containers, tanks, or 

containment buildings. The RCRA standardized permit would consist 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 uniform 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 also issue a supplemental portion on 

a case-by-case basis. The supplemental portion would impose site-specific permit terms and 

conditions that the Director determines necessary to institute corrective action under section 

264.101 (or State equivalent), or otherwise necessary 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 description 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 STANDARDIZED PERMIT

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

must submit to the Director a written notice of his or her intent to operate under the standardized 

permit. Along with this notice of intent, section 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 part 267) that will be used as the basis of the 

standardized permit application. Owners and operators whose facilities are not in compliance 

with part 267 at the time they submit their notice of intent must submit a schedule of compliance 

to the Director. This schedule must include an enforceable sequence of actions with milestones, 
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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 facilities. This information includes, among other 

things, a general description of the facility; a copy of the waste analysis plan and chemical and 

physical analyses of the hazardous waste and hazardous debris handled at the facility; a copy of 

the general inspection schedule; a copy of the contingency plan; a description of employee 

training programs; a copy of the closure plan; and documentation showing compliance with 

liability requirements. The unit-specific record keeping requirements are: 

• Owners and operators that store or treat hazardous waste in containers must keep at their 

facility information on the design and operation of the container storage area, including 

its containment system. In addition, they must keep information demonstrating 

compliance with special requirements for ignitable 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 store or treat hazardous waste in tanks must keep at their 

facility tank system information. This information 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 equipment leaks) must keep at their facility 

information required for that type of equipment. These information requirements concern 

emission standards for equipment that contains or comes in contact with hazardous waste 

with organic concentrations of at least 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 containers subject to part 264, subpart CC (air 

emission standards for tanks, surface impoundments, and containers). These information 

requirements concern compliance with air emission controls that apply to facilities 

managing hazardous waste in tanks and containers. (section 270.315) 

Finally, section 270.10(h) requires owners and 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 STANDARDIZED PERMIT

Sections 124.211, 124.212, 124.213, and 124.214 specify procedures for making routine, 

routine with prior approval, and significant changes to the standardized 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, Appendix I) to their standardized permits to 
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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 operators seeking to make routine 

changes with prior approval to submit their requests to the Director for approval and follow the 

procedures in section 124.212(b)(1) - (2). Section 124.214 requires owners and operators 

seeking to make significant changes 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 request to the Director. 

GENERAL FACILITY STANDARDS

40 CFR part 267, subpart B (sections 267.10 through 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 obtain an 

EPA identification number (section 267.12) and follow requirements for waste analyses (section 

267.13); security (section 267.14); inspections (section 267.15); employee training (section 

267.16); management of ignitable, reactive, or incompatible wastes (section 267.17); and facility 

location (section 267.18). EPA enables owners and operators to apply for a waiver from the 

security requirements if they believe that physical 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 operators of facilities that treat or store 

hazardous waste under a standardized permit must design, construct, maintain, and operate their 

facilities to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden 

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

could threaten human health or the environment. Specifically, section 267.36 states that the 

owners and operators of these facilities must attempt to make arrangements with the police, fire 

departments, emergency response teams, and hospitals, as appropriate for the type of waste 

handled at the facility and the potential need for services of these organizations. If State or local 

authorities decline to enter into such arrangements, 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 prepare and maintain updated contingency 

plans and comply with emergency reporting and record keeping requirements. The contingency 

plan describes the actions facility personnel will take should a fire, explosion, 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 to 
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minimize unanticipated damage from the treatment, storage, or disposal 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 authorities of an imminent or actual emergency 

situation (267.56(a)(2), and notifying local authorities of the need to evacuate local areas 

(267.56(c)(1)). If a release, fire, or explosion occurs, the owner or operator must notify the onscene coordinator or the National Response Center (267.56(c)(2)). Owners and operators also 

must notify the Regional Administrator that a facility 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 Administrator containing details of any emergency situation that requires 

implementation of the contingency 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 that treat or store hazardous waste under a standardized permit to keep 

written operating records at their facilities. Since the operating record is not submitted to EPA 

but must be available for inspection, maintaining an operating record is a record keeping activity. 

The operating record contains information regarding general operating practices conducted at the 

facility. Other record keeping requirements under 40 CFR part 267, subpart E, include 

maintaining records of the location of each hazardous waste within the facility and the quantity 

at each location (267.71(b)(2)). In addition, 40 CFR 267.36(b) requires facilities to document in 

the operating record any refusal of State or local authorities to enter into arrangements for 

emergency situations. Information collected pursuant 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 and 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, owners 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 transferring ownership or operation of a facility 

during its operating life, an owner 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 waste under a standardized permit 

must follow when closing storage and treatment units and/or when closing the facility. Storage 
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and treatment units must be closed in a manner that minimizes need for further maintenance and 

controls, minimizes, or eliminates, to the extent necessary to protect human health and the 

environment, post-closure escape of hazardous waste, hazardous constituents, leachate, 

contaminated runoff, or hazardous waste decomposition products to the ground or surface waters 

or to the atmosphere (section 267.111). To close a facility, the owner or operator must have an 

approved closure plan and follow notification requirements (section 267.112). In addition, 

owners and operators are required to submit to the Director a certification of closure within 60 

days of the completion of final closure of each unit under a standardized permit (section 

267.117). 

EPA uses closure plans to ensure that hazardous waste management facilities close in 

accordance with the Congressional mandate of protecting human health and the environment. 

EPA reviews closure certifications to determine whether closure took place in accordance with 

the approved closure plan and EPA, local authorities, 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 operators 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 for closure (section 267.143), and demonstrate 

financial assurance for liability (section 267.147). Owners and operators also 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 responsibility) (section 267.148). 

Finally, owners and operators are required to notify EPA when a State assumes legal 

responsibility or assures availability 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 through 267.177) specifies the standards for 

the use and management of containers under a standardized 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 emissions 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 these inspections, owners 

and operators should look for leaking containers and for deterioration of containers and the 

containment system caused by corrosion or other factors. 

TANK SYSTEMS
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40 CFR part 267, subpart J (sections 267.190 through 267.204) specifies the standards for 

above-ground and on-ground tanks used for the treatment or storage of hazardous waste under a 

standardized permit. These standards require record keeping and reporting associated with 

demonstrations for secondary containment waivers (section 267.190), design and construction 

standards (section 267.191), installation 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 incompatible wastes (sections 267.202 and 267.203), 

and control of air emissions (section 267.204). 

CONTAINMENT BUILDINGS

40 CFR part 267, subpart DD (sections 267.1100 through 267.1108) specifies standards 

applicable to containment buildings under a standardized permit. These standards require record 

keeping and reporting associated with inspections (section 267.1103); demonstrations for 

secondary containment requirement waivers (section 267.1104); containment buildings 

containing areas both with and without secondary 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 authority for each type of information collection 

analyzed in this ICR. Information collection 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 gives 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 wastes and make such information available to the 

government for the purposes of enforcing the provisions of this chapter. EPA believes the 

information collection requirements are necessary to balance the reduction in regulatory burden 

with the Agency’s responsibility to protect human health and the environment. 

APPLYING FOR A STANDARDIZED PERMIT

Section 270.275 requires that applicants for a standardized permit submit to the 

permitting agency information that will be used as the basis of the standardized permit 

application. This information includes: 

• Part A permit information required by section 270.13; 

• A summary of the pre-application public meeting and other materials required by section 

124.31; 
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• Documentation of compliance with the location standards of sections 267.18 and 

270.14(b)(11); 

• Information that allows the Director to carry out his obligations under other Federal laws 

required in section 270.3; 

• Solid waste management unit information required by section 270.14(d); and 

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

270.280. 

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

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

• The most recent closure cost estimate for your facility prepared under §267.142 and a 

copy of the documentation required to demonstrate financial assurance under §267.143. 

For a new facility, you may gather the required documentation 60 days before the initial 

receipt of hazardous wastes.

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

• Documentation showing that the same person owns both the waste generator and 

receiving facility, if you manage waste generated off-site

EPA needs this information to comprehensively 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 environment from hazardous waste management 

facilities. 

In addition, facilities that store or treat hazardous waste under a standardized permit must 

keep at their facilities general types of information (section 270.290), as well as unit-specific 

information for containers (section 270.300), tanks (section 270.305), equipment subject to part 

264, subpart BB (section 270.310), and tanks and containers 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 other equipment are in good condition and that operating requirements 

are being satisfied, and to prevent placing in proximity wastes that are incompatible with other 

wastes that are likely to ignite or explode. EPA needs this information to evaluate 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. 

MAINTAINING A STANDARDIZED PERMIT
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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 (Class 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 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). Sections 124.213 requires owners and operators seeking to make routine changes with 

prior approval to submit their requests for changes to the Director for approval and follow the 

procedures in section 124.212(b)(1) - (2). Section 124.214 requires owners and operators 

seeking to make significant changes 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 request to the Director. 

EPA needs this information to comprehensively evaluate whether requests for routine or 

significant changes should be granted. The permit modification procedures contribute to EPA’s 

goal of providing a role for the public in the permitting process. In general, these informational 

requirements aid in meeting EPA’s goal of ascertaining and minimizing risks to human health 

and the environment from hazardous waste management facilities. 

GENERAL FACILITY STANDARDS

40 CFR part 267, subpart B (sections 267.10 through 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 waste analyses (section 267.13); security (section 

267.14); inspections (section 267.15); employee training (section 267.16); management of 

ignitable, reactive, or incompatible wastes (section 267.17); and facility location (section 

267.18). 

(1) Waste Analyses

EPA and owners and operators use information 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 there are any potential dangers from handling the 

waste. 

(2) Security

EPA uses information on security to ensure that the owner and operator 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. 
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(3) Inspections

EPA and owners and operators use information in the inspection log to determine 

whether facility equipment is safe for handling 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 information in employee training records to 

determine whether employees have acquired the necessary expertise to perform their jobs. EPA 

also reviews personnel records to determine whether employees are receiving a level of training 

that is commensurate with their duties and responsibilities 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 personnel record keeping requirement contributes to 

EPA's goal of minimizing the potential 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 facilities are operating in a manner that is protective 

of human health and the environment. The documentation requirement contributes to EPA's goal 

of minimizing unanticipated damage from the treatment, storage, or disposal of hazardous waste. 

(6) Facility Location

EPA and owners and operators use site-specific 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) specifically requires owners and operators to document any refusal on the part 

of any local authorities to enter into an arrangement to handle emergencies. EPA and the owner 
10 

and operator of a facility use this information to ensure that adequate emergency response 

personnel are available, if needed, and to document that all necessary arrangements with State or 

local authorities have been made. 

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Section 3004(a)(5) of RCRA, as amended, requires 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 and maintain contingency plans, 

and to notify State and local authorities and prepare and emergency reports whenever an 

imminent or actual emergency situation occurs. 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 hazardous waste or hazardous constituents to air, 

soil, or surface water. Notifications to State and local authorities facilitate remedial actions and 

evacuations, if necessary. Requiring facilities to develop and maintain contingency plans and 

prepare emergency response reports and notifications contributes to EPA's goal of minimizing 

unanticipated damage from the treatment, storage, or disposal of hazardous waste. 

RECORD KEEPING, REPORTING, AND NOTIFYING

Section 267.70 through 267.74 direct owners or operators 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 things, 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; summary reports and details of all 

incidents that require implementing the contingency plan; and records and results of inspection 

reports. EPA uses information collected pursuant 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 particular 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 likely to ignite or explode. Requiring facilities to 

develop and maintain an operating record and conduct the record keeping activities contributes 

to EPA's goal of minimizing damage to the environment 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 plans, amend these plans when appropriate, and submit to EPA 

closure certifications. EPA reviews information in the closure plans to determine whether 

closure activities will comply with the regulatory requirements. EPA uses information in the 
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closure certifications to determine that closure took place in accordance with the approved 

closure plan. 

FINANCIAL REQUIREMENTS

Section 3004(a)(6) of the Resource Conservation and Recovery 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 qualifications as to ... 

financial responsibility (including financial responsibility for corrective action) as may be 

necessary or desirable." 

The need for financial assurance of closure care is indicated by the 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 increased by the fact that the costs for 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 financial assurance. Consequently, 

the Agency developed 40 CFR part 267, subpart H financial responsibility requirements for 

closure care. 

The liability requirements are designed to assure that funds will be available during the 

operating life of a facility from which third parties can seek compensation for bodily injury and 

property damage arising from the operation of the facility. The liability requirements are 

necessary for several reasons. First, the requirements provide protection 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 facilities, including payments for bodily injury 

and property damage. In addition, the Agency believes that without liability coverage 

requirements, there would be less public confidence in and greater opposition to proposed and 

existing hazardous waste facilities. 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 facility, and the oversight that insurers provide 

over facility operations. 

USE AND MANAGEMENT OF CONTAINERS

Sections 267.172 and 267.15(d) require owners and 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 SYSTEMS
12 

40 CFR part 267, subpart J specifies record keeping and reporting requirements 

associated with demonstrations for secondary containment waivers (section 267.190), design and 

construction standards (section 267.191), installation requirements (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 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. 

CONTAINMENT BUILDINGS

40 CFR part 267, subpart DD specifies record keeping and reporting requirements 

associated with inspections (section 267.1103); demonstrations for secondary containment 

requirement waivers (section 267.1104); containment 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 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. 

2(b) Practical Utility and Users of the Data

APPLYING FOR A STANDARDIZED PERMIT

EPA uses information submitted by facilities to evaluate exposure potential and minimize 

any risks to human health from hazardous waste management facilities. If EPA determines that a 

facility poses a substantial risk to human health, EPA may request that the Agency for Toxic 

Substances and Disease Registry conduct a health assessment. 

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

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

different types of hazardous waste management units 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 whether it is designed, constructed, and operated 

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

by part 264, subparts BB and CC to ensure compliance with air emission standards. 

MAINTAINING A STANDARDIZED 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. 
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GENERAL FACILITY STANDARDS

EPA uses the information requirements in 40 CFR parts 267 and 270 for owners and 

operators submitting standardized permit applications 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 compliance for ignitable or incompatible wastes, are primarily 

internal record keeping requirements used by owners and operators of facilities to assure that 

they can adequately handle the waste, to assure that the incoming waste is really what the 

generator claims it to be, and to prevent undetected releases or reactions of hazardous waste onsite. Much of the information in the waste analysis plan will also be used to provide a quality 

assurance check on both the generator and the owners' and operators' facilities. Both EPA and 

owners and operators use information in the employee training records to ensure that employees 

acquire the necessary expertise to perform their jobs. During inspections, EPA reviews job 

descriptions and training documents to determine whether each person is receiving a level of 

training that is commensurate with the person's duties 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 activities to minimize threats to human health and the environment 

caused by the release of waste from a fire, explosion, or any unplanned event. 

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Local emergency response teams, facility owners 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 whether additional site-specific emergency provisions 

are necessary. 

RECORD KEEPING, REPORTING, AND NOTIFYING

The facility owner or operator 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 ignite 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. Reviewing information in the operating record 

facilitates the owner's or operator's selection of an appropriate corrective action and cleanup 

measure. By providing facility-specific data, the operating record also enables EPA compliance 

officials to determine whether operating requirements can be better tailored to the needs of a 

particular site. 

CLOSURE
14 

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 closure certifications to ensure that the owner or operator closed 

his/her facility according to the specifications outlined in the approved closure plan. EPA uses 

information contained in demonstrations to ensure that any activities taking place during the 

closure period are protective of human health and the environment. 

FINANCIAL REQUIREMENTS

EPA uses the financial insurance information requirements to evaluate the facility 

owner’s financial ability to close the facility and to respond to any contingencies. The closure 

and liability coverage financial instruments submitted 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 financial assurance provider, 

adequacy of the instrument amount, and fulfillment of the other regulatory requirements. The 

information is also used to direct funds for closure 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 during 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 during 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 health and the environment. 

CONTAINMENT BUILDINGS

EPA uses information on containment buildings obtained during facility inspections to 

evaluate the adequacy of each containment 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, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

In finalizing the standardized permit rule, EPA streamlined the permit process by 

allowing certain types of facilities to obtain and modify permits more easily while maintaining 
15 

the protectiveness currently existing in the individual 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 standardized permit rule, we found only one facility 

that had been issued a standardized permit. A consultation was conducted with that one facility, 

BP Exploration in Alaska which received a standardized permit from EPA Region 10. A call 

was conducted on December 1, 2011 with Ms. Colleen 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 indicated 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 3rd party facility audit, and preparing 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 application 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 permit 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 and the public of the changes. EPA believes the 

collection frequencies specified in this ICR are necessary to ensure protection of human health 

and the environment. 

3(e) General Guidelines

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

OMB's implementing regulations, EPA's Information 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, contain 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 Classification System (NAICS) 

codes associated with industries most likely affected 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 Chemical 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 Organic Chemical Manufacturing 

325998 All Other Miscellaneous Chemical Product Manufacturing 

311942 Spice and Extract Manufacturing 

32411 Petroleum Refineries 

332813 Electroplating, Plating, Polishing, Anodizing and Coloring 

33271 Machine Shops 

332991 All Other Miscellaneous Fabricated Metal Product Manufacturing 

333319 Other Commercial or Service Industry Machinery Manufacturing 

 Accessories 

333999 All Other General Purpose Machinery Manufacturing 

336399 All Other Motor Vehicle Part Manufacturing 

334 Computer and Electronic Product Manufacturing 

336 Transportation Equipment Manufacturing 

48422 Specialized Freight (except Used Goods) Trucking, Local 

56211 Waste Collection 

22111 Electric Power Generation 

22112 Fossil Fuel Electric Power Generation 

22132 Sewage Treatment Facilities 

56292 Materials Recovery Facilities 
17 

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 requirements applicable to facilities that are 

affected by this ICR. 

APPLYING FOR A STANDARDIZED 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 owner 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 materials required by section 124.31; 

• Documentation of compliance with the location standards of sections 267.18 and 

270.14(b)(11), including: 

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

be located; 

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

264, a demonstration of compliance with the seismic standard as defined under 

section 264.18(a). This demonstration may be made using either published 

geologic data or data obtained from field investigations carried out by the 

applicant; 

-- An identification of whether the facility is located within a 100-year floodplain 
18 

• Information that allows the Director to carry out his obligations under other Federal laws 

required in section 270.3; 

• Solid waste management unit information 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 structural 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, where the Director ascertains that a RCRA 

Facility Assessment is necessary. 

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

270.280; and 

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

• The most recent closure cost estimate for your facility prepared under §267.142 and a 

copy of the documentation required to demonstrate financial assurance under §267.143. 

For a new facility, you may gather the required 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 manage waste generated off-site. 

• Documentation showing that the same person 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, owners 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 compliance with location standards; 

• Prepare information that allows the Director to carry out his obligations under other 

Federal laws; 

• Prepare the solid waste management 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-site, prepare a waste analysis plan. 

• If you manage waste generated off-site, prepare documentation showing that the same 

person owns both the waste generator 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 applying for a standardized permit to keep 

the following information at their facilities: 

• A general description of the facility; 
20 

• Chemical and physical analyses of the hazardous waste and hazardous debris handled at 

the facility. At a minimum, these analyses must contain all the information required to 

treat or store the wastes properly under the requirements of part 267; 

• A copy of the waste analysis plan 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 required by section 267.15(b), as well as the 

applicable inspection schedule requirements 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 prevention requirements of 

part 267, subpart C; 

• A copy of the contingency plan required 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 handling 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 personnel to hazardous waste; and 

-- Prevent releases to the atmosphere; 

• A description of precautions to prevent accidental ignition or reaction of ignitable, 

reactive, or incompatible wastes as required by section 267.17; 

• A description of traffic patterns, estimated volumes, and controls near the facility; 

• An outline of both the introductory and continuing programs you will use to prepare 

employees to operate or maintain the facility safely, as required 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 section 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 demonstrate 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 documentation that complies 

with the liability requirements of section 267.147. For a new facility, documentation 

showing the amount of insurance meeting the specification of section 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 requirements 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 physical analyses of the hazardous waste and 

hazardous debris handled at the facility (this activity is covered under section 267.13(a)); 

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

• Prepare and maintain 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; 

• Maintain a copy of the applicable 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 procedures, structures, or equipment used at the 

facility to: 

-- Prevent hazards in unloading operations; 

-- Prevent runoff from hazardous waste handling 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 personnel to hazardous waste; and 

-- Prevent releases to the atmosphere; 

• Maintain a description of precautions to prevent accidental ignition or reaction of 

ignitable, reactive, or incompatible wastes; 

• Prepare and maintain a description of traffic patterns, estimated volumes, and controls 

near the facility; 

• Maintain an outline of both the introductory 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 cost estimate and a copy of the documentation 

required to demonstrate financial assurance; 

• Where applicable, maintain a copy of the insurance policy or other documentation that 

complies with the liability requirements of section 267.147; 

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

• Obtain and maintain a topographic map. 

(3) Container Information Requirements

(i) Data items 
23 

In addition to the general information requirements listed at section 270.290, section 

270.300 requires owners and operators of facilities with containers 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 containers 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, dimensions, and materials of construction; 

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

standing liquids in the containment system; 

-- The capacity of the containment system relative to the number and volume of 

containers to be stored; 

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

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

• For storage areas that store containers holding wastes that do not contain free liquids, a 

demonstration of compliance with 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 section 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 otherwise managed in containers, a description 

of the procedures used to ensure compliance with sections 267.175(a) and (b); and 

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

 (ii) Respondent activities 
24 

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 description 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 sketches, drawings, or data demonstrating 

compliance with sections 267.174 and 267.175(c); 

• Where incompatible wastes are stored or otherwise 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 requirements 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 structural 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 cutoff, bypass systems, and pressure controls; 

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

• A description of materials and equipment used to provide external 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 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; 

• A description of controls and practices to prevent spills and overflows, 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 tank system and facility design 

will achieve compliance with the requirements of sections 267.202 and 267.203; and 

• Information on air emission control equipment 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, instrumentation, and a process flow for each 

tank system; 

• Maintain a description of materials and equipment 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 description 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 controls 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 procedures and tank system 

and facility design will achieve compliance 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 requirements 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 information at their facilities: 

• For each piece of equipment to which 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 equipment (e.g., gas/vapor or liquid); and 

-- Method of compliance with the standard; 

• For facilities that cannot install a closed-vent system and control device to comply with 40 

CFR part 264 subpart BB on the effective date that the facility becomes subject to the subpart 

BB provisions, an implementation schedule as specified in section 264.1033(a)(2); 

• For owners and operators who apply for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, condenser, 

or carbon adsorption system and choose to use test data to determine the organic removal 

efficiency or the total organic compound concentration achieved by the control device, a 

performance test plan as specified in section 264.1035(b)(3); 

• Documentation that demonstrates compliance with the equipment standards in sections 

264.1052 and 254.1059; and 
27 

• Documentation to demonstrate compliance with 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 analysis must address the vent stream 

characteristics and control device operation 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 design 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 owner or operator, certifying that the control 

device is designed to operate at an efficiency 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 identification number and hazardous waste management 

unit identification; 

-- Prepare and maintain approximate locations within the facility; 

-- Prepare and maintain a description of the type of equipment; 

-- Prepare and maintain a description of the 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); and 
28 

-- Prepare and maintain a description of the method of compliance with the 

standard; 

• For facilities that cannot install a closed-vent system and control 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 maintain an implementation schedule; 

• For owners and operators who apply for permission to use a control device other than a 

thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, 

condenser, or carbon adsorption system and choose 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 demonstrates compliance with the equipment 

standards in sections 264.1052 and 254.1059; and 

• Develop and maintain documentation to demonstrate compliance with section 264.1060. 

(6) Air Emissions Control Requirements

(i) Data items 

In addition to the general information requirements 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 information 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 information prepared by the owner or operator or 

provided by the manufacturer describing 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 container area subject to the requirements of part 264, subpart CC, 

and a certification that the requirements of this subpart are met; 

• 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). 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 system 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 Method 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 264.1084(e)(1) or (f)(1); 

• Prepare and maintain an identification of each container area subject 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 requirements of section 264.1087; and 

• Develop and maintain an emission monitoring plan for both Method 21 in 40 CFR part 

60, appendix A, and control device monitoring methods. 

(7) Switching from an Individual RCRA 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 standardized permit, in accordance with section 124.5. 

(ii) Respondent activities 
30 

In order to provide the data item listed above, owners and operators seeking to switch 

from a RCRA individual permit to a standardized 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 owners and 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. 

(ii) Respondent activities 

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

following activities: 

• Read the regulations; 

• Prepare and submit the notice of intent. 

MAINTAINING A STANDARDIZED PERMIT

(1) Making Routine Changes

(i) Data items 

Sections 124.212 and 270.320 require owners and 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 pursuant to section 270.267(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 activities
31 

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 information to the Director; and 

• Submit the revised information to the facility 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 section 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 information 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) desired, 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 meeting 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 and 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 application for an EPA identification number. 
33 

(2) Waste Analysis

(i) Data items 

Section 267.13(a) requires an owner or operator 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, developed under 40 CFR part 261, as well as existing 

data on the hazardous waste or hazardous waste 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 operator 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 and physical analysis of the waste. The owner or operator is 

required to keep the waste analysis plan at the facility. If you receive 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 initial 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 section 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 schedule 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 rate of deterioration of the equipment and the 

probability of an environmental or human health incident if the deterioration, malfunction, or any 

operator error goes undetected between inspections. At a minimum, the inspection schedule 

must include the items and frequencies 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 pursuant to section 267.15(b) in an inspection log or 

summary that is to be maintained at the facility. The inspection log or summary must contain, at 

a minimum, the date and time of the inspection, the name of the inspector, a notation of the 

observations made, and the date and nature of any repairs or other remedial actions. 

(ii) Respondent activities 

To meet the requirements outlined in sections 267.15(b) and 267.15(d), the owner or 

operator must conduct the following activities: 
35 

• Read the regulations; 

• Prepare the inspection schedule; and 

• Record the results of inspections in the inspection log. 

(5) Employee Training

(i) Data items 

Section 267.16(d) requires an owner or operator to maintain copies of personnel training 

documents and records at the facility. These documents should include the following data items: 

• Job title for each position at the facility related to hazardous waste management, and the 

name of the employee filling each job; 

• Written job description for each position, which includes the necessary skill, education, 

or other qualifications and duties of employees assigned 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 job experience required have been given to, 

and completed by, facility personnel. 

(ii) Respondent activities 

Respondent activities associated with section 267.16 (d) include reading the regulations, 

collecting the data items listed above, and maintaining (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 operator 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 (as specified in section 267.13), or the results of the treatment of similar 

wastes by similar treatment processes and under similar operating conditions. 
36 

(ii) Respondent activities 

Respondent activities associated with section 267.17(c) include reading the regulations, 

collecting and documenting the data items mentioned above, and maintaining (e.g., 

photocopying and filing) documentation at the facility. 

PREPAREDNESS AND PREVENTION

(1) Arrangements with Local Authorities

(i) Data items 

Section 267.36(b) requires owners 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) include reading the regulations, 

documenting any refusals, and placing this documentation 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 owner 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 State and local emergency response teams to 

coordinate emergency services; 

• An updated list of the names, addresses, and phone numbers (office and home) of all 

persons qualified to act as emergency coordinators; 
37 

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

description, and capabilities of the emergency equipment. The contingency plan should 

also indicate where the emergency equipment will be required; and 

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

be necessary. 

Section 267.53(b) requires owner and operators to submit a copy of the contingency plan 

and all revisions to all local police departments, fire departments, hospitals, and State and local 

emergency response teams that may be called upon to provide emergency services. 

Section 267.54 requires owners and operators to review and, if necessary, 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 increases 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 requirements, owners or operators are 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 Reporting
38 

(i) Data items 

Section 267.56(c)(1) requires owners and operators to immediately notify State and local 

authorities with designated response roles of an imminent or actual emergency situation. 

Section 267.56(c)(2) the facility emergency coordinator to notify the on-scene 

coordinator or the National Response Center of any release, fire, or explosion that could threaten 

human health or the environment outside the facility. The emergency notification 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 number 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 potential hazards to human health or the environment; and 

• Estimated quantity and disposition of recovered material that resulted from the incident. 
39 

Section 267.58(b) also requires owners and operators to note the 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 requirements 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 requirements of section 267.56(c)(2), owners and 

operators must perform the following activities: 

• Notify the on-scene coordinator 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 emergency 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 report, the owner or operator 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 associated with this 

requirement include the following: 

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

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

To comply with the requirements of section 267.58, owners and operators must record 

the details of any incident that requires implementing the contingency plan in the operating 

record. 

RECORD KEEPING, REPORTING, AND NOTIFYING

(1) Record Keeping
40 

(i) Data items 

Section 267.71 requires owners and operators to record and maintain the following 

information, as it becomes available, in the facility operating record until the facility is closed: 

• 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 as required by Appendix I of 

part 264; 

• The location of each hazardous waste within the facility and the quantity at each location; 

• Records and results of waste analyses performed; 

• Summary reports and details of all incidents 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 often than annually, that the permittee has a 

program in place to reduce the volume and toxicity 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 minimizes the present and future threat to 

human health and the environment; 

• For an on-site treatment facility, the information contained in the notice (except the 

manifest number), and the certification and demonstration required under section 268.7 

or section 268.8; 

• For an on-site storage facility, the information 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 facility. Respondent activities associated with maintaining an 

operating record include maintaining (e.g., photocopying and filing) the data items listed above. 

(2) Reports
41 

(i) Data items 

Section 267.73(a) requires owners and operators 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 owners and operators to report to the Regional Administrator: 

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

• Facility closures specified in section 267.117; and 

• As otherwise required by subparts I, J, and 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. Additionally, 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 transferring ownership or operation of a facility 

during its operating life, an owner 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 operators 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 items 
42 

Owners and operators are required by section 267.112 to submit a written closure plan 

with the Notice of Intent. The plan must identify 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 management unit at the facility will be closed 

in accordance with section 267.111; 

• A description of how final closure of the facility will be conducted in accordance with 

section 267.111 The description must identify the maximum extent of operations which 

will be unclosed during the active life of the facility; 

• An estimate of the maximum inventory of hazardous wastes ever on-site over the active 

life of the facility. This should include a detailed description of the methods to be used 

during partial closures and final closure such as methods for removing, transporting, 

treating, storing, or disposing of all hazardous wastes, and identification 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 partial and final closure; 

• A detailed description of other activities necessary during the closure period to ensure 

that all partial closures and final closure satisfy the closure 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 closure activities which will allow tracking of 

the progress of partial and final closure. 

(ii) Respondent activities 

The respondent activities associated with the closure plan described above include: 

• Reading the regulations; 

• Conducting an inventory of the hazardous waste present; 

• Recording results of inventory; Writing descriptions for the necessary activities; 

• Estimating final closure; and 
43 

• 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 treatment 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 Director a certification of 

closure within 60 days of the completion of final closure of each unit under a part 270 subpart J 

standardized permit. This certification must sent 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 items 
44 

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 will entail the following activities: 

• Reading the regulations; 

• Preparing a detailed estimate of closure costs; 

• Updating the estimate for 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 sections 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 signed 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 operators 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 operators 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 duplicates of the surety bond and trust agreement to the 

Regional Administrator. 

(4) Surety Bond Guaranteeing Performance of Closure

 (i) Data items 

Section 267.143(c) allows owners and operators to meet the financial assurance 

requirements for closure by obtaining a surety bond guaranteeing the performance of closure. 

The data items for this instrument include: 

• A surety bond instrument specified at section 264.151(c); and 

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

 (ii) Respondent activities 
46 

The respondent activities associated with this financial assurance instrument include: 

• Reading the regulations; 

• Obtaining a surety bond and trust agreement that comply with the financial assurance 

requirements of section 267.143(c); and 

• Submitting originally signed duplicates of the surety bond and 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 authorized 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 section 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 with a closure letter of credit: 

• Reading the regulations; 

• Obtaining a letter of credit from an issuing institution and establishing the stand-by trust 

fund; and 

• The letter of credit and an originally signed duplicate of the trust agreement to the 

Regional Administrator. 

(6) Closure Insurance 

(i) Data items 

Owners or operators may satisfy the financial assurance requirements for closure by 

establishing closure insurance according to section 267.143(e). The data item for this 
47 

information collection is a closure insurance policy (identified by a certificate of insurance) that 

meets the requirements specified 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 financial strength using the financial test specified in this section. 

Data items for this demonstration include: 

• A letter signed by the owner's or operator's chief 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 specifications 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 financial assurance, if the owner or operator 

fails the financial test and no longer meets the requirements of section 267.143(f)(1); 

• Reports of financial conditions as required by the Regional Administrator 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 requirements at section 267.143(g)(1). 

 (ii) Respondent activities 
48 

Owners and operators will need to perform the following activities 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 the chief financial officer; 

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

-- The special report from the independent certified public accountant; 

• Submitting updated information annually; 

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

Administrator of intent to establish other financial assurance; and 

• Writing and submitting additional reports of financial 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 single 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-closure care assured by the mechanism. 

 (ii) Respondent activities 
49 

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 operators to satisfy financial requirements for 

liability by establishing a trust agreement that conforms to the requirements specified in section 

264.147(j). 

 (ii) Respondent activities 

Owners or operators using this option to satisfy 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 operators to satisfy financial requirements for 

liability. The owner/operator must obtain a surety bond (and other information, where 

applicable) that conforms to the requirements specified in section 264.147(i). 

(ii) Respondent activities 

Owners or operators using this option to satisfy 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 operators to satisfy financial 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 satisfy 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 credit to the Regional Administrator. 

(12) Liability Insurance

(i) Data items 

Section 267.147 allows owners or operators to satisfy financial requirements 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 requested 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 attachment of the Hazardous Waste Facility 

Liability Endorsement or evidenced by a Certificate of Liability Insurance and meeting 

other specifications outlined in sections 264.147(a)(1) and 264.147(b)(1); 

• Submitting a signed duplicate original of the endorsement or the certificate of insurance 

to the Regional Administrator, or Regional Administrators if the facilities 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 operators to satisfy liability requirements by 

passing a financial test, as specified at section 267.147(f). Data items for this option include: 

• A letter signed by the owner's or operator's chief financial officer and worded as specified 

in section 264.151(g); if the financial test is also being used to demonstrate closure 

financial assurance, the letter 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 covering the specifications of section 267.147(f)(2)(i)(C); 

• Annual updates of the above data items; and 

• Should the owner or operator fail the test and no longer meet the requirements of section 

267.147(f)(1), evidence of alternate 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 activities in order to 

collect the data required 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 the chief financial officer; 

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

-- The special report from an independent 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 Guarantee for Liability Coverage

(i) Data items 

Section 267.147(g) allows owners or operators to meet liability requirements by 

obtaining a written guarantee, under the conditions specified in section 267.147(g)(2). Data 

items for this option include: 

• A certified copy of a written guarantee from the direct or higher-tier parent corporation of 

the owner or operator, a firm whose parent corporation is the parent corporation of the 

owner or operator, or a firm with a "substantial 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 Insurance 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 guarantee is located and in the State in which it has its 

principal place of business, and a written statement 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 valid and enforceable obligation in that State; 

and 
53 

• A letter from the guarantor's chief financial 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 activities in order to 

collect the data required 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 corporation is the parent corporation of the owner 

or operator, or a firm with a "substantial 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 guarantor has passed the financial test. 

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

(i) Data items 

Section 267.148 requires owners or operators 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 the Regional Administrator indicating the 

commencement of bankruptcy proceedings in which the owner or operator or guarantor is 

named as debtor. 

(16) State Assumption of Responsibility

(i) Data items 
54 

Section 267.150 requires owners or operators to notify EPA when a State assumes legal 

responsibility or assures availability of funds for an owner's or operator's compliance with the 

closure, post-closure care, or liability requirements of this part. Data items to be collected in 

this case include: 

• A letter from the owner or operator requesting 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-closure care or liability coverage that are 

guaranteed by the State; and 

• Any additional information which the Regional 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 the 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 store or treat hazardous 

waste in containers to inspect areas where they store containers, at least weekly. 

 (ii) Respondent activities 
55 

In order to provide the above data item, owners and operators will need to perform the 

following activities: 

• Read the regulations; 

• Inspect the areas where they store containers, 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 emission requirements established in subparts BB and 

CC of part 264. These requirements, however, are not addressed 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 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 operators to exempt their facilities from the 

secondary containment requirements in section 267.195 if they can demonstrate 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, using Method 9095 (Paint Filter Liquids Test) as 

described in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA 

Publication SW-846. 

 (ii) Respondent activities 

Respondent activities associated with the above data item include: 

• Reading the regulations; and 

• Preparing the no free liquids demonstration. 

(2) Design and Construction Standards

 (i) Data items 
56 

Section 267.191 requires owners and operators to obtain a written assessment, reviewed 

and certified by an independent, qualified registered professional engineer, following section 

270.11(d), attesting that the tank system 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 the 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 described above, owners and operators will need to 

perform the following activities: 

• Read the regulations; and 

• Obtain a written assessment from an independent, 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 required to certify the design of the tank system and to supervise the 

installation of the tank system as required in sections 267.192, 267.193, and 267.194(a) and (b). 

 (ii) Respondent activities 

In order to provide the data items described above, owners and operators will need to 

perform the following activities: 

• Reading the regulations; 

• Obtaining the written statements; and 
57 

• 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 carried out pursuant to 267.199(a)-(c). 

 (ii) Respondent activities 

In order to comply with section 267.199 requirements, owners and operators must 

perform the following activities: 

• Reading the regulations; 

• Developing and follow a schedule and procedure 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 area 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 system is operating properly within six 

months after initial installation and annually thereafter; 

-- Inspect and/or test all sources 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 Spills
58 

 (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 Administrator of the release within 24 hours of its 

detection; and 

• A report to the Regional Administrator, within 30 days of detection, containing the 

following information: 

-- The likely route of migration of the release; 

-- The characteristics of the surrounding soil; 

-- The results of any monitoring or sampling conducted in connection with the 

release; 

-- The proximity to downgradient drinking water, surface water, and populated 

areas; and 

-- A description of response 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, professional engineer that the repaired 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 Regional Administrator within 24 hours of leak 

detection; 

• Preparing and submitting a report to the Regional Administrator within 30 days of leak 

detection; and 

• Obtaining and submitting an engineer’s certification. 
59 

In addition, section 267.204 requires owners and operators to manage all hazardous waste 

placed in a tank according to the air emission requirements established in subparts BB and CC of 

part 264. These requirements, however, are not addressed 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 Emission 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 Standards 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 every seven days, data gathered from monitoring equipment and 

leak detection equipment as well as the containment 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 operators will have to perform the 

following activities: 

• Read the regulations; 

• Inspect data at least once every seven days; and 

• Record the results in the facility’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 Areas Both with and Without Secondary 

Containment

 (i) Data items 

Section 267.1105 requires owners and operators of containment buildings that have areas 

both with and without secondary containment to maintain in the facility’s operating log a written 

description of the operating procedures used to maintain the integrity of areas without secondary 

containment. 

 (ii) Respondent activities 

Respondent activities associated with the above data items include: 

• Reading the regulations; and 

• Preparing and maintaining a written description of the operating procedures. 

(4) Releases of Hazardous Waste

 (i) Data items 

Section 267.1106 requires owners and operators that detect a condition 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 description 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 notification to the Director 

providing verification, signed by a qualified, registered, professional engineer, that the 

repairs and cleanup have been completed according to the written plan described above. 

 (ii) Respondent activities 

In order to provide the above data items, owners and operators will need to perform the 

following activities: 
61 

• Reading the regulations; 

• Entering a record of the discovery 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 the Director within 14 working days of the 

discovery; and 

• Preparing and submitting the written 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 ensure that the information collections are not overly burdensome 

on small entities. 

5(a) Agency Activities

APPLYING FOR A STANDARDIZED PERMIT

Agency activities associated with a standardized permit application and renewal include 

reviewing the incoming notice of intent and supporting information, determining whether the 

facility is eligible for the standardized permit, and entering the information into a database. 

MAINTAINING A STANDARDIZED 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 Changes
62 

Agencies activities associated with significant changes to a standardized permit include 

reviewing the incoming modification request and supporting information, reviewing the proof of 

public notice, and entering the information into a database. 

GENERAL FACILITY STANDARDS

Agency activities associated with general facility standards requirements include: 

• Issuing an identification number to new facilities, 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 are in place and in working order. 

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

requirements, and deciding whether 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 development and amendment of the contingency 

plan include: reviewing the contingency plan during on-site inspections and reviewing revisions 

to the contingency plan. 

Agency activities associated with emergency reporting requirements include reviewing 

documents in the owners' or operators' and emergency 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. 

CLOSURE
63 

Agency activities associated with closure include 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, modify, or disapprove the closure plan. 

FINANCIAL REQUIREMENTS

Agency activities pertaining to financial requirements include: 

• Reviewing closure cost estimates, demonstrations of financial assurance for closure, and 

demonstrations of financial 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 releases 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 documentation 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 receive and keep records of the notifications and supporting 

documentation submitted by facility owners and operators 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 computers and applicable data software, when 

appropriate. 
64 

5(c) Small Entity Flexibility

The standardized permit provides regulatory relief from parts of RCRA hazardous waste 

permitting program for facilities with tanks, containers, and containment buildings that apply and 

obtain a standardized permit. Thus, small facilities, 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 reducing time and costs for providing information. Since 

small facilities conduct operations that are equally 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 businesses. As a result of this interpretation, no 

specific requirements are outlined 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 standardized 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 public to submit comments and request 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 comment 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 considers the public comments when specifying terms 

and conditions in the supplemental portion of the standardized permit, if any. 

Under section 267.112, facility owners and operators must submit a written closure plan 

with the Notice of Intent. Once the permitting agency receives this information, it must review 

and approve the closure plan. In addition, the permitting agency must provide the public an 

opportunity to comment on the plan. The comment 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 permitting 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 management 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 estimate the number of hours required to conduct each 

individual information collection activity and the cost associated 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 managerial staff, $40.68 for technical staff, and $22.73 for clerical 

staff. These wage rates are based on actual Bureau of Labor Statistics (BLS) mean rates, plus 

overhead and fringe benefits. These rates are lower than those previously used. Previous 

estimates reflected updates with a straight inflation factor applied to previous respondent hourly 

estimates. 

Capital Costs 

EPA estimates that only new facilities will incur 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 cabinets, CD-ROM, off-site storage, etc) and store 

their files on different media (paper, microfiche, electronic files, etc). For purposes of estimating 

these capital costs across all facilities, EPA has 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 materials 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 life 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 expected to apply for and obtain a 

standardized permit each year ($156 per year). 

Operation and Maintenance Costs

EPA estimates that respondents may incur annual operations and maintenance costs 

associated with the information collection requirements. EPA estimates that sending a 

 1

 EPA assumes existing permitted and interim-status facilities have already compiled much of 

the materials required in the standardized permit application; 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 demonstrations 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 estimates an average hourly Agency labor cost of $76.38 

for Regional legal staff, $54.94 for Regional managerial 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 Regional legal, managerial, technical, and clerical 

staff. For purposes of this ICR, EPA assigned 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 standard 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 treatment, storage, and disposal facilities 

(TSDFs) that currently store or non-thermally treat hazardous waste in containers, tanks, and/or 

containment buildings. 

Table 1 

Facilities that Treat and/or Store Hazardous Waste 

in Containers, Tanks, and Containment Buildingsa

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 

facilitiesb

740 512 228

Facilities with storage, non-thermal treatment, and other type of units 
67 

Containers 221 123 98

Tanks 228 125 103

Containment buildings 18 3 15

All storage and/or treatment 

facilitiesb

259 162 97

Total 

Containers 938 613 325

Tanks 742 451 291

Containment buildings 31 9 22

All storage and/or treatment 

facilitiesb

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 numbers of facilities presented in this table do 

not include federally owned and operated facilities. 

 b Note that certain facilities own or operate more 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 permitted and 325 interim status). The estimate of 

1000 was derived by taking the mid-point of the range of facilities potentially eligible for the 

standardized permit ((onsite + off-site) / 2). Of these 1000 TSDFs, 740 (512 permitted and 228 

interim status) facilities have storage and/or non-thermal treatment units only and 259 (162 

permitted and 97 interim status) facilities have storage, 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 container, 514 facilities have at least one tank, and 13 facilities have at 

least one containment building. Of the 259 TSDFs that have storage, non-thermal treatment, and 

other type of units, 221 facilities have at least one container, 228 facilities 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 approximately 13. All of these facilities are expected 

to apply for a standardized permit.2

 

 2

 Based on analysis of permitting data from the 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 other type of units, the annual 

number of permit renewals is expected to be 2. All of these facilities are expected to 

apply for a standardized permit.4

• For facilities that have storage, non-thermal treatment, and other type of units that are not 

up for permit renewal, 25 percent are expected to apply for a standardized permit (12 

facilities per year).5

Operating, interim-status facilities

• All facilities with storage 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 storage, 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 Standardized Permit Annuallya

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 

facilitiesc

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 

facilitiesc

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 

facilitiesc

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 numbers of facilities presented in this table do 

not include federally owned and operated facilities. In addition, total actions are based on midpoint of the lower and upper-bound estimates of annual actions presented 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. However, this issue has no bearing on this ICR. c

 Note that certain facilities own or operate more 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 Table 2, EPA estimated respondent burden and 

costs associated with all of the requirements covered in this ICR in Exhibits 1 through 9. A 

discussion of the burden estimates presented in these exhibits follows. 
70 

APPLYING FOR A STANDARDIZED 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). All 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 standardized 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 collected most of the required information 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 intent to operate under a 

standardized permit. 

EPA assumes that interim status and new facilities (i.e., a total of 86 facilities per year) 

will have to prepare and maintain 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 facilities, 5 percent of the facilities (i.e., a total of 9 

facilities) will not be in compliance with general information requirements of part 264 or 265.9

 

These facilities would have to prepare and submit a schedule of compliance with part 267 as part 

of their standardized permit application. 

Of the 1000 TSDFs, approximately 134 may be expected to receive waste from off-site 

facilities, and therefore, are required to submit documentation that the off-site facility is under 

the same ownership as the receiving facility. Based on the estimated 184 total actions (out of the 

1000 facilities) per year, approximately 25 facilities 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 the 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 interim-status and new facilities (i.e., a total 

of 82 facilities per year) will have to incur burden for record keeping information. The 

exceptions pertain to the record keeping of particular data items. Specifically, EPA assumes that 

only new facilities will incur burden for preparing a general description 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 preparedness and prevention requirements (i.e., a total of 9 facilities).10

(3) Container Information Requirements

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

containers. EPA also assumes that interim status 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 containers (i.e., 83 interim status facilities and 2 new 

facilities). 

(4) Tank Information Requirements

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

tanks. EPA also assumes that interim status and 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 interim status facilities and 1 new facility). In 

addition, EPA estimates that 10 percent of the permitted 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 total) 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 facilities will not incur burden in compiling 

information on their equipment. All permitted and interim status facilities are already required to 

have this information under 40 CFR part 270. However, 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 facilities 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 the air emission control standards. 

(7) Switching from an Individual RCRA Permit to a Standardized Permit

For permitted facilities switching to a standardized 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 three-year period of this ICR. 

MAINTAINING A STANDARDIZED PERMIT

EPA estimates that approximately 10 percent of the TSDFs (i.e., 0.10 x 184 facilities 

=18 facilities) operating under a standardized permit will have to make routine changes to their 

permits each year. Approximately 4 percent of the TSDFs (i.e., 0.04 x 184 facilities = 7 

facilities) operating under a standardized permit are expected to make 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 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 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 modifications. 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 pertaining to preparedness and prevention are 

already covered in the General Hazardous Waste Facility Standards 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 covered in the above 

mentioned ICR.) 

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Information collection requirements pertaining 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 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 covered in the 

above mentioned ICRs.) 

RECORD KEEPING, REPORTING, AND NOTIFYING

Information collection requirements pertaining to record keeping and reporting are 

already covered in the General Hazardous Waste Facility Standards 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 covered in the above 

mentioned ICR.) 

CLOSURE

Information collection requirements pertaining to closure are already 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 covered in the above mentioned ICRs.) 

FINANCIAL REQUIREMENTS

Information collection requirements pertaining to financial assurance are already 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 covered in the above mentioned ICRs.) 

USE AND MANAGEMENT OF CONTAINERS
74 

Information collection requirements pertaining to the use and management of containers 

are already covered in the Part B Permit Application, Permit Modifications, 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 respondents or activities 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.) 

TANK SYSTEMS

Information collection requirements pertaining to tank systems are already covered in the 

Part B Permit Application, Permit Modifications, 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 respondents or activities 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.) 

CONTAINMENT BUILDINGS

Information collection requirements pertaining 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 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 covered in the above mentioned ICR.)

6(e) Bottom Line Burden Hours and Costs 

Respondent Tally 

Exhibit 19 summarizes the total annual respondent burden and cost associated 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 Burden 
75 

The Operations and Maintenance (O&M) costs increased by $310 due to updates in 

current fees. 

The Agency costs have decreased from $758,920 to $616,306. This is due to an update in 

current salaries. 

6(g) Burden Statement 

The annual reporting burden for the new information collection requirements in this ICR 

is estimated to range from 53 to 57 hours per respondent. This burden includes time for facility 

owners and operators to submit to the permitting agency a notice of intent and supporting 

materials for a standardized permit application, if required, and permit modification requests for 

significant changes. The average time per response for reporting is about 37 hours. 

The annual record keeping burden for the new information collection requirements in this 

ICR is estimated to range from 31 to 178 hours per respondent. This includes time for reading 

the regulations and keeping records under section 270.290 and, if required, 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 disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR Chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-RCRA-2011-0624, which is available for online viewing at 

www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the RCRA Docket is (202) 566-0270. An electronic version 

of the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. When in the system, 
76 

select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

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

2050-0182 in any correspondence.
77 
78 

EXHIBIT 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 Prepare 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 Obtain the Part A information 1.50 3.00 9.00 1.50 15.00 $811.07 $0.00 Obtain 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 Develop documentation of compliance with location standards 0.00 0.00 2.00 0.50 2.50 $92.73 $0.00 Prepare information allowing the Director to carry out other Federal obligations 0.00 1.00 4.00 2.00 7.00 $293.04 $0.00 Prepare the solid waste management unit information 0.00 0.25 4.00 0.25 4.50 $189.62 $0.00 Prepare and sign the certification of compliance with part 267 0.10 0.10 0.10 0.17 0.47 $26.84 $0.00 If receiving waste from off-site, obtain infomration documenting same ownership 0.17 0.10 0.00 0.10 0.37 $28.47 $0.00 Prepare a schedule of compliance with part 267 0.17 0.25 2.00 0.50 2.92 $131.65 $0.00 Submit the above information to the Director 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 Read the regulations 0.00 0.50 0.50 0.00 1.00 $62.77 $0.00 Prepare and maintain a general description of the facility 0.00 2.00 15.00 2.00 19.00 $825.38 $0.00 Prepare and maintain a justification for any modification of the preparedness and prevention requirements 0.00 0.00 0.50 0.50 1.00 $31.71 $0.00 Prepare and maintain a description of the procedures, structures, and equipment used at the facility 0.00 0.25 4.00 0.50 4.75 $195.30 $0.00 Prepare 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 Obtain and maintain a topographic map 0.00 0.00 11.00 0.50 11.50 $458.85 $20.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Prepare and maintain a description of the containment system 0.00 1.00 4.80 0.40 6.20 $289.22 $1,233.33 Prepare and maintain a demonstration of compliance with Section 267.175(c) 0.00 0.30 2.40 0.20 2.90 $127.64 $500.00 Obtain and maintain sketches, drawings, or data demonstrating compliance with Sections 267.174 & 267.175(c) 0.00 1.00 5.00 0.50 6.50 $299.63 $500.00 Prepare and maintain a description of the procedures used to ensure compliance with Sections 267.175(a) & (b) 0.00 1.30 16.80 1.30 19.40 $823.29 $700.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Document and maintain the dimensions and capacity of each tank 0.00 3.00 12.00 1.00 16.00 $765.47 $2,000.00 Prepare and maintain a description of feed systems, safety cutoff, bypass systems, and pressure controls 0.00 0.00 3.00 1.00 4.00 $144.77 $500.00 Prepare and maintain a diagram of piping, instrumentation, and a process flow of each tank system 0.00 3.00 12.00 1.00 16.00 $765.47 $500.00 Prepare and maintain a detailed description of how new tank systems will be installed in compliance with Section 267.194 0.00 0.00 4.00 0.50 4.50 $174.09 $500.00 Prepare and maintain detailed plans for containment systems 0.00 1.00 5.00 0.40 6.40 $297.35 $1,200.00 Prepare and maintain a description of controls and practices to prevent spills and overflows 0.00 0.00 3.00 0.50 3.50 $133.41 $0.00 Prepare and maintain a description of operating procedure compliance for ignitable, reactive, or incompatible wastes 0.00 2.00 15.00 2.00 19.00 $825.38 $0.00 

T

O&M 

Cost/Year

Number o

Responden

Hours and Costs per Respondent

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

INFORM ATION COLLECTION ACTIVITY Cost/Year

Container Information Requirements (270.300)

General Info rmatio n R equirements (124.202, 270.275, 270.280, & 270.285)Tank Information Requirements (270.305)Record Keeping Requirements (270.290)
79 

EXH 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 IT

T

O&M 

Cost/Year

Number o

Responden

Hours and Costs per Respondent

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

INFORM ATION COLLECTION ACTIVITY Cost/Year

Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 M aintain the equipment identification number and hazardous waste management unit identification 0.00 0.25 0.25 0.10 0.60 $33.66 $0.00 Prepare and maintain approximate locations within the facility 0.00 0.25 0.25 0.10 0.60 $33.66 $0.00 Prepare and maintain descriptions of the type of equipment 0.00 0.50 3.00 0.50 4.00 $175.84 $0.00 Prepare and maintain descriptions of the percent by weight of total organics in the hazardous waste stream at the equipment 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 Prepare and maintain descriptions of the hazardous waste state at the equipment 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 Prepare and maintain descriptions of the methods of compliance 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 Prepare and maintain an implementation schedule for compliance with Part 264 subpart BB requirements 0.00 0.25 1.00 0.25 1.50 $67.58 $0.00 Develop and maintain a performance test plan 0.00 1.00 7.00 2.00 10.00 $415.08 $0.00 Develop and maintain documentation that demonstrates compliance with equipment standards 0.00 1.00 16.00 2.00 19.00 $781.20 $0.00 Develop and maintain documentation to demonstrate compliance with Section 264.1060 0.00 0.50 2.00 0.50 3.00 $135.16 $0.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Prepare and maintain documentation for floating roof covers 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Prepare and maintain a certification that covers meet applicable design specifications 0.00 0.25 0.50 0.00 0.75 $41.56 $0.00 Prepare and maintain identification and certifications for container areas 0.00 0.25 0.50 0.00 0.75 $41.56 $0.00 Prepare and maintain documentation for enclosures used to control air pollutant emissions from tanks or containers 0.00 0.10 0.15 0.00 0.25 $14.59 $0.00 Prepare and maintain documentation for closed-vent systems and control devices 0.00 0.10 0.15 0.00 0.25 $14.59 $0.00 Develop and maintain emission monitoring plans and control device monitoring methods 0.00 3.00 6.00 2.00 11.00 $544.12 $0.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Prepare and submit the request to the Director 0.50 1.00 2.00 0.50 4.00 $229.68 $4.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Prepare and submit the notice of intent 0.50 1.00 2.00 0.50 4.00 $229.68 $4.00 Total Varies Varies Varies Varies Varies Varies Varies 2,Equipment 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)
80 

EXHIBIT 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 Prepare and submit revised information to the Director 1.00 1.00 8.00 2.00 12.00 $559.94 $4.00 Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 Read the regulations 2.00 1.00 1.00 0.00 4.00 $333.90 $0.00 Prepare and submit modification request to the Director 1.00 1.00 8.00 2.00 12.00 $559.94 $4.00 Submit revised information to facility mailing list and local governments 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 Read the regulations 2.00 1.00 1.00 0.00 4.00 $333.90 $0.00 Prepare and submit proof of public notice 0.00 0.25 1.00 0.25 1.50 $67.58 $4.00 Prepare and submit the modification request to the Director 5.00 15.00 80.00 12.00 112.00 $5,320.96 $8,000.00 Total Varies Varies Varies Varies Varies Varies Varies 

Hours and Costs per Respondent

T

Cler. 

$ 22.73/Hr

O&M 

Cost/Year

Number o

Responden

Respondent 

Hours/Year

Labor 

INFORM ATION COLLECTION ACTIVITY Cost/Year

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

M 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)
81 

EXHIBIT 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 

Obtain, 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 Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 Collect data 0.00 0.00 3.00 0.50 3.50 $133.41 $0.00 Perform waste analysis 0.00 0.00 10.00 0.00 10.00 $406.80 $1,500.00 

Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 

Collect the data required for the waste analysis plan 0.00 10.00 90.00 9.00 109.00 $4,714.37 $0.00 Write the waste analysis plan 0.00 10.00 60.00 9.00 79.00 $3,493.97 $0.00 M aintain the waste analysis plan 0.00 0.00 0.00 1.00 1.00 $22.73 $0.00 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 Collect the required documents 0.00 0.00 1.00 0.50 1.50 $52.05 $0.00 M aintain the required documents 0.00 0.00 0.00 1.00 1.00 $22.73 $0.00 Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 Prepare the inspection schedule 0.00 8.00 80.00 1.00 89.00 $3,956.01 $0.00 Record the results of inspections in the inspection log 0.00 0.00 100.00 0.00 100.00 $4,068.00 $0.00 M aintain the inspection schedule 0.00 0.00 0.00 1.00 1.00 $22.73 $100.00 

Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 

Prepare 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 

M aintain the employee training documentation 0.00 0.00 0.00 80.00 80.00 $1,818.40 $100.00 

Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 

Collect and document compliance 0.00 1.00 40.00 1.00 42.00 $1,734.79 $0.00 M aintain the compliance documentation 0.00 0.00 0.00 1.00 1.00 $22.73 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responden

Obtaining 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)
82 

EXHIBIT 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 Document any refusals of local authorities and place in operating record 0.00 0.25 1.00 0.50 1.75 $73.26 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responden

A rrangements with Lo cal A utho rities (267.36(b))

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

EXHIBIT 5STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTCONTINGENCY P LAN AND EM ERGENCY P ROCEDURESRead the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 

Collect the data required in the contingency plan 0.00 0.00 12.00 3.00 15.00 $556.35 $0.00 Write the contingency plan 0.00 1.00 60.00 4.00 65.00 $2,616.58 $0.00 Submit the contingency plan to State and local authorities 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 M aintain the contingency plan 0.00 0.00 0.00 1.00 1.00 $22.73 $0.00 Read the regulations 0.00 0.25 0.75 0.00 1.00 $51.73 $0.00 Submit 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 Notify 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 Collect the information required in the emergency report 0.00 0.00 2.50 0.50 3.00 $113.07 $0.00 Write the emergency notification report 0.00 1.00 0.00 0.00 1.00 $84.86 $0.00 Collect the information required in the emergency report 0.00 0.00 8.00 0.50 8.50 $336.81 $0.00 Write the emergency report 0.00 0.25 4.00 0.50 4.75 $195.30 $0.00 Compile information that demonstrates that all affected areas are in compliance 0.00 0.00 2.50 0.50 3.00 $113.07 $0.00 Prepare a letter notifying the Regional Administrator of compliance 0.00 0.25 1.50 0.25 2.00 $87.92 $0.00 Record 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 Total Varies Varies Varies Varies Varies Varies Varies 

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Emergency R epo rting (267.56(c), 267.58(a) & (b))

Numb

Respo

C o ntingency P lan (267.51-54)

Hours and Costs per Respondent 

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr
83 

EXHIBIT 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 Read the regulations 0.00 0.10 0.25 0.00 0.35 $18.66 $0.00 Prepare and submit written notification to new owner or operator 0.00 0.00 0.50 0.13 0.63 $23.29 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Notifications (267.74)

Number o

Responden

R eco rd Keeping (267.71)

Hours and Costs per Respondent To

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

EXHIBIT 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 

Conduct a hazardous waste inventory 0.00 0.00 8.00 0.00 8.00 $325.44 $0.00 Record the results of the hazardous waste inventory 0.00 0.00 2.00 0.50 2.50 $92.73 $0.00 Write a description for the necessary closure activities 0.00 1.00 20.00 3.00 24.00 $966.65 $0.00 Estimate final closure 0.00 1.00 8.00 1.00 10.00 $433.03 $0.00 Write the closure schedule 0.00 0.50 1.00 0.50 2.00 $94.48 $0.00 Read the regulations 0.00 0.10 0.25 0.00 0.35 $18.66 $0.00 Prepare the written notification of closure 0.00 0.25 0.50 0.25 1.00 $47.24 $4.00 Submit the closure plan 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 Read the regulations 0.00 0.10 0.25 0.00 0.35 $18.66 $0.00 Prepare the certification 0.00 0.00 11.00 2.00 13.00 $492.94 $500.00 

Submit the certification 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 

Total Varies Varies Varies Varies Varies Varies Varies C 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&M 

Cost/Year

Number o

Responden

Certification of Closure

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year
84 

EXHIBIT 8STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTFINANCIAL REQUIREM ENTSRead the regulations covering financial requirements 8.00 2.00 8.00 0.00 18.00 $1,328.60 $0.00 

Prepare a detailed estimate of closure costs 0.00 0.00 10.00 3.00 13.00 $474.99 $0.00 Update the estimate for inflation annually 0.00 0.00 0.50 0.00 0.50 $20.34 $0.00 M aintain the estimate at the facility (under record keeping) 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 Establish a closure trust fund 4.00 1.50 2.00 0.50 8.00 $636.74 $0.00 Submit 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 Submit a receipt for the first payment to the Regional Administrator 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 Establish a surety bond and trust agreement 4.00 1.50 2.00 0.50 8.00 $636.74 $0.00 Submit 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 Obtain a surety bond and trust agreement 4.00 1.50 2.00 0.50 8.00 $636.74 $0.00 Submit 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 Obtain a letter of credit and establish a stand-by trust fund 4.00 1.50 2.00 0.50 8.00 $636.74 $0.00 Submit 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 Obtain a closure insurance policy 4.00 1.50 2.00 0.50 8.00 $636.74 $0.00 Submit a certificate of the insurance policy to the Regional Administrator 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 Prepare and submit the letter signed by the chief financial officer 1.00 0.25 2.00 0.75 4.00 $223.80 $4.00 Submit 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 Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $90.92 $4.00 Prepare 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 Write 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 Submit the corporate guarantee from the parent corporation 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 

Hours and Costs per Respondent 

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Num

Respo

Reading 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))
85 

EXHIBIT 8 Con't.STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTFINANCIAL REQUIREM ENTS

Hours and Costs per Respondent 

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Num

Respo

Submit required information to the Regional Administrator 0.50 1.00 0.50 2.00 4.00 $202.75 $4.00 

Submit evidence of financial assurance to all other applicable Regional Administrators 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 Establish a trust fund 4.50 1.50 1.00 1.00 8.00 $659.51 $0.00 Submit a duplicate of the trust agreement to the Regional Administrator 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 Obtain 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 Obtain 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 Obtain an insurance policy and submit documentation to the Regional Administrator 4.00 1.00 2.00 1.00 8.00 $605.67 $4.00 Prepare, 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 Obtain 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 Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $90.92 $4.00 Prepare 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 Obtain and submit a written guarantee to the Regional Administrator 0.50 0.50 0.50 0.50 2.00 $126.23 $4.00 Submit a letter from the guarantor's chief financial officer 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 Submit updated information annually 0.00 0.00 0.00 4.00 4.00 $90.92 $4.00 Submit 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 Prepare 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 Obtain and submit the letter from the State 0.00 0.00 0.00 1.00 1.00 $22.73 $4.00 Prepare and submit any additional information requested by the Regional Administrator 0.75 0.25 0.75 0.25 2.00 $135.54 $4.00 Total Varies Varies Varies Varies Varies Varies Varies Use 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)
86 

EXHIBIT 9STANDARDIZED P ERM ITSESTIM ATED ANNUAL RESP ONDENT BURDEN AND COSTSP ECIFIC UNIT REQUIREM ENTSRead the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 

Prepare the no free liquids demonstration 0.00 0.00 1.50 0.00 1.50 $61.02 $475.00 0 

Perform weekly inspections and record results 0.00 0.00 100.00 0.00 100.00 $4,068.00 $0.00 0 

Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Obtain an engineer's written assessment 0.00 3.00 12.00 1.00 16.00 $765.47 $2,000.00 0 

Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 

Obtain the written statements 0.00 0.00 7.00 1.50 8.50 $318.86 $1,000.00 0 

M aintain the written statements at the facility 0.00 0.00 0.00 0.10 0.10 $2.27 $4.00 0 

Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Develop an inspection schedule 0.00 8.00 80.00 1.00 89.00 $3,956.01 $0.00 0 Perform daily inspections and record the results 0.00 0.00 100.00 0.00 100.00 $4,068.00 $0.00 0 Perform 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 Perform 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 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Prepare 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 Prepare 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 Obtain and submit an engineer's certification 0.00 0.00 0.00 0.50 0.50 $11.37 $4.00 0 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Inspect data weekly and record the results 0.00 0.00 26.00 0.00 26.00 $1,057.68 $0.00 0 Read the regulations 0.00 0.25 0.25 0.50 1.00 $42.75 $0.00 0 Prepare the free liquids demonstration 1.00 1.00 2.00 0.50 4.50 $281.77 $1,500.00 0 

Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 

Prepare and maintain a written description of operating procedures 0.00 0.00 1.00 0.25 1.25 $46.36 $0.00 0 Read the regulations 0.00 0.25 0.25 0.00 0.50 $31.39 $0.00 0 Enter a record of the discovery in the operating record 0.00 0.00 0.50 0.00 0.50 $20.34 $0.00 0 Prepare 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 Prepare and submit a written notification within 14 days 0.00 0.00 0.50 0.25 0.75 $26.02 $4.00 0 Prepare and submit the written verification to the Director 0.00 0.50 0.00 0.25 0.75 $48.11 $4.00 0 Total Varies Varies Varies Varies Varies Varies Varies 0 

Hours and Costs per Respondent Total H

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Inspectio n R equirements (267.199)

Number of 

Respondents

H

Inspectio 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)
87 

EXH 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 Enter information into a database 0.00 0.00 0.00 0.50 0.50 $11.72 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number 

Responde

A pplying fo r a Standardized P ermit (124.204, 270.275, 270.280, & 270.285)

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

EXH 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 Review the modification request and supporting information 20.00 1.00 20.00 30.00 $2,353.82 Review the modification request and supporting information 20.00 1.00 40.00 0.00 61.00 $3,125.02 $0.00 Review proof of public notice 0.00 0.25 1.00 0.00 1.25 $52.30 $0.00 Enter information into a database 0.00 0.00 0.00 0.50 0.50 $11.72 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 3

Hours and Costs per Respondent To

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Significant C hanges (124.213 & 270.320(b))

Number of 

Respondent

R o utine C hanges (124.212 & 270.320(a))R o utine C hanges with prio r appro val (124.213 & 270.320)
88 

EXH 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 hazardous waste facility data system 0.00 0.25 2.00 0.50 2.75 $102.58 $0.00 

Review the security procedures and inspect the security system during an on-site inspection 0.00 0.00 1.00 0.00 1.00 $38.56 $0.00 Review the information submitted by permittees seeking a waiver from the security requirements and make a determination 0.00 0.25 0.50 0.00 0.75 $33.02 $0.00 Review the demonstration of compliance with location factors 0.00 0.00 1.00 0.00 1.00 $38.56 $0.00 Review information submitted by permittees seeking a waiver from the location standards and make a determination 0.00 0.25 2.00 0.00 2.25 $90.86 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/

H r

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responden

General F acility Standards (267.12, 267.14, & 267.18)

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/

H r

M gr. 

$ 84.86/

H r

Tech. 

$ 40.68/

H r

EXH IB IT 13STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTP REP AREDNESS AND P REVENTIONIf necessary, review during inspections the documentation of any refusals of local authorities to enter into emergency arrangements 0.00 0.00 0.25 0.00 0.25 $9.64 $0.00 

Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number of 

Respondent

A greements with Lo cal A utho rities (267.36)

Hours and Costs per Respondent To

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr
89 

EXH 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 inspections 0.00 0.00 0.50 0.00 0.50 $19.28 $0.00 

Review emergency reports 0.00 0.00 1.00 0.00 1.00 $38.56 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responden

C o ntingency P lan and Emergency R epo rting (267.51-54, 267.55, & 267.58)

Hours and Costs per Respondent To

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

EXH 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 inspections 0.00 0.00 2.00 0.00 2.00 $77.12 $0.00 

Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responden

R eco rd keeping (267.71)

Hours and Costs per Respondent To

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr
90 

EXH IB IT 16STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTCLOSUREReview all closure plans, closure plan amendment notifications, partial/final closure notifications, and closure certifications 0.00 0.00 15.00 0.00 15.00 $578.40 $0.00 

Review the closure plan amendment notifications 0.00 0.00 2.00 0.00 2.00 $77.12 $0.00 Review the partial/final closure notifications 0.00 0.00 2.00 0.00 2.00 $77.12 $0.00 Review the closure certifications 0.00 0.00 4.00 0.00 4.00 $154.24 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responde

C lo sure (267.112) 

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr
91 

EXH IB IT 17STANDARDIZED P ERM ITSESTIM ATED ANNUAL AGENCY BURDEN AND COSTFINANCIAL REQUIREM ENTSReview closure cost estimates, demonstrations of financial assurance for closure, and demonstrations of financial assurance for liability 4.00 1.00 16.00 0.00 21.00 $977.44 $0.00 

Enter the information into the RCRIS database 0.00 0.00 0.00 0.25 0.25 $5.86 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

Number o

Responde

F inancial R equirements (267.142, 267.143, 267.147, 267.148, & 267.150)

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

EXH 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 

Review notifications and detailed reports on releases to the environment 0.00 0.00 4.00 0.00 4.00 $154.24 $0.00 Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00 $38.56 $0.00 Review notifications on any releases to the environment 0.00 0.00 0.25 0.00 0.25 $9.64 $0.00 Review documentation submitted to support requests for secondary containment requirement waivers 0.00 0.25 1.00 0.25 1.50 $58.16 $0.00 Review inspection records, if necessary, during on-site inspections 0.00 0.00 1.00 0.00 1.00 $38.56 $0.00 Total Varies Varies Varies Varies Varies Varies Varies 

Hours and Costs per Respondent T

INFORM ATION COLLECTION ACTIVITY

Leg. 

$ 104.18/ H r

M gr. 

$ 84.86/Hr

Tech. 

$ 40.68/Hr

Cler. 

$ 22.73/Hr

Respondent 

Hours/Year

Labor 

Cost/Year

O&M 

Cost/Year

T ank Systems (267.200)C o ntainment B uildings (267.1104 & 267.1106)

Number o

Responde

Use 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 Facility 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